Overview

Assets Under Management: $1.8 billion
Headquarters: TAMPA, FL
High-Net-Worth Clients: 318
Average Client Assets: $4 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles, Pension Consulting, Investment Advisor Selection, Educational Seminars

Fee Structure

Primary Fee Schedule (JAFFE TILCHIN ADV 2A DISCLOSURE BROCHURE)

MinMaxMarginal Fee Rate
$0 and above 2.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $20,000 2.00%
$5 million $100,000 2.00%
$10 million $200,000 2.00%
$50 million $1,000,000 2.00%
$100 million $2,000,000 2.00%

Clients

Number of High-Net-Worth Clients: 318
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 77.33
Average High-Net-Worth Client Assets: $4 million
Total Client Accounts: 4,235
Discretionary Accounts: 4,046
Non-Discretionary Accounts: 189

Regulatory Filings

CRD Number: 143608
Filing ID: 2010089
Last Filing Date: 2025-08-27 16:13:00
Website: https://jaffetilchin.com

Form ADV Documents

Primary Brochure: JAFFE TILCHIN ADV 2A DISCLOSURE BROCHURE (2025-08-27)

View Document Text
Jaffe Tilchin Investment Partners, LLC Also doing business as: J Best Financial Group Jaffe Tilchin Wealth Management Jaffe Tilchin Institutional Consulting Jaffe Tilchin Investment Partners Trent Troncoso Group 15350 N. Florida Avenue Tampa, FL 33613 813-960-2500 www.jaffetilchin.com Disclosure Brochure August 27, 2025 Item 1: Cover Page This brochure provides information about the qualifications and business practices of Jaffe Tilchin Investment Partners, LLC. If you have any questions about the contents of this brochure, please contact us at 813.960-5293. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Jaffe Tilchin Investment Partners, LLC is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information about which you determine to hire or retain an adviser. Additional information about Jaffe Tilchin Investment Partners, LLC is also is available on the SEC’s website at www.adviserinfo.sec.gov. Item 2: Material Changes Jaffe Tilchin Investment Partners, LLC (“Jaffe Tilchin, we, us, our, ours”) has made the following material changes to our disclosure brochures since the last update dated March 27, 2025: • Items 4 and 9 were updated due to recent changes in ownership and management. Currently, our brochure may be requested by contacting our Chief Compliance Officer at 813.963.2500 or Scott@jaffetilchin.com. We will provide you with a new brochure at any time without charge. information about us available via Additional the SEC’s website: is www.adviserinfo.sec.gov. This website also provides information about any persons affiliated with Jaffe Tilchin who are registered as investment adviser representatives (“your advisory representative”) of Jaffe Tilchin. Information on our investment adviser representatives who work with your account can be found in our brochure supplements. Jaffe Tilchin Investment Partners, LLC SEC File Number 801-67720 CRD Number 143608 Item 3: Table of Contents Item 1: Cover Page .................................................................................................................................................. 1 Item 2: Material Changes......................................................................................................................................... 2 Item 3: Table of Contents ....................................................................................................................................... 1 Item 4: Advisory Business ......................................................................................................................................... 2 Item 5: Fees and Compensation ................................................................................................................................. 7 Item 6: Performance- Based Fees and Side- By- Side Management ......................................................................... 11 Item 7: Types of Clients .......................................................................................................................................... 12 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................... 13 Item 9: Disciplinary Information ............................................................................................................................. 21 Item 10: Other Fi nancial Industry Activities and Affiliations ................................................................................. 21 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading............................. 23 Item 12: Brokerage Practices .................................................................................................................................... 24 Item 13: Review of Accounts .................................................................................................................................. 26 Item 14: Client Referrals and Other Compensation ................................................................................................ 27 Item 15: Custody .................................................................................................................................................... 28 Item 16: Investment Discretion .............................................................................................................................. 29 Item 17: Voting Client Securities ............................................................................................................................. 30 Item 18: Fina ncial Information ............................................................................................................................... 30 Item 4: Advisory Business Jaffe Tilchin Investment Partners is a Limited Liability Company organized under the laws of Florida. Scott Jaffe & Louis Tilchin founded the Tampa-based investment advisory firm in 2007. Giancarlo (John) Troncoso, Scott Jaffe & Louis Tilchin are the principal owners. Jaffe Tilchin Investment Partners is a member of the Jaffe Tilchin Wealth Management family of companies. Jaffe Tilchin Investment Partners provides investment advisory services to both retail and institutional clients. Jaffe Tilchin Investment Partners also operates under the business names of J Best Advisory Group, Jaffe Tilchin Institutional Consulting, Jaffe Tilchin Wealth Management, Jaffe Tilchin Investment Partners, and Trent Troncoso Group. Asset Management for Retail Clients We provide continuous advice and portfolio management based on the goals, time horizon, and risk tolerance of each client. We create an investment plan for each client, which outlines the client’s current situation and then constructs a portfolio that matches each client’s specific situation and goals. Services include financial planning, investment strategy, asset allocation and selection, risk tolerance, personalized investment policy, and regular portfolio monitoring. We evaluate the current investments of each client with respect to their risk tolerance and time horizon. We will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. However, you may select non-discretionary management, in which we will request permission prior to selecting securities and executing transactions. We may recommend one or more of the model managed portfolios of which it directly manages. We manage these accounts on a continuous basis. You are advised that your account may be similar to multiple other clients selecting the same model portfolio. We provide assistance in selecting a model(s) suitable to your investment strategy. You grant discretionary authorization for us to buy and sell securities as deemed appropriate by us. You may contact us at any time to discuss your account. Unaffiliated Asset Managers We may contract with third party, unaffiliated asset managers to manage all or part of your portfolio. These third-party investment managers may manage accounts or private investment funds or vehicles for qualified investors. We will use the information you 2 have provided about your investment objectives, goals, time horizon, and risk tolerances, as well as other relevant information, to identify a third-party investment manager(s) whose investment strategies or investment vehicles appear appropriate for you. Some of the other relevant information considered in recommending a third-party asset manager include (but are not limited to): • Your preference for certain types of investment strategies; The size and composition of your investment account; • Your tax considerations; • Our prior experience with and preferences for particular investment managers; The fees charged by the investment manager; and • The experience and capabilities of the investment manager. We contact you at least annually or more often as we agree to review your financial situation and objectives, communicate information to the third-party manager managing the account or investment vehicle as warranted, and to assist you in understanding and evaluating the services provided by the third-party manager. Private Placement Due Diligence: When suitable for clients, typically accredited investors, qualified clients, and/or qualified purchasers (as those terms are defined by the Securities and Exchange Commission) with limited liquidity needs only, we may recommend and assist clients in making investments in private funds. Any private investments will be conducted exclusively via private funds offered and overseen by a reputable manager with recognizable institutional expertise in the targeted investment area. These funds are chosen when we believe they may offer some combination of: • exposure to assets or investment strategies that may be uncorrelated, or less correlated, to the broad publicly traded equity and debt markets • attractive sources of return from the assets or trading strategy that may be otherwise inaccessible or heavily constrained when offered in public investment vehicles To evaluate the relative attractiveness between private investments and publicly-traded alternatives after considering the added risk factors and implementation issues inherent in private investments, we will typically complete some or all of the following analysis before making any initial investment recommendation, and during the ongoing period that we hold exposure to that investment: 3 • Initial and ongoing due diligence of the manager and the investment offering that may include: ▪ Review of fund subscription materials, audited financials, historical tax reporting samples, historical investment commentary and other reporting furnished by fund manager or sponsor ▪ In-person or remote attendance at fund manager or sponsor update calls, webinars, or meetings ▪ Fund performance reviews: monthly, quarterly, semi-annual, or annual • Coordinating tax document delivery and ongoing tax planning related to the fund with client CPAs to monitor any unique income character and ancillary filing requirements resulting from the private structure itself or the underlying investment activity • Evaluation and integration of applicable fund liquidity opportunities within the context of, but not limited to, client goals, objectives, tax situation, need for liquidity, and estate planning • Non-discretionary management and handling of all intervening private fund cash flows – including but not limited to - initial commitments, ongoing capital calls, income/capital distributions, voluntary/involuntary redemption activity, sequential commitment structuring, target illiquidity maintenance at the portfolio level • Awareness and integration of any unique return/risk attributes for each individual fund and the private fund commitment as a whole with the consolidated portfolio construction and expected interaction between other client investments • Ongoing performance/valuation reporting maintenance for all individual private investments and the private fund commitment as a whole – fully integrated into the client’s consolidated performance/risk reporting which covers all public and private investments across the portfolio Pooled Investment Vehicles We are the investment adviser to the 3D Tech Plus, LLC ("3D Tech"), a privately placed investment fund. The General Partner is unrelated to Jaffe Tilchin and pursuant to Regulation D under the Securities Act of 1933, as amended privately offers interests in 3D Tech. 3D Tech currently relies on an exemption from registration under the Investment Company Act of 1940, as amended. Jaffe Tilchin does not receive any compensation (outside of its management and performance fee as set forth in Item 5). While 3D Tech is Jaffe Tilchin’s client, the term “client(s)” sometimes refers to the partners in 3D Tech. Participation as a partner in the 3D Tech LP is restricted to investors who are “qualified clients” pursuant to Rule 205-3 under the Advisers Act, as 4 well as those who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, and “qualified purchasers” as defined under the Investment Company Act of 1940, as amended. Not all Jaffe Tilchin clients will or are eligible to invest in 3D Tech and not all 3D Tech investors are Jaffe Tilchin clients. To the extent clients qualify and it meets their specific investment needs, Jaffe Tilchin may direct a portion of the account towards an investment in 3D Tech. An investment in 3D Tech as a limited partner involves a significant degree of risk, up to and including the full loss of any amount paid for any 3D Tech interest. The Confidential Private Offering Memorandum, Investor Agreement, and Subscription Agreement (together, the “Offering Documents”) details the relevant information, terms and conditions relative to 3D Tech. This information includes but is not limited to suitability, limited rights of redemption, risk factors such as limited liquidity (e.g., monthly), high leverage (i.e., the use of borrowed funds or discounted future liabilities), and potential conflicts of interest. Each investor is required to receive and/or execute prior the appropriate sections of the Offering Documents prior to admission as an investor in 3D Tech. For additional information regarding the 3D Tech, please refer to the Offering Documents. 3D Tech is an actively managed, opportunistic investment program seeking to optimize various volatility and/or arbitrage trading strategies. 3D Tech may also seek to exploit relative levels of implied volatility within a given security, between two securities, or between a security or group of securities and an index. 3D Tech’s net exposures may leave accounts exposed to equity market moves and/or changes in the overall level of equity market actual/implied volatility. In addition, leverage or the use of 3D Tech assets as collateral imposes certain incremental risks as stated in the sections entitled “Funding Risk”, Hard to Borrow Risk, Traditional Margin and Portfolio (Risk Based) Margin Risk. For more information on the 3D Tech, please refer to 3D Tech Strategy in Item 8 below. Wrap Fee Program While no longer offered to new clients, some of our legacy clients are engaged under our Wrap Fee Program. Please see our Wrap Fee Brochure for details. Financial Planning Services For certain clients, we prepare and provide you with a comprehensive, written financial plan designed to help you achieve your financial goals and investment objectives. The preparation of such a plan requires that you provide us with personal data such as family records, employment records, budgeting, assets, liabilities, estate information, and tax information. The financial plan may address any or all of the following as you request and/or direct: 5 • Asset protection • Financial Planning • Tax planning • Estate planning • Education planning • Retirement analysis Cash • Flow Charitable gifting Should you choose to implement the recommendations contained in your financial plan, we encourage you to work closely with your attorney, accountant, insurance agent, and other advisers. We will assist you to the extent you choose. Although you may choose to implement the recommendations made in your financial plan through us, you are free to employ the services of any advisor or registered representative of your choice, regardless of whether or not that person is associated with Jaffe Tilchin. General Institutional Consulting We serve as investment consultant for 401(k) plans, 403(b) plans, Defined Contribution Plans, Defined Benefit Plans, Cash Management Accounts, Non-Qualified Deferred Comp Plans, Endowments and Foundations, providing the following services for benefit of participants and their beneficiaries: plan needs assessment, investment policy statement review or creation recommendation of investment options, monitoring investment performance, periodic fee review, coordination of investment committee services, facilitation of provider selection, and plan design. Needs and Restrictions In managing your investment portfolio, we consider your: financial situation, financial situation, risk tolerance, investment horizon, liquidity needs, 6 tax considerations, investment objectives, and any other issues important to your state of affairs. You should notify us promptly of any changes in your financial situation or investment objectives or if you wish to impose any reasonable restrictions upon the management of your account. Assets under Management As of December 31, 2024, through both our institutional and retail asset management services, we managed approximately $1,738,576,700 in client assets on a discretionary basis where we made all of the investment decisions. We managed approximately $101,072,000 on a non-discretionary basis where clients made investment decisions based on our recommendations. Item 5: Fees and Compensation Jaffe Tilchin Asset Management Fees for Retail Clients You will pay our firm an annual asset-based management fee for our portfolio management services. The fee is calculated as a percentage of the market value of your assets, including the value of any actively managed cash balances, as such value is determined by the custodian of your account. The maximum asset management fee you will be charged annually is 2.00% of assets under management, which number is inclusive of any independent manager’s fees. Our asset-based fees are pro-rated for partial billing periods based on the number of days services are provided to you relative to the total number of days in the partial period. While some of our legacy clients participate in our wrap fee program, as outlines in our Wrap Fee Brochure, we no longer offer this program to new clients. 3D Tech Plus, LLC For our services as investment adviser to 3D Tech Plus, LLC, we charge 200 basis points or 2%per annum of the value of 3D Tech’s assets on the last day of the month. We may earn a performance fee that permits the general partner of 3D Tech to pay up to fifteen percent (15%) of the fund’s highest incremental net asset value or Net New High. The Offering Documents describe this calculation. Please refer to the Offering Documents for a more complete discussion of the fee for 3D Tech. For Jaffe Tilchin 7 clients, we exclude the value of any assets invested in 3D Tech when calculating our management fee. Unaffiliated Asset Managers Fees Fees are dependent upon the third party manager who may require a minimum investment. Their fees may or may not be negotiable. We typically receive your fee directly from the custodian of your assets. The fee we receive from the custodian generally has already had the third party manager fee deducted; if it has not the third party manager then receives their fee from us. A complete description of: the programs and services provided, the amount of total fees, the payment structure including, but not limited to, whether the fees are billed in arrears or advance and how fees are calculated, termination provisions, and other aspects of each program are detailed and disclosed in the unaffiliated asset manager’s brochure; wrap brochure (if available) or other applicable disclosure documents; and the unaffiliated asset managers’ account opening documents. A copy of all relevant disclosure documents of the unaffiliated asset manager and of the individual portfolio manager(s) are provided to anyone interested in these programs or managers. In addition to paying investment management fees, private funds or investment vehicles are subject to other investment expenses such as custodial charges, brokerage fees, commissions, and administrator costs plus expenses including, but not limited to, sales expenses, legal expenses, internal and external accounting, audit and tax preparation expenses; and organizational expenses. Private fund fees and expenses are passed on to the fund investors. To invest in private funds, the receipt and completion of special documents is required and all additional expenses are delineated in these. Fees for Financial Planning Services Fees for financial planning services are charged on a fixed-fee basis. The amount you will be charged will be negotiated between you and Jaffe Tilchin. Generally, the amount of our fees will depend upon the complexity of the services you need. Fixed fees may range from $1,000 to $40,000 per plan. We will provide you with an estimate of the cost 8 of the services to be provided to you prior to beginning the financial planning process. Fixed fees are payable upon completion of the services outlined in the executed financial planning agreement. Alternatively, you may elect pay this fee on a quarterly basis. Under this arrangement, one-quarter (1/4) of the fee will be due upon execution of our financial planning agreement and one-quarter (1/4) of the fee will be billed quarterly in advance thereafter until either the fee is paid in full or we have provided all of the services we agreed to provide to you. In that case, the balance of the fee will be due in its entirety. The Financial Planning Agreement may be terminated upon written notice by either party. Unearned fees paid in advance will be refunded pro rata, based on the work completed. Fees for General Institutional Consulting: Our fee schedule is described below: Plan Asset Balance Annual Fee1 Up to $5,000,000 $5,000,001 to $15,000,000 $15,000,001 to $30,000,000 $30,000,001 to $60,000,000 $60,000,001 to $100,000,000 1.00% 0.75% 0.65% 0.50% 0.45% 1Fees are negotiable at our sole discretion. In addition to our consulting fee, you may be required to pay other charges such as: custodial fees, brokerage commissions, transaction fees, SEC fees, internal fees and expenses charged by mutual funds or exchange traded funds (“ETFs”), and variable annuities, and other fees and taxes on brokerage accounts and securities transactions. We do not participate in or benefit from these charges. Mutual fund companies, ETFs, and variable annuity issuers charge internal fees and expenses for their products. These fees and expenses are in addition to any advisory fees charged by us. Complete details of these internal fees and expenses are explained in the 9 prospectuses for each investment. You are strongly encouraged to read these explanations before investing any money. You may ask us any questions you have about fees and expenses. If you purchase mutual funds through the custodian/broker-dealer, you may pay a transaction fee that would not be charged if the transactions were made directly through the mutual fund company. Also, mutual funds held in accounts at brokerage firms may pay internal fees that are different from funds held at the mutual fund company. While you may purchase shares of mutual funds directly from the mutual fund company without a transaction fee, those investments would not be part of our advisory relationship with you. This means that they would not be included in our investment strategies, investment performance monitoring, or portfolio reallocations. Variable annuity investments can also carry large internal fees, which are in addition to the advisory fee we charge. No advisory fees are charged on any mutual funds or unit investment trusts transferred into your account which were purchased within the preceding two years if a commission was paid to your advisory representative as a representative of a broker-dealer. With respect to certain of our clients who maintain margin accounts under our management, please be advised that upon negotiation, our percentage of assets fee may be billed on your total account balances, that is the total of debit and credit balances, not your net balance. This creates a conflict of interest inasmuch as taking on more risk in your account (increasing your leverage) will serve to increase our fee. This may incentive us to take on more risk in your margin account in order to increase our fee. Please be sure to read the section entitled “Brokerage Practices,” which follows later in this brochure. All advisory fees are billed quarterly, in advance as contractually agreed upon. Advisory fees are based upon market value of the plan assets on the last business day of the preceding calendar quarter. If you agree to pay our investment advisory fees in advance and you terminate the advisory agreement we have entered into within five (5) business days from the date the agreement is executed, you will receive a full refund of any fees paid. Should either one of us terminate the advisory agreement before the end of a billing period, any unearned fees that were deducted from your account will be returned to you by us. 10 The amount refunded to you is calculated by dividing the most recent advisory fee you paid by the total number of days in the quarter. This daily fee is then multiplied by the number of calendar days in the quarter that our agreement was in effect. This amount, which equals the amount we earned for the partial quarter, is subtracted from the total fee you paid in advance to determine your refund. We may also refer you to various asset management firms. Referral fees or a portion of the advisory fee will be paid to us if you establish a relationship with the asset manager. The above arrangements present a conflict of interest because they create an incentive to make recommendations based upon the amount of compensation we receive rather than based upon your needs. We will explain the specific costs associated with any recommended investments with you upon request. We also recommend no-load and load-waived mutual funds to further reduce conflicts of interest. Additionally, you have the option to purchase investment and insurance products through other brokers or agents who are not affiliated with us. Our investment adviser representatives are also registered representatives of various registered broker-dealers (members FINRA/SIPC). They are also licensed with various insurance companies. They may earn commissions if investment or insurance products are purchased through them in those capacities. This does not apply within the context of a consulting relationship. Item 6: Performance-Based Fees and Side-By-Side Management As we disclosed in Item 5 of this Brochure, private fund clients are charged two types of fees. These fees consist of a quarterly management fee, discussed under Item 4 above, and an annual performance fee. The performance fee is a percentage based upon the increase in the market value of the investment account at the end of the calendar year compared to the highest ending account balance at the end of any previous calendar year, in accordance with the terms contained in the Fund’s Offering Documents. Each year's performance fee, if any, is paid by the Fund based upon the performance results as of December 31 of that year. Performance fees paid will be in compliance with Rule 205-3 of the Investment Advisers Act of 1940. In cases where the same security may be owned by both individual accounts and the 11 Fund (i.e., side-by-side management), a conflict of interest may exist in regards to the allocation of securities. To avoid this conflict, we either allocate the entire trade across all accounts so that each client, including the Fund, receive the same price and commission per share (see Item 12 regarding Brokerage Practices) or we enter and allocate all client trades prior to placing trades in the Fund. We use reasonable efforts to ensure that the Fund does not receive preferential treatment over other client accounts. Clients should be aware that this type of fee arrangement may create an incentive for us to make more speculative investments for such clients or increase our focus on short-term profits, rather than focusing on long-term capital appreciation, which could expose such clients to additional levels of risk than would exist if such a fee structure were not in place. Item 7: Types of Clients We offer professional asset management services to individuals, trusts, estates, charitable organizations, corporations and pension plans. As a condition for starting and maintaining an advisory relationship. We, at our sole discretion, may accept clients with smaller portfolios based upon certain factors including: anticipated future earning, capacity, anticipated future, additional assets, account composition, related accounts, and pre-existing client relationships. We do not have an account minimum. 3D Tech Plus, LLC required investors to invest a minimum of $50,000, which the General Partners may waive. We do not control this decision. We may contract with third party, unaffiliated asset managers to manage all or part of your portfolio. These third-party managers may have their own minimum size requirements that will be outlined in their disclosure documents. Investors in private funds or investment vehicles are required to own or have a specified amount of assets and/or net worth. The completion of special documents are required prior to investing; minimum account sizes are specified. 12 We offer consulting services to 401(k), 403(b), Defined Contribution Plans, Defined Benefit Plans, Cash Management Accounts, Non-Qualified Deferred Comp Plans, Endowments and Foundations. There are no conditions for starting and maintaining an advisory relationship. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis The Firm may use the following methods when considering investment strategies and recommendations. Charting Review Charting is a technical analysis that charts the patterns of stocks, bonds, and commodities to help determine buy and sell recommendations for clients. It is a way of gathering and processing price and volume information in a security by applying mathematical equations and plotting the resulting data onto graphs in order to predict future price movements. A graphical historical record assists the analyst in spotting the effect of key events on a security’s price, its performance over a period of time, and whether it is trading near its high, near its low or in between. Chartists believe that recurring patterns of trading, commonly referred to as indicators, can help them forecast future price movements. Fundamental Review A fundamental analysis is a method of evaluating a company or security by attempting to measure its intrinsic value. Fundamental analysis attempts to determine the true value of a company or security by looking at all aspects of the company or security, including both tangible factors (e.g., machinery, buildings, land, etc.) and intangible factors (e.g., patents, trademarks, “brand” names, etc.). Fundamental analysis also involves examining related economic factors (e.g., overall economy and industry conditions, etc.), financial factors (e.g., company debt, interest rates, management salaries and bonuses, etc.), qualitative factors (e.g., management expertise, industry cycles, labor relations, etc.), and quantitative factors (e.g., debt-to-equity and price-to- equity ratios). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price with the aim of determining what sort of position to take with that security (e.g., if underpriced, the security should be bought; 13 if overpriced the security should sold). Fundamental analysis uses real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for many types of securities. Technical Review A technical analysis is a method of evaluating securities that analyzes statistics generated by market activity, such as past prices and volume. Technical analysis does not attempt to measure a security's intrinsic value, but instead uses past market data and statistical tools to identify patterns that can suggest future activity. Historical performance of securities and the markets can indicate future performance. Cyclical Review A cyclical analysis assumes the market reacts in reoccurring patterns that can be identified and leveraged to provide performance. Cyclical analysis of economic cycles is used to determine how these reoccurring patterns, or cycles, affect the returns of a given investment, asset, or company. Cyclical analysis is a time-based assessment which incorporates past and present performance to determine future value. Cyclical analyses exist because the broad economy has been shown to move in cycles, from periods of peak performance to periods of low performance. The risks of this strategy are two- fold: (1) the markets do not always repeat cyclical patterns; and (2) if too many investors begin to implement this strategy, it changes the very cycles of which they are trying to take advantage. Economic Review An economic analysis determines the economic environment over a certain time horizon. This involves following and updating historic economic data such as U.S. gross domestic product and consumer price index as well as monitoring key economic drivers such as employment, inflation, and money supply for the world’s major economies. 3D Tech Jaffe Tilchin's 3D Tech Strategy ("3D Tech") is an actively managed, opportunistic investment program seeking to optimize various volatility or other arbitrage style trading strategies and periodically employs other tactical trading strategies (e.g. dividend capture, merger arbitrage, etc.). 3D Tech seeks to exploit relative levels of implied/realized volatility within a given security, between two securities, or between a security or group of securities and an index. 3D Tech net exposures may leave accounts exposed to equity market moves and changes in the overall level of equity 14 market volatility. 3D Tech attempts to reduce the impacts to the strategy from changes in the overall level of equity market volatility. Dynamic hedges and risk-defined option trade structures reduce the directional risk of extreme market moving events. 3D Tech is typically appropriate for investors seeking additional sources of return that are unrelated to equity market valuations with higher levels of account variation than a fully hedged options’ portfolio. 3D Tech seeks to achieve its investment objective by utilizing various trading techniques with a portfolio of long and/or short options, common stocks, fixed income securities, commodities, exchange traded funds (“ETFs”), index related instruments, customized baskets of securities, and short- term instruments. 3D Tech principally involves trading options based on market changes in the implied volatility of each contract. The market price of an option is partially based on the expected volatility, or potential variation in price over time, of its underlying asset. By analyzing the implied/forecasted volatilities of a security and comparing them to the implied/forecasted volatilities of a historically correlated security, the traders attempt to identify situations where an option on one security is believed to be relatively undervalued and an option on the other security is believed to be relatively overvalued. In selecting the options that 3D Tech will trade, the traders first identify exchange- traded options with a trading volume sufficient to preclude 3D Tech’s trades from influencing prices. The traders next evaluate the available investment opportunities and uses a proprietary trading algorithm to assist them in determining when to buy and sell options. The traders may also create hedges, primarily utilizing options, common stocks, futures and ETFs, in an attempt to offset the risk of extreme price movements in the securities underlying the traded options. Such price movements affect the ability of the traders to implement successfully 3D Tech’s investment strategy. 3D Tech seeks to maintain exposure levels that may or may not be neutral to market movements and volatility levels. Jaffe Tilchin may allocate a portion of client capital to short-term, investment grade fixed income instruments, including United States Treasury Bills, money-market instruments, money-market mutual funds and/or Jaffe Tilchin’s Yield Hawk (described below). when they believe the options’ markets offer limited investment opportunities. 3D Tech may hold short-term instruments for an extended period while waiting for other attractive investment opportunities. Our fee for 3D Tech investment management services ranges is 200 basis points plus a potential performance fee of up to 15% of the account’s profit. The account’s profit means the net financial benefit to the client from the trading in the account for the 15 given period, subject to a lifetime high water mark. Only “Qualified Clients” may be charged performance-based fees. B. Investment Strategies When implementing investment advice to clients, the Firm may employ a variety of strategies to best pursue the objects of clients. Depending on market trends and conditions, Fiduciary Architects will employee any technique or strategy herein described, at the Firm’s discretion and in the best interests of the client. The Firm does not recommend any particular security or type of security. Instead, the Firm makes recommendations to meet a particular client’s financial objectives. There is inherent risk to any investment and clients may suffer loss of ALL OR PART of a principal investment. Long-Term Purchases Long-term purchases are securities that are purchased with the expectation that the value of those securities will grow over a relatively long period, generally greater than one year. Long-term purchases may be affected by unforeseen changes in the company in which a client is invested or in the overall market. Long term trading is designed to capture market rates of both return and risk. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Due to its nature, the long-term strategy can expose clients to various other types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include, but are not limited to, inflation (purchasing power) risk, interest rate risk, economic risk, and political/regulatory risk. Short-Term Purchases Short-term purchases are securities that are purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short-term price fluctuations. Short-term trading generally holds greater risk. Frequent trading can affect investment performance due to increased brokerage fees and other transaction costs and taxes. Strategic Asset Allocation Asset allocation is a combination of several different types of investments; typically, this includes stocks, bonds, and cash equivalents among various asset classes to achieve diversification. The objective of asset allocation is to manage risk and market exposure while still positioning a portfolio to meet financial objectives. 16 C. Risk of Loss Investing inherently involves risk up to and including loss of the principal sum. Further, past performance of any security is not necessarily indicative of future results. Therefore, future performance of any specific investment or investment strategy based on past performance should not be assumed as a guarantee. Fiduciary Architects does not provide any representation or guarantee that the financial goals of clients will be achieved. The potential return or gain and potential risk or loss of an investment varies, generally speaking, with the type of product invested in. Below is an overview of the types of products available on the market and the associated risks of each: General Risks. Investing in securities always involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives can or will be met. Past performance is in no way an indication of future performance. We also cannot assure that third parties will satisfy their obligations in a timely manner or perform as expected or marketed. General Market Risk. Investment returns will fluctuate based upon changes in the value of the portfolio securities. Certain securities held may be worth less than the price originally paid for them, or less than they were worth at an earlier time. Common Stocks. Investments in common stocks, both directly and indirectly through investment in shares of ETFs, may fluctuate in value in response to many factors, including, but not limited to, the activities of the individual companies, general market and economic conditions, interest rates, and specific industry changes. Such price fluctuations subject certain strategies to potential losses. During temporary or extended bear markets, the value of common stocks will decline, which could also result in losses for each strategy. Portfolio Turnover Risk. High rates of portfolio turnover could lower performance of an investment strategy due to increased costs and may result in the realization of capital gains. If an investment strategy realizes capital gains when it sells its portfolio investments, it will increase taxable distributions to you. High rates of portfolio turnover in a given year would likely result in short-term capital gains and under current tax law you would be taxed on short-term capital gains at ordinary income tax rates, if 17 held in a taxable account. Non-Diversified Strategy Risk. Some investment strategies may be non-diversified (e.g., investing a greater percentage of portfolio assets in a particular issuer and owning fewer securities than a diversified strategy). Accordingly, each such strategy is subject to the risk that a large loss in an individual issuer will cause a greater loss than it would if the strategy held a larger number of securities or smaller positions sizes. Model Risk. Financial and economic data series are subject to regime shifts, meaning past information may lack value under future market conditions. Models are based upon assumptions that may prove invalid or incorrect under many market environments. We may use certain model outputs to help identify market opportunities and/or to make certain asset allocation decisions. There is no guarantee any model will work under all market conditions. For this reason, we include model related results as part of our investment decision process but we often weigh professional judgment more heavily in making trades or asset allocations. ETF Risks, including Net Asset Valuations and Tracking Error. An ETF's performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depository Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. Clients should be aware that to the extent they invest in ETF securities they will pay two levels of advisory compensation – advisory fees charged by Fiduciary Architects plus any advisory fees charged by the issuer of the ETF. This scenario may cause a higher advisory cost (and potentially lower investment returns) than if a Client purchased the ETF directly. An ETF typically includes embedded expenses that may reduce the ETF's net asset value, and therefore directly affect the ETF's performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. Expenses of the ETF may include investment advisor management fees, 18 custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. Inflation, Currency, and Interest Rate Risks. Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. In addition, the relative value of the U.S. dollar-denominated assets primarily managed by Fiduciary Architects may be affected by the risk that currency devaluations affect Client purchasing power. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash to prevent a loss, realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally, investments are more liquid if the investment has an established market of purchasers and sellers, such as a stock or bond listed on a national securities exchange. Conversely, investments that do not have an established market of purchasers and sellers may be considered illiquid. Your investment in illiquid investments may be for an indefinite time, because of the lack of purchasers willing to convert your investment to cash or other assets. Legislative and Tax Risk. Performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to: changes in investment advisor or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities; and changes in the tax code that could affect interest income, income characterization and/or tax reporting obligations, particularly for options, swaps, master limited partnerships, Real Estate Investment Trust, Exchange Traded Products/Funds/Securities. We do not engage in tax planning, and in certain circumstances a Client may incur taxable income on their investments without a cash distribution to pay the tax due. Clients and their personal tax advisors are responsible for how the transactions in their account are reported to the IRS or any other taxing authority. Foreign Investing and Emerging Markets Risk. Foreign investing involves risks not typically associated with U.S. investments, and the risks maybe exacerbated further in emerging market countries. These risks may include, among others, adverse fluctuations in foreign currency values, as well as adverse political, social, and economic developments affecting one or more foreign countries. 19 In addition, foreign investing may involve less publicly available information and more volatile or less liquid securities markets, particularly in markets that trade a small number of securities, have unstable governments, or involve limited industry. Investments in foreign countries could be affected by factors not present in the U.S., such as restrictions on receiving the investment proceeds from a foreign country, foreign tax laws or tax withholding requirements, unique trade clearance or settlement procedures, and potential difficulties in enforcing contractual obligations or other legal rules that jeopardize shareholder protection. Foreign accounting may be less transparent than U.S. accounting practices and foreign regulation may be inadequate or irregular. Information Security Risk. We may be susceptible to risks to the confidentiality and security of its operations and proprietary and customer information. Information risks, including theft or corruption of electronically stored data, denial of service attacks on our website or websites of our third-party service providers, and the unauthorized release of confidential information are a few of the more common risks faced by us and other investment advisers. Data security breaches of our electronic data infrastructure could have the effect of disrupting our operations and compromising our customers' confidential and personally identifiable information. Such breaches could result in an inability of us to conduct business, potential losses, including identity theft and theft of investment funds from customers, and other adverse consequences to customers. We have taken and will continue to take steps to detect and limit the risks associated with these threats. Tax Risks. Tax laws and regulations applicable to an account with Fiduciary Architects may be subject to change and unanticipated tax liabilities may be incurred by an investor as a result of such changes. In addition, customers may experience adverse tax consequences from the early assignment of options purchased for a customer's account. Customers should consult their own tax advisers and counsel to determine the potential tax-related consequences of investing. Advisory Risk. There is no guarantee that our judgment or investment decisions on behalf of particular any account will necessarily produce the intended results. Our judgment may prove to be incorrect, and an account might not achieve her investment objectives. In addition, it is possible that we may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to accounts’ custodians’ software. Fiduciary Architects and its representatives are not responsible to any account for losses unless caused by Fiduciary Architects breaching our fiduciary duty. 20 Dependence on Key Employees. An accounts success depends, in part, upon the ability of our key professionals to achieve the targeted investment goals. The loss of any of these key personnel could adversely impact the ability to achieve such investment goals and objectives of the account. Item 9: Disciplinary Information Jaffe Tilchin has not been the subject of any civil, criminal or regulatory action or disciplinary event that would be material to your evaluation of our business or the integrity of our management. Lou Tilchin has previously been named in customer complaints which were settled. These are more fully described in the supplements to this brochure. Additional information is available at https://brokercheck.finra.org. Item 10: Other Financial Industry Activities and Affiliations In addition to their position with Jaffe Tilchin, your advisory representative may also be a registered representative of various registered broker-dealers (members FINRA/SIPC). You are under no obligation to purchase or sell securities through your advisory representative in conjunction with their association with these broker- dealers. If you do so, however, they may earn compensation in the form of commissions or investment advisory fees. Jaffe Tilchin Investment Partners, LLC is affiliated with Jaffe Tilchin Wealth Management, because Jaffe Tilchin Wealth Management owns Jaffe Tilchin Investment Partners, LLC. Jaffe Tilchin Wealth Management is an insurance agency and offers commissionable insurance products. Jaffe Tilchin Wealth Management also owns RCR Financial which offers commissionable insurance products. Certain advisory representatives are also licensed as insurance agents. You are under no obligation to purchase insurance products from Jaffe Tilchin Wealth Management, RCR Financial, or any advisory representative. If you choose to purchase insurance, these firms and individuals will receive commissions in addition to the advisory fees you pay to us. As noted above, when appropriate, we provide individualized advisory services to you through the recommendation of suitable third-party investment advisers. Because the compensation we receive may vary depending upon the adviser selected, we may have 21 a conflict of interest in recommending certain advisers to you. To address this potential conflict we consider the following factors in the selection of a third-party adviser which include, but may not be limited to: the management style, performance, reputation, pricing and reporting capabilities of the third-party investment adviser; your risk tolerance, goals and objectives, as well as investment experience; the amount of assets you have available for investment; and our familiarity with and preference for a particular adviser. You are under no obligation to follow our recommendations. Private Funds As previously disclosed in Item 5, we provide investment management services to the Fund and in such capacity receives a management fee and a performance-based fee. Clients should be aware that the receipt of additional compensation by us and our management persons or employees may create a conflict of interest that could impair the objectivity of our firm and our employees when making advisory recommendations. We endeavor, at all times, to put the interest of our clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps to address this potential conflict of interest: • we include disclosure in our brochure regarding the existence of all material conflicts of interest, including the potential for our firm and our employees to earn additional • compensation from advisory clients apart from our firm's advisory fees; • we disclose to clients that they are not obligated to purchase recommended investment products from our employees or affiliated companies; • we collect, maintain and document accurate, complete and relevant client background • information, including the client’s financial goals, objectives and risk tolerance; • our firm's management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances; • we require that our employees seek prior approval of any outside business activity so that we may ensure that any conflicts of interests in such activities are properly addressed; and • we periodically monitor these outside business activities to verify that any conflicts of interest continue to be properly addressed by our firm. 22 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading We have adopted a Code of Ethics (“Code”) to address the securities-related conduct of our advisory representatives and employees. The Code includes our policies and procedures developed to protect your interests in relation to the following: the duty at all times to place your interests ahead of ours; that all personal securities transactions of our advisory representatives and employees be conducted in a manner consistent with the Code and avoid any actual or potential conflict of interest, or any abuse of an advisory representative’s or employee’s position of trust and responsibility; that advisory representatives may not take inappropriate advantage of their positions; that information concerning the identity of your security holdings and financial circumstances are confidential; and that independence in the investment decision-making process is paramount. We will provide a copy of the Code to you or any prospective client upon request. We do not buy or sell securities for our firm that we also recommend to clients. Our advisory representatives and employees are permitted to buy or sell the same securities for their personal and family accounts that are bought or sold for your account(s). The personal securities transactions by advisory representatives and employees may raise potential conflicts of interest when they trade in a security that is owned by you or considered for purchase or sale for you. We may purchase for clients or recommend that clients invest in the 3D Tech, LLC Fund. We act as the investment adviser to the Fund and Associated Persons of our Firm may also have made investments in the Fund and therefore have an incentive to purchase or recommend the Fund for/to clients. We will not include the value of any investments in the Fund when calculating our investment management fees for separately managed accounts. We have adopted policies and procedures that are intended to address these conflicts of interest. These policies and procedures: require our advisory representatives and employees to act in your best interest, 23 prohibit favoring one client over another, and provide for the review of transactions to discover and correct any same-day trades that result in an advisory representative or employee receiving a better price than a client. Advisory representatives and employees must follow our procedures when purchasing or selling the same securities purchased or sold for you. Item 12: Brokerage Practices We will generally recommend Fidelity Brokerage Services, LLC (“Fidelity”), Charles Schwab & Co., Inc.., and/or Raymon James Financial Services, Inc, (collectively or separately, “Custodian”) to you for custody and brokerage services although we may agree to employ the services of one or more other custodians. We are independently owned and operated and not affiliated with the Custodian we recommend. Our use of the Custodian is, however, a beneficial business arrangement for us and for the Custodian. Information regarding the benefits of this relationship is described below. Our recommendation of a specific custodian is based in part on our existing relationships; the custodian’s financial strength; reputation; breadth of investment products; and, the cost and quality of custody and brokerage services provided to you and our other clients. The determining factor in the selection of the Custodian to execute transactions for your accounts is not the lowest possible transaction cost, but whether the Custodian can provide what is in our view the best qualitative execution for your account. In addition to brokerage and custody services, services customarily made available to advisers include access to investments generally available to institutional investors; research; software; and, educational opportunities. Custodians may also make available or arrange for these types of services to be provided to us by independent third parties. Custodians may discount or waive the fees they would otherwise charge for some of the services they make available to us. They may also pay all or a part of the fees of a third party providing these services to us. We receive economic benefits as a result of our relationship with the custodians because we do not have to produce or purchase the products and services listed above. These services are not contingent upon us committing any specific amount of business to the 24 custodians in trading commissions. We do not enter into soft-dollar arrangements with custodians or brokers. Because the amount of our compensation or the products or services we receive may vary depending on the custodian/broker-dealer we recommend to be used by our clients, we may have a conflict of interest in making that recommendation. Our recommendation of specific custodian/broker-dealers may be based in part on the economic benefit to us and not solely on the nature, cost or quality of custody and brokerage services provided to you and our other clients. We nonetheless strive to act in your best interests at all times. The custodians do not charge separately for holding our client accounts but may be compensated by you through other transaction-related fees associated with the securities transactions they execute for your account. Commissions and other fees for transactions executed through the Custodian may be higher than commissions and other fees available if you use another custodian/broker- dealer firm to execute transactions and maintain custody of your account. We believe, however, that the overall level of services and support provided to our clients by the Custodian outweighs the benefit of possibly lower transactions cost which may be available under other brokerage arrangements. Many of the services described above may be used to benefit all or a substantial number of our accounts, including accounts not maintained at the Custodian. We do not attempt to allocate these benefits to specific clients. Third party asset managers may require the use of certain custodians. Please refer to the Brokerage Practices sections of their respective brochures for more information. We may also receive economic and non-economic benefit from third-party asset managers we utilize in the form of the support products and services it makes available to use, such as research, technology or administrative support. The availability of these products and services are not based upon us giving particular investment advice, such as buying particular securities for our clients. The total advisory fee the client pays will not be higher because we accept these benefits. Directed Custodian We do not accept directed brokerage. You may choose Fidelity, Schwab, or Raymond James as the custodian of your account(s). We will make recommendations in your best interest. Block Trading 25 We may engage in block trading, which is the purchase or sale of a security for the accounts of multiple clients in a single transaction. If a block trade is executed, each participating client receives a price that represents the average of the prices at which all of the transactions in a given block were executed. Executing a blocked trade allows transaction costs to be shared equally and on a pro rata basis among all of the participating clients. If the order is not completely filled, the securities purchased or sold are distributed among participating clients on a pro rata basis or in some other equitable manner. Blocked trades are placed only when we reasonably believe that the combination of the transactions provides better prices for clients than had individual transactions been placed for clients. Transactions for nondiscretionary client accounts are not blocked with transactions for discretionary client accounts. Transactions for the accounts of our employees and advisory representatives may be included in blocked trades. They receive the same average price and pay the same commissions and other transaction costs, as clients. Transactions for the accounts of our advisory representatives or employees will not be favored over transactions for client accounts. We are not obligated to include any client account in a blocked trade. Blocked trades will not be placed for any client’s account where prohibited or otherwise inconsistent with that client’s investment advisory agreement. No client will be favored over any other client. Item 13: Review of Accounts All client accounts are monitored on an ongoing basis with a formal review conducted at least annually or as agreed upon with individual clients. The reviews focus on the consistency of portfolio investments with each client’s stated objectives and risk tolerances. The reviews also consider investment restrictions requested by individual clients, investment time horizons, liquidity needs, tax considerations, and other circumstances unique to each client. Changes in your investments and your investment strategies will be recommended by us as they are deemed appropriate. Account reviews may also be triggered by other factors such as changes in general economic and market conditions, analyst reports, issuer news and interest rate 26 movement. Louis Tilchin, President, and John Troncoso, Chief Executive Officer, assign reviewers based upon their familiarity with your accounts. Typically, advisory representatives review their own client accounts. You will receive statements from the custodian at least quarterly. These statements identify your current investment holdings, the cost of each of those investments, and their current market values. You will also receive performance analysis reports prepared by us which describe the returns realized on the investments in your account. Unaffiliated Asset Management Services Our advisory representatives will regularly review the reports provided to you by any third-party investment managers that are managing assets for you. We will contact you at least annually (or more often as agreed upon with you) to review your financial situation, investment goals and objectives and risk tolerances, and the performance of the third-party investment manager to help monitor that your account is being managed in a manner consistent with your objectives. Again, we strongly encourage you to advise us of any changes in your personal circumstances, your investment goals or objectives, and your risk tolerances to help ensure that your investments and investment strategies are appropriate for you. You will receive statements on at least a quarterly basis from the custodian holding your account. These statements will identify your current investment holdings, the cost of each of those investments, and their current market values. Item 14: Client Referrals and Other Compensation We may enter into written agreements with certain unaffiliated investment advisers and other professionals (such as CPAs, attorneys, etc.) to compensate them for referring clients to us. We will pay these individuals (referred to as “solicitors”) a percentage of the advisory fee that you pay us if it is determined that you have become a client of ours as a result of their direct or indirect efforts. The payments we make to a solicitor will not result in an increase in the amount of the advisory fee that the referred client will pay. Our solicitation or referral arrangements will comply with applicable laws that govern: the nature of the services provided; the fees to be paid; disclosure of solicitor arrangements to clients; and 27 client consents, as required. We may receive certain economic benefits as a result of Jaffe Tilchin Investment Partner’s participation in the Custodian’s institutional program. Those benefits are described in detail in the preceding section entitled “Brokerage Practices.” Item 15: Custody Your assets are maintained with a qualified custodian. You will receive statements from the custodian that holds your investment account on at least a quarterly basis. We urge you to carefully review these statements and compare them to the account statements that we may provide you. You should verify that the transactions in your account are consistent with your investment goals and the objectives for your account. We also encourage you to contact your advisory representative or our Chief Compliance Officer should you have any questions or concerns regarding your account. Custody is also disclosed in Form ADV because we have authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodians: the nature of the services provided; • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third 28 party contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Private Funds In addition, we are currently the managing member for the Fund. All funds and securities of this Fund are held in accounts maintained by a qualified custodian. An independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, audits the financial statements of the Fund annually. In addition, the audited financial statements, which are prepared in accordance with GAAP, are distributed to all members of the Fund within 120 days of the end of its fiscal year. In the event that audited financial statements of the Fund are not audited as set forth above, it is our policy that the funds and securities of the Fund will be examined on a surprise basis by an independent public accountant at least once each calendar year, without prior notice to us. Item 16: Investment Discretion We offer our advisory services on a discretionary basis. This means that we do not need advance approval from you to determine the type and amount of securities to be bought and sold for your accounts. We do not, however, have the ability to choose the broker- dealer through which transactions will be executed. Additionally, we do not have the ability to withdraw funds from your account (other than to withdraw our advisory fees which, may only be done with your prior written authorization.) This discretion is used in a manner consistent with the stated investment objectives for your account, if you have given us written authorization to do so. We only exercise discretion in accounts where we have been authorized by you. This authorization is typically included in the investment advisory agreement you enter into with us. Typically, under third-party investment management arrangements, the third-party investment manager exercises discretion in the management of your account. All securities transactions are selected and executed by that manager. We do not manage or obtain discretionary authority over the assets in those accounts. You may, however, grant us the discretionary authority to hire and fire such third-party managers on your behalf. 29 We offer our consulting services on a nondiscretionary basis. We do not have the ability to effect trades in your investment accounts. We also do not have the ability to choose the broker- dealer through which transactions will be executed. Item 17: Voting Client Securities We do not vote proxies on securities. Clients are expected to vote their own proxies. The client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, we will provide recommendations to the client. If a conflict of interest exists, it will be disclosed to the client. Item 18: Financial Information We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to you and we have not been the subject of a bankruptcy proceeding. We do not charge more than $1,200, six months or more in advance of services to be rendered. 30

Additional Brochure: JAFFE TILCHIN WRAP FEE PROGRAM BROCHURE (2025-08-27)

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Form ADV Part 2A Appendix 1 Jaffe Tilchin Investmen tPartners, LLC. Also doing business as: J Best Advisory Group Jaffe Tilchin Wealth Management Jaffe Tilchin Institutional Consulting Jaffe Tilchin Investment Partners Trent Troncoso Group 15350 N. Florida Avenue Tampa , FL33613 813.963.2500 www.jaffetilchin.com Jaffe Tilchin Wrap Fee Prog ram Brochure August 27, 2025 Item 1: Cover Page This wrap fee program brochure provides information about the qualifications and business practices of Jaffe Tilchin Investment Partners, LLC. If you have any questions about the contents of this brochure, please contact us at 813-963-2500. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Jaffe Tilchin Investment Partners, LLC is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information about which you determine to hire or retain an adviser. Additional information about Jaffe Tilchin Investment Partners, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. Item 2: Material Changes Jaffe Tilchin Investment Partners, LLC (“Jaffe Tilchin, we, us, our, ours”) has made the following material changes to our disclosure brochures since the last update dated March 27, 2025: o Item 4 was updated due to recent changes in ownership and management. You may request a copy of our brochure by contacting our Chief Compliance Officer at 813.963.2500 or Scott@jaffetilchin.com. We will provide you with a new brochure at any time without charge. Additional information about us is available via the SEC’s website: www.adviserinfo.sec.gov. This website also provides information about any persons affiliated with Jaffe Tilchin who are registered as investment adviser representatives (“your advisory representative”) of Jaffe Tilchin. Information on our investment adviser representatives who work with your account can be found in our brochure supplements. . Jaffe Tilchin Investment Partners, LLC SEC File Number 801‐67720 CRD Number 143608 ADV Part 2A Appendix 1 Item 3: Table of Contents Item 1: Cover Page ............................................................................................................................................ 1 Item 2: Material Changes .................................................................................................................................. 3 Item 3: Table of Contents ................................................................................................................................. 4 Item 4: Services, Fees and Compensation ............................................................................................................ 5 Item 5: Account Requirements and Types of Clients .......................................................................................... 8 Item 6: Portfolio Mana g er Selection and Evaluation ............................................................................................ 8 Item 7: Client Information Provided to Portfolio M an a gers................................................................................ 15 Item 8: Client Contact with Portfolio Mana g ers ................................................................................................. 15 Item 9: Additional Information ......................................................................................................................... 15 Item 4: Services, Fees and Compensation Jaffe Tilchin is a Limited Liability Company organized under the laws of Florida. Scott Jaffe & Louis Tilchin founded the Tampa -based investment advisory firm in 2007. Giancarlo (John) Troncoso, Scott Jaffe & Louis Tilchin are the principal owners. Jaffe Tilchin is a member of the Jaffe Tilchin Wealth Management family of companies. Jaffe Tilchin Investment Partners also operates under the business names of J Best Advisory Group, Jaffe Tilchin Institutional Consulting, Jaffe Tilchin Wealth Management, Jaffe Tilchin Investment Partners, and Trent Troncoso Group. Jaffe Tilchin Wrap Fee Program Our Investment Committee is comprised of John Troncoso, Chief Executive Officer, Brett Witkowski and Louis Tilchin, President. Brett Witkowski, acts as portfolio manager for the Jaffe Tilchin Wrap Fee Program (“Program”). Your advisory representative works with you to identify your risk tolerance, investment goals and objectives to assess your financial profile. This program is utilized for legacy clients already involved in this program, but is not offered to incoming clients of JTIP. We will design and manage your portfolio in a manner consistent with your financial profile. Your portfolio may consist of a variety of investments including: equities, exchange traded funds, fixed income securities and mutual funds. You must grant us discretionary authority to buy and sell securities as deemed appropriate by our Investment Committee. Your account may or may not be similar to other clients with the same investment objectives and financial profiles. You have the opportunity to place reasonable restrictions on the type of investments to be held in your portfolio. Your portfolio (“account” or “investment account”) and the investment strategies utilized are determined based upon your specific individual investment objectives, goals and risk tolerances. We may periodically adjust your account (a process referred to as “rebalancing”) to help ensure that your investment account remains consistent with your objectives, goals, and risk tolerances. Our advisory representatives rely on you to notify them of any changes in your objectives, goals and risk tolerances, as well as any other material changes in your personal circumstances (such as your employment, marital status, financial condition, etc.). These changes may prompt changes in your investment account and the investment strategies employed. Fees and Compensation Wrap fee structures allow you to pay an all- inclusive fee which includes: investment management fees shared by our firm, our advisory representatives, and, in some instances, the broker dealer of advisory representatives who are also registered as 5 | P a g e representatives of the broker-dealer; execution and clearing costs; transaction costs – if applicable – which may be paid to purchase and sell securities in your account; and custody fees. Fees are calculated based upon the market value of the assets in your account. Broker- dealers and other financial institutions that hold client accounts are referred to as custodians (hereinafter referred to as “custodian”). Your custodian determines the values of the assets in your portfolio. Our fee schedule is described below: Account Asset Balance Maximum_ Annual Fee1 Up to $5,000,000 2.00% Over $5,000,000 Negotiable 1Fees are negotiable at our sole discretion. Your custodian receives a portion of the advisory fee to cover transaction and custodial costs. We share approximately 60% of the remainder of the fee with your advisory representative. We will generally recommend Fidelity Brokerage Services, LLC (“Fidelity”) (“Custodian”) to you for custody and brokerage services although we may agree to employ the services of one or more other custodians. We are independently owned and operated and not affiliated with the Custodian we recommend. Please see “Brokerage Practices” on Page 11 of our Disclosure Brochure for more information about the services provided to us by the custodian. You must authorize us in writing to have the custodian pay us directly by charging your account. The custodian provides you with statements that show the amount paid directly to us. You should verify the calculation of our fees. The custodian does not verify the accuracy of fee calculations. All advisory fees are billed quarterly, in advance as contractually agreed, and are based upon market value of the account on the last business day of the preceding calendar quarter, as determined by the account custodian. If you agree to pay our investment advisory fees in advance and you terminate the advisory agreement we have entered into within five (5) business days from the date the agreement is executed, you will receive a full refund of any fees paid. Should either one of us terminate the advisory agreement before the end of a billing period, any unearned fees that were deducted from your account will be returned to you by us. The amount refunded to you is calculated by dividing the most recent advisory fee you paid by the total number of days in the quarter. This daily fee is then multiplied by the number of calendar days in the quarter that our agreement was in effect. This amount, which equals the amount we earned for the partial quarter, is subtracted from the total fee you paid in advance to determine your refund. We may also refer you to various asset management firms. Referral fees or a portion of the advisory fee 6 | P a g e will be paid to us if you establish a relationship with the asset manager. Third party asset managers may require the use of certain custodians. Please refer to the Brokerage Practices sections of their respective brochures for more information. The above arrangements present a conflict of interest because they create an incentive to make recommendations based upon the amount of compensation we receive rather than based upon your needs. We will explain the specific costs associated with any recommended investments with you upon request. We also recommend no-load and load- waived mutual funds to further reduce conflicts of interest. Additionally, you have the option to purchase investment and insurance products through other brokers or agents who are not affiliated with us. You should note that the same (or similar) services as those described above may be available from other sources at a lower cost to you. You should consider that depending upon the level of the wrap fee charges, the amount of portfolio activity in your account, the value of services that are provided, and other factors, a wrap fee may exceed the aggregate cost of services if they were to be provided separately. A non-wrapped pricing arrangement may be more cost effective for accounts that do not experience frequent trading activity. The wrap fee does not include mark-ups, markdowns, or payment of brokerage commissions for transactions made by a broker-dealer other than the custodian. In addition to our fee, you may be required to pay other charges such as: maintenance fees associated with certain retirement and qualified plan accounts; internal fees and expenses charged by mutual funds or exchange traded funds (“ETFs”), and other fees and taxes on brokerage accounts and securities transactions. Mutual fund companies, ETFs, and variable annuity issuers charge internal fees and expenses for their products. These fees and expenses are in addition to any advisory fees charged by us. Complete details of these internal fees and expenses are explained in the prospectuses for each investment. You are strongly encouraged to read these explanations before investing any money. You may ask us any questions you have about fees and expenses. While you may purchase shares of mutual funds directly from the mutual fund company without a transaction fee, those investments would not be part of our advisory relationship with you. This means that they would not be included in our investment strategies, investment performance monitoring, or portfolio reallocations. No advisory fees are charged on any mutual funds or unit investment trusts transferred into your account which were purchased within the preceding two years if a commission was paid to your advisory representative as a representative of a broker-dealer. As a result of your participation in this program, will receive a portion of the fee charged by us. These payments may be made as long as you participate in the program and may be greater than other forms of compensation had you paid separately for investment advice, brokerage and other services provided to you as part of a wrap fee program. As a result, our advisory representatives may have a financial incentive to utilize this program over other programs or services that may be available to you. 7 | P a g e Item 5: Account Requirements and Types of Clients As a condition for starting and maintaining an advisory relationship, we generally require a minimum portfolio size of $25,000. We, at our sole discretion, may accept clients with smaller portfolios based upon certain factors including: future earning capacity, future additional assets, anticipated anticipated account composition, related accounts, and pre-existing client relationships. We may consider the portfolios of your family members to determine if your portfolio meets the minimum size requirement. There is a minimum quarterly fee of $50. We reserve the right to waive or reduce this fee. We may contract with third party, unaffiliated asset managers to manage all or part of your portfolio. These third-party managers may have their own minimum size requirements that will be outlined in their disclosure documents. Investors in private funds or investment vehicles are required to own or have a specified amount of assets and/or net worth. The completion of special documents are required prior to investing; minimum account sizes are specified. We offer professional asset management services to individuals, trusts, estates, charitable organizations, corporations and pension plans. Item 6: Portfolio Manag er Selection and Evaluation Our Investment Committee is comprised of John Troncoso, Chief Executive Officer, Brett Witkowski and Louis Tilchin, President. Brett Witkowski, acts as portfolio manager for this Program. There is no other affiliated or unaffiliated portfolio management offered through this program. Advisory Business Jaffe Tilchin offers the following advisory services: Jaffe Tilchin Wrap Fee Program We design and manage portfolios based on your financial profile as described above under “Services, Fees and Compensation.” The following services and related fees are more fully described in their respective disclosure brochures which are available upon request: Unaffiliated Asset Managers We may contract with third party, unaffiliated asset managers to manage all or part of your portfolio. 8 | P a g e These third-party investment managers may manage accounts or private investment funds or vehicles for qualified investors. We will use the information you have provided about your investment objectives, goals, time horizon, and risk tolerances, as well as other relevant information, to identify a third-party investment manager(s) whose investment strategies or investment vehicles appear appropriate for you. Some of the other relevant information considered in recommending a third-party asset manager include (but are not limited to): Your preference for certain types of investment strategies; The size and composition of your investment account; Your tax considerations; Our prior experience with and preferences for particular investment managers; The fees charged by the investment manager; and The experience and capabilities of the investment manager. We contact you at least annually or more often as we agree to review your financial situation and objectives, communicate information to the third party manager managing the account or investment vehicle as warranted, and to assist you in understanding and evaluating the services provided by the third party manager. Needs and Restrictions In managing your investment portfolio, we consider your: financial situation, risk tolerance, investment horizon, liquidity needs, tax considerations, investment objectives, and any other issues important to your state of affairs. You should notify us promptly of any changes in your objectives, goals, and risk tolerances, as well as any other material changes in your personal circumstances (such as your employment, marital status, financial condition, etc.). These changes may require changes in your investment account and the investment strategies employed. You may impose any reasonable restrictions upon the manner in which we manage your investment account. For example, you may restrict the management of your account to certain types of investment products or investment strategies. Performance-Based Fees Performance-based fees are designed to give a portion of the returns of an investment to the investment adviser as a reward for positive performance. The fee is generally a percentage of the profits made on the investments. We do not charge performance- based fees on any Jaffe Tilchin Wrap Fee Program client accounts. Some of the unaffiliated third-party managers we recommend may charge a performance fee, however we do not receive any portion of any performance-based fee a manager may charge for the unaffiliated third-party managers’ funds. Our affiliate private fund “Fund” clients are typically charged two types of fees. These fees are a quarterly management fee and an annual performance fee. The quarterly management fee is a specified percentage of the net asset value of the Fund, payable based on the market value of the account at the 9 | P a g e end of the prior quarter (i.e., in arrears). The performance fee, if any, is a specified percentage based upon the increase in the market value of the account at the end of the calendar year compared to the highest ending account balance at the end of previous calendar years. Each year's performance fee, if any, is paid by the Fund based upon the performance results as of December 31 of each year. Performance fees paid will be in compliance with Rule 205-3 of the Investment Advisers Act of 1940. The information contained in this item is only a summary of the fees payable to us from our Fund client and is qualified in its entirety by the Funds’ private placement memorandum and other governing documents (the “Offering Documents”). Investors in the Fund are urged to refer to the Fund’s Offering Documents for a complete understanding of how we are compensated for its advisory services to the Fund, and the other fees and costs associated with an investment in the Fund Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis investment strategies and The Firm may use the following methods when considering recommendations. Charting Review Charting is a technical analysis that charts the patterns of stocks, bonds, and commodities to help determine buy and sell recommendations for clients. It is a way of gathering and processing price and volume information in a security by applying mathematical equations and plotting the resulting data onto graphs in order to predict future price movements. A graphical historical record assists the analyst in spotting the effect of key events on a security’s price, its performance over a period of time, and whether it is trading near its high, near its low or in between. Chartists believe that recurring patterns of trading, commonly referred to as indicators, can help them forecast future price movements. Fundamental Review A fundamental analysis is a method of evaluating a company or security by attempting to measure its intrinsic value. Fundamental analysis attempts to determine the true value of a company or security by looking at all aspects of the company or security, including both tangible factors (e.g., machinery, buildings, land, etc.) and intangible factors (e.g., patents, trademarks, “brand” names, etc.). Fundamental analysis also involves examining related economic factors (e.g., overall economy and industry conditions, etc.), financial factors (e.g., company debt, interest rates, management salaries and bonuses, etc.), qualitative factors (e.g., management expertise, industry cycles, labor relations, etc.), and quantitative factors (e.g., debt-to-equity and price-to-equity ratios). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price with the aim of determining what sort of position to take with that security (e.g., if underpriced, the security should be bought; if overpriced the security should sold). Fundamental analysis uses real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for many types of securities. Technical Review A technical analysis is a method of evaluating securities that analyzes statistics generated by market 10 | P a g e activity, such as past prices and volume. Technical analysis does not attempt to measure a security's intrinsic value, but instead uses past market data and statistical tools to identify patterns that can suggest future activity. Historical performance of securities and the markets can indicate future performance. Cyclical Review A cyclical analysis assumes the market reacts in reoccurring patterns that can be identified and leveraged to provide performance. Cyclical analysis of economic cycles is used to determine how these reoccurring patterns, or cycles, affect the returns of a given investment, asset, or company. Cyclical analysis is a time-based assessment which incorporates past and present performance to determine future value. Cyclical analyses exist because the broad economy has been shown to move in cycles, from periods of peak performance to periods of low performance. The risks of this strategy are two- fold: (1) the markets do not always repeat cyclical patterns; and (2) if too many investors begin to implement this strategy, it changes the very cycles of which they are trying to take advantage. Economic Review An economic analysis determines the economic environment over a certain time horizon. This involves following and updating historic economic data such as U.S. gross domestic product and consumer price index as well as monitoring key economic drivers such as employment, inflation, and money supply for the world’s major economies. B. Investment Strategies When implementing investment advice to clients, the Firm may employ a variety of strategies to best pursue the objects of clients. Depending on market trends and conditions, Fiduciary Architects will employee any technique or strategy herein described, at the Firm’s discretion and in the best interests of the client. The Firm does not recommend any particular security or type of security. Instead, the Firm makes recommendations to meet a particular client’s financial objectives. There is inherent risk to any investment and clients may suffer loss of ALL OR PART of a principal investment. Long-Term Purchases Long-term purchases are securities that are purchased with the expectation that the value of those securities will grow over a relatively long period, generally greater than one year. Long-term purchases may be affected by unforeseen changes in the company in which a client is invested or in the overall market. Long term trading is designed to capture market rates of both return and risk. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Due to its nature, the long-term strategy can expose clients to various other types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include, but are not limited to, inflation (purchasing power) risk, interest rate risk, economic risk, and political/regulatory risk. Short-Term Purchases Short-term purchases are securities that are purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short- term price fluctuations. Short-term trading generally holds greater risk. Frequent trading can affect investment performance due to increased brokerage fees and other transaction costs and taxes. 11 | P a g e Strategic Asset Allocation Asset allocation is a combination of several different types of investments; typically, this includes stocks, bonds, and cash equivalents among various asset classes to achieve diversification. The objective of asset allocation is to manage risk and market exposure while still positioning a portfolio to meet financial objectives. C. Risk of Loss Investing inherently involves risk up to and including loss of the principal sum. Further, past performance of any security is not necessarily indicative of future results. Therefore, future performance of any specific investment or investment strategy based on past performance should not be assumed as a guarantee. Fiduciary Architects does not provide any representation or guarantee that the financial goals of clients will be achieved. The potential return or gain and potential risk or loss of an investment varies, generally speaking, with the type of product invested in. Below is an overview of the types of products available on the market and the associated risks of each: General Risks. Investing in securities always involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives can or will be met. Past performance is in no way an indication of future performance. We also cannot assure that third parties will satisfy their obligations in a timely manner or perform as expected or marketed. General Market Risk. Investment returns will fluctuate based upon changes in the value of the portfolio securities. Certain securities held may be worth less than the price originally paid for them, or less than they were worth at an earlier time. Common Stocks. Investments in common stocks, both directly and indirectly through investment in shares of ETFs, may fluctuate in value in response to many factors, including, but not limited to, the activities of the individual companies, general market and economic conditions, interest rates, and specific industry changes. Such price fluctuations subject certain strategies to potential losses. During temporary or extended bear markets, the value of common stocks will decline, which could also result in losses for each strategy. Portfolio Turnover Risk. High rates of portfolio turnover could lower performance of an investment strategy due to increased costs and may result in the realization of capital gains. If an investment strategy realizes capital gains when it sells its portfolio investments, it will increase taxable distributions to you. High rates of portfolio turnover in a given year would likely result in short-term capital gains and under current tax law you would be taxed on short-term capital gains at ordinary income tax rates, if held in a taxable account. Non-Diversified Strategy Risk. Some investment strategies may be non-diversified (e.g., investing a greater percentage of portfolio assets in a particular issuer and owning fewer securities than a diversified strategy). Accordingly, each such strategy is subject to the risk that a large loss in an individual issuer will cause a greater loss than it would if the strategy held a larger number of securities or smaller 12 | P a g e positions sizes. Model Risk. Financial and economic data series are subject to regime shifts, meaning past information may lack value under future market conditions. Models are based upon assumptions that may prove invalid or incorrect under many market environments. We may use certain model outputs to help identify market opportunities and/or to make certain asset allocation decisions. There is no guarantee any model will work under all market conditions. For this reason, we include model related results as part of our investment decision process but we often weigh professional judgment more heavily in making trades or asset allocations. ETF Risks, including Net Asset Valuations and Tracking Error. An ETF's performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depository Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. Clients should be aware that to the extent they invest in ETF securities they will pay two levels of advisory compensation – advisory fees charged by Fiduciary Architects plus any advisory fees charged by the issuer of the ETF. This scenario may cause a higher advisory cost (and potentially lower investment returns) than if a Client purchased the ETF directly. An ETF typically includes embedded expenses that may reduce the ETF's net asset value, and therefore directly affect the ETF's performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. Expenses of the ETF may include investment advisor management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. Inflation, Currency, and Interest Rate Risks. Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. In addition, the relative value of the U.S. dollar-denominated assets primarily managed by Fiduciary Architects may be affected by the risk that currency devaluations affect Client purchasing power. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash to prevent a loss, realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally, investments are more liquid if the investment has an established market of purchasers and sellers, such as a stock or bond listed on a national securities exchange. Conversely, investments that do not have an established market of purchasers and sellers may be considered illiquid. Your investment in illiquid investments may be for an indefinite time, because of the lack of purchasers willing to convert your investment to cash or other assets. 13 | P a g e Legislative and Tax Risk. Performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to: changes in investment advisor or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities; and changes in the tax code that could affect interest income, income characterization and/or tax reporting obligations, particularly for options, swaps, master limited partnerships, Real Estate Investment Trust, Exchange Traded Products/Funds/Securities. We do not engage in tax planning, and in certain circumstances a Client may incur taxable income on their investments without a cash distribution to pay the tax due. Clients and their personal tax advisors are responsible for how the transactions in their account are reported to the IRS or any other taxing authority. Foreign Investing and Emerging Markets Risk. Foreign investing involves risks not typically associated with U.S. investments, and the risks maybe exacerbated further in emerging market countries. These risks may include, among others, adverse fluctuations in foreign currency values, as well as adverse political, social, and economic developments affecting one or more foreign countries. In addition, foreign investing may involve less publicly available information and more volatile or less liquid securities markets, particularly in markets that trade a small number of securities, have unstable governments, or involve limited industry. Investments in foreign countries could be affected by factors not present in the U.S., such as restrictions on receiving the investment proceeds from a foreign country, foreign tax laws or tax withholding requirements, unique trade clearance or settlement procedures, and potential difficulties in enforcing contractual obligations or other legal rules that jeopardize shareholder protection. Foreign accounting may be less transparent than U.S. accounting practices and foreign regulation may be inadequate or irregular. Information Security Risk. We may be susceptible to risks to the confidentiality and security of its operations and proprietary and customer information. Information risks, including theft or corruption of electronically stored data, denial of service attacks on our website or websites of our third-party service providers, and the unauthorized release of confidential information are a few of the more common risks faced by us and other investment advisers. Data security breaches of our electronic data infrastructure could have the effect of disrupting our operations and compromising our customers' confidential and personally identifiable information. Such breaches could result in an inability of us to conduct business, potential losses, including identity theft and theft of investment funds from customers, and other adverse consequences to customers. We have taken and will continue to take steps to detect and limit the risks associated with these threats. Tax Risks. Tax laws and regulations applicable to an account with Fiduciary Architects may be subject to change and unanticipated tax liabilities may be incurred by an investor as a result of such changes. In addition, customers may experience adverse tax consequences from the early assignment of options purchased for a customer's account. Customers should consult their own tax advisers and counsel to determine the potential tax-related consequences of investing. Advisory Risk. There is no guarantee that our judgment or investment decisions on behalf of particular any account will necessarily produce the intended results. Our judgment may prove to be incorrect, and an account might not achieve her investment objectives. In addition, it is possible that we may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to accounts’ custodians’ software. Fiduciary Architects and its representatives are not responsible to any account for losses unless caused by Fiduciary 14 | P a g e Architects breaching our fiduciary duty. Dependence on Key Employees. An accounts success depends, in part, upon the ability of our key professionals to achieve the targeted investment goals. The loss of any of these key personnel could adversely impact the ability to achieve such Voting Client Securities We do not vote proxies on securities. Clients are expected to vote their own proxies. The client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, we will provide recommendations to the client. If a conflict of interest exists, it will be disclosed to the client. Item 7: Client Information Provided to Portfolio Managers We work with you to identify your investment goals and objectives, as well as risk tolerance, in order to provide you with an initial portfolio allocation designed to complement your financial situation and personal circumstances. This information is updated when you communicate new information about your financial circumstances, objectives, or goals to your advisory representative. You may place reasonable restrictions on the strategies to be employed in your portfolio and the types of investments to be held in your portfolio. We obtain this information from you initially, annually, and as you inform us of any changes. Jaffe Tilchin values you as a client and recognizes the importance of protecting the personal information you provide. Jaffe Tilchin protects your information in accordance with our Privacy Statement which has been provided to you. Item 8: Client Contact with Portfolio Managers You have ready access to your advisory representative who can schedule a meeting with your portfolio manager. Portfolio managers are not required to be available for unscheduled or unannounced visits or calls by clients. However, portfolio managers are expected to periodically meet with clients and should generally be available to take client telephone calls on advisory-related matters. You are encouraged to contact your advisory representative with respect to any changes in your financial information that may affect the management of your account. Item 9: Additional Information Disciplinary Information Jaffe Tilchin has not been the subject of any civil, criminal or regulatory action or disciplinary event that would be material to your evaluation of our business or the integrity of our management. Lou Tilchin has previously been named in customer complaints which were settled. These are more fully 15 | P a g e to this brochure. Additional information is available at described in the supplements https://brokercheck.finra.org. Other Financial Industry Activities and Affiliations In addition to their position with Jaffe Tilchin, your advisory representative may also be a registered representative with APW Capital, Inc. (“APW”), a registered broker-dealer (member FINRA/SIPC). You are under no obligation to purchase or sell securities through your advisory representative in conjunction with their association with APW. If you do so, however, they may earn compensation in the form of commissions or investment advisory fees. Jaffe Tilchin Investment Partners, LLC is affiliated with Jaffe Tilchin Wealth Management and RCR Financial, through common ownership. Jaffe Tilchin Wealth Management and RCR Financial are insurance agencies and offer commissionable insurance products. Certain advisory representatives are also licensed as insurance agents. Certain advisory representatives are also licensed as insurance agents. You are under no obligation to purchase insurance products from Jaffe Tilchin Wealth Management, RCR Financial, or any advisory representative. If you choose to purchase insurance, these firms and individuals will receive commissions in addition to the advisory fees you pay to us. As noted above, when appropriate, we provide individualized advisory services to you through the recommendation of suitable third-party investment advisers. Because the compensation we receive may vary depending upon the adviser selected, we may have a conflict of interest in recommending certain advisers to you. To address this potential conflict we consider the following factors in the selection of a third-party adviser which include, but may not be limited to: the management style, performance, reputation, pricing and reporting capabilities of the third-party investment adviser; your risk tolerance, goals and objectives, as well as investment experience; the amount of assets you have available for investment; and our familiarity with and preference for a particular adviser. You are under no obligation to follow our recommendations. Private Funds We provide investment management services to the Fund and in such capacity receives a management fee and a performance-based fee. Clients should be aware that the receipt of additional compensation by us and our management persons or employees may create a conflict of interest that could impair the objectivity of our firm and our employees when making advisory recommendations. We endeavor, at all times, to put the interest of our clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps to address this potential conflict of interest: • we include disclosure in our brochure regarding the existence of all material conflicts of interest, including the potential for our firm and our employees to earn additional compensation from advisory clients apart from our firm's advisory fees; • • we disclose to clients that they are not obligated to purchase recommended investment products from our employees or affiliated companies; • we collect, maintain and document accurate, complete and relevant client background 16 | P a g e information, including the client’s financial goals, objectives and risk tolerance; • • our firm's management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances; • we require that our employees seek prior approval of any outside business activity so that we may ensure that any conflicts of interests in such activities are properly addressed; and • we periodically monitor these outside business activities to verify that any conflicts of interest continue to be properly addressed by our firm. Code of Ethics; Participation or Interest in Client Transactions and Personal Trading We have adopted a Code of Ethics (“Code”) to address the securities-related conduct of our advisory representatives and employees. The Code includes our policies and procedures developed to protect your interests in relation to the following: the duty at all times to place your interests ahead of ours; that all personal securities transactions of our advisory representatives and employees be conducted in a manner consistent with the Code and avoid any actual or potential conflict of interest, or any abuse of an advisory representative’s or employee’s position of trust and responsibility; that advisory representatives may not take inappropriate advantage of their positions; that information concerning the identity of your security holdings and financial circumstances are confidential; and that independence in the investment decision-making process is paramount. We will provide a copy of the Code to you or any prospective client upon request. We do not buy or sell securities for our firm that are also recommended to clients. Our advisory representatives and employees are permitted to buy or sell the same securities for their personal and family accounts that are bought or sold for your account(s). The personal securities transactions by advisory representatives and employees may raise potential conflicts of interest when they trade in a security that is owned by you, or considered for purchase or sale for you. We have adopted policies and procedures that are intended to address these conflicts of interest. These policies and procedures: require our advisory representatives and employees to act in your best interest, prohibit favoring one client over another, and provide for the review of transactions to discover and correct any same-day trades that result in an advisory representative or employee receiving a better price than a client. Advisory representatives and employees must follow our procedures when purchasing or selling the same securities purchased or sold for you. Review of Accounts All client accounts are monitored on an ongoing basis with a formal review conducted at least annually or as agreed upon with individual clients. The reviews focus on the consistency of portfolio investments with each client’s stated objectives and risk tolerances. The reviews also consider: investment restrictions requested by individual clients, investment 17 | P a g e time horizons, liquidity needs, tax considerations, and other circumstances unique to each client Changes in your investments and your investment strategies will be made or recommended by us as they are deemed appropriate. Account reviews may also be triggered by other factors such as changes in general economic and market conditions, analyst reports, issuer news and interest rate movement. Louis Tilchin, CEO, and Scott Jaffe, Director of Investment Management, assign reviewers based upon their familiarity with your accounts. Typically, advisory representatives review their own client accounts. You will receive statements from your Custodian at least quarterly. These statements identify your current investment holdings, the cost of each of those investments, and their current market values. You will also receive performance analysis reports prepared by us which describe the returns realized on the investments in your account. Unaffiliated Asset Management Services Our advisory representatives will regularly review the reports provided to you by any third-party investment managers that are managing assets for you. We will contact you at least annually (or more often as agreed upon with you) to review your financial situation, investment goals and objectives and risk tolerances, and the performance of the third-party investment manager to help monitor that your account is being managed in a manner consistent with your objectives. Again, we strongly encourage you to advise us of any changes in your personal circumstances, your investment goals or objectives, and your risk tolerances to help ensure that your investments and investment strategies are appropriate for you. You will receive statements on at least a quarterly basis from the custodian holding your account. These statements will identify your current investment holdings, the cost of each of those investments, and their current market values. Client Referrals and Other Compensation We may enter into written agreements with certain unaffiliated investment advisers and other professionals (such as CPAs, attorneys, etc.) to compensate them for referring clients to us. We will pay these individuals (referred to as “solicitors”) a percentage of the advisory fee that you pay us if it is determined that you have become a client of ours as a result of their direct or indirect efforts. The payments we make to a solicitor will not result in an increase in the amount of the advisory fee that the referred client will pay. Our solicitation or referral arrangements will comply with applicable laws that govern: the nature of the services provided; the fees to be paid; 18 | P a g e disclosure of solicitor arrangements to clients; and client consents, as required. Additionally, we receive certain economic benefits as a result of our participation in the institutional brokerage programs (the “Program”) of the Custodian. These benefits include products and services that assist us in managing and administering client accounts, including access to investments generally available to institutional investors, software, technology, and research. We utilize Fidelity as the custodian for your Wrap Fee Program Account. We are not affiliated with the custodian we recommend. We do not enter into soft dollar arrangements with any custodian. The benefits we receive are more fully described in our Part 2A Disclosure Brochure in the section entitled “Brokerage Practices.” Financial Information We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to you and we have not been the subject of a bankruptcy proceeding. We do not charge more than $1,200, six months or more in advance of services to be rendered. 19 | P a g e