Overview

Assets Under Management: $250 million
Headquarters: PLANTATION, FL
High-Net-Worth Clients: 80
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Educational Seminars

Fee Structure

Primary Fee Schedule (NORTHSTAR FINANCIAL PLANNERS INC ADV2A)

MinMaxMarginal Fee Rate
$0 $250,000 1.25%
$250,001 $2,000,000 1.00%
$2,000,001 and above 0.75%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,625 1.06%
$5 million $43,125 0.86%
$10 million $80,625 0.81%
$50 million $380,625 0.76%
$100 million $755,625 0.76%

Clients

Number of High-Net-Worth Clients: 80
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 62.04
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 905
Discretionary Accounts: 905

Regulatory Filings

CRD Number: 131507
Last Filing Date: 2025-01-07 00:00:00
Website: https://advisorlawyer.com

Form ADV Documents

Primary Brochure: NORTHSTAR FINANCIAL PLANNERS INC ADV2A (2025-09-08)

View Document Text
Item 1 Cover Page 1250 S. Pine Island Road, Suite 275 Plantation, Florida 33324 Phone: 954-693-0030 Fax: 954-693-0031 www.northstarplanners.com September 08, 2025 FORM ADV PART 2A FIRM BROCHURE This brochure provides information about the qualifications and business practices of Northstar Financial Planners, Inc. If you have any questions about the contents of this brochure, please contact us at 954-693-0030. 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. Additional information about Northstar Financial Planners, Inc. (CRD# 131507) is also available on the SEC’s website at www.adviserinfo.sec.gov. Northstar Financial Planners, Inc. is a Registered Investment Adviser. Registration with any federal or state securities authority does not imply a certain level of skill or training. Item 2 Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to the adviser’s disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since the filing of our last annual updating amendment dated March 06, 2025, we have the following material changes to report: • Item 4 was amended to reflect that Allen Giese is now the sole owner of Northstar Financial Planners, Inc. 2 | P a g e Item 3 Table Of Contents Item 1 Cover Page ...................................................................................................................... 1 Item 2 Material Changes ............................................................................................................. 2 Item 3 Table Of Contents............................................................................................................. 3 Item 4 Advisory Business ............................................................................................................ 4 Item 5 Fees and Compensation ................................................................................................... 6 Item 6 Performance-Based Fees and Side-By-Side Management............................................... 8 Item 7 Types of Clients ................................................................................................................ 9 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 9 Item 9 Disciplinary Information .................................................................................................. 11 Item 10 Other Financial Industry Activities and Affiliations ......................................................... 11 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 12 Item 12 Brokerage Practices ..................................................................................................... 13 Item 13 Review of Accounts ...................................................................................................... 15 Item 14 Client Referrals and Other Compensation .................................................................... 15 Item 15 Custody ........................................................................................................................ 16 Item 16 Investment Discretion ................................................................................................... 17 Item 17 Voting Client Securities ................................................................................................ 17 Item 18 Financial Information .................................................................................................... 17 Privacy Notice ........................................................................................................................... 18 3 | P a g e Item 4 Advisory Business Description of Services and Fees We are a registered investment adviser based in Plantation, Florida. We are organized as a sub- Chapter S corporation under the laws of the State of Florida. We have been providing investment advisory services since 2000. Allen Giese is the firm’s owner. Currently, we offer the following investment advisory services, which are personalized to each individual client: • Portfolio Management Services • Financial Planning and Consulting Services The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Northstar Financial Planners, Inc. and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this Brochure. As used in this Brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. Portfolio Management Services We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we will customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. Financial Planning and Consulting Services We offer broad-based and consultative financial planning services. Financial planning will typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. 4 | P a g e Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to our firm. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to implement any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. We may, at our sole discretion, waive or offset the financial planning fee should you choose to implement the plan through our portfolio management services. We reserve the right to determine whether the financial planning and/or consulting fees will be waived or offset by the advisory fees earned in the implementation process. The scope and complexity of the financial planning services provided will determine the waiver or offset of the fee. Separately Managed Accounts “SMA”s: When appropriate to the management of a client’s portfolio we will engage with sub-advisers through the use of Separately Managed Accounts “SMAs” where a portion of the client’s account(s) are allocated to one or more professionally managed fixed income and/or equity strategy models. We will work with the client to select and determine the appropriate allocation for any SMAs used as part of their portfolio and will assist the client with completing any of the sub-advisor’s account paperwork and/or agreements. Our review process and analysis of sub- advisers is further discussed in Item 8 of this Form ADV Part 2A. Additionally, we will meet with the Client on a periodic basis to discuss changes in their personal or financial situation, suitability, and any new or revised restrictions to be applied to the account. Fees pertaining to the use of SMAs are outlined in Item 5 of this brochure under “Additional Fees and Expenses”. Wrap Fee Program We do not participate in or sponsor a wrap fee program. Types of Investments We primarily recommend mutual funds; however, we may also offer advice on equity securities, including exchange traded funds, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, and U.S. Government securities. Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Assets Under Management As of December 31, 2024, we provided continuous management services for $273,053,616.00 in client assets and only on a discretionary basis. 5 | P a g e Item 5 Fees and Compensation Financial Planning and Consulting Fees We charge an hourly fee of $400.00 for financial planning services, which is negotiable depending on the scope and complexity of the plan, your situation, and your financial objectives. An estimate of the total time/cost will be determined at the start of the advisory relationship. In limited circumstances, the cost/time could potentially exceed the initial estimate. In such cases, we will notify you and request that you approve the additional fee. Fees are due upon completion of services rendered. You may terminate the financial planning agreement by providing written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement. Portfolio Management Fees Our fee for portfolio management services is based on a percentage of your assets we manage. While the exact fee structure may vary depending on specific services account complexity, our typical fee structure is as follows: Assets Under Management Annualized Fee Percentage First $250,000.00 1.25% $250,000.01 to $2,000,000.00 1.00% $2,000,000.01 and above 0.75% Our advisory fee is negotiable and will not exceed an annualized fee of 1.50%. The exact fee structure applicable to your accounts will be clearly stated in the portfolio management agreement. Our annual portfolio management fee is billed and payable quarterly in advance based on the value of your account on the last day of the previous quarter. If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in you paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. We will send you an invoice for the payment of our advisory fee, or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from 6 | P a g e your account. You should review all statements for accuracy. We will also receive a duplicate copy of your account statements. You may terminate the portfolio management agreement upon 30 days' written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the portfolio management agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. Additional Fees and Expenses As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual funds and exchange-trade funds. The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through which your account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, please refer to the "Brokerage Practices" section of this Brochure. When we utilize Separately Managed Account “SMA” portfolios offered by various Sub-Advisors, their management fees and any fees for trading in securities held within those SMAs are separate and in addition to any advisory fees we charge for our services. These fees are disclosed to clients at the start of an engagement if/when selecting an appropriate sub-advisor and SMA program. IRA Rollover Considerations As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because the people providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of: An employee will typically have four options: 1. Leaving the funds in your employer's (former employer's) plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. 7 | P a g e Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider before you do so: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs of those products and services. 3. Our strategy may have higher risk than the option(s) provided to you in your plan. 4. Your current plan may also offer financial advice. 5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. Item 6 Performance-Based Fees and Side-By-Side Management We do not accept performance-based fees or participate in side-by-side management. 8 | P a g e Item 7 Types of Clients We offer investment advisory services to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. In general, we require a minimum of $500,000 to open and maintain an advisory account. At our discretion, we may waive this minimum account size. For example, we may waive the minimum if you appear to have significant potential for increasing your assets under our management. We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Our Methods of Analysis and Investment Strategies We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: • Structured Asset Class Allocation - We create a diversified portfolio in which assets are grouped by asset class. An asset class is a group of securities whose price movements are closely correlated, or which tend to rise and fall in value at the same time. Large cap U.S. stocks are an example of an asset class. Other examples of asset classes are small cap U.S. stocks, large cap international stocks, real estate stocks, short term global bonds and long-term government bonds. o Risk: Market risk is that part of a security's risk that is common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. • Long Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. o Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other investments. • Short Term Purchases - securities 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. o Risk: Using a short-term strategy generally assumes purchase that we can predict how financial markets will perform in the short-term which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long- term trading. There are many factors that can affect financial market performance in the short- term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of time. • Margin Transactions - a securities transaction in which an investor borrows money to 9 | P a g e purchase a security, in which case the security serves as collateral on the loan. o Risk: If the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a "margin call." An investor's overall risk includes the amount of money invested plus the amount that was loaned to them. We may use margin transactions in limited circumstances when we determine that it is suitable given your stated investment objectives and tolerance for risk; however, engaging in these types of transactions are not a fundamental part of our overall investment strategy. Long-term purchases may also be affected by unforeseen long-term changes in the company in which you are invested or in the overall market. Short term trading generally involves a greater degree of risk than long term trading due to market volatility over a short period of time. Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. Use of Separately Managed Accounts “SMA”: We may utilize certain SMA programs offered by various sub-advisors to manage a portion of a client’s portfolio. When we determine it would be more appropriate to use an SMA program over mutual funds or ETFs for a portion of the client’s portfolio we will choose from various sub-advisors based on the available SMA programs that meet the needs and objectives established for the management of a client’s portfolio. We will review and monitor the sub-adviser’s holdings, strategies, concentrations, and leverage as part of our overall periodic risk assessment. Additionally, as part of our due diligence process, we survey the sub-adviser’s compliance and business enterprise risks. Through management of the SMA program the sub-advisor is responsible for the security selection(s) that make up a specific SMA with a given strategy. We do not control the individual security selection but do maintain the ability to increase, decrease, or remove the client’s allocation to any SMA that we use. While we perform extensive research on the sub-advisors and specific SMAs that we use, we may be unable to predict changes to the sub-advisors strategy for security selection and overall management style of the SMA. Moreover, as we do not control the sub-adviser’s daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you consult with a tax professional regarding the investing of your assets. Moreover, as a result of revised IRS regulations, custodians and broker-dealers will begin reporting the cost basis of equities acquired in client accounts on or after January 1, 2011. Your custodian will default to the Average Cost accounting method for calculating the cost basis of your investments and capital gains or losses generated when sales transactions occur. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, please provide written notice to our firm immediately and we will alert your account custodian of 10 | P a g e your individually selected accounting method. Please note that decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement and may not be changeable for future transactions within the same asset. Risk of Loss Investing in securities 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 will be met. Past performance is in no way an indication of future performance. Recommendation of Particular Types of Securities As disclosed under the "Advisory Business" section in this Brochure, we primarily recommend mutual funds; however, we may also recommend other types of securities since each client has different needs and a different tolerance for risk. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it. Mutual funds are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. The returns on mutual funds can be reduced by the costs of managing the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely, which can dilute other investors' interests. Item 9 Disciplinary Information Neither our firm nor any of our associated people have any reportable disciplinary information. Item 10 Other Financial Industry Activities and Affiliations Registration as a Broker/Dealer or Broker/Dealer Representative We are not registered and do not have an application pending to register, as a broker dealer and our management persons are not registered as broker/dealer representatives and there are no pending applications to become such a representative. 11 | P a g e Registration as a Futures Commission merchant, Commodity Pool Operator Our firm and our management are not registered and do not have application pending to register, as a futures commission merchant, commodity pool operator/advisor. Relationships Material to this Advisory Business and Possible Conflicts of Interest Our firm and our management have no other relationships that are material to its advisory business. Recommendation or Selection of Other Investment Advisors Except for the sub-advisers who may be selected to manage an SMA, which are described in Items 4 and 5, we do not recommend or select other investment advisers. We do not receive direct or indirect compensation from sub-advisers, except as described above. The compensation we receive in connection with sub-advisers is paid in the form of the advisory fees paid by a client, not any such advisers. Nonetheless, through sub-advisers, we have access to certain research and portfolio modeling tools, which tools we may not have access to if it did not refer clients to the sub-adviser. Consequently, to the extent we values the use of such tools and research, there is a conflict for it to act in its own economic best interest, rather than in the best interests of Clients, by recommending and selecting a sub-adviser so it will continue to have access to these tools and research and does not have to arrange or pay for these services from its separate funds. We address this conflict of interest by seeking to ensure full and fair disclosure in this Brochure. We monitor its accounts and evaluate the quality and costs of the services from sub-advisers that provide portfolio management services for clients to determine whether the recommendation or selection of them continues to meet its fiduciary obligations. Although we believe that our selections of sub-advisers meet its fiduciary obligations and are in the best interests of its clients, it is possible that its judgment could be materially affected by the desire to continue using these tools and services without payment from its separate funds. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All of our Associated Persons are expected to adhere strictly to these guidelines. Our Code of Ethics also requires that certain persons associated with our firm submit reports of their personal account holdings and transactions to a qualified representative of our firm who will review these reports on a periodic basis. Persons associated with our firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Participation or Interest in Client Transactions Neither our firm nor any of our Associated Persons has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this Brochure. 12 | P a g e Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or securities in which you are already invested. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is our policy that neither our Associated Persons nor we shall have priority over your account in the purchase or sale of securities. Item 12 Brokerage Practices We recommend the brokerage and custodial services of Schwab Advisor Services ("Schwab"). We believe that the recommended broker-dealer/custodian provides quality execution services for your account at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by the recommended broker- dealer/custodian, including the value of research provided, the firm's reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. In recognition of the value of research services and additional brokerage products and services we receive from the recommended broker-dealer/custodian, you may pay higher commissions and/or trading costs than those that may be available elsewhere. Research and Other Soft Dollar Benefits We do not have any soft dollar arrangements. Economic Benefits Schwab provides our firm with access to its institutional trading and operations services, which are typically not available to Schwab retail investors. These services are not part of a soft-dollar arrangement and are generally available to independent investment advisers at no charge to them so long as a total of at least $10 million of the firm’s clients’ account assets are maintained at Schwab. Schwab services may include research, brokerage, custody, access to mutual funds and other investments that are otherwise available only to institutional investors or would require significantly higher minimum initial investments. Schwab also makes available other products and services that benefit our firm but may not benefit our clients' accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution, provide research, pricing information and other market data, facilitate payment of our advisory fees from our clients' accounts, and assist with back-office support, recordkeeping, and client reporting. Our access to the foregoing products and services is not contingent upon our committing to Schwab any specific amount of business (assets in custody or trading). The products and services we receive from Schwab will generally be used in servicing all of our clients' accounts. Our use of these products and services will not be limited to the accounts that paid commissions to the broker dealer for such products and services. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. 13 | P a g e Directed Brokerage In limited circumstances, and at our discretion, some clients may instruct our firm to use one or more particular brokers for the transactions in their accounts. If you choose to direct our firm to use a particular broker, you should understand that this might prevent us from effectively negotiating brokerage commissions on your behalf. This practice may also prevent our firm from obtaining favorable net price and execution. Thus, when directing brokerage business, you should consider whether the commission expenses, execution, clearance, and settlement capabilities that you will obtain through your broker are adequately favorable in comparison to those that we would otherwise obtain for you. Block Trades We do not combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as "block trading") because we invest primarily in mutual funds which do not trade in blocks. Trade Errors In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. If a trade error results in a profit, you will keep the profit. Mutual Fund Share Classes Mutual funds are sold with different share classes, which carry different cost structures. Each available share class is described in the mutual fund's prospectus. When we purchase, or recommend the purchase of, mutual funds for a client, we select the share class that is deemed to be in the client's best interest, taking into consideration cost, tax implications, and other factors. When the fund is available for purchase at net asset value, we will purchase, or recommend the purchase of, the fund at net asset value. We also review the mutual funds held in accounts that come under our management to determine whether a more beneficial share class is available, considering cost, tax implications, and the impact of contingent deferred sales charges. It is the policy of the firm to seek best execution in all portfolio trading activities for all investment disciplines and products, regardless of whether commissions are charged. This applies to trading in any instrument, security, or contract including equities, bonds, and forward or derivative contracts. The standards and procedures governing best execution are set forth in several written policies. Generally, to achieve best execution, Northstar Financial Planners, Inc. considers the following factors, without limitation, in selecting brokers and intermediaries: • Financial responsibility of the broker- dealer • Execution capability • Order size and market depth • Availability of competing markets and liquidity • Trading characteristics of the security Availability of accurate information • comparing markets • Confidentiality • Reputation and integrity • Responsiveness • Recordkeeping • Ability and willingness to commit capital • Quantity and quality of research received from the broker dealer • Available technology 14 | P a g e • Ability to address current market conditions Northstar Financial Planners, Inc. evaluates the execution, performance, and risk profile of the broker-dealers it uses at least annually. Item 13 Review of Accounts Allen Giese, President of Northstar Financial Planners, Inc., or another qualified representative will monitor your accounts on an ongoing basis and will conduct account reviews at least quarterly and upon your request to ensure that the advisory services provided to you and/or the portfolio mix are consistent with your current investment needs and objectives. Additional reviews may be conducted based on various circumstances, including, but not limited to: • contributions and withdrawals, • year-end tax planning, • market moving events, • security specific events, and/or, • changes in your risk/return objectives. We will provide you with additional or regular written reports in conjunction with account reviews. Reports we provide to you will contain relevant account and/or market-related information such as an inventory of account holdings and account performance, etc. In addition, you will receive trade confirmations and monthly or quarterly statements from your account custodian(s). If you engage our firm for both financial planning and asset management services, we will provide you with a review and update of your financial plan upon your request at no additional fee. If you have only engaged our firm for financial planning services, you may request a review and update of your plan for an additional fee. Item 14 Client Referrals and Other Compensation Charles Schwab & Co., Inc - Institutional We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the referral arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12 Brokerage Practices). We do not receive any compensation from any third party in connection with providing investment advice to you nor do we compensate any individual or firm for client referrals. Please refer to the Brokerage Practices section above for disclosures on research and other benefits we may receive resulting from our relationship with your account custodian. 15 | P a g e Item 15 Custody Your independent custodian will directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other qualified custodian. You will receive account statements from the qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. We will also provide statements to you reflecting the amount of the advisory fee deducted from your account. You should compare our statements with the statements from your account custodian(s) to reconcile the information reflected on each statement. If you have a question regarding your account statement, or if you did not receive a statement from your custodian, contact us immediately at the telephone number on the cover page of this brochure. Standing Letters of Authorization Pursuant to Rule 206(4)-2 (the "Custody Rule"), we have taken steps to have controls and oversight in place to support the no-action letter issued by the SEC on February 21, 2017 (the "SEC no-action letter"). With respect to third party standing letters of authorization ("SLOA") where a client may grant us the authority to direct custodians to disburse funds to one or more third party accounts, we are deemed to have limited custody. However, we are not required to comply with the surprise examination requirement of the Custody Rule if we are otherwise in compliance with the seven requirements set forth in the February 21, 2017, no-action letter. To the extent we act pursuant to a SLOA, we shall comply with these seven requirements. 1. 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. 2. 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. 3. 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. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. 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 party contained in the client’s instruction. 6. 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. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. 16 | P a g e Item 16 Investment Discretion Before we can buy or sell securities on your behalf, you must first sign our discretionary management agreement, a limited power of attorney, and/or trading authorization forms. You must grant our firm discretion over the selection and number of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. You may specify investment objectives, guidelines, and/or impose certain conditions or investment parameters for your account(s). For example, you may specify that the investment in any particular stock or industry should not exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions in the securities of a specific industry or security. Please refer to the "Advisory Business" section in this Brochure for more information on our discretionary management services. Item 17 Voting Client Securities We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitation to vote proxies. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit. Moreover, we do not determine whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf. Item 18 Financial Information Balance Sheet Requirement We are not the qualified custodian for client funds or securities and nor do we require prepayment of fees of more than $1,200 per Client, six (6) months or more in advance. Financial Condition We do not have any financial impairment that would preclude our firm from meeting contractual commitments to clients. Bankruptcy Petition Our firm has not been the subject of a bankruptcy petition at any time during the last 10 years. 17 | P a g e Privacy Notice Facts WHAT DOES NORTHSTAR FINANCIAL PLANNERS INC (“NFP”) DO WITH YOUR PERSONAL INFORMATION? Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. The types of personal information we collect, and share depend on the product or service you have with us. This information can include: What? ● Social Security number and income ● Account balances and payment history ● Credit history and credit scores How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons we choose to share; and whether you can limit this sharing. Reasons we can share your personal information Do we share? Can you limit this sharing? Yes No For our everyday business purposes - such as to process your transactions, maintain your accounts(s), respond to court orders and legal investigations, or report to credit bureaus Yes No For our marketing purposes - to offer our products and services to you For joint marketing with other financial companies No Not Applicable Yes No For our affiliates’ everyday business purposes – information about your transactions and experiences No Not Applicable For our affiliates’ everyday business purposes – information about your creditworthiness For our affiliates to market to you No Not Applicable For non-affiliates to market to you No Not Applicable *Mail the form below. Please note: To limit our sharing If you are a new customer, we can begin sharing your information from the date you received this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Questions? Call 954-693-0030 Who we are Who is providing this notice? Northstar Financial Planners Inc. (“NFP”) What we do How does NFP protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards, secured files, and buildings. We collect your personal information, for example, when you How does NFP collect my personal information? ● Open an account Federal law gives you the right to limit only. ● Sharing for affiliates’ everyday business purposes—information about your creditworthiness Why can’t I limit all sharing? ● Affiliates from using your information to market to you. ● Sharing for non-affiliates to market to you State laws and individual companies may give you additional rights to limit sharing. Your choices will apply to everyone on your account—unless you tell us otherwise. What happens when I limit sharing for an account I hold jointly? Definitions Affiliates Companies related by common ownership or control. They can be financial and non- financial companies. Non-affiliates Companies not related by common ownership or control. They can be financial and non- financial companies. Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Mail-in this section Mark any you want to limit: • Do not share information about my creditworthiness with your affiliates for their everyday business purposes. • Do not allow your affiliates to use my personal information to market to me. If you have a joint account, your choice(s) will apply to everyone on your account unless you mark below. Name • Apply only to me Address Mail to: 1250 S. Pine Island Road, Suite 275 Plantation, Florida 33324 Phone Number 19 | P a g e