PACIFIC FINANCIAL ADVISORS

ITEM 1. COVER PAGE PACIFIC FINANCIAL ADVISORS, INC. FIRM BROCHURE (ADV PART 2A) APRIL 24, 2026 Pacific Financial Advisors, Inc. 11400 SE 8th Street, Suite 460 Bellevue, WA 98007 Phone: (425) 458-3292 This brochure provides information about the qualifications and business practices of Pacific Financial advisers, Inc. If you have any questions about its content, please contact us at (425) 458-3292. The following information has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration as an investment adviser does not imply any level of skill or training. Additional information about Pacific Financial Advisors, Inc. is available on the SEC’s website: www.adviserinfo.sec.gov.  ITEM 2. MATERIAL CHANGES - We have discontinued offering financial planning services on an hourly fee basis. - Since filing our annual updating amendment in March 2026, we have submitted an application to transition from state registration to SEC registration. Accordingly, we have made changes throughout this brochure to reflect differences in state and SEC regulatory requirements. Pacific Financial Advisors, Inc. Page 2 ADV Part 2A  Item 1. Cover Page ........................................................................................................................................... 1 Item 2. Material Changes ................................................................................................................................. 2 Item 4. Advisory Business ............................................................................................................................... 4 Item 5. Fees and Compensation ....................................................................................................................... 5 Item 6. Performance-Based Fees and Side-by-side management .................................................................... 6 Item 7. Types of Clients ................................................................................................................................... 6 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 6 Item 9. Other Financial Industry Activities and Affiliations ......................................................................... 10 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................. 11 Item 12. Brokerage Practices ......................................................................................................................... 11 Item 13. Review of Accounts......................................................................................................................... 14 Item 14. Client Referrals and Other Compensation ....................................................................................... 15 Item 15. Custody ............................................................................................................................................ 15 Item 16. Investment Discretion ...................................................................................................................... 15 Item 17. Voting Client Securities................................................................................................................... 16 Item 18. Financial Information ...................................................................................................................... 16 Pacific Financial Advisors, Inc. Page 3 ADV Part 2A  ITEM 4. ADVISORY BUSINESS OWNERSHIP/ADVISORY HISTORY Ross Sean Wolf (“Mr. Wolf”) is the sole shareholder of Pacific Financial Advisors, Inc. (the “adviser,” “we,” “our,” “us”), which was registered as an investment adviser in Washington on August 23, 2010. In 2026, we transitioned to SEC registration. ADVISORY SERVICES OFFERED Pacific Financial Advisors, Inc. provides discretionary portfolio management and financial planning services to its clients. TAILORED SERVICES The adviser’s services are individualized to each client, and the client may impose reasonable restrictions on the management of his/her accounts, i.e. to avoid certain asset classes or industries. WRAP PROGRAM The adviser does not sponsor a wrap program. This section is not applicable. CLIENT ASSETS MANAGED The adviser manages all client assets on a discretionary basis. Financial Planning Services Financial planning services are offered to all clients. Financial planning services include but are not limited to a thorough review of all applicable topics including wills, estate plan/trusts, investments review, tax review, income planning, retirement planning, and insurance. Insurance Planning Services and Insurance Purchase Recommendations The adviser provides clients with insurance planning services. Insurance planning services include, but are not limited to, a thorough review of all applicable topics including beneficiary liquidity needs, life insurance and annuities and are offered on a commission basis that is set by the insurance carriers. All insurance and annuity recommendations are based upon the individual’s goals, objectives, and risk tolerance. Pacific Financial Advisors, Inc. is under common ownership with an insurance planning firm, Pacific Insurance Advisors, LLC (“PIA”). Clients seeking assistance with insurance purchases are referred to PIA but are not obligated to use our affiliated insurance firm’s services. A conflict of interest arises when clients choose to use PIA because of the additional revenue earned when clients purchase an insurance product recommended by Pacific Financial Advisors. All fees for services provided by PIA are paid in the form of customary commissions paid by the insurance carrier in connection with the purchase of a specific insurance product. Pacific Financial Advisors, Inc. receives no compensation or referral fees from insurance sales by its affiliate. Mortgage Planning and Mortgage Brokerage Services The adviser provides clients with mortgage planning services. Mortgages, primarily reverse mortgages, are offered through our affiliate on a commission basis that is set by the lender, FHA or HUD. Services include the review and analysis of the client’s needs and recommendations are based upon the individual’s goals, Pacific Financial Advisors, Inc. Page 4 ADV Part 2A  objectives, and risk tolerance. Pacific Financial Advisors, Inc. is under common ownership with a licensed mortgage broker, Pacific Mortgage Advisors, Inc. (“PMA”). Clients seeking assistance with mortgage brokerage services are referred to PMA but are not obligated to use our affiliate. A conflict of interest arises when Pacific Financial Advisors recommend the use of its affiliate and clients choose to use PMA because of the additional revenue PMA and Mr. Wolf will earn. All fees for services provided by PMA are disclosed to clients and Pacific Financial Advisors, Inc. receives no compensation for the referral. See Item 10 for more information. Investment Management Services The adviser provides clients with ongoing portfolio management services on a discretionary basis based upon the individual’s investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. Investment products may include the following: ➢ Common stock of companies with various market capitalizations ➢ Passive/index-oriented exposures ➢ Actively managed mutual funds or exchange-traded funds ➢ Illiquid alternative investments (hedge funds, private equity partnerships, real estate partnerships and funds of funds) ➢ Other types of securities (structured notes, buffered ETFs, convertible securities, preferred stock, leveraged ETFs) ITEM 5. FEES AND COMPENSATION Fees for these services will be based on a percentage of assets under management as follows: Assets Under Management $0 - $2,000,000 $2,000,001+ Annual Fee 1.0 - 2.00% 0.85 - 1.5% Where we have allocated some or all of your assets to another adviser on a sub-advisory basis, we pass that adviser’s fees on to you, in addition to charging our own advisory fees. Clients receive a copy of the other adviser’s ADV 2A disclosure brochure when we choose to have them manage assets on a sub-advisory basis. We limit all-in advisory fees (Pacific Financial plus the third-party manager fees, if applicable) to 2% annually. OTHER FEES We provide financial planning to clients who have engaged us for investment management. In most cases, no additional fees apply. Clients may, however, choose to engage us for standalone financial planning on a negotiable fixed fee basis based on complexity and unique client needs. Financial plans will be completed and delivered within six months. In some cases, existing management clients may have a specific planning Pacific Financial Advisors, Inc. Page 5 ADV Part 2A  need outside the scope of the planning services we tend to assume. Where this applies, we may negotiate a separate planning agreement that will describe the services and additional related fees. Accounts within the same household may be combined for a reduced fee. Fees are negotiable and are billed monthly in arrears based on the amount of assets managed as of the close of business on the last business day of each month. All fees deducted from the custodial account will be reflected on the custodian’s statement provided to clients at least quarterly. We urge clients to carefully review the statement and to notify us promptly of any discrepancies. Clients may terminate advisory services with 30 days written notice. The adviser will be entitled to a pro rata fee for the days services were provided during the final month. CLIENT RESPONSIBILITY FOR THIRD PARTY FEES In addition to the advisory fees paid to the adviser, clients may also incur certain charges imposed by other third parties, such as third-party investment advisers, broker-dealers, custodians, trust companies, banks and other financial institutions. These additional charges may include securities brokerage commissions, transaction fees, custodial fees, management and performance fees charged by independent investment managers, margin costs, charges imposed directly by a mutual fund or ETF in a client's account, as disclosed in the fund's prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT The Adviser does not charge performance-based fees and this section is not applicable. ITEM 7. TYPES OF CLIENTS The adviser’s services are offered to individuals, trusts, estates, and charitable organizations. The adviser does not have a minimum account size or have any conditions for managing an account. ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS METHODS OF ANALYSIS AND INVESTMENT STRATEGIES The adviser uses the following methods of analysis: Fundamental Analysis – Fundamental analysis is a technique that attempts to determine a security’s value by focusing on underlying factors that affect a company's actual business and its future prospects. The analysis is performed on historical and present data. On a broader scope, one can perform fundamental analysis on industries or the economy. Technical Analysis – Technical analysis is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. Cyclical Analysis – Cyclical analysis is a method of evaluating business or economic cycles. The broad economy or its segments have been shown to move in cycles. The cyclical analyst looks for those cycles in which to invest. Pacific Financial Advisors, Inc. Page 6 ADV Part 2A  In addition to the Methods of analysis the adviser uses the following Investment Strategies: • Long term purchases (securities held at least a year) • Short term purchases (securities sold within a year) • Trading (securities sold within 30 days) • Margin transactions • Option writing, including covered options, uncovered options or spreading strategies INVESTMENT RISKS All investments bear different types and degrees of risk and investing in securities involves risk of loss that clients should be prepared to bear. While the adviser recommends investment strategies that are designed to provide appropriate investment diversification, some investments have significantly greater risks than others. Obtaining higher rates of return on investments entails accepting higher levels of risk. Recommended investment strategies seek to balance risks and rewards to achieve investment objectives. Clients need to ask questions about risks they do not understand. The adviser would be pleased to discuss them. The adviser strives to render its best judgment on behalf of its clients but cannot assure or guarantee clients that investments will be profitable or assure that no losses will occur in an investment portfolio. Past performance is an important consideration with respect to any investment or investment adviser but is not a reliable predictor of future performance. The adviser continuously strives to provide outstanding long-term investment performance, but many economic and market variables beyond its control can affect the performance of an investment portfolio. a. RECOMMENDED SECURITIES AND THEIR RISKS The adviser recommends several types of securities to its clients. These include but are not limited to mutual funds, stocks, bonds, warrants, certificates of deposit, commercial paper, municipal securities, variable life insurance, variable annuity, options, commodities, government securities, real estate limited partnerships and exchanges traded funds. An investment in a security could lose money over short or even long periods. A client should expect his/her account value and returns to fluctuate within a wide range, like the fluctuations of the overall stock and bond markets. The risks associated with the recommended securities include but are not limited to: Stock market risk: The chance that stock prices overall will decline. Stock markets tend to move in cycles, with periods of rising stock prices and periods of falling stock prices. Interest rate risk: The chance that bond prices overall will decline because of rising interest rates. Manager risk: The chance that poor security selection will cause a mutual fund or other managed product to underperform relevant to benchmarks or other securities products with similar investment objectives. Active management fees risk: Active management strategies that involve frequent trading generate higher transaction costs which diminish the fund's return. In addition, the short-term capital gains Pacific Financial Advisors, Inc. Page 7 ADV Part 2A  resulting from frequent trades often have an unfavorable income tax impact when such funds are held in a taxable account. International Investing Risk: Investing in the securities of non-U.S. companies involves special risks not typically associated with investing in U.S. companies. Foreign securities tend to be more volatile and less liquid than investments in U.S. securities, and may lose value because of adverse political, social or economic developments overseas or due to changes in the exchange rates between foreign currencies and the U.S. dollar. In addition, foreign investments are subject to settlement practices, as well as regulatory and financial reporting standards, that differ from those of the U.S. Cyclical Investment Risk: The risk of business cycles or other economic cycles adversely affecting the returns of an investment, an asset class or an individual company’s profits. Cyclical risks exist because the broad economy has been shown to move in cycles – periods of peak performance followed by a downturn, then a trough of low activity. Between the peak and trough of a business or other economic cycle, investments may fall in value to reflect the uncertainty surrounding future returns as compared with the recent past. Liquidity Risk: The adviser may recommend insurance or annuity products that have surrender charges for early withdrawal. This means the client would pay a penalty for withdrawing their funds prior to the conclusion of the surrender period. Clients are urged to read each insurance and annuity policy carefully and ask questions about the policy’s surrender period and charges. Generally speaking, most annuities include the right to surrender 10% of the annuities account value without any surrender charge. Mutual Funds: Mutual funds are pooled investments that hold multiple securities. Shareholders own a fractional interest in that pool of securities. Mutual funds are priced once a day based on the net asset value of the fund’s holdings. Investing in mutual funds generally carries the risk of the underlying holdings. For equity funds that own stocks, key risks are capital loss, business risk, and systematic market risk. Bond funds provide diversification and liquidity while individual bonds offer a fixed maturity date and guaranteed principal return. Bonds funds, similar to individual bonds, are affected by changes in interest rates and will decline in price when interest rates rise. All mutual funds are subject to management fees and other expenses that lower investment returns. Shareholders are subject to taxes on capital gains realized by the fund, not just gains on their personal holdings. Exchange-traded Funds (ETFs): ETFs are also pooled investment vehicles but they trade on an exchange and are somewhat more tax-efficient that mutual funds. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). An ETF is an investment fund traded on stock exchanges, similar to stocks. They often attempt to track the performance of a specific index (such as the S&P 500), or a basket of assets such as a group of industry, country-focused, or other sector-specific stocks. The risks of owning an ETF generally reflect the risks of owning the underlying securities they are designed to track, although lack of liquidity in an ETF could result in its price being more volatile than the underlying securities. ETFs are subject to management fees that increase their costs. They are also subject to other risks, including (i) the risk that the ir prices may not correlate perfectly with changes in the underlying index (tracking error); and (ii) the risk of possible trading halts and related illiquidity due to market conditions or other reasons that would make trading inadvisable in the view of the listing exchange, Other areas of concern include possible lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Buffered ETFs are a type of ETF funds that use options to track the performance of an index. They don't actually own stocks or bonds. Investors forgo some potential returns for Pacific Financial Advisors, Inc. Page 8 ADV Part 2A  protection against some losses. The expense ratios of these ETFs may be relatively high, which will lower returns over time. Over extended periods, they may not perform much differently than a typical balanced portfolio of 60% equities and 40% fixed income. They also may tend to sacrifice upside more than they protect on the downside. We use our judgment to select buffered ETFs that we think offer the most potential value. Structured Notes: These are hybrid securities that involve a debt obligation by the issuing financial institution, as well as an embedded derivative (option) component. They usually have a limited secondary market and are therefore relatively illiquid. This means you may not be able to sell them if you wish to— including if the market price is declining significantly—and may have to hold the security to maturity or sell to the issuer at significantly depressed prices. They should always be considered a long-term investment. Because structured notes are individually developed, they have a range of characteristics, features, and objectives. It is important to understand the specific features of the structured note used in any given portfolio. Some of the general risks of structured notes include the fact that they do not pay interest and do not repay a fixed amount of principal at maturity. Instead, your payment at maturity will depend on the underlying performance metrics established by the issuing company when they create the structured note. For example, a structured note may repay principal based on the relative performance of the S&P 500 index during a particular period when compared to some stated return. In general, returns and losses may be limited to a certain performance band. If this applies, it can limit upside as well as downside, but usually only within specified bands or caps. Once those bands have been exceeded, downside is likely not limited (or less limited), while upside continues to be limited. In general, the issuing company will structure the note to protect itself first. Unlike in a mutual fund or ETF that tracks an index, where dividends are typically reinvested, indices used for structured notes often exclude dividends and therefore usually have a lower return than the comparable index that shows dividends reinvested. Structured notes are also subject to credit risk as the financial institution sponsoring the structured note covers the obligations based on their promise to meet them, not subject to collateral or other forms of protection. Some structured notes have call provisions that permit the sponsor to redeem them (buy them back) prior to maturity and regardless of price. Structured notes have built in expenses to pay the issuing company to compensate them for the financial risk they’re taking on, as well as the issuance, hedging, and distribution costs. Annuities: Annuities are contracts issued by a life insurance company designed to meet retirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks; just as mutual funds do. Options: Options are a form of derivative, in that derive their value from an underlying asset, such as a stock. They are contracts to purchase or sell a security at a given price. Depending on the strategy used and whether the investor buys a long option or sells a short option, they can be used to hedge a position or portfolio, generate income, or speculate about future prices. Options can pose significant risks depending on the type and strategy and can also generate significant trading costs. Options have expiration dates and can expire worthless. We do not generally purchase options for clients, though they may be used in ETFs we hold in client portfolios. , Pacific Financial Advisors, Inc. Page 9 ADV Part 2A  Clients need to ask questions about risks they do not understand. The adviser would be pleased to discuss them. 6. DISCIPLINARY INFORMATION Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events in the past ten years that would be material to your evaluation of the Firm or the integrity of its management unless the event was resolved in the Firm or management person’s favor. Pacific Financial advisers, Inc. and Mr. Wolf have no information applicable to this Item. ITEM 9. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS BROKER-DEALER AFFILIATIONS The adviser and Mr. Wolf, President, are not affiliated with a broker-dealer. FUTURES/COMMODITIES FIRM AFFILIATION The adviser and Mr. Wolf, President, are not affiliated with a futures or commodities broker. OTHER INDUSTRY AFFILIATIONS Mr. Wolf is the owner of Pacific Insurance Advisors, LLC. (“PIA”). PIA is a licensed insurance agency authorized to sell life and health insurance. Mr. Wolf is a licensed independent life and health insurance agent. He is appointed to sell insurance with various insurance companies that are duly licensed in the State of Washington and is also an affiliated agent of PIA. Other advisory representatives of Pacific Financial Advisors are also affiliated with PIA and may recommend insurance products as both advisory representatives and insurance producers. In general, when a Pacific Financial Advisors representative recommends insurance, the insurance producer will receive customary commissions, and PIA will also receive a portion of the commission. Clients are not required to purchase insurance products we recommend through Mr. Wolf or other investment advisory representatives associated with Pacific Financial Advisors. They are free to implement our insurance recommendations through unaffiliated insurance agents. Additional information related to insurance recommendations can be found on the individual’s ADV Part 2B brochure supplement. Mr. Wolf is the owner of Pacific Mortgage Advisors, Inc. (PMA). PMA is a licensed mortgage broker in the State of Washington and Mr. Wolf is the only authorized representative of PMA. PMA and Mr. Wolf will earn commissions if clients choose to use the services of PMA and successfully obtain a mortgage and our recommendation of this affiliate creates a conflict of interest. Recommendations that clients use Mr. Wolf’s affiliated businesses create a conflict of interest because both Mr. Wolf and the entities he owns receive commissions for these services, which are separate from and in addition to Pacific Financial Advisors’ investment advisory fee described in Section 5. Mr. Wolf mitigate the conflict of interest by recommending the use of insurance or mortgage brokerage services only when he believes that to be in the best interest of the client; by disclosing the conflict; and by notifying clients they are free to implement his insurance or mortgage recommendations through unaffiliated providers. SELECTION OF THIRD-PARTY INVESTMENT ADVISERS Pacific Financial Advisors, Inc. Page 10 ADV Part 2A  On occasion the adviser may recommend the services of a third-party investment adviser to a client. When recommending the services of a third-party investment adviser, clients will be given a copy of its Form ADV Part 2A. Clients are encouraged to read and understand this disclosure document. ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING DESCRIPTION The adviser’s Code of Ethics covers all supervised persons, and it describes its high standard of business conduct, and fiduciary duty to its clients. All supervised persons must acknowledge the terms of the Code of Ethics annually, or as amended. A copy of Code of Ethics is available upon request. MATERIAL INTEREST IN SECURITIES The adviser does not recommend the purchase or sale of securities in which they have a material financial interest. INVESTING IN OR RECOMMENDING THE SAME SECURITIES The adviser and its personnel may buy or sell – for their personal account(s) - investment products identical or different than those recommended to clients. It is the general policy of the adviser that no person employed by the adviser may purchase or sell any security prior to a transaction(s) being implemented for an advisory account. On occasion, circumstances may arise where different trading programs or time horizons could have advisers (or individuals associated with the adviser) assuming a trading position before or after the client(s), transaction that may or may not be the same or is counter to those of advisory accounts. All positions are reviewed in an effort to prevent such employees from benefiting from transactions placed on behalf of advisory accounts. The adviser will always act in the client’s best interest and in accordance with the adviser’s fiduciary duty. ITEM 12. BROKERAGE PRACTICES RECOMMENDATION CRITERIA When the adviser recommends brokers or custodians, it will seek broker dealers who offer timeliness of execution, timeliness and accuracy of trade confirmations, research services, ability to provide investment ideas, execution facilitation services, record keeping services, custody services, frequency and correction of trading errors, ability to access a variety of market venues, expertise as it relates to specific securities, financial condition, business reputation and quality of services. The adviser recommends Charles Schwab & Co., Inc. (“Schwab”). A client’s choice of another broker-dealer is acceptable if proven feasible. The adviser recognizes its fiduciary responsibility in negotiating brokerage commissions, assuring best execution practices, and assuring adequate investment availability/inventory on behalf of its clients. With the use of independent broker-dealers, a client may incur a ticket charge or sales commission for the sale or purchase of securities. The adviser does not receive any portion of the ticket charge or sales commission from Schwab. Pacific Financial Advisors, Inc. Page 11 ADV Part 2A  How We Select Brokers/Custodians We seek to recommend a custodian/broker that will hold client assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. We consider a wide range of factors, including: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for the account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, ETFs, etc.) and financial services for Clients (banking, lending, etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate prices • Reputation, financial strength, security and stability • Dedicated service team and local personnel • Prior service to us and our clients • Availability of other products and services that benefit us, as discussed below We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. Your Brokerage and Custody Costs Schwab generally does not charge clients separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Schwab is also compensated by earning interest on the uninvested cash in Schwab’s Cash Features Program or on any margin balance maintained in Schwab accounts, and from other ancillary services. Most trades no longer incur commissions or transaction fees, though there are exceptions. Schwab discloses its fees and costs to clients, and we take those costs into account when executing transactions on your behalf. Schwab charges you a flat dollar amount as “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities purchased, or the funds from the securities sold, are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. Certain mutual funds and ETFs are made available for no transaction fee; as a result the confirmation may show “no commission” for a particular transaction. Typically the custodian (but not Pacific Financial Advisors) earns additional remuneration from such services as recordkeeping, administration, and platform fees, for the funds and ETFs on their no-transaction fee lists. This additional revenue to the custodian will tend to increase the internal expenses of the fund or ETF. We select investments based on our assessment of a number of factors, including liquidity, asset exposure, reasonable fees, effective management, and low Pacific Financial Advisors, Inc. Page 12 ADV Part 2A  execution cost. Where we choose a no-transaction fee fund or ETF, it is because it has met our criteria in all applicable categories. Products and Services Available to Pacific Financial Advisors from Schwab Schwab Advisor ServicesTM is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to their institutional broker services (trading, custody, reporting, and related services), some of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available without our requesting them and at no charge to us. Following is a more detailed description of these services: Services that Benefit Clients Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment, lending, and banking products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher cost or higher minimum initial investment by our clients. These services generally benefit you and your account. Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including If we had accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting Services that Generally Benefit Only Pacific Financial Advisors Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support • Occasional business entertainment of our personnel Pacific Financial Advisors, Inc. Page 13 ADV Part 2A  Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. We make limited use of the services in this section. We are most likely to use compliance and technology consulting and to attend conferences and other educational events, some of which include business entertainment. Pacific Financial Advisors’ Interest in Schwab’s Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them, and we don’t have to pay Schwab for them. This creates an incentive for us to recommend that clients maintain their accounts with Schwab, based on our interest in receiving Schwab’s services that benefit our business rather than based on clients’ interest in receiving the best value in custody services and the most favorable execution of their transactions. While this incentive creates a conflict of interest, we believe that our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We Select Brokers/Custodians”) and not Schwab’s services that benefit only us. RESEARCH AND SOFT DOLLARS We do not have any “soft dollar” arrangements, in which we receive research or other products or services other than execution from a broker-dealer or third party in connection with client securities transactions. We do, however, receive various benefits from our relationships with the custodians we recommend solely because we have an institutional agreement with the custodians and our clients choose to hold their assets with those firms. These benefits are described more fully in this section and are generally available to all investment advisers who use the custodians’ institutional platforms. BROKERAGE FOR CLIENT REFERRALS We do not use, recommend, or direct activity to brokers in exchange for client referrals. DIRECTED BROKERAGE Because we typically execute your investment transactions through the custodian holding your assets, we are effectively requiring that you “direct” your brokerage to your custodian, absent other specific instructions as discussed below. Because we are not usually choosing brokers on a trade-by-trade basis, we may not be able to achieve the most favorable executions for clients and this may ultimately cost clients more money. Not all investment advisers require directed brokerage. TRADE AGGREGATION When buying or selling the same security for multiple client accounts at the same time, the adviser may block or group the trades together. This can only happen when all client accounts are with the same custodian. As a result of trading all accounts as a “block,” each client will receive the average price received for the purchase or sale of the security. Additionally, the transaction costs (i.e. brokerage commissions or ticket charges) will be distributed on a prorated basis among the client accounts (unless pro-rating the transaction costs would be unfair under the circumstances). The prorated transaction costs may be lower than had the transaction been completed separately. ITEM 13. REVIEW OF ACCOUNTS PERIODIC REVIEWS Pacific Financial Advisors, Inc. Page 14 ADV Part 2A  Account holdings are reviewed on an ongoing basis. Client portfolios are reviewed no less than quarterly, by Mr. Wolf to ensure that the portfolio allocation continues to be consistent with the client’s financial profile and current objectives, risk tolerance, and cash flow requirements. OTHER REVIEWS Any notification to adviser by client of a change in life status - employment, retirement, marital status or household will trigger an automatic review of the account. Additional reviews are conducted periodically depending on market conditions, economic or political events. REPORTS Clients receive account statements issued by the custodian holding the assets no less than quarterly for managed accounts. Clients also receive confirmations of each transaction in the account from the custodian. If engaged for financial planning, we may provide related reports in connection with the financial planning engagement. ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION OTHER COMPENSATION The adviser utilizes the services of custodial broker dealers. Economic benefits are received by the adviser which would not be received if the adviser did not give investment advice to clients. These benefits include a dedicated trading desk, a dedicated service group and an account services manager dedicated to the adviser’s accounts, ability to conduct “block” client trades, electronic download of trades, balances and positions, duplicate and batched client statements, and the ability to have advisory fees directly deducted from client accounts. CLIENT REFERRALS The adviser does not pay for client referrals or use solicitors. ITEM 15. CUSTODY All client funds, securities and accounts are held at third-party custodians. The adviser does not take possession of a client’s securities. Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains the client’s investment assets. We may also provide financial planning reports that describe client assets. These are not a substitute for your custodian statements. We urge clients to carefully compare statements they receive from us to their custodian statements and notify us promptly of any discrepancies. ITEM 16. INVESTMENT DISCRETION The adviser’s services are discretionary. A discretionary investment account does not require the adviser to receive permission from the client prior to buying and/or selling securities in the client’s account. Clients give us discretionary authority through our investment management agreement, as well as through trading authorizations required by the custodian. We may agree to specific limits on our authority and, if we do so, this will be documented in writing in the client agreement. Pacific Financial Advisors, Inc. Page 15 ADV Part 2A  ITEM 17. VOTING CLIENT SECURITIES The adviser will not be responsible for responding to proxies for securities held in clients' accounts. Proxy solicitation materials will be forwarded to clients for response and voting. In the event a client has a question about a proxy solicitation, the client should contact the adviser. ITEM 18. FINANCIAL INFORMATION The adviser does not require or solicit prepayment of more than $1,200 in fees per client, six or more months in advance. The adviser does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Pacific Financial Advisors, Inc. Page 16 ADV Part 2A