PALADINO WEALTH

Item 1: Cover Page AVIATOR FINANCIAL CONSULTING LLC d/b/a PALADINO WEALTH 700 McCaleb Road, Suite L Montgomery, TX 77316 (936) 444-2583 www.paladinowealth.com March 5, 2026 Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of AVIATOR FINANCIAL CONSULTING LLC d/b/a PALADINO WEALTH. If you have any questions about the contents of this brochure, please contact us at (936) 444-2583 or by email support@paladinowealth.com. 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 AVIATOR FINANCIAL CONSULTING LLC d/b/a PALADINO WEALTH is also available on the SEC’s website at www.adviserinfo.sec.gov. AVIATOR FINANCIAL CONSULTING LLC d/b/a PALADINO WEALTH’s CRD number is: 307799. Aviator Financial Consulting LLC dba Paladino Wealth is a registered investment adviser. Registration as an investment adviser does not imply a certain level of skill or training. i  Item 2: Material Changes The brochure that AVIATOR FINANCIAL CONSULTING LLC d/b/a PALADINO WEALTH last filed with the SEC was dated March 5, 2025. There have been no other material changes since AVIATOR FINANCIAL CONSULTING LLC d/b/a PALADINO WEALTH filed its last brochure. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes .......................................................................................................................... ii Item 3: Table of Contents ......................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................... 2 Item 5: Fees and Compensation ................................................................................................................ 3 Item 6: Performance-Based Fees and Side-By-Side Management ............................................................ 4 Item 7: Types of Clients ............................................................................................................................. 5 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ......................................................... 5 Item 9: Disciplinary Information ............................................................................................................... 9 Item 10: Other Financial Industry Activities and Affiliations ..................................................................... 9 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 10 Item 12: Brokerage Practices .................................................................................................................. 10 Item 13: Review of Accounts ................................................................................................................... 11 Item 14: Client Referrals and Other Compensation ................................................................................ 12 Item 15: Custody ..................................................................................................................................... 13 Item 16: Investment Discretion ............................................................................................................... 13 Item 17: Voting Client Securities (Proxy Voting) ..................................................................................... 13 Item 18: Financial Information ................................................................................................................ 13 iii  Item 4: Advisory Business A. Description of the Advisory Firm AVIATOR FINANCIAL CONSULTING LLC d/b/a Paladino Wealth (hereinafter “AFCL”) is a Limited Liability Company organized in the State of Texas. AFCL was formed in July 2018, and the principal owner is William J. Paladino Jr. B. Types of Advisory Services Portfolio Management Services AFCL offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Portfolio management services include, but are not limited to, the following: Investment strategy Asset allocation Risk tolerance • • • Personal investment policy Asset selection Regular portfolio monitoring • • • AFCL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. AFCL will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement. AFCL seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of AFCL’s economic, investment or other financial interests. To meet its fiduciary obligations, AFCL attempts to avoid, among investment or trading practices that systematically advantage or other things, disadvantage certain client portfolios, and accordingly, AFCL’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is AFCL’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments AFCL generally limits its investment advice to mutual funds, fixed income securities, equities and ETFs (including ETFs in the gold and precious metal sectors). AFCL may use other securities as well to help diversify a portfolio when applicable. 2  C. Client Tailored Services and Client Imposed Restrictions AFCL will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by AFCL on behalf of the client. AFCL may use model allocations, together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. If the client, after entering this agreement instructs AFCL to restrict any investment that AFCL determines is appropriate, AFCL retains the right to terminate this agreement. AFCL may use different model portfolios to aid in the allocation of client’s accounts. The portfolios consider age, employment status, account type, and client’s goals. AFCL may use duplicate account strategies across similar accounts at our discretion. AFCL maintains the right to liquidate and reallocate at any time they feel is best, unless directed otherwise by the client or to meet the client’s needs. D. Wrap Fee Programs AFCL does not participate in any wrap fee programs. E. Assets Under Management AFCL has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 144,147,405 $0.00 December 31, 2025 Item 5: Fees and Compensation Portfolio Management Fees A. Fee Schedule Total Assets Under Management Annual Fees The First $0 - $1,000,000 1.00% The Next $1,000,001 - AND UP 0.75% 3  The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period and certain assets can be excluded from billing. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of AFCL's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 3 days' written notice. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client’s written authorization on a quarterly basis. Fees are paid in advance. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by AFCL. Please see Item 12 of this brochure regarding broker- dealer/custodian. D. Prepayment of Fees AFCL collects fees in advance. If applicable, AFCL will submit a pro-rated refund to the client’s custodian upon notification. The custodian will then be responsible for processing the client’s refund. For all asset-based fees paid in advance, the fee refund will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) Please note, deposits made by the accountholder(s) or on the accountholder(s) behalf, after AFCL quarterly billing period, at AFCL discretion, may be prorated and billed at the time of deposit. E. Outside Compensation for the Sale of Securities to Clients Neither AFCL nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management AFCL does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 4  Item 7: Types of Clients AFCL generally provides advisory services to the following types of clients: Individuals High-Net-Worth Individuals • • AFCL generally has a standard account minimum of $500,000. AFCL retains the right to make an exception to this minimum. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis AFCL’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. AFCL uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies: AFCL uses both short term and long term trading strategies. In approved accounts, AFCL may also trade option strategies allowed by the level of option approval for that account. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 5  B. Material Risks Involved All investment programs possess certain risks of loss that clients should be prepared to bear. AFCL does not offer any products or services that guarantee rates of return on investments for any time period to any client. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks: Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. 6  Investment Strategies Short term trading refers to strategies in which the time duration between entry and exit is within a range of days to a few months. Short term trading can be risky and unpredictable due to the volatile nature of the stock market at times. These risks include but are not limited to economic risk, political/regulatory risk, and adverse price action over a short time frame. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Model portfolios are designed to capture return and risk at market rates. This seeks to provide clients with diversification benefits help to smooth returns, reduce volatility and decrease asset- class and single-strategy risks. Risks specific to using model portfolios include the possibility that the model portfolio will underperform the market and the possibility that the model will not be able take advantage of opportunities that a non- model portfolio management approach might capture. Model portfolios entail inflation (purchasing power) risk, interest rate risk, economic risk, market risk, political/regulatory risk, and asset allocation risk – meaning that any given asset allocation strategy does not guarantee any specific result or profit nor protect against a loss. Options transactions: AFCL primarily utilizes option strategies that have similar risk exposure to purchasing the underlying security (cash-secured put), or having a held security possibly sold at a pre- determined price (covered call). There is a risk of loss with this type of investment. AFCL may utilize more aggressive, speculative option trading strategies including buying, selling, or a combination of buying/selling option instruments in approved speculative accounts. These aggressive strategies involve substantial risk, including a complete loss of principal. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. 7  Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. 8  Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. Self-regulatory Organization (SRO) Proceedings C. There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither AFCL nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither AFCL nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither AFCL nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections AFCL does not utilize nor select third-party investment advisers. 9  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics AFCL has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. AFCL's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests AFCL does not recommend that clients buy or sell any security in which a related person to AFCL or AFCL has a material financial interest. Investing Personal Money in the Same Securities as Clients C. From time to time, representatives of AFCL may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of AFCL to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. AFCL will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of AFCL may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of AFCL to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, AFCL will never engage in trading that operates to the client’s disadvantage if representatives of AFCL buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on AFCL’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and AFCL may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in AFCL's research efforts. AFCL will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. AFCL will require clients to use Schwab Institutional, a division of Charles Schwab & Co., Inc. 10  Research and Other Soft-Dollar Benefits While AFCL has no formal soft dollars program in which soft dollars are used to pay for third party services, AFCL may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). AFCL may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and AFCL does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. AFCL benefits by not having to produce or pay for the research, products or services, and AFCL will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that AFCL’s acceptance of soft dollar benefits may result in higher commissions charged to the client. Brokerage for Client Referrals AFCL receives no referrals from a broker-dealer or third party in exchange for using that broker- dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use AFCL will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts AFCL may aggregate or bunch the securities to be purchased or sold for multiple clients, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for AFCL's advisory services provided on an ongoing basis are reviewed at least quarterly by William J Paladino Jr. or his designee with regard to clients’ respective investment policies and risk tolerance levels. All accounts at AFCL are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of AFCL's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. 11  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) AFCL does not receive any economic benefit, directly or indirectly from any third party for advice rendered to AFCL's clients. With respect to Schwab, AFCL receives access to Schwab’s institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For AFCL client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to AFCL other products and services that benefit AFCL but may not benefit its clients’ accounts. These benefits may include national, regional or AFCL specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of AFCL by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist AFCL in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of AFCL’s fees from its clients’ accounts (if applicable). And assist with back-office training and support functions, record keeping and client reporting. Many of these services generally may be used to service all or some substantial number of AFCL’s accounts. Schwab Advisor Services also makes available to AFCL other services intended to help AFCL manage and further develop it business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange, and/or pay vendors for these types of services rendered to AFCL by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to AFCL. AFCL is independently owned and operated and not affiliated with Schwab. B. Compensation to Non – Advisory Personnel for Client Referrals AFCL does not directly or indirectly compensate any person who is not advisory personnel for client referrals. 12  Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, AFCL will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive account statements from the custodian and should carefully review those statements. Item 16: Investment Discretion AFCL provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, AFCL generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. Item 17: Voting Client Securities (Proxy Voting) AFCL will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet AFCL neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither AFCL nor its management has any financial condition that is likely to reasonably impair AFCL’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years AFCL has not been the subject of a bankruptcy petition in the last ten years. 13