Overview

Assets Under Management: $374 million
Headquarters: MARQUETTE, MI
High-Net-Worth Clients: 134
Average Client Assets: $2 million

Frequently Asked Questions

ROBERTS FINANCIAL SERVICES, LLC charges 1.15% on the first $0 million, 0.95% on the next $1 million, 0.75% on the next $3 million, 0.65% on the next $4 million according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #289856), ROBERTS FINANCIAL SERVICES, LLC is subject to fiduciary duty under federal law.

ROBERTS FINANCIAL SERVICES, LLC is headquartered in MARQUETTE, MI.

ROBERTS FINANCIAL SERVICES, LLC serves 134 high-net-worth clients according to their SEC filing dated February 09, 2026. View client details ↓

According to their SEC Form ADV, ROBERTS FINANCIAL SERVICES, LLC offers financial planning, portfolio management for individuals, pension consulting services, and selection of other advisors. View all service details ↓

ROBERTS FINANCIAL SERVICES, LLC manages $374 million in client assets according to their SEC filing dated February 09, 2026.

According to their SEC Form ADV, ROBERTS FINANCIAL SERVICES, LLC serves high-net-worth individuals and pension and profit-sharing plans. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (ROBERTS FINANCIAL DISCLOSURE BROCHURE & SUPPLEMENTS)

MinMaxMarginal Fee Rate
$0 $500,000 1.15%
$500,001 $1,000,000 0.95%
$1,000,001 $3,000,000 0.75%
$3,000,001 $4,000,000 0.65%
$4,000,001 $10,000,000 0.20%
$10,000,001 and above 0.10%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,500 1.05%
$5 million $34,000 0.68%
$10 million $44,000 0.44%
$50 million $84,000 0.17%
$100 million $134,000 0.13%

Clients

Number of High-Net-Worth Clients: 134
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 73.85
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 1,583
Discretionary Accounts: 1,578
Non-Discretionary Accounts: 5
Minimum Account Size: None

Regulatory Filings

CRD Number: 289856
Filing ID: 2041577
Last Filing Date: 2026-02-09 15:35:12

Form ADV Documents

Primary Brochure: ROBERTS FINANCIAL DISCLOSURE BROCHURE & SUPPLEMENTS (2026-02-09)

View Document Text
B.A. Roberts Financial Services, Inc. d/b/a Roberts Financial Services, Inc Form ADV Part 2A – Disclosure Brochure Effective: February 9, 2026 This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of B.A. Roberts Financial Services, Inc. d/b/a Roberts Financial Services, Inc (“Roberts Financial” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (906) 228-5564. Roberts Financial is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information through Roberts Financial to assist you in determining whether to retain the Advisor. Additional information about Roberts Financial and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 289856. B.A. Roberts Financial Services, Inc. d/b/a Roberts Financial Servcies, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Roberts Financial. For convenience, the Advisor has combined these documents into a single disclosure document. Roberts Financial believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Roberts Financial encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material change has been made to this Disclosure Brochure since the amended filing on August 26, 2025: • B.A. Roberts Financial Services, Inc. has succeeded the Advisor. B.A. Roberts Financial Services, Inc. is organized as a corporation under the laws of the State of Michigan. Please see Item 4 for more information. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of Roberts Financial. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD #289856. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (906) 228-5564. B.A. Roberts Financial Services, Inc. Page 2 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents .................................................................................................................................... 3 Item 4 – Advisory Services ................................................................................................................................... 4 A. Firm Information ............................................................................................................................................................. 4 B. Advisory Services Offered .............................................................................................................................................. 4 C. Client Account Management .......................................................................................................................................... 6 D. Wrap Fee Programs ....................................................................................................................................................... 7 E. Assets Under Management ............................................................................................................................................ 7 Item 5 – Fees and Compensation ......................................................................................................................... 7 A. Fees for Advisory Services ............................................................................................................................................. 7 B. Fee Billing ....................................................................................................................................................................... 8 C. Other Fees and Expenses ............................................................................................................................................. 9 D. Advance Payment of Fees and Termination .................................................................................................................. 9 E. Compensation for Sales of Securities .......................................................................................................................... 10 Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................ 10 Item 7 – Types of Clients ..................................................................................................................................... 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 10 A. Methods of Analysis ..................................................................................................................................................... 10 B. Risk of Loss .................................................................................................................................................................. 11 Item 9 – Disciplinary Information ....................................................................................................................... 12 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 12 A. Code of Ethics .............................................................................................................................................................. 12 B. Personal Trading with Material Interest ........................................................................................................................ 12 C. Personal Trading in Same Securities as Clients .......................................................................................................... 13 D. Personal Trading at Same Time as Client ................................................................................................................... 13 Item 12 – Brokerage Practices ............................................................................................................................ 13 A. Recommendation of Custodian[s] ................................................................................................................................ 13 B. Aggregating and Allocating Trades .............................................................................................................................. 14 Item 13 – Review of Accounts ............................................................................................................................ 14 A. Frequency of Reviews .................................................................................................................................................. 14 B. Causes for Reviews ..................................................................................................................................................... 14 C. Review Reports ............................................................................................................................................................ 14 Item 14 – Client Referrals and Other Compensation ........................................................................................ 15 A. Compensation Received by Roberts Financial ............................................................................................................ 15 B. Compensation for Client Referrals ............................................................................................................................... 15 Item 15 – Custody ................................................................................................................................................ 15 Item 16 – Investment Discretion ......................................................................................................................... 15 Item 17 – Voting Client Securities ...................................................................................................................... 16 Item 18 – Financial Information .......................................................................................................................... 16 Form ADV Part 2B – Brochure Supplement ...................................................................................................... 17 Privacy Policy ...................................................................................................................................................... 24 B.A. Roberts Financial Services, Inc. Page 3 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Item 4 – Advisory Services A. Firm Information B.A. Roberts Financial Services, Inc. d/b/a Roberts Financial Services, Inc. (“Roberts Financial” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Roberts Financial was founded in December 2017 and became a registered investment advisor in March 2018 and then became Roberts Financial Services, LLC in 2025. In 2026, the Advisor is now organized as a corporation under the laws of the State of Michigan. Roberts Financial is owned by Bruce A. Roberts (Principal and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Roberts Financial. For questions relating to this Disclosure Brochure, please contact Bruce Roberts at (906) 228-5564. B. Advisory Services Offered Roberts Financial offers investment advisory services to high-net worth individuals, families, trusts, estates, businesses, retirement plans and broker-dealers (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Roberts Financial fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Roberts Financial provides comprehensive investment management, planning and consulting services tailored to the individual needs of each Client. Investment Advisory Services Roberts Financial provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Roberts Financial works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an appropriate investment strategy. Roberts Financial will then construct an investment portfolio that may include the use of our internal investment management and/or independent managers. Internal Investment Management - Roberts Financial customizes its investment management services for its Clients. Portfolios are primarily constructed using mutual funds, exchange-traded funds (“ETFs”), individual stocks and fixed income securities. The Advisor may also utilize other types of investments, as appropriate, to meet the needs of each particular Client. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. Roberts Financial evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Roberts Financials’ investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. If it is consistent with the Client’s goals, the Advisor may also engage in an investment strategy that utilizes frequent trading in securities, please see Item 8 for more information. Roberts Financial will construct, implement and monitor the Client’s portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Roberts Financial, in its discretion, may redistribute investment allocations to diversify the portfolio. Roberts Financial may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Roberts Financial may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, B.A. Roberts Financial Services, Inc. Page 4 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Roberts Financial accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. Retirement Plan Rollover Recommendations – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client take a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers – When deemed to be in the Client’s best interest, Roberts Financial will recommend to Clients that all or a portion of their investment portfolio be implemented by utilizing one or more unaffiliated money managers or investment platforms (collectively “Independent Managers”). Independent Managers may be sourced directly or accessed through an investment management platform or directly engaged by the Advisor. The Client will be required to enter into a separate agreement with the Independent Manager[s]. Please see Item 10 for additional information. Roberts Financial serves as the Client’s primary advisor and relationship manager. However, the Independent Manager[s] will assume discretionary authority for the day-to-day investment management of those assets placed in their control. Roberts Financial will assist and advise the Client in establishing investment objectives for their account[s], the selection of the Independent Manager[s], and defining any restrictions on the account[s]. Roberts Financial will continue to provide oversight of the Client’s account[s] and ongoing monitoring of the activities of these unaffiliated parties. The Independent Manager[s] will implement the selected investment strategies based on their investment mandates. The Client may be able to impose reasonable investment restrictions on these accounts, subject to the acceptance of these third parties. Roberts Financial does not receive any compensation from these Independent Managers or Investment Platforms, other than its investment advisory fee (described in Item 5). Financial Planning and Consulting Services Roberts Financial will typically provide a variety of financial planning services to Clients as part of the investment advisory engagement or as a separate engagement. Services are offered in several areas of a Client’s financial situation, depending on their goals and, objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to investment planning, retirement planning, estate planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Roberts Financial may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a B.A. Roberts Financial Services, Inc. Page 5 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Roberts Financial provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: Investment Policy Statement (“IPS”) Design and Monitoring Investment Monitoring Services (ERISA 3(21)) • Vendor Analysis • Plan Participant Enrollment and Education Tracking • • • Performance Reporting • Ongoing Investment Recommendation and Assistance • ERISA 404(c) Assistance • Benchmarking Services Roberts Financial also provides communication and education services to the Plan and its Participants, pursuant to the terms of the Advisor’s agreement with each Plan Sponsor: Investment education • Direct Plan Participant contacts by phone, e-mail or letter upon eligibility to promote enrollment • • Regular on-site advisor visits with staff for account updates and reviews • Periodic company-wide employee survey of retirement plan understanding • Customer satisfaction surveys • Periodic Plan Participant group education opportunities Certain of these services are provided by Roberts Financial serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Roberts Financial’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Financial Institution Consulting Services Roberts Financial provides investment consulting services to brokerage customers (herein “Brokerage Customers”) of Mutual Securities, Inc. (herein “MSI”) who provide written consent requesting to receive the Advisor’s consulting services, pursuant to a written agreement with Roberts Financial. Consulting services are strictly provided on products where MSI serves as the broker-dealer. Please see Item 10 – Other Financial Industry Activities and Affiliations for additional details. C. Client Account Management Prior to engaging Roberts Financial to provide investment advisory services, each Client is required to enter into one or more advisory agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – Roberts Financial, in connection with the Client, will develop an investment strategy targeted to achieve the Client’s investment goals and objectives. B.A. Roberts Financial Services, Inc. Page 6 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com • Asset Allocation – Roberts Financial will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – Roberts Financial will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Roberts Financial will provide investment management and ongoing oversight of the Client’s investment portfolio. • Financial Planning and Consulting – For Clients engaging for investment advisory services, the Advisor provides ongoing financial planning and related services regarding the Client’s overall financial situation. D. Wrap Fee Programs Roberts Financial does not manage or place Client assets into a wrap fee program. E. Assets Under Management As of December 31, 2025, Roberts Financial manages approximately $373,879,035 in Client assets, $346,141,631 of which are managed on a discretionary basis and $27,737,404 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client shall sign one or more agreements that detail the responsibilities of Roberts Financial and the Client. A. Fees for Advisory Services Investment Advisory Services Investment advisory fees are paid monthly, in advance of each month, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior month. Investment advisory fees are based on the following tiered schedule: Assets Under Management ($) Annual Rate (%) $0 - $499,999 $500,000 – $999,999 $1,000,000 - $2,999,999 $3,000,000 - $3,999,999 $4,000,000 – $9,999,999 $10,000,000 and Above 1.15% 0.95% 0.75% 0.65% 0.20% 0.10% Certain clients may be subject to a legacy fee schedule that may differ from the one above. The investment advisory fee in the first month of service is prorated from the inception date of the account[s] to the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may have a fixed annual fee or fixed rate fee or a fee schedule that differs from above. The Client’s fees will take into consideration the aggregate assets under management with Advisor. All securities held in accounts managed by Roberts Financial will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuations to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. B.A. Roberts Financial Services, Inc. Page 7 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Use of Independent Managers As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually. Financial Planning and Consulting Services Financial planning and consulting services may be included as part of an overall wealth management engagement or provided as a stand-alone engagement. For separate engagements, financial planning and consulting services are offered at an hourly rate of up to $250 per hour or as a fixed fee engagement. Fees are based on the experience of the person performing the services, the complexity and duration the services to be provided. An estimate for total hours and/or costs will be determined prior to engaging for these services. Retirement Plan Advisory Services Retirement plan advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the retirement plan advisory agreement. Fees are generally based on the market value of assets in the Plan at the end of the prior calendar quarter and charged at an annual rate of up to 0.75%. Fee may also be billed at a fixed annual rate. Financial Institution Consulting Services Roberts Financial receives a consulting fee based on the assets under MSI’s management from Brokerage Customers who have provided written consent to MSI to receive the consulting service from Roberts Financial. The consulting fee is calculated from the assets under MSI’s management as of the end of a calendar quarter period multiplied by an annual rate of 0.65%. The initial fee is paid only after the completion of one full calendar quarter period following the date of the executed agreement with MSI. B. Fee Billing Investment Advisory Services Investment advisory fees will be calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor or delegate shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] for the respective period. The amount due is calculated by applying the monthly rate (annual rate divided by 12) to the total assets under management with Roberts Financial at the end of the prior month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to be deducted by Roberts Financial directly from their accounts held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers For Client accounts implemented through an Independent Manager, the Client’s overall fees will include Roberts Financials’ investment advisory fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager. The Independent Manager will assume the responsibility for calculating the Client’s fees and deducting all fees from the Client’s account[s]. Financial Planning and Consulting Services Financial planning and consulting fees are invoiced up to 50% upon the execution of the financial planning or consulting agreement with the balance due upon completion of the engagement deliverable[s]. B.A. Roberts Financial Services, Inc. Page 8 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Retirement Plan Advisory Services Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. Financial Institution Consulting Services MSI shall pay Roberts Financial for its consulting services on or before thirty (30) days past the end of each calendar quarter. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Roberts Financial, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, if applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The investment advisory fee charged by Roberts Financial is separate and distinct from these custody and execution fees. In addition, all fees paid to Roberts Financial for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Roberts Financial, but would not receive the services provided by Roberts Financial which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Roberts Financial to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Advisory Services Roberts Financial is compensated for its investment advisory services in advance of the month in which services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will promptly refund any unearned, prepaid fees to the Client. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s written consent. Use of Independent Managers In the event that a Client should wish to terminate their relationship with an Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and those third parties. Roberts Financial will assist the Client with the termination and transition as appropriate. Financial Planning and Consulting Services The Advisor is partially compensated for its financial planning and consulting services upon execution of the agreement. Either party may terminate a planning agreement, at any time, by providing written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be responsible for fees based on the hours worked by the Advisor or the percentage of the engagement completed. Any unearned prepaid financial planning fees will be promptly refunded to the Client. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. B.A. Roberts Financial Services, Inc. Page 9 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Retirement Plan Advisory Services Roberts Financial is compensated for its retirement plan advisory services in advance of the quarter in which services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the retirement plan advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will promptly refund any unearned, prepaid fees to the Client. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Institution Consulting Services Either party may terminate the consulting agreement by providing thirty (30) days advance written notice to the other party. The Advisor will be entitled to fees up to the date of termination. E. Compensation for Sales of Securities Roberts Financial does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Certain Advisory Persons are also licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person will earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by an Advisory Person are separate and in addition to advisory fees. This practice presents a conflict of interest because a person providing investment advice on behalf of the Advisor who is also an insurance agent has an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on Client needs. However, Clients are under no obligation, contractually or otherwise, to purchase insurance products through an Advisory Person. Item 6 – Performance-Based Fees and Side-By-Side Management Roberts Financial does not charge performance-based fees for its investment advisory services. The fees charged by Roberts Financial are as described in Item 5 above. Roberts Financial does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Roberts Financial offers investment advisory services to high-net worth individuals, families, trusts, estates, businesses and retirement plans. The amount of each type of Client is available on Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. Roberts Financial does not impose a size for establishing a relationship, but does tailor its services to high-net worth individuals. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Roberts Financial primarily employs fundamental analysis in developing investment strategies for its Clients. Research and analysis from Roberts Financial are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a B.A. Roberts Financial Services, Inc. Page 10 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. As noted above, Roberts Financial generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Roberts Financial will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Roberts Financial may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Roberts Financial will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. B.A. Roberts Financial Services, Inc. Page 11 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events to disclose involving Roberts Financial, or any of its management persons. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 289856. Item 10 – Other Financial Industry Activities and Affiliations Neither the Advisor nor its Supervised Persons has any registrations or affiliations with a futures commission merchant, commodity pool operator or commodity-trading advisor. Financial Institution Consulting Services Roberts Financial has an agreement with MSI to provide investment consulting services to Brokerage Customers, as noted in Item 4 – Advisory Services above. MSI compensates Roberts Financial for providing consulting services to Brokerage Customers who have broker-dealer business placed with MSI. This consulting arrangement does not include assuming discretionary authority over Brokerage Customers’ accounts or the monitoring of securities. These consulting services include a general review of Brokerage Customers’ investment holdings, which will result in Roberts Financial’s Advisory Persons making specific securities recommendations or offering general investment advice. This relationship presents a conflict of interest. These conflicts are mitigated by Brokerage Customers consenting to receive consulting services from Roberts Financial. In addition, Roberts Financial will not accept or bill for additional compensation on asset under MSI’s management, beyond the consulting fees disclosed in Item 5 – Fees and Compensation above. Advisory Persons of the Advisor will not engage or hold itself as a registered representative of MSI, as Advisory Persons are not registered to conduct commission-based activities under a broker-dealer. Insurance Agency Affiliations As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from an Advisory Person's role with the Advisor. As an insurance professional, an Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. An Advisory Person is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by an Advisory Person or the Advisor. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Roberts Financial has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This Code of Ethics applies to all persons associated with Roberts Financial (“Supervised Persons”). The Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Roberts Financial and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Roberts Financial Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code of Ethics covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code of Ethics, please contact the Advisor at (906) 228-5564. B. Personal Trading with Material Interest Roberts Financial allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients. Roberts Financial does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Roberts Financial does not have a material interest in any securities traded in Client accounts. B.A. Roberts Financial Services, Inc. Page 12 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com C. Personal Trading in Same Securities as Clients Roberts Financial allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that Roberts Financial recommends (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted a Code of Ethics, which addresses insider trading (material non-public information controls) and personal securities reporting procedures. When trading for personal accounts, Supervised Persons of Roberts Financial have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by Roberts Financial requiring reporting of personal securities trades by its employees for review by the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Roberts Financial allows the purchase or sale of the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Roberts Financial, or any Supervised Persons of Roberts Financial, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Roberts Financial does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Roberts Financial to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, Roberts Financial does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Roberts Financial does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by and will not incur any extra fee or cost associated with using a Custodian not recommended by Roberts Financial. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. The Advisor may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, its reputation, and/or the location of the Custodian's offices. Roberts Financial will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial Services, Inc. and Fidelity Brokerage Services, Inc. (collectively “Fidelity”), a FINRA-registered broker-dealer and member SIPC. Fidelity will serve as the Client’s “qualified custodian.” Roberts Financial maintains an institutional relationship with Fidelity, whereby the Advisor receives economic benefits from Fidelity. Roberts Financial has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. Access to the Fidelity platform is provided at no charge to the Advisor. The Fidelity platform includes brokerage, custody, administrative support, record keeping, technology, and related services designed to support registered investment advisors like Roberts Financial in serving Clients. These services are intended to serve the best interests of the Advisor’s Clients. Fidelity may charge brokerage commissions (securities transaction fees) for effecting certain securities transactions. Fidelity enables the Advisor to obtain certain no-load mutual funds without securities transaction fees and other no-load funds at nominal transaction charges. Fidelity’s commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees B.A. Roberts Financial Services, Inc. Page 13 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. Please see Item 14 below for additional information. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Roberts Financial does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor does receive certain economic benefit from Fidelity as described in Item 14 below. 2. Brokerage Referrals - Roberts Financial does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Roberts Financial will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s], unless instructed otherwise by the Client. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Roberts Financial will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Roberts Financial will execute its transactions through the Custodian as designated by the Client, unless otherwise instructed. Roberts Financial may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisor Persons of Roberts Financial and periodicially by its CCO. Formal reviews are generally conducted at least annually or more or less frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Roberts Financial if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage B.A. Roberts Financial Services, Inc. Page 14 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Roberts Financial Roberts Financial may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Roberts Financial may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform As noted in item 12, Roberts Financial has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Fidelity. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor’s recommendation of this Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. B. Compensation for Client Referrals Roberts Financial does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Item 16 – Investment Discretion Roberts Financial generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Roberts Financial. Discretionary authority will only be authorized upon full disclosure to the Client. The granting B.A. Roberts Financial Services, Inc. Page 15 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Roberts Financial will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Roberts Financial accepts proxy-voting responsibility for securities held in Client accounts when provided by the Client. The advisory agreement between Roberts Financial and the Client will generally specify whether or not Roberts Financial has the authority to vote proxies on behalf of a particular Client. Proxy Voting Policy and Procedures Roberts Financial shall vote proxies in the best interest of its Clients and shall not subrogate the Client interest to its own. Roberts Financial monitors corporate actions through the Custodian. Roberts Financial receives notice of upcoming proxy votes, meeting and record dates and other information on upcoming corporate actions by companies in which Roberts Financial Clients are shareholders. Clients may request a copy of Roberts Financial’s proxy voting records, free of charge, by contacting Roberts Financial. Conflicts of Interest in the Voting Process On occasion, a conflict of interest may exist between the Advisor and the Client regarding the outcome of certain proxy votes. In such cases, the Advisor is committed to resolving the conflict in the best interest of the clients before the Advisor votes the proxy in question. Client Direction of Voting Although most Clients for whom Roberts Financial votes proxies authorize the Advisor to vote in accordance with its proxy voting policy, a Client may request that the Advisor vote its proxies in accordance with a different policy. In such instances, Roberts Financial seeks to accommodate such requests. Additionally, a Client may direct the Advisor to vote its securities in a particular way on a particular proposal and Roberts Financial will seek to do so, assuming timely receipt of the instruction. Item 18 – Financial Information Neither Roberts Financial, nor its management, have any adverse financial situations that would reasonably impair the ability of Roberts Financial to meet all obligations to its Clients. Neither Roberts Financial, nor any of its Advisory Persons, has been subject to a bankruptcy or financial compromise. Roberts Financial is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. B.A. Roberts Financial Services, Inc. Page 16 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Roberts Financial Services, Inc. Form ADV Part 2B – Brochure Supplement for Bruce A. Roberts, CFP® Principal and Chief Compliance Officer Effective: February 9, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Bruce A. Roberts, CFP® (CRD# 2345101) in addition to the information contained in the B.A. Roberts Financial Services, Inc. d/b/a Roberts Financial Services, Inc. (“Roberts Financial” or the “Advisor”, CRD# 289856) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Roberts Financial Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (906) 228-5564. Additional information about Mr. Roberts is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2345101. B.A. Roberts Financial Services, Inc. Page 17 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Item 2 – Educational Background and Business Experience Bruce A. Roberts, born in 1969, is dedicated to advising Clients of Roberts Financial as a Principal and the Chief Compliance Officer. Mr. Roberts earned a Bachelor’s Degree in Economics and Public Administration from Northern Michigan University. Additional information regarding Mr. Roberts’s employment history is included below. Employment History: 01/2018 to Present 01/2009 to 01/2018 Principal and Chief Compliance Officer, B.A. Roberts Financial Services, Inc. d/b/a Roberts Financial Services, Inc. Financial Advisor, Sagepoint Financial, Inc. (also doing business as BA Roberts Financial Services Inc.) Agent, AIG American General Life Insurance Company Investment Advisor Representative, AIG Financial Advisors, Inc. Registered Representative, American General Securities Incorporated 10/2002 to 01/2018 01/2008 to 01/2009 10/2002 to 10/2008 CERTIFIED FINANCIAL PLANNER™ (“CFP®”) The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP® Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP® Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. B.A. Roberts Financial Services, Inc. Page 18 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP® Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Roberts. Mr. Roberts has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Roberts. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Roberts. However, we do encourage you to independently view the background of Mr. Roberts on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2345101. Item 4 – Other Business Activities Circle of Trust Properties Mr. Roberts is the general manager of Circle of Trust Properties, located at 989 W. Washington Street, Suite 101 in Marquette, MI since July of 2013. It is an Inc. that owns the property where his office is located. It is not investment related. Item 5 – Additional Compensation Mr. Roberts has additional business activities that are detailed in Item 4 above. Item 6 – Supervision Mr. Roberts serves as a Principal and the Chief Compliance Officer of Roberts Financial. Mr. Roberts can be reached at (906) 228-5564. Roberts Financial has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting their fiduciary obligations to Clients of Roberts Financial. Further, Roberts Financial is subject to regulatory oversight by various agencies. These agencies require registration by Roberts Financial and its Supervised Persons. As a registered entity, Roberts Financial is subject to examinations by regulators, which may be announced or unannounced. Roberts Financial is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. B.A. Roberts Financial Services, Inc. Page 19 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Roberts Financial Services, Inc. Form ADV Part 2B – Brochure Supplement for Jessica F. Kinonen Financial Advisor Effective: February 9, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Jessica F. Kinonen (CRD# 6083485) in addition to the information contained in the B.A. Roberts Financial Services, Inc. d/b/a Roberts Financial Services, Inc. (“Roberts Financial” or the “Advisor”, CRD# 289856) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Roberts Financial Disclosure Brochure or this Brochure Supplement, please contact us at (906) 228-5564. Additional information about Mrs. Kinonen is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 6083485. B.A. Roberts Financial Services, Inc. Page 20 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Item 2 – Educational Background and Business Experience Jessica F. Kinonen, born in 1983, is dedicated to advising Clients of Roberts Financial as a Financial Advisor. Mrs. Kinonen earned a Communication Disorders- Bachelor of Science from Northern Michigan University in 2007. Additional information regarding Mrs. Kinonen’s employment history is included below. Employment History: 05/2023 to Present 04/2022 to 05/2023 Financial Advisor, B.A. Roberts Financial Services, Inc. d/b/a Roberts Financial Services, Inc. Director of Business Development and Marketing, Roberts Financial Services, Inc. Director of Operations, Wealth Strategy Group 05/2012 to 04/2022 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mrs. Kinonen. Mrs. Kinonen has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mrs. Kinonen. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mrs. Kinonen. However, we do encourage you to independently view the background of Mrs. Kinonen on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 6083485. Item 4 – Other Business Activities Mrs. Kinonen is dedicated to the investment advisory activities of Roberts Financial’s Clients. Mrs. Kinonen does not have any other business activities. Item 5 – Additional Compensation Mrs. Kinonen is dedicated to the investment advisory activities of Roberts Financial’s Clients. Mrs. Kinonen does not receive any additional forms of compensation. Item 6 – Supervision Mrs. Kinonen serves as a Financial Advisor of Roberts Financial and is supervised by Bruce Roberts, the Chief Compliance Officer. Mr. Roberts can be reached at (906) 228-5564. Roberts Financial has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Roberts Financial. Further, Roberts Financial is subject to regulatory oversight by various agencies. These agencies require registration by Roberts Financial and its Supervised Persons. As a registered entity, Roberts Financial is subject to examinations by regulators, which may be announced or unannounced. Roberts Financial is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. B.A. Roberts Financial Services, Inc. Page 21 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Roberts Financial Services, Inc. Form ADV Part 2B – Brochure Supplement for Allen J. VanDeKreeke Financial Advisor Effective: February 9, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Allen J. VanDeKreeke (CRD# 7843522) in addition to the information contained in the B.A. Roberts Financial Services, Inc. d/b/a Roberts Financial Services, Inc. (“Roberts Financial” or the “Advisor”, CRD# 289856) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Roberts Financial Disclosure Brochure or this Brochure Supplement, please contact us at (906) 228-5564. Additional information about Mr. VanDeKreeke is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7843522. B.A. Roberts Financial Services, Inc. Page 22 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Item 2 – Educational Background and Business Experience Allen J. VanDeKreeke, born in 1992, is dedicated to advising Clients of Roberts Financial as a Financial Advisor. Mr. VanDeKreeke earned a B.S. in Sport Management with Minor in Business Management from University of Minnesota in 2015. Additional information regarding Mr. VanDeKreeke’s employment history is included below. Employment History: 06/2024 to Present Financial Advisor, B.A. Roberts Financial Services, Inc. d/b/a Roberts Financial Services, Inc. Senior Account Manager and Supply Chain Specialist, Made In Nature Account Coordinator, Life Time Fitness 01/2017 to 05/2024 04/2016 to 09/2016 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. VanDeKreeke. Mr. VanDeKreeke has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. VanDeKreeke. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. VanDeKreeke. However, we do encourage you to independently view the background of Mr. VanDeKreeke on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7843522. Item 4 – Other Business Activities Mr. VanDeKreeke is dedicated to the investment advisory activities of Roberts Financial’s Clients. Mr. VanDeKreeke does not have any other business activities. Item 5 – Additional Compensation Mr. VanDeKreeke is dedicated to the investment advisory activities of Roberts Financial’s Clients. Mr. VanDeKreeke does not receive any additional forms of compensation. Item 6 – Supervision Mr. VanDeKreeke serves as a Financial Advisor of Roberts Financial and is supervised by Bruce Roberts, the Chief Compliance Officer. Mr. Roberts can be reached at (906) 228-5564. Roberts Financial has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Roberts Financial. Further, Roberts Financial is subject to regulatory oversight by various agencies. These agencies require registration by Roberts Financial and its Supervised Persons. As a registered entity, Roberts Financial is subject to examinations by regulators, which may be announced or unannounced. Roberts Financial is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. B.A. Roberts Financial Services, Inc. Page 23 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com Privacy Policy Effective Date: February 9, 2026 Our Commitment to You B.A. Roberts Financial Services, Inc. d/b/a Roberts Financial Services, Inc. (“Roberts Financial” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Roberts Financial (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Roberts Financial does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. B.A. Roberts Financial Services, Inc. Page 24 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes Roberts Financial does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Roberts Financial or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients Roberts Financial does not disclose and does not intend to disclose, non- public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy, and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting the Advisor at (906) 228-5564. B.A. Roberts Financial Services, Inc. Page 25 d/b/a Roberts Financial Services, Inc. 989 West Washington Street, Suite 101, Marquette, MI 49855 Phone: (906) 228-5564 Fax: (906) 226-4694 http://baroberts.com