Secure Financial Management

Form ADV Part 2A: Firm Brochure Item 1 – Cover Page Kirkwood Financial Services, LLC doing business as Secure Financial Management 4630 De Zavala Road San Antonio, Texas 78249 (210) 428-6250 https://sfmplanning.com/ Date of Brochure: May 2026 ____________________________________________________________________________________ This disclosure brochure provides information about the qualifications and business practices of Kirkwood Financial Services, LLC doing business as Secure Financial Management (also referred to as we, us and Secure Financial Management throughout this disclosure brochure). If you have any questions about the contents of this disclosure brochure, please contact us at (210) 428-6250 or support@sfmplanning.com. The information in this disclosure brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Secure Financial Management is also available on the Internet at www.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for Kirkwood Financial Services, LLC doing business as Secure Financial Management or our firm’s CRD number 169278. *Registration as an investment adviser does not imply a certain level of skill or training. Secure Financial Management Page 1 Form ADV Part 2A: Firm Brochure  Item 2 – Material Changes Since our last annual amendment, dated March 3, 2025, we have made extensive changes to this brochure and encourage you to closely review it in its entirety. The following is a summary of the material changes made to the brochure.     Item 4 – Advisory Business has been updated to better describe the totality of investment advisory services we provided. We also added new disclosures regarding the recommendation of retirement plan rollover. We also removed all references from the brochure to the use of third- party sub-advisers and sub-advisory services. Item 5 – Fees and Compensation has been revised to better describe our fee schedules, how we collect fees and when we collect fees. We removed previous provisions for hourly fees. We also updated descriptions of the “other” fees and expenses clients incur from using our services. These are fees and expenses we do not receive but are assessed by third-parties. Item 7 – Types of Clients was updated to disclose the $250,000 minimum to open an account for out investment advisory services. Exceptions may be granted to this minimum upon approval of Jay Kirkwood and are typically determined based on the expectation of future investable assets.  Please review Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss, to read our current practices. The section was updated to better explain our processes and methods used. Item 10 – Other Financial Industry Activities and Affiliations o New disclosures were made to explain the annuity and insurance recommendations of our o investment adviser representatives in their separate capacities as insurance agents through our affiliated company, Wholesalers Insurance Group, LLC. When doing so, they can sell insurance products for commissions, which creates a conflict of interest. Information was added describing the fact that one of our affiliated persons, Frank Esquivel, can work with clients in need of health insurance and Medicare supplement plans. To the extent a client needs to purchase health insurance coverage, the client has the option to work with Mr. Esquivel through his company, F Esquivel Enterprises LLC. Through this company, Mr. Esquivel is an insurance agent and sells health insurance and Medicare supplemental plans. When doing so he will earn commissions for selling insurance products, which creates a conflict of interest. o The section was updated to describe our arrangement with Brian T. Boyd CPA, P.C., an unaffiliated, third party Certified Public Accountant, whereby we recommend their tax planning and tax preparation services to our clients. We pay all or a portion of fees charged by Brian T. Boyd CPA, P.C. to assist clients with tax planning needs. This benefit is not provided to all clients. o The section was updated to describe our arrangement with the Law Offices of Benjamin F Youngblood III, an unaffiliated, third-party law firm to assist with and/or prepare wills, powers of attorney, directives to physicians and family, and medical powers of attorney. We pay all or a portion of legal fees charged by the Law Offices of Benjamin F Youngblood III for these select services. This benefit is not provided to all clients.   Item 12 – Brokerage Practices was updated to fully describe our relationship with Charles Schwab & Company, Inc. We also updated our policy for “client-directed brokerage arrangements” and updated our block trading policy description. Item 14 – Client Referrals and Other Compensation was updated to disclose the receipt of reimbursement and/or payments for marketing from distributors of investment and/or insurance products, which creates a conflict of interest. Such reimbursements and/or payments are typically the result of informal expense sharing arrangements in which product sponsors underwrite costs Secure Financial Management Page 2 Form ADV Part 2A: Firm Brochure    incurred for marketing such as client appreciation events, advertising, publishing, and seminar expenses. Item 15 – Custody was revised to explain how we debit fees from client accounts and our procedures for ensuring client funds and securities are always maintained with a third-party qualified custodian. Item 17 – Voting Client Securities was updated to explain that we do not vote proxies on behalf of clients. We will ensure that you receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after our firm’s fiscal year ends. Our firm’s fiscal year ends on December 31, so you will receive the summary of material changes no later than April 30 each year. At that time we will also offer or provide a copy of the current disclosure brochure. We may also provide other ongoing disclosure information about material changes, as necessary. Secure Financial Management Page 3 Form ADV Part 2A: Firm Brochure  Item 3 – Table of Contents Item 1 – Cover Page ..................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................ 4 Item 4 – Advisory Business ........................................................................................................................... 5 Item 5 – Fees and Compensation ................................................................................................................. 8 Item 6 – Performance-Based Fees and Side-By-Side Management .......................................................... 10 Item 7 – Types of Clients ............................................................................................................................ 11 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 11 Item 9 – Disciplinary Information ................................................................................................................. 14 Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 14 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ............................... 17 Item 12 – Brokerage Practices .................................................................................................................... 18 Item 13 – Review of Accounts .................................................................................................................... 20 Item 14 – Client Referrals and Other Compensation .................................................................................. 21 Item 15 – Custody ....................................................................................................................................... 21 Item 16 – Investment Discretion ................................................................................................................. 22 Item 17 – Voting Client Securities ............................................................................................................... 22 Item 18 – Financial Information ................................................................................................................... 22 Secure Financial Management Page 4 Form ADV Part 2A: Firm Brochure  Item 4 – Advisory Business Secure Financial Management is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and is a limited liability company (LLC) formed under the laws of the State of Texas.  Jay Kirkwood is the Chief Compliance Officer (CCO), Managing Member and President of Secure Financial Management. He is the sole owner of Secure Financial Management.  Secure Financial Management was founded in January 2011 and has been registered as an investment adviser since January 2014. Description of Advisory Services The following are descriptions of the primary advisory services of Secure Financial Management. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and Secure Financial Management before we can provide you the services described below. The investment advisory services of Secure Financial Management are provided to you through an appropriately licensed individual who is an investment adviser representative of Secure Financial Management (referred to as your investment adviser representative throughout this brochure). Our services are a combination of retirement planning, financial planning and asset management. We consider ourselves to specialize in retirement planning, which can be described as providing you with the guidance and tools to identify any unique risks to your investments, analyzing the capabilities of your insurance coverage, and creating personalized strategies for your retirement needs. Our retirement planning services include, but are not necessarily limited to (1) tax-smart investing plans that involve taxable and tax-sheltered account management; (2) organizing sources of retirement income; and (3) retirement projections based on your lifestyle needs and goals, as well as market conditions. We will need to obtain certain information from you to determine your financial situation and investment objectives. In the process of obtaining the information from you, we provide ancillary financial planning and consultative services including long-term care planning, risk management, income planning as well as insurance and health care coverage. Such financial planning and consultative services are intended to better understand your financial situation and design an investment portfolio consistent with your long- term needs and goals. Unless specifically agreed upon, we do not provide formal written financial plans as all such services are consultative in-nature and integrated for your overall management program. If you are an asset management client and need a formal written financial plan, we can provide one as detailed in the Financial Planning Services section below and we do not charge an additional or separate fee for such services. We only charge separate fees for financial planning to people that are not Asset Management clients (described in the following paragraphs). Secure Financial Management provides asset management services, which is our core service, and involves us providing you with continuous and ongoing supervision over your specified accounts. You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. Refer to Item 12 – Brokerage Practices for more information. Secure Financial Management Page 5 Form ADV Part 2A: Firm Brochure  The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. Refer to Item 16 – Investment Discretion for more information. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You can impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities. It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably as consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Financial Planning & Consulting Services - Secure Financial Management offers financial planning services, which involve preparing a written financial plan covering specific or multiple topics. We provide full written financial plans, which typically address the following topics: Investment Planning,  Asset Allocation,  Cash Flow Analysis & Budgeting,  College/Education Planning,  Estate Planning,   Retirement Planning (for example, organizing sources of retirement income and retirement projections based on your lifestyle needs and goals, as well as market conditions),  Risk Management, and  Tax Planning (tax-smart investing plans that involve taxable and tax-sheltered account management). When providing financial planning services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. We also provide modular written financial plans which only cover those specific areas of concern mutually agreed upon by you and us. A modular written financial plan is limited or segmented and does not involve the creation of a full written financial plan. You should be aware that there are important issues that may not be taken into consideration when your investment adviser representative develops his or her analysis and recommendations under a modular written financial plan. Written financial plans prepared by us do not include specific recommendations of individual securities. Secure Financial Management Page 6 Form ADV Part 2A: Firm Brochure  Unless you are an asset management clients, our financial planning services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole responsibility for determining whether to implement our financial planning recommendations. To the extent that you would like to implement any of our investment recommendations through Secure Financial Management or retain Secure Financial Management to actively monitor and manage your investments, you must execute a written agreement with Secure Financial Management for our asset management services. Retirement Plan Rollover Recommendations - When Secure Financial Management provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, the way Secure Financial Management makes money creates conflicts with your interests so we have developed procedures designed to act in your best interest and not put our interest ahead of you. Our procedures are designed to:  Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put the financial interests of Secure Financial Management ahead of you when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interest, fees, and investments;  Follow policies and procedures designed to ensure that Secure Financial Management gives advice that is in your best interest;  Charge no more than is reasonable for the services of Secure Financial Management; and  Give you basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by Secure Financial Management, please know that Secure Financial Management and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by Secure Financial Management. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by Secure Financial Management. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. we have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in Secure Financial Management receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by Secure Financial Management and our supervised persons and Secure Financial Management Page 7 Form ADV Part 2A: Firm Brochure  any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of Secure Financial Management or our affiliated personnel. Limits Advice to Certain Types of Investments Secure Financial Management provides investment advice on, and typically holds in client accounts investments that are principally focused on individual stock positions (equity securities), Exchange Traded Funds (ETFs), and mutual funds. Bond exposure will consist of high-quality individual bond positions or highly-rated bond mutual funds and ETFs. Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients Secure Financial Management’s advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. Our consulting services are always provided based on your individual needs. When providing consulting services, we work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Client Assets Managed by Secure Financial Management The amount of client assets managed by Secure Financial Management totaled $399,765,022 as of March 10, 2026. The entire portion is managed on a discretionary basis. Refer to Item 16 – Investment Discretion for more information. Item 5 – Fees and Compensation In addition to the information provided in Item 4 – Advisory Business, this section provides additional details regarding our firm’s services along with descriptions of each service’s fees and compensation Secure Financial Management Page 8 Form ADV Part 2A: Firm Brochure  arrangements. The exact fees and other terms will be outlined in the agreement between you and Secure Financial Management. Investment Advisory Services (Asset Management) Fees charged investment advisory services are based on a percentage of assets under management, billed monthly in arrears (at the end of the billing period) and calculated based on the fair market value of your Account as of the last business day of the current billing period. Fees are prorated (based on the number of days service is provided during the initial billing period) for your Account opened at any time other than the beginning of the billing period. If investment advisory services commence in the middle of the billing period, then the prorated fee for that billing period will be billed in arrears at the end of that billing period. Fees charged for our investment advisory services are negotiable based on the potential for additional account deposits, the total amount of assets under management for the client, and as determined by your investment adviser representative.  The annual fee for asset management services will be between 0.80% and 1.50% We typically charge clients using a fee schedule whereby the annual fee rate is lowered when assets increase. For example, a client with $500,000 could be charged closer to 1.50% but a client with $3,000,000 will be charged closer to .80%. When client assets increase and they reach the next breakpoint on the fee schedule, the entire value of their assets will be charged at the next breakpoint. There is a minimum account size of $250,000. See Item 7 – Types of Clients for more information. Secure Financial Management believes that its annual fee is reasonable in relation to (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, our annual investment advisory fee may be higher than that charged by other investment advisers offering similar services/programs. The investment advisory fees will be deducted from your account and paid directly to our firm by the qualified custodian(s) of your account. Therefore, you must provide us written authorization and provide the qualified custodian written authorization to have fees deducted directly from your account(s). Refer to Item 15 – Custody for more information. Brokerage expenses and/or transaction fees charged by the qualified custodian are billed directly to you by the qualified custodian. Secure Financial Management does not receive any portion of such commissions or fees from you or the qualified custodian. In addition, you will incur certain charges imposed by third parties other than Secure Financial Management in connection with investments made through your account including, but not limited to, mutual fund sales loads, 12b-1 fees and surrender charges, variable annuity fees and surrender charges, IRA and qualified retirement plan fees, and charges imposed by the qualified custodian(s) of your account. Management fees charged by Secure Financial Management are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses are available in each investment company security’s prospectus. The investment advisory services continue until terminated by either party (i.e., Secure Financial Management or you) by giving thirty (30) days written notice to the other party. Because fees are billed in arrears, Secure Financial Management will prorate the final fee payment based on the number of days services are provided during the final period. The amount of client assets on the termination date will be used to determine the final fee payment. Secure Financial Management Page 9 Form ADV Part 2A: Firm Brochure  Financial Planning & Consulting Services As explained in Item 4 – Advisory Business of this brochure, most commonly, ongoing financial planning services will be available and bundled with our asset management services resulting in no additional cost for ongoing financial planning services for those that are also ongoing management and advisement clients. For people that are not asset management clients, but would like to engage our firm for financial planning services, the fees we charge for our financial planning are going to range based on the complexity of the client's situation, the number of topics/issues to be covered and the overall time required to develop findings and recommendations. The following are the fee arrangements available for financial planning services offered by Secure Financial Management. One-time financial planning projects have a cost between $5,000 and $20,000. Before commencing financial planning services, Secure Financial Management provides the total cost needed to complete the requested financial planning services. You will pay in advance up to 50% of the quoted total fee. However, under no circumstances will Secure Financial Management require you to pay fees more than $1,200 more than six months in advance. Any unpaid fees are due immediately upon completion and delivery of the financial plan and invoice to the client. There are other fees and expenses clients can incur. They include fees charged by mutual funds to their shareholders if you invest in mutual funds. These fees and expenses are described in each mutual fund’s prospectus. These fees will generally include a management fee, other fund expenses and a possible distribution fee (known as 12b-1 fees). If the mutual fund also imposes sales charges, you could pay an initial or deferred sales charge. Likewise, if you decide to invest through a qualified custodian due in part to the services, the qualified custodian or broker-dealer executing certain transactions will charge commissions for implementing transactions. The financial planning services terminate upon delivery of the written financial plan or upon either party providing the other party with written notice of termination. You may terminate the financial planning services within five (5) business days of entering into an agreement with Secure Financial Management without penalty or fees due. If you terminate the financial planning services after five (5) business days of entering into an agreement, you will be responsible for immediate payment of any financial planning services performed by Secure Financial Management prior to the receipt by Secure Financial Management of your notice. In the event that there is a remaining balance of any fees paid in advance based on the amount of work performed before termination notice, those remaining proceeds will be refunded by Secure Financial Management to you. You can pay fees owed for the financial planning services by submitting payment directly by check. You should notify Secure Financial Management within ten (10) days of receipt of an invoice if you have questions about or dispute any billing entry. Item 6 – Performance-Based Fees and Side-By-Side Management Performance-based fees are defined as fees based on a share of capital gains or capital appreciation of the assets held in a client’s account. Item 6 is not applicable to this Disclosure Brochure because we do not charge or accept performance-based fees. Secure Financial Management Page 10 Form ADV Part 2A: Firm Brochure  Item 7 – Types of Clients Secure Financial Management generally provides investment advice to the following types of clients:  Individuals, including their families, trusts, estates, individual 401k or similar retirement plans, and IRAs  High net worth individuals – An individual who is a qualified client under Rule 205-3 of the Investment Advisers Act of 1940 or is a “qualified purchaser”.  Business entities including sole proprietorship You are required to execute a written agreement with Secure Financial Management specifying the advisory services to establish a client arrangement with Secure Financial Management. Minimum Investment Amounts Required Secure Financial Management requires a minimum of $250,000 to open an account. To reach this account minimum, clients can aggregate all household accounts. Exceptions may be granted to this minimum upon approval of Jay Kirkwood and are typically determined based on the expectation of future investable assets. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Secure Financial Management uses the following methods of analysis in formulating investment advice: Charting - This is a set of techniques used in technical analysis in which charts are used to plot price movements, volume, settlement prices, open interest, and other indicators, in order to anticipate future price movements. Users of these techniques, called chartists, believe that past trends in these indicators can be used to extrapolate future trends. Charting is likely the most subjective analysis of all investment methods since it relies on proper interpretation of chart patterns. The risk of reliance upon chart patterns is that the next day's data can always negate the conclusions reached from prior days' patterns. Also, reliance upon chart patterns bears the risk of a certain pattern being negated by a larger, more encompassing pattern that has not shown itself yet. Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (like the overall economy and industry conditions) and individually specific factors (like the financial condition and management of a company). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Fundamental analysis is considered to be the opposite of technical analysis. Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. The risk associated with fundamental analysis is that it is somewhat subjective. While a quantitative approach is possible, fundamental analysis usually entails a qualitative assessment of how market forces interact with one another in their impact on the investment in question. It is Secure Financial Management Page 11 Form ADV Part 2A: Firm Brochure  possible for those market forces to point in different directions, thus necessitating an interpretation of which forces will be dominant. This interpretation may be wrong, and could therefore lead to an unfavorable investment decision. Technical – This is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are indications of future performance. Technical analysis is even more subjective than fundamental analysis in that it relies on proper interpretation of a given security's price and trading volume data. A decision might be made based on a historical move in a certain direction that was accompanied by heavy volume; however, that heavy volume may only be heavy relative to past volume for the security in question, but not compared to the future trading volume. Therefore, there is the risk of a trading decision being made incorrectly, since future trading volume is an unknown. Technical analysis is also done through observation of various market sentiment readings, many of which are quantitative. Market sentiment gauges the relative degree of bullishness and bearishness in a given security, and a contrarian investor utilizes such sentiment advantageously. When most traders are bullish, then there are very few traders left in a position to buy the security in question, so it becomes advantageous to sell it ahead of the crowd. When most traders are bearish, then there are very few traders left in a position to sell the security in question, so it becomes advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical measures is that a very bullish reading can always become more bullish, resulting in lost opportunity if the money manager chooses to act upon the bullish signal by selling out of a position. The reverse is also true in that a bearish reading of sentiment can always become more bearish, which may result in a premature purchase of a security. Investment Strategies Secure Financial Management uses the following investment strategies when managing client assets and/or providing investment advice: Long term purchases. Investments held at least a year. Value-Investment Strategy. When appropriate, we follow a value-investing strategy that attempts to acquire at reasonable valuations publicly traded businesses that can deliver sustainable excess returns. We focus on a long-only strategy. Long term strategies are designed to identify and select investments to be held for multiple years. We will also invest in value oriented special situations with shorter expected holding periods. Value Investing can be described as a strategy of selecting stocks that trade for less than their intrinsic values. Value investors typically seek stocks of companies that they believe the market has undervalued. They believe the market overreacts to good and bad news, resulting in stock price movements that do not correspond with the company's long-term fundamentals. The result is an opportunity for value investors to profit by buying when the price is deflated. Often, value investors select stocks with lower-than-average price-to-book or price-to-earnings ratios and/or high dividend yields. The risks associated with value-investing include incorrectly analyzing and overestimating the intrinsic value of a business, concentration risk, under performance relative to major benchmarks, macro-economic risks, investing in value traps i.e. businesses that remain perpetually undervalued, and lost purchasing power on cash holdings in the case of inflation. Secure Financial Management Page 12 Form ADV Part 2A: Firm Brochure  Tactical asset allocation. Allows for a range of percentages in each asset class (such as Stocks = 40-50%). The ranges establish minimum and maximum acceptable percentages that permit the investor to take advantage of market conditions within these parameters. Thus, a minor form of market timing is possible, since the investor can move to the higher end of the range when stocks are expected to do better and to the lower end when the economic outlook is bleak. Strategic asset allocation. Calls for setting target allocations and then periodically rebalancing the portfolio back to those targets as investment returns skew the original asset allocation percentages. The concept is akin to a “buy and hold” strategy, rather than an active trading approach. Of course, the strategic asset allocation targets may change over time as the client’s goals and needs change and as the time horizon for major events such as retirement and college funding grow shorter. Do Not Primarily Recommend One Type of Security We do not primarily recommend one type of security to clients. Instead, we recommend any product that may be suitable for each client relative to that client’s specific circumstances and needs. Risk of Loss Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated with investing in securities through our investment management program, as described below:  Market Risk – Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk.  Equity (stock) market risk – Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer.  Company Risk. When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. Secure Financial Management Page 13 Form ADV Part 2A: Firm Brochure   Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk.  Options Risk. Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks.  ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs.  Management Risk – Your investment with our firm varies with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease. Item 9 – Disciplinary Information Item 9 asks us to disclose any legal or disciplinary events that either the firm, or its management persons, may have been involved in, in any of the following areas: 1. A criminal or civil action in a domestic, foreign or military court of competent jurisdiction. o Secure Financial Management has nothing to report for this item. 2. An administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority. o Secure Financial Management has nothing to report for this item. 3. A self-regulatory organization (SRO) proceeding. o Secure Financial Management has nothing to report for this item. Item 10 – Other Financial Industry Activities and Affiliations Secure Financial Management is not and does not have a related person that is a broker/dealer, municipal securities dealer, government securities dealer or broker, an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), another investment adviser or financial planner, a futures commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift institution, an accountant or accounting firm, a lawyer or law firm, a pension consultant, a real estate broker or dealer, and a sponsor or syndicator of limited partnerships. Wholesalers Insurance Group, LLC Insurance Agents You may work with your investment adviser representative in his or her separate capacity as an insurance agent with Wholesalers Insurance Group, LLC. Insurance sales activities are independent of and outside the scope of the investment adviser representative’s affiliation with our investment adviser firm. However, Wholesalers Insurance Group, LLC and Secure Financial Management are related Secure Financial Management Page 14 Form ADV Part 2A: Firm Brochure  companies and therefore we have a conflict to recommend insurance through Wholesalers Insurance Group, LLC. When acting in his separate capacity as an insurance agent, the investment adviser representative can sell, for commissions, fixed annuities, life insurance, and other insurance products to you. As such, your investment adviser representative in his separate capacity as an insurance agent, can recommend that you implement recommendations of Secure Financial Management by purchasing fixed annuities, life insurance, or other insurance products. This receipt of commissions creates an incentive for the representative to recommend those products for which your investment adviser representative will receive a commission in his or her separate capacity as an insurance agent. Consequently, the advice rendered to you is biased, and your investment adviser representative has a conflict of interest when acting as an insurance agent. It is important for clients to understand that when acting in this separate capacity as a licensed insurance agent, this individual is not acting as a fiduciary and does not have the same obligations to act solely in the best interest of the client as when providing investment advisory services through our investment adviser firm. You are encouraged to inquire about the compensation arrangements related to insurance products. You should carefully evaluate insurance recommendations made by your investment adviser representative in his separate as an insurance agent and consider whether to obtain a second opinion from a third party. You are under no obligation to implement any insurance or annuity transaction through your investment adviser representative. Health Insurance Solutions One of our affiliated persons, Frank Esquivel, can work with clients in need of health insurance and Medicare supplemental plans. Although not an investment adviser representative, Mr. Esquivel specializes in health insurance solutions. He provides non-investment related advice specific to health insurance, Medicare planning and Medicare supplemental insurance needs. To the extent a client needs to purchase health insurance coverage, the client has the option to work with Mr. Esquivel through his company, F Esquivel Enterprises LLC. Through this company, Mr. Esquivel is an insurance agent and sells health insurance and Medicare supplemental plans. When doing so he will earn commissions for selling insurance products. Consequently, the advice rendered to you is biased, and Mr. Esquivel has a conflict of interest when acting as an insurance agent. It is important for clients to understand that when acting in this separate capacity as a licensed insurance agent, Mr. Esquivel is not acting as a fiduciary and does not have the same obligations to act solely in the best interest of the client as when our investment adviser representatives are providing investment advisory services through Secure Financial Management. You are encouraged to inquire about the compensation arrangements related to insurance products. You should carefully evaluate insurance recommendations made by Mr. Esquivel in his separate as an insurance agent and consider whether to obtain a second opinion from a third party. You are under no obligation to implement any insurance through Mr. Esquivel. Tax Planning and Tax Preparation Services We have formed an arrangement with Brian T. Boyd CPA, P.C., an unaffiliated, third party Certified Public Accountant, whereby recommending their tax planning and tax preparation services to our clients. We pay all or a portion of fees charged by Brian T. Boyd CPA, P.C. to assist clients with tax planning needs. We do not provide this benefit to all clients. For example, we do not pay for clients who can/should either self-prepare or who use a low-cost tax preparer because their tax situation is relatively simple. For clients that receive this benefit, we do not automatically pay for all accounting services provided by Brian T. Boyd Secure Financial Management Page 15 Form ADV Part 2A: Firm Brochure  CPA, P.C. Situations when clients in need of complex and sophisticated tax planning strategies that require significant time and analysis, will need to pay for such services on their own. Fees for the services of Brian T. Boyd CPA, P.C are in addition to and separate from the fees charged by Secure Financial Management. When we pay for the fees assessed by Brian T. Boyd CPA, P.C, the client will not be required to reimburse us for the payments. Moreover, to the extent that you personally engage an outside professional on your own and without the knowledge of Secure Financial Management, you will be responsible for the third-party fees, and Secure Financial Management will not be required to reimburse you for such payments. There may be other firms than those we suggest that are more appropriate for your tax planning and other firms that charge lower fees for such services. Covering third-party fees creates a potential conflict of interest because clients could perceive an incentive to use professionals recommended by Secure Financial Management over other, similar third-party providers. We address this conflict by:  Not accepting any compensation, referral fees, or other benefits from recommended professionals.  Providing multiple options, when necessary, and encouraging clients to conduct independent due diligence.  Allowing clients to select any provider of their choice. Estate Planning Attorney We have formed an arrangement with the Law Offices of Benjamin F Youngblood III, an unaffiliated, third party law firm, whereby recommending their legal services to our clients. We pay all or a portion of the legal fees charged by the Law Offices of Benjamin F Youngblood III to assist with and/or prepare wills, powers of attorney, directives to physicians and family, and medical powers of attorney. Clients in need of legal services beyond these areas will need to pay for such services on their own. This benefit is not provided to all clients. For clients that receive this benefit, legal fees for the services of the Law Offices of Benjamin F Youngblood III are in addition to and separate from the fees charged by Secure Financial Management. When we pay for the fees assessed by the Law Offices of Benjamin F Youngblood III, the client will not be required to reimburse us for the payments. Moreover, to the extent that you personally engage an outside professional on your own and without the knowledge of Secure Financial Management, you will be responsible for the third-party fees, and Secure Financial Management will not be required to reimburse you for such payments. There may be other legal firms than those we suggest that are more appropriate for your individual situation and other firms that charge lower fees for such services. Covering third-party fees creates a potential conflict of interest because clients could perceive an incentive to use professionals recommended by Secure Financial Management over other, similar third-party providers. We address this conflict by:  Not accepting any compensation, referral fees, or other benefits from recommended professionals.  Providing multiple options, when necessary, and encouraging clients to conduct independent due diligence.  Allowing clients to select any provider of their choice. Secure Financial Management Page 16 Form ADV Part 2A: Firm Brochure  Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Code of Ethics Summary According to the Investment Advisers Act of 1940, an investment adviser is considered a fiduciary and has a fiduciary duty to all clients. Secure Financial Management has established a Code of Ethics to comply with the requirements of Section 204(A)-1 of the Investment Advisers Act of 1940 that reflects its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires compliance with federal securities laws. The Code of Ethics covers all individuals that are classified as “supervised persons”. All employees, officers, directors and investment adviser representatives are classified as supervised persons. Secure Financial Management requires its supervised persons to consistently act in your best interest in all advisory activities. Secure Financial Management imposes certain requirements on its affiliates and supervised persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct required is higher than ordinarily required and encountered in commercial business. This section is intended to provide a summary description of the Code of Ethics of Secure Financial Management. If you wish to review the Code of Ethics in its entirety, you should send us a written request and upon receipt of your request, we will promptly provide a copy of the Code of Ethics to you. Affiliate and Employee Personal Securities Transactions Disclosure Secure Financial Management or supervised persons of the firm buy and sell for their personal accounts, investment products identical to those recommended to clients. This creates a conflict of interest. It is the express policy of Secure Financial Management that all persons associated in any manner with our firm must place clients’ interests ahead of their own when implementing personal investments. As is required by our internal procedures manual, Secure Financial Management and its supervised persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with our firm unless the information is also available to the investing public upon reasonable inquiry. We are now and will continue to be in compliance with applicable state and federal rules and regulations. To mitigate conflicts of interest that can occur when access persons manage their personal accounts at the same time Secure Financial Management manages client accounts, we have developed written supervisory procedures that include personal investment and trading policies for our representatives, employees (including independent contractor personnel) and their immediate family members (collectively, supervised persons):  Supervised persons cannot prefer their own interests to that of the client.  Supervised persons cannot purchase or sell any security for their personal accounts prior to implementing transactions for client accounts.  Supervised persons cannot buy or sell securities for their personal accounts when those decisions are based on information obtained because of their employment, unless that information is also available to the investing public upon reasonable inquiry.  Supervised persons are prohibited from purchasing or selling securities of companies in which any client is deemed an “insider”.  Supervised persons are discouraged from conducting frequent personal trading.  Supervised persons are generally prohibited from serving as board members of publicly traded companies unless an exception has been granted to the Chief Compliance Officer of Secure Financial Management. Any supervised person not observing our policies is subject to sanctions up to and including termination. Secure Financial Management Page 17 Form ADV Part 2A: Firm Brochure  Item 12 – Brokerage Practices When Secure Financial Management is responsible for the implementation of investment recommendations, we are also responsible to ensure that the client receives the best execution possible given the specific facts and circumstances. Best execution does not necessarily mean that clients receive the lowest possible commission costs but that the qualitative execution is best. In other words, all conditions considered, the transaction execution is in your best interest. When considering best execution, we look at a number of factors besides prices and rates including, but not limited to:  Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness, integration with our existing systems, ease of monitoring investments)  Products and services offered (e.g., investment programs, back office services, technology, regulatory compliance assistance, research and analytic services)  Financial strength, stability and responsibility  Reputation and integrity  Ability to maintain confidentiality We exercise reasonable due diligence to make certain that best execution is obtained for all clients when implementing any transaction by considering the back office services, technology and pricing of services offered. Brokerage Recommendations Secure Financial Management recommends, and in some situations will require, that clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc (“Schwab”), a FINRA-registered broker-dealer, Member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although Secure Financial Management may recommend/require the clients establish accounts at Schwab, it is the client’s ultimate decision to custody assets with Schwab and must open an account with Schwab by completing the forms and other documentation required by Schwab. Secure Financial Management is independently owned and operated and not affiliated with Schwab. Secure Financial Management may recommend additional unaffiliated broker-dealers to affect fixed income transactions. Schwab provides Secure Financial Management with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as the investment advisor’s clients’ assets are maintained at Schwab Advisor Services. However, these services are not contingent upon Secure Financial Management committing to Schwab any specific amount of business (assets in custody or trading commissions) and Secure Financial Management can use other custodians and broker/dealers. Schwab’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require significantly higher minimum initial investment. Schwab Advisor Services also makes available to Secure Financial Management other products are services that benefit Secure Financial Management but may not directly benefit clients’ accounts. Many of these products and services may be used to service all or some substantial number of Secure Financial Management’ accounts, including accounts not maintained Schwab. Schwab’s products and services that assist Secure Financial Management in managing and administering clients’ accounts include software and other technology that (i) provides access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and Secure Financial Management Page 18 Form ADV Part 2A: Firm Brochure  allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of Secure Financial Management’s fees from some of its accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Schwab Advisor Services also offers other services intended to help Secure Financial Management manage and further develop its business enterprise. These services may include: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or part of the fees of a third-party providing these services to Secure Financial Management. Schwab Advisor Services may also provide other benefits such as educational events or occasional business entertainment of Secure Financial Management personnel. While as a fiduciary, Secure Financial Management endeavors to act in its clients’ best interests, Secure Financial Management’s recommendation that clients maintain their assets in accounts at Schwab takes into account availability of some of the foregoing products and services and other arrangements not solely on the nature of cost or quality of custody and brokerage services provided by Schwab. These arrangements create a conflict of interest to the extent that we would have to pay for some or all of the research and/or services with “hard dollars” if we were unable to obtain the research and services in exchange for commissions in connection with client transactions. Client trades are always implemented based on the goals and objectives of the client and not on any research, products or other incentives available. Directed Brokerage Although we recommend Charles Schwab, clients are allowed to select the broker-dealer that will be used for their account if Secure Financial Management can accommodate the broker-dealer on an administrative and operational basis. If we are unable to “manage” the account, we will not be able to accommodate the broker-dealer platform. Clients directing the use of a particular broker/dealer or other custodian must understand that we may not be able to obtain the best prices and execution for the transaction. Under a client-directed brokerage arrangement, clients may receive less favorable prices than would otherwise be the case if the client had not designated a particular broker/dealer or custodian. Directed brokerage account trades are generally placed by Secure Financial Management after effecting trades for other clients of Secure Financial Management. If a client directs Secure Financial Management to use a particular broker-dealer, Secure Financial Management may not be authorized to negotiate commissions and may be unable to obtain volume discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to clients who direct Secure Financial Management to use a particular broker or dealer versus clients who do not direct the use of a particular broker or dealer. Block Trading Policy We may elect to purchase or sell the same securities for several clients at approximately the same time. This process is referred to as aggregating orders, batch trading or block trading and is used by our firm when Secure Financial Management believes such action may prove advantageous to clients. If and when we aggregate client orders, allocating securities among client accounts is done on a fair and equitable basis. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more Secure Financial Management Page 19 Form ADV Part 2A: Firm Brochure  equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. Secure Financial Management uses the average price allocation method for transaction allocation. Under this procedure Secure Financial Management will calculate the average price and transaction charges for each transaction included in a block order and assign the average price and transaction charge to each allocated transaction executed for the client’s account. If and when we determine to aggregate client orders for the purchase or sale of securities, including securities in which Secure Financial Management or our associated persons may invest, we will do so in accordance with the parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. Neither we nor our associated persons receive any additional compensation as a result of block trades. If Secure Financial Management includes proprietary accounts of the firm or personal accounts of its supervised persons in an aggregated client order (i.e., block trade), Secure Financial Management will take the following actions: 1. Aggregate transactions only if Secure Financial Management believes that aggregation is consistent with its duty of best execution; 2. Allocate orders on a pro rata basis for partially filled orders; 3. Not favor any client over any other client, proprietary account of Secure Financial Management (and its affiliates) or personal account of a supervised person of Secure Financial Management, and each client/proprietary account/personal account participating in the order will participate at an average share price of all Secure Financial Management’s transactions in that security on the day of execution and transaction costs will be shared on a pro rata base for each client’s participation in the transaction; 4. Prepare a written statement prior to entering into an aggregated order that will specify the participating clients/proprietary accounts/personal accounts and how Secure Financial Management intends to allocate the order among clients; 5. Deviate from the written allocation statement only on a fair basis with written documentation approved by the firm’s chief compliance officer or designee no later than one hour after the opening of the markets on the trading day following the day the order executed; 6. Maintain accurate records relating to the aggregated trades, including, each client account/proprietary account/personal account that is included in an aggregated order, the securities held by and bought and sold for that client account/proprietary account/personal account; 7. Not aggregate client/proprietary/personal assets collectively any longer than necessary to settle the purchase or sale transaction; 8. Not receive any additional compensation or remuneration as a result of any aggregated order; and 9. Render individual advice and treatment to each advisory client. Item 13 – Review of Accounts Account Reviews and Reviewers Managed accounts are reviewed at least quarterly but underlying investments are monitored on a weekly basis. We hold annual client meetings. While the calendar is the main triggering factor, reviews can also be conducted at your request. Account reviews will include investment strategy and objectives review and making a change if strategy and objectives have changed. Reviews are conducted by the following personnel, with reviews performed in accordance with your investment goals and objectives. Jay Kirkwood, Founder and President;  Secure Financial Management Page 20 Form ADV Part 2A: Firm Brochure  Jacob McDonald, Relationship Manager.  Tom Moore, Retirement Planning Advisor; and  Statements and Reports For our asset management services, you are provided with transaction confirmation notices and regular quarterly account statements in writing directly from the qualified custodian. Additionally, Secure Financial Management can provide position or performance reports during meetings with you and upon request. You are encouraged to always compare any reports or statements provided by us against the account statements delivered from the qualified custodian. When you have questions about your account statement, you should contact our firm and the qualified custodian preparing the statement. Item 14 – Client Referrals and Other Compensation Secure Financial Management does not directly or indirectly compensate any person for client referrals. We will from time to time receive reimbursement and/or payments for marketing from distributors of investment and/or insurance products. Such reimbursements and/or payments are typically the result of informal expense sharing arrangements in which product sponsors underwrite costs incurred for marketing such as client appreciation events, advertising, publishing, and seminar expenses. Although receipt of these marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are typically made by sponsors of investments/funds we recommend and hold in client accounts. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of our clients. We attempt to control this conflict by always basing investment decisions on the individual needs of our clients. Please see Item 5 - Fees and Compensation, Item 10 - Other Financial Industry Activities and Affiliations and Item 12 - Brokerage Practices, for additional discussion concerning other compensation. Item 15 – Custody Custody, as it applies to investment advisors, is defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment adviser has the ability to access or control client funds or securities, the investment adviser is deemed to have custody and must ensure proper procedures are implemented. Secure Financial Management is deemed to have custody of client funds and securities whenever Secure Financial Management is given the authority to have fees deducted directly from client accounts. However, this is the only form of custody Secure Financial Management will ever maintain. It should be noted that authorization to trade in client accounts is not deemed by regulators to be custody. We have established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Clients should carefully review those statements and are urged to compare the statements against reports received from Secure Financial Management. When clients have questions about their account statements, they should contact Secure Financial Management or the qualified custodian preparing the statement. Secure Financial Management Page 21 Form ADV Part 2A: Firm Brochure  Item 16 – Investment Discretion When providing asset management services, Secure Financial Management maintains trading authorization over your Account and provides management services on a discretionary basis. By granting discretionary authority, we will have the responsibility to determine the type of securities and the amount of securities that can be bought or sold for your portfolio without obtaining your consent for each transaction. However, it is the policy of Secure Financial Management to consult with you prior to making significant changes in the account even when discretionary trading authority is granted. You will have the ability to place reasonable restrictions on the types of investments that may be purchased in your Account. You may also place reasonable limitations on the discretionary power granted to Secure Financial Management so long as the limitations are specifically set forth or included as an attachment to the client agreement. Item 17 – Voting Client Securities Secure Financial Management does not vote proxies on behalf of Clients. We have determined that taking on the responsibilities for voting client securities does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with voting client securities. Therefore, it is your responsibility to vote all proxies for securities held in Account. You will receive proxies directly from the qualified custodian or transfer agent; we will not provide you with the proxies. You are encouraged to read through the information provided with the proxy-voting documents and make a determination based on the information provided. Although we do not vote client proxies, if you have a question about a particular proxy feel free to contact us. However, you will have the ultimate responsibility for making all proxy-voting decisions. Item 18 – Financial Information This Item 18 is not applicable to this brochure. Secure Financial Management does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet for the most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients. Finally, Secure Financial Management has not been the subject of a bankruptcy petition at any time. Secure Financial Management Page 22 Form ADV Part 2A: Firm Brochure