Smp Financial Planning, LLC

Item 1 – Cover Page SMP Financial Planning, LLC Form ADV Part 2A – Disclosure Brochure Version date: September 24, 2026 This brochure provides information about the qualifications and business practices of SMP Financial Planning, LLC (“SMP” or the “Advisor”). If you have any questions about the contents of this brochure, please contact us at (202) 450-0784. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about SMP Financial Planning, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for SMP Financial Planning, LLC is 315300. SMP Financial Planning, LLC is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any states securities authority does not imply a certain level of skill or training. SMP Financial Planning, LLC Private Residence Phone: (202) 450-0784 https://smpfp.com/ 1  Item 2 – Material Changes Material Changes The following are the material changes that have been made to SMP’s brochure since its last annual updating amendment dated November 1, 2025: • SMP Financial Planning, LLC has added Management of Restricted or Legacy Securities (Item 4.B) • SMP Financial Planning, LLC has updated their Assets Under Management (Item 4.E) • SMP Financial Planning, LLC has updated Fees and Compensation to include restricted securities (Item 5. A) • SMP Financial Planning, LLC has updated Method of Analysis, Investment Strategies and Risk of Loss to include “Transparency Risk” (Item 8. B) • SMP Financial Planning, LLC has added Portfolio Rebalancing (Item 12. C) • SMP Financial Planning, LLC has updated Review of Accounts to include restricted securities (Item 13. A) • SMP Financial Planning, LLC has updated Investment Discretion to include restricted securities (Item 16) 2  Item 3 – Table of Contents Item 1 – Cover Page .................................................................................................................................. 1 Item 2 – Material Changes ........................................................................................................................ 2 Item 3 – Table of Contents ....................................................................................................................... 3 Item 4 – Advisory Business ..................................................................................................................... 4 Item 5 – Fees and Compensation ........................................................................................................... 6 Item 6 – Performance-Based Fees, Side-By-Side Management and Supervision ........................... 8 Item 7 – Types of Clients .......................................................................................................................... 8 Item 8 – Method of Analysis, Investment Strategies and Risk of Loss ............................................. 8 Item 9 – Disciplinary Information .......................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations .......................................................... 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................................................................................................................... 10 Item 12 – Brokerage Practices .............................................................................................................. 11 Item 13 – Review of Accounts ............................................................................................................... 13 Item 14 – Client Referrals and Other Compensation ......................................................................... 13 Item 15 – Custody ................................................................................................................................... 14 Item 16 – Investment Discretion ............................................................................................................ 14 Item 17 – Voting Client Securities ......................................................................................................... 14 Item 18 – Financial Information ............................................................................................................ 14 3  Item 4 – Advisory Business A. Firm Information SMP Financial Planning, LLC (formerly Poirier Financial Management, LLC) is a Limited Liability Company formed in August 2021 that is registered with the SEC. SMP is owned by Mitchell Poirier and Scott Marx. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by SMP. B. Advisory Services Offered SMP offers wealth management services and stand-alone financial planning services to individuals, high net worth individuals, trusts, and estates (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. SMP’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services SMP provides wealth management services which include both discretionary investment management services and financial planning services. When managing assets on a discretionary basis, SMP does not need to obtain client approval prior to implementing its recommendations. SMP 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. SMP works closely with each Client to identify their unique financial needs, investment goals and objectives as well as their tolerance for risk and financial situation in order to create a portfolio strategy. SMP will construct an investment portfolio, consisting of exchange-traded funds(“ETFs”), open-end mutual funds, individual stocks, individual bonds, and/or other types in investments, as appropriate, to meet the needs of each unique Client. The Advisor may retain certain types of investments based on a Client’s legacy investments and/or tax considerations. Clients may request that certain securities or asset blocks (such as low-basis legacy equities, concentrated positions, or restricted stock) be excluded from trading due to tax considerations, capital gains constraints, or specific client mandates. Management of Restricted or Legacy Securities Unless explicitly excluded from fee calculations by written agreement, accounts containing restricted or tax-sensitive holdings remain subject to the firm's ongoing advisory services. For these holdings, the firm's ongoing services include: • Risk oversight & portfolio balancing: continuously monitoring the concentration risk of the restricted holding relative to the client’s overall asset allocation and managing the remainder of the portfolio to offset or balance single-stock exposure • Security valuation: analyzing the holding to evaluate whether a security is overvalued, undervalued, or fairly priced relative to its current market price. This includes tracking corporate events affecting the underlying security • Tax-budgeting and liquidation modeling: periodically evaluating multi-year tax projections to identify opportunities for systematic, phased liquidation or hedging strategies (such as tax- loss harvesting coordination) • Estate integration: coordinating with the client’s estate planning or tax professionals regarding step-up-in-basis planning or charitable transfer strategies. • Charitable Giving & Philanthropic Structuring: designing strategies to transfer the restricted 4  asset out of the taxable estate or portfolio efficiently, such as through direct gifts of appreciated securities, establishing a Donor-Advised Fund (DAF), or utilizing Charitable Remainder Trusts (CRTs) • Performance reporting inclusive of the restricted holdings While SMP’s investment strategies are primarily long-term focused, the Advisor may transact (buy, sell or re-allocate) positions that have been held for less than one year to meet the objectives of the Client, or if market conditions warrant the transaction(s). SMP will develop, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by each 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. SMP evaluates and selects investments for investment in Client portfolios only after applying its internal due-diligence process. SMP may recommend, on occasion, redistributing investment allocations to diversify the portfolio. SMP 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. SMP may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, 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 the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. 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. Financial Planning Services SMP provides financial planning services either as a component of our wealth management services or on a stand-alone basis. SMP will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. These services may include: • • Retirement planning – The first step of the retirement planning process involves an initial discovery and goal setting meeting, during which the Client will provide personal financial details, describe financial goals and outline their investment tolerance for risk. Next, SMP will then assess a Client’s current situation through a thorough review of the aforementioned data. SMP will then perform a gap analysis, which can include expected retirement expenses, a comparison of projected expenses and anticipated income and assets, and a final analysis of potential shortfalls or surpluses. SMP will then provide financial recommendations, specific methods of implementation and ongoing review. Investment analysis – SMP will first assess a Client’s tolerance for risk through a discovery and goal setting meeting. SMP will then analyze individual investment options (account types and available investments) and compare expected returns, volatility, costs, and alignment with Client financial goals. SMP will then develop a diversified allocation strategy based on the Client’s tolerance for risk and unique situation. • Budget analysis – SMP will first collect all pertinent income and expense information. Next, SMP will then compare monthly and annual income to expenses, identify surplus or deficit and highlight irregular or seasonal spending patterns. Through a well-defined process, SMP will work with the Client to separate essential spending from discretionary, and work to connect spending habits to financial goals. Finally, a savings plan will be established and SMP can help assist the Client with ongoing monitoring and evaluation. 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. 5  Examples include, but are not limited to, recommendations that the Client start or revise their investment programs, alter retirement savings, establish an after-tax savings plan, establish education savings and/or charitable giving programs. A conflict exists where SMP recommends itself to implement its financial planning recommendations. Nonetheless, clients retain sole discretion whether to accept or reject our recommendations, and they need not select SMP to implement any such recommendations. C. Client Account Management Prior to engaging SMP to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Developing an Investment Strategy – SMP, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – SMP 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 – SMP will develop a portfolio for the Client that is intended • to meet the stated goals and objectives of the Client. Investment Management and Supervision – SMP will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs SMP does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by SMP. E. Assets Under Management As of September 24, 2026, SMP has $75,820,024.09 in discretionary assets under management (AUM), and $627,346.43 in non-discretionary assets under management. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Wealth management fees are paid quarterly, at the end of each calendar quarter, pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value of assets under management at the end of the prior calendar quarter. Wealth management fees range from 0.40% to 1.00% annually based on the following tiered schedule: Assets Under Management ($) Annual Rate (%) Up to $1,000,000 1.00% Next $1,000,000 0.85% Next $3,000,000 0.75% Next $5,000,000 0.50% Over $10,000,000 0.40% The wealth management fee in the first quarter of service is prorated from the inception date of the account[s]to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. Certain Clients may be offered a fixed rate fee schedule, based on the Advisor’s discretion. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by SMP will be independently valued by the 6  Custodian. SMP will not have the authority or responsibility to value portfolio securities. 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. Fee Implications for restricted or legacy securities: because the Firm provides continuous risk oversight, tax-bracket monitoring, strategic planning for restricted or legacy holdings, and performance reporting, they are included in the total AUM upon which the firm's advisory fee is calculated, unless a specific fee exclusion has been formally agreed upon in writing. Clients acknowledge that while the firm maintains ongoing analytical and strategic oversight, execution authority for restricted blocks may be limited by client-imposed trading constraints. B. Fee for Financial Planning Services Financial planning services provided on a stand-alone basis are charged in advance through a fixed fee or hourly arrangement as agreed upon between the Client and SMP. There will never be an instance where $500 or more in fees is charged six or more months in advance. Hourly fees are generally charged when the scope of services cannot be determined or if the services are limited to just one meeting. Fixed fees are generally quoted to the Client for longer term consulting projects, and are calculated based on an hourly rate multiplied by the estimated time of plan completion. Fees are negotiable and vary depending upon the complexity of the Client situation and services to be provided. Hourly fees range from $150 to $500 per hour, depending upon what is negotiated between SMP and the Client. Similar financial planning services may be available elsewhere for a lower cost to the Client. Fixed fees for longer-term consulting projects range from $1,000 to $10,000 per project, and are calculated based on an hourly rate multiplied by the estimated time of project completion. An estimate for total hours and charges is determined at the start of the advisory relationship. Typically, Clients will be invoiced monthly for all time spent by SMP as agreed upon by Client or upon completion of the services if less than one month. In certain instances, SMP may charge for financial planning services in arrears. Clients that wish to terminate the planning process prior to completion may do so with written notice. The Client may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period by contacting Mitchell Poirier at (202) 450-0784. Upon its signing. The amount to be refunded is based on the difference between the pre-paid fee and the actual hours used prior to termination. C. Fee Billing Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. Fees are paid quarterly in arrears. IA uses the end of quarter balance in the Client’s account for the billing period, for purposes of determining the market value of the assets upon which the advisory fee is based. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review their quarterly statements carefully, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by SMP to be paid directly from their account[s] held by the Custodian as part of the wealth management agreement and separate account forms provided by the Custodian. D. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than SMP, 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, as 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 fees charged by SMP are separate and distinct from these custody and execution fees. In addition, all fees paid to SMP 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 7  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 SMP, but would not receive the services provided by SMP 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 SMP to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices. E. Payment of Fees and Termination SMP is compensated for its wealth management services at the end of the quarter after services are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the other party. 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. The Client’s wealth management agreement with the Advisor is non-transferable without the Client’s prior consent. F. Compensation for Sales of Securities SMP 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. Item 6 – Performance-Based Fees, Side-By-Side Management and Supervision SMP does not charge performance-based fees for its investment advisory services. The fees charged by SMP are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. SMP 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 SMP offers investment advisory services to individuals, high net worth individuals, trusts, estates, and retirement plans, specifically employer sponsored 401(k) plans. SMP generally does not impose a minimum relationship size. Item 8 – Method of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis SMP primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from SMP 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 criterion 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 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. Technical Analysis involves studying past price patterns and trends in the financial markets to 8  better estimate the direction of both the overall market and specific stocks. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not work long term. Dollar-Cost Averaging is a technique of buying a fixed dollar amount of securities at regularly scheduled intervals, regardless of the price per share. This may gradually, over time, decrease the average share price of the security. Dollar-cost averaging may lessen the risk of sharp asset price fluctuations impacting a Client’s long-term goals through gradual investment. As noted above, SMP generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. The Advisor’s investment strategy is based upon long-term investment objectives. SMP 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, SMP 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 macroeconomics. B. Risk of Loss Investing in securities involves a number of investment risks. Securities are subject to fluctuation in value, which may lead to complete loss. Clients should be prepared to bear the potential risk of loss. SMP 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. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as well as general risks of investing. While the methods of analysis help the Advisor and evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of 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. Each Client engagement will entail a review of the Client's unique 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 globally. This risk is systemic, and 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 9  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. Bond ETFs Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. 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. Transparency Risks Thinly-traded and private investments, such as hedge funds, private equity funds, and real estate funds, present heightened opacity, including infrequent or subjective Net Asset Value (NAV) valuations, illiquidity, redemption gating, complex external fee structures, and the potential for distributions to be funded from capital rather than property operating cash flow., among other risks. Clients must carefully consider these structural transparency and liquidity risks before allocating to unlisted real estate or similar non-exchange-traded investments. 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. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving SMP or its management persons. SMP values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or 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# 315300. Item 10 – Other Financial Industry Activities and Affiliations The sole business of SMP is to provide investment advisory services to its Clients. Neither SMP nor its Advisory Persons are involved in other business endeavors. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics SMP has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client relationship. The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. SMP has a duty of good faith, loyalty, and fairness towards each Client. It is the obligation of SMP to adhere not only to the specific provisions of 10  the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (202) 450-0784. B. Personal Trading with Material Interest SMP allows Supervised employees to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. SMP 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. SMP does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients SMP allows employees to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (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 the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. SMP will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the Client’s disadvantage when similar securities are being bought or sold. 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 SMP requiring reporting of personal securities trades by conducting a coordinated review of personal accounts and the accounts of the Clients. 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 SMP allows employees to purchase or sell 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 SMP, or any employees of SMP, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] SMP 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 SMP to direct trades to the Custodian as agreed upon in the wealth management agreement. Further, SMP does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where SMP 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 the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by SMP. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. SMP 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, and its reputation and/or the location of the Custodian’s offices. SMP will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC or TIAA. In considering which independent qualified custodian would be best fit for SMP’s model, SMP considered the following factors: financial strength, reputation, reporting capabilities, pricing, and types of quality research. Schwab or TIAA will serve as the Client’s “qualified custodian.” SMP maintains an institutional relationship with Schwab and TIAA, whereby the Advisor receives economic benefits such as not having to pay for products, research or services. SMP may have an incentive to select or recommend a broker-dealer based on the SMP’s interest in receiving research, products or services, rather than the interest in receiving most 11  favorable trade execution. Please see Item 14 below. 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. SMP does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian, such as not having to pay for their research, products or services. SMP has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like SMP. As a registered investment advisor participating on the Schwab Advisor Services platform and TIAA’s “Third-Party Advisor” unit, SMP receives access to research, other products and services, and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab and/or TIAA. Services provided by Schwab and/or TIAA benefit the Advisor and many, but not all services provided by Schwab and/or TIAA will benefit Clients. 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 potential 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. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab and TIAA, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab and TIAA provide participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab and/or TIAA. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab and TIAA also offers other services and financial support to SMP that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab and/or TIAA, which results in a potential conflict of interest as it may prevent the Advisor from achieving the most favorable execution of Client transactions. SMP believes, however, that the selection of Schwab or TIAA as Custodian is in the best interests of its Clients. 2. Brokerage Referrals - SMP does not receive any compensation from any third-party in connection with the recommendation for establishing an account. 3. Directed Brokerage - SMP may permit Clients to direct it to execute transactions through a specified broker-dealer. Clients must refer to their advisory agreements for a complete understanding of how they may be permitted to direct brokerage. If a Client directs brokerage, the Client will be required to acknowledge in writing that the Client’s direction with respect to the use of brokers supersedes any authority granted to SMP to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; the Client may be unable to participate in block trades (unless SMP is able to engage in “step outs”); and trades for the Client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their Clients to direct brokerage. Permitting Clients to direct brokerage may prevent the advisor from achieving the most favorable execution of Client transactions. B. Aggregating and Allocating Trades SMP will execute its transactions through the Custodian as authorized by the Client. SMP may 12  aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. 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 any particular Clients’ accounts. C. Portfolio Rebalancing SMP rebalances Client portfolios at least annually, when able. The Adviser continuously monitors client accounts and determines whether to execute rebalancing transactions based on factors including, but not limited to: target asset allocation drift, market volatility, liquidity needs, cash flows and tax considerations. Discretionary Tax & Execution Limitations The Adviser retains full discretion to refrain from rebalancing an account—or to rebalance an account partially—if doing so would result in adverse consequences for the client. Common reasons the Adviser may exercise discretion not to rebalance include: • Realization of substantial short-term or long-term capital gains • Breaching client-specified realized tax caps or tax-budget instructions for the entire portfolio • Wash-sale implications or holding-period considerations • De minimis trade sizes where transaction or custodian costs outweigh rebalancing benefits. Portfolio Drift & Associated Risks Given SMP manages restricted and tax-sensitive holdings, client portfolios may experience extended periods of asset allocation drift. During these periods, an account may become overweighted or underweighted in specific asset classes, exposing the client to higher market volatility, concentration risk, or performance that diverges from the Firm's target models. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by the Advisors of SMP, which can include Mitchell Poirier, Co-Founder and Scott Marx, Co-Founder. This includes accounts containing restricted or tax-sensitive holdings. Formal reviews are written or audible, and generally conducted at least annually or more 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 and can be written or audible. 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 SMP 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 written 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 statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports in writing, regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by SMP SMP is a fee-based advisory firm that is compensated solely by its Clients and not from any 13  investment product. SMP does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. SMP 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, SMP may receive non-compensated referrals of new Clients from various third parties. B. Client Referrals from Solicitors SMP does not engage paid solicitors for Client referrals. Item 15 – Custody SMP maintains custody of Client funds given the firm’s authority to deduct fees from Client accounts. Additionally, Clients are required to engage the Custodian to retain their funds and securities and direct SMP to utilize that Custodian for the Client’s security transactions. Clients should carefully review quarterly statements provided by the Custodian and compare to any reports provided by SMP to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. For fees deducted directly from Client accounts, in states that require it, SMP will: (A) Possess written authorization from the Client to deduct advisory fees from an account held by a custodian. (B) Send the custodian written notice of the amount of the fee to be deducted from the Client’s account and verify that the custodian sends invoices to the Client. (C) Send the Client a written invoice itemizing the fee upon or prior to fee deduction, including the formula used to calculate the fee, the time period covered by the fee and the amount of assets under management on which the fee was based. Item 16 – Investment Discretion SMP 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. SMP will exercise discretion over the selection and amount of securities to be bought or sold in Client accounts. These purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by SMP. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of a wealth management agreement containing all applicable limitations to such authority. All discretionary trades made by SMP will be in accordance with each Client's unique needs, investment objectives and goals. Unless explicitly outlined in the writing, accounts containing restricted or tax-sensitive holdings remain subject to the firm's ongoing advisory oversight and discretion. Item 17 – Voting Client Securities SMP does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Clients can forward all questions regarding proxy voting to Mitchell Poirier (202)-450-0784. Item 18 – Financial Information Neither SMP, nor its management, have any adverse financial situations that would reasonably impair the ability of SMP to meet all obligations to its Clients. Neither SMP, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. SMP is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees in excess of $500 or more for services to be performed six months or more in the future. 14