Overview
- Headquarters
- Plano, TX
- Average Client Assets
- $4.7 million
- SEC CRD Number
- 118450
Fee Structure
Primary Fee Schedule (SFP BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $3,000,000 | 1.00% |
| $3,000,001 | $6,000,000 | 0.75% |
| $6,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $45,000 | 0.90% |
| $10 million | $72,500 | 0.72% |
| $50 million | $172,500 | 0.34% |
| $100 million | $297,500 | 0.30% |
Clients
- HNW Share of Firm Assets
- 96.05%
- Total Client Accounts
- 566
- Discretionary Accounts
- 566
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection, Educational Seminars
Regulatory Filings
Primary Brochure: SFP BROCHURE (2026-03-31)
View Document Text
Strategic Financial Planning, Inc.
6513 Preston Road
Suite 100
Plano, Texas 75024
Phone : 972-403-1234
Fax : 972-403-1234
Web Site: www.strategicfp.com
March 30, 2026
BY APPOINTMENT ONLY
FORM ADV PART 2A
BROCHURE
Form ADV Part 2A, Item 1
This brochure provides information about the qualifications and business practices of
Strategic Financial Planning, Inc. If you have any questions about the contents of this
brochure, please contact us at 972-403-1234. The information in this brochure has not been
approved or verified by the Securities and Exchange Commission, Texas State Securities
Board or by any securities authority.
Additional information about Strategic Financial Planning, Inc. is also available on the
SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Strategic
Financial Planning, Inc. is 118450.
Registration with any securities authority does not imply a certain level of skill or training.
Strategic Financial Planning, Inc. IARD/CRD No: 118450
Form ADV Part 2A March 30, 2026
Brochure Supplement
Item 2: Material Changes
At least annually, this section will discuss only specific material changes that are made to the Strategic
Financial Planning, Inc. Brochure and provide you with a summary of such changes. Additionally,
reference to the date of the last annual update to this Brochure will be provided.
Since our last amendment filed on May 29, 2025, the following material changes were made to the
brochure:
No material changes
Strategic Financial Planning Inc’s (“SFP”) Brochure. ANY QUESTIONS: SFP’s Chief
Compliance Officer, Bryan Lee, remains available to address any questions regarding the above
changes, or any other issue pertaining to this Brochure.
A copy of our Brochure may be requested by contacting us at 972-403-1234 and/or
info@strategicfp.com.
Additional information about Strategic Financial Planning, Inc. is also available via the SEC’s
website www.adviserinfo.sec.gov. The IARD number for Strategic Financial Planning, Inc. is
118450. The SEC’s website also provides information about any persons affiliated with Strategic
Financial Planning, Inc. who are registered, or are required to be registered, as Advisory
Representatives of Strategic Financial Planning, Inc.
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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…………………………………………………………………...7
Item 6: Performance-Based Fees and Side-By-Side Management ……………………………...10
Item 7: Types of Clients …………………………………………………………………………10
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ………………………...10
Item 9: Disciplinary Information ………………………………………………………………..12
Item 10: Other Financial Industry Activities and Affiliations ……………………………...…...12
Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading 13
Item 12: Brokerage Practices ……………………………………………………………………13
Item 13: Review of Accounts …………………………………………………………...………15
Item 14: Client Referrals and Other Compensation …………………………………………..…15
Item 15: Custody ………………………………………………………………………………...16
Item 16: Investment Discretion ………………………………………………………………….16
Item 17: Voting Client Securities ……………………………………………………………….17
Item 18: Financial Information ………………………………………………………………….17
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Item 4: Advisory Business
Bryan Keith Lee (CRD Number 2444953) is President and Chief Compliance Officer of
Strategic Financial Planning, Inc. Mr. Lee owns one hundred (100%) percent of the equity of the
firm. The firm is not publicly owned or traded. There are no indirect owners of the firm or
intermediaries who have any ownership interest in the firm. As of December 31, 2025, the firm
managed, on a discretionary basis, $220,634,704 which represented 566 accounts. Client assets
are managed on an individualized basis. Clients may impose restrictions on their accounts. The
firm does not sponsor any wrap programs.
Introduction
Strategic Financial Planning, Inc. (“SFP”) offers an array of advisory services designed to
address the major areas of personal wealth management including, but not limited to, investment
portfolio management, cash-flow analysis, and investment management evaluation. SFP provides
financial planning advice, services, and recommendations and before doing so may confer with
Client and/or Client's other advisors; however, SFP does manage client portfolios on a
discretionary basis. The Client is always free to accept or reject any advice or recommendations,
in whole or in part.
SFP will work to make sure all reasonable client expectations are met. Termination of the
contract will be allowed with 30 days’ notice if the client is not satisfied for any reason. Fees
earned up to that point and including the following 30 days will have been earned by SFP and
shall be paid by the client.
Initial Planning
Upon commencement of the engagement, SFP will provide financial planning and related
consulting services regarding non-investment related matters, such as tax and estate planning,
insurance, etc. Prior to engaging SFP to provide planning or consulting services, clients are
generally required to enter into a Financial Planning & Investment Advisory Agreement with
SFP setting forth the terms and conditions of the engagement (including termination) and
describing the scope of the services to be provided.
Wealth Management
Upon completion of the initial financial plan, the client can engage SFP to provide ongoing
discretionary investment advisory services on a fee-only basis. Provided that the client has first
separately engaged SFP for the above referenced initial financial planning services, SFP's
quarterly investment advisory fee for wealth management services shall include investment
advisory services, and, to the extent requested by the client, financial planning, and consulting
services. This fee is billed quarterly in arrears. In the event that the client requires extraordinary
planning and/or consultation services (to be determined in the sole discretion of SFP), SFP may
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determine to charge for such additional services, the dollar amount of which shall be set forth in
a separate written notice to the client. Please Note. SFP believes that it is important for the client
to address financial planning issues on an ongoing basis. SFP’s advisory fee, as set forth at Item
5 below, will remain the same regardless of whether or not the client determines to address
financial planning issues with SFP.
To commence the investment advisory process, SFP will ascertain each client’s investment
objective(s) and then allocate the client’s assets consistent with the client’s designated
investment objective(s)/target asset allocation. Once allocated, SFP provides ongoing
supervision of the account(s). Before engaging SFP to provide investment advisory services,
clients are required to enter into a Financial Planning & Investment Advisory Agreement with
SFP setting forth the terms and conditions of the engagement (including termination), describing
the scope of the services to be provided, and the fee that is due from the client.
As part of SFP's ongoing wealth management services, Clients receive statements from
Custodian at least quarterly detailing account values, deposit and withdrawal activity, and the
amount of wealth management fee assessed each quarter. Clients are encouraged to review these
statements upon receipt. During the first quarter of each year, the Custodian provides 1099's in
order to aid in the tax preparation process.
In addition to financial planning and portfolio management, SFP may also at times:
Provide consultation on pension services to businesses regarding selection of plan
and/or investments, in which SFP may be compensated as a flat fee or on-going wealth
management fee as listed below
Host educational programs
Select other advisors if need determined, in which no compensation from other
advisors will be received
Additional services are provided as part of the ongoing wealth management fee or charged at a
fixed rate.
Miscellaneous
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. SFP does not serve as an attorney, accountant, or insurance agent, and no portion of
our services should be construed as same. Accordingly, SFP does not prepare legal documents,
prepare tax returns, or sell insurance products. To the extent requested by a client, we may
recommend the services of other professionals for non-investment implementation purpose (i.e.,
attorneys, accountants, insurance, etc.). The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from SFP and/or its
representatives. If the client engages any professional (i.e., attorney, accountant, insurance agent,
etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the
client agrees to seek recourse exclusively from the engaged professional. At all times, the
engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not SFP,
shall be responsible for the quality and competency of the services provided.
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Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective
client leaving an employer typically has four options regarding an existing retirement plan (and
may engage in a combination of these options): (i) leave the money in the former employer’s
plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and
rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash
out the account value (which could, depending upon the client’s age, result in adverse tax
consequences). If SFP recommends that a client roll over their retirement plan assets into an
account to be managed by SFP, such a recommendation creates a conflict of interest if SFP will
earn new (or increase its current) compensation as a result of the rollover. As SFP typically
manages retirement plan assets as part of clients’ total investment portfolios, SFP’s
compensation would typically not increase as a result of a retirement plan rollover and therefore
a conflict of interest would not be present (with possible exceptions, including rolling over a
pension balance into an IRA, in which case SFP’s compensation would increase). No client is
under any obligation to roll over retirement plan assets to an account managed by SFP.
SFP’s Chief Compliance Officer, Bryan Lee, remains available to address any questions
that a client or prospective client may have regarding the potential for conflict of interest
presented by such rollover recommendation.
Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to
recommend a broker-dealer/custodian for client accounts, SFP generally recommends that
Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-
dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for
effecting certain types of securities transactions (i.e., including transaction fees for certain
mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The
types of securities for which transaction fees, commissions, and/or other type fees (as well as the
amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain
custodians, including Schwab, do not currently charge fees on individual equity transactions,
others do). SFP does not receive any portion of these fees/charges. ANY QUESTIONS: SFP’s
Chief Compliance Officer, Bryan Lee, remains available to address any questions that a
client or prospective client may have regarding the above.
Portfolio Activity. SFP has a fiduciary duty to provide services consistent with the client’s best
interest. SFP will review client portfolios on an ongoing basis to determine if any changes are
necessary based upon various factors, including, but not limited to, investment performance,
market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a
change in the client’s investment objective. Based upon these factors, there may be extended
periods of time when SFP determines that changes to a client’s portfolio are neither necessary,
nor prudent. Clients remain subject to the fees described in Item 5 below during periods of
account inactivity.
Please Note-Use of Mutual and Exchange Traded Funds: SFP utilizes mutual funds and
exchange-traded funds for its client portfolios. In addition to SFP’s investment advisory fee
described below, and transaction and/or custodial fees discussed below, clients will also incur,
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relative to all mutual fund and exchange-traded fund purchases, charges imposed at the fund
level (e.g., management fees and other fund expenses).
Client Obligations. In performing our services, SFP shall not be required to verify any
information received from the client or from the client’s other professionals and is expressly
authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify
SFP if there is ever any change in his/her/its financial situation or investment objectives for the
purpose of reviewing/evaluating/revising our previous recommendations and/or services.
Please Note: Investment Risk. Different types of investments involve varying degrees of risk,
and it should not be assumed that future performance of any specific investment or investment
strategy (including the investments and/or investment strategies recommended or undertaken by
SFP) will be profitable or equal any specific performance level(s).
Item 5: Fees and Compensation
Financial planning is offered exclusively to our wealth management clients. As part of our
comprehensive approach, we provide personalized financial planning to help align your
investment strategy with your broader financial goals. Financial planning is designed to support
long-term success by addressing areas such as retirement planning, cash flow analysis, tax
strategies, and more—all tailored to your unique circumstances. The cost for this service is
included as part of the Wealth Management fee.
On-Going Wealth Management Fees are as follows:
Annual Fee as % of Value
Portfolio Value Range
First $3 million ($0 - $3m)
Next $3 million (>$3m - $6m)
Next $6 million (>$6m - $10m)
Over $10 million (>$10m)
1.00
0.75
0.50
0.25
The above fee schedule is a guideline for the typical Client strategy. SFP reserves the right to
negotiate fees, higher or lower, depending on unique circumstances. The above fees apply to
most client situations, but there may be exceptions. Minimum fees are determined by services
provided.
Fees are based on the portfolio value at the end of the calendar quarter and are debited directly
from the CLIENT’s investment account unless other arrangements are made prior to the
engagement. SFP continues to define portfolio value as the value of all investment accounts
(including any cash or money market securities) that ADVISOR manages and/or oversees, which
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includes, but is not limited to accounts at the Custodian, retirement plan accounts, 529 or
education funding accounts, etc. The advisory fee is a blended fee and is calculated by assessing
the percentage rates using the predefined levels of assets as shown in the above chart, resulting in
a combined weighted fee. For example, an account valued at $2,500,000 would pay an effective
fee of 0.95% with an annual fee of $23,750. The quarterly fee is determined by the following
calculation: (($2,000,000 x 1.00%) + ($500,000 x 0.75%)) ÷ 4 = $5,937.50. A minimum
quarterly fee applies and is determined based on the complexity of each client’s circumstances.
In certain instances, due to this minimum fee, a client may be charged a fee that is greater than
the industry norm, and that client may pay lower fees for comparable services from other
sources.
Certain investments recommended for ownership in Client portfolios will have their own internal
operating expenses, which are a cost to the Client that comes out of the investment's total return.
Such an example would be the annual expense ratio of a mutual fund/exchange-traded fund
product. SFP receives no economic benefit from such expenses and seeks investment products
that strive to keep such expenses low relative to other similar investments.
The custodian of Client assets will, in most cases, charge fees and/or commissions for their
services. SFP may negotiate with custodians to keep custodian and trading costs at a minimum.
All investment management services, and administration services will be provided on a fully
disclosed basis. Prior to any engagement, Client will receive, in writing, a schedule of all charges
to be assessed to the company sponsoring the plan and/or plan assets. Since the number of
possible administration firms and investment managers is numerous, any specific reference to
their charges has been omitted.
Generally, administration firms provide the record-keeping and IRS conformity testing for the
plan and charge a flat annual fee plus a per-participant charge. Investment managers will
typically charge an annual fee for assets under management depending on the size of the plan
and the number of investment options used. SFP may charge a one-time plan initiation fee,
which may vary according to complexity, to assist Client in establishing the plan investment
strategy.
Grandfathering of Minimum Account Requirements: Pre-existing advisory Clients may be
subject to SFP’s minimum account requirements and advisory fees that were in effect at the time
the Client entered into the advisory relationship. Therefore, our firm's minimum account
requirements may differ among Clients.
Fee Dispersion. SFP, in its discretion, may charge a lesser investment advisory fee,
charge a flat fee, waive its fee entirely, or charge fee on a different interval, based upon
certain criteria (i.e. anticipated future earning capacity, anticipated future additional
assets, dollar amount of assets to be managed, related accounts, account composition,
complexity of the engagement, anticipated services to be rendered, grandfathered fee
schedules, employees and family members, courtesy accounts, competition, negotiations
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with client, etc.). Please Note: As a result of the above, similarly situated clients could
pay different fees. In addition, similar advisory services may be available from other
investment advisers for similar or lower fees. ANY QUESTIONS: SFP’s Chief
Compliance Officer, Bryan Lee, remains available to address any questions that a client
or prospective client may have regarding advisory fees.
Margin Accounts: Risks/Conflict of Interest. SFP does not recommend the use of margin for
investment purposes. A margin account is a brokerage account that allows investors to borrow
money to buy securities and/or for other non-investment borrowing purposes. The
broker/custodian charges the investor interest for the right to borrow money and uses the
securities as collateral. By using borrowed funds, the customer is employing leverage that will
magnify both account gains and losses. Should a client determine to use margin, SFP will
include the entire market value of the margined assets when computing its advisory
fee. Accordingly, SFP’ fee shall be based upon a higher margined account value, resulting in
SFP earning a correspondingly higher advisory fee. As a result, the potential of conflict of
interest arises since SFP may have an economic disincentive to recommend that the client
terminate the use of margin. Please Note: The use of margin can cause significant adverse
financial consequences in the event of a market correction. ANY QUESTIONS: Our Chief
Compliance Officer, Bryan Lee, remains available to address any questions that a client or
prospective client may have regarding the use of margin.
Additional Fees and Expenses: In addition to the advisory fees paid to SFP, Clients bear certain
charges that are imposed by other third parties, such as broker-dealers, custodians, trust
companies, banks, and other financial institutions (collectively “Financial Institutions”). These
additional charges include securities brokerage commissions, transaction fees, custodial fees,
fees charged by the Independent Managers, charges imposed directly by a mutual fund or ETF in
a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other
fund expenses), margin costs, reporting charges, deferred sales charges, odd-lot differentials,
transfer taxes, wire transfer and electronic fund fees and other fees and taxes on brokerage
accounts and securities transactions. The Firm’s brokerage practices are described at length in
Item 12, below.
Item 6: Performance-Based Fees and Side-By-Side
Management
SFP is not a party to any performance or incentive-related compensation arrangements with its
clients.
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Item 7: Types of Clients
Individuals, high net worth individuals, pension plans, profit-sharing plans, charitable
organizations, corporations, and other business entities.
SFP imposes no minimum account size; however, it does require a minimum fee based on the
complexity of each client’s circumstances.
Fee Dispersion. As indicated above, SFP, in its discretion, may charge a lesser
investment advisory fee, charge a flat fee, waive its fee entirely, or charge fee on a
different interval, based upon certain criteria (i.e. anticipated future earning capacity,
anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, complexity of the engagement, anticipated services to be
rendered, grandfathered fee schedules, employees and family members, courtesy
accounts, competition, negotiations with client, etc.). In addition, based upon the scope
and compensation of the services to be provided, SFP could impose a minimum fee for
ongoing wealth management services. Please Note: In the event that the client is subject
to an annual minimum fee, the client could pay a higher percentage fee than referenced in
the above fee schedule. Please Also Note: As a result of the above, similarly situated
clients could pay different fees. In addition, similar advisory services may be available
from other investment advisers for similar or lower fees. ANY QUESTIONS: SFP’s
Chief Compliance Officer, Bryan Lee, remains available to address any questions that a
client or prospective client may have regarding advisory fees.
Item 8: Methods of Analysis, Investment Strategies
and Risk of Loss
SFP, in conjunction with research and analysis provided by unaffiliated third-party
A.
providers,
can utilize the following methods of investment analysis:
• Fundamental analysis performed on historical and present data, with the goal of making
financial forecast; and,
• Technical analysis performed on historical and present data, focusing on price and trade
volume, to forecast the direction of prices
SFP can utilize the following investment strategies when implementing investment advice given
to clients:
• Long Term Purchases (securities held at least a year); and/or,
• Short Term Purchases (securities sold within a year)
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Investment Risk. Investing in securities involves risk of loss that clients should be prepared to
bear. Different types of investments involve varying degrees of risk, and it should not be assumed
that future performance of any specific investment or investment strategy (including the
investments and/or investment strategies recommended or undertaken by SFP) will be profitable
or equal any specific performance level(s).
Investors generally face the following types of investment risks:
•
Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate.
For example, when interest rates rise, yields on existing bonds become less attractive,
causing their market values to decline.
•
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible
and intangible events and conditions. This type of risk may be caused by external factors
independent of the fund’s specific investments as well as due to the fund’s specific
investments. Additionally, each security’s price will fluctuate based on market movement
and emotion, which may or may not be due to the security’s operations or changes in its
true value. For example, political, economic, and social conditions may trigger market
events which are temporarily negative, or temporarily positive.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much
as a dollar next year, because purchasing power is eroding at the rate of inflation.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to
fixed income securities.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized product.
For example, Treasury Bills are highly liquid, while real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk
of profitability, because the company must meet the terms of its obligations in good times
and bad. During periods of financial stress, the inability to meet loan obligations may result
in bankruptcy and/or a declining market value.
B.
SFP’s methods of analysis and investment strategies do not present any significant or
unusual risks. However, every method of analysis has its own inherent risks. To perform an
accurate market analysis, SFP must have access to current/new market information. SFP has no
control over the dissemination rate of market information; therefore, unbeknownst to SFP, certain
analyses may be compiled with stale information, severely limiting the value of SFP’s analysis.
Furthermore, an accurate market analysis can only produce a forecast of the direction of market
values. There can be no assurances that a forecasted change in market value will materialize into
actionable and/or profitable investment opportunities.
SFP’s primary investment strategies—Long Term Purchases and Short-Term Purchases—are
fundamental investment strategies. However, every investment strategy has its own inherent risks
and limitations. For example, longer term investment strategies require a longer investment time-
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period to allow for the strategy to potentially develop. Shorter-term investment strategies require
a shorter investment time-period to potentially develop but, as the result of more frequent trading,
may incur higher transactional costs when compared to a longer-term investment strategy.
C.
SFP is an asset allocator, pursuant to which it allocates client investment assets on a
discretionary basis consistent with the client’s initial investment objective/target asset allocation
primarily among exchange traded funds (“ETFs”), with the remainder allocated primarily among
individual mutual funds.
Item 9: Disciplinary Information
SFP does not have any legal, financial, or other “disciplinary” item(s) to report.
Item 10: Other Financial Industry Activities and
Affiliations
As indicated at Item 4 above, SFP does not serve as an attorney, accountant, or insurance agent,
and no portion of our services should be construed as same. Accordingly, SFP does not prepare
legal documents, prepare tax returns, or sell insurance products. To the extent requested by a
client, we may recommend the services of other professionals for non-investment
implementation purpose (i.e., attorneys, accountants, insurance, etc.), including Complete Health
& Wellness, a separate business owned by SFP President, Bryan Lee, for functional medicine,
chiropractic, and other wellness services. The client is under no obligation to engage the services
of any such recommended professional, including Complete Health & Wellness. The client
retains absolute discretion over all such implementation decisions and is free to accept or reject
any recommendation from SFP and/or its representatives. Please Note-Conflict of Interest: The
recommendation by an SFP representative that a client utilize Complete Health & Wellness
presents a conflict of interest. No client is under any obligation to engage Complete Health &
Wellness. Clients are reminded that they may obtain similar services from unaffiliated providers.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
The firm has implemented an investment policy relative to personal securities transactions. This
investment policy is part of the firm’s overall Code of Ethics that serves to establish a standard
of business conduct for all of the firm’s associated persons, which is based upon fundamental
principles of openness, integrity, honesty, and trust, a copy of which is available to clients and
prospective clients upon request.
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From time to time, the Firm may deal for its own account. Whenever the Firm and a client
transact business in the same product and at the same point in time, if the two transactions are
made at different terms, the Firm will ensure that the client receives the more favorable financial
result and will accept for its own account the less favorable financial result.
The firm's Code of Ethics is monitored and reviewed on a regular basis by the firm's chief
compliance officer or designated representative. All of the firm’s associated persons must
acknowledge the terms of the Code of Ethics annually, or as amended. Issues and procedural
mandates concerning personal securities transactions and other ethical issues are memorialized in
the firm’s Code of Ethics. The advisor considers it a vital aspect of his client relations to
diligently provide his services in an ethically exemplary and accountable manner at the core of
which is the spot to place clients' interests before his own. A copy of the firm's Code of Ethics
will be provided to any client or prospective client upon request in accordance with SEC Rule
204A-1.
Item 12: Brokerage Practices
In the event that the client requests that SFP recommend a broker-dealer/custodian for execution
and/or custodial services, SFP generally recommends that investment advisory accounts be
maintained at Charles Schwab & Co., Inc. (“Schwab”). Prior to engaging SFP to provide
investment management services, the client will be required to enter into a formal Financial
Planning & Investment Advisory Agreement with SFP setting forth the terms and conditions
under which SFP shall advise on the client's assets, and a separate custodial/clearing agreement
with each designated broker-dealer/custodian.
Factors that SFP considers in recommending Schwab (or any other broker-dealer/custodian to
clients) include historical relationship with SFP, financial strength, reputation, execution
capabilities, pricing, research, and service. Broker-dealers such as Schwab can charge transaction
fees for effecting certain securities transactions (See Item 4 above). To the extent that a
transaction fee will be payable by the client to Schwab, the transaction fee shall be in addition to
SFP’s investment advisory fee referenced in Item 5 above.
To the extent that a transaction fee is payable, SFP shall have a duty to obtain best execution for
such transaction. However, that does not mean that the client will not pay a transaction fee that is
higher than another qualified broker-dealer might charge to effect the same transaction where
SFP determines, in good faith, that the transaction fee is reasonable. In seeking best execution,
the determinative factor is not the lowest possible cost, but whether the transaction represents the
best qualitative execution, taking into consideration the full range of a broker-dealer’s services,
including the value of research provided, execution capability, transaction rates, and
responsiveness. Accordingly, although SFP will seek competitive rates, it may not necessarily
obtain the lowest possible rates for client account transactions.
Research and Benefits: Although not a material consideration when determining whether to
recommend that a client utilize the services of a particular broker-dealer/custodian, SFP can
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receive from Schwab (or another broker-dealer/custodian, investment manager, platform
sponsor, mutual fund sponsor, or vendor) without cost (and/or at a discount) support services
and/or products, certain of which assist SFP to better monitor and service client accounts
maintained at such institutions. Included within the support services that can be obtained by SFP
can be investment-related research, pricing information and market data, software and other
technology that provide access to client account data, compliance and/or practice management-
related publications, discounted or gratis consulting services, discounted and/or gratis attendance
at conferences, meetings, and other educational and/or social events, marketing support-
including client events, computer hardware and/or software and/or other products used by SFP in
furtherance of its investment advisory business operations.
SFP’s clients do not pay more for investment transactions effected and/or assets maintained at
Schwab as the result of this arrangement. There is no corresponding commitment made by SFP
to Schwab, or any other any entity, to invest any specific amount or percentage of client assets in
any specific mutual funds, securities, or other investment products as result of the above
arrangement.
ANY QUESTIONS: SFP’s Chief Compliance Officer, Bryan Lee, remains available to
address any questions that a client or prospective client may have regarding the above
arrangements and the corresponding conflict of interest presented by such arrangements.
Directed Brokerage. SFP recommends that its clients utilize the brokerage and custodial
services provided by Schwab. The Firm generally does not accept directed brokerage
arrangements (but could make exceptions). A directed brokerage arrangement arises when a
client requires that account transactions be effected through a specific broker-dealer/custodian,
other than one generally recommended by the SFP (i.e., Schwab). In such client directed
arrangements, the client will negotiate terms and arrangements for their account with that broker-
dealer, and Firm will not seek better execution services or prices from other broker-dealers or be
able to "batch" the client’s transactions for execution through other broker-dealers with orders
for other accounts managed by SFP. As a result, a client may pay higher commissions or other
transaction costs or greater spreads, or receive less favorable net prices, on transactions for the
account than would otherwise be the case. Please Note: In the event that the client directs SFP to
effect securities transactions for the client’s accounts through a specific broker-dealer, the client
correspondingly acknowledges that such direction may cause the accounts to incur higher
commissions or transaction costs than the accounts would otherwise incur had the client
determined to effect account transactions through alternative clearing arrangements that may be
available through SFP. Please Also Note: Higher transaction costs adversely impact account
performance. Please Further Note: Transactions for directed accounts will generally be
executed following the execution of portfolio transactions for non-directed accounts.
Order Aggregation. Transactions for each client account generally will be effected
independently unless Firm decides to purchase or sell the same securities for several clients at
approximately the same time. The Firm may (but is not obligated to) combine or “batch” such
orders for individual equity transactions (including ETFs) with the intention to obtain better price
execution, to negotiate more favorable commission rates, or to allocate more equitably among
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Brochure Supplement
the Firm’s clients differences in prices and commissions or other transaction costs that might
have occurred had such orders been placed independently. Under this procedure, transactions
will be averaged as to price and will be allocated among clients in proportion to the purchase and
sale orders placed for each client account on any given day. In the event that the Firm becomes
aware that a Firm employee seeks to trade in the same security on the same day, the employee
transaction will either be included in the “batch” transaction or transacted after all discretionary
client transactions have been completed. The Firm shall not receive any additional compensation
or remuneration as the result of such aggregation.
Item 13: Review of Accounts
Portfolio account data is maintained on Custodian's computerized database system which tracks
all values and transactions on a daily basis. Portfolios are regularly reviewed (at least quarterly)
by the firm's financial planners. These reviews are intended to monitor asset allocation,
volatility, cash levels, and performance of holdings. In general, Advisor uses a diversified, asset
allocation approach to managing client assets, based primarily on the client's goals and
objectives, risk tolerance, and time horizon.
Statements which detail the current value of holdings, portfolio composition, aggregate account
value, and other information pertinent to the investment decision-making process are generally
provided by custodian monthly, but no less frequently than quarterly. Clients are encouraged to
review these statements upon receipt. Such reports will be sent or made available to client no
later than 15 days after the end of the calendar month directly from their custodian. Accounts
with no activity during a given month may not receive monthly statements, at the discretion of
the custodian. SFP urges you to carefully review such statements. Special communications are
directed to clients from time-to-time.
Item 14: Client Referrals and Other Compensation
SFP does not receive any economic benefit, directly or indirectly, from any third party for advice
rendered to our clients, nor do we compensate any person for Client Referrals.
As indicated at Item 12 above, SFP can receive from Schwab (and others) without cost (and/or at
a discount), support services and/or products. SFP’s clients do not pay more for investment
transactions effected and/or assets maintained at Schwab (or any other institution) as result of
this arrangement. There is no corresponding commitment made by SFP to Schwab, or to any
other entity, to invest any specific amount or percentage of client assets in any specific mutual
funds, securities, or other investment products as the result of the above arrangement. ANY
QUESTIONS: SFP’s Chief Compliance Officer, Bryan Lee, remains available to address
any questions that a client or prospective client may have regarding the above arrangement
and the corresponding conflict of interest presented by such arrangement.
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SFP does not maintain solicitor arrangements/pay referral fee compensation to non-employees
for new client introductions.
Item 15: Custody
For the service provided in opening accounts, transacting trades, wiring funds, and/or other
administrative functions, the custodian may charge certain fees.
SFP shall have the ability to deduct its advisory fee from the client’s custodial account. Clients
are provided with written transaction confirmation notices, and a written summary account
statement directly from the custodian (i.e., Schwab, etc.) at least quarterly. Please Note: To the
extent that SFP provides clients with periodic account statements or reports, the client is urged to
compare any statement or report provided by SFP with the account statements received from the
account custodian. Please Also Note: The account custodian does not verify the accuracy of
SFP’s advisory fee calculation.
In addition, certain clients have established asset transfer authorizations that permit the qualified
custodian to rely upon instructions from SFP to transfer client funds or securities to third parties.
These arrangements are disclosed at Item 9 of Part 1 of Form ADV. However, in accordance
with the guidance provided in the SEC’s February 21, 2017, Investment Adviser Association No-
Action Letter, the affected accounts are not subject to an annual surprise CPA examination.
Other services and/or practices (i.e., password possession and asset transfer authorizations) that
are disclosed at Item 9 of Part 1 of Form ADV are subject to an annual surprise CPA
examination. ANY QUESTIONS: SFP’s Chief Compliance Officer, Bryan Lee,
remains available to address any questions that a client or prospective client may
have regarding custody-related issues.
Item 16: Investment Discretion
The client can determine to engage SFP to provide investment advisory services on a
discretionary basis. Prior to engaging SFP to provide investment management services, the client
will be required to enter into a formal Financial Planning & Investment Advisory Agreement
with SFP setting forth the terms and conditions under which SFP shall manage the client's assets,
and a separate custodial/clearing agreement with each designated broker-dealer/custodian.
Clients who engage SFP on a discretionary basis may, at any time, impose restrictions, in
writing, on SFP’s discretionary authority. (i.e., limit the types/amounts of particular securities
purchased for their account, exclude the ability to purchase securities with an inverse relationship
to the market, limit or proscribe SFP’s use of margin, etc.).
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Item 17: Voting Client Securities
SFP does not vote client proxies. Clients maintain exclusive responsibility for: (1) directing the
manner in which proxies solicited by issuers of securities owned by the client shall be voted, and
(2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy
proceedings or other type events pertaining to the client’s investment assets. Clients will receive
their proxies or other solicitations directly from their custodian. Clients may contact SFP to
discuss any questions they may have with a particular solicitation.
Item 18: Financial Information
A. SFP does not require clients pay fees more than six months in advance.
B. SFP is unaware of any financial condition that is reasonably likely to impair its ability to
meet its contractual commitments relating to its discretionary authority over certain client
accounts.
C. SFP has not been the subject of a bankruptcy petition.
Privacy Notice To Customers
SFP does not disclose nonpublic personal information about our individual clients or former
clients except as permitted by law. SFP restricts access to nonpublic personal information about
you (that we may obtain from your account and your transactions) to those employees who need
to know that information to provide products or services to you or to alert you to new, enhanced,
or improved products or services we provide. SFP maintains physical, electronic, and procedural
safeguards that comply with federal standards to safeguard your nonpublic personal information.
ANY QUESTIONS: SFP’s Chief Compliance Officer, Bryan Lee, remains available to
address any questions regarding this Part 2A.
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