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The Financial Advisors, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: April 08. 2025
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of The Financial Advisors, LLC (“TFA” or the “Advisor”). If you have any questions about the content of
this Disclosure Brochure, please contact the Advisor at (978) 475-3242.
TFA is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information about TFA to assist you in determining whether to retain the Advisor.
Additional information about TFA and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 146680.
The Financial Advisors, LLC
26 Essex Street
Andover, MA 01810
Phone: (978) 475-3242
Fax: (888) 974-0397
40R Merrimac Street Suite 101W
Newburyport, MA 01950
Phone: (978) 463-6660
Fax: (888) 974-0397
http://the-financial-advisors.com
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of TFA. For convenience, the Advisor has combined these documents into a single disclose document.
TFA believes that communication and transparency are the foundation of its relationship with clients and will
continually strive to provide you with complete and accurate information at all times. TFA encourages all current
and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the
Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the last annual amendment
filing on March 8, 2024:
● The Advisor no longer offers Independent Managers, and has updated Item 4, 5, and 10
respectively.
● The Advisor no longer offers a flat fee for Wealth Management, and has updated Item 4 and 5
respectively.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material
change occurs.
You may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 146680. You may also
request a copy of this Disclosure Brochure at any time by contacting the Advisor at (978) 475-3242.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 2
www.the-financial-advisors.com
Item 3 – Table of Contents
Item 1 – Cover Page
1
Item 2 – Material Changes
Item 3 – Table of Contents
Item 4 – Advisory Services
5
A. Firm Information
B. Advisory Services Offered
C. Client Account Management
D. Wrap Fee Programs
E. Assets Under Management
5
5
8
8
8
Item 5 – Fees and Compensation
A. Fees for Advisory Services
B. Fee Billing
C. Other Fees and Expenses
D. Advance Payment of Fees and Termination
E. Compensation for Sales of Securities
7
8
10
10
11
11
Item 6 – Performance-Based Fees and Side-By-Side Management
12
Item 7 – Types of Clients
12
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
12
A. Methods of Analysis
B. Risk of Loss
12
14
Item 9 – Disciplinary Information
15
Item 10 – Other Financial Industry Activities and Affiliations
15
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
15
A. Code of Ethics
B. Personal Trading with Material Interest
C. Personal Trading in Same Securities as Clients
D. Personal Trading at Same Time as Client
15
15
15
16
Item 12 – Brokerage Practices
16
A. Recommendation of Custodian[s]
14
B. Aggregating and Allocating Trades
15
Item 13 – Review of Accounts
A. Frequency of Reviews
B. Causes for Reviews
C. Review Reports
15
15
15
17
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 3
www.the-financial-advisors.com
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by TFA
B. Compensation for Client Referrals
16
16
18
Item 15 – Custody
16
Item 16 – Investment Discretion
17
Item 17 – Voting Client Securities
17
Item 18 – Financial Information
17
Form ADV Part 2A – Wrap Brochure - Appendix 1
20
Form ADV Part 2B – Brochure Supplements
26
Privacy Policy
44
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 4
www.the-financial-advisors.com
Item 4 – Advisory Services
A. Firm Information
The Financial Advisors, LLC (“TFA” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the
laws of Massachusetts. TFA was founded in 2008. TFA is primarily owned and operated by Robert C. Miller
(Member and Chief Compliance Officer), and Michael P. Kumph (Managing Member). TFA maintains two offices
in Andover, MA and Newburyport, MA.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by TFA. If you have any questions relating to this Disclosure Brochure, please contact Mr.
Miller at (978) 463-6660.
B. Advisory Services Offered
TFA offers wealth management services including investment management and financial planning services to
individuals, high net worth individuals, trusts, estates, charitable organizations, businesses, and retirement plans
(each referred to as a “Client”).
The Advisor acts 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. TFA’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.
TFA utilizes a multi-disciplinary team approach to addressing each Client’s financial planning and investment
management needs. The Advisor’s team includes a Certified Public Accountant, IRS Enrolled Agents, and
Certified Financial Planners. Most Clients hire an attorney to work on estate plans or other legal issues. In
addition, some Clients engage other professionals, e.g., accountants or insurance agents. TFA will consult with
all such professionals as planning recommendations are formulated and/or implemented for the Client.
Investment Management:
TFA will generally construct a portfolio, consisting of institutional no-load mutual funds with low annual expense
ratios and other low-cost investment solutions such as exchange-traded funds (“ETFs”) to achieve the Client’s
investment goals. While TFA generally does not recommend individual common stocks, Clients may at times,
desire to retain certain existing holdings, or to purchase additional stocks. Reasons for a Client’s desire might
include emotional ties to the stock and/or the presence of substantial unrealized capital gains. 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. The Advisor may retain other types of investments from the
Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as
identified between the Advisor and the Client.
TFA’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. TFA will construct, implement and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. TFA evaluates and selects investments for inclusion in
Client portfolios only after applying its internal due diligence process. TFA may recommend, on occasion,
redistributing investment allocations to diversify the portfolio. TFA 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. TFA 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.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 5
www.the-financial-advisors.com
At no time will TFA accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Financial Planning Services
TFA will typically provide a variety of financial planning and consulting services to Clients as part of their Wealth
Management Advisory Services. However, TFA can also provide financial planning services on a standalone
engagement pursuant to a written financial planning agreement. Services are offered in several areas of a
Client’s financial situation, depending on their goals and objectives. A financial plan is designed to help the Client
with all aspects of financial planning without necessarily including ongoing investment management after the
financial plan is completed.
The planning process typically involves 3 to 4 meetings between the Advisor and the Client. The financial
planning topics discussed during those meeting may include, but are not limited to: a summary of holdings
statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and
providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans
including recommendations; a review of insurance policies and recommendations for changes, if necessary; one
or more retirement scenarios; estate planning review and recommendations; and education planning with funding
recommendations.
Detailed investment advice and specific recommendations are provided as part of a financial plan.
Implementation of the recommendations is at the discretion of the Client.
TFA may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor, as it would
increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations
made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement these transactions through
the Advisor.
Retirement Plan Advisory Services
TFA provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized
to the needs of the Plan and Plan Sponsor. Services generally include:
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 6
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• Plan Participant Enrollment and Education Tracking
These services are provided by TFA serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of TFA’s fiduciary status, the specific services to be rendered and
all direct and indirect compensation the Advisor reasonably expects under the engagement.
Donor Advised Fund Services
The Advisor also provides the Schwab Charitable Donor Advised Fund (“DAF”) to Clients via Schwab Charitable,
a web-based interface and administrative solution for charitable giving to philanthropic vehicles via the Schwab
Charitable Fund (“SCF”), an IRS approved philanthropic vehicle established for the purpose of managing
charitable donations contributed by or on behalf of donor clients. The DAF allows the Advisor to actively manage
assets that have been donated to and are owned by SCF, with the ability of charging an investment management
fee. At this time, TFA does not charge an investment management fee on these accounts. The Advisor’s DAF
participation is in conjunction with approval by the SCF Investment Committee for the Advisor to operate as an
advisory manager on the platform. The Schwab Charitable Fund is an independent company and unaffiliated with
the Advisor.
C. Client Account Management
Prior to engaging TFA 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:
● Establishing an Investment Strategy – TFA, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s investment goals and objectives.
● Asset Allocation – TFA 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 – TFA will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
●
Investment Management and Supervision – TFA will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
TFA typically includes the securities trading costs for the purchase or sale of investments (herein “Covered
Costs”) under its Wealth Management Advisory Services as part of its overall investment advisory fee. The
bundling of trading costs and advisory fees in considered a “Wrap Fee Program”. While many Wrap Fee
Programs include pre-defined investment options, TFA customizes its wealth management services for its
Clients. The Wrap Fee Program is solely offered by TFA to provide these services for a single fee. The Wrap Fee
Program Brochure supplements the disclosures in this section and Item 5: Fees and Compensation below. The
Wrap Fee Program Brochure is included as Appendix 1 of this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2024, TFA manages $1,108,355,372 in Client assets, $1,094,889,615 of which are
managed on a discretionary basis and $13,465,757 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or
more agreements with the Advisor.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 7
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A. Fees for Advisory Services
Wealth Management Advisory Services
Wealth management fees are paid quarterly, at the end of each calendar quarter, pursuant to the terms of the
advisory agreement. Wealth management fees are based on the following schedule:
Annual Rate (%)
1.00%
0.80%
0.60%
Assets Under Management ($)
First $1,000,000
Next $1,000,000 (Up to
$2,000,000)
Next $1,000,000 (Up to
$3,000,000)
Above $3,000,000
0.20%
Advisory fees are based on the average daily balance of the account[s] during the quarter. Fees may be
negotiable at the sole discretion of the Advisor. Certain accounts may be held under a legacy fee arrangement as
documented within the Client’s Agreement. All securities held in accounts managed by TFA will be independently
valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure
accurate billing.
Financial Planning Services
TFA additionally offers standalone financial planning services either on an hourly basis or for a fixed annual fee.
The fee for a financial plan is predicated upon the facts known at the start of the engagement. Initial and renewal
year’s financial planning services are offered for a fixed annual fee.
TFA’s hourly rate ranges from $150 to $300 per hour. Fixed engagement fees are based on the hourly rate for
the Advisory Person involved, times the anticipated number of hours required for the plan. Fixed fees range from
$1,000 to $10,000. Fees may be higher for certain complex engagements.
Financial planning fees are not negotiable. However, the Client is always the primary determiner of the scope
and number of hours of financial planning needed. An estimate for total hours and total costs will be provided to
the Client prior to engaging for these services. In the event that the Client’s situation is substantially different than
disclosed at the initial meeting, a revised fee will be provided for mutual agreement. The Client must approve the
change of scope in advance of the additional work being performed when a fee increase is necessary.
Fixed fee engagements allow the Client access to the Advisor during the term of the engagement. Consultations
after the completion of the planning process are usually by telephone or email. TFA will provide hourly planning
services for Clients who need advice for a limited scope of work. Hourly charges are the actual number of hours
for each advisor and staff person times the negotiated hourly rate. Hourly fees are due at the time of the
consultation.
TFA, at its discretion, may charge a different fee based on several factors, including: the complexity of the
services to be provided and the overall relationship with the Advisor.
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.00% and are billed
in arrears, pursuant to the terms of the retirement plan advisory agreement. Retirement plan advisory fees are
based on the market value of assets under management at the end of the calendar quarter. Fees may be
negotiable depending on the size and complexity of the Plan.
B. Fee Billing
Wealth Management Advisory Services
Wealth management fees are calculated based upon the market value of the assets as measured by the average
daily balance during the quarter. The fees are generally deducted from a designated Client account to facilitate
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 8
www.the-financial-advisors.com
billing. Clients provide written authorization permitting advisory fees to be deducted by TFA directly from their
account[s] held by the Custodian as part of the advisory agreement.
Financial Planning Services
For project-based engagements, financial planning fees are generally due in full at the time of the engagement,
unless otherwise directed by the Advisor. Fixed fee and annual retainer engagements typically require an
advance deposit of up to 50% of the expected cost of the engagement prior to commencing services. For fixed
project-based engagements, the balance shall be due upon the completion of the engagement deliverables. For
annual/ongoing retainer engagements, the Advisor will establish a progress billing schedule with one or more
additional payments required during the annual period. TFA will not accept advance payment of $1,200 or more
for any services or portion thereof that will not be completed in less than six months.
Retirement Plan Advisory Services
TFA is compensated for its services at the end of the quarter after advisory services are rendered. Retirement
plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan,
depending on the terms of the retirement plan advisory agreement.
C. Other Fees and Expenses
When using our wealth management services, Clients may incur certain fees or charges imposed by third parties
in connection with investments made on behalf of the Client’s account[s]. TFA typically includes the Covered
Costs for the purchase or sale of investments under its Wealth Management Services. The inclusion of Covered
Costs into a single, bundled fee may cost the Client more or less than if these fees were paid separately, based
on the volume of trading for the Client’s account[s]. Please see Appendix 1 – Wrap Fee Program Brochure.
There are other charges associated with a Client’s account[s]. When stocks, bonds, mutual funds, or other
securities are bought or sold a variety of fees and charges may occur. These fees or charges may include but
are not limited to: trade ticket charges, special services fees, and mutual fund expenses. TFA pays the trade
ticket charges for Clients for its discretionary trading. Securities transaction fees for Client-directed trades are the
responsibility of the Client. Special services fees such as wire transfer fees or returned-check fees are paid by
the Client.
Clients may also incur “account termination fees” upon the transfer of an account from one brokerage firm
(custodian) to another. Clients should contact their custodians (brokerage firms, bank or trust company, etc.) to
determine the amount of account termination fees, which may be charged and deducted from their accounts for
any existing accounts, which may be transferred.
In addition, all fees paid to TFA for its advisory services are separate and distinct from the expenses charged by
mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each
fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other
fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible
distribution fee. A Client may be able to invest in certain products directly, without the services of TFA, but would
not receive the services provided by TFA 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.
Institutional share classes of mutual funds may not be available to Clients directly and retail shares often carry a
higher internal expense ratio. The Client should review both the fees charged by the fund[s] and the fees charged
by TFA to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional
information.
D. Advance Payment of Fees and Termination
Wealth Management Advisory Services
TFA is compensated for its services at the end of the quarter after services are rendered. Either party may
terminate the agreement, at any time, by providing advance written notice to the other party. The Client may also
terminate the agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client.
After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 9
www.the-financial-advisors.com
termination and such fees will be due and payable by the Client. There is never a termination fee. The Client’s
agreement with the Advisor is non-transferable without the Client’s prior consent.
Financial Planning Services
TFA requires an advance deposit as described above. Either party may terminate the financial planning
agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the
financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the
Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point
of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any
unearned, prepaid planning fees from the effective date of termination. Fees are based on the percentage of the
engagement scope completed by the Advisor. There is never a termination fee. The Client’s agreement with the
Advisor is non-transferable without the Client’s prior consent.
Past Due Accounts
TFA reserves the right to stop work on any Client relationship that is more than thirty (30) days overdue. In
addition, TFA reserves the right to terminate any financial planning engagement where a Client has willfully
concealed or has refused to provide pertinent information about financial situations when necessary and
appropriate, in TFA’s judgment, to providing proper financial advice.
Retirement Plan Advisory Services
TFA is compensated for its services at the end of the quarter after advisory services are rendered. Either party
may request to terminate their services with TFA, at any time, in whole or in part, by providing advance written
notice to the other party. The Client may also terminate the retirement plan advisory agreement within five (5)
business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will
incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and
payable by the Client. The Client shall be responsible for retirement plan advisory fees up to and including the
effective date of termination. The Client’s retirement plan advisory agreement with the Advisor is non-transferable
without the Client’s prior consent.
E. Compensation for Sales of Securities
TFA 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.
Clients pay TFA for its Wealth Management Services on a percentage of the Client’s assets managed or a fixed
annual fee. This is a very common form of compensation for registered investment advisory firms and avoids the
multiple inherent conflicts of interest associated with commission-based compensation. But this percentage-
based method of compensation can still at times lead to conflicts of interest between the Advisor and Clients as
to the advice we provide. This is because any decision that results in the Client having less money under the
management of TFA would lead to the Client paying a lower total fee to TFA. For example, conflicts of interest
may arise relating to the following financial decisions in life: incur or pay down debt; gift funds to charities or to
individuals; purchases of a (larger) home or cars or other non-investment assets; expenditures of funds for travel
or other activities; and the amount of funds to place in non-managed cash reserve accounts. TFA has adopted
internal policies to properly manage these and other potential conflicts of interest. TFA’s goal is that the advice
recommended to the Client remains at all times in the Client’s best interests, disregarding any impact of the
decision upon TFA.
Item 6 – Performance-Based Fees and Side-By-Side Management
TFA does not charge performance-based fees for its investment advisory services. The fees charged by TFA are
as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by
any Client.
TFA 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.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 10
www.the-financial-advisors.com
Item 7 – Types of Clients
TFA offers wealth management services to individuals, trusts, estates, charitable organizations, businesses and
retirement plans. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These
amounts may change over time and are updated at least annually by the Advisor. TFA generally requires a
minimum size for establishing a relationship of $50,000, which may be reduced at the sole discretion of the
Advisor. Accounts of less than $50,000 may be set up when the Client and the Advisor anticipate the Client will
add additional funds to the accounts within a reasonable time. Other exceptions will apply to employees of TFA
and their relatives, or relatives of existing Clients. Client relationships vary in scope and length of service.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
TFA provides the investment strategies and its implementation for all Advisory Clients, utilizing a variety of
investment vehicles (such as mutual funds and ETFs). Clients of TFA receive the benefit of TFA’s developed
investment philosophies and strategies, research and due diligence, account monitoring, and personal financial
planning recommendations.
TFA’s Investment Committee establishes the overall investment strategies employed by the firm, reviews the
brokerage firms we recommend to our Clients, and approves of particular investments which may be used by
Advisory Persons of TFA. The Investment Committee includes Robert Miller, Michael Kumph, Louis Bonasera,
Michael Dempsey, Kevin Henderson, Lucas Deslauriers, and Anna Larina.
Extensive academic research, investment information, and certain proprietary analyses are drawn upon by TFA
in order to provide innovative investment advisory services. Each of TFA’s Clients receives an Asset Allocation
Spreadsheet, which sets forth a recommended strategic asset allocation.
In designing investment plans for Clients, TFA relies upon the information supplied by the Client and the Client’s
other professional advisors. Such information may pertain to the Client's financial situation, estate planning, tax
planning, risk management planning, short-term and long-term lifetime financial goals and objectives, investment
time horizon, and perceived current tolerance for risk. This information becomes the basis for the strategic asset
allocation plan, which we believe will best meet the Client's stated long-term personal financial goals. The
strategic asset allocation provides for investments in those asset classes which TFA believes (based on historical
data and TFA’s proprietary analysis) will possess attractive combinations of return, risk, and correlation over the
long term.
The main sources of information used by TFA in our selection of asset classes for Clients’ portfolios are the
following: Morningstar Advisor Workstation mutual fund information, Morningstar Advisor Workstation ETF
information, Morningstar Advisor Workstation stock information, and other sources. Other sources of information
include financial newspapers and magazines, research materials prepared by others, corporate rating services,
annual reports, prospectuses, filings with the U.S. Securities and Exchange Commission, and company press
releases.
The investment advice which TFA provides is based upon long-term investment strategies which incorporate the
principles of Modern Portfolio Theory. The utilization of several different asset classes as part of an investor’s
portfolio is emphasized, as this has been shown to usually effect a reduction in portfolio volatility (i.e. the
standard deviation of the portfolio returns) over long periods of time. TFA allocates and diversifies the Client’s
assets among various asset classes and then among individual investments, following the investment policy
agreed to by the Client.
TFA’s investment approach is rooted in the belief that markets are reasonably efficient (although not always
rational) and that investors’ gross returns are determined principally by asset allocation decisions. To say that
markets are “efficient” means that the price of each stock (or other security) reflects all known information about
the company involved. But fear and greed are well known to produce situations where a stock’s price is different
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
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from what a purely rational analysis of the company would suggest. For this reason, TFA typically utilizes actively
managed mutual funds and passive ETFs in constructing portfolios. Active fund managers with a long history of
excellent performance can take advantage of inefficiencies in stock pricing, buying stocks whose price is too low
and selling those whose prices are too high. Low-cost ETFs with high correlation to their benchmarks help
provide efficient diversification for the portfolios. A focus is also provided on developing and implementing
globally diversified portfolios. We seek to accomplish this through the use of low-cost and tax-efficient actively
managed institutional stock and bond mutual funds and ETFs. Investment policy and overall portfolio weightings
between equities and fixed income investments are based upon each Client’s needs and desires, perceived risk
tolerance and the need to assume various risks, and investment time horizon. The portfolios of Clients may then
follow models designed by TFA to fit the overall weightings of equities (stocks, stock mutual funds, ETFs etc.)
and fixed income investments (notes, bonds, bond funds, CDs, etc.) in an investor’s portfolio. TFA’s philosophy is
best suited for investors who desire a buy and hold strategy for a substantial portion of their funds. Even then,
investing is inherently uncertain as to future returns. TFA considers both macro- and micro-economic factors for
the purpose of weighing the risks and estimating the expected returns of various asset classes. TFA does not
generally engage in market-timing activities.
For all Clients, the investment portfolio’s strategic asset class allocation is customized to meet the specific
circumstances of a Client (e.g., the presence of investments in 401(k) or other accounts) as well as a perception
of the Client’s understanding of the fundamental forces affecting risk and return in the capital markets. In
addition, a Client’s initial or revised strategic asset allocation may be influenced by a review of the relative
valuation levels of various asset classes and the investment time horizon of that Client.
From time to time, asset class “bubbles” may occur, in which security prices are inflated beyond reasonable
levels. When bubbles “burst”, the prices may fall below appropriate levels. In such cases, we may employ a
temporary, tactical asset allocation strategy to take advantage of prices that are well below what we believe are
appropriate.
Investment Strategies
The primary investment strategy used on Client accounts is strategic asset allocation utilizing actively-managed
funds and ETFs. We rebalance portfolios at least annually. Portfolios are globally diversified to control the risk
associated with traditional markets. The investment strategy for a specific Client is based upon the objectives
stated by the Client during consultations. The Client may change these objectives at any time.
A new Client’s existing investments are evaluated in light of the desired investment policy objectives. TFA works
with new Clients to develop a plan to transition from a Client’s existing portfolio to the desired portfolio.
Investment advice may be offered on any investments held by a Client at the start of the advisory relationship.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. TFA 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.
While the methods of analysis help 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 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 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
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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. Our investment approach constantly keeps the risk of loss in mind.
Investors face the following investment risks:
● 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 is caused by external factors independent of a security’s
particular underlying circumstances. For example, political, economic and social conditions may trigger
market events.
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.
Inflation Risk: When any type of inflation is present, a dollar next year will not buy as much as a dollar
today, because purchasing power is eroding at the rate of inflation.
● Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the
currency of the investment’s originating country. This is also referred to as exchange-rate risk.
● 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.
● Business Risk: These risks are associated with a particular industry or a particular company within an
industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process,
before they can generate a profit. They carry a higher risk of profitability than an electric company, which
generates its income from a steady stream of customers who buy electricity no matter what the
economic environment is like.
● 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 company’s operations increases the risk of reduced
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.
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 TFA or any of its management persons.
TFA 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 and its
Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov
by searching with the Advisor’s name or CRD# 146680.
Item 10 – Other Financial Industry Activities and Affiliations
Tax Services
TFA may also assist Clients in the preparation of tax returns. The costs for these services are not included in the
Advisor’s fees. Clients are under no obligation to engage the Advisor for tax preparation services.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
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Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
TFA has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each
Client. This Code applies to all persons associated with TFA (“Supervised Persons”). The Code was developed
to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. TFA
and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation
of TFA’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general
principles that guide the Code. The Code 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 (978) 475-3242.
B. Personal Trading with Material Interest
TFA allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. TFA 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. TFA does not have a material interest
in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
TFA allows Supervised Persons 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.
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 TFA by conducting a coordinated review of personal accounts and the accounts of the Clients by the
Chief Compliance Officer (“CCO”) or delegate[s]. 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 TFA allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients, at no time will TFA, or any Supervised Person of TFA, transact in any security to
the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
TFA 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 TFA to direct trades to this Custodian as agreed in the applicable advisory agreement. Further,
TFA does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade
basis.
Where TFA does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to
Clients for custody and execution services. TFA may recommend the Custodian based on criteria such as, but
not limited to, reasonableness of commissions charged to the Client, services made available to the Client, its
reputation and/or the location of the Custodian’s offices. Clients are not obligated to use the recommended
Custodian and will not incur any extra fee or cost associated with using a custodian not recommended by TFA.
However, TFA may have limitations in the services it can provide.
TFA typically recommends that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a
FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. TFA
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
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maintains an institutional relationship with Schwab, whereby the Advisor receives certain economic benefits from
Schwab, 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. TFA does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, TFA receives economic benefits from its relationship with Schwab. Please see Item
14 below.
2. Brokerage Referrals - TFA does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where TFA will place trades
within the established account[s] at the Custodian designated by the Client, unless otherwise instructed. Further,
all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal
transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other
Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). TFA will not
be obligated to select competitive bids on securities transactions and does not have an obligation to seek the
lowest available transaction costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
TFA generally does not aggregate trades as most trades involve mutual funds or exchange-traded funds where
trade aggregation does not garner any Client benefit.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by the TFA Investment Committee.
Formal reviews are 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. 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 TFA if changes occur in the
Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews
may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s].
At annual reviews Clients receive written updates in the form of an Annual Financial Review packet. The written
updates may include a summary of holdings, asset allocation spreadsheet, retirement illustration, performance
report, a summary of their estate plan and insurance as well as a summary of objectives and progress towards
meeting those objectives.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
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Item 14 – Client Referrals and Other Compensation
A. Compensation Received by TFA
Participation in Institutional Advisor Platform
TFA has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like TFA. As a registered investment advisor
participating on the Schwab Advisor Services platform, TFA receives access to software and related support
without cost because the Advisor renders investment management services to Clients that maintain assets at
Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services
provided by Schwab 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 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, 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 provides 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. 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 also offers other services and financial support to TFA 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, which results in a conflict of interest. TFA believes, however, that the
selection of Schwab as Custodian is in the best interests of its Clients.
B. Compensation for Client Referrals
TFA does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client
referrals.
Item 15 – Custody
TFA does not accept or maintain custody of any Client accounts, except for the limited circumstances outlined
below:
Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction
of advisory fees, all Clients for whom TFA exercises discretionary authority must hold their assets with a
"qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and
securities and must instruct TFA to utilize that Custodian for securities transactions on their behalf. Clients are
encouraged to review statements provided by the Custodian and compare to any reports provided by TFA to
ensure accuracy, as the Custodian does not perform this review. For more information about custodians and
brokerage practices, see Item 12 – Brokerage Practices.
Money Movement Authorization - For instances where Clients authorize TFA to move funds between their
accounts, TFA and the Custodian have implemented safeguards to ensure that all money movement activities
are conducted strictly in accordance with the Client’s documented instructions.
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Summary of Holdings - Clients are frequently provided a Summary of Holdings statement by TFA. The
information contained in this report is collected from the Custodian and other sources and are believed to be
reliable. However, Clients are urged to compare their Summary of Holdings with the account statements they
receive directly from the product sponsors. These summaries may contain approximations of bank account
balances as well as the value of land and hard-to-price real estate, which are provided by the Client. These
summaries are used for long-term financial planning where the exact values of assets are not material to the
financial planning tasks.
Item 16 – Investment Discretion
TFA generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by TFA.
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 an investment advisory agreement containing all applicable limitations
to such authority. All discretionary trades made by TFA will be in accordance with each Client's investment
objectives and goals. Clients may also engage with TFA on a non-discretionary basis. In such non-discretionary
arrangements, the Client must approve each trading decision.
Item 17 – Voting Client Securities
TFA does not vote proxies on securities. Clients receive proxies directly from the Custodian and are expected to
vote their own proxies. Clients with questions about a specific proxy solicitation may call their advisor for a
recommendation. If a conflict of interest exists, it will be disclosed to the Client.
Item 18 – Financial Information
Neither TFA, nor its management, have any adverse financial situations that would reasonably impair the ability
of TFA to meet all obligations to its Clients. Neither TFA, nor any of its Advisory Persons, have been subject to a
bankruptcy or financial compromise. TFA is not required to deliver a balance sheet along with this Disclosure
Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more
in advance.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
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The Financial Advisors, LLC
Form ADV Part 2A – Appendix 1
(“Wrap Fee Program Brochure”)
Effective: April 08. 2025
This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications
and business practices for The Financial Advisors, LLC (“TFA” or the “Advisor”) services when offering services
pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the TFA
Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did not
receive the complete TFA Disclosure Brochure or you have any questions about the content of this Wrap Fee
Program Brochure or the TFA Disclosure Brochure, please contact the Advisor at (978) 475-3242.
TFA is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment advisor does not imply any specific level of skill or training.
This Wrap Fee Program Brochure provides information about TFA to assist you in determining whether to retain
the Advisor.
Additional information about TFA and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s name or CRD# 146680.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
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Item 2 – Material Changes
Form ADV 2 - Appendix 1 provides information about a variety of topics relating to an Advisor’s business
practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses wrap fee programs
offering by the Advisor.
Material Changes
There have been no material changes to this Disclosure Brochure since the last annual amendment filing on
March 8, 2024.
Future Changes
From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in our business
practices, changes in regulations or routine annual updates as required by the securities regulators. This
complete Wrap Fee Program Brochure (along with the complete TFA Disclosure Brochure) or a Summary of
Material Changes shall be provided to you annually and if a material change occurs in the business practices of
TFA.
At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the
SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s
name or CRD# 146680. You may also request a copy of this Disclosure Brochure at any time by contacting the
Advisor at (978) 475-3242.
Item 3 – Table of Contents
Item 2 – Material Changes ................................................................................................................................... 19
Item 3 – Table of Contents .................................................................................................................................. 19
Item 4 – Services Fees and Compensation ....................................................................................................... 20
Item 5 – Account Requirements and Types of Clients ..................................................................................... 21
Item 6 – Portfolio Manager Selection and Evaluation ....................................................................................... 21
Item 7 – Client Information Provided to Portfolio Managers ............................................................................ 22
Item 8 – Client Contact with Portfolio Managers ............................................................................................... 22
Item 9 – Additional Information .......................................................................................................................... 22
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
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Item 4 – Services Fees and Compensation
A. Services
The Financial Advisors, LLC (“TFA” or the “Advisor”) provides customized wealth management services for its
Clients. The TFA Wrap Fee Program Brochure is provided solely as a disclosure whereby TFA includes
securities transaction fees (herein “Covered Costs”) as part of its overall fee (as detailed in Item 5 of the
Disclosure Brochure).
Clients are typically offered a fee structure that includes, as a single fee, the Covered Costs for trading in Client
accounts along with the fees earned by TFA. The securities regulations often refer to such a structure as a “Wrap
Fee Program”. While traditional Wrap Fee Programs are rigidly pre-packaged investment programs offered by or
through broker-dealer firms, TFA customizes its investment strategies individually for its Clients. The sole
purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of
Covered Costs into the single “bundled” investment advisory fee. This Wrap Fee Program Brochure will
reference back to the TFA Disclosure Brochure in which this Wrap Fee Program Brochure is an Appendix.
Please see Item 4: Advisory Services of the Disclosure Brochure for details on TFA’s investment philosophy and
related services.
B. Program Costs
Advisory services provided by TFA are offered in a wrap fee structure whereby Covered Costs are included in
the overall investment advisory fee paid to TFA. As the level of activity in a Client’s account[s] may vary from
year to year, the annual cost to the Client may be more or less than engaging for advisory services where the
Covered Costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on
services to be provided to each Client, however, the Client is not charged more if there is higher trading activity
or other Covered Costs. A Wrap Fee structure presents a conflict of interest as the Advisor is incentivized to limit
the number of trades placed in the Client’s account[s] or to utilize securities that do not have transaction fees. As
noted above, 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. As such, the Advisor is incentivized to utilize ETFs and other equity securities to limit the overall
cost to the Advisor. The Advisor will only place Client assets into a Wrap Fee Program when it is believed to be
in the Client’s best interest. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for
complete details on fees.
C. Fees
The TFA Wrap Fee Program includes Covered Costs incurred in connection with TFA’s Wealth Management
Advisory Services. Securities transaction fees for Client-directed trades may be charged to the Client.
Clients may incur certain fees or charges imposed by third parties, which are not included in TFA’s Investment
Advisory Fee. Other fees, such as wire fees, return check fees and other fees charged by the Custodian are not
included in the Advisor's combined fee. In addition, taxes resulting from securities transactions in the Client’s
account[s] are not included in the Wrap Fee. The Advisor does not control nor share in these fees. Further, all
fees paid to TFA for investment advisory services are separate and distinct from the expenses charged by
mutual funds and exchange-traded funds to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. Accordingly, the Client should review both the fees charged by the fund[s]
and the fees charged by TFA to fully understand the total fees to be paid.
Please see item 5: Fees and Compensation for complete details in the Firm.
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D. Compensation
TFA is the sponsor and portfolio manager of this Wrap Fee Program. TFA receives investment advisory fees paid
by Clients for participating in the Wrap Fee Program and pays the Covered Costs associated with the
management of the Client’s account[s].
Item 5 – Account Requirements and Types of Clients
TFA offers investment advisory services to individuals, trusts, estates, charitable organizations, businesses and
retirement plans. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These
amounts may change over time and are updated at least annually by the Advisor. TFA generally requires a
minimum size for establishing a relationship of $50,000, however, the Advisor may waive this minimum at its sole
discretion. Accounts of less than $50,000 may be set up when the Client and the advisor anticipate the Client will
add additional funds to the accounts within a reasonable time. Other exceptions will apply to employees of TFA
and their relatives, or relatives of existing Clients.
Client relationships vary in scope and length of service. Please see Item 7 – Types of Clients in the Disclosure
Brochure for additional information.
Item 6 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
TFA serves as sponsor and as portfolio manager for the TFA Wrap Fee Program. The Advisor does not select
third-party advisors to manage the Wrap Fee Program.
Related Persons
TFA personnel or affiliates serve as portfolio manager[s] for services under this Wrap Fee Program. TFA only
manages this wrap fee program. TFA does not act as portfolio manager for any third-party wrap fee programs.
Performance-Based Fees
TFA does not charge performance-based fees for its investment advisory services. The fees charged by TFA are
as described in item 5: Fees and Compensation in the Disclosure Brochure and are not based upon the capital
appreciation of the funds or securities held by any Client. TFA 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.
Supervised Persons
TFA Advisory Persons serve as portfolio managers for the TFA Wrap Fee Program described in this Wrap Fee
Program Brochure. Please refer to the complete Disclosure Brochure (included with this Wrap Fee Program
Brochure) for details on the services provided by TFA and the backgrounds of its Advisory Persons.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the
research and analysis methods employed by the Advisor.
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. TFA 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.
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. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for
details on investment risks.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 21
www.the-financial-advisors.com
Proxy Voting
TFA 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.
Item 7 – Client Information Provided to Portfolio Managers
TFA is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information
with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also
see the TFA Privacy Policy (included after this Wrap Fee Program Brochure).
Item 8 – Client Contact with Portfolio Managers
TFA is a full-service investment management advisory firm. Clients always have direct access to the Portfolio
Managers at TFA.
Item 9 – Additional Information
A. Disciplinary Information and Other Financial Industry Activities and Affiliations
Please see Item 9 of the TFA Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure
Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the
background of the Advisor and its Advisory Persons.
Other Financial Activities and Affiliations
Please see Items 10 and 14 of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee
Program Brochure).
B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information
TFA has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This
Code of Ethics applies to all persons subject to TFA’s compliance program (our “Supervised Persons”).
Complete details on the TFA Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client
Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure).
Review of Accounts
Model portfolio reviews are performed at least quarterly by the TFA Investment Committee. Account reviews are
performed at least annually and often more frequently when market or Client conditions dictate. Account reviews
are conducted by the Investment Advisor assigned to the account. Please see Item 13 of the Form ADV Part 2A
– Disclosure Brochure.
Other Compensation
Please see Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this
Wrap Fee Program Brochure) for details on additional compensation that may be received by TFA or its
Advisory Persons. Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Program
Brochure) provides details on any outside business activities and the associated compensation.
Participation in Institutional Advisor Platform
TFA has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Charles Schwab & Co., Inc. dedicated to serving independent advisory firms like TFA. As a registered
investment advisor participating on the Schwab Advisor Services platform, TFA receives access to software and
related support without cost because the Advisor renders investment management services to Clients that
maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but
not all services provided by Schwab 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
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 22
www.the-financial-advisors.com
benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's
recommendation of this custodian over one that does not furnish similar software, systems support, or services.
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, 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 provides 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. 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 also offers other services and financial support to TFA 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, which results in a conflict of interest. TFA believes, however, that the
selection of Schwab as Custodian is in the best interests of its Clients.
Compensation for Client Referrals
TFA does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client
referrals.
Financial Information
Neither TFA, nor its management has any adverse financial situations that would reasonably impair the ability of
TFA to meet all obligations to its Clients. Neither TFA, nor any of its Advisory Persons, has been subject to a
bankruptcy or financial compromise. TFA is not required to deliver a balance sheet along with this Disclosure
Brochure, as the firm does not collect advance fees of 1,200 or more for services to be performed six months or
more in advance. Please see Item 18 of the Form ADV Part 2A – Disclosure Brochure.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 23
www.the-financial-advisors.com
Form ADV Part 2B – Brochure Supplement
for
Robert C. Miller, CFP®
Member, Chief Compliance Officer, and Financial Advisor
Effective: March 12. 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Robert C. Miller, CFP® (CRD# 1666853) in addition to the information contained in the The Financial Advisors,
LLC (“TFA” or the “Advisor”, CRD# 146680) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the TFA Disclosure Brochure or this
Brochure Supplement, please contact the Advisor at (978) 475-3242.
Additional information about Mr. Miller is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1666853.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 24
www.the-financial-advisors.com
Item 2 – Educational Background and Business Experience
Robert C. Miller, CFP®, born in 1962, is dedicated to advising Clients of TFA as a Member and the Chief
Compliance Officer and Financial Advisor and a principal owner. Mr. Miller earned a Bachelor of Arts from
Boston College and his MBA from The Carroll School of Management Boston College. Additional information
regarding Mr. Miller’s employment history is included below.
Employment History:
01/2008 to Present
Member, Chief Compliance Officer and Financial Advisor, The Financial
Advisors, LLC
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP® Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s
financial planning subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate planning;
● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real world circumstances;
● Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
● Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of
their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP®
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®
certification.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 25
www.the-financial-advisors.com
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures required for
this item. However, the Advisor encourages Clients to independently view the background of Mr. Miller on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his
Individual CRD# 1666853.
Item 4 – Other Business Activities
Mr. Miller is dedicated to the investment advisory activities of TFA’s Clients. Mr. Miller does not have any other
business activities.
Item 5 – Additional Compensation
Mr. Miller is dedicated to the investment advisory activities of TFA’s Clients. Mr. Miller does not receive any
additional forms of compensation.
Item 6 – Supervision
Mr. Miller serves as the Chief Compliance Officer of TFA. Mr. Miller can be reached at (978) 463-6660.
TFA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of TFA. Further, TFA is subject to regulatory oversight by various
agencies. These agencies require registration by TFA and its Supervised Persons. As a registered entity, TFA is
subject to examinations by regulators, which may be announced or unannounced. TFA is required to periodically
update the information provided to these agencies and to provide various reports regarding the business
activities and assets of the Advisor.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 26
www.the-financial-advisors.com
Form ADV Part 2B – Brochure Supplement
for
Michael P. Kumph, CFP®
Managing Member and Financial Advisor
Effective: March 12. 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Michael P. Kumph, CFP® (CRD# 3163298) in addition to the information contained in the The Financial Advisors,
LLC (“TFA” or the “Advisor”, CRD# 146680) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the TFA Disclosure Brochure or this
Brochure Supplement, please contact the Advisor at (978) 475-3242.
Additional information about Mr. Kumph is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 3163298.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 27
www.the-financial-advisors.com
Item 2 – Educational Background and Business Experience
Michael P. Kumph, CFP®, born in 1975, is dedicated to advising Clients of TFA as Managing Member and a
Financial Advisor. Mr. Kumph earned a MS from Bentley College in 1998 and his B.S. from Bentley College in
1997. Additional information regarding Mr. Kumph’s employment history is included below.
Employment History:
Managing Member, Financial Advisor, The Financial Advisors, LLC
01/2008 to Present
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP® Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s
financial planning subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate planning;
● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real world circumstances;
● Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
● Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of
their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP®
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®
certification.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 28
www.the-financial-advisors.com
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures required for
this item. However, the Advisor encourages Clients to independently view the background of Mr. Kumph on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his
Individual CRD# 3163298.
Item 4 – Other Business Activities
Mr. Kumph is dedicated to the investment advisory activities of TFA’s Clients. Mr. Kumph does not have any
other business activities.
Item 5 – Additional Compensation
Mr. Kumph is dedicated to the investment advisory activities of TFA’s Clients. Mr. Kumph does not receive any
additional forms of compensation.
Item 6 – Supervision
Mr. Kumph serves as Managing Member and a Financial Advisor of TFA and is supervised by Robert C. Miller,
the Chief Compliance Officer. Mr. Miller can be reached at (978) 463-6660.
TFA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of TFA. Further, TFA is subject to regulatory oversight by various
agencies. These agencies require registration by TFA and its Supervised Persons. As a registered entity, TFA is
subject to examinations by regulators, which may be announced or unannounced. TFA is required to periodically
update the information provided to these agencies and to provide various reports regarding the business
activities and assets of the Advisor.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 29
www.the-financial-advisors.com
Form ADV Part 2B – Brochure Supplement
for
Louis C. Bonasera, CPA, PFS®
Member and Financial Advisor
Effective: March 12. 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Louis C. Bonasera, CPA, PFS® (CRD# 4606122) in addition to the information contained in the The Financial
Advisors, LLC (“TFA” or the “Advisor”, CRD# 146680) Disclosure Brochure. If you have not received a copy of
the Disclosure Brochure or if you have any questions about the contents of the TFA Disclosure Brochure or this
Brochure Supplement, please contact the Advisor at (978) 475-3242.
Additional information about Mr. Bonasera is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4606122.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 30
www.the-financial-advisors.com
Item 2 – Educational Background and Business Experience
Louis C. Bonasera, CPA, PFS®, born in 1967, is dedicated to advising Clients of TFA as a Financial Advisor and
a minority owner. Mr. Bonasera earned a MS in Taxation from Northeastern University in 1998 and a B.S. in
Accounting from Merrimack College in 1989. Additional information regarding Mr. Bonasera’s employment history
is included below.
Employment History:
Financial Advisor, The Financial Advisors, LLC
01/2008 to Present
Personal Financial Specialist (“PFS®”)
The PFS® credential demonstrates that an individual has met the minimum education, experience and testing
required of a CPA in addition to a minimum level of expertise in personal financial planning. To attain the PFS®
credential, a candidate must hold an unrevoked CPA license, fulfill 3,000 hours of personal financial planning
business experience, complete 80 hours of personal financial planning CPE credits, pass a comprehensive
financial planning exam and be an active member of the AICPA. A PFS® credential holder is required to adhere
to AICPA’s Code of Professional Conduct, and is encouraged to follow AICPA’s Statement on Responsibilities in
Financial Planning Practice. To maintain their PFS® credential, the recipient must complete 60 hours of financial
planning CPE credits every three years. The PFS® credential is administered through the AICPA.
Certified Public Accountant (“CPA”)
CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the
education, experience and testing requirements for licensure as a CPA generally include minimum
college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in
accounting), minimum experience levels (most states require at least one year of experience providing services
that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting
skills, all of which must be achieved under the supervision of or verification by a CPA), and successful passage
of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of
40 hours of continuing professional education (CPE) each year (or 80 hours over a two-year period or 120 hours
over a three-year period). Additionally, all American Institute of Certified Public Accountants (AICPA) members
are required to follow a rigorous Code of Professional Conduct which requires that they act with integrity,
objectivity, due care, competence, fully disclose any conflicts of interest (and obtain client consent if a conflict
exists), maintain client confidentiality, disclose to the client any commission or referral fees, and serve the public
interest when providing financial services. The vast majority of state boards of accountancy have adopted the
AICPA’s Code of Professional Conduct within their state accountancy laws or have created their own.
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures required for
this item. However, the Advisor encourages Clients to independently view the background of Mr. Bonasera on
the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or
his Individual CRD# 4606122.
Item 4 – Other Business Activities
Mr. Bonasera is a Trustee and Property Manager of the The Bonasera Family Realty Trust. Mr. Bonasera
dedicates approximately 2.5 hours per month to this business, 0 hours during trading hours. Mr. Bonasera’s
duties include property management, rent collection, administrative duties and financial reporting.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 31
www.the-financial-advisors.com
Item 5 – Additional Compensation
Mr. Bonasera receives additional forms of compensation through his other business activities as described in
item 4.
Item 6 – Supervision
Mr. Bonasera serves as a Financial Advisor of TFA and is supervised by Robert C. Miller, the Chief Compliance
Officer. Mr. Miller can be reached at (978) 463-6660.
TFA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of TFA. Further, TFA is subject to regulatory oversight by various
agencies. These agencies require registration by TFA and its Supervised Persons. As a registered entity, TFA is
subject to examinations by regulators, which may be announced or unannounced. TFA is required to periodically
update the information provided to these agencies and to provide various reports regarding the business
activities and assets of the Advisor.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 32
www.the-financial-advisors.com
Form ADV Part 2B – Brochure Supplement
for
Michael A. Dempsey, CFP®, EA
Member and Financial Advisor
Effective: March 12. 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Michael A. Dempsey, CFP®, EA (CRD# 5526750) in addition to the information contained in the The Financial
Advisors, LLC (“TFA” or the “Advisor”, CRD# 146680) Disclosure Brochure. If you have not received a copy of
the Disclosure Brochure or if you have any questions about the contents of the TFA Disclosure Brochure or this
Brochure Supplement, please contact the Advisor at (978) 475-3242.
Additional information about Mr. Dempsey is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5526750.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 33
www.the-financial-advisors.com
Item 2 – Educational Background and Business Experience
Michael A. Dempsey, CFP®, EA, born in 1959, is dedicated to advising Clients of TFA as a Financial Advisor and
minority owner. Mr. Dempsey also earned a Bachelor of Science - Computer Science from Rochester Institute of
Technology in 1982. Additional information regarding Mr. Dempsey’s employment history is included below.
Employment History:
Financial Advisor, The Financial Advisors, LLC
04/2008 to Present
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP® Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s
financial planning subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate planning;
● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real world circumstances;
● Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
● Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of
their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP®
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®
certification.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 34
www.the-financial-advisors.com
Enrolled Agent (EA)
An enrolled agent (EA) is a federally-authorized tax practitioner who has technical expertise in the field of
taxation and who is empowered by the U.S. Department of the Treasury to represent taxpayers before all
administrative levels—examination, collection, and appeals—of the Internal Revenue Service. In addition to
taxpayer representation, enrolled agents often provide tax consultation services and prepare a wide range of
federal and state tax returns.
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures required for
this item. However, the Advisor encourages Clients to independently view the background of Mr. Dempsey on
the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or
his Individual CRD# 5526750.
Item 4 – Other Business Activities
Enrolled Agent (EA)
An enrolled agent (EA) Mr. Dempsey is a federally-authorized tax practitioner who has technical expertise in the
field of taxation and who is empowered by the U.S. Department of the Treasury to represent taxpayers before all
administrative levels—examination, collection, and appeals—of the Internal Revenue Service. In addition to
taxpayer representation, Mr. Dempsey provides tax consultation services and tax preparation for a wide range of
federal and state tax returns. Mr. Dempsey provides these services to Clients of the Advisor as needed.
Item 5 – Additional Compensation
Mr. Dempsey has additional business activities that are detailed in Item 4 above, however, no compensation is
received for performing the activity.
Item 6 – Supervision
Mr. Dempsey serves as a Financial Advisor of TFA and is supervised by Robert C. Miller, the Chief Compliance
Officer. Mr. Miller can be reached at (978) 463-6660.
TFA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of TFA. Further, TFA is subject to regulatory oversight by various
agencies. These agencies require registration by TFA and its Supervised Persons. As a registered entity, TFA is
subject to examinations by regulators, which may be announced or unannounced. TFA is required to periodically
update the information provided to these agencies and to provide various reports regarding the business
activities and assets of the Advisor.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 35
www.the-financial-advisors.com
Form ADV Part 2B – Brochure Supplement
for
Kevin J. Henderson CFP®
Financial Advisor
Effective: March 12. 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Kevin J. Henderson CFP® (CRD# 7111953) in addition to the information contained in the The Financial
Advisors, LLC (“TFA” or the “Advisor”, CRD# 146680) Disclosure Brochure. If you have not received a copy of
the Disclosure Brochure or if you have any questions about the contents of the TFA Disclosure Brochure or this
Brochure Supplement, please contact us at (978) 475-3242.
Additional information about Mr. Henderson is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7111953.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 36
www.the-financial-advisors.com
Item 2 – Educational Background and Business Experience
Kevin J. Henderson, born in 1996, is dedicated to advising Clients of TFA as a Financial Advisor. Mr. Henderson
earned a Bachelors from Bentley University in 2019. Additional information regarding Mr. Henderson’s
employment history is included below.
Employment History:
Financial Advisor, The Financial Advisors, LLC
Financial Advisor, Woodside Wealth Management
Associate Advisor, Woodside Wealth Management
Financial Planning Intern, Woodside Wealth Management
Finance Intern, Raytheon Technologies
Audit Intern, Grant Thornton LLP
Ambassador, Bentley University
Student, Bentley University
06/2022 to Present
06/2021 to 05/2022
06/2019 to 05/2021
09/2018 to 05/2019
06/2018 to 08/2018
08/2016 to 06/2017
01/2016 to 05/2019
09/2015 to 05/2019
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP® Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s
financial planning subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate planning;
● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real world circumstances;
● Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
● Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of
their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP®
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 37
www.the-financial-advisors.com
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®
certification.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Henderson. Mr. Henderson has
never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Henderson.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Henderson.
However, we do encourage you to independently view the background of Mr. Henderson on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 7111953.
Item 4 – Other Business Activities
Mr. Henderson is dedicated to the investment advisory activities of TFA’s Clients. Mr. Henderson does not have
any other business activities.
Item 5 – Additional Compensation
Mr. Henderson is dedicated to the investment advisory activities of TFA’s Clients. Mr. Henderson does not
receive any additional forms of compensation.
Item 6 – Supervision
Mr. Henderson serves as a Financial Advisor of TFA and is supervised by Robert Miller, the Chief Compliance
Officer. Mr. Miller can be reached at (978) 475-3242.
TFA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of TFA. Further, TFA is subject to regulatory oversight by various
agencies. These agencies require registration by TFA and its Supervised Persons. As a registered entity, TFA is
subject to examinations by regulators, which may be announced or unannounced. TFA is required to periodically
update the information provided to these agencies and to provide various reports regarding the business
activities and assets of the Advisor.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 38
www.the-financial-advisors.com
Form ADV Part 2B – Brochure Supplement
for
Lucas Deslauriers, CFP®
Financial Advisor
Effective: March 12. 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Lucas Deslauriers CFP® (CRD# 7710658) in addition to the information contained in the The Financial Advisors,
LLC (“TFA” or the “Advisor”, CRD# 146680) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the TFA Disclosure Brochure or this
Brochure Supplement, please contact us at (978) 475-3242.
Additional information about Mr. Deslauriers is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7710658.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 39
www.the-financial-advisors.com
Item 2 – Educational Background and Business Experience
Lucas Deslauriers CFP®, born in 1998, is dedicated to advising Clients of TFA as a Financial Advisor. Mr.
Deslauriers earned a Bachelors from Bentley University in Finance. Additional information regarding Mr.
Deslauriers’ employment history is included below.
Employment History:
Financial Planner, The Financial Advisors, LLC
Student Ambassador, Bentley University
Student, Bentley University
Intern, Morgan Stanley
Intern, Newport Gulls Baseball Club
06/2021 to Present
08/2018 to 05/2021
08/2017 to 05/2021
07/2020 to 07/2020
05/2019 to 08/2019
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP® Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s
financial planning subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate planning;
● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real world circumstances;
● Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
● Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of
their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP®
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP®
certification.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 40
www.the-financial-advisors.com
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Deslauriers. Mr. Deslauriers has
never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Deslauriers.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Deslauriers.
However, we do encourage you to independently view the background of Mr. Deslauriers on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 7710658.
Item 4 – Other Business Activities
Mr. Deslauriers is dedicated to the investment advisory activities of TFA’s Clients. Mr. Deslauriers does not have
any other business activities.
Item 5 – Additional Compensation
Mr. Deslauriers is dedicated to the investment advisory activities of TFA’s Clients. Mr. Deslauriers does not
receive any additional forms of compensation.
Item 6 – Supervision
Mr. Deslauriers serves as a Financial Advisor of TFA and is supervised by Robert Miller, the Chief Compliance
Officer. Mr. Miller can be reached at (978) 475-3242.
TFA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of TFA. Further, TFA is subject to regulatory oversight by various
agencies. These agencies require registration by TFA and its Supervised Persons. As a registered entity, TFA is
subject to examinations by regulators, which may be announced or unannounced. TFA is required to periodically
update the information provided to these agencies and to provide various reports regarding the business
activities and assets of the Advisor.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 41
www.the-financial-advisors.com
Form ADV Part 2B – Brochure Supplement
for
Anna V. Larina
Financial Advisor
Effective: March 12. 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Anna V. Larina (CRD# 5375985) in addition to the information contained in the The Financial Advisors, LLC
(“TFA” or the “Advisor”, CRD# 146680) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the TFA Disclosure Brochure or this Brochure
Supplement, please contact us at (978) 475-3242.
Additional information about Ms. Larina is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 5375985.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 42
www.the-financial-advisors.com
Item 2 – Educational Background and Business Experience
Anna V. Larina, born in 1978, is dedicated to advising Clients of TFA as an Financial Advisor. Ms. Larina earned
a Bachelors Degree in Accounting and Finance from University of Massachusetts in 2004. Additional information
regarding Ms. Larina’s employment history is included below.
Employment History:
Financial Advisor, The Financial Advisors, LLC
01/2008 to Present
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Larina. Ms. Larina has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Ms. Larina.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Ms. Larina.
However, we do encourage you to independently view the background of Ms. Larina on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
5375985.
Item 4 – Other Business Activities
Ms. Larina is dedicated to the investment advisory activities of TFA’s Clients. Ms. Larina does not have any other
business activities.
Item 5 – Additional Compensation
Ms. Larina is dedicated to the investment advisory activities of TFA’s Clients. Ms. Larina does not receive any
additional forms of compensation.
Item 6 – Supervision
Ms. Larina serves as a Financial Advisor of TFA and is supervised by Robert Miller, the Chief Compliance
Officer. Mr. Miller can be reached at (978) 475-3242.
TFA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of TFA. Further, TFA is subject to regulatory oversight by various
agencies. These agencies require registration by TFA and its Supervised Persons. As a registered entity, TFA is
subject to examinations by regulators, which may be announced or unannounced. TFA is required to periodically
update the information provided to these agencies and to provide various reports regarding the business
activities and assets of the Advisor.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 43
www.the-financial-advisors.com
Privacy Policy
Effective: March 12. 2025
Our Commitment to You
The Financial Advisors, LLC (“TFA” or the “Advisor”) is committed to safeguarding the use of personal
information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as
described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. TFA (also referred to as "we", "our"
and "us”) protects the security and confidentiality of the personal information we have and implements controls to
ensure that such information is used for proper business purposes in connection with the management or
servicing of our relationship with you.
TFA does not sell your non-public personal information to anyone. Nor do we provide such information to others
except for discrete and reasonable business purposes in connection with the servicing and management of our
relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal
information and have policies over the transmission of data. Our associates are trained on their responsibilities to
protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they
receive from us.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 44
www.the-financial-advisors.com
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including
but not limited to: processing transactions; general account
maintenance; responding to regulators or legal investigations; and credit
reporting.
No
Not Shared
Marketing Purposes
TFA does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where TFA or the
client has a formal agreement with the financial institution. We will only
share information for purposes of servicing your accounts, not for
marketing purposes.
Yes
Yes
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
No
Not Shared
Information About Former Clients
TFA does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
State-specific Regulations
Massachusetts
In response to Massachusetts law, the Client must “opt-in” to share non-public personal
information with non-affiliated third parties before any personal information is disclosed.
Client opt-in is obtained through the Client’s execution of authorization forms provided by the
third parties, by executing an Information Sharing Authorization Form, or by other written
consent by the Client, as appropriate and consistent with applicable laws and regulations.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of the Advisor’s current Privacy Policy by
contacting the Advisor at (978) 475-3242.
The Financial Advisors, LLC
26 Essex Street, Andover, MA 01810
Phone: (978) 475-3242 * Fax: (888) 974-0397
Page 45
www.the-financial-advisors.com