THINK DIFFERENT FINANCIAL PLANNING

Item 1: Cover Page Think Different Financial Planning, LLC 1300 El Camino Real, Suite 100 #84 Menlo Park, CA 94025 (650) 387-0533 Form ADV Part 2A – Firm Brochure April 21, 2026 This Brochure provides information about the qualifications and business practices of Think Different Financial Planning, LLC. If you have any questions about the contents of this Brochure, please contact us at (650) 387-0533 or will@thinkdifferentfp.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Think Different Financial Planning, LLC is registered as an Investment Adviser with the SEC. Registration of an Investment Adviser does not imply any level of skill or training. Additional information about Think Different Financial Planning, LLC is available on the SEC’s website at www.adviserinfo.sec.gov, which can be found using the firm’s identification number, 312539. 1  Item 2: Material Changes Since the previous annual filing of the Form ADV Part 2A for Think Different Financial Planning, LLC dated January, 2026, the following material changes have been made to this version of the brochure: ● The firm has applied for SEC Registration as a large advisory firm. ● Updated flat fee as discussed in Item 5 Future Changes From time to time, we may amend this Brochure to reflect changes in our business practices, changes in regulations, and routine annual updates as required by securities regulators. Either this complete Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of Think Different Financial Planning, LLC. At any time, you may view the current Brochure online at the SEC's Investment Adviser Public Disclosure website at http://www.adviserinfo.sec.gov by searching for our firm name or by our CRD number 312539. You may also request a copy of this Brochure at any time, by contacting us at (650) 387-0533. 2  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees and Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12: Brokerage Practices Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information Item 19: Requirements for State-Registered Advisers Form ADV Part 2B – Brochure Supplement 1 2 3 4 7 9 9 9 13 13 14 15 17 17 18 18 18 18 19 20 3  Item 4: Advisory Business Description of Advisory Firm Think Different Financial Planning, LLC (hereinafter referred to as “TDFP”, “we”, “firm”, and “us”) is registered as an Investment Adviser with the United States Securities and Exchange Commission (SEC). We are a limited liability company founded in January of 2021. William Steinberger is the principal owner of TDFP. Types of Advisory Services Wealth Management Services Wealth Management encompasses investment management services and financial planning. Our firm provides continuous advice to a Client regarding the investment of Client funds based on the individual needs of the Client. Through personal discussions in which the goals and objectives based on a Client's particular circumstances are established, we develop a Client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation targets. We will also review and discuss a Client’s prior investment history, as well as family composition and background. include developing an Wealth management services investment policy statement, building portfolio recommendations and implementing these recommendations at a third party custodian. Wealth management services also include the ongoing monitoring of the investment portfolio, including quarterly performance reporting, asset allocation analysis, rebalancing and tax-loss harvesting recommendations. Investment recommendations are primarily limited to open-end mutual funds and exchange-traded funds, but we also serve to help clients with existing positions. We do not advise our clients to invest in individual stocks and bonds. Account supervision is guided by the stated objectives of the Client (e.g., maximum capital appreciation, growth, income, or growth, and income), as well as tax considerations. TDFP manages account(s) on a discretionary basis. More information regarding discretion can be found in Item 16 of this Brochure. Use of Third Party Managers, Outside Managers, or Sub-Advisors (TAMPs) TDFP may determine that opening an account with a professional independent third-party money manager is in your best interests. If so, we will provide you with information about the money manager, including the services they provide and the fees they charge. You may approve or disapprove the use of the independent money manager for your account. Any money manager selected to manage an account for you will have discretion to determine the securities to buy and sell for the account, subject to any reasonable restrictions imposed by you. You will be provided with the money manager’s ADV Disclosure Brochure, which you should carefully review for important details about the manager and their fees and services. GeoWealth Management, LLC, TDFP’s chosen third-party money manager, offers several different portfolios, including customized index portfolios built by SmartHarvest Portfolios, LLC and Aperio (a division of BlackRock). TDFP has entered into an agreement with GeoWealth Management, LLC to assist in managing client portfolios. TDFP is not affiliated with GeoWealth Management, LLC, SmartHarvest, or Aperio. If we recommend the use of an independent money manager, TDFP will: ● Assist in the identification and ongoing review of your investment objectives ● Recommend and assist in the selection of appropriate money managers 4  ● Recommend specific investment strategies offered by the money managers ● Assist in the review of performance and progress toward your investment objectives ● Recommend any appropriate changes to your investment strategy ● Recommend the hiring and firing of money managers, as needed. Ongoing Comprehensive Financial Planning This service involves working one-on-one with a planner over an extended period of time. Clients get to work with a planner who will work with them to develop and implement their plan. The planner will monitor the plan, recommend any changes and ensure the plan is up-to-date. Upon desiring a comprehensive plan, a Client will be taken through establishing their goals and values around money. They will be required to provide information to help complete the following areas of analysis: net worth, cash flow, insurance, credit scores/reports, employee benefits, retirement planning, insurance, investments, college planning, and estate planning. Once the Client's information is reviewed, their plan will be built and analyzed, and then the findings, analysis, and potential changes to their current situation will be reviewed with the Client. Clients subscribing to this service will receive a written or an electronic report, providing the Client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. If a follow-up meeting is required, we will meet at the Client's convenience. The plan and the Client's financial situation and goals will be monitored throughout the year and follow-up phone calls and emails will be made to the Client to confirm that any agreed-upon actionable steps have been carried out. On an annual basis, there will be a full review of this plan to ensure its accuracy and ongoing appropriateness. Any needed updates will be implemented at that time. In general, the financial plan will address any or all of the following areas of concern: ● Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. ● Tax Planning: We may review our clients tax returns and overall situation to look to advise on what can be done to lower overall state and federal income taxes. Recommendations may be made around filing status, itemizing deductions, contributing more to a company retirement account, donating to nonprofits, or other tax-minimization strategies. ● College Savings: Includes projecting the amount that will be needed to achieve college or other post-secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid or the best way to contribute to your children or grandchildren’s (if appropriate) college expenses. ● Employee Benefits Optimization: We will provide review and analysis as to whether you, as an employee, are taking full advantage of your employee benefits. 5  ● Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request. ● Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. ● Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile. ● Investment Analysis: This may involve developing an asset allocation strategy to meet clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing company retirement accounts (e.g., 401(k) or 403(b)), reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. ● Retirement Planning: Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). ● Philanthropic Planning: This may involve reviewing how much the client may want to donate and determining the most tax-efficient ways to do so, whether it is through donating highly-appreciated securities, donor-advised funds, etc. Project-Based Financial Planning Services Project-Based Financial Planning is a one-time engagement that is billed on an hourly basis. Clients may select from one of the financial planning topics outlined above or a specific topic they want TDFP to address. Financial Planning involves an evaluation of a Client's current and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they affect and are affected by the entire financial and life situation of the Client. Clients purchasing this service will receive a written or an electronic report, providing the Client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. Client Tailored Services and Client Imposed Restrictions We offer the same suite of services to all of our clients. However, specific Client financial plans and their implementation are dependent upon the Client Investment Policy Statement which outlines each Client’s current 6  situation (income, tax levels, and risk tolerance levels) and is used to construct a Client-specific plan to aid in the selection of a portfolio that matches Client’s restrictions, needs, and targets. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. However, approval of such requests are at the firm’s sole discretion. Wrap Fee Programs We do not participate in wrap fee programs. Assets under Management TDFP reports $141,525,076 in discretionary assets under management and $0 in non-discretionary assets under management as of December 31, 2025. Item 5: Fees and Compensation Please note, unless a Client has received this brochure at least 48 hours prior to signing an investment advisory and/or Financial Planning Agreement (collectively, “Client Contract”), the Client Contract may be terminated by the Client within five (5) business days of signing the Client Contract without incurring any fees. How we are paid depends on the type of advisory services we perform. Below is a brief description of our fees, however, you should review your executed Client Contract for more detailed information regarding the exact fees you will be paying. Legacy Clients may be billed under a different fee schedule than what is described below. Wealth Management Services Fees for wealth management are charged based on a flat annual fee of $22,000, paid quarterly in advance. The quarterly fee is calculated by dividing the annual fee by four (4). Our fees are not tied to the value of the client’s investment portfolio. We feel strongly that this structure is the most equitable to investors and helps to reduce the conflicts of the asset-gathering model. Fees may be negotiable on a per-client basis. Clients may select to pay fees through direct deduction from Client accounts held at an unaffiliated third-party custodian, check, credit card, or electronic funds transfer. Accounts initiated during a calendar quarter will be charged a prorated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice by either party. Upon receipt of any written notice of termination, TDFP will no longer charge an advisory fee effective immediately or on the date indicated by the Client. Any advisory fee collected in advance that is unearned will be refunded to the Client. Use of Third Party Managers, Outside Managers, or Sub-Advisors (TAMPs) Fees billed by GeoWealth Management, LLC, our chosen third party manager, are $1,500 per year when household assets are less than $10,000,000. The $1,500 fee is included in the $22,000 fee for clients of TDFP who’ve engaged the firm for Wealth Management Services as described above. For example, assuming the non-discounted fee of $22,000, a client with $12,000,000 in assets will pay an annual 7  fee of $23,500, which includes the outside manager's fee, while a client with $11,999,999.99 will pay an annual fee of $23,000 (including the outside manager’s fee). Further examples are summarized in the table* below: *This table is intended for illustration purposes only and is not an exhaustive table of fees applicable to client accounts with a greater amount of assets. For accounts utilizing customized index portfolios built by SmartHarvest or Aperio, clients are charged an annual asset-based fee of 0.20% that is in addition to TDFP’s advisory fee. There is an account size minimum of $250,000 in order to use customized index portfolios built by SmartHarvest or Aperio. GeoWealth’s fees are billed quarterly, in advance. When GeoWealth is utilized, they will debit their fee and TDFP’s fees from the client’s managed account(s) and remit TDFP’s portion to us. For accounts utilizing customized index portfolios built by SmartHarvest or Aperio, SmartHarvest or Aperio will debit their annual asset-based fee directly from the clients’ managed account(s) pursuant to written authorization from the client. Ongoing Comprehensive Financial Planning Fees for Ongoing Comprehensive Financial Planning are charged based on a flat annual fee of $20,500, paid quarterly in advance. The quarterly fee is calculated by multiplying the annual fee by the number of days in a quarter and dividing it by the number of days in the year. Fees may be negotiable on a per client basis. Fees for this service may be paid by electronic funds transfer, or check. A Client Contract may be terminated with written notice by either party. Upon receipt of any written notice of termination, TDFP will no longer charge a financial planning fee effective immediately or on the date indicated by the Client. Any financial planning fee collected in advance that is unearned will be refunded to the Client. Project-Based Financial Planning We also provide financial planning through an hourly fee structure. The hourly rate is $325 per hour, depending on complexity. An estimate of the number of hours needed to complete the project will be agreed upon at the signing of the Agreement. The fee may be negotiable in certain cases. Half of the estimated fee is due upon signing the Agreement, the remainder is due upon completion of the engagement. In the event of early termination by the Client, any fees for the hours already worked will be due. Fees for this service may be paid by electronic funds transfer (EFT), credit card, or check. Other Types of Fees and Expenses Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange-traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees, and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. 8  Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for Client’s transactions and determining the reasonableness of their compensation (e.g., commissions). We do not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management We do not offer performance-based fees and do not engage in side-by-side management. Item 7: Types of Clients We provide financial planning and portfolio management services to individuals and high net-worth individuals. We do not have a minimum account size requirement to open or maintain an account under our management. However, third-party managers may have their own account minimums. Please refer to the third-party managers Form ADV and/or investment advisory agreement to see if your account requires a certain minimum threshold. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Research proves that passive investing works for all investors, regardless of size or scope. Our investment strategy begins with a general long-term acceptance of the Efficient Market Hypothesis, which states that the primary driver of a portfolio’s risk and return characteristics is determined by asset allocation, and not security selection. As countless studies have proven, active management as a whole, underperforms the market portfolio, and attempting to pick investments or investment managers which will outperform the market is more an act of luck than skill. To protect our clients from the needless costs of active management and the inevitable underperformance that results, clients are advised to invest in passive strategies, also known as index funds. The primary vehicles recommended to TDFP clients are exchange-traded funds. As with any stock-based investment, mutual funds, including passively managed mutual funds, carry the risk of losses. While we can reduce company-specific risk through diversification, eliminate manager-risk with passive portfolios and reduce overall portfolio volatility with a broad mix of stocks, bonds and other assets, we cannot eliminate the risk of fluctuation that comes with investing in stocks and bonds. It is always possible in any given week, month or year that an investor’s portfolio value could be less than the previous period. The Efficient Market Hypothesis dictates that it is this market risk that offers investors potential long-term rewards, so we aim to reduce other previously mentioned risks wherever possible. Modern Portfolio Theory The underlying principles of MPT are: ● Investors are risk averse. The only acceptable risk is that which is adequately compensated by an expected return. Risk and investment return are related and an increase in risk requires an increased expected return. ● Markets are efficient. The same market information is available to all investors at the same time. The market prices every security fairly based upon this equal availability of information. 9  ● ● ● The design of the portfolio as a whole is more important than the selection of any particular security. The appropriate allocation of capital among asset classes will have far more influence on long-term portfolio performance than the selection of individual securities. Investing for the long-term (preferably longer than ten years) becomes critical to investment success because it allows the long-term characteristics of the asset classes to surface. Increasing diversification of the portfolio with lower correlated asset class positions can decrease portfolio risk. Correlation is the statistical term for the extent to which two asset classes move in tandem or opposition to one another. Use of Outside Managers: We may refer Clients to Third Party Managers, Outside Managers, or Sub-Advisors (collectively, “TAMPs”). Our analysis of TAMPs involves the examination of the experience, expertise, investment philosophies, and past performance of the TAMPs in an attempt to determine if that TAMP has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the TAMP's underlying holdings, strategies, concentrations, and leverage as part of our overall periodic risk assessment. Additionally, as part of our due diligence process, we survey the TAMP's compliance and business enterprise risks. A risk of investing with a TAMP who has been successful in the past is that they may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a TAMP's portfolio. There is also a risk that a TAMP may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our Clients. Moreover, as we do not control the TAMP's daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. Passive Investment Management We primarily practice passive investment management. Passive investing involves building portfolios that are composed of various distinct asset classes. The asset classes are weighted in a manner to achieve the desired relationship between correlation, risk, and return. Funds that passively capture the returns of the desired asset classes are placed in the portfolio. The funds that are used to build passive portfolios are typically index mutual funds or exchange-traded funds. Passive investment management is characterized by low portfolio expenses (i.e. the funds inside the portfolio have low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency (because the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal). In contrast, active management involves a single manager or managers who employ some method, strategy or technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a designated benchmark. Material Risks Involved All investing strategies we offer involve risk and may result in a loss of your original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other investment or security. Material risks associated with our investment strategies are listed below. ● Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. 10  ● Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. ● Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the Client’s portfolio. ● Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s performance. ● Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate investments at prices we consider reasonable or favorable or find buyers at any price. ● Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. ● Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. ● Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. ● Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your investments remains the same. Risks Associated with Securities Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or less. Being unsecured the risk to the investor is that the issuer may default. Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks. Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, 11  investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on factors such as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations. Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the complete loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price. Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are delisted from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the Clients invest. Mutual Funds When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). Socially Responsible Investing - TDFP may utilize various socially conscious investment approaches if a client desires. TDFP may construct portfolios that utilize mutual funds, ETFs, or individual securities with the purpose of incorporating socially conscious principles into a client’s portfolio. These portfolios may sometimes also be customized to reflect the personal values of each individual, family, or organization. This allows the Firm’s clients to invest in a way that aligns with their values. TDFP may rely on mutual funds and ETFs that incorporate Environmental, Social and Governance (“ESG”) research as well as positive and negative screens related to specific business practices to determine the quality of an investment on values-based merits. Additionally, TDFP may construct portfolios of individual securities in order to provide clients with a greater degree of control over the socially conscious strategies they are utilizing. TDFP relies on third-party research when constructing portfolios of individual securities with socially conscious considerations. 12  Item 9: Disciplinary Information Criminal or Civil Actions TDFP and its management persons have not been involved in any criminal or civil action. Administrative Enforcement Proceedings TDFP and its management persons have not been involved in administrative enforcement proceedings. Self-Regulatory Organization Enforcement Proceedings TDFP and its management persons have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of TDFP or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Neither TDFP or its management persons is registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Neither TDFP or its management persons is registered, or have an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor. Neither TDFP or its management persons have any relationship or arrangement with any related parties. TDFP only receives compensation directly from Clients. Recommendations or Selections of Other Investment Advisers As referenced in Item 4 of this brochure, TDFP recommends Clients to TAMPs to manage their accounts. In the event that we recommend a TAMP, we do not share in their advisory fee. Our fee is separate and in addition to their compensation (as noted in Item 5 of this brochure). In addition, you will be provided a copy of the TAMP’s Form ADV 2A, Firm Brochure, which also describes the TAMP’s fee. You are not obligated, contractually or otherwise, to use the services of any TAMP we recommend. Moreover, TDFP will only recommend a TAMP who is properly licensed or registered as an investment adviser. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm has a duty of utmost good faith to act solely in the best interests of each Client. In the simplest of terms this means that our first obligation is to put the client’s needs above all other interests or conflicts. TDFP takes our fiduciary duty very seriously and has built our business model around our obligation to minimize conflicts of interest with our clients and to truly make recommendations that are in their best interests. Our Clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted by the CFP® Board of Standards Inc., and accepts the obligation not only to comply with the mandates and requirements 13  of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities. Code of Ethics Description This Code of Ethics does not attempt to identify all possible conflicts of interest, and compliance with each of its specific provisions will not shield our firm or its access persons from liability for misconduct that violates a fiduciary duty to our Clients. A summary of the Code of Ethics' Principles is outlined below. Integrity ‒ Access persons shall offer and provide professional services with integrity. ● ● Objectivity ‒ Access persons shall be objective in providing professional services to Clients. ● Competence ‒ Access persons shall provide services to Clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. ● Fairness ‒ Access persons shall perform professional services in a manner that is fair and reasonable to Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. ● Confidentiality ‒ Access persons shall not disclose confidential Client information without the specific consent of the Client unless in response to proper legal process, or as required by law. ● Professionalism ‒ Access persons conduct in all matters shall reflect the credit of the profession. ● Diligence ‒ Access persons shall act diligently in providing professional services. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest Neither our firm, its access persons, or any related person is authorized to recommend to a Client or effect a transaction for a Client, involving any security in which our firm or a related person has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, principal transaction, among others. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Our firm, its access persons, and its related persons may buy or sell securities similar to those we recommend to Clients for their accounts. In an effort to reduce or eliminate certain conflicts of interest, our Code of Ethics may require that we restrict or prohibit access persons’ transactions in specific reportable securities. Any exceptions or trading pre-clearance must be approved by TDFP’s Chief Compliance Officer in advance of the transaction in an account. TDFP maintains a copy of access persons’ personal securities transactions as required. Trading Securities At/Around the Same Time as Client’s Securities From time to time our firm, its access persons, or its related persons may buy or sell securities for themselves at or around the same time as they buy or sell securities for Clients’ account(s). To address this conflict, our Code of Ethics requires that we purchase or sell securities for our clients’ accounts, if suitable and appropriate, before purchasing or selling any of the same securities for any accounts owned by us or our access persons. The only exception to this policy is where our firm or its access persons’ transactions are bundled in an aggregate (“block”) trade simultaneously with client accounts. This policy is not applicable to securities where no conflict of interest exists, such as shares of mutual funds that are equally priced daily. 14  Item 12: Brokerage Practices Factors Used to Select Custodians and/or Broker-Dealers In recommending broker-dealers, we have an obligation to seek the “best execution” of transactions in Client accounts. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the broker-dealer’s services. The factors we consider when evaluating a broker-dealer for best execution include, without limitation, the broker-dealer’s: ● Execution capability; ● Commission rate; ● Financial responsibility; ● Responsiveness and customer service; ● Custodian capabilities; ● Research services/ancillary brokerage services provided; and ● Any other factors that we consider relevant. With this in consideration, our firm recommends Charles Schwab & Co., Inc. (“Schwab”), an independent and unaffiliated SEC registered broker-dealer firm and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Although clients may request us to use a broker-dealer of their choosing, we generally recommend that clients open brokerage accounts with Schwab. We are not affiliated with Schwab. The Client will ultimately make the final decision of the Custodian to be used to hold the Client’s investments by signing the selected broker-dealer’s account opening documentation. Your brokerage and custody costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. Research and Other Soft-Dollar Benefits Schwab may provide us with certain brokerage and research products and services that qualify as “brokerage or research services” under Section 28(e) of the Securities Exchange Act of 1934 (“Exchange Act”). This is commonly referred to as a “soft dollar” arrangement. These research products and/or services will assist us in our investment decision making process. Such research generally will be used to service all of our client accounts, but brokerage charges paid by the client may be used to pay for research that is not used in managing that specific client’s account. Products and Services Available to Us From Schwab Schwab Advisor Services (formerly Schwab Institutional) is Schwab’s business serving independent investment advisory firms like us. They provide our clients and us with access to its institutional brokerage-- trading, custody, reporting, and related services--many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. 15  Services That Benefit You: Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services That May Not Directly Benefit You: Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: ● Provide access to client account data (such as duplicate trade confirmations and account statements); ● Facilitate trade execution and allocate aggregated trade orders for multiple client accounts; ● Provide pricing and other market data; ● Facilitate payment of our fees from our clients’ accounts; and ● Assist with back-office functions, recordkeeping, and client reporting. Services That Generally Benefit Only Us: Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: ● Educational conferences and events; ● Technology, compliance, legal, and business consulting; ● Publications and conferences on practice management and business succession; and ● Access to employee benefit providers, human capital consultants, and insurance providers. Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide these services to use. Schwab may also discount or waive its fees for some of these services or pay all or a part of the third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our personnel. Brokerage for Client Referrals We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use If the client selects a broker-dealer other than the recommended broker-dealer (i.e., directed brokerage), you are advised that we may be unable to seek best execution of your transactions and your commission costs may be higher than those of our recommended broker-dealer. For example, in a directed brokerage account, you may pay higher brokerage commissions and/or receive less favorable prices on the underlying securities purchased or sold for your account because we may not be able to aggregate your order with the orders of other clients. In addition, where you direct brokerage, we may place orders for your transactions after we place transactions for clients using our recommended broker-dealer. We reserve the right to reject your request to use a particular broker-dealer if we believe such selection would frustrate our management of your account, or for any other reason. 16  Aggregating (Block) Trading for Multiple Client Accounts When appropriate, we combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion, regarding particular circumstances and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or access persons may participate in block trading with your accounts; however, they will not be given preferential treatment. Outside Managers used by TDFP may block Client trades at their discretion. Their specific practices are further discussed in their ADV Part 2A, Item 12. Item 13: Review of Accounts Will Steinberger, Founder & CEO of TDFP, will work with Clients to obtain current information regarding their assets and investment holdings and will review this information as part of our financial planning services. TDFP does not provide specific reports to Clients, other than financial plans. Clients who engage us for wealth management services will have their account(s) reviewed regularly on a quarterly basis by Will Steinberger, Founder & CEO. The account(s) are reviewed with regards to the Client’s investment policies and risk tolerance levels. Events that may trigger a special review would be unusual performance, addition or deletions of Client-imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per Client's needs. Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. TDFP will provide written reports to wealth management Clients on a quarterly basis. We urge Clients to compare these reports against the account statements they receive from their custodian. Item 14: Client Referrals and Other Compensation Beyond what is disclosed in Item 12 above, we do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our Clients. Nor do we, directly or indirectly, compensate any person who is not advisory personnel for Client referrals. Item 15: Custody TDFP does not accept custody of Client funds except in the instance of withdrawing TDFP’s management fees. For Client accounts in which TDFP directly debits their management fee: i. ii. TDFP will send a copy of its invoice to the custodian at the same time that it sends the Client a copy. The custodian will send at least quarterly statements to the Client showing all disbursements for the account, including the amount of the management fee. 17  iii. The Client will provide written authorization to TDFP, permitting them to be paid directly for their accounts held by the custodian. Clients should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains Client's investment assets. We urge you to carefully review such statements and compare such official custodial records to the account statements or reports that we may provide to you. Our statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16: Investment Discretion For those Client accounts where we provide Wealth Management Services, we maintain discretion over Client accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold. Investment discretion is explained to Clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm discretion over the account(s). Additionally, the discretionary relationship will be outlined in the advisory contract and signed by the Client. Clients may limit our discretion by requesting certain restrictions on investments. However, approval of such requests are at the firm’s sole discretion. Item 17: Voting Client Securities TDFP does not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the Client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies. Item 18: Financial Information We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to our Clients, nor have we been the subject of any bankruptcy proceeding. We do not have custody of Client funds or securities, except as disclosed in Item 15 above, or require or solicit prepayment of more than $1,200 in fees six months in advance. 18  Think Different Financial Planning, LLC 1300 El Camino Real, Suite 100 #84 Menlo Park, CA 94025 (650) 387-0533 Form ADV Part 2B – Brochure Supplement February 26, 2026 Will Steinberger, CFP® - Individual CRD# 5541333 Founder, CEO and Chief Compliance Officer This brochure supplement provides information about Will Steinberger that supplements the Think Different Financial Planning, LLC (“TDFP”) brochure. A copy of that brochure precedes this supplement. Please contact Will Steinberger if the TDFP brochure is not included with this supplement or if you have any questions about the contents of this supplement. Additional information about Will Steinberger is available on the SEC’s website at www.adviserinfo.sec.gov which can be found using the identification number 5541333. 19  Item 2: Educational Background and Business Experience William (“Will”) Steinberger Born: 1987 Educational Background • 2010 – Bachelor of Science, Business, Concentration in Finance, San Jose State University Business Experience • • • • • 03/2021 – Present, Think Different Financial Planning, LLC, Founder, CEO, and CCO 12/2018 – 03/2021, Opes Wealth Management, Wealth Advisor 10/2017 – 12/2018, Opes Advisors, Inc., Associate Wealth Advisor 10/2016 – 12/2016, Buckingham Asset Management, Portfolio Advisor 08/2014 – 10/2016, Raub Brock Capital Management, LP, Associate Financial Planner Professional Designations: CFP (Certified Financial Planner)®: 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 20  ● 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. in suspension or permanent revocation of CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result their CFP® certification. Item 3: Disciplinary Information No management person at Think Different Financial Planning, LLC has ever been involved in an arbitration claim of any kind or been found liable in a civil, self-regulatory organization, or administrative proceeding. Item 4: Other Business Activities Will Steinberger is not involved with outside business activities. Item 5: Additional Compensation Will Steinberger does not receive any economic benefit from any person, company, or organization, in exchange for providing Clients advisory services through TDFP. Item 6: Supervision Will Steinberger, as Chief Compliance Officer of TDFP, is the sole investment adviser representative. Should there be additional representatives in the future, Will Steinberger would be responsible for their supervision. Will Steinberger is bound by TDFP’s Code of Ethics. Clients may contact Will Steinberger at the phone number on this brochure supplement. 21