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Firm Brochure
(Part 2A of Form ADV)
2180 SR 434, Suite 6140
Longwood, FL 32779
PHONE: 407-331-6961
FAX: 888-807-6590
EMAIL: tim@timlooneyinvestments.com
WEBSITE: www.timlooneyinvestments.com
This brochure provides information about the qualifications and business
practices of Tim Looney Investments, LLC. Being registered as a registered
investment adviser does not imply a certain level of skill or training. If you have
any questions about the contents of this brochure, please contact us at 407-331-
6961 or by email at tim@timlooneyinvestments.com. The information in this
brochure has not been approved or verified by the United States Securities and
Exchange Commission, or by any state securities authority.
Additional information about Tim Looney Investments, LLC (IARD #164413) is
available on the SEC’s website at www.adviserinfo.sec.gov.
February 13, 2026
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Tim Looney Investments, LLC
Item 2: Material Changes
Annual Update
Material Changes since the Last Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
•
Since the last update on February 7, 2025 the following has been updated:
•
John McCully is now the Chief Compliance Officer and to disclose the firm’s most
recent assets under management calculation.
Full Brochure Available
Item 10 has been updated to indicate there are no material relationships to disclose.
This Firm Brochure being delivered is the complete brochure for the Firm.
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Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Firm Brochure ............................................................................................................................................................................. i
Item 2: Material Changes ....................................................................................................................................................... ii
Annual Update ..........................................................................................................................................................................................ii
Material Changes since the Last Update ........................................................................................................................................ii
Item 3: Table of Contents ...................................................................................................................................................... iii
Full Brochure Available ........................................................................................................................................................................ii
Item 4: Advisory Business ...................................................................................................................................................... 1
Firm Description ......................................................................................................................................................................................1
Types of Advisory Services .................................................................................................................................................................1
Client Tailored Services and Client Imposed Restrictions ....................................................................................................4
Wrap Fee Programs ................................................................................................................................................................................4
Item 5: Fees and Compensation ........................................................................................................................................... 4
Client Assets under Management .....................................................................................................................................................4
Method of Compensation and Fee Schedule ................................................................................................................................4
Client Payment of Fees ..........................................................................................................................................................................5
Additional Client Fees Charged .........................................................................................................................................................5
Prepayment of Client Fees ...................................................................................................................................................................6
Item 6: Performance-Based Fees ......................................................................................................................................... 6
External Compensation for the Sale of Securities to Clients ................................................................................................6
Item 7: Types of Clients ........................................................................................................................................................... 6
Sharing of Capital Gains ........................................................................................................................................................................6
Description .................................................................................................................................................................................................6
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................................................... 6
Account Minimums .................................................................................................................................................................................6
Methods of Analysis ...............................................................................................................................................................................6
Investment Strategy ...............................................................................................................................................................................6
Item 9: Disciplinary Information ......................................................................................................................................... 8
Security Specific Material Risks ........................................................................................................................................................7
Criminal or Civil Actions.......................................................................................................................................................................8
Administrative Enforcement Proceedings ...................................................................................................................................8
Item 10: Other Financial Industry Activities and Affiliations ................................................................................... 8
Self Regulatory Organization Enforcement Proceedings ......................................................................................................8
Broker-Dealer or Representative Registration ..........................................................................................................................8
Futures or Commodity Registration ...............................................................................................................................................8
Material Relationships Maintained by this Advisory Business and Any Conflicts of Interest ..............................8
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 8
Recommendations or Selections of Other Investment Advisors and Any Conflicts of Interest ...........................8
Code of Ethics Description ..................................................................................................................................................................8
Investment Recommendations Involving a Material Financial Interest and Any Conflict of Interest ..............9
Advisory Firm Purchase of Same Securities Recommended to Clients and Any Conflicts of Interest ..............9
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and
Item 12: Brokerage Practices ............................................................................................................................................... 9
Any Conflicts of Interest .......................................................................................................................................................................9
Factors Used to Select Broker-Dealers for Client Transactions..........................................................................................9
Item 13: Review of Accounts .............................................................................................................................................. 10
Aggregating Securities Transactions for Client Accounts .................................................................................................. 10
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved .......... 10
Review of Client Accounts on Non-Periodic Basis ................................................................................................................. 10
Item 14: Client Referrals and Other Compensation................................................................................................... 11
Content of Client Provided Reports and Frequency ............................................................................................................. 11
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............. 11
Item 15: Custody ..................................................................................................................................................................... 11
Advisory Firm Payments for Client Referrals .......................................................................................................................... 11
Item 16: Investment Discretion ........................................................................................................................................ 12
Account Statements ............................................................................................................................................................................. 11
Item 17: Voting Client Securities ...................................................................................................................................... 12
Discretionary Authority for Trading ............................................................................................................................................ 12
Item 18: Financial Information ......................................................................................................................................... 12
Proxy Votes ............................................................................................................................................................................................. 12
Balance Sheet ......................................................................................................................................................................................... 12
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients12
Supervised Person Brochure ............................................................................................................................................. 13
Bankruptcy Petitions during the Past Ten Years ................................................................................................................... 12
Part 2B of Form ADV ............................................................................................................................................................. 13
Brochure Supplement (Part 2B of Form ADV) ............................................................................................................. 14
Principal Executive Officer ............................................................................................................................................................... 14
Tim Looney.............................................................................................................................................................................................. 14
Item 2 Educational Background and Business Experience................................................................................................ 14
Item 3 Disciplinary Information .................................................................................................................................................... 14
Item 4 Other Business Activities .................................................................................................................................................... 14
Item 5 Additional Compensation ................................................................................................................................................... 14
Item 6 Supervision ............................................................................................................................................................................... 14
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Supervised Person Brochure ............................................................................................................................................. 15
Part 2B of Form ADV ............................................................................................................................................................. 15
Brochure Supplement (Part 2B of Form ADV) ............................................................................................................. 16
Brian Flanagan
Item 2 Educational Background and Business Experience
.................................................................................................................................................................................... 16
Item 3 Disciplinary Information
....................................................................................... 16
Item 4 Other Business Activities
............................................................................................................................................... 16
Item 5 Additional Compensation
............................................................................................................................................... 16
Item 6 Supervision
.............................................................................................................................................. 16
Supervised Person Brochure ............................................................................................................................................. 18
............................................................................................................................................................................ 17
Part 2B of Form ADV ............................................................................................................................................................. 18
Brochure Supplement (Part 2B of Form ADV) ............................................................................................................. 19
John Michael McCully
Item 2 Educational Background and Business Experience
...................................................................................................................................................................... 19
Item 3 Disciplinary Information
....................................................................................... 19
Item 4 Other Business Activities
............................................................................................................................................... 19
Item 5 Additional Compensation
............................................................................................................................................... 19
Item 6 Supervision
.............................................................................................................................................. 19
............................................................................................................................................................................ 19
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Tim Looney Investments, LLC
Item 4: Advisory Business
Firm Description
Tim Looney Investments, LLC (“TLI”) was founded in 2012. Tim Looney is 50% owner.
Brian Flanagan and John McCully are each 25% owners.
TLI provides personalized confidential financial planning and investment management to
primarily to individuals. Advice is provided through consultation with the client and may
include: determination of financial objectives, identification of financial problems, cash
flow management, tax planning, insurance review, investment management, education
funding, retirement planning, and estate planning.
TLI is a fee based financial planning and investment management firm. Advisors with TLI
sell annuities and other insurance commissioned products as an independent insurance
agents.
Investment advice is provided with the client making the final decision on investment
selection. TLI does not act as a custodian of client assets.
An evaluation of each client's initial situation is provided to the client, often in the form of
a net worth statement, risk analysis or similar document. Periodic reviews are also
communicated to provide reminders of the specific courses of action that need to be
taken. More frequent reviews occur but are not necessarily communicated to the client
unless immediate changes are recommended.
Types of Advisory Services
Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are
engaged directly by the client on an as-needed basis and may charge fees of their own.
Conflicts of interest will be disclosed to the client in the event they should occur.
TLI provides investment supervisory services, also known as asset management services
and furnishes financial planning and investment advice through consultations.
ASSET MANAGEMENT
TLI’s principal service is providing investment advisory services based on the client’s
specific investment objectives, goals and financial situation. Investment strategies,
investment selection, asset allocation, portfolio monitoring and the overall investment
program will be based on the above factors. The advisor practices custom management of
portfolios, on a non-discretionary basis. TLI will determine the securities to be bought or
sold and the amount of the securities to be bought or sold. However, TLI will obtain prior
client approval before executing any transactions.
ERISA PLAN SERVICES
TLI provides service to qualified and non-qualified retirement plans including 401(k)
plans, 403(b) plans, pension and profit sharing plans, cash balance plans, and deferred
Limited Scope ERISA 3(21) Fiduciary.
compensation plans. TLI will act as a 3(21) advisor:
TLI typically acts as a limited scope ERISA 3(21)
fiduciary that can advise, help and assist plan sponsors with their investment decisions
on a non-discretionary basis. As an investment advisor TLI has a fiduciary duty to act in
the best interest of the client. The plan sponsor is still ultimately responsible for the
decisions made in their plan, though using TLI can help mitigate that plan sponsor’s
liability by following a diligent process.
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1.
•
Fiduciary Services are:
•
Provide non-discretionary investment advice to the Client about asset classes
and investment alternatives available for the Plan in accordance with the Plan’s
investment policies and objectives. Client will make the final decision regarding
the initial selection, retention, removal and addition of investment options.
Advisor acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A)
(ii).
•
Assist the Client with the selection of a broad range of investment options
consistent with ERISA Section 404(c) and the regulations thereunder.
•
Assist the Client in the development of an investment policy statement (“IPS”).
The IPS establishes the investment policies and objectives for the Plan. Client
shall have the ultimate responsibility and authority to establish such policies and
objectives and to adopt and amend the IPS.
that document
investment performance, consistency of
•
Assist in monitoring investment options by preparing periodic investment
reports
fund
management and conformance to the guidelines set forth in the IPS and make
recommendations to maintain, remove or replace investment options.
•
Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
Provide non-discretionary investment advice to the Plan Sponsor with respect to
the selection of a qualified default investment alternative for participants who
are automatically enrolled in the Plan or who have otherwise failed to make
investment elections. The Client retains the sole responsibility to provide all
notices to the Plan participants required under ERISA Section 404(c) (5).
2.
•
Non-fiduciary Services are:
•
Assist in the education of Plan participants about general investment information
and the investment alternatives available to them under the Plan. Client
understands the Advisor’s assistance in education of the Plan participants shall
be consistent with and within the scope of the Department of Labor’s definition
of investment education (Department of Labor Interpretive Bulletin 96-1). As
such, the Advisor is not providing fiduciary advice as define by ERISA to the Plan
participants. Advisor will not provide investment advice concerning the prudence
of any investment option or combination of investment options for a particular
participant or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding
by the employees.
Advisor may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between Advisor and Client.
3.
The Advisor has no responsibility to provide services related to the following types
•
of assets (“Excluded Assets”):
Employer securities;
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•
•
Real estate (except for real estate funds or publicly traded REITs);
•
Stock brokerage accounts or mutual fund windows;
•
Participant loans;
•
Non-publicly traded partnership interests;
•
Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
Other hard-to-value or illiquid securities or property.
not
be included in calculation of Fees paid to the Advisor under this
Excluded Assets will
Agreement.
FINANCIAL PLANNING
TLI offers financial planning services for a fixed fee based on the client’s net worth and is
described in Item 5 of this brochure. Services include but are not limited to a thorough
review of all applicable topics including:
•
•
•
•
•
Retirement Planning
Budgeting
Education Planning
Asset Allocation
Insurance needs
If a conflict of interest exists between the interests of the investment advisor and the
interests of the client, the client is under no obligation to act upon the investment
advisor’s recommendation. If the client elects to act on any of the recommendations, the
client is under no obligation to effect the transaction through TLI. Financial plans will be
completed and delivered inside of thirty (30) days.
FINANCIAL CONSULTING
TLI offers consulting on a client’s financial needs based on an hourly fee basis and is
described in Item 5 of this brochure. Financial consulting projects may include:
•
•
•
•
Advise on mortgage refinancing and debt management;
Review and reallocate asset allocation in 401(k), 403(b), 529 and other
retirement and education plans;
Budgets, Net Worth Statements and Cash Flow analysis; and/or
Establish savings goals for retirement and education.
Clients may terminate the advisory contract with TLI at any time by giving written notice.
SEMINARS AND WORKSHOPS
TLI holds seminars and workshops to educate the public on different types of investments
and the different services they offer. The seminars are educational in nature and no
specific investment or tax advice is given. TLI does not charge a fee for attendance to
these seminars.
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Tim Looney Investments, LLC
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each client are documented in our client files. Investment
strategies are created that reflect the stated goals and objective. Clients may impose
restrictions on investing in certain securities or types of securities.
Wrap Fee Programs
Agreements may not be assigned without written client consent.
Client Assets under Management
TLI does not sponsor or participate in wrap fee programs.
TLI has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
Date Calculated:
$490,256,479
December 31, 2025
$0
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
TLI bases its fees on a percentage of assets under management, percentage of net worth
and hourly charges.
Assets Under Management
Annual Fee
Quarterly Fee
ASSET MANAGEMENT
TLI offers non-discretionary direct asset management services to advisory clients. Fees
for these services will be based on a percentage of Assets Under Management as follows:
$0 - $500,000
$500,001 and up
.8%
.6%
.20%
.15%
The annual fee may be negotiable. Accounts within the same household may be combined
for a reduced fee. Fees are billed quarterly in advance based on the amount of assets
managed as of the last business day of the previous quarter. Cash is included as part of
your managed assets and, at times, your fee will exceed the money market yield. Lower
fees for comparable services may be available from other sources. Quarterly advisory fees
deducted from the clients' account by the custodian will be reflected in the client’s
statement from the custodian. The client will be entitled to a pro rata refund for the days
service was not provided in the final quarter. Client shall be given thirty (30) days prior
written notice of any increase in fees, and client will acknowledge, in writing, any
agreement of increase in said fees.
Clients may terminate their account within five (5) business days of signing the
Investment Advisory Agreement for a full refund. Clients may terminate advisory services
with thirty (30) days written notice.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed
.8%. The initial fee will be based on the market value of the Plan assets as calculated by
the custodian or record keeper of the Included Assets on the first business day of the
initial fee period and will be due quarterly in arrears. If the services to be provided start
any time other than the first day of a quarter, the fee will be prorated based on the
number of days remaining in the initial fee period. Thereafter, the fee will be based on the
market value of the Plan assets on the last business day of the previous fee period
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Tim Looney Investments, LLC
(without adjustments for anticipated withdrawals by Plan participants or other
anticipated or scheduled transfers or distribution of assets) and will be due the following
business day. If this Agreement is terminated prior to the end of the fee period, TLI shall
be entitled to a prorated fee based on the number of days during the fee period services
were provided. Any unearned fees shall be refunded to the Plan or Plan Sponsor.
The compensation of TLI for the services is described in detail in Schedule A of the ERISA
Plan Agreement. The Plan is obligated to pay the fees, however the Plan Sponsor may
elect to pay the fees. TLI does not reasonably expect to receive any additional
compensation, directly or indirectly, for its services under this Agreement. If additional
compensation is received, TLI will disclose this compensation, the services rendered, and
the payer of compensation. TLI will offset the compensation against the fees agreed upon
under this Agreement.
Annual Fixed Fee
FINANCIAL PLANNING FEES
TLI offers financial planning services for a fixed fee based on the client’s net worth. Fees
are payable upon delivery of the financial plan. Lower fees for comparable services may
be available from other sources. An annual follow-up is recommended and available for
half the cost based on the client’s net worth at the time a follow-up is recommended.
The fees are as follows: Client’s Net Worth
$0 - $1,000,000
$1,000,001- $2,000,000
$2,000,001 - $4,000,000
$4,000,001 - $6,000,000
$6,000,001 and up
$1,200
$2,400
$3,600
$4,800
$6,000
Client Payment of Fees
FINANCIAL CONSULTING FEES
TLI will be compensated for its financial consulting services by charging fees based on a
negotiable hourly rate of $300. TLI fee will be negotiated in advance and will be set-out in
each client’s advisory contract. Payment will be due at the time the project is complete.
Investment management fees are billed quarterly in advance, meaning we bill you before
the three-month period has started. Fees are usually deducted from a designated client
account to facilitate billing. The client must consent in advance to direct debiting of their
investment account.
Additional Client Fees Charged
Financial planning fee and financial consulting fees will be negotiated in advance and will
be set-out in each client’s advisory contract. Final payment will be due upon delivery of
the finished plan or project.
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, and exchange-traded funds. These charges may
include Mutual Fund
transactions fees, postage and handling and miscellaneous fees (fee levied to recover
costs associated with fees assessed by self-regulatory organizations). These transaction
charges are usually small and incidental to the purchase or sale of a security. The
selection of the security is more important than the nominal fee that the custodian
charges to buy or sell the security.
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Tim Looney Investments, LLC
Prepayment of Client Fees
TLI, in its sole discretion, may waive its minimum fee and/or charge a lesser investment
advisory fee based upon certain criteria (e.g., historical relationship, type of assets,
anticipated future earning capacity, anticipated future additional assets, dollar amounts of
assets to be managed, related accounts, account composition, negotiations with clients,
etc.).
For more details on the brokerage practices, see Item 12 of this brochure.
External Compensation for the Sale of Securities to Clients
Investment management fees are billed quarterly in advance. Upon termination, any fees
paid in advance will be prorated to the date of termination and any excess will be
refunded to client.
TLI does not receive any external compensation for the sale of securities to clients, nor do
any of the investment advisor representatives of TLI.
Item 6: Performance-Based Fees
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
TLI does not use a performance-based fee structure because of the conflict of interest.
Performance-based compensation may create an incentive for the adviser to recommend
an investment that may carry a higher degree of risk to the client.
Item 7: Types of Clients
Description
Account Minimums
TLI generally provides investment advice primarily to individuals. Client relationships
vary in scope and length of service.
TLI does not require a minimum to open an account.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods may include fundamental analysis, technical analysis, and
cyclical analysis. Investing in securities involves risk of loss that clients should be
prepared to bear. Past performance is not a guarantee of future returns.
Fundamental analysis involves evaluating a stock using real data such as company
revenues, earnings, return on equity, and profits margins to determine underlying value
and potential growth. Technical analysis involves evaluating securities based on past
prices and volume. Cyclical analysis involves analyzing the cycles of the market.
Investment Strategy
The main sources of information include financial newspapers and magazines, research
material prepared by others, corporate rating services, annual reports, prospectuses,
filings with the Securities and Exchange Commission and company press releases.
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. Each
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Tim Looney Investments, LLC
client executes an Investment Policy Statement or Risk Tolerance that documents their
objectives and their desired investment strategy.
Security Specific Material Risks
Other strategies may include long-term purchases, short-term purchases and trading.
All investment programs have certain risks that are borne by the investor. Fundamental
analysis may involve interest rate risk, market risk, business risk, and financial risk. Risks
involved in technical analysis are inflation risk, reinvestment risk, and market risk.
Cyclical analysis involves inflation risk, market risk, and currency risk.
Interest-rate Risk
•
Our investment approach constantly keeps the risk of loss in mind. Investors face the
following investment risks and should discuss these risks with their investment advisor
representative:
• Market 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.
•
: 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
Inflation Risk
events.
: When any type of inflation is present, a dollar today will buy more
than a dollar next year, because purchasing power is eroding at the rate of
• Currency Risk
inflation.
• Reinvestment 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.
• Business Risk
: This is the risk that future proceeds from investments may
have to be reinvested at a potentially lower rate of return (i.e. interest rate). This
primarily relates to fixed income securities.
• Liquidity Risk
: 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.
• Financial 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.
: Excessive borrowing to finance a business’ operations increases
the risk of profitability, because the company must meet the terms of its
obligations in good times and bad. During periods of financial stress, the inability
to meet loan obligations may result in bankruptcy and/or a declining market
value.
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Tim Looney Investments, LLC
Item 9: Disciplinary Information
Criminal or Civil Actions
Administrative Enforcement Proceedings
The firm and its management have not been involved in any criminal or civil action.
Self Regulatory Organization Enforcement Proceedings
The firm and its management have not been involved in administrative enforcement
proceedings.
The firm and its management have not been involved in legal or disciplinary events
related to past or present investment clients.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Futures or Commodity Registration
Neither TLI nor any of its employees are registered representatives of a broker-dealer.
Neither TLI nor its employees are registered or has an application pending to register as a
futures commission merchant, commodity pool operator, or a commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Any Conflicts of
Interest
There are no material relationships to disclose. Recommendations or Selections of
Other Investment Advisors and Any Conflicts of Interest
TLI does not recommend or select other investment advisors.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
The employees of Tim Looney Investments, LLC have committed to a Code of Ethics
(“Code”). The purpose of our Code is to set forth standards of conduct expected of TLI
employees and addresses conflicts that may arise. The Code defines acceptable behavior
for employees of TLI. The Code reflects TLI and its supervised persons’ responsibility to
act in the best interest of their client.
One area which the Code addresses is when employees buy or sell securities for their
personal accounts and how to mitigate any conflict of interest with our clients. We do not
allow any employees to use non-public material information for their personal profit or to
use internal research for their personal benefit in conflict with the benefit to our clients.
TLI’s policy prohibits any person from acting upon or otherwise misusing non-public or
inside information. No advisory representative or other employee, officer or director of
TLI may recommend any transaction in a security or its derivative to advisory clients or
engage in personal securities transactions for a security or its derivatives if the advisory
representative possesses material, non-public information regarding the security.
TLI’s Code is based on the guiding principle that the interests of the client are our top
priority. TLI’s officers, directors, advisors, and other employees have a fiduciary duty to
our clients and must diligently perform that duty to maintain the complete trust and
confidence of our clients. When a conflict arises, it is our obligation to put the client’s
interests over the interests of either employees or the company.
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Tim Looney Investments, LLC
to clients, or who have access
The Code applies to “access” persons. “Access” persons are employees who have access to
non-public information regarding any clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in
making securities recommendations
to such
recommendations that are non-public.
The firm will provide a copy of the Code of Ethics to any client or prospective client upon
request.
Investment Recommendations Involving a Material Financial Interest and Any
Conflict of Interest
TLI and its employees do not recommend to clients securities in which we have a material
Advisory Firm Purchase of Same Securities Recommended to Clients and Any
financial interest.
Conflicts of Interest
TLI and its employees may buy or sell securities that are also held by clients. In order to
mitigate conflicts of interest such as front running, employees are required to disclose all
reportable securities transactions as well as provide TLI with copies of their brokerage
statements.
The Chief Compliance Officer of TLI is John McCully. He reviews all employee trades each
quarter. The personal trading reviews ensure that the personal trading of employees does
not affect the markets and that clients of the firm receive preferential treatment over
employee transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Any Conflicts of Interest
TLI does not maintain a firm proprietary trading account and does not have a material
financial interest in any securities being recommended and therefore no conflicts of
interest exist. However, employees may buy or sell securities at the same time they buy or
sell securities for clients. In order to mitigate conflicts of interest such as front running,
employees are required to disclose all reportable securities transactions as well as
provide TLI with copies of their brokerage statements.
The Chief Compliance Officer of TLI is John McCully. He reviews all employee trades each
quarter. The personal trading reviews ensure that the personal trading of employees does
not affect the markets and that clients of the firm receive preferential treatment over
employee transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
TLI will recommend the use of a particular broker-dealer based on their duty to seek best
execution for the client, meaning they have an obligation to obtain the most favorable
terms for a client under the circumstances. The determination of what may constitute
best execution and price in the execution of a securities transaction by a broker involves a
number of considerations and is subjective. Factors affecting brokerage selection include
the overall direct net economic result to the portfolios, the efficiency with which the
transaction is affected, the ability to effect the transaction where a large block is involved,
the operational facilities of the broker-dealer, the value of an ongoing relationship with
such broker and the financial strength and stability of the broker. TLI will select
appropriate brokers based on a number of factors including but not limited to their
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Tim Looney Investments, LLC
Directed Brokerage
•
relatively low transaction fees and reporting ability. TLI relies on its broker to provide its
execution services at the best prices available. Lower fees for comparable services may be
available from other sources. Clients pay for any and all custodial fees in addition to the
advisory fee charged by TLI. TLI does not receive any portion of the trading fees.
• Best Execution
TLI will recommend the use of Charles Schwab & Co., Inc.
In circumstances where a client directs TLI to use a certain broker-dealer, TLI still
has a fiduciary duty to its clients. The following may apply with Directed Brokerage:
TLI’s inability to negotiate commissions, to obtain volume discounts, there may be a
disparity in commission charges among clients and conflicts of interest arising from
brokerage firm referrals.
• Soft Dollar Arrangements
Investment advisors who manage or supervise client portfolios on a discretionary
basis have a fiduciary obligation of best execution. The determination of what may
constitute best execution and price in the execution of a securities transaction by a
broker involves a number of considerations and is subjective. Factors affecting
brokerage selection include the overall direct net economic result to the portfolios,
the efficiency with which the transaction is effected, the ability to effect the
transaction where a large block is involved, the operational facilities of the broker-
dealer, the value of an ongoing relationship with such broker and the financial
strength and stability of the broker. TLI does not receive any portion of the trading
fees.
The Securities and Exchange Commission defines soft dollar practices as
arrangement under which products or services other than execution services are
obtained by TLI from or through a broker-dealer in exchange for directing client
transactions to the broker-dealer. As permitted by Section 28(e) of the Securities
Exchange Act of 1934, TLI receives economic benefits as a result of commissions
generated from securities transactions by the broker-dealer from the accounts of
TLI. These benefits include both proprietary research from the broker and other
research written by third parties.
Aggregating Securities Transactions for Client Accounts
A conflict of interest exists when TLI receives soft dollars. This conflict is mitigated
by disclosures, procedures, and the firm’s Fiduciary obligation to act in the best
interest of its clients and the services received are beneficial to all clients.
TLI is not authorized to aggregate purchases and sales and other transactions.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Review of Client Accounts on Non-Periodic Basis
Account reviews are performed quarterly by Investment Advisor Representatives of TLI.
Account reviews are performed more frequently when market conditions dictate.
Financial Plans are considered complete when recommendations are delivered to the
client and a review is done only upon request of client.
Other conditions that may trigger a review of client’s accounts are changes in the tax laws,
new investment information, and changes in a client's own situation.
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Tim Looney Investments, LLC
Content of Client Provided Reports and Frequency
Clients receive account statements no less than quarterly for managed accounts. Account
statements are issued by the Advisor’s custodian. Client receives confirmations of each
transaction in account from Custodian and an additional statement during any month in
which a transaction occurs.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and
Conflicts of Interest
TLI receives additional economic benefits from external sources as described above in
Item 12.
Advisory Firm Payments for Client Referrals
TLI does not compensate for client referrals.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at their address of record at least quarterly. Clients are
urged to compare the account statements received directly from their custodians to the
performance reports prepared by TLI.
TLI is deemed to have constructive custody solely because advisory fees are directly
deducted from client’s accounts by the custodian on behalf of TLI.
TLI is also deemed to have limited custody due to its Third-Party Standing Letters of
Authorization (“SLOA”).
TLI and its qualified custodian meet the following seven (7) conditions in order to avoid
maintaining full custody and be subject to the surprise exam requirement:
1.
The Client provides an instruction to the qualified custodian, in writing, that includes
the Client’s signature, the third party’s name, and either the third party’s address or
the third party’s account number at a custodian to which the transfer should be
directed.
2.
The Client authorizes TLI, in writing, either on the qualified custodian’s form or
separately, to direct transfers to the third party either on a specified schedule or
from time to time.
3.
The Client’s qualified custodian performs appropriate verification of the instruction,
such as a signature review or other method to verify the Client’s authorization and
provides a transfer of funds notice to the Client promptly after each transfer.
4.
The Client has the ability to terminate or change the instruction to the Client’s
qualified custodian.
5.
TLI has no authority or ability to designate or change the identity of the third party,
the address, or any other information about the third party contained in the Client’s
instruction.
6.
TLI maintains records showing that the third party is not a related party nor located
at the same address as TLI.
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Tim Looney Investments, LLC
7.
The Client’s qualified custodian sends the Client, in writing, an initial notice
confirming the instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Discretionary Authority for Trading
TLI accepts non-discretionary authority to manage securities accounts on behalf of
clients. TLI will obtain prior client approval before executing any transactions.
The client approves the custodian to be used and the commission rates paid to the
custodian. TLI does not receive any portion of the transaction fees or commissions paid
by the client to the custodian on certain trades.
Item 17: Voting Client Securities
Proxy Votes
TLI does not vote proxies on securities. Clients are expected to vote their own proxies.
The client will receive their proxies directly from the custodian of their account or from a
transfer agent.
When assistance on voting proxies is requested, TLI will provide recommendations to the
client. If a conflict of interest exists, it will be disclosed to the client.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because TLI does not serve as a custodian
for client funds or securities and TLI does not require prepayment of fees of more than
$1200 per client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
Bankruptcy Petitions during the Past Ten Years
TLI has no condition that is reasonably likely to impair our ability to meet contractual
commitments to our clients.
Neither TLI nor its management has had any bankruptcy petitions in the last ten years.
12
Tim Looney Investments, LLC
Supervised Person Brochure
Part 2B of Form ADV
Timothy G. Looney
Tim Looney Investments, LLC
2180 SR 434, Suite 6140
Longwood, FL 32779
PHONE: 407-331-6961
FAX: 888-807-6590
EMAIL: tim@timlooneyinvestments.com
This brochure provides information about Timothy G. Looney and supplements the
Tim Looney Investments, LLC brochure. You should have received a copy of that
brochure. Please contact Timothy G. Looney if you did not receive Tim Looney
Investments, LLC’s brochure or if you have any questions about the contents of this
supplement.
Additional information about Timothy G. Looney (CRD #1803045) is available on
the SEC’s website at www.adviserinfo.sec.gov.
February 13, 2026
13
Tim Looney Investments, LLC
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer
Tim Looney
•
Item 2 Educational Background and Business Experience
Year of birth: 1965
•
Educational Background:
Florida Southern College; Bachelor of Science in Business with a Finance
Concentration; 1987
•
Business Experience:
•
•
Item 3 Disciplinary Information
Tim Looney Investments, LLC; Managing Member/Investment Advisor
Representative; 05/2012 - Present
Tim Looney; Independent Insurance Agent;04/2002 – 12/2024
Commonwealth Financial Network; Investment Advisor Representative; 04/2002 –
May 2012
Item 4 Other Business Activities
None to report.
Item 5 Additional Compensation
Managing Member Tim Looney has no outside business activities at this time
Item 6 Supervision
Tim Looney does not receive additional compensation or any performance based fees.
face-to-face and phone
interactions.
John McCully can be
John McCully is the Chief Compliance Officer of TLI. John McCully reviews Tim Looney’s
work through Client account reviews and quarterly personal transaction reports, as well
as
reached at
john@timlooneyinvestments.com or 407-331-6961.
14
Tim Looney Investments, LLC
Supervised Person Brochure
Part 2B of Form ADV
Brian Flanagan
Tim Looney Investments, LLC
2180 SR 434, Suite 6140
Longwood, FL 32779
PHONE: 407-331-6961
FAX: 888-807-6590
EMAIL: brian@timlooneyinvestments.com
This brochure provides information about Brian Flanagan and supplements the
Tim Looney Investments, LLC brochure. You should have received a copy of that
brochure. Please contact Brian Flanagan if you did not receive Tim Looney
Investments, LLC’s brochure or if you have any questions about the contents of this
supplement.
Additional information about Brian Flanagan (CRD #4728629) is available on the
SEC’s website at www.adviserinfo.sec.gov.
February 13, 2026
15
Tim Looney Investments, LLC
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Brian Flanagan
•
Item 2 Educational Background and Business Experience
Year of birth: 1980
•
Educational Background:
Florida State University; Bachelor of Science in Risk Management & Insurance; 2003
•
Business Experience:
•
Tim Looney Investments, LLC; Member; 01/2023 - Present
•
Tim Looney Investments, LLC; Investment Advisor Representative; 12/2022 –
Present
•
Brian Flanagan, Sole Proprietor; Insurance Agent; 07/2024 – 08/2025
•
Florida Financial Group Auto & Home, LLC; Insurance Agent; 07/2024 – 08/2025
•
MML Investors Services, LLC;
Florida Financial Group Auto & Home, LLC; Owner/ Insurance Agent; 07/2016 –
07/2024
o
o
Investment Advisor Representative; 11/2022 – 11/2022
•
Registered Representative; 03/2017 – 11/2022
•
Massachusetts Mutual Life Insurance Company; Insurance Agent/ Financial Services
Executive; 07/2016 – 11/2022
MSI Financial Services, Inc.;
o
o
Investment Advisor Representative; 01/2011 – 03/2017
•
Registered Representative; 01/2004 – 03/2017
•
Metlife Securities, Inc.; Insurance Agent/ Financial Services Executive; 11/2003 –
07/2016
Item 3 Disciplinary Information
Metropolitan Life Insurance Company; Sales; 11/2003 – 07/2016
Item 4 Other Business Activities
None to report.
Item 5 Additional Compensation
Brian Flanagan has no other business to disclose.
Brian Flanagan receives additional compensation in his capacity as an insurance agent,
but he does not receive any performance based fees.
16
Tim Looney Investments, LLC
Item 6 Supervision
John McCully is the Chief Compliance Officer of TLI. John McCully reviews Brian
Flanagan’s work through Client account reviews and quarterly personal transaction
reports, as well as face-to-face and phone interactions. John McCully can be reached at
john@timlooneyinvestments.com or 407-331-6961.
17
Tim Looney Investments, LLC
Supervised Person Brochure
Part 2B of Form ADV
John Michael McCully
Tim Looney Investments, LLC
2180 SR 434, Suite 6140
Longwood, FL 32779
PHONE: 407-331-6961
FAX: 888-807-6590
EMAIL: john@timlooneyinvestments.com
This brochure provides information about John Michael McCully and supplements
the Tim Looney Investments, LLC brochure. You should have received a copy of
that brochure. Please contact John Michael McCully if you did not receive Tim
Looney Investments, LLC’s brochure or if you have any questions about the
contents of this supplement.
Additional information about John Michael McCully (CRD #7692508) is available
on the SEC’s website at www.adviserinfo.sec.gov.
February 13, 2026
18
Tim Looney Investments, LLC
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
John Michael McCully
•
Item 2 Educational Background and Business Experience
Year of birth: 1978
Educational Background:
•
•
Stetson University; Masters of Business Administration in Business; 2004
Stetson University; Bachelor of Business Administration in Business; 2000
•
Business Experience:
•
Tim Looney Investments, LLC; Investment Advisor Representative; 02/2024 -
Present
•
Tim Looney Investments, LLC; Member; 01/2023 – Present
•
Downtown Pet Hospital; Owner; 05/2019 - Present
•
Orangewood Christian School; Director of Operations; 11/2017 – 12/2022
Item 3 Disciplinary Information
North American Risk Services; Chief Client Officer; 05/2001 – 10/2017
Item 4 Other Business Activities
None to report.
John Michael McCully has a non-financial affiliated business as an Owner of Downtown
Pet Hospital. None of his time is spent on this activity. This is not a conflict of interest as
Item 5 Additional Compensation
there are no crossover clients.
Item 6 Supervision
John Michael McCully does not receive any additional compensation or performance
based fees.
John McCully, as the Chief Compliance Officer, is ultimately responsible for all supervision
and formulation and monitoring of investment advice offered to clients. He will adhere to
the policies and procedures as described in the firm’s Compliance Manual. John McCully
can be reached at john@timlooneyinvestments.com or 407-331-6961.
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Tim Looney Investments, LLC