FAAS is registered with the Securities and Exchange Commission (SEC) as a registered investment
adviser. FAAS is a limited liability company formed in the State of Washington. Our firm has been
in business as an investment adviser since 2008 and is one hundred percent (100%) owned by
Financial Advocates, LLC.
Our business model is based on a decentralized network of Investment Adviser Representatives
(“IARs” or “Consultants”) with offices located in various cities in Washington and Oregon.
Although all of the IAR’s are registered with and subject to oversight and supervision by FAAS,
some of the offices operate independently under a separate business name or “DBA” (see the
cover page of this brochure for the DBA name utilized by your IAR). Because our IAR’s operate
independently they have significant flexibility in providing tailored individualized investment
advice to the firm’s clients. Some of our DBA offices allow for independence across their IAR’s
while others require their IAR’s to tailor their advice to the DBA’s model. Our IAR’s are
independent contractors with us. FAAS home office in Olympia WA assists the IAR’s with
marketing, back-office functions and manages compliance responsibilities. A list of all of the
FAIM approved DBA names can be found on our Schedule D, Section 1.B. Other Business Names
of our Form ADV Part 1 which is available on the SEC’s Investment Advisor Public Disclosure
website at www.adviserinfo.sec.gov.
SERVICES
FAAS IAR’s specialize in the following types of services: hourly consulting, financial planning and
consultations, and pension consulting services. IAR’s offer general investment advice to clients
utilizing these services. Since we offer our services in a consulting capacity, we have no assets
under management and do not provide continuous and regular investment management or
supervisory services.
Consulting Services, Financial Planning
FAAS IAR’s provide a variety of financial planning and consulting services to individuals, families
and other clients regarding the management of their financial resources based upon an analysis
of the client’s current financial circumstances, goals, and objectives. Generally, such financial
planning services will involve preparing a financial plan or rendering a financial consultation for
clients based on the client’s financial goals and objectives. Clients enter into a Consulting
Agreement for the services described below.
Comprehensive Financial Planning addresses one or more of the six key areas of financial
planning:
Financial Position,
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Protection Planning,
Investment Planning,
Corporate and Personal Income Tax Planning,
Retirement Planning, and
Estate Planning.
Hourly Consulting is provided for a variety of purposes including, but not limited to, the following:
Annual update to Financial Plan,
Asset Allocation Recommendations,
General portfolio management recommendations,
Third party review (2nd opinion), and
Individual Issue Consulting.
In addition, both Comprehensive Financial Planning and Hourly Consulting may include one or
more of the following areas:
Charitable Planning,
Education Planning,
Cost Segregation Study,
Mortgage/Debt Analysis,
Insurance Analysis,
Lines of Credit Evaluation, and
Business and Personal Financial Planning
Our written financial plans provided to clients or financial consultations rendered to clients
usually include general recommendations for a course of activity or specific actions to be taken
by the clients. For example, recommendations may be made that the clients begin or revise
investment programs, create or revise wills or trusts, obtain or revise insurance coverage,
commence or alter retirement savings, or establish education or charitable giving programs.
For Comprehensive Financial Planning engagements, we provide our clients with a written
summary of their financial situation, observations, and recommendations. For Hourly consulting
engagements, we usually do not provide our clients with a written summary of our observations
and recommendations as the process is less formal than our planning service. Plans or
consultations are typically completed within six (6) months of a client signing a contract with us,
assuming that all the information and documents we request from the client are provided to us
promptly.
Implementation of the recommendations will be at the discretion of the client. Clients
are free to implement investment recommendations through brokers unaffiliated with FAAS or
its IARs. It should also be noted that we refer clients to an accountant, attorney or other
specialist, as necessary for non-advisory related services.
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Investment Fiduciary & Retirement Plan Consulting
We provide consulting and advisory services for employer-sponsored retirement plans that are
designed to assist plan sponsors of employee benefit plans (“Sponsor(s)”). These services are
offered to Sponsors on a one-time or ongoing basis. Generally, such pension consulting services
consist of assisting Sponsors in establishing, monitoring and reviewing their company's
participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising
could include, but are not limited to, the following: investment options, plan structure and
participant education.
All pension consulting services shall be in compliance with the applicable state law(s) regulating
pension consulting services. This applies to client accounts that are pension or other employee
benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to
provide our services to such accounts, we acknowledge our fiduciary role within the meaning of
Section 3(21) of ERISA (but only with respect to the provision of services described in the Services
section of the Investment Fiduciary & Retirement Plan Consulting Agreement (“RPAC”)). When
providing any ERISA fiduciary services, we will solely be making recommendations to the Sponsor
and the Sponsor retains full discretionary authority and/or control over the assets.
When entering into an RPAC agreement, the Plan Sponsor may select from a number of different
services described below. FAAS will be acting in a non-discretionary capacity and will solely be
making recommendations to the Plan Sponsor. FAAS will not perform recordkeeping or
brokerage services to the Plan. Neither FAAS nor the IAR will assume the duties of a trustee or a
Plan Administrator, as defined in ERISA Sec. 3(16).
Investment Fiduciary Services - Plan Level
Recommendations to establish or revise the Plan’s Investment Policy Statement (“IPS”),
Recommendations to select and monitor the Designated Investment Alternatives
(“DIAs”),
Recommendations to select and monitor Qualified Default Investment Alternatives
(“QDIAs)
Recommendation to select and monitor other investment managers
Retirement Plan Consulting Services
Administrative Support
oAssist Plan Sponsor in reviewing objectives and options through the Plan
oReview of Plan committee structure and administrative policies & procedures
oRecommend participant education and communications policies under ERISA
404(c)
oAssist with development/maintenance of fiduciary audit file and document
retention policies
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oDeliver fiduciary training and/or education periodically or upon reasonable
request.
oCoordinate and reconcile participant disclosures under 404(a)(5)
oDevelop requirements for responding to participant requests
Oversight of Relationship with Service Provider
oAssist with process to select, monitor and replace service providers
oAssist with review of Covered Service Providers (CSPs) disclosures under ERISA
408(b)(2) and fee benchmarking
oProvide reports and/or information designed to assist with monitoring CSPs
oReview ERISA Spending Accounts or Plan Expense Recapture Accounts
oAssist with preparation and review of RFPs and/or RFIs
oCoordinate and assist with CSP replacement and conversion
Investments
oPeriodic review of investment policy in context of plan objectives
oAssist Plan committee with monitoring investment performance
oProvide analysis of investment managers and model portfolios
oReview and recommend Designated Investment Managers and/or third-party
advice providers as necessary
oEducation Plan committee members, as needed, regarding replacement of DIA(s)
and/or QDIA(s)
Participant Services
oFacilitate group enrollment meetings
oCoordinate employee education regarding plan investments and fees
oAssist plan participants in understanding plan benefits, retirement readiness and
impact of increasing deferrals.