Description of the Advisory Firm BFC is an independent, fee only, investment advisory firm specializing in retirement planning and investment management. BFC provides financial planning services including investment advice ("Financial Planning Services") for individuals and trusts. BFC began providing Financial Planning Services in October 1996. We are owned by James M. Birks and James D. Birks.
The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to Birks Financial Corp and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Types of Advisory Services Initial Financial Plan BFC will collect financial and demographic information from the client in order to identify objectives and goals for specific financial planning and investment purposes. The information provided by the client is used to analyze the client's circumstances to evaluate and identify an appropriate financial planning and investment strategy. BFC will prepare and present a written Financial Analysis and Recommendations ("Financial Plan") for the client, and BFC will be available to help the client implement the Recommendations.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
Retained Financial Planning and Investment Management Services BFC assists clients with the implementation and updates of their Financial Plan and Investment Policy Statement.
BFC will conduct a thorough risk tolerance study and recommend an initial investment asset allocation based on the client's specific needs and goals.The asset allocation strategy will be outlined in the client's Investment Policy Statement (IPS). BFC assists clients with the implementation of the IPS and manages client portfolios. This includes:
•Opening new investment accounts
•Recommending the appropriate securities to satisfy the IPS
•Recommending replacement securities as necessary
•Rebalancing of investment accounts
•Statement reporting and consolidation The client is responsible for promptly notifying BFC about changes to their financial situation, financial goals and attitudes towards risk.
4 In determining the initial asset allocation to be used, BFC may use several model portfolios constructed by BFC and comprised of no-load mutual funds.
Portfolios are rebalanced per the Rebalancing Procedure of the Investment Policy Statement in effect.
BFC may also recommend third party money managers for separate account management. BFC does not receive compensation directly or indirectly from those advisors.
Selection of Other Advisers We may recommend that you use the services of a third party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. After gathering

information about your financial situation and objectives, we may recommend that you engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives.
Client Tailored Services and Client Imposed Restrictions BFC offers the same suite of services to all of its clients. However, individual client advice is tailored to each client's needs per their Financial Plan and Investment Policy Statement.
Clients may impose restrictions in investing in certain securities or types of securities. However, if the restrictions prevent BFC from properly advising the client, or if the restrictions would require BFC to deviate from its standard suite of services, BFC reserves the right to terminate the relationship.
Wrap Fee Programs BFC does not participate in any wrap fee programs.
Types of Investments We primarily offer advice on Mutual Funds. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: 5
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Management of Client Assets BFC manages accounts on a non-discretionary basis. As of February 14, 2024, BFC has $196,621,617 of regulatory assets under management.