A Financial Forum, Inc. (“Financial Forum” “we” or “us”) is a registered investment advisor located in Spokane,
Washington and registered with the SEC since March 2020. Financial Forum is owned by Jeff Comstock and
Landy Comstock.
Under this Wrap Fee Program, Financial Forum serves individuals and businesses in all areas of investment
management (which includes buying and selling of investments) and financial planning, including asset
management, investment consulting, education funding, risk management, tax management, retirement
planning, estate planning services, and employee and executive benefits. While we do not provide tax or
legal advice, we provide a full range of services coupled in coordination with other advisors such as
attorneys and Certified Public Accountants.
Under this Wrap Fee Program, Financial Forum charges Clients annual fees for investment advisory services
as follows:
Fees are generally not negotiable. For Clients in the Wrap Fee Program, the Advisory Fee noted on their
Advisory Agreement covers typical commissions charged by the custodian hold the Client accounts.
B In determining whether to establish an account under our Wrap Fee Program, you should be aware that
the overall cost to you of the program may be higher or lower than you might incur by purchasing
separately, or unbundled, the types of securities available in the program. In order to compare the cost of
the program with unbundled services, you should consider the turnover rate in our investment strategies,
trading activity in the account and standard advisory fees and brokerage commissions that would be
charged at our custodian, or at other broker‐dealers and investment advisors.
Depending upon the percentage wrap fee charged by our firm (as described more fully above), the amount
of portfolio activity in your account, and the value of custodial and other services provided, the wrap
fee
may or may not exceed the aggregate cost of such services if they were to be provided separately and/or if
we were to negotiate transaction fees and seek best price and execution of transactions for your individual
account. In as much as the execution costs for transactions effected in your account will be paid by our firm,
a conflict of interest arises in that we may have a disincentive to trade securities in your account.
C Clients that are enrolled in the Wrap Fee Program will still be required to pay certain fees including: (1) The
Client’s proportionate share of any internal mutual fund’s fees and charges; (2) The Client’s proportionate
share of internal fees and expenses of exchange‐traded funds such as fees and expenses for investment
advisory services, administration, and other fund‐level expenses; (3) Client charges imposed by the Client’s
current custodian (e.g., a transfer or termination fee) before the assets are transferred to Financial Forum;
(4) Client charges imposed by Financial Forum’s custodian (e.g., a transfer or termination fee) before the
assets are transferred from Financial Forum; (5) Client charges necessary to liquidate incoming positions
into our recommended portfolio.
D Financial Forum and its investment advisor representatives receive compensation because of your
participation in the Wrap Fee Program. This compensation may be more than the amount Financial Forum
and its investment advisor representatives would receive if you paid separately for investment advice,
brokerage, and other services. Accordingly, a conflict of interest exists because Financial Forum and its
investment advisor representatives have a financial incentive to recommend the program.
Advisory Fee Assets Managed
1.25% on the first $500,000, plus
1.00% on the next $2,500,000, plus
0.85% on the next $2,000,000, plus
0.70% on amounts over $5,000,000