A. Firm Information
FFG Retirement Advisors, LLC (“FFG Retirement Counseling” or the “Advisor”) is a registered investment
advisor with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability
Company (“LLC”) under the laws of the State of Colorado. The Advisor was founded in August 2020 and is
wholly owned by FFG Retirement, Inc. FFG is operated by Sean O’Reilly (Partner and Chief Compliance
Officer) and Blake Barnett (Partner). This Disclosure Brochure provides information regarding the qualifications,
business practices, and the advisory services provided by FFG Retirement Counseling.
B. Advisory Services Offered
FFG Retirement Counseling offers investment advisory services to individuals, high net worth individuals, trusts,
estates, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to
mitigate potential conflicts of interest. FFG Retirement Counseling’s fiduciary commitment is further described in
the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of
Ethics, Participation or Interest in Client Transactions and Personal Trading.
Wealth Management Services
FFG Retirement Counseling provides Clients with wealth management services, which generally include
comprehensive financial planning and consulting strategies as well as discretionary management of investment
portfolios.
Investment Management Services – FFG Retirement Counseling provides customized investment advisory
solutions for its Clients. This is achieved through continuous personal Client contact and interaction while
providing discretionary investment management services. FFG Retirement Counseling works closely with each
Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to
create a portfolio strategy. FFG Retirement Counseling will then construct an investment portfolio primarily
consisting of low-cost, diversified, mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s
investment goals. The Advisor may also utilize individual stocks or bonds, as appropriate to meet the needs of
its Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
FFG Retirement Counseling’s investment approach is primarily long-term focused, but the Advisor may buy,
sell, or re-allocate positions that have been held for less than one year to meet the objectives of the Client or
due to market conditions. FFG Retirement Counseling will construct, implement, and monitor the portfolio to
ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will
have the opportunity to place reasonable restrictions on the types of investments to be held in their respective
portfolio, subject to acceptance by the Advisor.
FFG Retirement Counseling evaluates and selects investments for inclusion in Client portfolios only after
applying its internal due diligence process. FFG Retirement Counseling may recommend, on occasion,
redistributing investment allocations to diversify the portfolio. FFG Retirement Counseling may recommend
specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash
positions as a possible hedge against market movement. FFG Retirement Counseling may recommend selling
positions for reasons that include but are not limited to harvesting capital gains or losses, business or sector risk
exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the
portfolio, changes in the risk tolerance of the Client, generating cash to meet the Client’s needs, or any risk
deemed unacceptable for the Client’s risk tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
www.ffgretirement.com Page 5
the assets to an IRA or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor earns a new
(or increases its current) advisory fee as a result of the transaction. No client is under any
obligation to roll over
a retirement account to an account managed by the Advisor.
At no time will FFG Retirement Counseling accept or maintain custody of a Client’s funds or securities, except
for the limited authority as outlined in Item 15 - Custody. All Client assets will be managed within the designated
account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage
Practices.
Financial Planning Services – FFG Retirement Counseling provides financial planning and consulting services
as part of its wealth management services or pursuant to a written financial planning agreement. Services are
offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such
financial planning services involve preparing a formal financial plan and ongoing monitoring of the progress of
plan recommendation[s] or rendering a specific financial consultation based on the Client’s financial goals and
objectives. This planning or consulting may encompass one or more areas of need, including but not limited to
investment planning, retirement planning, personal savings, education savings, insurance needs, and other
areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
FFG Retirement Counseling may also refer Clients to an accountant, attorney, or other specialists, as
appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a
written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc
engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed
within six (6) months of the contract date, assuming all information and documents requested are provided
promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
C. Client Account Management
Prior to engaging FFG Retirement Counseling to provide investment advisory services, each Client is required
to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and
responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – FFG Retirement Counseling, in connection with the Client, will
develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – FFG Retirement Counseling will develop a strategic asset allocation that is targeted to
meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
• Portfolio Construction – FFG Retirement Counseling will develop a portfolio for the Client that is
intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – FFG Retirement Counseling will provide investment
management and ongoing oversight of the Client’s investment portfolio.
www.ffgretirement.com Page 6
D. Wrap Fee Programs
FFG Retirement Counseling includes securities transaction fees (herein “Covered Costs) together with its
investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee
Program.” The Advisor customizes its investment management services for its Clients. The Advisor sponsors
the FFG Retirement Counseling Wrap Fee Program solely as a supplemental disclosure regarding the
combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year,
the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see
Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2022, FFG Retirement Counseling manages $154,554,721 in Client assets, all of which are
managed on a discretionary basis. Clients may request more current information at any time by contacting the
Advisor.