Our Advisory Business FFA is an investment advisory firm providing customized financial planning and investment advisory services to a broad array of clients. FFA is a limited liability company founded in 2017 by Jason Mickool and, as of September 12, 2022 is now directly owned by Florida-Trinity Holdco, LLC that is principally owned by Jason Mickool (through Mickool Enterprises One, Inc., Mickool Enterprises Two, Inc. and Mickool Enterprises Three, Inc.) and AL Marketing, LLC, a wholly owned subsidiary of AmeriLife Group LLC (“AmeriLife”). FFA is also under common ownership with Trinity Wealth Securities, LLC (“TWS”), a broker/dealer, and Florida Financial Insurance, LLC (“FFI”), an insurance agency. For additional information about TWS and FFI, see Item 10. FFA is registered as an investment adviser with the SEC. As of December 31, 2023, we had $199,000,000 in discretionary and $0 in non-discretionary assets under management. We provide investment advice through our Investment Adviser Representatives (IARs) associated with us. We primarily provide financial planning and investment advisory services to individuals, trusts, estates, charitable organizations, pension plans/profit sharing plans, corporations and business entities, and state or municipal government entities. Financial Planning As part of our investment advisory relationship with our clients, we provide financial planning services. Fee based financial planning is a comprehensive relationship which incorporates many different aspects of your financial status into an overall plan to help guide your goals and objectives. The financial planning relationship consists of face-to-face meetings and ad hoc meetings with you and/or your other professionals (e.g., attorneys, accountants, etc.) as necessary. Generally, the financial plan is presented to the client within 30 – 60 days (of the contract date). Follow-on client service meetings may take place thereafter, at FFA’s discretion. In performing financial planning services, we typically examine and analyze your overall financial situation, which can include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing your current investment program. Our services focus on all or only one of these areas depending upon the scope of our engagement with you. It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant, or other professionals. FFA ADV Part 2A March 2024 Page 5 of 32 If you engage us to perform these services, you will receive a written agreement specifying the services, fees, terms, and conditions of the relationship. An IAR can make various recommendations through the financial plan, including but not limited to recommending the services of other professionals for implementation purposes. The IAR can recommend using or select TWS’ brokerage services or FFI’s insurance services, affiliates of FFA. You are under no obligation to implement recommendations through us. You can implement your financial plan through any financial organization of your choice. See disclosures below in Item 10. Investment Advisory Services FFA manages client investment portfolios on a discretionary or non-discretionary basis. FFA tailors its advisory services to meet the needs of its individual clients. FFA consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify FFA if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if FFA determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Adviser’s management efforts. FFA primarily allocates client assets among various mutual funds, exchange-traded funds (ETFs), and individual equity securities and recommends various products and services available through Turnkey Asset Management Platforms (“TAMPs”) in accordance with the client’s stated investment objectives. Upon request, FFA can also provide services related to client assets “held-away” at

other custodians, administrators, or product providers. This service generally applies to variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans) and other client accounts where FFA is providing very limited services. For these types of assets, investment selection is generally limited to the investment options approved by the plan administrator or product provider. Because of this, FFA’s advisory services to held-away accounts are limited to those available investment options and can be subject to other service limitations, as disclosed to the client in a separate written agreement. Turnkey Asset Management Platforms (“TAMPs”) Services or Selection of Other Advisers: We recommend and/or select Turnkey Asset Management Platforms (“TAMPs”) or other advisers to handle all or a portion of the asset management process. TAMPs typically include technology, FFA ADV Part 2A March 2024 Page 6 of 32 investment research, portfolio management and other outsourcing services. TAMPs generally provide services that enable the advisors to integrate multiple providers, programs, products, and custodians. In addition, we currently offer investment advisory products and services through, including wrap fee programs offered by, the following TAMP Sponsors:
• Envestnet Asset Management, Inc. (“Envestnet”),
• Morningstar Investment Services LLC (“Morningstar”) and
• Orion Portfolio Solutions, LLC (“Orion”). Note: FFA clients that use Envestnet and Morningstar will be required to custody their assets with Schwab; FFA clients that use Orion may custody their assets at either Fidelity or Schwab. For additional information about FFA’s brokerage practices, see Item 12. We can offer the investment advisory products and services of other TAMP Sponsors in the future. For more information regarding these programs, including additional information on the advisory services and fees that are applicable, the types of investments available in the programs and the potential conflicts of interest presented by the programs, please refer to the information provided by us, including, but not limited to, the applicable TAMP Sponsor’s Form ADV Part 2A brochure, Wrap Fee Program brochure or the applicable program’s Form ADV Part 2A brochure, Wrap Fee Program brochure and applicable agreement(s). The difference between an account in a wrap fee program and a non-wrap fee account is whether the TAMP Sponsor or the client pay for the custodial and/or transaction charges. FFA receives an investment advisory fee for its services, even if those services are provided through a TAMP. Additional information on fees and compensation is described below in Item 5. Retirement Assets: 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 an exemption that requires us to act in your best interest and not put our interest ahead of yours. Under this exemption, we must:
• 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; FFA ADV Part 2A March 2024 Page 7 of 32
• 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. Pension Consulting Services FFA offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker/dealers
• creating a written pension consulting plan. These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants.