A. The Company Make the Memory Financial Planning, LLC (“MMFP” or the “firm”) is a Tennessee limited liability company established in 2024. In May 2024, MMFP applied for registration with the SEC. The principal partners of MMFP are Jordan Vlastuin and Matthew Hale. B. Advisory Services MMFP offers the following investment advisory services: Investment Management Services MMFP offers ongoing Investment Management Services based on the individual goals, objectives, time horizon and risk tolerance of each client. Investment Management Services include, but are not limited to, the following:
• Establishing an Investment Policy Statement – MMFP, in conjunction with the client, will develop a statement that summarizes the client’s investment goals and objectives along with the broad strategy[ies] to be employed to meet those objectives.
• Financial Planning – Investment Management Services includes basic financial planning, which may contain advice regarding asset allocation, the selection of investments, cash flow analysis, retirement advice, and educational planning.
• Portfolio Construction – MMFP will develop a strategic asset allocation for the client based on the client’s risk profile and investment guidelines and is intended to meet the stated goals and objectives of the client.
• Investment Management and Supervision – MMFP will provide investment management and ongoing oversight of the client’s portfolio and overall account. Investment Management Services will be provided on either a discretionary or non- discretionary basis. For accounts managed on a discretionary basis, the client gives MMFP full authority to manage the client's assets in accordance with what MMFP deems to be in the client's best interest based on the client’s investment objective and guidelines. Clients will retain individual ownership of all securities in their accounts. Financial Planning Services If a client desires to obtain financial planning apart from the basic planning services provided as part of portfolio management services, MMFP also provides financial planning as a separate service. MMFP will typically provide a variety of financial planning services to individuals and families. Services are offered in several areas of a client’s financial situation, depending on their goals, objectives, and financial situation. Financial planning services can be provided in one or both of the following manners: Planning Financial planning will involve preparing a financial plan for clients based on the client’s financial goals and objectives. This planning may encompass one or more areas of need, including, but not limited to, investment planning, retirement planning, personal savings, education savings and other areas of a client’s financial situation. A financial plan developed for 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. MMFP may also refer clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, MMFP will provide a written summary of client’s financial situation, observations, and recommendations. Plans are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Consulting Clients can also receive financial advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, reviewing a client's existing portfolio, or any other specific topic. MMFP also provides specific consultation and administrative services regarding investment and financial concerns of the client. Additionally, MMFP provides advice on non-securities matters. Generally, this is in connection with the rendering of

estate planning, insurance and/or annuity advice. For these more limited engagements, MMFP may not provide a written summary. Recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company. Financial Planning Disclosures Should a client choose to implement the financial planning recommendations made by MMFP, MMFP may recommend its own services or that of other professionals (i.e., attorney, accountant, insurance agent, and/or broker-dealer). In performing its services, MMFP is not required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely on such information. Clients are advised that a conflict of interest exists if MMFP recommends its own services. The client is under no obligation to act upon any of the recommendations made by MMFP under a financial planning engagement and/or engage the services of any such recommended professional, including MMFP or its investment adviser representatives. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by MMFP or its investment adviser representatives. MMFP shall cooperate with any attorney, accountant, broker or other adviser chosen by the client with regard to implementation of any such recommendations. Sub-Advisory Services MMFP offers investment advisory services to other registered investment advisers on a sub- advisory basis. Such sub-advisory services may include providing proprietary research and investment ideas. MMFP provides sub-advisory services on both a discretionary and a non- discretionary basis. C. Client Tailored Services and Client Imposed Restrictions MMFP’s investment management services are tailored to meet the specific needs of each client. In order to provide appropriate individualized services, MMFP will work with each client to obtain information regarding the client’s financial circumstances, investment objectives, overall financial condition, income and tax status, personal and business assets, risk profile and other information regarding the client’s financial and investment needs. At least annually, MMFP will review with clients their financial circumstances, investment objectives and risk profile. In order for MMFP to provide effective investment management services, it is critical that clients provide accurate and complete information to MMFP and inform MMFP anytime such information needs to be updated or anytime there is a change in their financial circumstances, investment objectives and/or risk profile. Generally, clients are permitted to impose reasonable restrictions on investing in certain securities or types of securities in their advisory accounts, provided, however, that some restrictions may not be accommodated when utilizing Exchange Traded Funds or mutual funds. In addition, a restriction request may not be honored if it is fundamentally inconsistent with MMFP’s investment philosophy, runs counter to the client’s stated investment objectives, or would prevent MMFP from properly servicing client accounts. Whether clients will be able to place reasonable restrictions on the types of investments which will be made on the client's behalf is at the sole discretion of MMFP. D. Wrap Fee Programs Under a wrap fee program, advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and transaction services (e.g., execution of trades) are provided for one fee. These portfolio solutions are generally pre- configured with limited flexibility. This is different than traditional investment management programs whereby services are provided for a fee, but transaction services are billed separately on a per-transaction basis. MMFP does not offer clients the option of investing in a wrap-fee program. E. Assets Under Management As a newly registered investment adviser, MMFP does not currently have any assets under management.