TFC Financial Management, Inc. (“we,” “us” or “the firm”) is an SEC-registered investment adviser with its principal place of business at 260 Franklin Street, Boston, Massachusetts. We began conducting business in 1981. We provide investment management and financial planning services, as described in more detail below. The fact that we are registered with the SEC does not imply that we have a certain level of skill or training. The principal owner of the firm, which is a Massachusetts corporation is:
• Renée Kwok, President and CEO (over 25% owner) Ms. Kwok is a full-time employee of the firm and is actively engaged in the business, operations and management of the firm. We offer the following services to our clients: Investment Management Services We provide investment management services on a discretionary basis. This is our principal business activity. For client accounts that we manage on a discretionary basis, guided by a mutually agreed to Investment Policy Statement (IPS), we direct the investment and reinvestment of the assets in the client’s account(s), the proceeds thereof, and any additions thereto, in our discretion and without prior notice to, or approval of the client within the agreed upon Investment Policy Statement guidelines signed by the Client and TFC. We also manage a limited number of special situation client accounts on a non-discretionary basis. For these clients, we monitor the investment accounts they have designated to us and make investment recommendations to the client, but the recommendations are only implemented with the client’s specific approval. Our investment management clients are invested primarily in no-load, open-end mutual funds and/or ETFs, but may also be invested in individual equity and fixed income securities. The mutual funds and/or ETFs we invest in, or recommend to clients, are global in scope and diversified among various asset classes and investment styles. As of December 31, 2022, we managed client assets of approximately $1.2 billion on a discretionary basis. For all clients, we provide continuous supervision of the client’s account based on the individual goals and objectives of each client. Through discussions with each client in which investment goals and objectives, risk tolerance, time horizons, and liquidity requirements are established, we develop with the client a written Investment Policy Statement that becomes part of the client’s contract with the firm. We then create and manage the client’s portfolio (or make investment recommendations to the client), in accordance with, and with a view to achieving the client’s goals and objectives as set forth in the client’s Investment Policy Statement. We believe that a globally diversified portfolio of no-load mutual funds and ETFs provides our clients with a broader foundation and, therefore, moderation of potential risk and volatility than investment in individual securities. However, it is possible that a portfolio of individual securities could outperform a portfolio invested in mutual funds and/or ETFs. Employing what has become defined as an “open architecture” approach, our clients are primarily invested in no-load, open-end mutual funds and/or ETFs. Those funds may invest in, and we may provide advice to clients from time to time regarding the following types of investments:
• Exchange-traded funds (ETFs)
• Closed-end mutual funds
• Exchange-listed and over-the counter equity and fixed income securities
• Securities of foreign issuers, both corporate and sovereign
• Warrants and other rights
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance products
• Variable and fixed annuities
• Federal and state governmental securities
• Real estate, through publicly traded REITS
• Natural resources
• Interests in partnerships and other alternative investment vehicles Because some of these investments involve additional levels and types of risk, we will only buy them or recommend them if it is consistent with the client's Investment Policy Statement. Use of Third-Party Managers and/or Consultants We have a consulting agreement with an SEC-registered investment advisor to provide advice to us with respect to individual equity securities held in our clients’ accounts. While we take such advice into consideration in managing our clients’ accounts, we make all final investment decisions and recommendations. Any fees paid under this consulting agreement are fully born by TFC. We may also, when appropriate, recommend direct investment with independent third-party managers, typically when those managers demonstrate knowledge and expertise in a particular investment strategy such as management of fixed-income or alternative investments portfolios. As part of this service, we perform management searches of various unaffiliated registered investment advisers. Based on a client's individual circumstances and needs (as exhibited in the client's IPS) we will determine which third-party manager’s portfolio management style is appropriate for that client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client and the investment philosophy of each third-party manager. With the client’s initial prior consent, we will open a separate account for the client to be managed by the third-party manager. The client will sign a separate Investment Management Agreement with the third-party

manager, granting the third-party manager the discretionary authority needed for day-to-day management of the client’s portfolio placed with that particular manager. We encourage clients to review each third-party manager’s disclosure document regarding the particular characteristics of any program and managers selected by us. Once we determine which third-party manager(s) are most appropriate for the client, we will provide the selected third-party managers(s) with the client's investment objectives. The selected third-party manager will then create and manage the client's portfolio based upon the client’s objectives, as communicated by us. We will regularly and continuously monitor the performance of the selected third-party manager(s). If we determine that a particular third-party manager is not providing sufficient management services to the client or is not managing the client's portfolio in a manner consistent with the client's stated investment objectives, we will remove the client's assets from that third- party manager and place the client's assets with another third-party manager pursuant to the grant of discretionary investment authority by the client to our firm. Our firm will conduct appropriate due diligence on all independent third-party managers, making reasonable inquiries into their performance calculations, policies and procedures, Code of Ethics, and other operational and compliance matters deemed important to account performance and risk management. No referral fees are paid by selected-third-party managers to our firm. Financial Planning Services We provide comprehensive, as well as targeted (i.e., goal-specific), financial planning services. Financial planning involves a comprehensive evaluation of a client’s current and future financial situation using currently known information and variables to project future cash flows, asset values and withdrawal plans. We gather relevant client information through in-depth interviews and financial data collection. Information gathered includes the client's current financial status, tax status, future goals, return objectives, and attitudes towards risk. We carefully review documents supplied by the client (such as wills and trusts, income tax returns, insurance policies, and retirement plans), including a detailed questionnaire completed by the client. In the financial planning process, we attempt to consider all relevant factors as they impact, and are impacted by, the entire financial and life situation of the client. Clients engaging us for financial planning generally receive a list of recommendations designed to assist the client in achieving his or her financial goals and objectives. Although a financial planning engagement may be targeted at one client objective, such as retirement, usually a financial plan will address any or all of the following areas:
• Personal finances: We review family records, cash flows, personal liability exposure, estate information and financial goals.
• Tax and cash flows: We input and analyze the client’s past and current income tax and spending levels then illustrate the impact of various types of investments on the client's current and future cash flow and tax liability.
• Investments: We analyze the client’s current investments and possible alternatives, recommend changes, and discuss their potential effect (risk vs. return) on the client's portfolio.
• Insurance: We review existing life, health, disability, long-term care, liability, home and automobile policies and make generic recommendations if we think coverage should be changed. We do not make recommendations for specific replacement tied to any carrier, broker or agent, but sometimes suggest an agent to assist with implementation.
• Retirement: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• Death and disability: We review the client’s potential cash needs in the event of death or disability, including income and liquidity needs of surviving dependents and disability income.
• Estate planning: In consultation with the client’s estate planning attorney, we assist the client in assessing and developing long-term dispositive strategies, including as appropriate, living trusts, wills, protecting estate taxes under current tax laws, powers of attorney, asset protection. Any new estate planning documents are prepared by the client’s estate planning attorney, which we are prepared to review for completeness. Typically, the financial planning recommendations are presented to the client within six months of the contract date, usually during a series of meetings, each covering specific segments of the planning process. Should the client choose to implement the firm’s recommendations, we suggest the client work with his/her attorney, accountant, insurance agent, and/or securities broker. We are prepared to assist in the implementation of financial plan recommendations, but how this is carried out is entirely at the client's discretion. Investment Monitoring Services Clients may elect TFC to continuously monitor their investment portfolios and provide recommendations relating to such portfolios. Under the terms of this service, clients remain solely responsible for deciding whether to implement TFC’s recommendations and for implementing any or all of the received recommendations. TFC does not typically have investment discretion or trading authority for these client accounts.