Investment Adviser Representatives ("IAR"s) associated with SPI provide various investment advisory services and are appropriately licensed, qualified, or authorized to provide advisory services on behalf of SPI.
SPI's principal owner(s): Edward J. Mallon Revocable Trust P.O. Box 1162 Portsmouth, NH 03802 Since 1/19/2000 100% ownership Asset Management Services SPI offers discretionary and non-discretionary continuous asset management services. Our investment advice is tailored to meet the needs and investment objectives of SPI's client. SPI offers initial consultations and request pertinent information about a client's personal and financial circumstances to determine the best suitable investment objectives.
Where SPI enters into a discretionary asset management agreement with a client, SPI is granted discretion and authority to manage a client's account subject to any client specific written guidelines. Accordingly, SPI is authorized to perform various functions without further approval from the client. Such functions may include the determination and amount of securities and/or mutual funds to be purchased and/or sold. Once a portfolio is constructed, SPI provides ongoing portfolio supervision and rebalancing as changes in market conditions and client circumstances may require. For non- discretionary asset management services, SPI monitors a client's assets and provides recommendations as to a client's asset allocation. A client is free at all times to accept or reject any investment recommendations and SPI shall implement its recommendations only upon obtaining client approval.
All employees providing investment advisory services & advice to clients must have passed the Series 65 or Series 7 and 66 securities examination administered by the Financial Industry Regulatory Authority. Equivalent Professional Designations such as CFP, CFA will also be considered.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"). 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 a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, 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; 4
•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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. As of 12/31/2023, total discretionary accounts equal 822 with assets under management of approximately $163,149,923. Secure Planning, LLC currently has no non-discretionary accounts.
SEI Asset Management Program SPI maintains an agreement with SEI Investment Management Corporation, SEI Investments Distribution Company, and SEI Trust Company (collectively "SEI") whereby SPI's IARs may offer SEI's asset allocation programs to clients. IARs assist clients in selecting a specific and suitable allocation portfolio by discussing the various levels of risk and completing a questionnaire detailing their annual income, net worth, long-term goals, and objectives. SPI's services may include:
•Educating clients as to various funds offered through SEI's approved list of third-party Mutual Funds, Individual Stocks and Bonds;
•Construct a customized asset allocation program from the approved list (noted

above) to meet client investment objectives;
•Alternatively, select an SEI model portfolio if it better meets the needs of a client;
•Provide clients with a prospectus for each of the Mutual Funds selected and explain the rebalancing guidelines utilized in the management of a portfolio;
•Reinvesting all dividends and interest in accordance with the asset allocation policy;
•Notify clients at the time of signing an agreement that if quarterly rebalancing is suspended, rebalancing shall be done by SPI;
•Once a specific allocation is agreed upon, the IAR instructs SEI to purchase or sell no-load mutual funds pursuant to the investment objectives and rebalancing parameters selected by a client; and
•SEI shall serve as custodian and provides clients with account statements, quarterly performance reports and an annual tax report. Charles Schwab & Co. Asset Management Program SPI maintains an agreement with Charles Schwab & Co., (SCH) to provide asset allocation programs to clients.
SPI utilizes SCH's asset allocation program on a limited basis and recommends this program only when a client's financial circumstances and investment suitability is appropriate.
By signing an Asset Management Program Account Agreement, a client directs SPI to initiate the instructions with SCH.
SPI assist clients in selecting a specific and suitable allocation portfolio by discussing the various levels of risk and completing a questionnaire detailing a client's annual income, total net worth, tax bracket, risk tolerance and long-term goals and objectives. 5 SPI's services may include:
•Educating clients as to various funds offered through SCH's approved list of third-party Mutual Funds;
•Construct a customized asset allocation program from the approved list (noted above) to meet client investment objectives;
•Provide clients with a prospectus for each of the Mutual Funds selected and explain the rebalancing guidelines utilized in the management of a portfolio;
•Reinvesting all dividends and interest in accordance with the asset allocation policy;
•Notify clients at the time of signing an agreement that if rebalancing is suspended, rebalancing shall be done by SPI;
•Once a specific allocation is agreed upon, SPI instructs SCH to purchase or sell mutual funds pursuant to the investment objectives and rebalancing parameters selected by a client; and
•SCH serves as custodian and provides clients with account statements, performance reports and an annual tax report. Financial Planning Services SPI offers financial planning and consulting services for a fee. SPI's services are advisory in nature, with respect to the management of client's financial resources. Financial plans are based on the client's financial situation at the time the plan is presented and on financial information disclosed by a client to SPI.
Clients are advised that certain assumptions may be made with respect to interest and inflation rates and use of past trends and performance of the market and economy.
Past performance is in no way an indication of future performance. SPI cannot offer any guarantees or promises that the client's financial goals and objectives will be met.
Should a client's financial situation, goals, objectives, or needs change, the client must notify SPI promptly.
Financial planning and consulting arrangements may provide, but not limited to, the following:
•After an individual client analysis is conducted and a client approves SPI for its financial planning services, an IAR will conduct follow up meetings to collect additional information about the client's financial circumstances and objectives;
•Once client suitability and financial objectives information is reviewed and analyzed, a financial plan may be presented to the client;
•A client may act on SPI's recommendations by placing securities transactions with any brokerage firm the client determines and is under no obligation to act on SPI's financial planning recommendations; and
•Should a client act on any of SPI's recommendations, there is no obligation to implement the financial plan through SPI. Finn Wealth Advisors The advisory services described in this brochure are also offered to certain clients through Finn Wealth Advisors doing business under SPI. Finn Wealth Advisors focuses on supporting athletes in achieving their goals through wealth management. 6