A. Business Commencement Date Focus Financial Network, Inc. ("FFN") was formed in Minnesota in September of 1993. B. Ownership FFN is owned by multiple individuals. None has an ownership interest greater than 20 percent. C. Services Advisory accounts are managed by Investment Advisory Representatives affiliated with us (each, an “Advisor”). Your Advisor might not offer all the advisory services and programs described in this Brochure. Talk to your Advisor about the services he/she provides. MANAGED ACCOUNT SERVICES We offer personalized management services tailored to your individual needs. Your Advisor elicits information about your financial situation, investment objectives, retirement goals, risk tolerance, liquidity or cost of living needs, education funding objectives, and investment time horizons (collectively, your “Investor Profile”). Your Advisor will analyze your information and construct a customized allocation mix and investment strategy that he/she believes is suitable. Your Advisor provides continuous and ongoing management of your account. As agreed by you and your Advisor, asset management services will be provided on either a discretionary or non- discretionary basis, as described below. Discretionary. You grant us the authority to buy and sell securities in your account without having to obtain your prior authorization for each trade. Non-discretionary. We will need your approval before effecting each transaction in your account. If you approve a recommended transaction, we will arrange the transaction. We offer these managed account services if your account is held by one of the following firms:
• Osaic Wealth, Inc. (“Osaic Wealth”) custodied at Pershing, LLC (“Pershing”)
• Charles Schwab & Co., Inc. ("Schwab")
• National Financial Services, LLC and Fidelity Brokerage Services, LLC (together, "Fidelity") (if the account is a Qualified Corporate Retirement Plan)
• Directly with the variable annuity company Since transaction recommendations and decisions are based on each client's Investor Profile, recommendations for or actions in your account may differ from or conflict with the advice we give to or actions we take in other client accounts. Some custodians (such as Schwab) provide an automated rebalancing option where your asset holdings will be rebalanced at certain intervals. If you select a firm that is not listed above for custodial and/or brokerage services, you will not be able to receive managed account services from us. Instead, your Advisor can provide you with Recommendation Services (see below). RECOMMENDATION SERVICES On an ongoing basis, consistent with your Investor Profile, your Advisor will recommend investment strategies, asset allocation mixes, or securities transactions on a non-discretionary basis. You will implement the recommendations as you see fit and arrange for the transactions in your account. We will not have the authority to buy or sell securities in your account. WRAP PROGRAM ACCOUNTS We offer discretionary asset management services through two different wrap fee programs (the “Wrap Programs”). In a Wrap Program, you pay a “wrap fee” that covers the advisory services offered by us, the execution of transactions in the advisory account by the program’s broker-dealer (the “Wrap Broker”), and the custodial services. We remit a portion of the wrap fee we collect to the Wrap Broker for its execution services. For Wrap Program accounts, we direct all account brokerage transactions to the Wrap Broker to prevent incurring additional transaction charges outside of the wrap fee. We might not be able to obtain the most favorable price because we might not be able to aggregate or batch the trades from these accounts with other client trades. In addition, the wrap fee program may cost you more or less than purchasing such services separately, particularly where there are a low number of transactions. See Item 5 below, which provides fee schedules for wrap accounts as well as for non-wrap accounts. Specific information about each Wrap Program we offer is available in the applicable Wrap Fee Program Brochure that is provided prior to or concurrent with enrollment in the Program. Summary information about our Wrap Programs follows: Vision2020 Wealth Management - Advisor Managed Portfolios Program Through the Advisor Managed Portfolios (“AMP”) Program, your Advisor manages your assets using asset allocation planning software that offers risk tolerance assessment tools, efficient frontier plotting, fund profiling and performance data, and portfolio optimization and re- balancing tools. Your Advisor uses these tools to construct an investment portfolio based on your risk tolerance (which is determined through a detailed questionnaire) as well as your specific investment objectives, time horizon, and overall financial situation (collectively, your “Investor Profile”). Pershing provides the execution, clearing and custodial services. Your Advisor can allocate your portfolio among a mix of stocks, bonds, options, exchange-traded funds, mutual funds and other securities ("Program Investments") consistent with your Investor Profile. Each portfolio is designed to help you meet your stated goals and objectives. We will have the discretionary authority to buy and sell securities in your account consistent with any reasonable restrictions you place on the types of securities that can be purchased. If the restrictions you wish to impose prevent us from properly servicing the account or would require us to deviate from our standard suite of services, we may terminate the relationship. See the Advisor Managed Portfolios Wrap Fee Program Brochure for further information. Vision2020 Wealth Management - Unified Managed Account Program The Wealth Management Platform – Unified Managed Account ("UMA") Program provides the opportunity to invest your assets across multiple investment strategies and asset classes by implementing an asset allocation strategy. After you discuss your financial goals and objectives with your Advisor, we will recommend an asset allocation model ("UMA Model") that will consist of investment strategies created and managed by investment managers or your Advisor. Generally, assets are invested in a selection of mutual funds, exchange traded products, equities, and/or bonds. We will recommend a UMA Model to you based on your responses to a Questionnaire, your investment objectives and goals, risk tolerance, investment time horizon, and overall financial situation. In addition, you can place reasonable restrictions on investing in certain securities or types of securities within your UMA. All recommendations in the UMA are made on a discretionary basis, which means your Advisor can buy and sell securities without your prior approval. See the Wealth Management Platform – Unified Managed Account Wrap Fee Program Brochure for further information. THIRD PARTY MANAGERS In some cases, particularly for clients having investable assets under $10,000, your Advisor may recommend utilizing the services of a third-party investment adviser. These third parties are not affiliated with us and we do not manage, control, or supervise their activities. Turn-Key Asset Management Program (Orion) The Turn-Key Asset Management Program (“TAMP”) consists of various model portfolios made available by and managed by a third-party investment adviser, Orion Portfolio Solutions, LLC (“Orion”). Your Advisor evaluates the objectives and risk profiles of the available models, which range from conservative to moderate, in conjunction with your investment objectives, risk tolerance, and financial profile to assist you in determining which model is best suited for you. For each model, money is invested in mutual funds, cash, and/or cash equivalents. Your account will be invested in accordance with the selected model. Accounts are rebalanced when additional contributions exceed 10% of the portfolio’s value and at the discretion of the Advisor. Clients in this program will enter into a separate agreement with Orion to grant Orion the discretionary authority to purchase and sell assets on their behalf within the selected model. The limitations on Orion’s authority as well as their fees and billing methods are described in Orion’s Form ADV Part 2A Brochure and/or its Client Agreement. Our advisory fees are in addition to Orion’s fees. Your Advisor will remain available to answer questions you have regarding your account. Third Party Manager Platforms Your Advisor develops

a customized portfolio tailored to your investment objectives, risk tolerance, and financial profile. Your Advisor determines the securities to be purchased and sold and when to execute the purchases and sales within your account. Your Advisor also determines when to rebalance the account or revise the allocation of the account. Transactions are conducted on a discretionary basis (i.e. you will not receive prior notice of securities transactions). Your Advisor uses a third party’s platform to arrange for the transactions in your account. A portion of the fee you pay to us is given to the third party to pay for use of the platform. RETIREMENT PLAN CONSULTING SERVICES We offer the following non-fiduciary retirement plan and other consulting services to Employer- Sponsored Plans. Our role is limited to providing generalized, non-discretionary advice concerning the merits and risks of investments. Platform Provider Search and Plan Set-up We gather information about the company (statistical data, goals, objectives, and needs). Based on this information, we request proposals from appropriate interested providers. We review the proposals with the company to help select the appropriate platform. We assist in setting up the plan and communicating the plan to the plan participants. Strategic Planning and Investment Policy Development or Review We meet with the designated fiduciaries of the Plan to assist in developing an investment policy statement (the "IPS"). If the Plan already has an IPS, we will review the existing IPS and assist the Plan in determining whether (i) the performance of the Plan's investments is consistent with the goals set forth in its IPS; and/or (ii) the IPS should be revised based on our analysis of the Plan's liquidity requirements, performance goals and risk tolerance levels. Plan Review We will review the structure of the Plan (e.g., product vendors, investment options) to gauge whether it is operating in accordance with the Plan's IPS (if any) and governing plan documents. We will present recommendations in connection with our review. The Plan is ultimately responsible for deciding whether to accept our recommendations and for consulting with its legal counsel to ensure compliance with applicable laws. Fee and Cost Review We will conduct an expense analysis of the various fees and costs borne by the Plan, including any fees paid from participant accounts, and report the results of such analysis to the plan fiduciary. Such analysis will compare the fees to one or more generally accepted benchmarks. The analysis will be based on information received from the Plan and/or its third-party service providers. Third Party Service Providers - Liaison As agreed upon between FFN and the Plan, we will assist the Plan fiduciary(ies) in coordinating services offered by Plan service providers, including, as applicable, trustees, custodians, named fiduciaries (as defined by ERISA), actuaries, legal and/or accounting advisors, and other third party service providers. Assessment of Investments As agreed upon between FFN and the Plan, we will (a) perform periodic reviews concerning fund performance, risk vs. return, fund expenses, number of participants, and asset allocation, and compile a list of funds to be considered for adding or removal, (b) prepare investment provider paperwork and participant notices to implement fund changes, and (c) review and monitor investment managers. Participant Education and Communication We conduct investment education seminars and/or enrollment meetings where we provide descriptive information about the Plan, the benefits of Plan participation, and the investment options available. As agreed, services can also include:
• General financial and investment information
• Generic asset allocation models (including models for specific plan investment options)
• Assistance in selecting a third-party vendor to help in education and enrollment meetings
• Support in plan termination meetings to educate participants on their options
• General retirement planning seminars for participants We can also provide advisory services directly to plan participants, plan benchmarking, plan conversion, assistance in plan mergers, and legislative and regulatory updates or plan corrections. RECOMMENDATIONS (PENSION, PROFIT SHARING, 401(k) & 403(b) PLANS) On a one-time non-discretionary basis, your Advisor can recommend an asset allocation mix for your company’s retirement plan within the available investment options. The plan will be responsible for implementing any accepted recommendations. If you would like to receive ongoing asset allocation recommendations, you will need to supply your Advisor with current statements of the plan’s accounts on an ongoing basis. FINANCIAL PLANNING SERVICES The agreement will specify the types of financial planning services to be provided. The types of financial planning advice we offer include, but are not limited to:
• Asset allocation recommendations tailored to your financial and tax status, investment objectives and risk tolerance.
• Tax Planning Illustrations
• Estate Planning Illustrations
• Employee Benefit Planning
• Insurance advice (provided at no charge where charges are prohibited by state statute)
• Accumulation Planning
• Retirement Planning Illustrations
• Cash Flow Analysis and/or Debt Analysis Generally, planning services will involve a one-time analysis of your financial circumstances and objectives. The analysis can include present and anticipated assets and liabilities, insurance needs, savings, investments, and anticipated retirement or other employee benefits. The analysis can include recommendations and an action plan. You can also engage us for ongoing financial planning and consulting services on an annual basis, in which case you will have access to your Advisor at any time during the year upon your request. Services will include a financial analysis, updates to the financial cost analysis as requested by you, and consultation services upon your request during the year. Financial plans and analyses are based on your financial situation at the time disclosed to us by you. Although certain assumptions will be made with respect to interest and inflation rates and market trends and performance, it’s important to keep in mind that past performance is not indicative of future performance. We cannot give any guarantee as to results and we cannot assure that the objectives of the accounts will be realized. You should notify us if your financial situation or investment objectives change. ROLLOVER RECOMMENDATIONS. When leaving an employer, you typically have four options (alone or in combination) regarding an existing retirement plan: (i) leave the money in the former plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an individual retirement account (IRA), or (iv) cash out the account value (which could, depending on your age, have adverse tax consequences). We have an inherent conflict of interest when recommending that you roll over your money into an account managed by us if we charge based on the advisory account’s value. Upon any rollover recommendation, we will give you a disclosure notice about your options that you should carefully consider before taking any action. You are never under any obligation to rollover retirement plan assets to an account managed by us. GENERAL INFORMATION. Our investment advice and recommendations should not be construed as legal or accounting advice. Transactions in your account, account reallocations, and rebalancing might trigger a taxable event. You should coordinate and discuss the impact of financial advice and decisions with your attorney and/or accountant. You should inform us promptly about any material changes in your financial situation and investment objectives. INVESTMENT PRODUCT TYPES. Generally, our investment advice is confined to the following universe of securities and products:
• Exchange-traded equity securities
• U.S. government securities
• Mutual funds (open end and closed end)
• Variable contracts (including variable annuities)
• Exchange-traded funds (ETFs)
• Real estate investment trusts (REITs) D. Assets Under Management As of December 31, 2023, FFN was managing $5,050,214,974 on a discretionary basis and of $335,753,568 on a non-discretionary basis.