Financial Life Focus, LLC (“Financial Life Focus”) is a registered investment advisor with the Securities and Exchange Commission (“SEC”). Financial Life Focus is organized as a limited liability company in the State of Pennsylvania, which has been in business since October 2001. Financial Life Focus has been a registered investment advisor with the SEC and has been in business since June 2010. Financial Life Focus is owned and operated by Jeremy Levinn. Certain Investment Adviser Representatives (“IAR”) market and deliver advisory services under a practice name or “doing business as”, whose names and logos may appear on marketing materials as approved by Financial Life Focus, or client statements approved by the custodian. It is important to note that the businesses are legal entities of the IARs and not Financial Life Focus, nor the custodian. However, advisory services are engaged exclusively through Financial Life Focus. The Advisor has $311,599,847 in Client assets under management as of December 31, 2022, all of which are managed on a non-discretionary basis. Financial Life Focus, LLC (“Financial Life Focus” or the “Advisor”) provides financial life planning on behalf of individuals, high net worth individual, trusts, estates, charities, and pension/profit sharing plans (each a “Client”). The Advisor applies the principles of Financial Life Planning® to develop and nurture mutually beneficial relationships with its Clients and their families. Financial Life Focus aims to empower its Clients to approach their lives and resources in a balanced and successful manner by seeking to: act with integrity, compassion, and the highest level of professional standards; guide Clients to understand and articulate their core values and improve their comfort in addressing financial issues; explore Clients’ needs and concerns and help them to navigate life transitions; and create and support the implementation of wealth-building strategies that align with Clients’ goals and dreams. The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate potential conflicts of interest. Financial Life Focus’ fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Prior to engaging Financial Life Focus, the Client is required to enter into one or more written agreements with the Advisor setting forth the terms and conditions under which Financial Life Focus renders its services (collectively the “Agreement”). This Disclosure Brochure describes the business of Financial Life Focus. Certain sections will also describe the activities of its associated persons (herein our “Supervised Persons”). Supervised Persons are any of the Advisor’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on Financial Life Focus’ behalf and is subject to Financial Life Focus’ supervision or control. Financial Life Services Financial Life Focus works closely with its Clients by providing comprehensive advisory services through an ongoing advisory retainer. The Advisor’s services provide Clients with a broad range of comprehensive and personalized financial planning along with non-discretionary management of Client investment portfolios. Details of these services are described below. The terms of these retainer services are more fully set forth in the Financial Life Focus advisory agreement. In delivering these services, the Advisor typically meets with Clients throughout the year, through in-person meetings, phone calls, and electronic communications. Page 5 Financial Planning Services Financial Life Focus may provide its Clients with a broad range of comprehensive financial planning services. As detailed in Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss these services are based on the principles of Financial Life Planning®. The Client is not obligated to implement any suggestions made by the Advisor in the financial plan, and may accept or reject any of Financial Life Focus’ recommendations. In order to keep the financial plan current, the Client is advised to notify the Advisor if there is ever any change in financial situation or investment objectives. Financial planning supports

the Advisor’s investment management services, and the financial plan drives any management decisions. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Investment Management Services Certain investment advisor representatives offer investment management services on a stand-alone basis. Clients can engage Financial Life Focus to manage all or a portion of their assets on a non-discretionary basis. Financial Life Focus primarily allocates Clients’ investment management assets among institutional mutual funds and exchange-traded funds (“ETFs”), in accordance with the investment objectives of the Client. To accomplish this, and as further discussed in response to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss and Item 12 – Brokerage Practices below, Financial Life Focus recommends that Clients use the asset allocation services of Buckingham Strategic Partners, LLC (“BSP”). BSP is an unaffiliated investment advisor registered with the SEC. BSP provides an asset allocation and investment account management platform and associated administrative services to Financial Life Focus and its Clients. Financial Life Focus tailors its advisory services to the individual needs of Clients. The Advisor consults with each Client to discuss their risk tolerance and financial situation initially and on an ongoing basis to develop a Statement of Investment Selection (“SIS”), which determines risk tolerance, time horizon, and other factors that may impact the Client’s investment needs. Prior to completing a SIS, the Advisor requests that the Client completes a risk tolerance assessment. Financial Life Focus ensures that the Client’s investments are suitable for their investment needs, goals, objectives, and risk tolerance. Financial Life Focus then provides the Client’s investment strategy, trade restrictions, and target allocation to BSP to implement the plan.
Clients may impose reasonable restrictions or mandates on the management of their account[s] if, in Financial Life Focus’ sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client take a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Account (“IRA”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee- based account). In certain instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest only if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Retirement Plan Advisory Services Financial Life Focus provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: ● Vendor Analysis ● Plan Participant Enrollment and Education Tracking ● Investment Policy Statement (“IPS”) Design and Monitoring [OR] Review ● Investment Oversight Services (ERISA 3(21)) ● Performance Reporting Page 6 ● Ongoing Investment Recommendation and Assistance These services are provided by Financial Life Focus serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Financial Life Focus’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.