Financial Advocates Investment Management, LLC (“FAIM,” “us,” “we,” “our”) is registered with the Securities and Exchange Commission (SEC) as a registered investment adviser. FAIM is a limited liability company formed in the State of Washington. Our firm has been in business as an investment adviser (IA) since 2010 and is 100% owned by Financial Advocates, LLC. (www.financialadvocates.com). Our business model is based on a decentralized network of Investment Adviser Representatives (“IARs” or “Consultants”) with offices located in numerous states and cities. Although all of the IARs are registered with, and subject to oversight and supervision by, FAIM, they operate their businesses independently and some offices work under a separate business name or “DBA”. IARs associated with FAIM may provide IAR services to clients under a DBA name that is owned and registered by the IAR or the group of IARs which the DBA name represents. As such, marketing materials provided to clients and potential clients may include the DBA name and may include a logo associated with the DBA name. FAIM continues to review and approve marketing materials related to the IAR or IA firm services offered and provided to clients. FAIM supervises IARs in the performance of their IAR duties whether the services are performed under the IAR’s name, the DBA name, or the FAIM name. If properly disclosed as an outside business activity of the IAR, FAIM allows IARs to provide other products and services through their DBA so long as they are unrelated to FAIM’s IA business. These outside business activities are not associated with or supervised by FAIM. Because all of our IARs operate their businesses independently from one another, they have significant flexibility in providing tailored individualized investment advice to clients. FAIM’s home office in Olympia, WA, assists the IARs with marketing, back-office functions and compliance responsibilities. A list of all of the FAIM approved DBA names can be found on our Schedule D, Section 1.B. Other Business Names of our Form ADV Part 1 which is available on the SEC’s Investment Advisor Public Disclosure website at www.adviserinfo.sec.gov. As of December 31, 2023, we managed assets of approximately $ $3,854,566,433 on a discretionary basis. We do not manage assets on a non-discretionary basis. FAIM as a whole offers the following types of services: investment management, hourly consulting, financial planning and consultations, and pension consulting services. Individual IARs offer investment advice to clients utilizing some or all of these services. The following paragraphs describe our services and fees. Asset Management As part of our asset management services, we create a portfolio for each client, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds and/or other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least quarterly and, if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. In designing an investment portfolio for a client, we may work with a third party money manager, also an investment adviser, who is independent of FAIM. When we work with third party money managers, we’re utilizing that money manager’s experience and strategies, helping to develop a suitable portfolio for each client. We conduct initial and ongoing due diligence on any money manager utilized. We also have discretionary authority to add and remove money managers within your investment portfolio. We make sure other advisers are properly registered before we begin working with them. Strategic Wealth Management FAIM offers a comprehensive, open-architecture, fee-based investment platform, LPL’s Strategic Wealth Management (SWM), to clients. Through this platform, clients can consolidate multiple investments into one account and receive one statement. There is no minimum account size required for utilizing the SWM platform. Page 5 of 24 March 30, 2024 In the SWM program, the FAIM advisor may select to have transaction fees included in a single “wrap” fee that covers both advisory fees and transaction costs. SWM is IAR-driven, meaning that the FAIM advisor selects the specific investments in accordance with client objectives, risk tolerance, and other requirements. More detailed information about the benefits and costs of SWM can be found in Item 5, below. More detailed information about the benefits and costs of SWM II can be found in our Wrap Fee Brochure. Wrap Programs: Depending on, among other things, the size of the account, changes in its value over time, the ability to negotiate fees or commissions, and the number of transactions, the amount of the compensation we receive through wrap programs may be more or less than what we would receive if the client participated in other programs, whether through LPL Financial (“LPL”), Double Leaf Portfolios (which are described in more detail in the next section) or another sponsor, or paid separately for investment advice, brokerage and other services. Similarly, services may cost clients more or less than if they paid for the services separately. Where we earn additional compensation due to the client’s participation in a wrap fee program, we have a financial incentive to recommend these programs over other programs where our compensation is lower. This creates a conflict of interest, which we mitigate by fully disclosing our compensation and the choices available to clients, and by making recommendations consistent with our fiduciary duties to clients. Double Leaf Portfolio Solutions FAIM’s Double Leaf Portfolio Solutions are financial models created for use by our IAR’s for their clients. FAIM has partnered with Horizon Investments, to create models that are designed with the client’s investment lifecycle in mind.
• Double Leaf Growth portfolios are designed for clients who are the wealth accumulation stage of their investment lifecycle. There are five globally diverse options, each are balanced with active and passive management to achieve growth in a cost effective manner. These options seek to achieve flexibility while also being focused on the client’s long term objectives. The five models include Double Leaf Aggressive Growth, Double Leaf Growth, Double Leaf Moderate, Double Leaf Conservative and Double Leaf Ultra Conservative.
• Double Leaf Prepare portfolios are designed to help clients with the preservation of wealth stage of their investment lifecycle. The Double Leaf Prepare portfolios singularly prioritize risk management above market returns. The models are Double Leaf Aggressive with Risk Management, Double Leaf Growth with Risk Management, Double Leaf Moderate Growth with Risk Management, Double Leaf Conservative with Risk Management and Double Leaf Ultra Conservative with Risk Management.
• Double Leaf Retire portfolios are designed for clients who are at the distribution of wealth stage of their investment lifecycle. The Double Leaf Retire portfolios seek to increase the likelihood that the client doesn’t outlive their assets and are designed specifically with longevity in mind. The models are Double Leaf 6% Spend, Double Leaf 5% Spend and Double Leaf 4% Spend. Horizon Investment is responsible for the portfolio construction and selection of the underlying investments with input and approval from FAIM. Horizon does not have knowledge of, or interaction, with the end-clients utilizing these models. Wrap Programs Sponsored by LPL Financial Most of our IARs are also registered with LPL, an un-affiliated registered investment adviser and broker-dealer. We may provide advisory services through certain programs sponsored by LPL under a wrap fee program. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs, please see the LPL Financial Form ADV 2A, LPL wrap fee brochure for the specific program, and applicable client agreement. Any Page 6 of 24 March 30, 2024 LPL-sponsored advisory program becomes effective only when an authorized representative of FAIM has accepted the applicable paperwork and client agreement in writing. For all of the LPL-sponsored advisory programs that FAIM offers, LPL serves as program sponsor, investment adviser and broker-dealer. FAIM also acts as investment adviser for these programs and will share in the management fees and may share in other fees associated with these accounts. When using LPL wrap programs, FAIM retains discretionary authority to select individual investments within the programs, but does not have discretionary authority to select new programs or to terminate existing programs. Selection of a new wrap program would require new paperwork and client authorization. Guided Wealth Portfolios (GWP) GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program, which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell exchange-traded funds and open-end mutual funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of FutureAdvisor, Inc. (“FutureAdvisor”), based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although the IAR will be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the program (the “Educational Tool”) is provided for a period of up to forty-five (45) days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL, FutureAdvisor and FAIM by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure.

Users of the Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor or FAIM, do not enter into an advisory agreement with LPL, FutureAdvisor or FAIM, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service. Additional information regarding GWP can be found in our ADV Part 2 A Guided Wealth Portfolios brochure. Third Party Asset Management Programs FAIM makes available advisory services and programs of third party asset managers. Under these programs, FAIM’s IARs provide ongoing investment advice to clients that is tailored to the individual needs of the client, assisting the client in determining suitability of the program, setting investment objectives and processing the paperwork with the third party asset manager. The IAR may also assist the client in selecting the model portfolio designed by the asset manager. When selecting third-party managers, FAIM retains discretionary authority to hire new managers or to terminate existing managers, but does not have discretionary authority to select individual investments. Consulting Services, Financial Planning Some FAIM IARs may offer consulting services, including financial planning. Financial planning services are based on an analysis of the client’s current financial circumstances, goals and objectives. Typically, financial planning and consulting services involve a process of information gathering by the IAR, analysis of the client’s needs or goals, then preparation of a financial plan or other written report. Financial planning services or hourly consulting services may include analysis or discussion in one or more of the following areas:
• Charitable Planning
• Education Planning
• Cost Segregation Study Page 7 of 24 March 30, 2024
• Mortgage/Debt Analysis
• Insurance Analysis
• Lines of Credit Evaluation
• Business and Personal Financial Planning Clients enter into a Consulting Agreement for financial planning and other consulting services. These services vary depending on each client’s needs, but may include any of the above-listed services. FAIM is not qualified to offer legal or accounting advice and we refer clients to an accountant, attorney or other specialist as necessary for non-advisory related services. Comprehensive Financial Planning Generally, financial planning services are based on an analysis of the client’s current financial circumstances, goals and objectives. This involves a process of information gathering by the IAR, then preparation of a financial plan or other written report. Specifically, comprehensive financial planning will address one or more of the six key areas of financial planning:
• Financial Position
• Protection Planning
• Investment Planning
• Corporate and Personal Income Tax Planning
• Retirement Planning
• Estate Planning. Our written financial plans provided to clients or financial planning consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. For comprehensive financial planning engagements, we provide our clients with a written summary of their financial situation, observations and recommendations. Financials plans or consultations are typically completed within six (6) months of a client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Implementation of the recommendations will be at the discretion of the client. Clients are free to implement investment recommendations through brokers unaffiliated with FAIM or its IARs. Hourly Consulting Services General hourly consulting services are provided for a variety of purposes including, but not limited to:
• Annual Update to Financial Plan
• Asset Allocation Recommendations
• Portfolio Management Recommendations
• Individual Issue Consulting
• Third party review (2nd opinion) For hourly consulting engagements, we usually do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our financial planning services. Implementation of any recommendations or next steps to be taken will be at the discretion of the client. Page 8 of 24 March 30, 2024 Investment Fiduciary & Retirement Plan Consulting We provide consulting and advisory services for employer-sponsored retirement plans that are designed to assist plan sponsors of employee benefit plans (“Sponsor”). These services are offered to the Sponsors on a one-time or ongoing basis. Generally, such pension consulting services consist of assisting the Sponsor in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the Sponsor dictate, areas of advising could include, but are not limited to, investment options, plan structure and participant education. Where we offer plan participants the option of using our Participant Advisory Services for discretionary investment management services, we’ll enter into a separate agreement with that participant, describing our services and fees for that service. We also ask that the participant provide information that will help us understand their investment objectives. In providing this service, we are deemed to be a fiduciary and investment manager as defined in ERISA Section 3(38). All pension consulting services shall be in compliance with the applicable state law(s) regulating pension consulting services. This applies to client accounts that are pension or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide our services to such accounts, we acknowledge our fiduciary role within the meaning of Section 3(21) of ERISA, but only with respect to the provision of services described in the Services section of the Investment Fiduciary & Retirement Plan Consulting Agreement (“RPAC”). When providing any ERISA fiduciary services, we will solely be making recommendations to the Sponsor and the Sponsor retains full discretionary authority and/or control over the assets. When entering into an RPAC agreement, the Plan Sponsor may select from a number of different services described below. With the exception of Participant Advisory Services, FAIM will be acting in a non-discretionary capacity and will solely be making recommendations to the Plan Sponsor. FAIM will not perform recordkeeping or brokerage services to the Plan. Neither FAIM nor the IAR will assume the duties of a trustee or a Plan Administrator, as defined in ERISA Sec. 3(16). Services offered under an RPAC agreement are described below. Investment Fiduciary Services: Plan-Level
• Recommendations to establish or revise the Plan’s Investment Policy Statement (“IPS”),
• Recommendations to select and monitor the Designated Investment Alternatives (“DIAs”),
• Recommendations to select and monitor Qualified Default Investment Alternatives (“QDIAs)
• Recommendation to select and monitor other investment managers Investment Fiduciary Services: Participant Level
• IAR will meet with Plan Participants periodically, or upon reasonable request, to collect information necessary to provide individual participants with investment advice and related services regarding the investment options available under the Plan.
• IAR will manage the Participant’s account on a discretionary basis. Retirement Plan Consulting Services
• Administrative Support o Assist Plan Sponsor in reviewing objectives and options through the Plan o Review of Plan committee structure and administrative policies & procedures o Recommend participant education and communications policies under ERISA 404(c) o Assist with development/maintenance of fiduciary audit file and document retention policies o Deliver fiduciary training and/or education periodically or upon reasonable request. o Coordinate and reconcile participant disclosures under 404(a)(5) o Develop requirements for responding to participant requests Page 9 of 24 March 30, 2024
• Oversight of Relationship with Service Provider o Assist with process to select, monitor and replace service providers o Assist with review of Covered Service Providers (CSP) disclosures under ERISA 408(b)(2) and fee benchmarking o Provide reports and/or information designed to assist with monitoring CSPs o Review ERISA Spending Accounts or Plan Expense Recapture Accounts o Assist with preparation and review of Request for Proposals (RFPs) and/or Request for Information (RFIs) o Coordinate and assist with CSP replacement and conversion
• Investments o Periodic review of investment policy in context of Plan objectives o Assist Plan committee with monitoring investment performance o Provide analysis of investment managers and model portfolios o Review and recommend Designated Investment Managers and/or third-party advice providers as necessary o Educate Plan committee members, as needed, regarding replacement of DIA(s) and/or QDIA(s)
• Participant Services o Facilitate group enrollment meetings o Coordinate employee education regarding Plan investments and fees o Assist Plan participants in understanding Plan benefits, retirement readiness and impact of increasing deferrals. Small Market Solution (SMS) Program Under SMS, LPL Research (a team of investment professionals within LPL) creates and maintains a series of different investment menus (“Investment Menus”) consisting of a mix of different asset classes and investment vehicles (“investment options”) for clients that sponsor and maintain participant-directed defined contribution plans (“Plan Sponsors”). The Plan Sponsor is responsible for selecting the Investment Menu that it believes is appropriate based on the demographics and other characteristics of the Plan and its participants. LPL Research is responsible for the selection and monitoring of the investment options made available through Investment Menus. The investment options that are offered through SMS are limited to the specific investments available through the record keeper that the Plan Sponsor selects. The Plan Sponsor may only select an Investment Menu in its entirety and does not have the option to remove or substitute an investment option. Certain other services may also be available. Please refer to LPL Financial LLC’s Retirement Plan Programs Brochure.