Strategic Financial Partners, Ltd. (hereinafter “SFP”) is a registered investment advisor based in Bend, Oregon. We are a corporation, organized under the laws of the State of Oregon. Grant Carroll and Richard Williams are the founders and only shareholders of SFP. While the two founders have provided financial planning and investment advice since 1989, SFP was established in 2009. You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of our firm. Where required, such persons are properly registered as investment adviser representatives. Currently, we offer the following investment advisory services, personalized to each individual Client:
• Wealth Management Services
• Portfolio Management Services
• Financial Planning Services
• Pension Consulting Services Wealth Management Services SFP provides broad-based wealth management services to Clients. This service is a combination of financial planning and portfolio management services. Clients purchasing this service receive a financial plan that is used to assist SFP in organizing a Client’s financial information and determining the scope of services that are most suitable for the Client’s financial situation and investment needs. Once a financial plan is in place, the firm implements investment recommendations as part of its ongoing portfolio management service. The financial plan is monitored and revised on an as needed basis. SFP’s financial planning and portfolio management services are described in further detail below. Portfolio Management Services Our firm offers continuous discretionary and, in limited cases, non-discretionary portfolio management services. Discretionary portfolio management means we will make investment decisions and place buy or sell orders in your account without contacting you. These decisions are made based upon your stated investment objectives. You may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Non-discretionary portfolio management service means that we must obtain your approval prior to making any transactions in your account. Our investment advice is tailored to meet your needs and investment objectives. If you decide to hire our firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals, and decide how much risk you should take in your investments. The information we gather will help us implement an asset allocation strategy that will be specific to your goals, whether we are actively investing for you or simply providing you with advice. SFP does not recommend one particular type of security over other types of securities, but we do provide advice on various types of securities, such as exchange listed equities, over the counter equities, foreign issues, American depository receipts, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (including mutual funds and exchange traded funds), US Government securities, options contracts on securities and/or commodities, private equity instruments, and interests in partnership investing in real estate. Additionally, we will provide advice on existing investments you may hold at the inception of the advisory relationship or on other types of investments for which you ask advice. Because some types of 5 | P a g e investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. However we construct your investment portfolio, we will monitor your portfolio’s performance on a continuous basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions, your financial circumstances, or both. Wrap Fee Programs SFP is the portfolio manager and sponsor of the SFP Wrap Fee Program. A wrap fee program combines portfolio management, advisory services, and trade execution for a single fee. SFP, as portfolio manager is responsible for the research, security selection, and implementation of transaction orders in the Client's account. The transactions in the Client's account will be executed by and custodied at LPL Financial, LLC (“LPL”). SFP receives a portion of the Wrap Fee for portfolio management services. LPL will receive a portion of the fee for trade execution expenses. Please see the attached Wrap Fee Brochure for additional information on this program. Recommendation of Third Party Investment Advisers As part of our overall portfolio management strategy, we may also recommend third party investment advisers or programs to manage all or a portion of your account. All third party investment advisers recommended by our firm must either be registered as investment advisers or exempt from registration requirements. Factors that we take into consideration when making our recommendations include, but are not limited to, the following: the third party investment adviser’s performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will periodically monitor the third party investment adviser’s performance to ensure its management and investment style remains aligned with your investment goals and objectives. Financial Planning Services We offer various financial planning related services, which assist our Clients in the management of their financial resources. Financial planning services are based upon an analysis of your individual needs and begin with one or more information gathering consultations. Once we collect and analyze all documentation gathered during these consultations, we provide a written financial plan designed to achieve your financial goals and objectives. In this way, SFP assists you in developing a strategy for the successful management of income, assets, and liabilities. In general, financial planning services may include any one or all of the following:
• Cash Flow Analysis – Assessment of your present financial situation by collecting information regarding net worth and cash flow statements, tax returns, insurance policies, investment portfolios, pension plans, employee benefit statements, etc. The firm advises on ways to reduce risk, coordinate, and organize records, and estate information.
• Retirement Analysis – Identification of your long-term financial and personal goals and objectives including advice for accumulating wealth for retirement income or appropriate distribution of assets following retirement. Tax consequences and implications are identified and evaluated.
• Insurance Analysis – Includes risk management associated with advisory recommendations based on a combination of insurance types to meet your needs, e.g., life, health, disability, and long-term care insurance. This will necessitate an analysis of cash needs of family at death, income needs of surviving dependents, and disability income analysis.
• Portfolio Analysis/Investment Planning – We provide investment alternatives, including asset allocation, and effect on your portfolio. We evaluate economic and tax characteristics of existing investments as well as their suitability for your objectives. We identify and evaluate tax consequences and their

implications.
• Education Savings Analysis – Alternatives and strategies with respect to the complete or partial funding of college or other post-secondary education. 6 | P a g e
• Estate Analysis – We provide advice with respect to property ownership, distribution strategies, estate tax reduction, and tax payment techniques. The recommendations and solutions are designed to achieve your desired goals, subject to periodic evaluation of the financial plan, which may require revision to meet changing circumstances. Financial plans are based on your financial situation based on the information provided to the firm. We should be notified promptly of any change to your financial situation, goals, objectives, or needs. You may choose to accept or reject our recommendations. If you decide to proceed with our recommendations, you may do so either through our investment advisory services or by using the advisory, brokerage, or insurance provider of your choice. Retirement Plan Consulting Services SFP provides several defined contribution plan and defined benefit plan consulting services separately or in combination. While the primary Clients for these services will be pension, profit sharing, and 401(k) plans, SFP will also offer these services, where appropriate, to businesses, individuals, trusts, estates, and charitable organizations. When providing any discretionary fiduciary services, SFP will exercise discretionary authority over the plan assets selected by the plan sponsor. With respect to any discretionary fiduciary services provided to a plan covered by Title I of ERISA, Section 402(c)(3) of ERISA allows the plan sponsor to delegate responsibility for selecting, monitoring and replacing plan assets to an "investment manager" that meets the requirements of Section 3(38) of ERISA. SFP is registered as an investment adviser under the Investment Advisers Act of 1940 and has acknowledged its fiduciary status to the plan under ERISA. SFP is, therefore, qualified to serve as an investment manager under Section 3(38) of ERISA. When providing any non-discretionary fiduciary services, SFP will solely be making recommendations to the plan sponsor, and the plan sponsor retains full discretionary authority or control over assets of the plan. SFP provides the following discretionary fiduciary services: Investment Policy Statement (IPS): SFP will review with sponsor the investment objectives, risk tolerance and goals of the plan. If the plan does not have an IPS, SFP will provide recommendations to sponsor to assist with establishing an IPS. If the plan has an existing IPS, SFP will review it for consistency with the plan's objectives. If the IPS does not represent the objectives of the plan, SFP will recommend to the sponsor revisions to align the IPS with the plan's objectives. Management of Trust Fund: Based on the plan's IPS or other investment guidelines established by the plan, SFP will review the investment options available to the plan and select investments for the plan on a discretionary basis. SFP will provide reports, information and recommendations, on a periodic basis, designed to assist sponsor with monitoring SFP in its capacity as an "investment manager" as that term is defined under Sec. 3(38) of ERISA. If the IPS criteria require any investment(s) to be removed, SFP will replace the investment(s) on a discretionary basis. SFP provides the following non-discretionary fiduciary services: Investment Policy Statement (IPS): SFP will review with sponsor the investment objectives, risk tolerance and goals of the plan. If the plan does not have an IPS, SFP will provide recommendations to sponsor to assist with establishing an IPS. If the plan has an existing IPS, SFP will review it for consistency with the plan's objectives. If the IPS does not represent the objectives of the plan, SFP will recommend to the sponsor revisions to align the IPS with the plan's objectives. 7 | P a g e Advice Regarding Designated Investment Alternatives (DIAs): Based on the plan's IPS or other guidelines established by the plan, SFP will review the investment options available to the plan and will make recommendations to assist sponsor with selecting DIAs to be offered to plan participants. Once sponsor selects the DIAs, SFP will, on a periodic basis and/or upon reasonable request, provide reports and information to assist sponsor with monitoring the DIAs. If a DIA is required to be removed, SFP will provide recommendations to assist sponsor with replacing the DIA. Advice Regarding Model Asset Allocation Portfolios (Models): Based on the plan's IPS or other guidelines established by the plan, SFP will make recommendations to assist sponsor with creating risk-based Models comprised solely among the plan's DIAs. Once sponsor approves the Models, SFP will provide reports, information and recommendations, on a periodic basis, designed to assist sponsor with monitoring the Models. Upon reasonable request, and depending upon the capabilities of the record-keeper, SFP will make recommendations to sponsor to reallocate and/or rebalance the Models to maintain their desired allocations. Advice Regarding Qualified Default Investment Alternative (QDIA): Based on the plan's IPS or other guidelines established by the plan, SFP will review the investment options available to the plan and will make recommendations to assist sponsor with selecting or replacing the plan's QDIA(s). SFP provides the following non fiduciary retirement plan consulting services: Administrative Support
• Assist sponsor in reviewing objectives and options available through the plan
• Recommend plan participant education and communication policies under ERISA 404(c)
• Assist with development/maintenance of fiduciary audit file and document retention policies
• Deliver fiduciary training and/or education periodically or upon reasonable request Service Provider Support
• Assist fiduciaries with a process to select, monitor and replace service providers
• Assist fiduciaries with review of Covered Service Providers ("CSP") and fee benchmarking
• Assist with preparation and review of Requests for Proposals and/or Information
• Coordinate and assist with CSP replacement and conversion Investment Monitoring Support
• Periodic review of investment policy in the context of plan objectives
• Assist the plan committee with monitoring investment performance Participant Services
• Facilitate group enrollment meetings and coordinate investment education
• Assist plan participants with financial wellness education, retirement planning and/or gap analysis Our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, SFP may only charge fees for investment advice about products for which our firm and/or our related persons do not receive any commissions or 12b-1 fees, or conversely, investment advice about products for which our firm and/or our related persons receive commissions or 12b-1 fees, however, only when such fees are used to offset SFP's advisory fees. Assets Under Management As of February 20, 2024, we manage approximately $231,927,149 in Client assets on a discretionary basis, and $0 in Client assets on a non-discretionary basis. 8 | P a g e