ADV Part 2A Brochure

Home Office: 401 S 12th St #2 Tampa, FL 33602 4301 Anchor Plaza Pkwy #100 Tampa, FL 33634 (813) 710-5065

Branch Office: 622 E Washington St., Suite 320 FL 32801 (407) 550-5809

Branch Office: 100 South Broad St Suite 1801 Philadelphia, PA 19110 (215) 330-2931

Branch Office: 901 Ponce de Leon Suite 600, Coral Gables, FL 33134 (305) 677-9099

Branch Office: 100 N Laura Street, Suite 802 Jacksonville FL 32202 (904) 371-4435

Branch Office: 3400 Peachtree Road NE, Suite 700 Atlanta, GA 30326 (404) 689-7031

Branch Office: 2125 Southend Dr, Suite 350 Charlotte, NC 28203 (704) 440-4508

www.floridafa.com | Download Copy of ADV Part 2A Brochure

April 25, 2022

This Brochure provides information about the qualifications and business practices of Florida Financial Advisors, Inc (“FFA”, “Adviser”, “us”, “we”, “our”). If you have any questions about the contents of this Brochure, please contact us at (813) 710-5065 or via email at jason.mickool@floridafa.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority.

FFA is a Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information that you may use to determine whether to hire or retain them.

Additional information about the Adviser is also available via the SEC’s website www.adviserinfo.sec.gov.

You can search this site by using a unique identifying number, known as a CRD number. The CRD number for the Adviser is 288811. The SEC’s web site also provides information about any persons affiliated with the Adviser who are registered, or are required to be registered, as Investment Adviser Representatives of the Adviser.

Item 2 – Material Changes

The material changes in this brochure from the last annual updating amendment of Florida Financial Advisors, Inc. on March 29, 2021 are described below. Material changes relate to Florida Financial Advisors, Inc.’s policies, practices or conflicts of interests

• The firm has updated its primary firm address (Cover page).
• The firm has updated branch office addresses and phone number (Cover Page).
• The firm has updated fees and compensation and has added selection of other advisors’ services (Item 4, Item 5, Item 10, Item 14).
• The firm has updated outside business activities (Item 10).
• The firm has updated personal trading and conflicts of interest (Item 11).
• The firm has added Fidelity Brokerage Services LLC as custodian (Item 12).
• The firm has added pension consulting services (Items 4 & 5).
• The firm has updated the frequency that they bill from quarterly to monthly (Item 5)
• The firm has added TD Ameritrade as a custodian (Item 12 & 14).
• The firm has added wrap fee services (Item 4 & 5).
• The firm has added written acknowledgement of fiduciary status language (Item 4).

In the future, this section of the Brochure will discuss only the specific material changes that were made to the Brochure and will provide you with a summary of all material changes that have occurred since the last filing of this Brochure. This section will also identify the date of our last annual Brochure update.

We will ensure that you receive a summary of any material changes to this and subsequent Brochures within 90 days of the close of our business’ fiscal year end which is December 31st. We will provide other ongoing disclosure information about material changes as they occur. We will also provide you with information on how to obtain the complete brochure. Currently, our Brochure may be requested at any time, without charge, by contacting Jason Mickool at (813) 710-5065.

Item 3 – Table of Contents

I ADV Part 2A Brochure ............................................................................................................................................................................................................................................................................................1

Florida Financial Advisors, Inc...................................................................................................................................................................................................................................................................................1

Item 2 – Material Changes.........................................................................................................................................................................................................................................................................................3

Item 3 – Table of Contents.........................................................................................................................................................................................................................................................................................4

Item 4 – Advisory Business Introduction ...............................................................................................................................................................................................................................................................5

Item 5 – Fees and Compensation .............................................................................................................................................................................................................................................................................8

Item 6 – Performance-Based Fee and Side by Side Management ....................................................................................................................................................................................................................12

Item 7 – Types of Client(s) ..........................................................................................................................................................................................................................................................................................12

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ...........................................................................................................................................................................................................13

Item 9 – Disciplinary Information .............................................................................................................................................................................................................................................................................18

Item 10 – Other Financial Industry Activities and Affiliations ...........................................................................................................................................................................................................................18

Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading ....................................................................................................................................................................19

Item 12 – Brokerage Practices ...................................................................................................................................................................................................................................................................................22

Item 13 – Review of Accounts ...................................................................................................................................................................................................................................................................................24

Item 14 – Client Referrals and Other Compensation ...........................................................................................................................................................................................................................................25

Item 15 – Custody ........................................................................................................................................................................................................................................................................................................26

Item 16 – Investment Discretion ...............................................................................................................................................................................................................................................................................26

Item 17 – Voting Client Securities .............................................................................................................................................................................................................................................................................26

Item 18 – Financial Information .................................................................................................................................................................................................................................................................................27

Item 19 – Requirements for State Registered Advisers ........................................................................................................................................................................................................................................27

Item 4 – Advisory Business Introduction

Our Advisory Business

FFA is a Registered Investment Adviser which offers investment advisory and insurance services to clients. We are a registered investment adviser in the State of Florida.

We provide investment advice through Investment Adviser Representatives (“IAR”) associated with us. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on our behalf. In addition, all IARs are required to have an associate’s degree or commensurate business experience.

The Adviser was founded in 2017 by Jason Mickool who serves as Chief Compliance Officer. We provide portfolio management services to individuals, trusts, estates, charitable organizations, corporations and business entities, and state or municipal government entities.

We are committed to the precept that by placing the client’s interests first, we will add value to the asset management process and earn the client’s trust and respect. We value long term relationships with our clients whom we regard as strategic partners in our business.

Services

We can work with you, in a consulting capacity, to create an Investment Policy Statement (IPS) that will serve as the roadmap to guide your wealth management program. Your IPS will incorporate many different aspects of your financial status into an overall plan designed to meet your goals and objectives. We will create a formal IPS and deliver it to you upon completion.

Orion is the sponsor of a wrap fee program, which is an investment program where the client pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. FFA will be the portfolio manager, therefore, this brochure describes FFA’s non-wrap fee advisory services; clients utilizing FFA’s wrap fee portfolio management should see FFA’s separate Wrap Fee Program Brochure. FFA manages the investments in the wrap fee program, but does not manage those wrap fee accounts any differently than it would manage non-wrap fee accounts. FFA receives the advisory fee set forth in Item 5 below as a management fee under the wrap fee program. Please also see Item 5.

Asset Management

FFA manages client investment portfolios on a discretionary or non-discretionary basis. FFA tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. FFA consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify FFA if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if FFA determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts.

FFA primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, options and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. In addition, FFA may also recommend that certain eligible clients invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds).

Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage FFA to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans).

In these situations, FFA directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. FFA tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives.

FFA consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify FFA if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if FFA determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts.

Selection of Other Advisers

FFA may direct clients to third party investment advisers. Before selecting other advisers for clients, FFA will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where FFA is recommending the adviser to clients.

Financial Planning

As part of our investment advisory relationship with our clients we also provide financial planning services. Fee based financial planning is a comprehensive relationship which incorporates many different aspects of your financial status into an overall plan that meets your goals and objectives. The financial planning relationship consists of face-to-face meetings and ad hoc meetings with you and/or your other advisors (attorneys, accountants, etc.) as necessary.

In performing financial planning services, we typically examine and analyze your overall financial situation, which may include issues such as taxes, insurance needs, overall debt, credit, business planning, retirement savings and reviewing your current investment program. Our services may focus on all or only one of these areas depending upon the scope of our engagement with you.

It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant or other professionals.

If you engage us to perform these services, you will receive a written agreement detailing the services, fees, terms and conditions of the relationship. You will also receive this Brochure. You are under no obligation to implement recommendations through us. You may implement your financial plan through any financial organization of your choice.

Pension Consulting Services

FFA offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:

• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker-dealers
• creating a written pension consulting plan

These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants.

Written Acknowledgement of Fiduciary Status

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;
• 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 obtain information from a wide variety of publicly available sources. We do not have any inside private information about any investments that are recommended. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Choosing which advice to follow is your decision.

As of December 31, 2021, we had $61,876,000 in discretionary and $0 in non-discretionary assets under management.

Item 5 – Fees and Compensation

Asset Management

Investment management services are offered through the Program on a fee basis, meaning that clients pay a single annualized fee based upon assets under management. The Firm also offers advisory services outside of the Program under different fee arrangements than those discussed below.

The management fee varies depending upon the size and composition of a client’s portfolio and the type of services rendered and the representative providing services. The maximum fee will be based upon the following blended fee schedule:

PORTFOLIO VALUE	FEE UP TO
First $250,000	2.65%
Next $250,000	2.45%
Next $500,000	1.90%
Next $1,000,000	1.65%
Next $3,000,000	1.65%
Next $5,000,000	1.40%
Above $10,000,000	1.40%

Please Note: Fee Differentials-Conflict of Interest. FFA’s representatives determine the amount of advisory fee to be paid by the client within the parameters of the fee schedule set forth above, which could present a conflict of interest. No client will be charged more than the reflected maximum annual percentage fee. As a result, similarly situated clients could pay diverse advisory. FFA’s advisory services could also be available from other advisers at a lesser annual percentage advisory fee. Each client should take this potential fee differential into consideration when determining whether or not to engage FFA’s services. FFA’s Chief Compliance Officer, Jason Mickool, remains available to address any questions that a client or prospective client may have regarding the above potential for fee differentials and corresponding conflict of interest.

The annual fee is prorated and charged, in advance, based upon the market value of the assets being managed by FFA on the last day of the previous billing period. While the timing of billing is negotiable and variable among clients, generally, all fees will be charged quarterly, in advance. When a copy of the Brochure Document(s) is not provided to the client at least 48 hours prior to signing the contract(s), client has five business days in which to cancel the contract, without penalty.

Under certain engagements, the firm may adjust billing as follows: if assets in excess of $100,000 are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial term of the Program, the fee is calculated on a pro rata basis. In the event the Agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding balance or unearned portion of the fee is charged or refunded to the client, as appropriate.

Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), FFA may negotiate a fee rate that differs from the range set forth above. Clients can obtain a full refund within a year of paying their bill. FFA will always refund the full amount.

Fee Discretion

The fee schedule above is the maximum fee that will be charged. FFA, in its sole discretion, may negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client relationship, account retention and pro bono activities.

Fee Debit

The Firm’s Agreement and the separate agreement with any Financial Institutions generally authorize FFA and/or the Independent Managers to debit its clients’ accounts for the amount of the Program fee and to directly remit that fee to FFA or the Independent Managers. Any Financial Institutions recommended by FFA have agreed to send statements to clients not less than quarterly indicating all amounts disbursed from the account, including the amount of Program fees paid directly to FFA. Alternatively, clients may elect to have FFA send them an invoice for payment. FFA sends an invoice to the custodian at the same time they send an invoice to the client.

Account Additions and Withdrawals

Clients may make additions to and withdrawals from their account at any time, subject to FFA’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to FFA, subject to the usual and customary securities settlement procedures. However, FFA designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. FFA may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications.

Selection of Other Advisers Fees

FFA may direct clients to third-party investment advisers. FFA will be compensated via a fee share from the advisers to which it directs those clients. The fees shared are negotiable and will not exceed any limit imposed by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected.

FFA may specifically direct clients to Morningstar Advisory Services (Morningstar). The annual fee schedule is as follows:

Total Assets	FFA’s Fee	Morningstar’s Fee	Total Fee
$1- $500,000	0.75%	0.55%	1.30%
$500,001 - $1,000,000	0.75%	0.50%	1.25%
$1,000,001 - $2,000,000	0.75%	0.45%	1.20%
$2,000,001 – And Up	0.75%	0.40%	1.15%

 

FFA may specifically direct clients to Brinker Advisory Services (Brinker). The annual fee schedule is as follows:

Total Assets	FFA’s Fee	Brinker’s Fee	Total Fee
All Assets	Up to 2.51%	0.14%	Up to 2.65%

 

The selection of other advisors’ fees are paid monthly in advance.

Fees for selection of Morningstar Advisory Services as third-party adviser are withdrawn by Morningstar Advisory Services directly from client accounts. FFA then receives its portion of the fees from Morningstar Advisory Services; FFA does not directly deduct the advisory fees.

Fees for selection of Brinker Advisory Services as third-party adviser are withdrawn by Brinker Advisory Services directly from client accounts. FFA then receives its portion of the fees from Brinker Advisory Services; FFA does not directly deduct the advisory fees.

Third Party Fees

Our fees do not include brokerage commissions, transaction fees, and other related costs and expenses. You may incur certain charges imposed by custodians, third party investment companies and other third parties. These include fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds, money market funds and exchange-traded funds (ETFs) also charge internal management fees, which are disclosed in the fund’s prospectus. These fees may include, but are not limited to, a management fee, upfront sales charges, and other fund expenses. Certain strategies offered by us may involve investment in mutual funds and/or ETFs. Load and no load mutual funds may pay annual distribution charges, sometimes referred to as “12(b)(1) fees”. These 12(b)(1) fees come from fund assets, and thus indirectly from clients’ assets. We do not receive any compensation from these fees. All of these fees are in addition to the management fee you pay us. You should review all fees charged to fully understand the total amount of fees you will pay. Services similar to those offered by us may be available elsewhere for more or less than the amounts we charge. Our brokerage practices are discussed in more detail under Item 12 – Brokerage Practices.

Financial Planning and Consulting

FFA generally charges a fixed fee or fee based upon the net worth or assets held by the client for providing financial planning and consulting services. These fees are negotiable, but generally range from $200 to $7,500 on a fixed fee basis or up to 2% of net worth or assets being addressed in the plan or under consultation, depending upon the scope and complexity of the services and the professional rendering the financial planning and/or the consulting services. If the client purchases products through Jason Mickool as a registered representative of Trinity Wealth Securities, LLC, the Adviser may, but is not required to, offset all or a portion of its fees for those services based upon the amount paid for the financial planning and/or consulting services.

The terms and conditions of the financial planning and/or consulting engagement are set forth in the Advisory Agreement and the fees are collected in arrears after delivery and satisfaction of the financial plan.

Pension Consulting Services Fees

PORTFOLIO VALUE	FEE UP TO
First $250,000	2.65%
Next $250,000	2.45%
Next $500,000	1.90%
Next $1,000,000	1.65%
Next $3,000,000	1.65%
Next $5,000,000	1.40%
Above $10,000,000	1.40%

 

Payments will be invoiced and payable via cash, check, or wire. The fees will be paid monthly and in advance.

Other Compensation

This brochure describes FFA’s non-wrap fee advisory services; clients utilizing FFA’s wrap fee portfolio management should see the separate Wrap Fee Program Brochure for additional details regarding third party fees. Client accounts not participating in the wrap fee program are responsible for the payment of all third party fees (i.e., custodian fees, commissions, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by Orion.

Certain individuals of FFA will receive additional compensation from sales of securities and/or investment products with regard to their role as registered representatives of Trinity Wealth Securities, LLC or other broker/ dealers.

While FFA endeavors at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving additional compensation creates a conflict of interest, and may affect certain individuals’ judgments when making recommendations. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that Clients may purchase recommended securities from other registered representatives not affiliated with us.

Certain individuals of FFA may also receive additional compensation from sales of insurance products. He may be eligible to receive incentive awards (including prizes such as trips or bonuses) for recommending certain types of insurance policies or other investment products.

While FFA endeavors at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving incentive awards creates a conflict of interest, and may affect their judgment when making recommendations. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that Clients may purchase recommended insurance products from other insurance agents not affiliated with us.

Item 6 – Performance Based Fee and Side by Side Management

We do not charge any performance-based fees. These are fees based on a share of capital gains on or capital appreciation of the assets of a client.

Item 7 – Types of Client(s)

We provide portfolio management services to individuals, trusts, estates, charitable organizations, corporations, business entities, and state or municipal government entities.

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

We use multiple analyses methods and strategies as part of our overall investment management discipline; the implementation of these analyses as part of our investment advisory services to you may include any, all or a combination of the following:

Fundamental Analysis

Fundamental analysis is a technique that attempts to determine a security’s value by focusing on the underlying factors that affect a company's actual business and its future prospects. Fundamental analysis is about using real data to evaluate a security's value. It refers to the analysis of the economic well-being of a financial entity as opposed to only its price movements.

The end goal of performing fundamental analysis is to produce a value that we can compare with the security's current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short).

Modern Portfolio Theory (MPT)

We use Modern Portfolio Theory to help select the funds we use in your account.

Modern portfolio theory tries to understand the market as a whole, rather than looking for what makes each investment opportunity unique. Investments are described statistically, in terms of their expected long-term return rate and their expected short-term volatility. The volatility is equated with "risk," measuring how much worse than average an investment's bad years are likely to be. The end goal is to identify your acceptable level of risk tolerance, and then to find a portfolio with the maximum expected return for that level of risk.

Technical Analysis

Technical Analysis is a technique that attempts to determine a security’s value by developing models and trading rules based upon price and volume transformation. Technical analysis assumes that a market’s price reflects all relevant information so the analysis focuses on the history of a security’s trading behavior rather than external drivers such as economic, fundamental and news events. The practice of technical analysis incorporates the importance of understanding how market participants perceive and act upon relevant information rather than focusing on the information itself. Ultimately, technical analysts develop trading models and rules by evaluating factors such as market trends, market participant behaviors, supply and demand and pricing patterns and correlations.

As with other types of analysis, the predictive nature of technical analysis can vary greatly; models and rules are often modified and updated as new patterns and behaviors develop. Past performance is not an indicator of future return.

Targeted Asset Allocation

Six targeted asset allocation model portfolios covering everything from conservative income to very aggressive growth oriented approaches have been compiled by us. We will assign you a targeted portfolio that meets your goals and time horizon, while addressing the level of risk you are comfortable assuming. The strategic model portfolio allocation remains constant; your specific portfolio model may change infrequently to reflect shifts in your risk tolerance and goals. We screen and select funds and securities to be added to or removed from the model portfolio on a regular basis. Rebalancing can occur after a move in the market of 15% or more within any year but at least once per year based on the annual review of your financial situation.

Cyclical Analysis

While we do not attempt to time the market, we may use cyclical analysis in conjunction with other strategies to help determine if shifts are required in your investment strategies depending upon long and short-term trends in financial markets and the performance of the overall national and global economy.

Investment Strategies

In order to perform this analysis, we use many resources, such as:

• Morningstar
• Financial newspapers and magazines (e.g. Wall Street Journal, Forbes, etc.)
• Annual reports, prospectuses, filings
• Company press releases and websites

The investment strategies we use to implement any investment advice given to you include, but are not limited to:

• Long term purchases - securities held at least a year
• Short term purchases - securities sold within a year
• Trading -securities sold within 30 days
• Short sales
• Margin Transactions
• Option writing, including covered options, uncovered options or spreading strategies.

Risk of Loss

We cannot guarantee our analysis methods will yield a return. In fact, a loss of principal is always a risk. Investing in securities involves a risk of loss that you should be prepared to bear. You need to understand that investment decisions made for your account by us are subject to various market, currency, economic, political and business risks. The investment decisions we make for you will not always be profitable nor can we guarantee any level of performance.

A list of all risks associated with the strategies, products and methodology we offer are listed below:

Alternative Investment Risk

Investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include:

• Loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices
• Lack of liquidity in that there may be no secondary market for the fund and none expected to develop
• Volatility of returns
• Absence of information regarding valuations and pricing
• Delays in tax reporting
• Less regulation and higher fees than mutual funds.

Bond Fund Risk

Bond funds generally have higher risks than money market funds, largely because they typically pursue strategies aimed at producing higher yields of the risks associated with bond funds include:

• Call Risk - The possibility that falling interest rates will cause a bond issuer to redeem—or call—its high-yielding bond before the bond's maturity date.
• Credit Risk - the possibility that companies or other issuers whose bonds are owned by the fund may fail to pay their debts (including the debt owed to holders of their bonds). Credit risk is less of a factor for bond funds that invest in insured bonds or U.S. Treasury bonds. By contrast, those that invest in the bonds of companies with poor credit ratings generally will be subject to higher risk.
• Interest Rate Risk - the risk that the market value of the bonds will go down when interest rates go up. Because of this, you can lose money in any bond fund, including those that invest only in insured bonds or Treasury bonds.
• Prepayment Risk - the chance that a bond will be paid off early. For example, if interest rates fall, a bond issuer may decide to pay off (or "retire") its debt and issue new bonds that pay a lower rate. When this happens, the fund may not be able to reinvest the proceeds in an investment with as high a return or yield.

Fundamental Analysis Risk

Fundamental analysis, when used in isolation, has a number of risks:

• There are an infinite number of factors that can affect the earnings of a company, and its stock price, over time. These can include economic, political and social factors, in addition to the various company statistics.
• The data used may be out of date.
• It is difficult to give appropriate weightings to the factors.
• It assumes that the analyst is competent.
• It ignores the influence of random events such as oil spills, product defects being exposed, and acts of God and so on.

Modern Portfolio Theory (MPT) Risk

Modern Portfolio Theory tries to understand the market as a whole and measure market risk in an attempt to reduce the inherent risks of investing in the market. However, with every financial investment strategy there is a risk of a loss of principal. Not every investment decision will be profitable, and there can be no guarantee of any level of performance.

Cyclical Analysis Risk

Looking at market cycles in conjunction with other investment strategies can be useful when making investment decisions. However, market cycles are not always predictable. Each financial investment strategy has benefits and risks. Not every investment decision will be profitable, and there can be no guarantee of any level of performance.

Exchange Traded Fund (“ETF”) Risk

Most ETFs are passively managed investment companies whose shares are purchased and sold on a securities exchange. An ETF represents a portfolio of securities designed to track a particular market segment or index. ETFs are subject to the following risks that do not apply to conventional funds:

• The market price of the ETF’s shares may trade at a premium or a discount to their net asset value;
• An active trading market for an ETF’s shares may not develop or be maintained; and
• There is no assurance that the requirements of the exchange necessary to maintain the listing of an ETF will continue to be met or remain unchanged

Insurance Product Risk

The rate of return on variable insurance products is not stable, but varies with the stock, bond and money market subaccounts that you choose as investment options. There is no guarantee that you will earn any return on your investment and there is a risk that you will lose money. Before you consider purchasing a variable product, make sure you fully understand all of its terms. Carefully read the prospectus. Some of the major risks include:

• Liquidity and Early Withdrawal Risk – There may be a surrender charges for withdrawals within a specified period, which can be as long as six to eight years. Any withdrawals before a client reaches the age of 59 ½ are generally subject to a 10 percent income tax penalty in addition to any gain being taxed as ordinary income.
• Sales and Surrender Charges – Asset-based sales charges or surrender charges. These charges normally decline and eventually are eliminated the longer you hold your shares. For example, a surrender charge could start at 7 percent in the first year and decline by 1 percent per year until it reaches zero.
• Fees and Expenses – There are a variety of fees and expenses which can reach 2% and more such as:
  • Mortality and expense risk charges
  • Administrative fees
  • Underlying fund expenses
  • Charges for any special features or riders.
• Bonus Credits – Some products offer bonus credits that can add a specified percentage to the amount invested ranging from 1 percent to 5 percent for each premium payment. Bonus credits, however, are usually not free. In order to fund them, insurance companies typically impose high mortality and expense charges and lengthy surrender charge periods.
• Guarantees – Insurance companies provide a number of specific guarantees. For example, they may guarantee a death benefit or an annuity payout option that can provide income for life. These guarantees are only as good as the insurance company that gives them.
• Market Risk – The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall.
• Principal Risk – The possibility that an investment will go down in value, or "lose money," from the original or invested amount.

Mutual Funds Risk

The following is a list of some general risks associated with investing in mutual funds.

• Country Risk - The possibility that political events (a war, national elections), financial problems (rising inflation, government default), or natural disasters (an earthquake, a poor harvest) will weaken a country's economy and cause investments in that country to decline.
• Currency Risk - The possibility that returns could be reduced for Americans investing in foreign securities because of a rise in the value of the U.S. dollar against foreign currencies. Also called exchange-rate risk.
• Income Risk - The possibility that a fixed-income fund's dividends will decline as a result of falling overall interest rates.
• Industry Risk - The possibility that a group of stocks in a single industry will decline in price due to developments in that industry.
• Inflation Risk - The possibility that increases in the cost of living will reduce or eliminate a fund's real inflation-adjusted returns.
• Manager Risk - The possibility that an actively managed mutual fund's investment adviser will fail to execute the fund's investment strategy effectively resulting in the failure of stated objectives.
• Market Risk - The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall.
• Principal Risk - The possibility that an investment will go down in value, or "lose money," from the original or invested amount.

Stock Fund Risk

Overall "market risk" poses the greatest potential danger for investors in stocks funds. Stock prices can fluctuate for a broad range of reasons, such as the overall strength of the economy or demand for particular products or services.

Technical Analysis risk

• Technical analysis is derived from the study of market participant behavior and its efficacy is a matter of controversy.
• Methods vary greatly and can be highly subjective; different technical analysts can sometimes make contradictory predictions from the same data.
• Models and rules can incur sufficiently high transaction costs.

Overall Risks

Clients need to remember that past performance is no guarantee of future results. All funds carry some level of risk. You may lose some or all of the money you invest, including your principal, because the securities held by a fund goes up and down in value. Dividend or interest payments may also fluctuate, or stop completely, as market conditions change.

Before you invest, be sure to read a fund's prospectus and shareholder reports to learn about its investment strategy and the potential risks. Funds with higher rates of return may take risks that are beyond your comfort level and are inconsistent with your financial goals.

While past performance does not necessarily predict future returns, it can tell you how volatile (or stable) a fund has been over a period of time. Generally, the more volatile a fund, the higher the investment risk. If you'll need your money to meet a financial goal in the near-term, you probably can't afford the risk of investing in a fund with a volatile history because you will not have enough time to ride out any declines in the stock market.

Item 9 – Disciplinary Information

Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. We do not have any information to disclose concerning the Adviser or any of our IARs. We adhere to high ethical standards for all IARs and associates.

Item 10 – Other Financial Industry Activities and Affiliations

Certain individuals of FFA are registered representatives of Trinity Wealth Securities, LLC or other broker/dealers.

Neither FFA nor its representatives are registered as or have pending applications to become either a Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities.

Other Financial Industry Affiliations

The IARs of the Adviser have the following outside business activities and/or affiliations to disclose.

Jason Mickool, the President and Chief Compliance Officer for FFA, is also an owner of Trinity Wealth Securities, LLC, a broker/dealer. Therefore, FFA and Trinity Wealth Securities, LLC are under common ownership. From time to time, Jason Mickool will recommend securities products that will pay them a commission through their broker-dealer relationship. This conflict of interest is mitigated as Jason Mickool is supervised by another principal to ensure that all recommendations are always in the best interest of the client.

As stated earlier, certain individuals of FFA are registered representatives of Trinity Wealth Securities, LLC or other broker/dealers. From time to time, they will recommend securities products that will pay them a commission through their broker-dealer relationship.

When such recommendations or sales are made, a conflict of interest exists as the registered representatives may receive more commissions from the sale of these products than from providing you with advisory services. We require that all IARs disclose this conflict of interest when such recommendations are made. We also require IARs to disclose to clients that they may purchase recommended products from other representatives not affiliated with us. Our Code of Ethics requires our IARs do what is in the client’s best interests at all times. Our CCO monitors all transactions to ensure that representatives put their clients first, not the commission they may receive. The broker-dealer also monitors all transaction to make certain they are suitable for the client.

Jason Mickool, the President and Chief Compliance Officer for the Adviser, is a licensed insurance agent/broker with various companies. The sale of these products accounts for approximately 40% of his time.

Certain individuals of FFA may recommend insurance products and may also, as an independent insurance agent, sell those recommended insurance products to clients. When such recommendations or sales are made, a conflict of interest exists as the insurance licensed IAR earns insurance commissions for the sale of those products, which may create an incentive to recommend such products. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that clients may purchase recommended insurance products from other insurance agents not affiliated with us.

FFA may direct clients to third-party investment advisers. FFA will be compensated via a fee share from the advisers to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. This creates a conflict of interest in that FFA has an incentive to direct clients to the third-party investment advisers that provide FFA with a larger fee split. FFA will always act in the best interests of the client, including when determining which third party investment adviser to recommend to clients. FFA will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where FFA is recommending the adviser to clients.

The Supervised Person, in addition to providing investment advisory and/or financial planning services, is also registered as a broker/dealer agent of Trinity Wealth Securities, LLC, offering various securities products to clients. The Supervised Person may receive commissions from the sale of various securities products. In the case of mutual funds, the Supervised Person may also receive trails, in the form of 12b-1 fees, for existing mutual fund positions. For Portfolio Management Program(s) selected for or by the Client, Stephen P Schmitt may be entitled to a portion of commissions as an agent of the firm’s affiliated broker/dealer, Trinity Wealth Securities, LLC, if the Client is responsible for the commission charges. The receipt of commissions presents a conflict of interest as the Supervised Person has an incentive to recommend products based on compensation. The firm has adopted policies and practices designed to review transactions for compensation received and their overall appropriateness for the Client.

The Supervised Person, as an insurance agent, may recommend and conduct insurance transactions. The Supervised Person receives commissions for insurance transactions. The receipt of commissions presents a conflict of interest as the Supervised Person has an incentive to recommend products based on compensation. The firm has adopted policies and practices requiring activity be consistent with standards of commercial honor and principles of trade and that such activity must be consistent with the Client’s needs.

Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading

General Information

We have adopted a Code of Ethics for all supervised persons of the firm describing its high standards of business conduct, and fiduciary duty to you, our client. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts, the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All of our supervised persons must acknowledge the terms of the Code of Ethics annually, or as amended.

Participation or Interest in Client Accounts

Our Compliance policies and procedures prohibit anyone associated with the Adviser from having an interest in a client account or participating in the profits of a client’s account without the approval of the CCO.

The following acts are prohibited:

• Employing any device, scheme or artifice to defraud
• Making any untrue statement of a material fact
• Omitting to state a material fact necessary in order to make a statement, in light of the circumstances under which it is made, not misleading
• Engaging in any fraudulent or deceitful act, practice or course of business
• Engaging in any manipulative practices

Clients and prospective clients may request a copy of the firm's Code of Ethics by contacting the CCO.

Personal Trading

IAR's of FFA may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of FFA to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. It is our process to only trade in the same securities we have recommended to you after we have placed your order. Such transactions may create a conflict of interest. FFA will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold.

Certain affiliated accounts may trade in the same securities with your accounts on an aggregated basis when consistent with our obligation of best execution. When trades are aggregated, all parties will share the costs in proportion to their investment. We will retain records of the trade Order (specifying each participating account) and its allocation. Completed Orders will be allocated as specified in the initial trade order. Partially filled Orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order.

The Adviser has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of “Access Persons”. The policy requires that an Access Person of the firm provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide the Chief Compliance Officer or his/her designee with a written report of the Access Person’s current securities holdings at least once each twelve (12) month period thereafter on a date the Adviser selects; provided, however that at any time that the Adviser has only one Access Person, he or she shall not be required to submit any securities report described above.

We have established the following restrictions in order to ensure our fiduciary responsibilities regarding insider trading are met:

• No securities for our personal portfolio(s) shall be bought or sold where this decision is substantially derived, in whole or in part, from the role of IARs of the Adviser, unless the information is also available to the investing public on reasonable inquiry. In no case, shall we put our own interests ahead of yours.

Privacy Statement

We are committed to safeguarding your confidential information and hold all personal information provided to us in the strictest confidence. These records include all personal information that we collect from you or receive from other firms in connection with any of the financial services they provide. We also require other firms with whom we deal with to restrict the use of your information. Our Privacy Policy is available upon request.

Conflicts of Interest

IAR's of FFA may employ the same strategy for their personal investment accounts as it does for its clients. This may provide an opportunity for representatives of FFA to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. It is our process that our IARs may not place their orders in a way to benefit from the purchase or sale of a security.

We act in a fiduciary capacity. If a conflict of interest arises between us and you, we shall make every effort to resolve the conflict in your favor. Conflicts of interest may also arise in the allocation of investment opportunities among the accounts that we advise. We will seek to allocate investment opportunities according to what we believe is appropriate for each account. We strive to do what is equitable and in the best interests of all the accounts we advise.

Item 12 – Brokerage Practices

Factors Used to Select Custodians

In recommending a custodian/broker-dealer, we look for a company that offers relatively low transaction fees, access to desired securities, trading platforms, and support services. We may recommend clients use Charles Schwab as the qualified custodian for their accounts when utilizing our asset management services.

FFA recommends Fidelity Brokerage Services LLC (CRD# 7784) and TD Ameritrade Institutional, a division of TD Ameritrade, Inc. Member FINRA/SIPC.

Soft Dollars

Charles Schwab and other third party managers may provide us with certain brokerage and research products and services that qualify as "brokerage or research services" under the rules. These research products and/or services will assist the IAR in its investment decision making process. Such research generally will be used to service all of the IAR’s clients, but brokerage commissions paid by the client may be used to pay for research that is not used in managing the client’s account. The account may pay to a broker-dealer a commission greater than another qualified broker-dealer might charge to effect the same transaction where the IAR determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received.

Because soft dollar benefits could be considered to provide a benefit to the adviser that might cause the client to pay more than the lowest available commission without receiving the most benefit, they are considered a conflict of interest in recommending or directing custodial and third party managerial services. FFA mitigates these conflicts of interest through strong oversight of soft-dollar arrangements by the Chief Compliance Officer, in order to assure the soft dollar benefits serve the best interests of the client.

There may other benefits from recommending Charles Schwab or other third party managers such as software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions, recordkeeping and client reporting.

Other services may include, but are not limited to, performance reporting, financial planning, contact management systems, third party research, publications, access to educational conferences, roundtables and webinars, practice management resources, access to consultants and other third party service providers who provide a wide array of business related services and technology with whom FFA may contract directly. FFA may receive seminar expense reimbursements from product sponsors which may be based on the sales of products to their clients.

Soft dollar benefits may be proportionally allocated to any accounts that may generate different amounts of the soft dollar benefits.

FFA may recommend that clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to custody assets with Schwab is at the discretion of the Advisor’s clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. FFA is independently owned and operated and not affiliated with Schwab. Schwab provides FFA with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisor’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment.

For FFA client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts.

Schwab also makes available to FFA other products and services that benefit FFA but may not benefit its clients’ accounts. These benefits may include national, regional or FFA specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of FFA by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist FFA in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of FFA’s fees from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of FFA accounts, including accounts not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to FFA other services intended to help FFA manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to FFA by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to FFA. While, as a fiduciary, FFA endeavors to act in its clients’ best interests, FFA recommendation/requirement that clients maintain their assets in accounts at Schwab may be based in part on the benefit to FFA of the availability of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest.

Best Execution

We have an obligation to seek best execution for you. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, reputation and responsiveness. Therefore, we will seek competitive commission rates, but we may not obtain the lowest possible commission rates for account transactions.

Brokerage for Client Referrals

In selecting and/or recommending broker-dealers, we do not take into consideration whether or not we will receive client referrals from the broker-dealer or third party.

Directed Brokerage

In the event that the client requests that FFA recommend a broker-dealer/custodian for execution and/or custodial services (exclusive of those clients that may direct FFA to use a specific broker dealer/custodian), FFA generally recommends that investment management accounts be maintained at Schwab. Prior to engaging FFA to provide investment management services, the client will be required to enter into a formal Investment Advisory Agreement with FFA setting forth the terms and conditions under which FFA shall manage the client's assets, and a separate custodial/clearing agreement with each designated broker-dealer/custodian.

Trading

Transactions for each client account generally will be effected independently, unless we decide to purchase or sell the same securities for several clients at approximately the same time. We may (but are not obligated to) combine or “batch” such Orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among our clients’ differences in prices and commission or other transaction costs. Under this procedure, transactions will be price-averaged and allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day.

Item 13 – Review of Accounts

Reviews

Reviews are conducted at least annually or as agreed to by us. Reviews will be conducted by Jason Mickool. You may request more frequent reviews and may set thresholds for triggering events that would cause a review to take place. Generally, we will monitor for changes and shifts in the economy, changes to the management and structure of a mutual fund or company in which client assets are invested, and market shifts and corrections.

Reports

We do not provide any other statements except the one provided by your custodian, along with an invoice copy.

Item 14 – Client Referrals and Other Compensation

FFA receives compensation from third-party advisers to which it directs clients.

FFA receives economic benefit from Schwab in the form of the support products and services made available to our firm and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit out firm, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of Schwab’s products and services is not based on our firm giving particular investment advice, such as buying particular securities for our clients.

FFA participates in the institutional advisor program (the “Program”) offered by TD Ameritrade. TD Ameritrade offers to independent investment advisor services which include custody of securities, trade execution, clearance and settlement of transactions. FFA receives some benefits from TD Ameritrade through its participation in the Program.

As part of the Program, FFA may recommend TD Ameritrade to clients for custody and brokerage services. There is no direct link between FFA ’s participation in the Program and the investment advice it gives to its clients, although FFA receives economic benefits through its participation in the Program that are typically not available to TD Ameritrade retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving FFA participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have FFA’s fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to FFA by third party vendors. TD Ameritrade may also pay for business consulting and professional services received by FFA’s related persons. Some of the products and services made available by TD Ameritrade through the Program may benefit FFA but may not benefit its client accounts. These products or services may assist FFA in managing and administering client accounts, including accounts not maintained at TD Ameritrade. Other services made available by TD Ameritrade are intended to help FFA manage and further develop its business enterprise. The benefits received by FFA or its personnel through participation in the Program do not depend on the amount of brokerage transactions directed to TD Ameritrade. As part of its fiduciary duties to clients, FFA endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by FFA or its related persons in and of itself creates a conflict of interest and may indirectly influence FFA ’s choice of TD Ameritrade for custody and brokerage services.

Item 15 – Custody

We do not have physical custody of any accounts or assets. However, we may be deemed to have custody of your account(s) if we have the ability to deduct your advisory fees from the custodian. You should receive at least quarterly statements from the broker-dealer or custodian that holds and maintains your investment assets. We urge you to carefully review such statements.

Item 16 – Investment Discretion

We usually receive discretionary authority from you at the beginning of an advisory relationship to select the identity and amount of securities to be bought or sold. This information is described in the Advisory Agreement you sign with us. In all cases, however, this discretion is exercised in a manner consistent with your stated investment objectives for your account.

When we manage assets on a discretionary basis, you have given us the authority to determine the following with/without your consent:

• Securities to be bought or sold for your account
• Amount of securities to be bought or sold for your account
• Broker-dealer to be used for a purchase or sale of securities for your account
• Commission rates to be paid to a broker or dealer for your securities transaction.

If you have not given us the authority to manage your account on a discretionary basis, then we cannot trade in your account without your express permission.

When selecting securities and determining amounts, we observe the investment policies, limitations and restrictions you have set. For registered investment companies, our authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made.

Prior to assuming discretionary authority, clients must execute the Advisory Agreement. Execution of the Advisory Agreement grants us the authority to determine, without obtaining specific client consent, both the amount and the type of securities to be bought and sold to help achieve the client account objectives.

Item 17 – Voting Client Securities

Due to the nature of the services provided, we do not have any authority to and do not vote proxies on behalf of advisory clients. You retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolios. We may provide advice to you regarding your voting of proxies.

The custodian will forward you copies of all proxies and shareholder communications relating to your account assets.

Item 18 – Financial Information

We are required to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that would impair our ability to meet any contractual and fiduciary commitments to you, our client. We have not been the subject of any bankruptcy proceedings. In no event shall we charge advisory fees that are both in excess of five hundred dollars and more than six months in advance of advisory services rendered.

Item 19 – Requirements for State Registered Advisers

Principals

There is one principal of the Adviser, Jason Mickool. He is the Chief Compliance Officer and was born in 1969. His education information, business background, and other business activities can be found in the Form ADV Part 2B Brochure Supplement below.

Performance Fees

We do not charge a performance-based fee (fees based on a share of capital gains on, or capital appreciation of, the assets of a client) for our normal asset management accounts.

Disclosable Events

Neither the Adviser nor Jason Mickool has any reportable events to disclose here.

Other Relationships

Neither the Adviser nor Jason Mickool has any relationship with any issuer of securities.

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ADV Part 2B Brochure Supplement – Jason Kurt Mickool

Item 1 – Cover Page

Jason Mickool
CRD # 2606335

FFA
401 S 12th St #2 Tampa, FL 33602
4301 Anchor Plaza Pkwy #100 Tampa, FL 33634

Florida Financial Advisors, Inc.

Home Office: 401 S 12th St #2 Tampa, FL 33602 4301 Anchor Plaza Pkwy #100 Tampa, FL 33634 (813) 710-5065

Branch Office: 622 E Washington St., Suite 320 FL 32801 (407) 550-5809

Branch Office: 100 South Broad St Suite 1801 Philadelphia, PA 19110 (215) 330-2931

Branch Office: 901 Ponce de Leon Suite 600, Coral Gables, FL 33134 (305) 677-9099

Branch Office: 100 N Laura Street, Suite 802, Jacksonville FL 32202 (904) 371-4435

Branch Office: 3400 Peachtree Road NE, Suite 700 Atlanta, GA 30326 (404) 689-7031

Branch Office: 2125 Southend Dr, Suite 350 Charlotte, NC 28203 (704) 440-4508

www.floridafa.com

March 12, 2021

This Brochure supplement provides information about Jason Mickool and supplements the FFA (“Adviser”) Brochure. You should have received a copy of that Brochure. Please contact Mr. Mickool if you did not receive the Brochure or if you have any questions about the contents of this supplement.

Additional information about Jason Mickool, CRD# 2606335 is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Full Legal Name: Jason Kurt Mickool Year of Birth: 1969

Education

Bristol Community College, Fall River, MA

Business History

May 2017 – Present	CCO at FFA
April 2019 – Present	Registered Representative at Trinity Wealth Securities, LLC
March 2018 – April 2019	Registered Representative at IFS Securities
Oct 2014 – March 2018	Registered Representative at Purshe Kaplan Sterling Investments
Jul 2013 – Sep 2014	Investment Adviser Representative at Voya Financial Advisors, Inc.
May 2012 – Apr 2017	Group Vice President at Mickool Financially Advanced

Item 3 – Disciplinary History

Neither FFA nor Jason Mickool has any disciplinary history to disclose. Additional information regarding this can be found on www.adviserinfo.sec.gov

Item 4 – Other Business Activities

As stated in Item 10 above, Jason Mickool is a registered representative of Trinity Wealth Securities, LLC. On occasion, he will recommend securities products that will pay them a commission through their broker-dealer relationship. When such recommendations or sales are made, a conflict of interest exists as the registered representatives may receive more commissions from the sale of these products than from providing you with advisory services. Mr. Mickool spends approximately 80 hours per month in this role. We require that all IARs disclose this conflict of interest when such recommendations are made. We also require IARs to disclose to clients that they may purchase recommended products from other representatives not affiliated with us. Our Code of Ethics requires our IARs do what is in the client’s best interests at all times. Our CCO monitors all transactions to ensure that representatives put their clients first, not the commission they may receive. The broker-dealer also monitors all transaction to make certain they are suitable for the client.

Mr. Mickool may recommend insurance products and may also, as an independent insurance agent sell those recommended insurance products to clients. When such recommendations or sales are made, a conflict of interest exists as the insurance licensed IAR earns insurance commissions for the sale of those products, which may create an incentive to recommend such products. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that clients may purchase recommended insurance products from other insurance agents not affiliated with us.

Item 5 – Additional Compensation

Jason Mickool may receive additional compensation from sales of insurance and securities products in his role as a registered representative with Trinity Wealth Securities, LLC and as a licensed insurance agent with various carriers.

While Mr. Mickool endeavors at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving additional compensation creates a conflict of interest, and may affect Mr. Mickool’s judgment when making recommendations. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that clients may purchase recommended securities from other registered representatives not affiliated with us.

Item 6 – Supervision

Jason Mickool is the Chief Compliance Officer and performs all supervisory duties for his firm.

Item 7 – Requirements for State-Registered Advisers

Jason Mickool has no reportable events to disclose here.