Overview

Assets Under Management: $108 million
Headquarters: MCLEAN, VA
High-Net-Worth Clients: 8
Average Client Assets: $13 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Educational Seminars

Fee Structure

Primary Fee Schedule (FORM ADV PART 2A 2B)

MinMaxMarginal Fee Rate
$0 $500,000 1.00%
$500,001 $1,000,000 0.90%
$1,000,001 $2,000,000 0.80%
$2,000,001 and above 0.70%

Minimum Annual Fee: $9,600

Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $9,600 0.96%
$5 million $38,500 0.77%
$10 million $73,500 0.74%
$50 million $353,500 0.71%
$100 million $703,500 0.70%

Additional Fee Schedule (FORM ADV PART 2A 2B)

MinMaxMarginal Fee Rate
$0 $500,000 1.00%
$500,001 $1,000,000 0.90%
$1,000,001 $2,000,000 0.80%
$2,000,001 $5,000,000 0.70%
$5,000,001 $10,000,000 0.65%
$10,000,001 $20,000,000 0.60%
$20,000,001 $50,000,000 0.55%
$50,000,001 and above 0.50%

Minimum Annual Fee: $10,800

Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,800 1.08%
$5 million $38,500 0.77%
$10 million $71,000 0.71%
$50 million $296,000 0.59%
$100 million $546,000 0.55%

Clients

Number of High-Net-Worth Clients: 8
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 99.55
Average High-Net-Worth Client Assets: $13 million
Total Client Accounts: 73
Discretionary Accounts: 26
Non-Discretionary Accounts: 47

Regulatory Filings

CRD Number: 325930
Last Filing Date: 2024-04-07 00:00:00
Website: https://www.actsfinancialadvisors.com

Form ADV Documents

Primary Brochure: FORM ADV PART 2A 2B (2025-03-17)

View Document Text
Item 1: Cover Page Acts Financial Advisors, LLC 1390 Chain Bridge Rd #10147 McLean, VA 22101 Form ADV Part 2A – Firm Brochure (571) 749-5522 Last revised on March 17, 2025 This Brochure provides information about the qualifications and business practices of Acts Financial Advisors, LLC, “AFA”. If you have any questions about the contents of this Brochure, please contact us at (571) 749-5522. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Acts Financial Advisors, LLC is registered as an Investment Adviser with the SEC. Registration of an Investment Adviser does not imply any level of skill or training. Additional information about AFA is available on the SEC’s website at www.adviserinfo.sec.gov, which can be found using the firm’s identification number, 325930. Item 2: Material Changes Acts Financial Advisors, LLC has the following material changes to report. Material changes relate to Acts Financial Advisors, LLC’s policies, practices or conflicts of interests. The firm updated Item 5 to update fee structures for its service offerings. From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations, and routine annual updates as required by the securities regulators. Either this complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of Acts Financial Advisors, LLC. At any time, you may view the current Disclosure Brochure online at the SEC's Investment Adviser Public Disclosure website at http://www.adviserinfo.sec.gov by searching for our firm name or by our CRD number 325930. You may also request a copy of this Disclosure Brochure at any time, by contacting us at (571) 749-5522. 2 Item 3: Table of Contents Contents Item 1: Cover Page 1 Item 2: Material Changes 2 Item 3: Table of Contents 3 Item 4: Advisory Business 4 Item 5: Fees and Compensation 7 Item 6: Performance-Based Fees and Side-By-Side Management 10 Item 7: Types of Clients 10 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 11 Item 9: Disciplinary Information 14 Item 10: Other Financial Industry Activities and Affiliations 14 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 15 Item 12: Brokerage Practices 16 Item 13: Review of Accounts 17 Item 14: Client Referrals and Other Compensation 17 Item 15: Custody 17 Item 16: Investment Discretion 18 Item 17: Voting Client Securities 18 Item 18: Financial Information 18 Form ADV Part 2B – Brochure Supplement 19 Form ADV Part 2B – Brochure Supplement 22 3 Item 4: Advisory Business Description of Advisory Firm Acts Financial Advisors, LLC became registered as an Investment Advisor with the State of Virginia and with the SEC in 2023. Stephen Chang and Mark Eid are the principal owners of AFA. As of December 31 2024, AFA has $79,169,643 discretionary assets under management and $35,673,191 non-discretionary assets under management. Types of Advisory Services One-Time Financial Planning Services We provide financial planning services on topics such as retirement planning, risk management, cash flow, debt management, work benefits, and estate planning. Financial planning involves an evaluation of a Client's current and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they affect and are affected by the entire financial and life situation of the Client. Clients purchasing this service will receive a written or an electronic report, providing the Client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. The adviser will meet with the Client to review the financial plan and outline the corresponding action plan. In general, the financial plan will address any or all of the following areas of concern. The Client and advisor will work together to select specific areas to cover. These areas may include some or all of, but are not limited to, the following: ● Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. ● Financial Goals: We will help Clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. ● Employee Benefits Optimization: We will provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals. ● Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which 4 type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with the consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. ● Investment Analysis: This may involve developing an asset allocation strategy to meet Clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. ● Retirement Planning: Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. ● Insurance Needs Analysis & Risk Management: Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile. A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long‐ term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (retention of risk, sometimes called “self‐insuring”). ● Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts, as well as a review of your asset protection strategies. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request. ● Education Planning: We review Clients' education goals and existing savings vehicles. We also help to identify sources of education funding and assist with evaluating and establishing optimal methods of saving for future education costs based on Clients' preferences. 5 Ongoing Financial Planning Services We provide financial planning services on an ongoing basis. Clients purchasing this service will receive a written or an electronic report during the first year of services, providing the Client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. The adviser will meet with the Client to review the financial plan and outline the corresponding action plan. There will be a full review of this plan every 6-12 months to ensure its accuracy and ongoing appropriateness. In addition to including the services provided in One-Time Financial Planning as described above, we also provide the following: • Investment Management (AFA manages accounts): We manage individually tailored investment portfolios. Our firm provides continuous advice to a Client regarding the investment of Client funds based on the individual needs of the Client. Through personal discussions in which goals and objectives based on a Client's particular circumstances are established, we develop a Client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation targets. We will also review and discuss a Client’s prior investment history, as well as family composition and background. Account supervision is guided by the stated objectives of the Client (e.g., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Fees pertaining to this service are outlined in Item 5 of this brochure. Business Planning & Consulting Services We provide consulting services for Clients who are considering starting a business, currently operate their own business, or are planning for an exit by sale or succession from their current business. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. Real Estate Analysis Services We provide real estate analysis services for Clients who currently own property, are considering purchasing a new property, or are planning to sell their current property. Depending on the property, investment analysis could encompass consultation about the development and management needs of real estate across classes and markets. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. Pension Consulting Services We offer consulting services to pension or other employee benefit plans (including but not limited to 401(k), 403b, 457 plans, and Defined Benefit Plans). Pension consulting may include, but is not limited to: • identifying investment objectives and restrictions • providing guidance on various assets classes and investment options 6 • monitoring performance of 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. Educational Seminars/Workshops We provide periodic educational seminars and workshops to the general public. Seminars are typically 1-2 hours in length. The seminars are meant to be informational in nature and would cover various aspects of personal finance, including but not limited to investing, tax optimization, retirement planning, and risk management/insurance needs. Client Tailored Services and Client Imposed Restrictions We offer the same suite of services to all of our Clients. However, specific Client financial plans and their implementation are dependent upon the Client Investment Policy Statement which outlines each Client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a Client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Wrap Fee Programs We do not participate in wrap fee programs. Item 5: Fees and Compensation Please note, unless a Client has received the firm’s Disclosure Brochure at least 48 hours prior to signing the investment advisory contract, the investment advisory contract may be terminated by the Client within five (5) business days of signing the contract without incurring any advisory fees. How we are paid depends on the type of advisory service we are performing. Please review the fee and compensation information below. One-Time Financial Planning Fees One-Time Financial Planning engagements can be offered at an hourly rate of $400 per hour. The total fee, which may be negotiable in certain cases, will be estimated and outlined in the client contract. A retainer commensurate with the scope of the engagement will be collected at the beginning. Thereafter, monthly bills will be provided, with the final balance due at completion. One-Time Financial Planning engagements can also be offered on a project/fixed fee basis. The total fee, which may be negotiable in certain cases, will be estimated and outlined in the client contract and based on scope and complexity. For project-based billing, half of the fee will be due at the beginning of the engagement and the remaining amount will be due at the completion of the engagement. Fees for this service may be paid by check or electronic funds transfer. This work will commence immediately after the fee is paid and will be completed within 60 days of the date the Client provides his or her full financial information OR within the first 175 days of the date the fee is paid, whichever is earlier. Therefore, the upfront 7 portion of the fee will not be paid more than 6 months in advance. In the event of early termination by the Client, any fees for work already performed will be due or, if applicable, any prepaid fees will be returned to the Client. Ongoing Financial Planning Fees Our standard annual advisory fee is based on the market value of the assets under management (which includes assets held at our recommended custodian, assets held away, and assets under advisement) and is calculated as follows: Account Value Annual Advisory Fee $0 - $500,000 1.0% $500,001 - $1,000,000 0.9% $1,000,001 - $2,000,000 0.8% $2,000,001 and above 0.7% New Ongoing Financial Planning clients are required to pay one-quarter of the minimum annual advisory fee upfront for the first year only. The financial plan, which is included with these services, will be provided within 60 days of the date the Client provides his or her full financial information OR within the first 175 days of the date the fee is paid, whichever is earlier. The annual advisory fees are negotiable, based on certain factors, e.g., personal relationships, net worth, income. Annual advisory fees are pro-rated and paid in arrears on a monthly basis. The annual advisory fee is a tiered fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the above chart and applying the fee to the account value as of the last day of the previous month. (In the event that the account value cannot be ascertained as of the last day of the previous month, the value from the last day of the previous quarter will be used instead.) The annual advisory fee is subject to a $9,600 minimum (and an $800 monthly minimum) per client, which is inclusive of comprehensive financial planning and investment management fees. Annual advisory fees will not exceed more than 1.00% of the client’s total AUM as a result. No increase in the annual advisory fee shall be effective without agreement from the Client by signing a new agreement or amendment to their current advisory agreement. We calculate period-end account values after all dividends settle in the account. Therefore, the account value used to calculate advisory fees may differ from that of the custodial account statement. Our billing invoice will indicate the total account value used to calculate the advisory fee. Advisory fees are directly debited from Client accounts when possible. Accounts initiated or terminated during a month will be charged a pro-rated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice at least 15 calendar days in advance. Since fees are paid in arrears, no refund will be needed upon termination of the account. Note: Our annual minimum fee of $9,600 (and monthly minimum fee of $800) may not be suitable for all clients, and in certain cases, could result in what may appear to be unreasonable and excessive charges. In such scenarios, we reserve the right to invoke our fiduciary duty, decline the engagement, and counsel those for whom we are not a good fit that they should seek a lower cost alternative. 8 Business Planning & Consulting Services Business Planning & Consulting engagements can be offered at an hourly rate of $400 per hour. The total fee, which may be negotiable in certain cases, will be estimated and outlined in the client contract. A retainer commensurate with the scope of the engagement will be collected at the beginning. Thereafter, monthly bills will be provided, with the final balance due at completion. Business Planning & Consulting engagements can also be offered on a project/fixed fee basis. The total fee, which may be negotiable in certain cases, will be estimated and outlined in the client contract and based on scope and complexity. For project-based billing, half of the fee will be due at the beginning of the engagement and the remaining amount will be due at the completion of the engagement. AFA will not bill an amount greater than $1,200.00 six months or more in advance. Fees for this service may be paid by check or electronic funds transfer. This work will commence immediately after the fee is paid and will be completed within 60-90 days of the date the Client provides his or her full financial information OR within the first 175 days of the date the fee is paid, whichever is earlier. Therefore, the upfront portion of the fee will not be paid more than 6 months in advance. In the event of early termination by the Client, any fees for work already performed will be due or, if applicable, any prepaid fees will be returned to the Client. Real Estate Analysis Services Real Estate Analysis engagements can be offered at an hourly rate of $400 per hour. The total fee, which may be negotiable in certain cases, will be estimated and outlined in the client contract. A retainer commensurate with the scope of the engagement will be collected at the beginning. Thereafter, monthly bills will be provided, with the final balance due at completion. Real Estate Analysis engagements can also be offered on a project/fixed fee basis. The total fee, which may be negotiable in certain cases, will be estimated and outlined in the client contract and based on scope and complexity. For project-based billing, half of the fee will be due at the beginning of the engagement and the remaining amount will be due at the completion of the engagement. AFA will not bill an amount greater than $1,200.00 six months or more in advance. Fees for this service may be paid by check or electronic funds transfer. This work will commence immediately after the fee is paid and will be completed within 60-90 days of the date the Client provides his or her full financial information OR within the first 175 days of the date the fee is paid, whichever is earlier. Therefore, the upfront portion of the fee will not be paid more than 6 months in advance. In the event of early termination by the Client, any fees for work already performed will be due or, if applicable, any prepaid fees will be returned to the Client. Pension Consulting Services AFA will be compensated for Employee Benefit Plan services according to the value of plan assets not to exceed 0.75% of total plan assets. This does not include fees to other parties, such as Recordkeepers, Custodians, or Third Party-Administrators. Fees for this service may be negotiable in certain cases and are typically deducted directly from the plan assets by the Custodian on a quarterly basis in arrears. Pension Consulting Services may be terminated with written notice at least 15 calendar days in advance. Since fees are paid in arrears, no refund will be needed upon termination of the account. 9 Educational Seminar/Workshop Fees Educational seminars and workshops are offered free of charge. Other Types of Fees and Expenses Fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as 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 fund and exchange- traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees, and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for Client’s transactions and determining the reasonableness of their compensation (e.g., commissions). Stephen Chang and Mark Eid are licensed to accept compensation for the sale of investment products to AFA clients. This may present a conflict of interest and can give the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of securities or investment products for which the supervised persons receives compensation, AFA will document the conflict of interest in the client file and inform the client of the conflict of interest. Clients always have the right to decide whether to purchase AFA-recommended products and, if purchasing, have the right to purchase those products through other brokers or agents that are not affiliated with AFA. Commissions are not AFA’s primary source of compensation for advisory services. Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. Item 6: Performance-Based Fees and Side-By- Side Management We do not offer performance-based fees and do not engage in side-by-side management. Item 7: Types of Clients We provide financial planning and other services to individuals, high net-worth individuals, charitable organizations, corporations or other businesses, state or municipal government entities, and other investment advisers. We do not have a minimum account size requirement. Please see Item 5 for the minimum fee requirement. 10 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Our primary methods of investment analysis are fundamental, technical, cyclical, and charting analysis. Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience, and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The risk of fundamental analysis is that the information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick sectors that may outperform market indices. However, there is no assurance of accurate forecasts or that trends will develop in the markets we follow. In the past, there have been periods without discernible trends and similar periods will presumably occur in the future. Even where major trends develop, outside factors like government intervention could potentially shorten them. Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical method may fail to identify trends requiring action. In addition, technical methods may overreact to minor price movements, establishing positions contrary to overall price trends, which may result in losses. Finally, a technical trading method may underperform other trading methods when fundamental factors dominate price moves within a given market. Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and trends based upon business cycles. Economic/business cycles may not be predictable and may have many fluctuations between long-term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Modern Portfolio Theory (MPT) The underlying principles of MPT are: ● Investors are risk averse. The only acceptable risk is that which is adequately compensated by an expected return. Risk and investment return are related and an increase in risk requires an increased expected return. ● Markets are efficient. The same market information is available to all investors at the same time. The market prices every security fairly based upon this equal availability of information. ● ● ● The design of the portfolio as a whole is more important than the selection of any particular security. The appropriate allocation of capital among asset classes will have far more influence on long-term portfolio performance than the selection of individual securities. Investing for the long term (preferably longer than ten years) becomes critical to investment success because it allows the long-term characteristics of the asset classes to surface. Increasing diversification of the portfolio with lower correlated asset class positions can decrease portfolio risk. Correlation is the statistical term for the extent to which two asset classes move in tandem or opposition to one another. 11 Passive Investment Management We primarily practice passive investment management. Passive investing involves building portfolios that are composed of various distinct asset classes. The asset classes are weighted in a manner to achieve the desired relationship between correlation, risk, and return. Funds that passively capture the returns of the desired asset classes are placed in the portfolio. The funds that are used to build passive portfolios are typically index mutual funds or exchange-traded funds. Passive investment management is characterized by low portfolio expenses (i.e., the funds inside the portfolio have low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency (because the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal). In contrast, active management involves a single manager or managers who employ some method, strategy or technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a designated benchmark. Material Risks Involved All investing strategies we offer involve risk and may result in a loss of your original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other investment or security. Material risks associated with our investment strategies are listed below. Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the Client’s portfolio. Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s performance. Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate investments at prices we consider reasonable or favorable or find buyers at any price. Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. 12 Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your investments remains the same. Risks Associated with Securities Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks. Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on factors such as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations. Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the Clients invest. Mutual Funds When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). Alternative Investments Investing in alternative investments and/or strategies will not be suitable for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. 13 Item 9: Disciplinary Information Criminal or Civil Actions AFA and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings AFA and its management have not been involved in administrative enforcement proceedings. Self-Regulatory Organization Enforcement Proceedings AFA and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of AFA or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations No AFA employee is registered, or has an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. No AFA employee is registered, or has an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor. Mark Eid is a Real Estate Agent with INK Homes and Lifestyle. Mark Eid and Stephen Chang are Owners/Co-Founders of Rich to Wealthy, LLC, a personal finance-related social media and website-based education and entertainment company. Mark Eid and Stephen Chang are licensed insurance agents. From time to time, they will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and may involve a conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. AFA always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients always have the right to decide whether or not to utilize the services of any representative of AFA in such individual’s outside capacities. Recommendations or Selections of Other Investment Advisers AFA does not recommend Outside Managers to manage client accounts. 14 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of each Client. Our Clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm also accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities. Code of Ethics Description This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not shield associated persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory Clients. A summary of the Code of Ethics’ Principles is outlined below. • Integrity – Associated persons shall offer and provide professional services with integrity. • Objectivity – Associated persons shall be objective in providing professional services to Clients. • Competence – Associated persons shall provide services to Clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. • Fairness – Associated persons shall perform professional services in a manner that is fair and reasonable to Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. • Confidentiality – Associated persons shall not disclose confidential Client information without the specific consent of the Client unless in response to proper legal process, or as required by law. • Professionalism – Associated persons’ conduct in all matters shall reflect the credit of the profession. • Diligence – Associated persons shall act diligently in providing professional services. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest None among our firm, its associates, or any related person is authorized to recommend to a Client or to effect a transaction for a Client that involves any security in which our firm or a related person has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, etc. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Our firm and its “related persons” may buy or sell securities similar to, or different from, those we recommend to Clients for their accounts. In an effort to reduce or eliminate certain conflicts of interest involving the firm or personal trading, our policy may require that we restrict or prohibit associates’ transactions in specific reportable securities transactions. Any exceptions or trading pre-clearance must be approved by the firm principal in advance 15 of the transaction in an account, and we maintain the required personal securities transaction records per regulation. Trading Securities At/Around the Same Time as Client’s Securities From time to time, our firm or its “related persons” may buy or sell securities for themselves at or around the same time as Clients. We will not trade non-mutual fund securities 5 days prior to the same security for Clients. Item 12: Brokerage Practices Factors Used to Select Custodians and/or Broker-Dealers Acts Financial Advisors, LLC does not have any affiliation with Broker-Dealers. Specific custodian recommendations are made to the Client based on their need for such services. We recommend custodians based on the reputation and services provided by the firm. 1. Research and Other Soft-Dollar Benefits We currently do not receive soft dollar benefits. 2. Brokerage for Client Referrals We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use We do recommend a specific custodian for Clients to use, however, Clients may custody their assets at a custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions. By allowing Clients to choose a specific custodian, we may be unable to achieve the most favorable execution of Client transaction, and this may cost Clients money over using a lower-cost custodian. We recommend that a client use Adviser’s broker of choice, Charles Schwab & Company, Inc. (“Schwab”). Should the client indicate that they would prefer not to use Schwab, then we reserve the right to either decide not to provide investment advisory services for the client, to leverage held-away account access tools to provide discretionary asset management services, or to provide non-discretionary asset management services. None of these circumstances results in higher fees for clients. However, use of held-away account access tools or non- discretionary advisement might lead to delays in trade execution. The Custodian and Brokers We Use (Schwab) AFA may participate in the Schwab Advisor Services (SAS) services program offered to independent investment advisors by Schwab and is an unaffiliated SEC-registered broker dealers and FINRA/SIPC member broker dealers. Each offer to independent advisors, services which include custody of securities, trade execution, clearance and settlement transactions. Schwab is also FINRA member and member of SIPC. Aggregating (Block) Trading for Multiple Client Accounts Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion, regarding particular circumstances and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a 16 proportionate share of all transaction costs. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. Item 13: Review of Accounts Client accounts with the Investment Management Service will be reviewed regularly on a quarterly basis by the portfolio manager. The account is reviewed with regards to the Client’s investment policies and risk tolerance levels. Events that may trigger a special review would be unusual performance, addition or deletions of Client imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per Client’s needs. For Ongoing Financial Planning clients, there will be a full review of this plan every 6-12 months to ensure the plan’s accuracy and ongoing appropriateness. Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. Item 14: Client Referrals and Other Compensation We do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our Clients. Nor do we, directly or indirectly, compensate any person who is not advisory personnel for Client referrals. Item 15: Custody AFA does not accept custody of Client funds except in the instance of withdrawing Client fees. For Client accounts in which AFA directly debits their advisory fee: i. AFA will send a copy of its invoice to the custodian at the same time that it sends the Client a copy. ii. iii. The custodian will send at least quarterly statements to the Client showing all disbursements for the account, including the amount of the advisory fee. The Client will provide written authorization to AFA, permitting them to be paid directly for their accounts held by the custodian. Clients should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains Client’s investment assets. We urge you to carefully review such statements and compare such official custodial records to the account statements or reports that we may provide to you. Our statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. 17 Item 16: Investment Discretion For those Client accounts where we provide Investment Management services, we typically maintain discretion over Client accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold. Investment discretion is explained to Clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm discretion over the account. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. For some Client accounts where we provide Investment Management services, we may provide advice in a non- discretionary fashion. In this case, before we can buy or sell securities on the Client’s behalf, we will obtain explicit approval prior to the execution of any transactions for Client’s account(s). The Client has an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. If the Client chooses to limit our trading authority, we are not responsible for any losses which may occur because of a communication delay by Client, AFA, or the Custodian. In some cases, Client may engage us to provide periodic advice on assets held in a brokerage account held with a custodian other than Schwab. In these cases, we may provide portfolio advice, research, analysis or recommendations that we will communicate to Client for action implemented by Client at his or her own discretion. The type of relationship, discretionary or non-discretionary, will be outlined in the advisory contract and signed by the Client. Item 17: Voting Client Securities We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the Client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, Client will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to Client by mail, unless Client has authorized our firm to contact you by electronic mail, in which case, we would forward to Client by electronic mail any electronic solicitation to vote proxies. Item 18: Financial Information Registered Investment Advisers are required in this Item to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to Clients, and we have not been the subject of a bankruptcy proceeding. AFA neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. 18 Acts Financial Advisors, LLC 1390 Chain Bridge Rd #10147 McLean, Virginia, 22101 (571) 749-5522 Form ADV Part 2B – Brochure Supplement For Mark Eid Individual CRD# 7717662 Owner, Co-CEO, and Chief Compliance Officer This brochure supplement provides information about Mark Eid that supplements the Acts Financial Advisors, LLC (“AFA”) brochure. A copy of that brochure precedes this supplement. Please contact Mark Eid if the AFA brochure is not included with this supplement or if you have any questions about the contents of this supplement. Additional information about Mark Eid is available on the SEC’s website at www.adviserinfo.sec.gov which can be found using the identification number 7717662. 19 Item 2: Educational Background and Business Experience Mark Eid Born: 1980 Educational Background • 05/2006 – Doctor of Medicine, Johns Hopkins School of Medicine • 05/2010 – Master of Business Administration, Temple Fox School of Business Business Experience • 03/2023 – Present, Acts Financial Advisors, LLC, Owner & CCO • 01/2020 – Present, Qualderm Partners, Managing Clinical Director of VA • 02/2012 – 12/2019, VA Dermatology and Skin Surgery Center, Owner & Founder Item 3: Disciplinary Information No management person at Acts Financial Advisors, LLC has ever been involved in an arbitration claim of any kind or been found liable in a civil, self-regulatory organization, or administrative proceeding. Item 4: Other Business Activities Mark Eid also works as a Mohs micrographic surgeon at Qualderm Partners. He spends approximately 2 days per week performing clinical duties. Mark Eid is a Real Estate Agent with INK Homes and Lifestyle. Mr. Eid spends 0 hours per month during trading hours, and 5 hours per month outside trading hours on this activity. Mark Eid is Owner/Co-Founder of Rich to Wealthy, LLC, a personal finance-related social media and website- based education and entertainment company. Mr. Eid spends 10 hours per month during trading hours, and 10 hours per month outside trading hours on this activity. Mark Eid is a licensed insurance agent. From time to time, he will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and may involve a conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. AFA always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients always have the right to decide whether or not to utilize the services of any representative of AFA in such individual’s outside capacities. Mr. Eid spends 5 hours per month during trading hours, and 5 hours per month outside trading hours on this activity. 20 Item 5: Additional Compensation Mark Eid does not receive any economic benefit from any person, company, or organization, in exchange for providing Clients advisory services through AFA. Item 6: Supervision Mark Eid, as Chief Compliance Officer of AFA, is responsible for supervision. He may be contacted at the phone number on this brochure supplement. 21 Acts Financial Advisors, LLC 1390 Chain Bridge Rd #10147 McLean, Virginia, 22101 (571) 749-5522 Form ADV Part 2B – Brochure Supplement For Stephen Chang Individual CRD# 7717661 Owner, Co-CEO This brochure supplement provides information about Stephen Chang that supplements the Acts Financial Advisors, LLC (“AFA”) brochure. A copy of that brochure precedes this supplement. Please contact Stephen Chang if the AFA brochure is not included with this supplement or if you have any questions about the contents of this supplement. Additional information about Stephen Chang is available on the SEC’s website at www.adviserinfo.sec.gov which can be found using the identification number 7717661. 22 Item 2: Educational Background and Business Experience Stephen Chang Born: 1980 Educational Background • 06/2002 – Bachelor of Arts, Harvard • 06/2006 – Doctor of Medicine, Johns Hopkins School of Medicine • 05/2014 – Master of Business Administration, University of Pennsylvania Business Experience • 03/2023 – Present, Acts Financial Advisors, LLC, Owner • 09/2021 – 03/2023, McKinsey, Expert • 10/2020 – 03/2021, Virginia Dermatology, COO, Senior Advisor • 07/2013 – 03/2022, Capital College, President • 07/2013 – 08/2020, United Medical Laboratories, President • 07/2012 – 06/2013, Radiology Associates of Ridgewood, Radiologist Item 3: Disciplinary Information No management person at Acts Financial Advisors, LLC has ever been involved in an arbitration claim of any kind or been found liable in a civil, self-regulatory organization, or administrative proceeding. Item 4: Other Business Activities Stephen Chang is Owner/Co-Founder of Rich to Wealthy, LLC, a personal finance-related social media and website-based education and entertainment company. Mr. Chang spends 10 hours per month during trading hours, and 10 hours per month outside trading hours on this activity. Stephen Chang is a licensed insurance agent. From time to time, he will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and may involve a conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. AFA always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients always have the right to decide whether or not to utilize the services of any representative of AFA in such individual’s outside capacities. Mr. Chang spends 5 hours per month during trading hours, and 5 hours per month outside trading hours on this activity. 23 Item 5: Additional Compensation Stephen Chang does not receive any economic benefit from any person, company, or organization, in exchange for providing Clients advisory services through AFA. Item 6: Supervision Mark Eid, as Chief Compliance Officer of AFA, is responsible for supervision. He may be contacted at the phone number on this brochure supplement. 24

Additional Brochure: FORM ADV PART 2A 2B (2025-03-31)

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Item 1: Cover Page Acts Financial Advisors, LLC 1390 Chain Bridge Rd #10147 McLean, VA 22101 Form ADV Part 2A – Firm Brochure (571) 749-5522 Last revised on March 28, 2025 This Brochure provides information about the qualifications and business practices of Acts Financial Advisors, LLC, “AFA”. If you have any questions about the contents of this Brochure, please contact us at (571) 749-5522. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Acts Financial Advisors, LLC is registered as an Investment Adviser with the SEC. Registration of an Investment Adviser does not imply any level of skill or training. Additional information about AFA is available on the SEC’s website at www.adviserinfo.sec.gov, which can be found using the firm’s identification number, 325930. Item 2: Material Changes Acts Financial Advisors, LLC has the following material changes to report. Material changes relate to Acts Financial Advisors, LLC’s policies, practices or conflicts of interests. The firm updated Item 4 to add an additional service offering. The firm updated Item 5 to update fee structures for its service offerings. The firm updated Item 9 to clarify disciplinary action disclosures. From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations, and routine annual updates as required by the securities regulators. Either this complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of Acts Financial Advisors, LLC. At any time, you may view the current Disclosure Brochure online at the SEC's Investment Adviser Public Disclosure website at http://www.adviserinfo.sec.gov by searching for our firm name or by our CRD number 325930. You may also request a copy of this Disclosure Brochure at any time, by contacting us at (571) 749-5522. 2 Item 3: Table of Contents Contents Item 1: Cover Page 1 Item 2: Material Changes 2 Item 3: Table of Contents 3 Item 4: Advisory Business 4 Item 5: Fees and Compensation 7 Item 6: Performance-Based Fees and Side-By-Side Management 11 Item 7: Types of Clients 11 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 11 Item 9: Disciplinary Information 14 Item 10: Other Financial Industry Activities and Affiliations 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 15 Item 12: Brokerage Practices 17 Item 13: Review of Accounts 18 Item 14: Client Referrals and Other Compensation 18 Item 15: Custody 18 Item 16: Investment Discretion 19 Item 17: Voting Client Securities 19 Item 18: Financial Information 19 Form ADV Part 2B – Brochure Supplement 20 Form ADV Part 2B – Brochure Supplement 23 3 Item 4: Advisory Business Description of Advisory Firm Acts Financial Advisors, LLC became registered as an Investment Advisor with the State of Virginia and with the SEC in 2023. Stephen Chang and Mark Eid are the principal owners of AFA. As of December 31 2024, AFA has $79,169,643 discretionary assets under management and $35,673,191 non-discretionary assets under management. Types of Advisory Services One-Time Financial Planning Services We provide financial planning services on topics such as retirement planning, risk management, cash flow, debt management, work benefits, and estate planning. Financial planning involves an evaluation of a Client's current and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they affect and are affected by the entire financial and life situation of the Client. Clients purchasing this service will receive a written or an electronic report, providing the Client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. The adviser will meet with the Client to review the financial plan and outline the corresponding action plan. In general, the financial plan will address any or all of the following areas of concern. The Client and advisor will work together to select specific areas to cover. These areas may include some or all of, but are not limited to, the following: ● Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. ● Financial Goals: We will help Clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. ● Employee Benefits Optimization: We will provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals. ● Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which 4 type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with the consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. ● Investment Analysis: This may involve developing an asset allocation strategy to meet Clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. ● Retirement Planning: Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. ● Insurance Needs Analysis & Risk Management: Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home, and automobile. A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long‐ term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (retention of risk, sometimes called “self‐insuring”). ● Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts, as well as a review of your asset protection strategies. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request. ● Education Planning: We review Clients' education goals and existing savings vehicles. We also help to identify sources of education funding and assist with evaluating and establishing optimal methods of saving for future education costs based on Clients' preferences. 5 Investment Management Services We manage individually tailored investment portfolios. Our firm provides continuous advice to a Client regarding the investment of Client funds based on the individual needs of the Client. Through personal discussions in which goals and objectives based on a Client's particular circumstances are established, we develop a Client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation targets. We will also review and discuss a Client’s prior investment history, as well as family composition and background. Account supervision is guided by the stated objectives of the Client (e.g., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Fees pertaining to this service are outlined in Item 5 of this brochure. Ongoing Financial Planning Services We provide financial planning services on an ongoing basis. Clients purchasing this service will receive a written or an electronic report during the first year of services, providing the Client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. The adviser will meet with the Client to review the financial plan and outline the corresponding action plan. There will be a full review of this plan every 6-12 months to ensure its accuracy and ongoing appropriateness. In addition to including the services provided in One-Time Financial Planning as described above, we also provide the services described above in Investment Management. Business Planning & Consulting Services We provide consulting services for Clients who are considering starting a business, currently operate their own business, or are planning for an exit by sale or succession from their current business. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. Real Estate Analysis Services We provide real estate analysis services for Clients who currently own property, are considering purchasing a new property, or are planning to sell their current property. Depending on the property, investment analysis could encompass consultation about the development and management needs of real estate across classes and markets. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. Business Retirement Plan Management Services We offer consulting services to pension and other employee benefit plans (including but not limited to 401(k), 403b, 457 plans, Cash Balance Pension Plans, and Defined Benefit Plans). Business Retirement Plan Management may include, but is not limited to: • identifying investment objectives and restrictions, 6 • providing guidance on various assets classes and investment options , • monitoring performance of investment options and making recommendations for changes, • • recommending other service providers, such as custodians, administrators and broker-dealers, and creating a written plan for business retirement plan management. These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Educational Seminars/Workshops We provide periodic educational seminars and workshops to the general public. Seminars are typically 1-2 hours in length. The seminars are meant to be informational in nature and would cover various aspects of personal finance, including but not limited to investing, tax optimization, retirement planning, and risk management/insurance needs. Client Tailored Services and Client Imposed Restrictions We offer the same suite of services to all of our Clients. However, specific Client financial plans and their implementation are dependent upon the Client Investment Policy Statement which outlines each Client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a Client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Wrap Fee Programs We do not participate in wrap fee programs. Item 5: Fees and Compensation Please note, unless a Client has received the firm’s Disclosure Brochure at least 48 hours prior to signing the investment advisory contract, the investment advisory contract may be terminated by the Client within five (5) business days of signing the contract without incurring any advisory fees. How we are paid depends on the type of advisory service we are performing. Please review the fee and compensation information below. One-Time Financial Planning Fees One-Time Financial Planning engagements can be offered at an hourly rate of $450 per hour. The total fee, which may be negotiable in certain cases, will be estimated and outlined in the client contract. A retainer commensurate with the scope of the engagement will be collected at the beginning. Thereafter, monthly bills will be provided, with the final balance due at completion. One-Time Financial Planning engagements can also be offered on a project/fixed fee basis. The total fee, which may be negotiable in certain cases, will be estimated and outlined in the client contract and based on scope and complexity. For project-based billing, half of the fee will be due at the beginning of the engagement and the remaining amount will be due at the completion of the engagement. Fees for this service may be paid by check or electronic funds transfer. This work will commence immediately after the fee is paid and will be completed within 60 days of the date the Client provides his or her full financial 7 information OR within the first 175 days of the date the fee is paid, whichever is earlier. Therefore, the upfront portion of the fee will not be paid more than 6 months in advance. In the event of early termination by the Client, any fees for work already performed will be due or, if applicable, any prepaid fees will be returned to the Client. Ongoing Financial Planning Fees Our standard annual advisory fee is based on the market value of the assets under management (which includes assets held at our recommended custodian, assets held away, and assets under advisement) and is calculated as follows: Account Value Annual Advisory Fee $0 - $500,000 1.00% $500,001 - $1,000,000 0.90% $1,000,001 - $2,000,000 0.80% $2,000,001 - $5,000,000 0.70% $5,000,001 - $10,000,000 0.65% $10,000,001 - $20,000,000 0.60% $20,000,001 - $50,000,000 0.55% $50,000,001 and above 0.50% New Ongoing Financial Planning clients are required to pay one-quarter of the minimum annual advisory fee upfront for the first year only. The financial plan, which is included with these services, will be provided within 60 days of the date the Client provides his or her full financial information OR within the first 175 days of the date the fee is paid, whichever is earlier. The annual advisory fees are negotiable, based on certain factors, e.g., personal relationships, net worth, income. Annual advisory fees are pro-rated and paid in arrears on a monthly basis. The annual advisory fee is a tiered fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the above chart and applying the fee to the account value as of the last day of the previous month. (In the event that the account value cannot be ascertained as of the last day of the previous month, the value from the last day of the previous quarter will be used instead.) The annual advisory fee is subject to a $10,800 minimum (and an $900 monthly minimum) per client, which is inclusive of comprehensive financial planning and investment management fees. Annual advisory fees will not exceed more than 1.00% of the client’s total AUM as a result. No increase in the annual advisory fee shall be effective without agreement from the Client by signing a new agreement or amendment to their current advisory agreement. We calculate period-end account values after all dividends settle in the account. Therefore, the account value used to calculate advisory fees may differ from that of the custodial account statement. Our billing invoice will indicate the total account value used to calculate the advisory fee. Advisory fees are directly debited from Client accounts when possible. Accounts initiated or terminated during a month will be charged a pro-rated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice at least 15 calendar days in advance. Since fees are paid in arrears, no refund will be needed upon termination of the account. 8 Note: Our annual minimum fee of $10,800 (and monthly minimum fee of $900) may not be suitable for all clients, and in certain cases, could result in what may appear to be unreasonable and excessive charges. In such scenarios, we reserve the right to invoke our fiduciary duty, decline the engagement, and counsel those for whom we are not a good fit that they should seek a lower cost alternative. Investment Management Services Our standard annual advisory fee is based on the market value of the assets under management (which includes assets held at our recommended custodian, assets held away, and assets under advisement) and is calculated as follows: Account Value Annual Advisory Fee $0 - $500,000 1.00% $500,001 - $1,000,000 0.90% $1,000,001 - $2,000,000 0.80% $2,000,001 - $5,000,000 0.70% $5,000,001 - $10,000,000 0.65% $10,000,001 - $20,000,000 0.60% $20,000,001 - $50,000,000 0.55% $50,000,001 and above 0.50% The annual investment management fees are negotiable, based on certain factors, e.g., personal relationships, net worth, income. Annual investment management fees are pro-rated and paid in arrears on a monthly basis. The annual investment management fee is a tiered fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the above chart and applying the fee to the account value as of the last day of the previous month. (In the event that the account value cannot be ascertained as of the last day of the previous month, the value from the last day of the previous quarter or applicable period will be used instead.) Annual investment management fees will not exceed more than 1.00% of the client’s total AUM as a result. No increase in the annual investment management fee shall be effective without agreement from the Client by signing a new agreement or amendment to their current investment management agreement. We calculate period-end account values after all dividends settle in the account. Therefore, the account value used to calculate investment management fees may differ from that of the custodial account statement. Our billing invoice will indicate the total account value used to calculate the advisory fee. Investment management fees are directly debited from Client accounts when possible. Accounts initiated or terminated during a month will be charged a pro-rated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice at least 15 calendar days in advance. Since fees are paid in arrears, no refund will be needed upon termination of the account. Business Planning & Consulting Services Business Planning & Consulting engagements can be offered at an hourly rate of $450 per hour. The total fee, which may be negotiable in certain cases, will be estimated and outlined in the client contract. A retainer 9 commensurate with the scope of the engagement will be collected at the beginning. Thereafter, monthly bills will be provided, with the final balance due at completion. Business Planning & Consulting engagements can also be offered on a project/fixed fee basis. The total fee, which may be negotiable in certain cases, will be estimated and outlined in the client contract and based on scope and complexity. For project-based billing, half of the fee will be due at the beginning of the engagement and the remaining amount will be due at the completion of the engagement. AFA will not bill an amount greater than $1,200.00 six months or more in advance. Fees for this service may be paid by check or electronic funds transfer. This work will commence immediately after the fee is paid and will be completed within 60-90 days of the date the Client provides his or her full financial information OR within the first 175 days of the date the fee is paid, whichever is earlier. Therefore, the upfront portion of the fee will not be paid more than 6 months in advance. In the event of early termination by the Client, any fees for work already performed will be due or, if applicable, any prepaid fees will be returned to the Client. Real Estate Analysis Services Real Estate Analysis engagements can be offered at an hourly rate of $450 per hour. The total fee, which may be negotiable in certain cases, will be estimated and outlined in the client contract. A retainer commensurate with the scope of the engagement will be collected at the beginning. Thereafter, monthly bills will be provided, with the final balance due at completion. Real Estate Analysis engagements can also be offered on a project/fixed fee basis. The total fee, which may be negotiable in certain cases, will be estimated and outlined in the client contract and based on scope and complexity. For project-based billing, half of the fee will be due at the beginning of the engagement and the remaining amount will be due at the completion of the engagement. AFA will not bill an amount greater than $1,200.00 six months or more in advance. Fees for this service may be paid by check or electronic funds transfer. This work will commence immediately after the fee is paid and will be completed within 60-90 days of the date the Client provides his or her full financial information OR within the first 175 days of the date the fee is paid, whichever is earlier. Therefore, the upfront portion of the fee will not be paid more than 6 months in advance. In the event of early termination by the Client, any fees for work already performed will be due or, if applicable, any prepaid fees will be returned to the Client. Business Retirement Plan Management Services AFA will be compensated for Employee Benefit Plan services according to the value of plan assets not to exceed 0.75% of total plan assets. This does not include fees to other parties, such as Recordkeepers, Custodians, or Third Party-Administrators. Fees for this service may be negotiable in certain cases and are typically deducted directly from the plan assets by the Custodian on a quarterly basis in arrears. Business Retirement Plan Management Services may be terminated with written notice at least 15 calendar days in advance. Since fees are paid in arrears, no refund will be needed upon termination of the account. Educational Seminar/Workshop Fees Educational seminars and workshops are offered free of charge. 10 Other Types of Fees and Expenses Fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as 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 fund and exchange- traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees, and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for Client’s transactions and determining the reasonableness of their compensation (e.g., commissions). Stephen Chang and Mark Eid are licensed to accept compensation for the sale of investment products to AFA clients. This may present a conflict of interest and can give the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of securities or investment products for which the supervised persons receives compensation, AFA will document the conflict of interest in the client file and inform the client of the conflict of interest. Clients always have the right to decide whether to purchase AFA-recommended products and, if purchasing, have the right to purchase those products through other brokers or agents that are not affiliated with AFA. Commissions are not AFA’s primary source of compensation for advisory services. Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. Item 6: Performance-Based Fees and Side-By- Side Management We do not offer performance-based fees and do not engage in side-by-side management. Item 7: Types of Clients We provide financial planning and other services to individuals, high net-worth individuals, charitable organizations, corporations or other businesses, state or municipal government entities, and other investment advisers. We do not have a minimum account size requirement. Please see Item 5 for the minimum fee requirement. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Our primary methods of investment analysis are fundamental, technical, cyclical, and charting analysis. Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience, and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of 11 the company’s stock compared to the current market value. The risk of fundamental analysis is that the information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick sectors that may outperform market indices. However, there is no assurance of accurate forecasts or that trends will develop in the markets we follow. In the past, there have been periods without discernible trends and similar periods will presumably occur in the future. Even where major trends develop, outside factors like government intervention could potentially shorten them. Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical method may fail to identify trends requiring action. In addition, technical methods may overreact to minor price movements, establishing positions contrary to overall price trends, which may result in losses. Finally, a technical trading method may underperform other trading methods when fundamental factors dominate price moves within a given market. Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and trends based upon business cycles. Economic/business cycles may not be predictable and may have many fluctuations between long-term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Modern Portfolio Theory (MPT) The underlying principles of MPT are: ● Investors are risk averse. The only acceptable risk is that which is adequately compensated by an expected return. Risk and investment return are related and an increase in risk requires an increased expected return. ● Markets are efficient. The same market information is available to all investors at the same time. The market prices every security fairly based upon this equal availability of information. ● ● ● The design of the portfolio as a whole is more important than the selection of any particular security. The appropriate allocation of capital among asset classes will have far more influence on long-term portfolio performance than the selection of individual securities. Investing for the long term (preferably longer than ten years) becomes critical to investment success because it allows the long-term characteristics of the asset classes to surface. Increasing diversification of the portfolio with lower correlated asset class positions can decrease portfolio risk. Correlation is the statistical term for the extent to which two asset classes move in tandem or opposition to one another. Passive Investment Management We primarily practice passive investment management. Passive investing involves building portfolios that are composed of various distinct asset classes. The asset classes are weighted in a manner to achieve the desired relationship between correlation, risk, and return. Funds that passively capture the returns of the desired asset classes are placed in the portfolio. The funds that are used to build passive portfolios are typically index mutual funds or exchange-traded funds. Passive investment management is characterized by low portfolio expenses (i.e., the funds inside the portfolio have low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency (because the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal). 12 In contrast, active management involves a single manager or managers who employ some method, strategy or technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a designated benchmark. Material Risks Involved All investing strategies we offer involve risk and may result in a loss of your original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other investment or security. Material risks associated with our investment strategies are listed below. Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the Client’s portfolio. Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s performance. Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate investments at prices we consider reasonable or favorable or find buyers at any price. Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your investments remains the same. Risks Associated with Securities Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks. Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, 13 investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on factors such as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations. Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the Clients invest. Mutual Funds When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). Alternative Investments Investing in alternative investments and/or strategies will not be suitable for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. Item 9: Disciplinary Information Criminal or Civil Actions AFA and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings AFA and its management have not been involved in administrative enforcement proceedings. Self-Regulatory Organization Enforcement Proceedings 14 AFA and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of AFA or the integrity of its management. Other Disciplinary Actions The Adviser will disclose the existence of any public discipline or bankruptcy, and the location(s) of the webpages of all relevant public websites of any governmental authority, self-regulatory organization, or professional organization that sets forth the Adviser’s or its IARs’ public disciplinary history or any personal bankruptcy or business bankruptcy where an IAR was a Control Person: There are no bankruptcies, whether personal or business, to disclose. Medical license disciplinary actions, if any, can be found by searching https://www.dhp.virginia.gov/Boards/Medicine/, https://www.mbp.state.md.us/, https://wvbom.wv.gov/, https://www.ncmedboard.org/, https://www.michigan.gov/lara/bureau-list/bpl/health/hp-lic-health-prof/medical, https://idfpr.illinois.gov/profs/boards/statemedboard.html, and https://www.mbc.ca.gov/. Item 10: Other Financial Industry Activities and Affiliations No AFA employee is registered, or has an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. No AFA employee is registered, or has an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor. Mark Eid is a Real Estate Agent with INK Homes and Lifestyle. Mark Eid and Stephen Chang are Owners/Co-Founders of Rich to Wealthy, LLC, a personal finance-related social media and website-based education and entertainment company. Mark Eid and Stephen Chang are licensed insurance agents. From time to time, they will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and may involve a conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. AFA always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients always have the right to decide whether or not to utilize the services of any representative of AFA in such individual’s outside capacities. Recommendations or Selections of Other Investment Advisers AFA does not recommend Outside Managers to manage client accounts. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of each Client. Our Clients entrust us with their funds and personal information, which in turn places a high standard 15 on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm also accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities. Code of Ethics Description This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not shield associated persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory Clients. A summary of the Code of Ethics’ Principles is outlined below. Integrity – Associated persons shall offer and provide professional services with integrity. • • Objectivity – Associated persons shall be objective in providing professional services to Clients. • Competence – Associated persons shall provide services to Clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. • Fairness – Associated persons shall perform professional services in a manner that is fair and reasonable to Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. • Confidentiality – Associated persons shall not disclose confidential Client information without the specific consent of the Client unless in response to proper legal process, or as required by law. • Professionalism – Associated persons’ conduct in all matters shall reflect the credit of the profession. • Diligence – Associated persons shall act diligently in providing professional services. We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest None among our firm, its associates, or any related person is authorized to recommend to a Client or to effect a transaction for a Client that involves any security in which our firm or a related person has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, etc. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Our firm and its “related persons” may buy or sell securities similar to, or different from, those we recommend to Clients for their accounts. In an effort to reduce or eliminate certain conflicts of interest involving the firm or personal trading, our policy may require that we restrict or prohibit associates’ transactions in specific reportable securities transactions. Any exceptions or trading pre-clearance must be approved by the firm principal in advance of the transaction in an account, and we maintain the required personal securities transaction records per regulation. Trading Securities At/Around the Same Time as Client’s Securities From time to time, our firm or its “related persons” may buy or sell securities for themselves at or around the same time as Clients. We will not trade non-mutual fund securities 5 days prior to the same security for Clients. 16 Item 12: Brokerage Practices Factors Used to Select Custodians and/or Broker-Dealers Acts Financial Advisors, LLC does not have any affiliation with Broker-Dealers. Specific custodian recommendations are made to the Client based on their need for such services. We recommend custodians based on the reputation and services provided by the firm. 1. Research and Other Soft-Dollar Benefits We currently do not receive soft dollar benefits. 2. Brokerage for Client Referrals We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use We do recommend a specific custodian for Clients to use, however, Clients may custody their assets at a custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions. By allowing Clients to choose a specific custodian, we may be unable to achieve the most favorable execution of Client transaction, and this may cost Clients money over using a lower-cost custodian. We recommend that a client use Adviser’s broker of choice, Charles Schwab & Company, Inc. (“Schwab”). Should the client indicate that they would prefer not to use Schwab, then we reserve the right to either decide not to provide investment advisory services for the client, to leverage held-away account access tools to provide discretionary asset management services, or to provide non-discretionary asset management services. None of these circumstances results in higher fees for clients. However, use of held-away account access tools or non- discretionary advisement might lead to delays in trade execution. The Custodian and Brokers We Use (Schwab) AFA may participate in the Schwab Advisor Services (SAS) services program offered to independent investment advisors by Schwab and is an unaffiliated SEC-registered broker dealers and FINRA/SIPC member broker dealers. Each offer to independent advisors, services which include custody of securities, trade execution, clearance and settlement transactions. Schwab is also FINRA member and member of SIPC. Aggregating (Block) Trading for Multiple Client Accounts Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion, regarding particular circumstances and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. 17 Item 13: Review of Accounts Client accounts with the Investment Management Service will be reviewed regularly on a quarterly basis by the portfolio manager. The account is reviewed with regards to the Client’s investment policies and risk tolerance levels. Events that may trigger a special review would be unusual performance, addition or deletions of Client imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per Client’s needs. For Ongoing Financial Planning clients, there will be a full review of this plan every 6-12 months to ensure the plan’s accuracy and ongoing appropriateness. Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. Item 14: Client Referrals and Other Compensation We do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our Clients. Nor do we, directly or indirectly, compensate any person who is not advisory personnel for Client referrals. Item 15: Custody AFA does not accept custody of Client funds except in the instance of withdrawing Client fees. For Client accounts in which AFA directly debits their advisory fee: i. AFA will send a copy of its invoice to the custodian at the same time that it sends the Client a copy. ii. iii. The custodian will send at least quarterly statements to the Client showing all disbursements for the account, including the amount of the advisory fee. The Client will provide written authorization to AFA, permitting them to be paid directly for their accounts held by the custodian. Clients should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains Client’s investment assets. We urge you to carefully review such statements and compare such official custodial records to the account statements or reports that we may provide to you. Our statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. 18 Item 16: Investment Discretion For those Client accounts where we provide Investment Management services, we typically maintain discretion over Client accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold. Investment discretion is explained to Clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm discretion over the account. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. For some Client accounts where we provide Investment Management services, we may provide advice in a non- discretionary fashion. In this case, before we can buy or sell securities on the Client’s behalf, we will obtain explicit approval prior to the execution of any transactions for Client’s account(s). The Client has an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. If the Client chooses to limit our trading authority, we are not responsible for any losses which may occur because of a communication delay by Client, AFA, or the Custodian. In some cases, Client may engage us to provide periodic advice on assets held in a brokerage account held with a custodian other than Schwab. In these cases, we may provide portfolio advice, research, analysis or recommendations that we will communicate to Client for action implemented by Client at his or her own discretion. The type of relationship, discretionary or non-discretionary, will be outlined in the advisory contract and signed by the Client. Item 17: Voting Client Securities We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the Client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. In most cases, Client will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to Client by mail, unless Client has authorized our firm to contact you by electronic mail, in which case, we would forward to Client by electronic mail any electronic solicitation to vote proxies. Item 18: Financial Information Registered Investment Advisers are required in this Item to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to Clients, and we have not been the subject of a bankruptcy proceeding. AFA neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. 19 Acts Financial Advisors, LLC 1390 Chain Bridge Rd #10147 McLean, Virginia, 22101 (571) 749-5522 Form ADV Part 2B – Brochure Supplement For Mark Eid Individual CRD# 7717662 Owner, Co-CEO, and Chief Compliance Officer This brochure supplement provides information about Mark Eid that supplements the Acts Financial Advisors, LLC (“AFA”) brochure. A copy of that brochure precedes this supplement. Please contact Mark Eid if the AFA brochure is not included with this supplement or if you have any questions about the contents of this supplement. Additional information about Mark Eid is available on the SEC’s website at www.adviserinfo.sec.gov which can be found using the identification number 7717662. 20 Item 2: Educational Background and Business Experience Mark Eid Born: 1980 Educational Background • 05/2006 – Doctor of Medicine, Johns Hopkins School of Medicine • 05/2010 – Master of Business Administration, Temple Fox School of Business Business Experience • 03/2023 – Present, Acts Financial Advisors, LLC, Owner & CCO • 01/2020 – Present, Qualderm Partners, Managing Clinical Director of VA • 02/2012 – 12/2019, VA Dermatology and Skin Surgery Center, Owner & Founder Item 3: Disciplinary Information No management person at Acts Financial Advisors, LLC has ever been involved in an arbitration claim of any kind or been found liable in a civil, self-regulatory organization, or administrative proceeding. Item 4: Other Business Activities Mark Eid also works as a Mohs micrographic surgeon at Qualderm Partners. He spends approximately 2 days per week performing clinical duties. Mark Eid is a Real Estate Agent with INK Homes and Lifestyle. Mr. Eid spends 0 hours per month during trading hours, and 5 hours per month outside trading hours on this activity. Mark Eid is Owner/Co-Founder of Rich to Wealthy, LLC, a personal finance-related social media and website- based education and entertainment company. Mr. Eid spends 10 hours per month during trading hours, and 10 hours per month outside trading hours on this activity. Mark Eid is a licensed insurance agent. From time to time, he will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and may involve a conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. AFA always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients always have the right to decide whether or not to utilize the services of any representative of AFA in such individual’s outside capacities. Mr. Eid spends 5 hours per month during trading hours, and 5 hours per month outside trading hours on this activity. 21 Item 5: Additional Compensation Mark Eid does not receive any economic benefit from any person, company, or organization, in exchange for providing Clients advisory services through AFA. Item 6: Supervision Mark Eid, as Chief Compliance Officer of AFA, is responsible for supervision. He may be contacted at the phone number on this brochure supplement. 22 Acts Financial Advisors, LLC 1390 Chain Bridge Rd #10147 McLean, Virginia, 22101 (571) 749-5522 Form ADV Part 2B – Brochure Supplement For Stephen Chang Individual CRD# 7717661 Owner, Co-CEO This brochure supplement provides information about Stephen Chang that supplements the Acts Financial Advisors, LLC (“AFA”) brochure. A copy of that brochure precedes this supplement. Please contact Stephen Chang if the AFA brochure is not included with this supplement or if you have any questions about the contents of this supplement. Additional information about Stephen Chang is available on the SEC’s website at www.adviserinfo.sec.gov which can be found using the identification number 7717661. 23 Item 2: Educational Background and Business Experience Stephen Chang Born: 1980 Educational Background • 06/2002 – Bachelor of Arts, Harvard • 06/2006 – Doctor of Medicine, Johns Hopkins School of Medicine • 05/2014 – Master of Business Administration, University of Pennsylvania Business Experience • 03/2023 – Present, Acts Financial Advisors, LLC, Owner • 09/2021 – 03/2023, McKinsey, Expert • 10/2020 – 03/2021, Virginia Dermatology, COO, Senior Advisor • 07/2013 – 03/2022, Capital College, President • 07/2013 – 08/2020, United Medical Laboratories, President • 07/2012 – 06/2013, Radiology Associates of Ridgewood, Radiologist Item 3: Disciplinary Information No management person at Acts Financial Advisors, LLC has ever been involved in an arbitration claim of any kind or been found liable in a civil, self-regulatory organization, or administrative proceeding. Item 4: Other Business Activities Stephen Chang is Owner/Co-Founder of Rich to Wealthy, LLC, a personal finance-related social media and website-based education and entertainment company. Mr. Chang spends 10 hours per month during trading hours, and 10 hours per month outside trading hours on this activity. Stephen Chang is a licensed insurance agent. From time to time, he will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and may involve a conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. AFA always acts in the best interest of the client, including the sale of commissionable products to advisory clients. Clients always have the right to decide whether or not to utilize the services of any representative of AFA in such individual’s outside capacities. Mr. Chang spends 5 hours per month during trading hours, and 5 hours per month outside trading hours on this activity. 24 Item 5: Additional Compensation Stephen Chang does not receive any economic benefit from any person, company, or organization, in exchange for providing Clients advisory services through AFA. Item 6: Supervision Mark Eid, as Chief Compliance Officer of AFA, is responsible for supervision. He may be contacted at the phone number on this brochure supplement. 25