ARMSTRONG, FLEMING & MOORE, INC.

ARMSTRONG, FLEMING & MOORE, INC. Part 2A of Form ADV Brochure 1800 M Street, NW Suite 1010-S Washington, DC 20036 202-887-8135 www.afmfa.com March 28, 2025 This Brochure provides information about the qualifications and business practices of Armstrong, Fleming & Moore, Inc. (“AFM” or “Firm” or “We”). If you have any questions about the contents of this Brochure, please contact us at 202-887-8135. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. information about AFM is also available on Additional the SEC’s website at: www.adviserinfo.sec.gov. AFM is a registered investment adviser. Registration as an investment adviser does not imply a certain level of skill or training.  Material Changes This Brochure updates AFM’s brochure as filed with the SEC in March 2024. AFM has made several clarifying revisions to the disclosure contained herein. Please review this Brochure carefully in its entirety. Table of Contents Material Changes ............................................................................................................................ 2 Table of Contents ............................................................................................................................ 2 Advisory Business .......................................................................................................................... 3 Fees and Compensation .................................................................................................................. 8 Performance Based Fees and Side-by-Side Management ............................................................ 13 Types of Clients ............................................................................................................................ 13 Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 14 Disciplinary Information ............................................................................................................... 22 Other Financial Industry Activities and Affiliations .................................................................... 22 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 23 Brokerage Practices ...................................................................................................................... 24 Review of Accounts ...................................................................................................................... 27 Client Referrals and Other Compensation .................................................................................... 28 Custody ......................................................................................................................................... 28 Investment Discretion ................................................................................................................... 28 Voting Client Securities ................................................................................................................ 30 Financial Information.................................................................................................................... 30  Advisory Business Armstrong, Fleming & Moore (“AFM”) was founded in 1983 and is principally owned by Ryan Fleming and Mary Moore. Other owners include Chris Rivers and Carl Holubowich. As of December 31, 2024, AFM managed $1,087,292,612 on a discretionary basis and $30,288,170 on a non-discretionary basis on behalf of approximately 447 household Clients. Portfolio Management Services AFM offers Clients investment management services as covered in the Portfolio Management Agreement where each Client’s investment account and portfolio are managed on a regular and continuous basis. AFM will assist the Client in determining, among other things, suitability, investment objectives, goals, time horizons, and risk tolerances. The Client’s personal investment allocation will be developed from these goals and objectives, and AFM will manage the Client’s portfolios based on that allocation. Account supervision is guided by stated objectives of the Client (i.e., maximum capital appreciation, growth, income, or growth and income). AFM believes that to the extent possible, the Firm must tailor portfolio investment strategies to the needs of the individual Client. In general, the Firm's investment philosophy is to seek to achieve capital appreciation and/or current income within the constraints of prudent risk-taking in accordance with the Client's ability and willingness to accept risk. However, individual portfolio strategies will vary according to the Client's stated objectives. Portfolios are structured to meet current investment objectives of the Client and to anticipate future needs and changes in the Client's longer-term goals. AFM manages advisory accounts on a discretionary or a non-discretionary basis. Within its non- discretionary capacity, AFM may, with Client consent, purchase or sell securities to meet the cash needs of the Client on an as needed basis. These purchases and sales will be executed in a manner such that the resulting allocations will generally match the allocation in the account prior to the purchase or sale. However, in situations where consent to a transaction is required, non- discretionary Clients will forgo trading until such time as AFM can contact the Client and receive authorization for the transaction. The unavailability of a client to authorize a transaction may have a materially negative impact on performance of the Client’s account; accordingly, Client assumes such risk. into an agreement with Commonwealth Equity Services, AFM has entered Inc. (“Commonwealth”) a FINRA-registered broker/dealer and SEC-registered investment adviser to offer AFM Clients access to Commonwealth’s Advisory Services Program, PPS Custom Account Program, PPS Select Account Program, PPS Direct Account Program and Retirement Plan Consulting Program. In the case of the PPS Custom Account Program, AFM will assist Clients in the development of personalized asset allocation programs. In the case of the PPS Select Account Program, portfolio management is provided by Commonwealth’s Asset Management team. In the case of the PPS Direct Account Program, AFM offers the services of approved money management firms referred to as “Sub-Advisors” to assist in managing Client portfolios. In the case of the Retirement Plan Consulting Program, AFM provides a fee-for- service consulting program whereby advisors offer one-time or ongoing advisory services to qualified retirement plans. Clients may engage AFM for Retirement Plan Consulting services on  a negotiated hourly, flat, fixed, or asset-based fee basis. The maximum annual account consulting fee, when stated as a percentage of assets, is 1.50%, and is negotiable. Fees may be paid at the time of service, in advance of service, or after service has been rendered. If fees are being charged on an hourly basis, they may not exceed $500 per hour. Through the Retirement Plan Consulting Program, AFM may assist plan sponsors with their fiduciary duties and provide individualized advice based upon the needs of the plan and/or plan participants regarding investment management matters, such as: Investment policy statement support • Investment selection and monitoring • • Overall portfolio composition • Participant advice programs Clients who participate in one or more of Commonwealth’s Programs will receive Commonwealth’s Form ADV Part2A and/or Wrap Fee Brochure, in addition to AFM’s Form ADV Part 2A. Clients should refer to Commonwealth’s Form ADV Part 2A and/or Wrap Fee Brochure for detailed information about Commonwealth and Commonwealth’s Programs. Clients utilizing AFM’s portfolio management services must utilize the brokerage services of Commonwealth, of which advisory personnel of AFM are registered representatives (See Other Financial Industry Activities and Affiliations for more information). Fees for brokerage/execution will be charged pursuant to Commonwealth’s then current transaction schedule, which will be provided separately upon request. Accounts held at Commonwealth are also subject to custodial and account servicing fees. AFM has no revenue or profit interest in such fees. Financial Planning Services AFM offers financial planning services, including comprehensive or segmented (limited) financial plans, investment plans, and/or individual consultations regarding a Client’s financial affairs as covered in the Financial Planning Agreement. These services are made available to clients primarily through its investment professionals – individuals associated with AFM as Investment Advisor Representatives (“Advisor Representatives1” or “representative”). Each relationship may be managed by one or more Advisor Representatives, who serve as the primary point of contact for the Client. The design and implementation of a financial plan may begin with the process of gathering data regarding income, expenses, taxes, insurance coverage, retirement plans, wills, trusts, investments and/or other relevant information pertaining to a Client’s overall financial situation. This information is carefully analyzed taking into account a Client’s goals and stated 1 Advisor Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Advisor Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Advisor Representative's Form ADV 2B brochure supplement, a separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive an ADV 2B brochure supplement, they should contact their Advisor Representative or AFM directly.)  objectives, and a series of recommendations and/or alternative strategies will be developed which are designed to achieve optimum overall results. interest in recommending Financial planning Clients are under no obligation to implement any recommendations through AFM. However, AFM will be available to help the Client implement the recommendations, including by providing securities (through Commonwealth) and insurance brokerage where representatives of AFM have a profit interest in such transactions. Transaction and account fees will generally follow the summary schedule included in the Portfolio Management section. AFM has a conflict of implementation of financial planning recommendations through our Advisor Representative as they receive additional compensation, should you choose to implement the plan. Hourly Consultation Services In addition to offering portfolio management and financial planning services, AFM also offers specific administrative and consulting services on an hourly basis. This hourly consultation service may take the form of general investment advice or other forms of consulting arrangements. For consultation services provided by AFM, Client shall agree to pay AFM hourly fees at the rates set forth in the schedule included in the Financial Planning section. Investment recommendations and advice offered by AFM and its IARs do not constitute legal, tax, or accounting advice. Clients should coordinate and discuss the impact of the financial advice they receive from their Advisor Representatives with their attorney and accountant. Clients should also inform their Advisor Representatives promptly of any changes in their financial situation, investment goals, needs, or objectives. Failure to notify AFM of any material changes could result in investment advice not meeting the changing needs of the Client. IRA Rollover Considerations As part of AFM’s financial planning and advisory services, AFM may provide the Client with recommendations and advice concerning Client’s employer retirement plan or other qualified retirement plans. When appropriate, AFM may recommend that Client withdraw assets from Client’s employer-sponsored retirement plan or other qualified retirement accounts and roll the assets over to an Individual Retirement Account (“IRA”) or other retirement savings account to be managed by AFM or a Third-Party Manager that AFM recommends. If the Client elects to roll the assets to an IRA under AFM’s management, AFM will charge the Client an asset-based fee as described in Item 5. This practice presents a conflict of interest because AFM’s representatives have an incentive to recommend a rollover to the Client for the purpose of generating fee-based compensation rather than solely based on the Client’s needs. Client is under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if the Client does complete the rollover, Client is under no obligation to have the Client’s IRA assets managed under AFM’s or a Third-Party Managed Program. Client has the right to decide whether to complete the rollover and the right to consult with other financial professionals. Some employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or  change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, the Client should consider the costs and benefits of each. An employee will typically have four options: 1. Leave the funds in current employer’s (former employer’s) plan. 2. Roll over the funds to a new employer’s retirement plan. 3. Cash out and take a taxable distribution from the plan. 4. Roll the funds into an IRA or other Retirement plan account. Each of these options has advantages and disadvantages. Before making a change, AFM encourages Client to speak with a financial advisor, CPA and/or tax attorney. Before rolling over the Client’s retirement funds to an IRA for AFM to manage or to a Third-Party Managed Program, carefully consider the following. NOTE: This list is not exhaustive. 1. Determine whether the investment options in the Client’s employer’s retirement plan address the Client’s needs or whether other types of investments are needed. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. 2. Client’s current plan may have lower fees than AFM’s fees and/or the Third-Party Manager’s fee combined. a. If Client is interested in investing only in mutual funds, Client should understand the cost structure of the share classes available in your employer’s retirement plan and how the costs of those share classes compare with those available in an IRA. b. Client should understand the various products and services available through an IRA provider and their costs. c. It is likely Client will not be charged a management fee and will not receive ongoing asset management services unless Client elects to have such services if such services are offered. If a Client’s plan offers management services, the fee associated with the service may be more or less than our fee and/or the Third-Party Manager’s fee combined. 3. The Third-Party Manager’s or AFM’s management strategy may have higher risk than the options provided to Client in Client’s plan. 4. Client’s current plan may offer financial advice, guidance, management and/or portfolio options at no additional cost. 5. If Client keeps assets titled in a 401(k) or retirement account, Client could potentially delay Client’s required minimum distribution beyond the required minimum distribution age. 6. Client’s 401(k) may offer more liability protection than an IRA; each state varies. Generally, Federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies; however, there can be exceptions. Client should consult an attorney if Client is concerned about protecting Client’s retirement plan assets from creditors. 7. Client may be able to take out a loan on Client’s 401(k), but not from an IRA.  8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or a home purchase. 9. If Client owns company stock in Client’s retirement plan, Client may be able to liquidate those shares at a lower capital gains tax rate if Client rolls Client’s account to an IRA. 10. Client’s plan may allow Client to hire AFM or another firm as the manager and keep the assets titled in the plan name. It is important that you understand your options, their features and their differences, and decide whether a rollover is best for you. If you have questions, contact us at our main number listed on the cover page of this brochure. Program Choices and Conflicts of Interest Clients should be aware that the compensation to AFM and its Advisor Representatives will differ according to the specific advisory program chosen. This compensation to AFM and it’s Advisor Representatives may be more than the amounts AFM would otherwise receive if a Client participated in another program or paid for investment advice, brokerage, and/or other relevant services separately. As a result of the differences in fee schedules and other sources of compensation that exist among the various advisory programs and services offered by AFM and Advisor Representatives, AFM and Advisor Representatives have a financial incentive to recommend a particular program or service over other programs or services. As discussed in detail in Item 10 (Financial Industry Activities and Affiliations), AFM has chosen to partner with Commonwealth to provide certain services, including but not limited to fee billing and account performance reporting, to AFM and its Clients. For the services it provides, Commonwealth charges financial advisors an administrative fee and asset-based fees. The administrative fee is charged to and paid by Commonwealth rather than the Advisor Representatives and is calculated as a percentage of the total account assets, including cash and money market positions, held by the Clients. The administrative fee covers Commonwealth’s maintenance costs associated with performance reporting, account reconciliation, auditing, and quarterly statements. In the same manner as many advisors offer asset management fee discounts to their larger clients, Commonwealth offers its advisors administrative fee discounts based on their total assets under management. As advisors grow their fee-based business on which Commonwealth provides administrative services, Commonwealth’s economies of scale are shared with its advisors by reducing the percentage amount of administrative fees that would otherwise be charged to the advisors. Advisors are offered discounts on the administrative fee when they reach specified asset levels, starting at $10 million. As the amount of advisors’ client assets in either their own asset management program(s) and/or Commonwealth’s PPS programs grows above certain levels, advisors receive larger percentage discounts to the administrative fees than they would otherwise receive with fewer assets in their own asset management program(s) and/or Commonwealth’s PPS programs.  Additionally, advisors with assets under management of at least $25 million qualify for an increased payout percentage on advisors’ clients’ account management fees, starting at 90.00% and rising to a maximum of 98.00% as their assets under management grow. These discounts in administrative fees and higher payouts for reaching various assets under management (“AUM”) levels present a conflict of interest because they provide a financial incentive for Client’s Advisor Representatives to recommend either their own asset management programs or Commonwealth’s PPS programs over other available managed or wrap account programs that do not offer such discounts or higher payouts to Client’s advisor. Fees and Compensation Clients paying asset based fees will be billed at the end of their specified quarterly schedule based on the ending balance. Clients will be billed pro-rata for any partial calendar quarters. Payment is due no later than 30 days after receipt of the portfolio report. Payments of fees may be made directly by the Client, or by the custodian holding the Client’s funds and securities. However, two criteria must be met when payment is made by the custodian: (1) the Client provides written authorization permitting the fees to be paid directly from the Client’s account held by the independent custodian; and (2) the custodian agrees to send to the Client a statement, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to AFM. AFM’s standard fee schedule is as follows: Assets under management First $5 Million Amounts in excess of $5 Million & up to $10 Million Amounts in excess of $10 Million Maximum Annual Fee 1.00% 0.60% 0.40% Portfolio management services provided to assets held in employer retirement plans are charged an annual fee related to assets and complexity of the relationship up to 1.00%. Note: The above-referenced fee schedule reflects the standard fees charged by AFM, however, fees are negotiable at the discretion of AFM. AFM will aggregate related Client accounts under management for purposes of application of the fees noted above. All fees paid to AFM for portfolio management services are separate and distinct from the fees and expenses charged by mutual funds to their shareholders. These fees and expenses are described in each fund’s prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may also pay an initial or deferred sales charge. A Client could invest in a mutual fund directly, without the services of AFM. In that case, the Client would not pay an investment advisory fee to AFM. However, the Client also would not receive the services provided by AFM, which are designed, among other things, to assist the Client in determining which mutual fund or funds are most appropriate to each Client’s financial condition and objectives. Accordingly, the Client should  review both the fees charged by the funds and the fees charged by AFM to fully understand the total amount of fees to be paid by the Client in order to evaluate the advisory services being received. The fees charged by AFM will not be based on the capital gains or the capital appreciation of any Client portfolio except as described above. A Client’s Investment Advisory Agreement may be cancelled at any time, by either party, for any reason upon receipt of written notice to the other party. Upon termination, any unpaid fees will be due for an amount that is pro-rated based on the number of days that the account was managed. In consideration of financial planning services provided by AFM, the Client shall agree to pay AFM hourly fees as follows: Up to $900 per hour Principals Financial Planners & Financial Advisors Paraplanners $300 per hour $150 per hour These hourly fees are negotiable at the discretion of AFM. General Information on Fees Fees for financial planning and consultation services that are charged on an hourly basis may require fifty percent (50%) of total fee due in advance based on an estimated number of hours of services to be provided. The Client agrees that the remainder of the fee is due upon completion of the services. If it appears that the quoted fees will exceed the estimated amount of time as stated above, AFM will contact the Client to obtain written approval prior to continuing such services. Such hourly fees may be negotiable at the discretion of AFM. Prepayment of fees will not exceed $1200 per client, 6 months in advance. Any balance of prepaid fees shall be refunded to the Client. While AFM makes every effort to obtain account balances directly from the custodian of Client assets, for certain accounts AFM may request that the Client regularly provide copies of account statements. Commonwealth passes on to Clients the securities clearance and settlement fees charged by its clearing broker dealer with a substantial markup that is retained by Commonwealth. Commonwealth adds a markup to the transaction fees assessed by its clearing firm and paid by clients or clients’ advisors to compensate Commonwealth for the cost of its resources utilized in processing the transaction(s) and to generate additional revenue for Commonwealth. AFM typically passes on the securities clearance and settlement fees charged by Commonwealth and its clearing broker/dealer. The maximum charges are as follows:  Transaction Charges Stocks, ETFs, and Closed-End Funds Online order entry (including block trades) Trader assisted $7.951/$4.952 $251 Bonds, CDs, CMOs, and Structured products $301 UITs $201 Options Online order entry (including block trades) Trader assisted Alternative Investments $15 + $1 per contract1 $20 + $1.25 per contract1 $50 $501 Precious Metals Mutual Funds No Transaction Fee Buy Sell $0 $07 $0 Supporting3 $122/$151 $122/$151 $0 Exchange PIP/SWP8 $0 $0 Nonsupporting4,5 $301/$351,6 $301/$351,6 $30/$356 $3 1Plus service fee of $4 for accounts not enrolled in all available e-notification (e-delivery) options (excluding tax documents). 2Account must be enrolled in all available e-delivery options (excluding tax documents). 3Represents more than 500 supporting fund families from which Commonwealth receives revenue-sharing payments from NFS. 4Commonwealth does not receive revenue-sharing payments derived from investments in nonsupporting funds. NFS assesses Commonwealth a transaction surcharge for buys, sells, and exchanges of nonsupporting funds. Commonwealth’s transaction charges are substantially higher for nonsupporting funds to compensate Commonwealth for the absence of revenue sharing and the assessment of a transaction surcharge by NFS. These nonsupporting fund families are CGM, Dodge & Cox, and Vanguard. 5While Commonwealth does receive revenue-sharing payments from NFS that are derived from Dimensional Fund Advisors (DFA) fund assets, these payments are substantially less as a percentage of fund assets than amounts paid by supporting fund families. Commonwealth therefore classifies DFA funds as nonsupporting funds. Unlike other nonsupporting funds, NFS does not assess Commonwealth a transaction surcharge for transactions in DFA funds. Nevertheless, Commonwealth assesses the same surcharges for buy transactions in DFA funds that are noted in footnote 4 for nonsupporting funds. DFA sell transaction surcharges are identified in footnote 3 which are lower than sell transactions for other nonsupporting funds identified in footnote 4. DFA sell transactions processed through the Commonwealth’s trade desk shall be $20. Commonwealth’s receipt of revenue-sharing payments from DFA fund assets (albeit substantially less than from supporting funds), combined with the higher transaction charges for buys generates greater revenue for Commonwealth relative to DFA fund assets than the other nonsupporting funds identified in footnote 4. 6If processed by Commonwealth’s Trade Desk. 7Funds purchased prior to their NTF effective date will still incur a transaction charge. 8Periodic investment plans (PIPs) and systematic withdrawal plans (SWPs) carry a $100 minimum Commonwealth adds a markup to the confirmation fees assessed by its clearing firm and paid by Clients to cover the costs of client mailings, electronic delivery, account verification, and other costs assessed to Commonwealth by its clearing firm and to generate additional revenue for Commonwealth.  In addition to the charges noted above, Clients incur certain charges in connection with certain investments, transactions, and services in your account. In many cases, Commonwealth will receive a portion of these fees and charges or add a markup to the charges clients would otherwise pay to generate additional revenue for Commonwealth. The actual fees and charges that Clients will incur are dependent upon the type of account and the nature and quantity of the transactions that occur, the services that are provided, or the positions that are held in the account. Additional fees and charges that clients will typically pay include, but are not limited to: • Mutual fund or money market 12b-1 fees, sub transfer agent fees, and distributor fees • Mutual fund and money market management fees and administrative expenses • Mutual fund transaction and redemption fees • Certain deferred sales charges on mutual funds purchased or transferred into the account • Other transaction charges and service fees • IRA and qualified retirement plan fees • Other charges that may be required by law • Brokerage account fees and charges Information describing the brokerage fees and charges that are applicable to a Commonwealth brokerage or AFM managed account is provided on Commonwealth’s Schedule of Miscellaneous is available on Commonwealth’s website at Account and Service Fees, which www.commonwealth.com/for-clients in the For Clients section on the right side of the page. AFM advisors may select share classes of mutual funds that pay advisors 12b-1, sub transfer agent, distributor, transaction, and/or revenue-sharing fees when lower-cost institutional or advisory share classes of the same mutual fund exist that do not pay AFM or Client’s advisor additional fees. As a matter of policy, Commonwealth (on AFM’s behalf) credits the mutual fund 12b-1 fees it receives from mutual funds purchased or held in AFM managed accounts back to the client accounts paying such 12b-1 fees. In most cases, mutual fund companies offer multiple share classes of the same mutual fund. Some share classes of a fund charge higher internal expenses, whereas other share classes of a fund charge lower internal expenses. Institutional and advisory share classes typically have lower expense ratios and are less costly for a client to hold than Class A shares or other share classes that are eligible for purchase in an advisory account. Mutual funds that offer institutional share classes, advisory share classes, and other share classes with lower expense ratios are available to investors who meet specific eligibility requirements that are described in the mutual fund’s prospectus or its statement of additional information. These eligibility requirements include, but may not be limited to, investments meeting certain minimum dollar amounts and accounts that the fund considers qualified fee-based programs. The lowest-cost mutual fund share class for a fund may not be offered through our clearing firm or made available by AFM for purchase within our managed accounts. Clients should never assume that they will be invested in the share class with the lowest possible expense ratio or cost.  AFM urges Clients to discuss with their Advisor Representatives whether lower-cost share classes are available in their program account. Clients should also ask their Advisor Representatives why the funds or other investments that will be purchased or held in their managed account are appropriate for them in consideration of their expected holding period, investment objective, risk tolerance, time horizon, financial condition, amount invested, trading frequency, the amount of the advisory fee charged, whether the Client will pay transaction charges for fund purchases and sales, whether clients will pay higher internal fund expenses in lieu of transaction charges that could adversely affect long-term performance, and relevant tax considerations. Client’s Advisor Representative may recommend, select, or continue to hold a fund share class that charges you higher internal expenses than other available share classes for the same fund. The purchase or sale of transaction-fee (“TF”) funds available for investment through AFM will result in the assessment of transaction charges to you, Client’s advisor, or Commonwealth. Although no-transaction-fee (“NTF”) funds do not assess transaction charges, most NTF funds have higher internal expenses than funds that do not participate in an NTF program. These higher internal fund expenses are assessed to investors who purchase or hold NTF funds. Depending upon the frequency of trading and hold periods, NTF funds may cost you more, or may cost Commonwealth or Client’s advisor less, than mutual funds that assess transaction charges but have lower internal expenses. In addition, the higher internal expenses charged to Clients who hold NTF funds will adversely affect the long-term performance of their accounts when compared to share classes of the same fund that assess lower internal expenses. The existence of various fund share classes with lower internal expenses that AFM may not make available for purchase in its managed account programs presents a conflict of interest between Clients and AFM. A conflict of interest exists because AFM and Advisor Representatives have a greater incentive to make available, recommend, or make investment decisions regarding investments that provide additional compensation to AFM that cost clients more than other available share classes in the same fund that cost you less. For those advisory programs that assess transaction charges to clients or to AFM or the advisor, a conflict of interest exists because AFM and Client’s advisor have a financial incentive to recommend or select NTF funds that do not assess transaction charges but cost you more in internal expenses than funds that do assess transaction charges but cost you less in internal expenses. Other Forms of Compensation Clients should be aware that, when assets are invested in shares of mutual funds or variable insurance products, Clients will pay investment advisory fees to AFM for their advisory services in connection with the investments. In addition to the payments received by AFM and Advisor Representatives, Clients will also typically pay management fees and other fees charged by the investment company, alternative investment, or insurance product sponsor themselves. Clients may be able to invest directly in the investment company, alternative investment, or insurance product without incurring the investment advisory fees charged by AFM. If a Client’s assets are invested in a fee-based annuity, the Client will pay both the direct management fee to AFM and his or her Advisor Representatives for the advisory services provided by AFM and the advisor in connection with that investment and, indirectly, the management and other fees charged by the underlying annuity investment options, as well as the charges assessed by the insurance company for the product. Of course, Clients should also be aware of the tax implications of investing, as  well as of the existence of deferred sales charges or redemption fees charged by some product sponsors for positions the client subsequently sells in AFM managed accounts. AFM and Advisor Representatives receive service fees and other compensation from investment product sponsors and distributors when they make recommendations or investment decisions for you. These fees and compensation include, but are not limited to, mutual fund and money market 12b-1 and sub transfer agent fees, mutual fund transaction fees, due diligence fees, marketing reimbursements or reallowances, or other transaction or service fees. This additional compensation presents a conflict of interest because AFM and Advisor Representatives have a greater incentive to make available, recommend, or make investment decisions regarding investments for your account that provide additional compensation to Advisor Representatives or AFM over other investments that do not provide additional compensation to Advisor Representatives or AFM. Clients are urged to read and consider the contents of this Brochure carefully and to inquire about AFM’s and the advisor’s various sources of compensation and conflicts of interest in making a fair and reasonable assessment of the fees and charges clients will pay for the services rendered by AFM and their Advisor Representatives. Further information about AFM’s and Advisor Representatives’ sources of compensation and conflicts of interest is provided in this Brochure. Information regarding fees and charges assessed to you by the investment products you purchase is available in the appropriate. For California Residents: Subsection (j) of Rule 260.238 of the California Code of Regulations requires that all investment advisers disclose to their advisory clients that lower fees for comparable services may be available from other sources. For District of Columbia Residents: Section 1811.1 Subsection (j) of the D.C. Rules requires AFM to disclose that lower fees for comparable services may be available from other sources. Subsection (k) requires AFM to indicate that all material conflicts of interest that relate to the advisor or to any of its employees, and that would cause AFM not to render unbiased and objective advice, have been disclosed to the Client in writing via the disclosure provided in this Form ADV Part 2. For Massachusetts Residents: Massachusetts General Law Section 203A requires disclosure that information about the disciplinary history and the registration of RIA NAME and its associated persons may be obtained by contacting the Public Reference Branch of the SEC at 202.942.8090, or by contacting the Massachusetts Securities Division at One Ashburton Place, 17th Floor, Boston, MA 02108 or at 617.727.3548. Performance Based Fees and Side-by-Side Management AFM does not charge any performance fees. Some investment advisers experience conflicts of interest in connection with the side-by-side management of accounts with different fee structures. However, these conflicts of interest are not applicable to AFM. Types of Clients AFM provides financial planning and portfolio management services. These services are designed  to be most beneficial to high income, high net worth individuals. The typical financial planning Client who benefits most from the comprehensive financial planning services the advisory personnel provide is an individual or family whose net worth is in excess of $3,000,000. A minimum of $1,000,000 under management is recommended for portfolio management services. In certain unusual circumstances, fees and account minimums may be negotiable at the sole discretion of AFM. Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that investors should be sure they understand and should be prepared to bear. AFM’s principals and paraplanners work together to conduct fundamental analysis on all securities recommended for Client accounts. It is important to note that there is no investment strategy that will guarantee a profit or prevent loss. This analysis varies depending on the security in question. For stocks and bonds the analysis generally includes a review of: • The issuer’s management; • The amount and volatility of past profits or losses; • The issuer’s assets and liabilities, as well as any material changes from historical norms; • Prospects for the issuer’s industry, as well as the issuer’s competitive position within that industry; and • Any other factors considered relevant. For mutual funds and the analysis generally includes a review of: • The fund’s management team; • The fund’s historical risk and return characteristics; • The fund’s exposure to sectors and individual issuers; • The fund’s fee structure; and • Any other factors considered relevant. AFM’s Investment Committee is led by its principals. The Investment Committee generally meets Investments are evaluated monthly to discuss existing and prospective investments. independently, as well as in the context of clients’ existing holdings and sector exposures.  AFM primarily invests for relatively long time horizons, often for several years or more. However, market developments could cause AFM to sell securities more quickly. Risk of Loss – General All investing involves a risk of loss and the investment strategy offered by AFM could lose money over short or long periods. Performance could be negatively impacted by a number of different market risks including, but not limited to, portfolio management techniques used by AFM may not produce the desired results. This could cause accounts to decline in value. In addition, AFM may rely on information that turns out to be wrong. AFM selects investments based, in part, on information provided by issuers to regulators or made directly available to AFM by the issuers or other sources. AFM is not always able to confirm the completeness or accuracy of such information, and in some cases, complete and accurate information is not available. Incorrect or incomplete information increases risk and can result in losses. Market Risk - The prices of, and the income generated by, the common stocks, bonds, and other securities you own may decline in response to certain events taking place around the world, including those directly involving the issuers; conditions affecting the general economy; overall market changes; local, regional, or global political, social, or economic instability; governmental or governmental agency responses to economic conditions; and currency, interest rate, and commodity price fluctuations. Stock Market Risk - Stock market risk is the possibility that stock prices overall will decline over short or extended periods. Markets tend to move in cycles, with periods of rising prices and periods of falling prices. Investing in small- and medium-sized companies involves greater risk than is customarily associated with more established companies. Stocks of such companies may be subject to more volatility in price than larger company securities. Foreign Securities Risk - Foreign securities are subject to the same market risks as U.S. securities, such as general economic conditions and company and industry prospects. However, foreign securities involve the additional risk of loss due to political, economic, legal, regulatory, and operational uncertainties; differing accounting and financial reporting standards; limited availability of information; currency conversion; and pricing factors affecting investment in the securities of foreign businesses or governments. Interest Rate Risk - Bonds also experience market risk as a result of changes in interest rates. The general rule is that if interest rates rise, bond prices will fall. The reverse is also true: if interest rates fall, bond prices will generally rise. A bond with a longer maturity (or a bond fund with a longer average maturity) will typically fluctuate more in price than a shorter term bond. Because of their very short-term nature, money market instruments carry less interest rate risk. The prices of, and the income generated by, most debt and equity securities will most likely be affected by changing interest rates and by changes in the effective maturities and credit ratings of these securities. For example, the prices of debt securities generally decline when interest rates rise and increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem,  “call,” or refinance a security before its stated maturity date, which would typically result in having to reinvest the proceeds in lower-yielding securities. Credit Risk - Bonds and bond mutual funds are also exposed to credit risk, which is the possibility that the issuer of a bond will default on its obligation to pay interest and/or principal. U.S. Treasury securities, which are backed by the full faith and credit of the U.S. Government, have limited credit risk, while securities issued or guaranteed by U.S. Government agencies or government-sponsored enterprises that are not backed by the full faith and credit of the U.S. Government may be subject to varying degrees of credit risk. Corporate bonds rated BBB or above by Standard & Poor's are generally considered to carry moderate credit risk. Corporate bonds rated lower than BBB are considered to have significant credit risk. Of course, bonds with lower credit ratings generally pay a higher level of income to investors. Debt securities are also subject to credit risk, which is the possibility that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default. Liquidity Risk - Liquidity risk exists when a particular security is difficult to trade. A mutual fund’s investment in illiquid securities may reduce the returns of the mutual fund because the mutual fund may not be able to sell the assets at the time desired for an acceptable price, or might not be able to sell the assets at all. The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at all. Certain structured products, interval funds, and alternative investments are less liquid than securities traded on an exchange, and you should be aware of the fact that you may not be able sell these products outside of prescribed time periods. You should consult your advisor prior to purchasing products considered illiquid and in instances where changes in your financial situation and objectives may increase your need for liquidity. Call Risk - Many fixed income securities have a provision allowing the issuer to repay the debt early, otherwise known as a "call feature." Issuers often exercise this right when interest rates are low. Accordingly, holders of such callable securities may not benefit fully from the increase in value that other fixed income securities experience when rates decline. Furthermore, after a callable security is repaid early, a mutual fund would reinvest the proceeds of the payoff at current interest rates, which would likely be lower than those paid on the security that was called. Objective/Style Risk - All of the mutual funds and investment managers are subject, in varying degrees, to objective/style risk, which is the possibility that returns from a specific type of security in which a mutual fund or manager invests will trail the returns of the overall market. U.S. Government Agency Securities Risk - Securities issued by U.S. Government agencies or government-sponsored entities may not be guaranteed by the U.S. Treasury. If a government- sponsored entity is unable to meet its obligations, the securities of the entity will be adversely impacted. Time horizon and longevity risk: Time horizon risk is the risk that your investment horizon is shortened because of an unforeseen event (e.g., the loss of your job). This may force you to sell  investments that you were expecting to hold for the long term. If you must sell at a time that the markets are down, you may lose money. Longevity risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired or nearing retirement. Risk of Investing Real Estate Investment Trusts (REITs) - When profits, revenues, or the value of real estate property owned by REITs decline or fail to meet market expectations, REIT stock prices may decline as well. Therefore, a Fund is subject to the risks associated with investing in real estate (any of which could cause the value of a REIT's stock price to decline), which include, without limitation: possible declines in the value of real estate; adverse general and local economic conditions; possible lack of availability of, or high cost of, financing; overbuilding in a given market; changes in interest rates; and environmental problems. In addition to risks related to investments in real estate generally, investing in REITs involves certain other risks related to their structure and focus including, without limitation, the following: dependency upon management skills; limited diversification; the risks of locating and managing financing for projects; possible default by borrowers; the costs and potential losses of self-liquidation of one or more holdings; and, in many cases, relatively small market capitalization, which may result in less market liquidity and greater price volatility. Investing in REITs also involves risks related to the heavy cash flow dependency of REITs and the possibility that a REIT may fail to maintain applicable exemptions under U.S. and foreign securities and tax laws. Tax considerations: Our strategies and investments may have unique and significant tax implications. Unless specifically agreed otherwise, and in writing, however, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, it is strongly recommended that you consult with a tax professional regarding the investing of your assets. Custodians and broker/dealers must report the cost basis of equities acquired in client accounts. Your custodian will default to the first in, first out (“FIFO”) accounting method for calculating the cost basis of your equity investments and average-cost for mutual fund positions. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and Commonwealth will alert your account custodian of your individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Margin transactions - Securities transactions in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan, inherently have more risk than cash purchases. If the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a “margin call.” An investor’s overall risk in accounts utilizing margin includes the amount of money invested plus the amount that was loaned to them. Pledging Assets - Pledging assets in an account to secure a loan involves additional risks. The bank holding the loan has the authority to liquidate all or part of the securities at any time without prior notice in order to maintain required maintenance levels, or to call the loan at any time, and this may cause you to sell assets and realize losses in a declining market. In addition, because of  collateral requirements imposed by the bank, investment decisions for the account may be restricted. These restrictions, or a forced liquidation, may interfere with your long-term investment goals and/or result in adverse tax consequences. Cybersecurity - AFM and its service providers are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data from both intentional cyber-attacks and hacking by other computer users as well as unintentional damage or interruption that, in either case, can result in damage or interruption from computer viruses, network failures, computer and telecommunications failures, infiltration by unauthorized persons and security breaches, usage errors by their respective professionals. A cybersecurity breach could expose both AFM and its clients to substantial costs. While AFM has established policies and procedures as well as other controls that seek to prevent cybersecurity breaches, there are inherent limitations in such controls and policies and procedures, including the possibility that certain risks have not been identified. Furthermore, AFM cannot control the cybersecurity plans, strategies, systems, policies and procedures put in place by other service providers. Business, Terrorism and Catastrophe Risks - Clients will be subject to the risk of loss arising from exposure that it may incur, indirectly, due to the occurrence of various events, including hurricanes, earthquakes, and other natural disasters, terrorism and other catastrophic events such as a pandemic. These catastrophic risks of loss can be substantial and could have a material adverse effect on AFM’s business as well as investments recommended by AFM. Recommendation of particular types of securities - We will recommend various types of securities and do not primarily recommend one particular type of security over another since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it, and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. In very general terms, however, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. Descriptions of the types of securities we may recommend to you and some of their inherent risks are provided below: • Money market funds: A money market fund is technically a security, and, as such, there is a risk of loss of principal, although it is generally rare. In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation (“FDIC”) insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or down. If it goes up, that may result in a positive outcome. If it goes down, however, and you earn less than you expected to, you may end up needing more cash. A final risk you are taking with money market funds has to do with inflation. Because money market funds are considered to be safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods of time, inflation can eat away at your returns.  • Municipal securities: Municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to, the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same amount of interest or yield to maturity. • Bonds: Also known as corporate debt securities, bonds are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default, when the bond is set to mature, and whether the bond can be “called” prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. • Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as “equities” or “stocks”). In very broad terms, the value of a stock depends on the financial health of the company issuing it. Stock prices, however, can be affected by many other factors, including, but not limited to, the class of stock (e.g., preferred or common), the health of the market sector of the issuing company, and the overall health of the economy. In general, larger, more well-established companies (i.e., large-caps) tend to be safer than smaller start-up companies (i.e., small-caps), but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. • Mutual funds and ETFs: Mutual funds and ETFs are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund’s investments in accordance with the fund’s investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) 29 rather than balancing the fund with different types of securities. ETFs differ from mutual funds in that they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are “no load,” meaning there’s no fee to buy into or sell out of the fund, other types of mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be “closed-end” or “open-end.” Open-end mutual funds continue to allow new investors indefinitely, whereas closed-end funds have a fixed number of shares to sell, which can limit their availability to new investors. • Variable annuities: A variable annuity is a form of insurance where the seller or issuer (typically an insurance company) makes a series of future payments to a buyer (annuitant) in exchange for the immediate payment of a lump sum (single-payment annuity) or a series of regular payments (regular-payment annuity). The payment stream from the issuer to the annuitant has an unknown duration based principally upon the date of death of the  annuitant. At this point, the contract will terminate, and the remainder of the funds accumulated will be forfeited unless there are other annuitants or beneficiaries in the contract. Annuities can be purchased to provide an income during retirement. Unlike fixed annuities that make payments in fixed amounts or in amounts that increase by a fixed percentage, variable annuities pay amounts that vary according to the performance of a specified set of investments, typically bond and equity mutual funds. Many variable annuities typically impose asset-based sales charges or surrender charges for withdrawals within a specified period. Variable annuities may impose a variety of fees and expenses, in addition to sales and surrender charges, such as mortality and expense risk charges, administrative fees, underlying fund expenses, and charges for special features, all of which can reduce the return. • Real estate: Real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. In fact, real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. The asset class still bears a considerable amount of market risk, however. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or by property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. • Limited partnerships: A limited partnership is a financial affiliation that includes at least one general partner and a number of limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner has management authority and unlimited liability. The general partner runs the business and, in the event of bankruptcy, is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks is dependent on the nature of the partnership and disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities; however, like privately placed limited partnerships, their tax treatment is under a different tax regime from equities. You should speak to your tax adviser in regard to their tax treatment. • Options contracts: Options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (i.e., the expiration date). The two types  of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope that the stock will increase substantially before the option expires. A put gives the holder 30 the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the price of the stock will fall before the option expires. Selling options is more complicated and can be even riskier. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. • Structured products: A structured product is generally a prepackaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and, to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. In addition to a fixed maturity, they have two components: a note and a derivative. The derivative component is often an option. The note provides for periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell to the investor the security or securities at a predetermined price. Other products use the derivative component to provide for a call option written by the investor that gives the buyer of the call option the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a “principal guarantee” function, which offers protection of principal if held to maturity. These products are not always FDIC insured, however; they may only be insured by the issuer and, thus, have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves a number of risks, including, but not limited to, fluctuations in the price, level, or yield of underlying instruments; interest rates; currency values; and credit quality. They also involve the risk of substantial loss of principal, limits on participation in any appreciation of the underlying instrument, limited liquidity, credit risk of the issuer, conflicts of interest, and other events that are difficult to predict Investments may also be affected by currency controls; different accounting, auditing, financial reporting, disclosure, and regulatory and legal standards and practices; expropriation (occurs when governments take away a private business from its owners); changes in tax policy; greater market volatility; different securities market structures; higher transaction costs; and various administrative difficulties, such as delays in clearing and settling portfolio transactions or in receiving payment of dividends. These risks may be heightened in connection with investments in developing countries. Investments in securities issued by entities domiciled in the United States may also be subject to many of these risks. Any of the common risks described above could adversely affect the value of your portfolio and account performance, and you can lose money. Even though these risks exist, AFM and your Advisor Representative will still earn the fees and other compensation described in this Brochure. Clients should carefully consider the risks of investing and the potential that they may lose  principal while AFM and your Advisor Representative continue to earn fees and other forms of compensation. Your investments are not bank deposits and are not insured or guaranteed by the FDIC or any other governmental agency, entity, or person, unless otherwise noted and explicitly disclosed as such, and as such may lose value. Disciplinary Information AFM and its employees have not been involved in any legal or disciplinary events in the past 10 years that would be material to a client’s evaluation of the company or its personnel. Other Financial Industry Activities and Affiliations Advisory representatives of AFM are Registered Representatives of Commonwealth, member FINRA, SIPC. Portfolio management Clients must utilize the services of Commonwealth. All prospective and existing Clients are advised of this affiliation. Financial planning and hourly consultation Clients are under no obligation to purchase or sell securities through these related persons; however, if they choose to implement a financial plan, commissions and/or additional investment advisory fees will be earned in addition to any fees paid for financial planning services. These commissions may be higher or lower at Commonwealth than at other broker-dealers, and investment advisory fees may be higher or lower at AFM than at other investment advisers. AFM’s Advisor Representatives have a conflict of interest in recommending that Clients purchase securities and/or insurance related products through Commonwealth in that the higher their production with Commonwealth the greater potential for obtaining a higher pay-out on commissions earned. Further, Advisor Representatives are restricted to only offering those products and services that have been reviewed and approved for offering to the public through Commonwealth. AFM’s Advisor Representatives are also licensed insurance agents and offer various insurance products for which they will be paid a commission. Advisors spend approximately 5% of their time offering insurance products. Should you choose to purchase an insurance product on which our Advisor Representative is paid a commission, there will be no advisory fee associated with the product. The remainder of the advisor’s time is spent acting in the capacity of an investment adviser representative for AFM. AFM’s Chairman Emeritus, Alexandra Armstrong, owns and operates a book publishing company named “On Your Own Publishing Company LLC.” The Publishing Company has published Ms. Armstrong’s books, “On Your Own, A Widow’s Guide to Emotional and Financial Well-Being, 6th Edition.” and “Your Next Chapter: A Woman’s Guide to A Successful Retirement”. This activity does not conflict with Ms. Armstrong’s role at AFM. AFM has approved a number of advisory programs for its Clients. Each program may involve different custodial accounts, administrative and fee arrangements. As described in Item 4, AFM offers clients the investment advisory programs and/or services of Commonwealth Financial  Network. Should Clients be offered one or more of these programs, Clients are advised that AFM, Advisor Representatives and Commonwealth will receive compensation pursuant to your participation in Commonwealth’s programs. The advisory fees associated with these programs may be higher or lower than advisory fees for similar programs with other investment advisors. AFM, Client’s advisor and Commonwealth have a conflict of interest in recommending that you participate in these programs given the compensation that will be received. AFM performs reasonable due diligence on Commonwealth on both an initial and ongoing basis. AFM attempts to mitigate this conflict by providing Client with this disclosure document and noting that Client may be able to receive similar services for less cost from other providers. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, as amended, AFM has adopted a Code of Ethics (“COE”) that governs a number of conflicts of interest AFM has when providing our advisory services to Client. AFM’s Code of Ethics is designed to ensure that AFM meets its fiduciary obligations to Client and to foster a culture of compliance throughout AFM. The COE is designed to help AFM detect and prevent violations of securities laws and to help ensure that AFM keeps Client’s interests first. AFM distributes its COE to each supervised person at AFM at the time of his or her initial affiliation with AFM; AFM makes sure it remains available to each supervised person for as long as he or she remains associated with AFM; and AFM ensures that updates to its COE are communicated to each supervised person as changes are made. AFM’s COE sets forth certain standards of conduct and addresses conflicts of interest between AFM, and its employees, agents, advisors, and advisory clients. AFM and its employees may also buy and sell the same securities that may be recommended to Clients. If the possibility of a conflict of interest occurs, the Client's interest will prevail. It is the policy of AFM that priority will always be given to the Client's orders over the orders of an employee of AFM. However, when executing bunched trades, AFM or its employees can contemporaneously participate in these types of trades. To avoid any potential conflicts of interest involving personal trades, AFM’s COE includes personal trading reporting and review policies and procedures and insider trading policies and procedures. AFM’s COE requires, among other things, that employees: • Act with integrity, competence, diligence, respect, and in an ethical manner with the public, Clients, prospective Clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets; • Place the integrity of the investment profession, the interests of Clients, and the interests of Advisor above one’s own personal interests; • Adhere to the fundamental standard that you should not take inappropriate advantage of your position; • Avoid or disclose any actual or potential conflict of interest;  • Conduct all personal securities transactions in a manner consistent with this policy; • Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities; • Practice and encourage others to practice in a professional and ethical manner that will reflect credit on yourself and the profession; • Promote the integrity of, and uphold the rules governing, capital markets; • Maintain and improve your professional competence and strive to maintain and improve the competence of other investment professionals. • Comply with applicable provisions of the federal securities laws. AFM’s COE also requires employees to: 1) pre-clear certain personal securities transactions, 2) report personal securities transactions on a quarterly basis, and 3) provide AFM with a detailed summary of certain holdings and securities accounts (both initially upon commencement of employment and annually thereafter) over which such employees have a direct or indirect beneficial interest. A copy of AFM’s COE is available upon request. Brokerage Practices When deemed appropriate, AFM will seek to aggregate transactions for multiple Clients such that all participating clients receive an average price. Non-discretionary Clients may forgo the ability to participate in such block trades if they are unavailable to consent to the transaction. Investment or Brokerage Discretion As disclosed previously in this brochure, our Advisor Representatives are dually registered with Commonwealth Financial Network. Commonwealth policy restricts its advisors from conducting securities transactions away from Commonwealth unless Commonwealth provides the Advisor Representatives with written authorization. Therefore, Clients are advised that our Advisor Representatives are substantially always limited to conducting securities transactions through Commonwealth and its clearing firms, National Financial Services LLC (“NFS”) and Pershing. Substantially all of AFM’s clients must select Commonwealth as the broker/dealer of record and NFS as the clearing firm for their managed accounts. In all cases, the account custodian will be identified in the respective managed account client agreement. Client transactions will be charged according to Commonwealth's then-current commission schedule and clients may pay higher commission rates and other fees than otherwise available. The Client may be assessed transaction or other fees charged by Commonwealth, custodians and/or product sponsors, in addition to normal and customary commissions, all of which are fully disclosed to the client. These fees and expenses are separate and distinct from any fee(s) charged by AFM. This additional compensation received by Commonwealth creates a conflict of interest. Additionally, by using Commonwealth as the broker/dealer for AFM’s managed account program(s), we may be unable to achieve most favorable execution of client transactions, which may cost clients more money. AFM attempts to mitigate this conflict of interest by engaging in a regular review of our relationship with Commonwealth to ensure that the costs  incurred are reasonable in comparison to industry norms, and by advising our clients that you are not obligated to open an account with us or Commonwealth; you may open an account and implement advice provided by AFM with the firm of your choice. Our Clients do not generally have the option to direct securities brokerage transactions to other broker/dealers or other account custodians. If, however, a Client should request, and Commonwealth approve, the use of a broker/dealer other than NFS or Pershing for securities transaction execution, the Client should be aware that AFM will generally be unable to negotiate commissions or other fees and charges for the client’s account, and we would not be able to combine the client’s transactions with those of other Clients purchasing or selling the same securities (“batched trades”), as discussed further below. As a result, AFM would be unable to ensure that the client receives “best execution” with respect to such directed trades. AFM may also be unable to provide timely monitoring of transaction activity or provide the client with quarterly performance reporting. When portfolio management Clients agree to utilize the brokerage services of Commonwealth or its representatives, including AFM advisory personnel, discretion may be used by a related person with regard to commissions paid. The commissions paid by AFM's Client for stock and bond transactions may be more or less than commissions charged by other brokers. However, in all such cases, AFM will cause the Client to pay only fair and reasonable commissions. AFM personnel do not earn a profit on the commissions charged to portfolio management clients by Commonwealth or any other broker-dealer. As noted above, the AFM’s Advisor Representatives are also registered representatives of Commonwealth. Accordingly, AFM recommends Commonwealth and executes Client transactions through Commonwealth. AFM is not in a position to, and will not, seek to negotiate commission rates with Commonwealth because AFM’s Advisor Representatives are registered representatives of Commonwealth and receive certain economic benefits for Client transactions executed through Commonwealth. Financial planning Clients should be aware that brokerage commissions and commission equivalent rates may, from time to time, be individually negotiated with the AFM’s Advisor Representatives acting as the registered representatives of Commonwealth. Thus, Clients may be charged different commissions and commission equivalents than those charged other Clients for identical transactions. Commissions paid by Client may be higher than those of a discount broker. However, it is believed that the executions and service rendered through Commonwealth will be competitive with that of most stock brokerage firms. Financial planning and hourly consultation Clients are free to execute securities transactions through any broker-dealer. However, if the Client elects to implement the investment advice using the services of the AFM, then the broker-dealer used must be Commonwealth. Commonwealth offers AFM and its Advisor Representatives one or more forms of financial benefits based on our Advisor Representatives’ total AUM held at Commonwealth or financial  assistance for advisory representatives transitioning from another firm to Commonwealth. The types of financial benefits that our Advisor Representatives may receive from Commonwealth include, but are not limited to, forgivable or unforgivable loans, enhanced payouts, and discounts or waivers on transaction, platform, and account fees; technology fees; research package fees; financial planning software fees; administrative fees; brokerage account fees; account transfer fees; and the cost of attending conferences and events. The enhanced payouts, discounts, and other forms of financial benefits that Advisor Representatives may receive from Commonwealth are a conflict of interest, and provide a financial incentive for advisory representatives to select Commonwealth as broker/dealer for your accounts over other broker/dealers from which they may not receive similar financial benefits. We attempt to mitigate this conflict of interest by disclosing the conflict in this Brochure and engaging in a regular review of our relationship with Commonwealth to ensure the relationship continues to be appropriate in all respects for our firm’s Clients. Best Execution Advisor attempts to achieve best execution for its Clients. The best net price is an important factor in brokerage decisions, but other factors may also enter into this decision. These include: AFM’s knowledge of negotiated commission rates currently available, as well as other transaction costs; the nature of the security being traded; the size of the transaction; the desired timing of the trade; the activity existing and expected in the market for the particular security; confidentiality; execution, clearance, and settlement capabilities and costs; and other information available at the time of execution. Research for AFM is provided in part from Commonwealth and in part from the AFM's choice of other sources, including, but not limited to: Argus Research, Morningstar, Standard & Poor’s, and Value Line. Information gained from these sources is used to advise all the Firm's accounts, including those not traded through Commonwealth, despite the fact that AFM is able to pay reduced fees for these services because of its relationship with Commonwealth. Core Account Sweep Programs (“CASPs”) Through our relationship with Commonwealth, our firm has access to a core account sweep program (“CASP”). CASP is the core account investment vehicle for eligible accounts used to hold cash balances while awaiting reinvestment. The cash balance in your eligible accounts will be deposited automatically or “swept” into interest-bearing FDIC-insurance eligible deposit accounts at one or more FDIC-insured financial institutions The interest rates for your eligible accounts may be obtained from at www.commonwealth.com/clients/deposit-sweep-program.aspx. Specific features and account eligibility of CASP are further explained in the Disclosure Document provided to clients that participate in CASP. A current version of the CASP Disclosure Document is available at https://www.commonwealth.com/for-clients/disclosure/core-account-sweep- programs. Clients should note that, though the default options for cash held in accounts are the core account investment vehicles, clients may at any time seek higher yields in other available investment options. Commonwealth keeps a portion of the interest paid by the bank(s) participating in CASP as a fee for providing bank sweep services. This fee reduces the rate of interest you receive on your cash in the bank sweep program. AFM receives no financial benefits from the CASP  program. We encourage our clients to review CASP program details to understand how Commonwealth and the program banks get paid for the sweep program and to discuss other available investment options should you wish to do so. Money Market Accounts For Client assets awaiting reinvestment in money market funds rather than the CASP, the Fidelity Government Money Market Capital Reserves is available to clients in accounts held at NFS. This fund pays Commonwealth up to 0.45% (45 basis points). Clients may instruct their advisor to manually select a Money Class money fund rather than the default Reserve Class money fund at any time. NTF Program Additionally, NFS offers an NTF program composed of no-load mutual funds which AFM does not participate in. Participating mutual fund sponsors pay a fee to NFS to participate in this program, and a portion of this fee is shared with Commonwealth. None of these additional payments is paid to AFM or any advisors who sell these funds. NTF mutual funds may be purchased within an investment advisory account at no charge to the client. Clients, however, should be aware that funds available through the NTF program often contain higher internal expenses than mutual funds that do not participate in the NTF program. Commonwealth’s receipt of a portion of the fees associated with the NTF program creates a conflict of interest because Commonwealth has an incentive to make available those products that provide such compensation to NFS and Commonwealth over those mutual fund sponsors that do not make such payments to NFS and Commonwealth. While AFM is does not receive additional compensation from NFS or Commonwealth based on the particular investment (potentially including one or more NTF funds), AFM’s menu of investment options is limited to investments made available by Commonwealth. Thus, clients may be impacted by the conflict of interest previously described in this paragraph. As stated previously, AFM regularly evaluates our relationship with Commonwealth to ensure it remains appropriate for the firm and our clients. The investment advisory services provided by AFM may cost the client more or less than purchasing similar services separately. Clients should consider whether the appointment of Commonwealth as the sole broker/dealer may result in certain costs or disadvantages to the client as a result of possibly less favorable executions. Factors to consider include the type and size of the account and the client’s historical and expected account size or number of trades. Review of Accounts Accounts are reviewed quarterly, semi-annually or annually as specified by contract. A special review of a Client's account may be triggered by changes in tax law, economic climate, or market conditions. A review may be initiated by a Client inquiry due to personal changes in his/her financial affairs. Each account is reviewed on a regular basis by the person supervising the account. There are several reviewers, each of whom is responsible for his/her own Client's accounts. Reports to Clients are individualized, therefore the nature and frequency are determined by client need and the services offered. However, most of the portfolio management Clients of AFM will receive quarterly reports summarizing the investment performance of their account(s), in addition  to annual reports containing tax-related information. Clients also receive monthly, quarterly, and/or annual statements from investment companies, product sponsors, broker-dealers, and custodians, as applicable. Financial planning Clients receive no reports other than the financial plan and any other mutually agreed-upon reports. Client Referrals and Other Compensation AFM from time to time enters into written solicitor agreements with employees of AFM and pays a portion of the fees to the employee based upon fees received by AFM from the referred client relationship. AFM does not charge Clients referred by an employee a fee higher or lower than it charges to other similarly situated Clients who were not referred to by a solicitor. Other than the previously described products and services that AFM receives from Commonwealth, AFM does not receive any other economic benefits from non-clients in connection with the provision of investment advice to Clients. As noted above, AFM may recommend that Clients purchase investments including but not limited to various mutual funds, REITs and other equities. These companies can pay for AFM’s Advisor Representatives to attend conferences or meeting which they sponsor. The purpose of attending these events are research related, although there may be an entertainment component to these events. AFM maintains internal procedures, such as oversight by its investment committee, to ensure that this conflict does not impact the recommendations provided to Clients. Custody AFM does not maintain physical custody of your assets. Under SEC rules, we are deemed to have custody of Clients assets if a Client authorize us to instruct their account custodian to deduct advisory fees directly from their account, or if a Client provides us with authorization to transfer funds from their account to a third party. AFM maintains a relationship with Commonwealth who, as described previously in this Brochure, maintains a primary clearing relationship for the execution of client transactions with NFS as the account custodian, and a secondary clearing relationship for the execution of client transactions with Pershing as the account custodian. Substantially all of our advisory Clients must select Commonwealth as the broker/dealer of record and NFS as the clearing firm for their managed accounts. In all cases, the name and address of the account custodian will be identified in the respective managed account client agreement. Clients who establish a managed account with AFM utilizing Commonwealth as the broker/dealer of record will receive custodial account statements directly from the respective custodian that holds those assets, such as NFS, Pershing, or a direct product sponsor. Clients should carefully review the statements they receive from their account custodians and should promptly report material discrepancies to AFM. Investment Discretion AFM renders investment advice to the vast majority of its managed account clients on a discretionary basis, pursuant to written authorization granted by the Client to AFM and Advisor  Representatives. This authorization grants to AFM and Advisor Representatives the discretion to buy, sell, exchange, convert, or otherwise trade in securities and/or insurance products, and to execute orders for such securities and/or insurance products with or through any distributor, issuer, or broker/dealer as AFM or Advisor Representatives may select. Advisor Representatives may, without obtaining your consent, determine which products to purchase or sell for your managed account, as well as when to purchase or sell such products, and the prices to be paid. Neither AFM nor Advisor Representatives, however, is granted authority to take possession of Client assets or direct the delivery of Client assets to anywhere other than the Client’s address of record. A Client may terminate this discretionary authorization at any time by providing written notice to AFM. Clients may impose reasonable restrictions on their managed account, including, but not limited to, the type, nature, or specific names of securities to be bought, sold, or held in their managed account, as well as the type, nature, or specific names of securities that may not be bought, sold, or held in their managed account. Clients generally grant AFM and their Advisor Representative discretionary trading authority over their managed accounts. If not specifically requested otherwise by the Client, discretionary authority will be established at the time the account is first opened. Our managed account program does, however, permit the Client to choose to have AFM and the Advisor Representative provide investment advice and recommendations to the Client on a nondiscretionary basis. Clients who wish to receive advice with respect to their managed account on a nondiscretionary basis would need to execute an amendment to modify the Client agreement to be nondiscretionary. Clients may request a copy of the nondiscretionary amendment form from their Advisor Representative if they desire to exercise this option. In performing any of its services, AFM shall not be required to verify any information received from Client or from Client’s other professionals and is expressly authorized to rely thereon. If requested by Client, AFM may recommend the services of other professionals for implementation purposes. Client is under no obligation to engage the services of any such recommended professional. Client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from AFM. in Client’s financial situation or investment objectives for Client is advised that it remains Client’s responsibility to promptly notify AFM if there is ever any the purpose of change reviewing/evaluating/revising AFM’s previous recommendations and/or services. AFM is not obligated to recommend for any account any security that AFM or its related persons may acquire for its or their own accounts or for the account of any Client, if in the absolute discretion of AFM, it is not practical or desirable to recommend a position in such security. Because AFM engages in an investment advisory business and manages more than one account, there may be conflicts of interest over the AFM's time devoted to managing any one account and the allocation of investment opportunities among all accounts managed by AFM. AFM will attempt to resolve all such conflicts in a manner that is generally fair to all of its Clients. AFM may give advice and take action with respect to any of its Clients that may differ from advice given or the timing or nature of action taken with respect to any particular Client so long as it is AFM's policy, to the extent practicable, to allocate investment opportunities over a period of time on a  fair and equitable basis relative to other Clients. Any trade errors will be rectified to make the Client whole as if the error did not occur. Voting Client Securities AFM will not exercise proxy voting authority over Client securities. The obligation to vote Client proxies shall at all times rest with Clients. Clients shall in no way be precluded from contacting AFM for advice or information about a particular proxy vote. However, AFM shall not be deemed to have proxy voting authority solely as a result of providing such advice to Clients. With regard to all matters for which shareholder action is required or solicited with respect to securities beneficially held by a Client’s account, such as (i) all matters relating to class actions, including without limitation, matters relating to opting in or opting out of a class and approval of class settlements and (ii) bankruptcies or reorganizations, AFM affirmatively disclaims responsibility for voting (by proxies or otherwise) on such matters and will not take any action with regard to such matters. Upon Client’s authorized instructions, AFM may act on tender offers for securities held in Client accounts. Financial Information AFM has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage client accounts.