Overview

Assets Under Management: $194 million
Headquarters: VERO BEACH, FL
High-Net-Worth Clients: 96
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Educational Seminars

Fee Structure

Primary Fee Schedule (TREASURE COAST FINANCIAL PLANNING 2025 ANNUAL REVISED FORM ADV PART 2A/2B)

MinMaxMarginal Fee Rate
$0 $500,000 1.25%
$500,001 $1,000,000 1.00%
$1,000,001 $2,000,000 0.85%
$2,000,001 $5,000,000 0.60%
$5,000,001 and above 0.50%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $11,250 1.12%
$5 million $37,750 0.76%
$10 million $62,750 0.63%
$50 million $262,750 0.53%
$100 million $512,750 0.51%

Clients

Number of High-Net-Worth Clients: 96
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 78.51
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 625
Discretionary Accounts: 625

Regulatory Filings

CRD Number: 166684
Last Filing Date: 2024-03-20 00:00:00
Website: HTTP://WWW.THEPLANNINGCO.COM

Form ADV Documents

Primary Brochure: TREASURE COAST FINANCIAL PLANNING 2025 ANNUAL REVISED FORM ADV PART 2A/2B (2025-03-31)

View Document Text
Item 1. Cover Page Treasure Coast Financial Planning, Inc. Form ADV Part 2A Firm Brochure March 2025 This brochure provides information about the qualifications and business practices of Treasure Coast Financial Planning, Inc. Our CRD number is 166684. If you have any questions about the contents of this brochure, please contact Guy L. Bassini, our Chief Compliance Officer at (772) 231-1422. This information has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. SEC registration does not imply a certain level of skill or training. Additional information about Treasure Coast Financial Planning, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Treasure Coast Financial Planning, Inc. 545 Beachland Blvd. Vero Beach, FL 32963 Tel: (772) 231-1422 Fax: (772) 231-1402 www.theplanningco.com Item 2. Material Changes Annual Update: Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s brochure, the adviser is required to notify clients and provide a description of the material changes. Generally, we will notify clients of material changes on an annual basis. However, where we determine that an interim notification is either meaningful or required, we will notify our clients promptly. In either case, we will notify our clients in a separate document. Material Changes You Should Know: The last annual filing of our brochure dated March 2024, has been updated as of March 2025. Material changes since the last update include: • Item 5: We have increased our annual financial planning fee for financial planning only clients. Additionally, we have updated our assets under management, but we do not consider these other changes to be material. Full Brochure Available: The revised brochure will be available since our last delivery or posting of this brochure on the SEC’s public disclosure website (IAPD) at www.adviserinfo.sec.gov or clients may contact our office at the number or by email listed on the cover page of this brochure to obtain a copy. When an update is made to this brochure, we will send a copy to clients with the summary of material changes, or a summary of material changes that includes an offer to send clients a copy [either by electronic means (email) or in hard copy form]. 2 Item 3. Table of Contents TABLE OF CONTENTS Item 1. Cover Page……………………………………………………………………………………………… Item 2. Material Changes……………………………………………………………………………………… Item 3. Table of Contents……………………………………………………………………………………… Item 4. Advisory Business…………………………………………………………………………………….4 Item 5. Fees and Compensation ........................................................................................................... 6 Item 6. Performance-Based Fees and Side-by-Side Management ............................................. 10 Item 7. Types of Clients………………………………………………………………………………………10 Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss .................................... 10 Item 9. Disciplinary Information ....................................................................................................... 15 Item 10. Other Financial Industry Activities and Affiliations .................................................... 15 Item 11. Code of Ethics, Participation or Interest in Client Transactions .............................. 16 Item 12. Brokerage Practices .............................................................................................................. 17 Item 13. Review of Accounts ............................................................................................................... 19 Item 14. Client Referrals and Other Compensation ..................................................................... 20 Item 15. Custody……………………………………………………………………………………………….20 Item 16. Investment Discretion .......................................................................................................... 21 Item 17. Voting Client Securities ....................................................................................................... 21 Item 18. Financial Information .......................................................................................................... 22 Brochure Supplements Attached 3 Item 4. Advisory Business A. General Description of Advisory Firm. Treasure Coast Financial Planning, Inc. (“TCFP,” “Firm,” or “we/us/our”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). SEC registration does not imply a certain level of skill or training. Our Firm was founded in 1996 and became an SEC registered investment adviser in 2013. We are located in Vero Beach, Florida. We provide comprehensive wealth management services, which include fee-based asset management and financial planning investment advisory services to separately managed Client accounts, primarily on a discretionary basis (“Clients” or “you/your"). Our Firm is organized as a corporation and our principal owner is Guy L. Bassini. B. Description of Advisory Services It is our goal to attempt to eliminate, mitigate, or disclose conflicts of interest with our Clients wherever possible. Our Firm is independent and was structured to avoid the common conflicts of interest that can exist in the investment advisory business. As further described below, we do not have any affiliated entities (such as a broker-dealer), proprietary products, investment banking relationships or other business activities that may be inconsistent with our Client’s needs. All conflicts of interest are disclosed in this brochure and the brochure supplements. In addition, as part of our Firm’s compliance program, we have developed procedures to reasonably identify, mitigate and disclose conflicts of interests for our Firm and our employees. Our advisory services encompass an assessment of the Client's goals, financial situation, risk tolerance and time horizon followed by asset allocation, investment selection and investment implementation recommendations as agreed upon with our Client. We strive to meet with our Clients to review their investments at least annually and more often as necessary to help them meet their goals. We provide investment consulting services that relate to matters such as asset allocation, executive compensation packages, stock option analysis, business transfer and other general economic and financial topics. Our consulting services include client retirement plans such as 401(k) and 403(b) plans. For example, some Clients will utilize our services to manage their retirement plan’s underlying investment allocations. We receive financial planning fees for our consulting services. Client account supervision is guided by the stated objectives of our Client’s Investment Management Agreement (“IMA”) with us, and all Client accounts will be maintained with an independent custodian bank or broker-dealer. We participate in the institutional services program offered to independent investment advisers by Pershing Advisor Solutions LLC (an affiliate of the Bank of New York Mellon) (“Pershing” 4 or “Platform Provider”). We have selected Pershing because we believe they are one of the leading custody, clearing, and trade execution providers in the industry. Pershing gives us access to a comprehensive range of products, and we believe it will help us in our attempt to observe industry best practices for your account. See Item 12 below for information on our brokerage practices. Clients with variable annuity products may select to use our services to manage the subaccount investments. We will review the annuity’s subaccount options and determine the best fit for the Client based upon the Client’s investment objectives for the product. Clients that select this service option will have the annuity’s assets included in the Client’s total assets under management with our Firm, and management fees will apply. We also provide tax-related services to Clients. This is not considered an investment advisory service, and tax-related services make up a small percentage of our overall business. Additional information regarding our other business activities is disclosed below in Item 10 and in our Form ADV Part 2B Brochure Supplements for our investment professionals. At times, TCFP provides educational seminars for Clients and prospective clients. The seminars are not designed to provide specific and/or personal financial advice, and no fee is charged. IRA Rollover Recommendations For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") when applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under an exemption that requires us to act in your best interest and not put our interest ahead of yours. Under this exemption, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice), • Never put our financial interests ahead of yours when making recommendations (give loyal advice), • Avoid misleading statements about conflicts of interest, fees, and investments, • Follow policies and procedures designed to ensure that we give advice that is in your best interest, • Charge no more than is reasonable for our services, and • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under 5 management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Donor Advised Fund Services Some TCFP Clients will establish donor advised funds through various third-party charitable programs including the American Endowment Foundation (“AEF” or “Charitable Platform”). Currently, TCFP maintains a relationship with AEF, but does not have a formal referral arrangement in place with any donor advised fund and does not receive compensation for referrals to AEF or any other donor advised fund. The funds will be managed in accordance with the specific investment policies and guidelines of the Charitable Platform. Clients will establish a donor advised account, transfer funds earmarked for charitable donation and recognize a tax deduction in the year that funds are transferred into an account opened on the Charitable Platform. The funds remain in such account until the Client designates a charity, an amount, and a date to donate to such charity. Under independent advisor programs established within the Charitable Platform, donors appoint an independent investment adviser, which could include TCFP, to manage accounts established on the Charitable Platforms. If appointed, TCFP will manage the donor’s account pursuant to investment guidelines established by the Charitable Platform. C. Availability of Tailored Services for Individual Clients As a Client, you may impose restrictions on investing in certain securities. The advice we provide is based on the individual needs of each Client, and we are responsible for all day-to-day investment and trading decisions for accounts. In providing these services, we consider such factors as size of the account, Client’s income and investment objectives (including tax sensitivity), investment guidelines, investment restrictions and relative tolerance for risk as stated in your IMA. D. Wrap Fee Programs. This is not applicable as we do not offer any wrap fee programs. E. Client Assets Under Management. As of December 31, 2024, we have $206,877,327 in assets under management, managed on a discretionary basis and $0 managed on a non-discretionary basis. Item 5. Fees and Compensation A. Advisory Fees and Compensation We receive a management fee from our Clients for investment management services pursuant to our IMA (the “Management Fee”). Our investment advisory fees are negotiable at our 6 discretion and will vary depending on account size, among other factors. Therefore, Clients with similar assets under management and investment objectives may pay significantly higher or lower fees than other Clients. Fees are based on the aggregate value of all accounts in a household under management in order to provide clients with the largest possible discount from the standard fee schedule. We reserve the right to waive fees. We charge four types of fees to our Clients: 1) Management Fees 2) Financial Planning Fees 3) Hourly Consulting Fees 4) Tax Return Preparation Fees (non-securities/advisory related business) 1) Management Fees: Typically, our fee for advisory services is determined as a percentage of assets under management according to the following schedule (which is subject to change at our discretion): ASSETS UNDER MANAGEMENT ANNUAL FEE First $500,000-$1,000,000 1.00% Next $1,000,001-$2,000,000 0.85% Next $2,000,001-$5,000,000 0.60% Over $5,000,001+ 0.50% Total AUM Below $500,000 1.25% This is a tiered scheduled fee schedule. For example, the first $1,000,000 of a $5,000,000 account is charged at 1.00%. Donor Advised Fund Services For donor advised funds, if TCFP is appointed to serve as investment adviser under a Charitable Platform, the Firm will continue charge an annual management fee based on the schedule above, and which is negotiable. Please note that donor advised funds have their own expenses (similar to a trustee fee) that generally range from .10% to .70% based on Fund balance. Please discuss all donor advised fund fees with your IAR. 2) Financial Planning Fees: We generally charge a fixed-rate fee which ranges based upon the type of services being performed, as described in the table below. These fees are determined and subject to change at our discretion. This fixed-rate fee applies to financial planning fees only and is negotiated with each Client. Financial Plan Fee Schedule: (next page) 7 TRADITIONAL $3,900 EXECUTIVE $5,000 CEO $10,000 Financial Plan Fee Schedule – Entire Fee due with initial agreement Cash flow management Cash flow management Retirement planning Estate planning Net worth analysis Tax analysis Risk management Education planning Cash flow management Retirement planning Estate planning Net worth analysis Tax analysis Risk management Education planning Multiple Real Estate Holdings Multi-state issues Retirement planning Estate planning Net worth analysis Tax analysis Risk management Education planning Multiple Real Estate Holdings Multi-state issues Executive compensation packages Stock option analysis Small business owners Executive compensation packages Complex stock option analysis Small business owners Extensive estate planning Business transfer Financial Planning-only Clients: Additional $1,450 annual eMoney system maintenance fee due on plan anniversary date (includes annual review meeting). 3) Hourly Consulting Fees: We generally charge around $250 per hour; however, this rate can be higher depending on the complexity of the plan. 4) Tax Return Preparation Fees (non-securities related business): We offer Individual Federal 1040 Income Tax return preparation services (and state income tax returns where required) for our Clients as well as Federal form 1041 Fiduciary Income Tax Returns (and state where required). Our minimum fee is $250 for Federal 1040 (state return(s), if required, will incur additional fees) and $525 for Federal 1041 (state return(s), if required, will incur additional fees). B. Payment of Fees. When opening an account, you will authorize us to invoice your custodian directly for our Management Fee, and you authorize the custodian to pay us directly from your account. This authorization is part of our IMA. TCFP shall be paid a percentage fee based on the fair market value of a Client’s account on a quarterly basis (the “Management Fee”). The Management Fee will be calculated and billed quarterly in advance based upon the value of the account on the last day on which the New 8 York Stock Exchange is open in each quarterly cycle. Please note that the balance your fee is based on may not match the statement you receive from the custodian due to dividends, incoming contributions, outgoing withdrawals, settlement issues, etc. Accounts that are opened other than the first day of a quarter shall be billed based upon the deposits received within the quarter and the fees will be prorated throughout the quarter. If the IMA is terminated before the end of the quarterly period, the Client shall be reimbursed a prorated refund of any pre-paid quarterly Management Fee based on the number of days remaining in the quarterly cycle after termination date. Our financial planning fees are payable as follows: One half of the fee is due with the initial agreement, and the balance is due upon delivery of our agreed upon services with the Client. Hourly consulting and tax return preparation fees are due when invoiced. C. Other Fees and Expenses. As a Client, you will incur other fees and expenses in connection with our management of your account(s). For example, you will have a third-party custodian bank that has possession of your assets and settles trades (typically Pershing). Your custodian will charge additional fees, including but not limited to wire transfers, cash management, NSF (non-sufficient funds), foreign transaction fees, and account closing fees. Cash balances in your account will not bear interest. If you choose to participate in one of the interest-bearing money market funds offered by Pershing, you should be aware that these funds charge a management fee that is assessed as an expense. This should be considered an additional fee. We will occasionally invest Client cash balances in other available bank deposit programs as well. If you have assets in your account which are invested in funds (such as mutual funds or exchange-traded funds), those assets will be considered part of the value of your account when we calculate our Management Fee. Variable annuity assets will also be included if we provide subaccount management services. You will also pay additional fees and charges to the managers of those funds or subaccounts. For example, a mutual fund manager charges a management fee and other fund fees and expenses that you will pay in addition to any fees paid to us in the form of Management Fees. This will lower your overall account performance in the aggregate. We primarily recommend no-load or load-waived mutual funds and variable annuities for our Clients. Variable annuities have additional fees based on the product and issuer, including but not limited to mortality and expense, administrative, distribution, and potentially rider related fees, all of which are disclosed in the product prospectus. A Client could invest in a mutual fund or variable annuity directly, without our services, and not incur our Management Fee. In that case, the Client would not receive the services provided by us which are designed, among other things, to assist the Client in determining which mutual fund or subaccounts/funds are most appropriate to each Client’s financial condition and objectives. Under all circumstances, we will not be compensated or receive compensation of any kind payable by a mutual fund or other money manager. 9 See Item 12 below for additional information on our Brokerage Practices and additional fees charged to you as a Client. D. Prepayment of Fees. As stated above in Section B, we receive our Management Fee in advance each quarter. We do not bill more than six (6) months in advance, and any prepaid fees are refunded on a pro-rata basis upon termination. We do not keep any unearned fees. E. Additional Compensation and Conflicts of Interest. We are not affiliated with any broker-dealers, so we do not receive investment commissions on investment transactions. We do not buy or sell securities for our own proprietary account. We are not compensated for the sale of securities or other investment products, including asset- based sales charges or service fees from the sale of mutual funds. Item 6. Performance-Based Fees and Side-by-Side Management We do not charge performance-based fees; this item is not applicable to our Firm. Item 7. Types of Clients We provide management services to individuals, including high-net worth individuals, charitable organizations, donor advised funds, and corporations or other business entities. As noted above, we may impose a minimum Client account balance of $500,000 per household for opening an account with us, which is subject to change at our sole discretion. In addition, donor advised funds are subject to a minimum $125 per quarter fee. Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies. Our fundamental approach to Client portfolio management is based upon a number of core beliefs. Among these is that markets tend to be efficient over long periods of time. As a result, during most periods portfolios will generally benefit from core positions focused on broad diversification and low cost. We also believe that while it is impossible to eliminate risk, broad diversification helps reduce the possibility that an unforeseen negative event will seriously damage the overall portfolio. Our several decades of cumulative investment experience have demonstrated to us that highly concentrated positions, frequent trading, and high costs pose an unnecessary challenge to the long-term success of client portfolios. Therefore, we believe that clients should diversify across asset classes, markets, countries and maturities. 10 We utilize a top-down approach to developing strategic allocation models for our Clients. Target allocations are determined according to the time horizon and risk profile of Clients. In keeping with our belief in the importance of low cost and broad diversification we primarily use mutual funds (no load and load-waived) and Exchange Traded Funds (“ETFs”) for our core Client positions. We then seek to increase return, reduce risk, or meet income needs by overweighting to sectors which we believe have the potential to add value to Client portfolios or underweighting those sectors we view less favorably. Client risk tolerance permitting, we will periodically add real estate funds, long/short funds, arbitrage funds, commodity funds, and market neutral funds. In larger Client accounts, we will also use individual bond positions or hold individual stocks. While we believe that over long periods of time markets tend to be efficient, there are infrequent periods of serious inefficiency when extreme values present themselves. It is during those periods that we will significantly increase our allocation to an undervalued sector. Based upon the risk tolerance and investment objectives Clients provide us with, we will make investments in their account which follow those objectives. While we primarily use ETFs, no- load (or load-waived) mutual funds and bond investments (for larger accounts) when investing on behalf of our Clients, we at times also include other equity securities (including over-the- counter and securities of foreign issuers), commercial paper, certificates of deposit, United States government securities and other government-related bonds, options contracts on securities, and convertible securities. Clients may impose restrictions on investing in certain securities which will be outlined in the IMA. We invest Client assets using the strategy we think is appropriate based on the Client’s stated investment objectives. If Clients instruct us to emphasize a specific approach, it will be noted in the IMA. B. Material Risks (Including Significant or Unusual Risks) Relating to Investment Strategies. It is important to note that investing in securities involves a risk of loss that Clients should be prepared to bear. All investments involve financial risk for which you are responsible. It is also your responsibility to pay any taxes which may be due on transactions in your account. An investment strategy could prove to be unprofitable, and you should be prepared to withstand losses when investing in securities. You take on risk whenever you have market exposure, including, but not limited to, the following: ETF Risk. ETFs are investment companies (including open-end and closed-end) that are bought and sold on a securities exchange, like a stock. The risks of owning an ETF are generally comparable to the risks of owning the underlying securities held by the ETF. However, when an account invests in an ETF, it will bear additional expenses based on its pro rata share of the ETF’s expense ratio. In addition, because of these expenses, compared to owning the underlying securities directly, it will be more costly to own an ETF. 11 Mutual Funds. Mutual funds are investment companies. Open-end mutual funds shares are issued by the fund, unlike closed-end mutual funds which are market-traded securities. The risks of owning mutual funds are generally comparable to the risks of owning the underlying securities held by the mutual fund. When an account invests in mutual funds it will bear additional expenses incurred by the fund. Stock Market Risk. The value of the equity securities in which an account invests will decline in response to developments affecting individual companies and/or general economic conditions. Price changes may be temporary or last for extended periods. For example, stock prices have historically fluctuated in periodic cycles. Accounts investing in the stock market directly will experience greater volatility, both upside and downside. Stock Selection Risk. In addition to, or in spite of, the impact of movements in the overall stock market, the value of an account’s investments may decline if the particular companies in which the account invests do not perform well in relation to the market. Sector Concentration Risk. An account may invest a substantial portion of its assets within one or more economic sectors. To the extent an account is concentrated in one or more sectors, market or economic factors impacting those sectors could have a significant effect on the value of the account’s investments. Additionally, an account’s performance will be more volatile when the account’s investments are less diversified across sectors. For example, since benchmark sector weights influence an account’s sector exposure, an account could tend to be more heavily weighted in health care or information technology companies. The values of health care and information technology companies are particularly vulnerable to rapid changes in technology product cycles, government regulation and competition. Health care stocks are also heavily influenced by the impact of cost containment measures. Technology stocks, especially those of less-seasoned companies, tend to be more volatile than the overall market. Credit Risk. An account may lose money if an issuer of a fixed income security is unable or unwilling to make timely principal and/or interest payments or to otherwise honor its payment obligations. Further, when an issuer suffers adverse changes in its financial condition or credit rating, the price of its debt obligations will decline and/or experience greater volatility. A change in financial condition or credit rating of a fixed income security can also affect its liquidity and make it more difficult to sell. Interest Rate Risk. The value of a bond will decline due to an increase in the absolute level of interest rates, or changes in the spread between two rates, the shape of the yield curve or any other interest rate relationship. Longer-term bonds are generally more sensitive to interest rate changes than shorter-term bonds. Generally, the longer the average maturity of the bonds held by an account, the more an account’s value will fluctuate in response to interest rate changes. Pre-payment Risk. If an account is invested in asset-backed and mortgage-backed securities such account may be subject to higher prepayment risk than an account with a higher concentration in other types of fixed income securities. An account may experience losses when an issuer exercises its right to pay principal on an obligation earlier than expected. This will happen during a period of declining interest rates. Under these circumstances, the account 12 will be unable to recoup all of its initial investment and will suffer from having to reinvest in lower yielding securities. The loss of higher yielding securities and the reinvestment at lower interest rates can reduce an account’s income, total return and share price. Rates of prepayment, faster or slower than expected, could reduce an account’s overall yield, increase the volatility of the account and/or cause a decline in value. Municipal Securities Risk. The yields of municipal securities may move differently and adversely compared to yields of the overall debt securities markets. There could be changes in applicable tax laws or tax treatments that reduce or eliminate current federal income tax exemptions on municipal securities and otherwise adversely affect the current federal or state tax status of municipal securities. Such changes also will adversely impact the value of municipal securities owned by an account and, as a result, the value of the account. The value of a municipal security is also affected by the overall financial health of the specific municipal entity issuer. A local municipality that cannot meet its financial obligations could lead to a default on its bonds. When-Issued Securities and Delayed Delivery Risk. A purchase of “when-issued” securities refers to a transaction made conditionally because the securities, although authorized, have not yet been issued. A delayed delivery or forward commitment transaction involves a contract to purchase or sell securities for a fixed price at a future date beyond the customary settlement period. Purchasing or selling securities on a when-issued, delayed delivery or forward commitment basis involves the risk that the value of the securities may change by the time they are actually issued or delivered. These transactions also involve the risk that the counterparty may fail to deliver the security or cash on the settlement date. In some cases, an account may sell a security on a delayed delivery basis that it does not own, which may subject the account to additional risks generally associated with short sales. Among other things, the market price of the security may increase after an account enters into the delayed delivery transaction, and the account will suffer a loss when it purchases the security at a higher price in order to make delivery. In addition, an account may not always be able to purchase the security it is obligated to deliver at a particular time or at a favorable price. Legal and Regulatory Matters Risks. Legal developments which may adversely impact investing and investment-related activities can occur at any time. “Legal Developments” means changes and other developments concerning foreign, as well as US federal, state and local laws and regulations, including adoption of new laws and regulations, amendment or repeal of existing laws and regulations, and changes in enforcement or interpretation of existing laws and regulations by governmental regulatory authorities and self-regulatory organizations (such as the SEC, the US Commodity Futures Trading Commission, the Internal Revenue Service, the US Federal Reserve and the Financial Industry Regulatory Authority). Our management of accounts may be adversely affected by the legal and/or regulatory consequences of transactions effected for the accounts. Accounts may also be adversely affected by changes in the enforcement or interpretation of existing statutes and rules by governmental regulatory authorities or self-regulatory organizations. System Failures and Reliance on Technology Risks. Our investment strategies, operations, research, communications, risk management, and back-office systems rely on technology, 13 including hardware, software, telecommunications, internet-based platforms, and other electronic systems. Additionally, parts of the technology used are provided by third parties and are, therefore, beyond our direct control. We seek to ensure adequate backups of hardware, software, telecommunications, internet-based platforms, and other electronic systems, when possible, but there is no guarantee that our efforts will be successful. In addition, natural disasters, power interruptions and other events may cause system failures, which will require the use of backup systems (both on- and off-site). Backup systems may not operate as well as the systems that they back up and may fail to properly operate, especially when used for an extended period. To reduce the impact a system failure may have, we continually evaluate our backup and disaster recovery systems and perform periodic checks on the backup systems’ conditions and operations. Despite our monitoring, hardware, telecommunications, or other electronic systems malfunctions may be unavoidable, and result in consequences such as the inability to trade for or monitor client accounts and portfolios. If such circumstances arise, the Investment Committee will consider appropriate measures for clients. Cybersecurity Risk. A portfolio is susceptible to operational and information security risks due to the increased use of the internet. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyberattacks include, but are not limited to, infection by computer viruses or other malicious software code, gaining unauthorized access to systems, networks, or devices through “hacking” or other means for the purpose of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches by third-party service providers may cause disruptions and impact the service providers’ and our business operations, potentially resulting in financial losses, the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement, or other compensation costs, and/or additional compliance costs. While we have established business continuity plans and risk management systems designed prevent or reduce the impact of such cyberattacks, there are inherent limitations in such plans and systems due in part to the everchanging nature of technology and cyberattack tactics. Pandemic Risks. The outbreak of the novel coronavirus rapidly became a pandemic and has resulted in disruptions to the economies of many nations, individual companies, and the markets in general, the impact of which cannot necessarily be foreseen at the time. This created closed borders, quarantines, supply chain disruptions and general anxiety, negatively impacting global markets in an unforeseeable manner. The impact of the novel coronavirus and other such future infectious diseases in certain regions or countries may be greater or less due to the nature or level of their public health response or due to other factors. Health crises caused by the coronavirus outbreak and future infectious diseases may exacerbate other pre- existing political, social, and economic risks in certain countries. The impact of such health crises may be quick, severe and of unknowable duration. These pandemics and other epidemics and pandemics that may arise in the future, could result in continued volatility in the financial markets and could have a negative impact on investment performance. Please note that there are many other circumstances not described here that could adversely affect the Client’s investment and prevent the Client from meeting the Client’s investment objectives. The list represents the typical risks involved. The explanation of certain risks is not 14 exhaustive, but rather highlights some of the more significant risks involved in the Firm’s investment strategies. We encourage all Clients to familiarize themselves with the investment risks. C. Risks Associated With Types of Securities that are Primarily Recommended (Including Significant or Unusual Risks). We primarily recommend no-load (or load-waived) mutual funds and exchange-traded funds for our Clients. The material risks associated with these types of investments is described in Item 8.B. above. Item 9. Disciplinary Information We have no legal or material disciplinary events related to our Firm or any of our employees. Item 10. Other Financial Industry Activities and Affiliations A. Broker Dealer Registrations. We have no registered representatives of a broker-dealer at our Firm. B. Futures or Commodities Registrations. This item is not applicable to our Firm. C. Material Relationships. We consider our relationship with Pershing to be a material relationship since the majority of our advisory Client accounts are expected to be custodied at Pershing. Pershing provides us with transaction and reporting data that allows us to monitor our Client accounts. We have no affiliation or relationship with Pershing other than as described in this brochure. We are not affiliated with Pershing. Tax Services: As described in Item 4 above, we offer tax preparation services. This causes a potential conflict of interest in that we have a financial incentive to recommend our tax services over a competitor. However, we take our fiduciary duty seriously and have developed a compliance program to identify and monitor all of our business activities and Clients are under no obligation to use us, or any other recommended tax preparation firm, to meet their tax needs. Furthermore, we see our tax services as enhancing our ability to do proactive planning as opposed to reactive planning. D. Selection of Other Investment Advisers. We do not recommend or select other investment advisers for our Clients. 15 Item 11. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Code of Ethics. Our Firm has adopted a Code of Ethics pursuant to SEC Rule 204A-1 that obligates our Firm and our employees to put the interests of our clients before our own interests and to act honestly and fairly in all respects in dealing with our Clients. Our employees are also required to comply with applicable federal securities laws. Our Code of Ethics describes our Firm's fiduciary duties and responsibilities to our Clients and sets forth a practice of supervising the personal securities transactions of our employees with access to Client information. Employees of our Firm will buy or sell securities for their personal accounts identical to or different from those recommended to our Clients. It is our Firm’s expressed policy that employees must put the interests of Clients ahead of their personal investment decisions. To supervise compliance with our Code of Ethics, we require that anyone associated with us that has access to advisory recommendations provide duplicate copies of brokerage account activity and annual securities holdings reports to our Firm's Chief Compliance Officer. It is also required that such employees receive approval from our Chief Compliance Officer prior to investing in any initial public offerings (“IPOs”) or private placements. Our Code of Ethics further includes a policy prohibiting the use of material non-public information. As noted below, ETFs are treated as reportable securities and subject to review under our policy. Any employee not in observance of the above is subject to disciplinary procedures. A complete copy of our Firm’s Code of Ethics will be provided to any client upon request to our Firm’s Chief Compliance Officer at our principal address, telephone (772) 231-1422. B. Client Transactions in Securities where Adviser has a Material Financial Interest. We do not engage in principal transactions or agency cross transactions. We do not execute transactions between Client accounts (including rebalancing trades between Client accounts). Our Firm has no material financial interest in, nor any affiliation with, any other firm or securities issuer; therefore, no such conflicts exist with our Clients. Further, our Firm does not buy or sell securities of any kind for our Firm’s own proprietary account for any purpose including, for example, for reselling to Clients. Trades are not conducted between a Firm account and Client accounts. C. Investing in Securities Recommended to Clients. Our employees are permitted to invest in the same securities that we recommend to our Clients. Our Code of Ethics requires the reporting of personal transactions in reportable securities (as defined under Rule 204A-1), which is reviewed at least quarterly by our Chief Compliance 16 Officer. These reviews are reasonably designed to attempt to identify and mitigate any potential manipulative trading, trading ahead of Clients and insider trading. D. Conflicts of Interest Created by Contemporaneous Trading. Conflicts of interest are created when one of our employees is trading in the same security as a Client. Our employees, who have accounts with us, are permitted to participate in aggregated trade orders with our Clients when all parties receive the same average price. We primarily recommend mutual funds and ETFs for our Clients. Unaffiliated open-end mutual funds are not considered reportable securities under Rule 204A-1 since they are not market-traded securities. ETFs are market-traded securities and could present an opportunity for improper trading, therefore our employees’ personal trading activities in ETFs are reportable securities and subject to review under our policy. Item 12. Brokerage Practices A. Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions. As previously noted, we participate in the institutional services program offered to independent investment advisers by Pershing Advisor Solutions LLC, an investment advisor platform in which we participate (“Pershing” or “Platform Provider”). Transactions are conducted by its affiliated clearing broker, Pershing LLC (an affiliate of the Bank of New York Mellon). Clients in need of brokerage and custodial services will have Pershing recommended to them. Not all advisers make such broker-dealer recommendations. As part of the Platform Provider program, we receive benefits that we would not receive if we did not offer investment advice, such as access to their services. For example, we receive benefits by selecting Pershing to execute client transactions, and the transaction compensation charged by Pershing might not be the lowest compensation we might otherwise be able to negotiate. Included within the support services that may be obtained by us may be investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, and/or software and/or other products used by us in furtherance of our investment advisory business operations. In evaluating whether to recommend or require that Clients’ custody their assets at Pershing, we take into account the availability of the foregoing products and services and other arrangements as part of the total mix of factors it considers and not solely the nature, cost or quality of custody and brokerage services provided by Pershing. Clients should be aware that the receipt of such economic benefits by us creates a conflict of interest and may indirectly influence our choice of Pershing for custody and brokerage services. To address these conflicts of interest, we have developed and implemented a Compliance Program, which includes a review of the services and execution quality we receive from Pershing. 17 We have not entered into a formal soft dollar arrangement, whereby, we are required to direct a certain amount of transaction activity to Pershing for specific research or brokerage services, but certain services are available to us at no charge to us so long as our clients’ assets are maintained in accounts at Pershing. At the time of executing your IMA with us, you must choose to enter into a custodial arrangement with either: • Pershing Advisor Solutions LLC, the Platform Provider where we receive custodial services for our Client accounts along with access to investment research; or, • Another custodian you have selected and identified in your IMA (a “directed custodian”). Clients are free to select a broker-dealer custodian of their choice when we manage portfolios and investment assets. We reserve the right to decline any client account that directs the use of a broker dealer custodian other than Pershing if we believe that the broker dealer would adversely affect our fiduciary duty to the client and/or ability to effectively service the client portfolio. With either choice above, you will incur other fees and expenses in connection with our management of your account. Transactions in Client accounts executed through Pershing are charged customary commissions, mark-ups or other similar fees in connection with trading activity. These fees are paid by you, the Client, in addition to our Management Fee. Transactions executed away from Pershing will be executed through third-party broker-dealers who also charge commissions, mark-ups or other similar fees in connection with their trading activity. Accounts with a directed broker-dealer custodian may or may not pay higher commissions and mark-ups on transactions. We are in no position to negotiate commission rates or other transaction related charges for directed accounts. Clients are encouraged to check with their selected custodian regarding commission rates and mark-ups charged to accounts, which will be incurred in addition to our Management Fee. All trading orders received by our Platform Provider from our Firm are routed to Pershing LLC for execution. Pershing has a best execution steering committee which oversees their commitment to achieving best execution for their clients, such as our Firm, and they have a customer execution quality department which provides analytical data to their committee. Pershing regularly reviews, among other things, speed of execution, counterparty risk, cost of access, technology, customer service and a variety of metrics/reports regarding client trade order flows. Pershing provides our Firm with periodic reports regarding our Client trade orders, and we conduct our own periodic, independent analysis of trade executions for our Clients (such as random sample reviews) in an effort to ensure our Clients are receiving favorable trade order executions. 1. Research and Other Soft Dollar Benefits. We do not use soft dollars or have any other commission sharing agreements. 18 2. Brokerage for Client Referrals. We do not and have not received any referrals from a broker-dealer, and this factor is not a part of the consideration in selecting or recommending broker-dealers to our Clients. 3. Directed Brokerage. a) See Item 12.A. above regarding our selection of broker-dealers for Client accounts. b) Client-Directed Brokerage. Upon request, Clients may select a custodial broker other than our Platform Provider. Upon such request, we will determine if our fiduciary duties or best execution will be compromised, and we reserve the right to deny such Client requests. If applicable, when Clients designate our Firm to use specific brokers or dealers through which transactions are to be effected, orders for such directed brokerage Clients will be placed after orders for Clients that leave the selection of brokers to our discretion. For these accounts, it may not be possible for us to obtain lower commission rates which might be attainable if we had full discretion in the selection of the executing firm. Clients directing brokerage may also incur other transaction costs or greater spreads or receive less favorable net prices on transactions for their accounts than might otherwise be the case. B. Order Aggregation. As a fiduciary, we must allocate investment opportunities among our Clients in a fair and equitable manner. None of our Clients will be given investment priority over any other Client. However, as noted above, each Client may have separate investment objectives and investment restrictions which we will be required to follow; as a result, certain investment opportunities may be appropriate for certain Clients and not appropriate for other Clients. We may combine orders (known as “bunching” or “blocking” trades) for more than one Client account where blocking the trades appears to be potentially advantageous for each participating Client account (e.g., for the purpose of reducing brokerage commissions or obtaining a more favorable transaction price). Bunched trades will be recorded at an average price and allocated pro-rata to the Client account. In some instances, average pricing may result in higher or lower prices than a single account may otherwise obtain. Item 13. Review of Accounts A. Frequency and Nature of Review. The Investment Adviser Representative typically reviews Client accounts on an ongoing basis as needed and meets formally with Clients at least annually to review accounts in person.1 1 We will make our best efforts to meet with clients at least annually. However, the timing of such reviews may be impacted by client request or unintended events impacting either us or the client that result in a review not taking place at least annually. 19 The timing and nature of account reviews are dictated by a variety of factors, including contributions or withdrawals of cash from a Client account, a substantial change in the market value of assets under management, a Client’s request for information regarding the performance or structure of an account, and changes necessary to rebalance the portfolio to maintain client objectives and desired asset mix. Additionally, whenever transactions occur in a Client account, the account is generally reviewed the following day by the Investment Adviser Representative on the account. B. Other Periodic Reviews See response to Item13.A. above. C. Content and Frequency of Regular Account Reports. Quarterly statements showing all transactions, money movements and security positions are provided directly to Clients by the custodian (typically Pershing). Pershing will send statements in electronic format to Clients who have authorized electronic delivery. In addition, upon request, we provide Clients with monthly and/or quarterly account reports, typically in electronic format as authorized by the Client. Item 14. Client Referrals and Other Compensation A. Economic Benefits Received from Non-Clients for Providing Services to Clients. We do not accept or receive any benefits (cash or non-cash) other than our advisory fee in relation to our investment advisory business. B. Compensation to Non-Supervised Persons for Client Referrals. We do not directly or indirectly compensate anyone or any entity for client referrals. Item 15. Custody We do not hold custody of any Client funds or securities. All Client funds and securities are held at independent qualified custodians, Pershing and Nationwide. However, we are deemed to have limited custody of Client funds and securities due to the ability to deduct our advisory fees from Client accounts upon Client authorization and the ability to transfer Clients funds to or from their Pershing account(s) based on their signed Standing Letter of Authorization (“SLOA”). The SEC has set forth a set of standards intended to protect client assets in such situations, which we follow. Nationwide is the issuer of the annuity products we manage for our Clients. 20 As noted in Item 13 above, Client account statements are prepared independently and directly forwarded by the custodian (typically Pershing or Nationwide) to each Client on at least a quarterly basis. The account statements will reveal the funds and securities held with the qualified custodian, any transactions that occurred in your account and the deduction of our fee. We strongly recommend that our Clients compare quarterly account statements received from their custodian with any reports sent by us. You should contact us at the address or phone number on the cover of this brochure with any questions about your statements. You should notify us if you do not receive the account statements, at least quarterly, from the qualified custodian. Item 16. Investment Discretion As a Client, you may impose restrictions on investing in certain securities. We have discretionary authority over Client accounts for the purchase and sale of securities, which includes the investment selection, timing, amount, and priority of implementation. Discretionary authority is granted to us in the IMA signed by our Clients including any specific restrictions on this authority. An executed copy of the IMA must be obtained before trading in a Client’s discretionary account shall commence. In regard to any donor advised accounts described in Item 4 above, if TCFP is selected to act as an investment adviser by the Charitable Platforms, TCFP will maintain discretion to manage such assets pursuant to the applicable Charitable Platform’s specific investment guidelines. Item 17. Voting Client Securities We do not vote proxies or exercise voting rights for our Client investments, and we do not act on behalf of our Clients in any legal proceedings, including bankruptcies or class actions involving securities held or previously held in Client accounts. It is our Client’s responsibility to vote proxies for securities, exercise voting rights, and take any legal action pertaining to investments in their account. Ordinarily, our Client’s custodian (typically Pershing) will forward proxies or other communications about investments in our Client accounts directly to our Client. We direct our Clients to contact their custodian if they have any questions about proxy voting, including if they do not receive proxies or other mailings about the investments in their accounts; however, upon request from a Client, we may from time to time provide general information related to a proxy vote, such as helping Clients understand the language of the proxy questions or discussing possible effects of various votes but not recommending a vote for or against any particular item. 21 Item 18. Financial Information A. We do not bill our Clients $1,200 and more than six (6) months in advance; therefore, we do not need to provide our Clients with a balance sheet. B. We do not believe there is any existing financial condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. C. We have not been subject to a bankruptcy petition at any time. 22 Part 2B Brochure Supplements Item 1. Cover Page Brochure Supplement Guy L. Bassini March 2022 Treasure Coast Financial Planning, Inc. 545 Beachland Blvd. Vero Beach, FL 32963 (772) 231-1422 (telephone) (772) 231-1402 (fax) www.theplanningco.com This brochure supplement provides information about Guy L. Bassini that supplements the Treasure Coast Financial Planning, Inc. firm brochure. You should have received a copy of that firm brochure. Please contact Guy L. Bassini at (772) 231-1422 if you did not receive the firm brochure or if you have any questions about the contents of this supplement. Additional information about Guy L. Bassini is available on the SEC’s website at www.adviserinfo.sec.gov. 23 Item 2. Educational Background and Business Experience Name: Guy L. Bassini, CRD number 1874159 Year of Birth: 1955 Education: State University of New York, Empire State College - B.A. in History The University of Nebraska, Kearney - M.A. in History Career Summary: Business Experience: Founder and Chief Executive Officer, Treasure Coast Financial Planning, Inc., 1996 – Present Branch Manager, LPL Financial, 1995-2013 Professional Designations: Certified Financial Planner® (CFP) – Certified Financial Planner Board of Standards, Inc. (1999) I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional, and I may use these and CFP Board’s other certification marks (the “CFP Board Certification Marks”). CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold CFP® certification. You may find more information about CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • Education –Earn a bachelor’s degree from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. • Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. 24 • Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. • Continuing Education – Complete 30 hours of continuing education hours every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. Item 3. Disciplinary Information There are no legal or material disciplinary matters related to Mr. Bassini. Item 4.Other Business Activities Mr. Bassini has no other business activities. Item 5.Additional Compensation Mr. Bassini does not receive any additional compensation in connection with the above activities or any other activities. Item 6.Supervision As Chief Executive Officer and Chief Compliance Officer, Mr. Bassini is in charge of the overall activities of our Firm. However, Mr. Bassini has his trading activity (personal and Client trading) supervised by Anthony J. Dzielski. Mr. Dzielski may be reached at (772) 231-1422. 25 Item 1. Cover Page Brochure Supplement Anthony J. Dzielski Jr. March 2022 Treasure Coast Financial Planning, Inc. 545 Beachland Blvd. Vero Beach, FL 32963 (772) 231-1422 (telephone) (772) 231-1402 (fax) www.theplanningco.com This brochure supplement provides information about Anthony J. Dzielski Jr. that supplements the Treasure Coast Financial Planning, Inc. firm brochure. You should have received a copy of that firm brochure. Please contact Guy L. Bassini at (772) 231-1422 if you did not receive the firm brochure or if you have any questions about the contents of this supplement. Additional information about Anthony J. Dzielski Jr. is available on the SEC’s website at www.adviserinfo.sec.gov. 26 Item 2. Educational Background and Business Experience Name: Anthony J. Dzielski Jr., Enrolled Agent, CRD number 5050321 Year of Birth: 1983 Education: University of Florida – B.A. in Business Administration, 2005 Career Summary: Business Experience: Financial Planner, Treasure Coast Financial Planning, Inc., 2008 – Present Professional Designations: CFP – Certified Financial Planner (2012) I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional, and I may use these and CFP Board’s other certification marks (the “CFP Board Certification Marks”). CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold CFP® certification. You may find more information about CFP® certification at www.cfp.net. CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: • Education –Earn a bachelor’s degree from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. • Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. • Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code 27 of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. • Continuing Education – Complete 30 hours of continuing education hours every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. Enrolled Agent (May 2021) Enrolled agents (EAs) are the only federally licensed tax practitioners who specialize in taxation and also have unlimited rights to represent taxpayers before the IRS. The license is earned in one of two ways, by passing a comprehensive examination which covers all aspects of the tax code or having worked at the IRS for five years in a position which regularly interpreted and applied the tax code and its regulations. All candidates are subjected to a rigorous background check conducted by the IRS. In addition to the stringent testing and application process, the IRS requires enrolled agents to complete 72 hours of continuing education, reported every three years, to maintain their enrolled agent status. National Association of Enrolled Agents (NAEA) members are obligated to complete 30 hours per year (for a total of 90 hours per three-year period). Members of NAEA must fulfill continuing professional education requirements that exceed the IRS’ required minimum which is of 16 hours per year (2 of which must be on ethics). In addition, NAEA members adhere to a stringent Code of Ethics and Rules of Professional Conduct of the Association, as well as the Treasury Department’s Circular 230 regulations, which provides the regulations governing the practice of enrolled agents before the IRS. 28 Item 3. Disciplinary Information There are no legal or disciplinary matters related to Mr. Dzielski. Item 4.Other Business Activities Mr. Dzielski is not engaged in any outside business activities. Item 5.Additional Compensation Mr. Dzielski does not receive any additional compensation in connection with the above activities or any other activity. Item 6.Supervision Mr. Dzielski is supervised by Guy L. Bassini, Chief Executive Officer. Mr. Bassini may be reached at (772) 231-1422. 29