This web site is for informational purposes only and does not constitute a complete description of our investment services or performance. This web site is in no way a solicitation or offer to sell securities or investment advisory services except, where applicable, in states where we are registered or where an exemption or exclusion from such registration exists. Information throughout this site, whether stock quotes, charts, articles, or any other statement or statements regarding market or other financial information, is obtained from sources which we and our suppliers believe reliable, but we do not warrant or guarantee the timeliness or accuracy of this information. Nothing on this web site should be interpreted to state or imply that past results are an indication of future performance. Neither we nor our information providers shall be liable for any errors or inaccuracies, regardless of cause, or the lack of timeliness of, or for any delay or interruption in the transmission thereof to the user.

THERE ARE NO WARRANTIES, EXPRESSED OR IMPLIED, AS TO ACCURACY, COMPLETENESS, OR RESULTS OBTAINED FROM ANY INFORMATION POSTED ON THIS OR ANY LINKED WEB SITE.

Front Porch Financial Advisory (“FPFA”) is a Registered Investment Advisor (“RIA”), located in the State of North Carolina. FPFA provides investment advisory and related services for clients nationally. FPFA will maintain all applicable registration and licenses as required by the various states in which FPFA conducts business, as applicable. FPFA renders individualized responses to persons in a particular state only after complying with all regulatory requirements, or pursuant to an applicable state exemption or exclusion.

We adhere to the ethical attributes upheld by the CFP® designation. Being an RIA means we have fiduciary responsibility, which in turn means we are legally bound to put our clients’ interests before our own.

Investment advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law.

Federal law gives the customer the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information.

 TYPES OF NONPUBLIC PERSONAL INFORMATION (NPI) WE COLLECT

We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization. This can include but is not limited to your Social Security Number, Date of Birth, Banking Information, Financial Account Numbers and/or Balances, Sources of Income, and Employment Information. When you are no longer our customer, we may continue to share your information only as described in this notice.

PARTIES TO WHOM WE DISCLOSE INFORMATION

All Investment Advisers may need to share personal information to run their everyday business. In the section below, we list the reasons that we may share your personal information:

• For everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus;

• For SEC firm books and records examinations;

• For our marketing – to offer our products and services to you;

• With your prior permission, for collaboration with your other advisory professionals, e.g. CPAs and attorneys.

If you are a new customer we may begin sharing your information on the day you sign our agreement. When you are no longer our customer, we may continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Note – We do not sell your personal information.

PROTECTING CONFIDENTIALITY OF CURRENT AND FORMER CLIENT’S INFORMATION

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law, including computer safeguards and secured files and building.

FEDERAL & STATE LAW ALLOWS YOU TO LIMIT SHARING – OPTING OUT

Federal law allows you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for non-affiliates’ everyday business purposes – information about your creditworthiness; or sharing with affiliates or non-affiliates who use your information to market to you. State laws and individual companies may give you additional rights to limit sharing. Please know that our firm never shares your information with affiliate or non-affiliate firms that would market to you.

DEFINITIONS:

Affiliates – companies related by common ownership or control. They can be financial and non-financial companies;

Non-affiliates – companies not related by common ownership or control. They can be financial and non-financial companies;

Joint marketing – a formal agreement between non-affiliated financial companies that together market financial products or services to you.

NOTE REGARDING GEOFFREY OWEN’S ROLE AS CHIEF COMPLIANCE OFFICER, ANTI-MONEY LAUNDERING COMPLIANCE OFFICER(AMCLO), and FINOP for BROKER DEALER B&D CAPITAL, LLC (BDCP)

 Mr. Owen operates as an independent contractor for a registered broker dealer transacting merger and acquisition (M&A) business.  Mr. Owen will not actively market BDCP’s services to FPFA clients nor FPFA services to BDCP clients. However, the services of each firm understandably may arise in general conversation.  Please note that information about a client of one firm will not be used for the purposes of the other unless expressly requested by the client and only after the client has received disclosures of any conflicts of interest.  For instance, BDCP colleagues will not know of an FPFA client unless that client has inquired of BDCP’s M&A services and received all disclosures of potential conflicts of interest.

BUSINESS SUCCESSION PLANNING

FPFA has established a business continuity plan with an external firm in the event Geoffrey Owen dies or is otherwise unable to perform duties in the best interest of FPFA clients.  Should a triggering event occur, the succeeding advisory firm would engage with Charles Schwab for the smooth transition of client accounts.  FPFA client information would be attained from Charles Schwab by the succeeding firm.  Client agreement for this activity is obtained in the firm’s Investment Advisory Contract.

EMAIL COMMUNICATIONS

FPFA often communicates with its clients and prospective clients through electronic mail (“email”) and other electronic means. Your privacy and security are very important to us. FPFA makes every effort to ensure that email communications do not contain sensitive information. We remind our clients and others not to send FPFA private information over email. If you have sensitive data to deliver, we can provide secure means for such delivery, such as a client portal.

Please note: FPFA does not accept trading or money movement instructions via email.

As a registered investment advisor, FPFA emails may be subject to inspection by the Chief Compliance Officer (“CCO”) of FPFA or the securities regulators.

If you have received an email from FPFA in error, we ask that you contact the sender and destroy the email and its contents.

Please call if you have any questions. Your privacy, our professional ethics, and the ability to provide you with quality financial services are very important to us.

Front Porch Financial Advisory has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business.  Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur.  With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us: If after a significant business disruption you cannot contact us as you usually do at (980) 428-2297, you should go to our web site at www.frontporchfa.com . If you cannot access us through either of those means, you should contact our clearing firm Charles Schwab & Co. at (800) 515‑2157 for instructions on how they may provide prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions.

Our Business Continuity Plan: We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firm Charles Schwab & Co., backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firms that their objectives are to restore their own operations and be able to complete existing transactions and accept new transactions and payments within 0 to 48 hours (Charles Schwab & Co.) Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions: Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business. In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site www.frontporchfa.com. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customers’ prompt access to their funds and securities.

For more information: If you have questions about our business continuity planning, you can contact us at (980) 428-2297.

Different types of investments involve varying degrees of risk. Therefore, it should not be assumed that future performance of any specific investment or investment strategy will be profitable.

Asset allocation may be used in an effort to manage risk and enhance returns. It does not, however, guarantee a profit or protect against loss. Performance of the asset allocation strategies depends on the underlying investments.

Please remember that it remains your responsibility to advise FPFA, in writing, if there are any changes in your personal/financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services, if you would like to impose, add, or to modify any reasonable restrictions to our investment advisory services.

FPFA has adopted a Code of Ethics for all supervised persons of the Firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at FPFA must acknowledge the terms of the Code of Ethics annually, or as amended.

Advisors of FPFA may buy or sell securities that are recommended to clients. FPFA’s employees and persons associated with FPFA are required to follow the Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of FPFA and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for FPFA’s clients.  The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of FPFA will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interest of FPFA’s clients. In addition, the Code requires pre-approval of many transactions, and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client. Employee trading is continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between FPFA and its clients.

Advisors may buy or sell securities, at or around the same time as those securities are recommended to clients.  This practice creates a conflict of interest in that FPFA or its Representatives are in a position to benefit from the sale or purchase of those securities. FPFA’s Code of Ethics provides a policy to monitor the personal trading activities and securities holdings of each of the Firm’s Representatives or other Access Persons.  The Code of Ethic’s personal trading policies include procedures for limitations on personal securities transactions of associated persons, reporting and review of such trading.  These policies are designed to discourage and prohibit personal trading that would disadvantage clients.

Aggregated trades (employees and client trades)

Trades may be done on an aggregated basis when consistent with FPFA’s obligation of best execution. In such circumstances, the Advisor (or related account) and client accounts will share commission costs equally and receive securities at a total average price. FPFA will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the order.

FPFA’s clients or prospective clients may request a copy of the Firm’s Code of Ethics by contacting the Compliance Department at the main number.