Compliance & Regulatory Disclosures¶

Effective Date: January 1, 2025
Last Revised: August 1, 2025
Chief Compliance Officer: compliance@apexfinancialpartners.com

Apex Financial Partners, LLC ("Apex") is committed to operating with the highest standards of regulatory compliance, ethical conduct, and transparency. This page provides important disclosures regarding our regulatory status, compliance policies, and the protections available to our clients under federal securities laws.

1. Regulatory Status¶

1.1 Registered Investment Adviser¶

Apex Financial Partners, LLC is registered as an investment adviser with the U.S. Securities and Exchange Commission (SEC) pursuant to the Investment Advisers Act of 1940, as amended (15 U.S.C. 80b-1 et seq.). Our SEC registration number is 801-XXXXX and our CRD number is XXXXXX. Registration with the SEC does not imply any particular level of skill, training, or endorsement by the Commission.

Clients and prospective clients may verify our registration status, review our Form ADV, and check the disciplinary history of our firm and associated persons through the SEC's Investment Adviser Public Disclosure (IAPD) database at adviserinfo.sec.gov or through FINRA's BrokerCheck at brokercheck.finra.org.

1.2 Broker-Dealer Affiliation¶

Apex Securities, LLC, an affiliated entity, is a registered broker-dealer and member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). Apex Securities operates under SEC registration pursuant to Section 15(b) of the Securities Exchange Act of 1934 (15 U.S.C. 78o). Certain securities transactions recommended by Apex Financial Partners may be executed through Apex Securities, LLC, subject to applicable best execution obligations.

1.3 State Registrations¶

Apex Financial Partners is registered or notice-filed in all fifty (50) U.S. states, the District of Columbia, Puerto Rico, and the U.S. Virgin Islands, as required by applicable state securities laws (commonly referred to as "Blue Sky" laws). State-specific regulatory information is available upon request.

2. Form ADV Summary¶

Apex Financial Partners' Form ADV is our primary disclosure document filed with the SEC and made available to all clients and prospective clients. The document consists of the following parts:

Form ADV Part 1: Contains information about the firm's business, ownership, clients, employees, business practices, affiliations, and any disciplinary events. Filed electronically through the Investment Adviser Registration Depository (IARD).
Form ADV Part 2A (Firm Brochure): Provides a narrative description of the firm's services, fees, investment strategies, conflicts of interest, disciplinary information, and other material facts. Delivered to all clients at or before the time of entering into an advisory agreement, and annually thereafter.
Form ADV Part 2B (Brochure Supplement): Provides information about the specific advisory personnel who provide services to the client, including educational background, business experience, and disciplinary history.
Form ADV Part 3 (Form CRS - Client Relationship Summary): A concise document summarizing the nature of advisory and brokerage services, fees, conflicts of interest, and disciplinary history, designed to help retail investors compare financial service providers.

Copies of all Form ADV parts are available at no charge by contacting compliance@apexfinancialpartners.com or by visiting the SEC's IAPD website.

3. Fiduciary Standard¶

When acting in an investment advisory capacity, Apex Financial Partners owes fiduciary duties to its clients as established by the Investment Advisers Act of 1940 and interpreted by the Supreme Court of the United States in SEC v. Capital Gains Research Bureau, Inc., 375 U.S. 180 (1963). Our fiduciary obligations include:

Duty of Loyalty: Placing client interests ahead of our own in all matters relating to the advisory relationship, and fully disclosing all material conflicts of interest.
Duty of Care: Providing investment advice that is suitable and in the client's best interest based on a thorough understanding of the client's financial situation, investment objectives, risk tolerance, and other relevant factors.
Duty of Good Faith: Acting honestly, fairly, and in accordance with the terms of the advisory agreement and applicable law.
Duty to Seek Best Execution: Seeking the most favorable terms reasonably available when executing securities transactions on behalf of advisory clients, taking into consideration factors including price, commission, execution speed, settlement reliability, and overall transaction cost.

4. Best Execution Policy¶

Apex maintains a comprehensive best execution policy in compliance with its fiduciary duty and FINRA Rule 5310 (Best Execution and Interpositioning). Key elements include:

Regular and Rigorous Review: Apex's Best Execution Committee conducts quarterly reviews of execution quality, evaluating price improvement statistics, fill rates, execution speed, and total transaction costs across all execution venues.
Venue Selection: Orders may be routed to national securities exchanges, alternative trading systems (ATS), electronic communication networks (ECNs), or market makers based on an assessment of execution quality factors.
Soft Dollar Disclosure: Apex does not maintain soft dollar arrangements as defined by Section 28(e) of the Securities Exchange Act of 1934. All research and analytical tools used by Apex are paid for with firm resources ("hard dollars").
Order Handling: Client orders are aggregated and allocated in a fair and equitable manner when multiple clients are purchasing or selling the same security simultaneously. Apex maintains a written allocation policy to prevent preferential treatment.

5. Conflicts of Interest¶

Apex identifies, discloses, and manages the following categories of conflicts of interest:

Compensation Conflicts: Apex's advisory fee, calculated as a percentage of assets under management, creates an incentive to encourage clients to increase account balances. This conflict is mitigated by the fiduciary standard and disclosed in Form ADV Part 2A.
Affiliated Entity Transactions: Recommendations to utilize affiliated entities (e.g., Apex Securities, LLC for brokerage execution, Apex Insurance Solutions for insurance products) create potential conflicts. Such recommendations are made only when in the client's best interest and are disclosed in advance.
Personal Trading: Apex employees who are "access persons" under Rule 204A-1 of the Investment Advisers Act are required to pre-clear personal securities transactions, report holdings quarterly, and comply with blackout periods around client trading activity. Apex maintains a comprehensive Code of Ethics available upon request.
Outside Business Activities: All employee outside business activities and private securities transactions are subject to prior approval and ongoing monitoring by the Compliance Department in accordance with FINRA Rules 3270 and 3280.

6. Anti-Money Laundering (AML) & Bank Secrecy Act (BSA) Compliance¶

Apex maintains a risk-based Anti-Money Laundering Program in compliance with the Bank Secrecy Act (31 U.S.C. 5311-5332), the USA PATRIOT Act (Pub. L. 107-56), and FINRA Rule 3310. Key program components include:

AML Compliance Officer: A designated AML Compliance Officer with authority and resources to implement and enforce the AML program.
Risk Assessment: Annual enterprise-wide AML risk assessment evaluating client types, products and services, geographic risk, and transaction patterns.
Transaction Monitoring: Automated transaction monitoring systems that screen for suspicious patterns, including structuring, layering, rapid movement of funds, and transactions involving high-risk jurisdictions.
Suspicious Activity Reporting: Procedures for investigating potentially suspicious activity and filing Suspicious Activity Reports (SARs) with the Financial Crimes Enforcement Network (FinCEN) within thirty (30) days of detection, as required by 31 CFR 1023.320.
Sanctions Screening: Real-time screening of clients, counterparties, and transactions against OFAC sanctions lists (SDN, Sectoral Sanctions, Non-SDN lists), with automated blocking and rejection procedures for positive matches.
Employee Training: Annual AML training for all employees, with enhanced training for client-facing and compliance personnel.
Independent Testing: Annual independent audit of the AML program conducted by a qualified third party.

7. Customer Identification Program (CIP)¶

In accordance with Section 326 of the USA PATRIOT Act and 31 CFR 1023.220, Apex implements a Customer Identification Program requiring the following for all new account openings:

Collection and verification of the client's name, date of birth, address, and identification number (SSN for U.S. persons; passport number, country of issuance, and foreign tax ID for non-U.S. persons).
Documentary verification using government-issued photo identification (driver's license, passport, or national ID card) and a secondary document confirming address (utility bill, bank statement, or tax assessment).
Non-documentary verification through third-party identity verification databases, credit bureau checks, and public records searches where documentary verification is insufficient.
Screening against government lists, including the OFAC SDN list, FinCEN 314(a) requests, and other applicable watchlists.
Ongoing monitoring and periodic re-verification of customer information based on risk rating.

8. Business Continuity Plan (BCP)¶

Apex maintains a comprehensive Business Continuity Plan in compliance with FINRA Rule 4370 (Business Continuity Plans and Emergency Contact Information). The BCP addresses:

Alternate Processing Sites: Geographically separated primary and secondary data centers with automatic failover. A tertiary disaster recovery facility is maintained for catastrophic scenarios.
Critical Personnel: Cross-training and succession planning for key operational and compliance roles. Remote work capabilities for all critical functions.
Data Protection: Continuous data replication, daily backups, and a Recovery Point Objective (RPO) of one (1) hour and Recovery Time Objective (RTO) of four (4) hours.
Communication Plan: Procedures for notifying clients, employees, regulators, and counterparties in the event of a significant business disruption. Alternate communication channels include dedicated toll-free hotline, SMS notifications, and the Apex status page.
Annual Testing: The BCP is tested at least annually through tabletop exercises and live failover drills. Test results are reviewed by senior management and documented for regulatory examination purposes.

The BCP summary is available to clients upon request by contacting compliance@apexfinancialpartners.com.

9. Privacy Notice (GLBA)¶

Pursuant to Regulation S-P (17 CFR Part 248), which implements the privacy provisions of the Gramm-Leach-Bliley Act, Apex provides an initial privacy notice to all clients at the time of establishing the advisory relationship and annually thereafter. The privacy notice describes the categories of personal information collected, the purposes for which information is used, the categories of third parties with whom information is shared, and the client's right to opt out of certain information-sharing practices. The full Privacy Policy is available at Privacy Policy & Data Protection.

10. Complaint Filing Procedures¶

10.1 Filing a Complaint with Apex¶

Clients who wish to file a complaint regarding Apex's services, personnel, or practices may do so through any of the following channels:

Written Complaint: Apex Financial Partners, Attn: Compliance Department, One Financial Center, Suite 4200, New York, NY 10004
Email: complaints@apexfinancialpartners.com
Telephone: 1-800-APEX-CMP (1-800-273-9267)
Online: Through the complaint submission form in the Apex Client Portal

All complaints are acknowledged within two (2) business days and investigated by the Compliance Department. A written response is provided within thirty (30) business days. Complaints alleging violations of securities laws or regulations are escalated to the Chief Compliance Officer for immediate review.

10.2 Filing a Complaint with Regulators¶

Clients may also file complaints directly with the following regulatory agencies:

SEC: Office of Investor Education and Advocacy, 100 F Street NE, Washington, DC 20549. Online: sec.gov/tcr. Phone: 1-800-SEC-0330.
FINRA: FINRA Investor Complaint Center. Online: finra.org/investors/have-problem. Phone: 1-301-590-6500.
State Securities Regulators: Contact your state's securities regulator through the North American Securities Administrators Association (NASAA) at nasaa.org.

11. SIPC Coverage¶

Client securities accounts held through Apex Securities, LLC are protected by the Securities Investor Protection Corporation (SIPC) up to $500,000 per customer (including up to $250,000 for cash claims) in the event of the broker-dealer's financial failure. SIPC protection does not cover losses due to market fluctuations, poor investment decisions, or fraud by the issuer of a security.

Apex Securities maintains excess SIPC insurance coverage through Lloyd's of London, providing additional protection of up to $150,000,000 in securities and $2,000,000 in cash per client, subject to an aggregate limit of $600,000,000. This coverage supplements, and does not replace, SIPC protection.

For more information about SIPC protection, visit sipc.org or call 1-202-371-8300.

12. Regulatory Contacts¶

Regulatory Body	Purpose	Contact
Securities and Exchange Commission (SEC)	Investment adviser oversight, securities regulation	sec.gov / 1-800-SEC-0330
Financial Industry Regulatory Authority (FINRA)	Broker-dealer oversight, arbitration	finra.org / 1-301-590-6500
Securities Investor Protection Corporation (SIPC)	Brokerage account protection	sipc.org / 1-202-371-8300
Financial Crimes Enforcement Network (FinCEN)	AML/BSA compliance	fincen.gov / 1-800-767-2825
Office of Foreign Assets Control (OFAC)	Sanctions compliance	treasury.gov/ofac / 1-800-540-6322
Consumer Financial Protection Bureau (CFPB)	Consumer financial product complaints	consumerfinance.gov / 1-855-411-2372
New York State Department of Financial Services (NYDFS)	State insurance and financial services regulation	dfs.ny.gov / 1-800-342-3736

Apex Financial Partners, LLC
Compliance Department
One Financial Center, Suite 4200
New York, NY 10004
Email: compliance@apexfinancialpartners.com
Telephone: 1-800-APEX-CMP (1-800-273-9267)
BrokerCheck: finra.org/brokercheck

Compliance & Regulatory Disclosures