For your CCO, compliance department, or RIA principal.

1. Description of the Platform

Plan Your Passing is a third-party technology and content platform providing estate-planning education to families. Content includes: 50-state probate guides, scripted conversations for adult-children-with-aging-parents dynamics, an 8-document framework for personal estate readiness, an 88,600-word book manuscript, and document- builder tools (will builder, advance directive builder, POA builder) which produce starting drafts with explicit “consult a licensed attorney” language on every output. The platform is owned by Plan Your Passing (5740 Everwood Court, San Pablo, CA 94806) and is not affiliated with any BD, RIA, or insurance carrier.

2. Nature of the Partner Subscription

The partner advisor pays a flat monthly SaaS fee ($97–$297/month) for: a co-branded subdomain (yourfirm.planyourpassing.org), a sales-asset library (email templates, social posts, family meeting facilitation guide, workshop kit), and ongoing content updates. The fee is not contingent on any client transaction, is not a referral fee, is not paid out of any advisory fee or commission, and is not compensation for the recommendation of any security or investment product. It is the same category as a CRM, marketing automation tool, or content- syndication subscription.

3. FINRA Rule 2210 (BD-affiliated advisors)

All advisor-facing marketing materials provided in the sales kit are educational/general in nature. They do not recommend any security, investment strategy, or specific product. They are categorized as retail communications under Rule 2210(a)(5) when distributed to more than 25 retail investors, and require principal approval prior to use. The advisor partner is responsible for submitting all platform-provided materials through their BD's standard advertising review process before deployment, including any state-specific filings. Pre-filing requirements (e.g., NASAA model rule, certain state IA rules) are the advisor's responsibility.

4. SEC Marketing Rule (RIA-affiliated advisors)

The platform is subject to compliance under the SEC Marketing Rule (Rule 206(4)-1 under the Investment Advisers Act of 1940). All platform-provided materials are reviewed by the partner advisor prior to use. The platform does not provide testimonials, endorsements, or performance results. The earnings projections on the partner-facing pages (/for-advisors, /partners) are disclosed as illustrative and are not distributed to retail prospects or clients — they exist on the platform's public-facing partner-recruitment pages, which carry an FTC-compliant earnings disclaimer (16 CFR §437). No client- facing material in the partner sales kit contains performance, return, or income claims.

5. Hypothetical Performance & Income Claims

The advisor-facing landing page (/for-advisors) contains hypothetical income projections for advisors (e.g., $19,200 in retained AUM fees from a 40-point retention delta). These are not investment performance claims — they project the advisor's own business revenue under stated assumptions. They are flagged as projections, not guarantees, and linked to the platform's full earnings disclaimer. None of these claims appear in any client-facing materials in the sales kit. Client materials describe the family-meeting process and the estate-planning content only.

6. Books & Records

Per Rule 204-2 (Advisers Act) and FINRA Rule 4511, the partner advisor must retain copies of all advertisements and marketing communications for the required retention period (typically 5 years; first 2 years in an easily accessible location). The platform-provided assets are static text files; copies can be exported to the advisor's recordkeeping system. Co-branded subdomain pages can be archived via WebPreserver, PageVault, or standard PDF archival.

7. Required Disclosures on Partner Materials

Every advisor-distributed asset (email, postcard, social post, workshop deck) must include the partner advisor's required compliance disclosures, which the platform supports via a configurable footer block. Examples:

• Advisor's legal name and required designation reference
• Firm name and required affiliation language
• Form ADV / Form CRS references where applicable
• FINRA / SIPC / SEC registration disclosures
• State-specific advertising disclosures (e.g., California §25140)
• “Educational only — not investment, legal, or tax advice”
• CAN-SPAM physical mailing address (the advisor's firm address)

8. Conflicts of Interest

The platform does not pay the advisor for any client activity. The advisor does not pay the platform any transaction-based or asset-based fee. There is no soft- dollar arrangement, no commission share, and no inducement tied to client recommendations. The platform owner (Roger Daniel Grubb) is a California-licensed real estate broker with no financial-services registrations. He does not solicit, refer, or transact in securities, advisory services, or insurance products.

9. Privacy & Data

The platform operates under a public privacy policy and CCPA/CPRA-compliant California consumer notice. Client contact information submitted via the advisor's co-branded forms is forwarded directly to the advisor and not used for any other purpose. The platform does not sell, share for behavioral advertising, or transmit client data to any third party. The advisor's firm remains the data controller for advisory-relationship information.