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4:8 FINANCIAL
WWW.48FINANCIAL.COM
266 NORTHWEST 1ST AVE.
CANBY, OR 97013
P|(503) 266-4848
F|(503) 266-4840
PAUL@48FINANCIAL.COM
FORM ADV PART 2A
FIRM BROCHURE
DECEMBER 5, 2025
This brochure provides information about the qualifications and business practices of Carlson
Financial, Inc. dba 4:8 Financial. If you have any questions about the contents of this brochure,
please contact us at (503) 266-4848. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities
authority.
4:8 Financial is a registered investment adviser. Registration of an investment adviser does not
imply any level of skill or training.
information about 4:8 Financial
is available on
Additional
the SEC’s website
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD
number. 4:8 Financial CRD number is 335831.
ITEM 2 - MATERIAL CHANGES
We have no material changes to report since our firm’s initial brochure filing on July 1, 2025.
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ADV PART 2A – 12/5/2025
ITEM 3 – TABLE OF CONTENTS
ITEM 2 - MATERIAL CHANGES .............................................................................................................................. 2
ITEM 3 – TABLE OF CONTENTS ............................................................................................................................. 3
ITEM 4 – ADVISORY BUSINESS .............................................................................................................................. 4
ITEM 5 – FEES AND COMPENSATION ..................................................................................................................... 6
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE BY SIDE MANAGEMENT ..................................................................... 8
ITEM 7 – TYPES OF CLIENTS ................................................................................................................................. 8
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................................................ 8
ITEM 9 – DISCIPLINARY INFORMATION ................................................................................................................. 10
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ...................................................................... 10
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTION AND PERSONAL TRADING .................. 10
ITEM 12 – BROKERAGE PRACTICES ...................................................................................................................... 11
ITEM 13 – REVIEW OF ACCOUNTS ...................................................................................................................... 13
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .................................................................................... 13
ITEM 15 – CUSTODY ........................................................................................................................................ 13
ITEM 16 – INVESTMENT DISCRETION ................................................................................................................... 14
ITEM 17 – VOTING CLIENT SECURITIES ................................................................................................................ 14
ITEM 18 – FINANCIAL INFORMATION ................................................................................................................... 14
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ITEM 4 – ADVISORY BUSINESS
OWNERSHIP/ADVISORY HISTORY
Carlson Financial, Inc. dba 4:8 Financial (“we”) is an Oregon Corporation formed in May 2015. We
registered as an investment adviser with the Securities and Exchange Commission (“SEC”) in
August 2025. Paul Carlson is the owner and Chief Compliance Officer. Additional information
about Mr. Carlson can be found under Item 19 along with his Supplemental Brochure.
ADVISORY SERVICES OFFERED
We offer a complementary comprehensive financial plan where we will review your financial
situation, goals and risk tolerance. Through a series of personal interviews and/or the use of
questionnaires we will collect pertinent data, identify goals, objectives, financial problems, and
potential solutions. With this information, we tailor your financial plan and advice we give to
you. Our advice may cover any of the following topics: net worth statement; cash flow analysis;
insurance and long-term care analysis; tax planning; retirement planning; 401(k) and 401(b)
planning, college planning, risk management, income distribution, or other needs as identified
during our meetings with you.
LPL FINANCIAL SPONSORED ADVISORY PROGRAMS
We also provide advisory services through certain programs sponsored by LPL Financial LLC (LPL),
a registered investment advisor and broker-dealer. Below is a brief description of each LPL
advisory program that we offer. For more information regarding the LPL programs, including
more information on the advisory services and fees that apply, the types of investments available
in the programs and the potential conflicts of interest presented by the programs please see the
program account packet (which includes the account agreement and LPL Form ADV program
brochure) and the Form ADV, Part 2A of LPL or the applicable program.
STRATEGIC WEALTH MANAGEMENT (SWM)
We offer ongoing portfolio management services based on your individual goals, objectives, time
horizon, and risk tolerance. We evaluate the current investments with respect to your risk
tolerance levels and time horizon. We will request discretionary authority from you in order to
select securities and execute transactions without permission from you prior to each transaction
according to the portfolio selected.
A minimum account value of $100,000 is required for Manager Access Select, however, in certain
instances, the minimum account size may be lower or higher.
OPTIMUM MARKET PORTFOLIOS
OMP offers the ability to participate in a professionally managed asset allocation program using
Optimum Funds shares. Under OMP, you will authorize LPL on a discretionary basis to purchase
and sell Optimum Funds pursuant to investment objectives chosen by you. Advisor will assist you
in determining the suitability of OMP and assist you in setting an appropriate investment
objective. Adviser will have discretion to select a mutual fund asset allocation portfolio designed
by LPL consistent with your investment objectives. LPL will have discretion to purchase and sell
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Optimum Funds pursuant to the portfolio selected for you. LPL will also have authority to
rebalance the account.
A minimum account value of $10,000 is required for OMP. In certain instances, LPL will permit a
lower minimum account size.
MODEL WEALTH PORTFOLIOS
MWP offers a professionally managed mutual fund asset allocation program. We will obtain the
necessary financial data, assist you in determining the suitability of the MWP program and assist
you in setting an appropriate investment objective. We will initiate the steps necessary to open
an MWP account and have discretion to select a model portfolio designed by LPL’s Research
Department consistent with your stated investment objectives. LPL’s Research Department or
third-party portfolio strategists are responsible for selecting the mutual funds or ETFs within a
model portfolio and for making changes to the mutual funds or ETFs selected.
You will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs
and to liquidate previously purchased securities. You will also authorize LPL to effect rebalancing
for MWP accounts.
MWP requires a minimum asset value for a program account to be managed. The minimums vary
depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The
lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio
is permitted.
GUIDED WEALTH PORTFOLIOS (GWP)
GWP offers clients the ability to participate in a centrally managed, algorithm-based investment
program, which is made available to users and clients through a web-based, interactive account
management portal (“Investor Portal”). Investment recommendations to buy and sell open-end
mutual funds and exchange-traded funds are generated through proprietary, automated
computer algorithms (collectively, the “Algorithm”) of Xulu, Inc., doing business as FutureAdvisor
(“FutureAdvisor”), based upon model portfolios constructed by LPL and selected for the account
as described below (such model portfolios selected for the account, the “Model Portfolio”).
Communications concerning GWP are intended to occur primarily through electronic means,
including but not limited to, through email communications or through the Investor Portal,
although we will be available to discuss investment strategies, objectives or the account in
general in person or via telephone.
A preview of the Program (the “Education Tool”) is provided for a period of up to forty-five (45)
days to help users determine whether they would like to become advisory clients and receive
ongoing financial advice form LPL, FutureAdvisor or us by enrolling in the advisory service (the
“Managed Service”). The Education Tool and Managed Service are described in more detail in
the GWP Program Brochure. Users of the Education Tool are not considered to be advisory
clients of LPL, FutureAdvisor or us, do not enter into an advisory agreement with LPL,
FutureAdvisor or us, do not receive ongoing investment advice or supervision of their assets, and
do not receive any trading services.
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A minimum account value of $5,000 is required to enroll in the Managed Service.
RETIREMENT PLAN CONSULTING
We provide retirement plan consulting on participant education and enrollment. Additional
services may be offered based on the needs of the qualified plan.
TAILORED SERVICES
We tailor all our services to the client’s stated goals, needs and objectives. For our portfolio
management services clients, we allow them to impose restrictions on investments in certain
securities or types of securities. All restrictions may be presented to us in writing.
WRAP PROGRAM
We offer our SWM services with LPL through a wrap fee program. LPL is the sponsor of the wrap
fee program. Our wrap fee accounts are managed on an individualized basis according to your
existing investments, investment objectives, financial goals, risk tolerance, etc. Our portfolio
management services are only offered through a wrap fee program. With our wrap fee program,
you charged a specified annual fee – not based directly on transactions in your accounts – for
Investment Advisory services, which include portfolio management, third party manager
selections (if offered), custody, brokerage, other costs of execution of client transactions, and
other services provided under the program. A portion of the fee goes to us for services provided
under the wrap fee program, and a portion goes towards third-party brokerage, execution, and
custody costs. Please note that the wrap fee is separate and distinct from the fees and expenses
charged by mutual funds & ETFs to their shareholders, and it is separate and distinct from fees
charged by third-party managers. Unlike clients in a wrap fee program, clients in a non-wrap fee
program pay the custodian a per-trade commission or ticket charge and pay the costs of
brokerage, execution, and custody separately. The wrap fee program may cost more or less than
purchasing the covered wrap fee services separately, depending on a variety of factors, including
the amount of trading in the account and the costs of the services purchased separately. There
is no difference in the style of management, or the portfolios and securities used in the Wrap Fee
Program as opposed to a Non-Wrap Program.
Additional information about our model portfolios as a wrap program can be found in our
Appendix 1 to the ADV Part 2A (i.e., Wrap Fee Program Brochure).
CLIENT ASSETS MANAGED
As of October 2, 2025, we manage $299,187,159 in discretionary assets and $2,100,000 in non-
discretionary assets.
ITEM 5 – FEES AND COMPENSATION
LPL FINANCIAL SPONSORED ADVISORY PROGRAMS
We charge a management fee based on the percentage of assets under management. The
management fee for the OMP, GWP* and MWP* is an annual fee that ranges from 0% to 1.35%.
The fee is negotiable.
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The management fee will be calculated and collected quarterly, in advance, based on the
account’s prior quarter-end value as reported by the account’s custodian.
*The MWP account fee consists of an LPL program fee, a strategist fee (if applicable) and an
adviser fee. Accounts remaining under the legacy fee structure may be charged one aggregate
account fee, for which the maximum account fee will not exceed 2.50%. See the MWP program
brochure for more information.
*GWP Managed Service clients are charged an account fee consisting of an LPL program fee of
0.35%. In the future, a strategist fee may apply. However, PLP Research currently serves as the
sole portfolio strategist and does not charge a fee for its services. FutureAdvisor is compensated
directly by PLP for its services, including the Algorithm and related software, through an annual
sub-advisory fee (tiered based on assets under management by FutureAdvisor, at a rate ranging
from 0.10% to 0.17%). As each asset tier is reached, LPL’s share of the compensation shall
increase, and clients will not benefit from such asset tiers.
GWP Education Tool provides access to sample recommendations at no charge to users.
However, if users decide to implement sample recommendations by executing trades, they will
be charged fees, commissions, or expenses by the applicable broker or adviser, as well as
underlying investment fees and expenses. Account fees are payable quarterly, in advance. The
portfolio management fee will be calculated and collected on a quarterly basis in arrears. The
management fee is based on the custodian’s reported account value as of the last business day
of the quarter. The management fee will be directly deducted from the client’s account by LPL
(see Item 15 for additional details).
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and
expenses that are incurred by the client. Clients may incur other custodian charges, which are
separate from our fees. Also, our fee does not include the third-party investment adviser or LPL’s
management fee in the MWP program.
The programs invest in mutual funds. The client pays the mutual funds a management fee and
other expenses as a shareholder of the mutual fund in addition to paying an advisory fee to us
and LPL for managing the assets. Because mutual funds may be purchased directly, the client
could avoid the second layer of fees by not using our management services and by making his or
her own investment decisions.
TERMINATION OF SERVICES
You may terminate any service for any reason within the first five (5) business days after signing
an advisory contract, without any cost or penalty. Thereafter, the advisory contract may be
terminated at any time by giving ten (10) days’ written notice. To cancel the agreement, you
must notify us in writing at 4:8 Financial, 266 Northwest 1st Avenue, Canby, OR 97013. Because
we charge in advance you will receive a prorated refund for the number of days the account was
not managed during the quarter’s billing period. For example, if services were terminated 45
days into a 90-day quarter you will receive a 50% refund (45 days divided by 90 days equals
50%).
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OTHER SECURITIES COMPENSATION
We do not receive any other securities compensation.
RETIREMENT ROLLOVER CONFLICTS OF INTEREST
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 of interest with your
interests, so we operate under a special rule that requires us to act in your best interest and not
put our interests ahead of yours.
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE BY SIDE MANAGEMENT
We do not charge any performance-based fees (fees based on a share of capital gains or capital
appreciation of the assets of a client) or provide side by side management.
ITEM 7 – TYPES OF CLIENTS
We offer our services to individuals, high net worth individuals, charities, and pension and profit-
sharing plans. We do not require a minimum account balance.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
When we create your portfolio, we use asset allocation and strategic asset allocation. Once the
asset allocation strategy is created, we use fundamental analysis. Once the portfolio is created,
we will buy and hold but also reallocate assets regularly. A description of these methods of
analysis and investment strategies are described below:
Asset Allocation is an investment strategy that aims to balance risk and reward by apportioning
a portfolio's assets according to an individual's goals, risk tolerance and investment horizon
among various asset classes. The asset classes typically include, but are not limited to equities,
fixed income, and cash and equivalents. The risk associated with asset allocation is that each class
has different levels of risk and return, so each will behave differently over time. There is no
guarantee that diversification among asset classes will grow a portfolio.
Strategic asset allocation is a portfolio strategy that involves setting target allocations for various
asset classes and rebalance periodically. The portfolio is rebalanced to the original allocations
when they deviate significantly from the initial settings due to differing returns from the various
assets. The target allocations depend on several factors, such as the investor’s risk tolerance,
time horizon, and investment objectives, and may change over time as these parameters change.
Strategic asset allocation is compatible with a buy-and-hold strategy, as opposed to tactical asset
allocation that is more suited to an active trading approach.
Our analysis of securities and advice relating thereto may be based upon information obtained
from financial newspapers and magazines, research materials prepared by others, corporate
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ratings services, and annual reports, prospectuses and filings made with the Securities and
Exchange Commission. We could also utilize computer models for performance analysis, asset
allocation and risk management.
INVESTMENT RISKS
All investment programs have certain risks that are borne by you and investing in securities
involves risk of loss that clients should be prepared to bear. Our goal is to reduce the risk of loss,
but not at the expense of portfolio growth. Recommended investment strategies seek to balance
risks and rewards to achieve investment objectives. To manage risk, we rebalance model
portfolios on an as needed basis to bring the asset allocations back to their intended balances.
The client should feel free to ask questions about risks that he or she does not understand; we
would be pleased to discuss them.
RECOMMENDED SECURITIES
We use several types of securities in client portfolios including, but not limited to, mutual funds,
Exchange Traded Funds (ETFs), stocks, bonds, and CDs. Some of the risks associated with these
securities include:
Credit Risk: This is the risk an issuer of a bond could suffer an adverse change in financial
condition that results in a payment default, security downgrade, or inability to meet
financial obligation.
Inflation Risk: This is the risk that inflation will undermine the performance of an
investment and/or the future purchasing power of a client's assets.
Interest Rate Risk: The chance that bond prices overall will decline because of rising
interest rates.
Exchange-Traded Funds (ETFs). ETFs are typically investment companies that are legally
classified as open-end mutual funds or UITs, however, they differ from traditional mutual
funds because ETF shares are listed on a securities exchange. Shares can be bought and
sold throughout the trading day like shares of other publicly traded companies. ETF shares
may trade at a discount or premium to their net asset value. This difference between the
bid price and the ask price is often referred to as the “spread.” The spread varies over
time based on the ETF’s trading volume and market liquidity and is generally lower if the
ETF has a lot of trading volume and market liquidity and higher if the ETF has little trading
volume and market liquidity. Although many ETFs are registered as investment companies
under the Investment Company Act of 1940 like traditional mutual funds, some ETFs,
including those that invest in commodities, are not registered as investment companies.
Manager Risk: The chance that the proportions allocated to the various securities will
cause the client’s account to underperform relevant to benchmarks or other accounts
with a similar investment objective.
Stock Market Risk: The chance that stock prices overall will decline. Stock markets tend
to move in cycles, with periods of rising stock prices and periods of falling stock prices.
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ITEM 9 – DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of each supervised person providing
investment advice. We do not have information applicable to this item.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
BROKER DEALER AFFILIATION
We are not affiliated with a broker dealer.
FUTURES/COMMODITIES FIRM AFFILIATION
We are not affiliated with a futures or commodities broker.
OTHER INDUSTRY AFFILIATIONS
Our owner, Mr. Carlson, and associates are licensed insurance agents. They may recommend the
sale of insurance products to you. This other business activity pays them commissions that are
separate from the fees described in item 5, above. The commissions give them a financial
incentive to recommend and sell you the insurance products. They attempt to mitigate any
conflicts of interest to the best of their ability by placing your interest ahead of our own and
through the implementation of policies and procedures that address the conflict. Additionally,
you are informed that you always have the right to choose whether to act on the
recommendation and you have the right to purchase recommended insurance through any
licensed insurance agent.
RECOMMENDATION OF THIRD-PARTY INVESTMENT ADVISER
In the MWP program, we may use the services of unaffiliated Third-Party Investment Advisers
(“Third Party Adviser”) to assist in managing your account. We will disclose the use of an
unaffiliated Third-Party Adviser when used in your account. We do not receive compensation
directly or indirectly from the advisers or have any other business relationships that would create
a material conflict of interest.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTION AND PERSONAL
TRADING
DESCRIPTION
Our Code of Ethics establishes ideals for ethical conduct based upon fundamental principles of
openness, integrity, honesty, and trust. We will provide a copy of our Code of Ethics to any client
or prospective client upon request.
Our Code of Ethics covers all supervised persons, and it describes our high standard of business
conduct and fiduciary duty to our clients. The Code of Ethics includes, among other things,
provisions relating to the confidentiality of client information, a prohibition on insider trading, a
prohibition on rumor mongering, restrictions on the acceptance of significant gifts and the
reporting of certain gifts and business entertainment items, and personal securities trading
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procedures. All supervised persons must acknowledge the terms of the Code of Ethics annually
or as amended.
MATERIAL INTEREST IN SECURITIES
We do not have a material interest in any securities.
INVESTING IN OR RECOMMENDING THE SAME SECURITIES
Our owner and our representatives may buy or sell the same securities for his own account at or
about the same time that he recommends those securities to you or purchase them for client
accounts. A conflict of interest may exist because they can trade ahead of client trades. We
mitigate any conflict of interest in two ways. First, our Code of Ethics requires employees to: 1)
report personal securities transactions on at least a quarterly basis, and 2) provide us with a
detailed summary of certain holdings (both initially upon commencement of employment and
quarterly thereafter) in which employees have a direct or indirect beneficial interest. The reports
are reviewed to ensure we do not trade ahead of your accounts. Second, we require your
transactions be placed ahead of our associates’ personal trades or our associates can place
personal trades as part of a block trade (Please see Item 12.B for details on our block trading
practices). The records of all associates’ personal and client trading activities are reviewed and
made available to regulators to review on the premises.
ITEM 12 – BROKERAGE PRACTICES
RECOMMENDATION CRITERIA
We generally recommend that you establish a brokerage account with LPL Financial to maintain
custody of your assets and to effect trades for their accounts.
LPL FINANCIAL
LPL Financial provides brokerage and custodial services to independent investment advisory
firms, including us. For our accounts custodied at LPL Financial, LPL Financial generally is
compensated by clients through commissions, trials, or other transaction-based fees for trades
that are executed through LPL Financial or that settle into LPL Financial accounts. For IRA
accounts, LPL Financial generally charges account maintenance fees. In addition, LPL Financial
also charges you miscellaneous fees and charges, such as account transfer fees. LPL Financial
charges us an asset-based administration fee for administrative services provided by LPL
Financial. Such administration fees are not directly borne by you but may be taken into account
when we negotiate our advisory fee with you.
You should also be aware that for accounts where LPL Financial serves as the custodian, we are
limited to offering services and investment vehicles that are approved by LPL Financial and may
be prohibited from offering services and investment vehicles that may be available through other
broker-dealers and custodians, some of which may be more suitable for your portfolio than the
services and investment vehicles offered through LPL Financial.
You should understand that not all investment advisers request that you custody your accounts
and trade through specific broker-dealers.
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Benefits Received by Our Personnel
LPL Financial makes available to us various products and services designed to assist us in
managing and administering client accounts. Many of these products and services may be used
to service all or a substantial number of our accounts, including accounts not held with LPL
Financial. These include software and other technology that provide access to your account data
(such as trade confirmation and account statements); facilitate trade execution (and aggregation
and allocation of trade orders for multiple client accounts); provide research, pricing information
and other market data; facilitate payment of our fees from your accounts; and assist with back-
office functions; recordkeeping and client reporting.
LPL Financial also makes available to us other services intended to help us manage and further
develop its business. Some of these services assist us to better monitor and service program
accounts maintained at LPL Financial, however, many of these services benefit only us, for
example, services that assist us in growing our business. These support services and/or products
may be provided without cost, at a discount, and/or at a negotiated rate, and include practice
management-related publications; consulting services; attendance at conferences and seminars,
meetings, and other educational and/or social events; marketing support; and other products
and services used by us in furtherance of the operation and development of our investment
advisory business.
Where such services are provided by a third party vendor, LPL Financial will either make a
payment to us to cover the cost of such services, reimburse us for the cost associated with the
services, or pay the third party vendor directly on behalf of us.
The products and services described above are provided to us as part of our overall relationship
with LPL Financial. While as a fiduciary we endeavor to act in your best interests, the receipt of
these benefits creates a conflict of interest because we recommend that you custody your assets
at LPL Financial is based in part on the benefit to us of the availability of the foregoing products
and services and not solely on the nature, cost or quality of custody or brokerage services
provided by LPL Financial. Our receipts of some of these benefits may be based on the amount
of advisory assets custodied on the LPL Financial platform.
RESEARCH AND SOFT DOLLARS
“Soft dollars” are defined as a form of payment investment firms can use to pay for goods and
services such as news subscriptions or research. When an investment firm gives its business to a
particular brokerage firm, the brokerage firm in return can agree to use some of its revenue to
pay for these types of services. We may receive economic benefits through our participation with
LPL Financial. Additional details are described in Item 12, above and Item 14.
BROKERAGE FOR CLIENT REFERRALS
We do not receive client referrals or any other incentive from any broker-dealer or custodian.
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DIRECTED BROKERAGE
We require clients use LPL Financial, LLC (“LPL”) as the custodian of the client accounts that we
manage. LPL sponsors our wrap program. We believe LPL’s wrap program platform provides the
quality trade execution, reliable services, and the availability of numerous investment options.
TRADE AGGREGATION
We may aggregate transactions in equity and fixed income securities for a client with other clients
to improve the quality of execution. When transactions are aggregated, the actual prices
applicable to the aggregated transactions will be averaged, and the client account will be deemed
to have purchased or sold its proportionate share of the securities involved at the average price
obtained. We may determine not to aggregate transactions, for example, based on the size of
the trades, the number of client accounts, the timing of the trades, the liquidity of the securities
and the discretionary or non-discretionary nature of the trades. If we do not aggregate orders,
some clients purchasing securities around the same time may receive a less favorable price than
other clients. This means that this practice of not aggregating may cost clients more money.
ITEM 13 – REVIEW OF ACCOUNTS
PERIODIC REVIEWS
Our representatives will conduct periodic reviews of the account holdings and rebalance when
necessary. They will also attempt to meet with you annually either in person, by telephone, or
via virtual meeting and provide any updates to your financial situation.
OTHER REVIEWS
Additional reviews are conducted periodically depending on market conditions, economic or
political events, or any changes in a client’s financial situation (such as retirement, termination
of employment, physical move, or inheritance).
REPORTS
If you engage in comprehensive financial planning, we may provide a written financial plan. You
will also receive at least quarterly statements and quarterly performance reports from LPL
Financial, LLC. We urge you to carefully review those statements.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
OTHER COMPENSATION
We do not receive any other compensation.
CLIENT REFERRALS
We do not use solicitors or pay for client referrals.
ITEM 15 – CUSTODY
Your funds, securities, and accounts will be held by a qualified custodian, LPL. We do not take
possession of your assets. However, you will be asked to authorize LPL with the ability to deduct
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our management fee directly from the client’s account. This authorization will be to deduct our
management fee only. A client may cancel this authorization at any time by notifying us or LPL.
The client will receive at least quarterly statements from LPL. We urge clients to carefully review
those statements.
ITEM 16 – INVESTMENT DISCRETION
We offer discretionary investment management services. You must sign the investment
management agreement to grant us discretionary power over the account. Our investment
management agreement contains a limited power of attorney that allows us to select the
security, the amount, and the time of the purchase or sale in your account. It also allows us to
place each such trade without your prior approval. In addition to our investment management
agreement, your custodian may request that you sign the custodian’s limited power of attorney.
This varies with each custodian. We discuss all limited powers of attorney with you prior to their
execution. In all cases, however, such discretion is to be exercised in a manner consistent with
the stated investment objectives for your account, and any other investment policies, limitations
or restrictions.
ITEM 17 – VOTING CLIENT SECURITIES
We do not vote proxy votes for any client. All proxy materials are mailed or emailed directly to
you from the custodian. Any proxy materials received by us will be forwarded to you for response
and voting. In the event you have a question about a proxy solicitation, you should feel free to
contact us.
ITEM 18 – FINANCIAL INFORMATION
BALANCE SHEET
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or
more in advance. Therefore, we are not required to provide a balance sheet.
FINANCIAL CONDITION
We are required in this Item to provide you with certain financial information or disclosures about
our financial condition if we have a financial commitment that impairs our ability to service you.
We do not have a financial commitment that impairs our ability to service our clients.
BANKRUPTCY
We have not been the subject of a bankruptcy proceeding.
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