Overview
- Headquarters
- Columbia, SC
- Average Client Assets
- $7.7 million
- SEC CRD Number
- 107994
Fee Structure
Primary Fee Schedule (ABACUS PLANNING GROUP PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $2,000,000 | 1.00% |
| $2,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.25% |
Minimum Annual Fee: $18,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $18,000 | 1.80% |
| $5 million | $35,000 | 0.70% |
| $10 million | $60,000 | 0.60% |
| $50 million | $160,000 | 0.32% |
| $100 million | $285,000 | 0.28% |
Clients
- HNW Share of Firm Assets
- 90.68%
- Total Client Accounts
- 2,854
- Discretionary Accounts
- 2,818
- Non-Discretionary Accounts
- 36
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles
Regulatory Filings
Additional Brochure: ABACUS PLANNING GROUP PART 2A (2026-04-09)
View Document Text
part 2 form ADV \
item 1
cover page
Abacus Planning Group, Inc.
2500 Devine Street
Columbia, South Carolina 29205-2400
803.933.0054
marc@abacusplanninggroup.com
www.abacusplanninggroup.com
March 25, 2026
| This brochure provides information about the qualifications and business practices of Abacus Planning Group,
Inc. If you have any questions about the contents, please contact Abacus at 803.933.0054 or Marc McQueen,
CCO, at marc@abacusplanninggroup.com. Neither The United States Securities and Exchange Commission nor
any state securities authority approved the information in this brochure.
| Additional information about Abacus Planning Group, Inc. is available on the SEC website:
www.adviserinfo.sec.gov. You may search this site by using a unique identifying number, known as a CRD
number. Abacus's CRD number is 107994.
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item 2 material changes
There have been material changes made to this brochure since the firm’s last Annual Amendment filing on March 14,
2025:
| As of the date of the filing of this Brochure, the Firm’s Chief Compliance Officer is Mr. Marc McQueen
| As of December 31, 2025, all series of Terrum Royalty Fund have been dissolved.
item 3 table of contents
item 1 cover page
item 2 material changes
item 3 table of contents
item 4 advisory business
item 5 fees and compensation
item 6 performance-based fees and side-by-side management
item 7 types of clients
item 8 methods of analysis, investment strategies and risk of loss
item 9 disciplinary information
item 10 other financial industry activities and affiliations
item 11 code of ethics, participation or interest in client transactions and personal trading
item 12 brokerage practices
item 13 review of accounts
item 14 client referrals and other compensation
item 15 custody
item 16 investment discretion
item 17 voting client securities
item 18 financial information
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item 4 advisory business
Abacus Planning Group, Inc. (Abacus), founded in 1998, is a SEC-registered investment adviser headquartered in
Columbia, South Carolina.
The investment advice provided by Abacus focuses solely on the individual needs of the client. Through
conversations, collection of financial information and assessment questionnaires, Abacus documents a client’s
personal circumstances, individual objectives, risk tolerance, time horizons, liquidity needs, growth and income
expectations, as well as income and estate tax considerations. When appropriate, Abacus also reviews a client's prior
investment history.
Information gathered in this process guides the creation and management of the client’s portfolio.
After establishing written investment policy guidelines and implementing the investment recommendations approved
by the client, the Abacus investment team consistently reviews the portfolio using both manual and automated
methods. The portfolio is rebalanced on an ongoing basis to consistently reflect the client's established guidelines.
Our investment recommendations are not limited to any specific product or service and will generally include advice
regarding the following securities:
| Exchange-listed securities
| Exchange-traded funds
| Securities traded over-the-counter
| Foreign issuers
| Corporate debt securities [other than commercial paper]
| Hedge funds
| Limited partnership interests
| Municipal bonds
| Mutual fund shares
| United States governmental securities
| Money market funds
| Certificates of deposit
financial planning
Our financial planning services begin with a comprehensive financial plan. The financial plan will typically address the
following areas:
goal setting | Abacus documents a set of personalized financial objectives for each client through a series of open-
ended questions and assessment tools.
investment philosophy | Abacus educates each client as to its basic tenets of portfolio management. Abacus also
presents each client with an initial analysis of his or her current portfolio.
financial independence | Abacus creates long-term cash-flow projections, in order for each client to understand
how much to save at the pre-retirement stage or how much can be spent each year if he or she is already financially
independent. Abacus creates multiple “what-if” scenarios to make clients aware of how changes in the assumptions
can impact their future financial security.
education funding | Abacus projects the cost of educating children or grandchildren and suggests the most
effective ways to fund these upcoming expenses.
investment policy guidelines and recommendations | Abacus dovetails a client’s investment plan with the
client’s goals through written investment policy guidelines and specific investment recommendations unique to each
client.
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risk management review | Abacus evaluates a client’s various insurance policies – from automobile to long-term
care and life insurance. Abacus will comment on the quality and cost of the existing coverage as well, and where
necessary, make recommendations for termination or additional coverage in conjunction with your insurance agent.
income tax review | Abacus will review each client’s income tax return and, in conjunction with the client’s CPA,
make income tax planning recommendations.
estate planning review | Abacus examines each client’s current estate plan to confirm it meets stated goals and
family objectives. If changes are needed, we will work closely with the client’s estate planning attorney and
accountant to implement these changes. If a client needs to engage an attorney or accountant, we will assist in
selecting the appropriate professional.
portfolio reports | Clients are “walked through” the format of the Abacus portfolio report. This ensures each client
is familiar with the presentation of the information and has a chance to ask questions to fully understand the regular
reports.
Typically, the initial financial plan is completed and presented over the course of the first year of the advisory
contract date. The Abacus team continually updates each client’s planning component, to reflect changes within the
client’s financial life or external to the client such as changes to income or estate tax laws.
tax preparation | At Abacus’ discretion, Abacus may assist with a client’s tax return preparation. There is no
additional fee for tax return preparation services. No client or prospective client is obligated to engage Abacus for tax
return preparation services. Clients are reminded that they can engage other providers. Abacus will happily work
with the tax professional of the client’s choosing.
important disclosures
limitations of financial planning and non-investment consulting / implementation services | As indicated
above, to the extent requested by a client, Abacus may provide financial planning and related consulting services.
Abacus and its investment adviser representatives will assist clients with the implementation of a financial plan.
Unless engaged to do so, Abacus does not monitor a client’s financial plan. It is the client’s responsibility to revisit
their financial plan with Abacus, if and when desired.
Furthermore, although Abacus may provide recommendations regarding non-investment related matters, such as
estate planning, tax planning and insurance, Abacus does not serve as a law firm, accounting firm, or insurance
agency, and no portion of Abacus’ services should be construed as legal, accounting, or insurance implementation
services. Accordingly, Abacus does not prepare estate planning documents, tax returns or sell insurance products
except when specifically requested by a client.
To the extent requested by a client, Abacus may recommend the services of other professionals for certain non-
investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are reminded that
they are under no obligation to engage the services of any such recommended professional. The client retains
absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made
by Abacus or its representatives.
If the client engages any unaffiliated recommended professional, and a dispute arises thereafter relative to such
engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times,
the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not Abacus, shall be
responsible for the quality and competency of the services provided.
retirement plan rollovers – potential for conflict of interest | A client or prospective client leaving an employer
typically has four options regarding an existing retirement plan (and may engage in a combination of these options):
(i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if
one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash
out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Abacus
recommends that a client roll over their retirement plan assets into an account to be managed by Abacus, such a
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recommendation creates a conflict of interest if Abacus will earn new (or increase its current) compensation as a
result of the rollover. If Abacus provides a recommendation as to whether a client should engage in a rollover or not
(whether it is from an employer’s plan or an existing IRA), Abacus is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account
managed by Abacus, whether it is from an employer’s plan or an existing IRA.
use of mutual funds, exchange traded funds and dimensional fund advisors mutual funds | Abacus utilizes
mutual funds and exchange traded funds for its client portfolios. In addition to Abacus’ investment advisory fee
described below, and transaction and/or custodial fees discussed above, clients will also incur, relative to all mutual
fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund
expenses). The mutual funds and exchange traded funds utilized by the Abacus are generally available directly to
the public. Thus, a client can generally obtain the funds recommended and/or utilized by Abacus independent of
engaging Abacus as an investment advisor. However, if a prospective client does so, then they will not receive
Abacus' initial and ongoing investment advisory services.
Others mutual funds, such as those issued by Dimensional Fund Advisors (“DFA”) are generally only available
through registered investment advisers. Abacus may allocate client investment assets to DFA mutual funds.
Therefore, upon the termination of Abacus’s services to such a client, restrictions regarding transferability, additional
purchases of, or reallocation among DFA funds will apply. Please Note: In addition to Abacus’ investment advisory
fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all
mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and
other fund expenses).
affiliated private funds | Abacus is the managing partner of Terrum Real Estate Partnership I, LP, Tyche
Opportunity Fund I, LP, Periculum, LP, Series A, Periculum, LP, Series B, and Periculum, LP, Series C (together the
“Affiliated Funds”), the complete description of which is set forth in the each of the Affiliated Fund’s offering
documents. Abacus, on a non-discretionary basis, may recommend that qualified clients consider allocating a portion
of their investment assets to one or more of the Affiliated Funds. Abacus’s clients are under absolutely no obligation
to consider or make an investment in a private investment fund(s).
Private investment funds generally involve various risk factors, including, but not limited to, potential for complete
loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each
fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid
investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each
prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall
establish that they are qualified for investment in the fund, and acknowledges and accepts the various risk factors
that are associated with such an investment.
In the event that we reference Affiliated Funds owned by the client on any supplemental account reports, the values
for all Affiliated Funds will generally reflect the most recent value. The current value of any Affiliated Fund could be
significantly more or less than the original purchase price or the price reflected in any supplemental account report.
If an Affiliated Funds has invested in a third-party fund, the investment manager of that fund is responsible for
determining the value of interests in that fund. Abacus will rely on values provided by the third-party fund’s
manager.
portfolio activity | Abacus has a fiduciary duty to provide services consistent with the client’s best interest. As part
of its investment advisory services, we will review client portfolios on an ongoing basis to determine if any changes
are necessary based upon various factors, including but not limited to investment performance, fund manager
tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s
investment objectives. Based upon these and other factors, there may be extended periods of time when we
determine that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject
to the fees described in Item 5 below during periods of account inactivity.
cash positions | Abacus continues to treat cash as an asset class. As such, unless determined to the contrary by
Abacus, all cash positions (money markets, etc.) shall continue to be included as part of assets under management
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for purposes of calculating Abacus’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will
occur), Abacus may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash,
such amounts could miss market advances. Depending upon current yields, at any point in time, Abacus’s advisory
fee could exceed the interest paid by the client’s money market fund.
cash sweep accounts | Certain account custodians can require that cash proceeds from account transactions or
new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on
the sweep account will generally be lower than those available for other money market accounts. When this occurs,
to help mitigate the corresponding yield dispersion, Abacus shall (usually within 30 days thereafter) generally (with
exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s
platform, unless Abacus reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day
period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur
with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of
dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from
the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the
account. Please Note: The above does not apply to the cash component maintained within Abacus’ actively managed
investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep
account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated
investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain
exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances
maintained in any Abacus unmanaged accounts. ANY QUESTIONS: Abacus’ Chief Compliance Officer remains
available to address any questions that a client or prospective client may have regarding the above.
other assets | To the extent that Abacus provides advisory monitoring or review services for client investment
assets for which the Abacus does not maintain custodian access or trading authority (including initial and ongoing
consideration of such assets as part of the client’s asset allocation), Abacus may determine to include such assets in
its advisory fee calculation per Item 5 below.
cybersecurity risk | The information technology systems and networks that Abacus and its third-party service
providers use to provide services to Abacus’s clients employ various controls that are designed to prevent
cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions
in Abacus’s operations and/or result in the unauthorized acquisition or use of clients’ confidential or non-public
personal information. Clients and Abacus are nonetheless subject to the risk of cybersecurity incidents that could
ultimately cause them to incur financial losses and/or other adverse consequences. Although Abacus has established
processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be
successful, especially considering that Abacus does not control the cybersecurity measures and policies employed by
third-party service providers, issuers of securities, broker-dealers, qualified custodians, governmental and other
regulatory authorities, exchanges, and other financial market operators and providers.
client privacy and confidentiality | Abacus maintains policies and procedures designed to help protect the
confidentiality and security of client nonpublic personal information (“NPPI”). NPPI includes, but is not limited to,
social security numbers, credit or debit card numbers, state identification card numbers, driver’s license number and
account numbers. Abacus maintains administrative, technical, and physical safeguards designed to protect such
information from unauthorized access, use, loss, or destruction. These safeguards include controls relating to data
access, information security, and incident response, and are reviewed to address changes in risk and business. Client
information may be disclosed in response to regulatory requests, legal obligations, or as otherwise permitted by law,
and any such disclosure is made in accordance with applicable privacy and confidentiality requirements. Abacus may
engage non-affiliated service providers in connection with providing advisory services, and such providers may have
access to client NPPI, as necessary, to perform their functions. These service providers represent to Abacus that they
maintain safeguards designed to protect client information from unauthorized access or use and that they will
provide notice to Abacus in the event of a cybersecurity incident involving client information. While Abacus maintains
policies and procedures designed to protect client information, such measures cannot eliminate all risk. Upon
becoming aware of a data breach involving a client’s NPPI, Abacus will notify clients of such breach as may be
required by applicable state and federal laws.
artificial intelligence | Abacus may use certain Artificial Intelligence (“AI”) tools in connection with its investment
advisory services. Abacus has adopted an AI Policy that governs the appropriate use of AI tools to ensure that
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Abacus and its employees abide by their fiduciary duty and comply with all applicable regulations. AI tools are not
used by Abacus as a substitute for professional judgment by Abacus or its employees, and all AI generated output is
reviewed by Abacus for accuracy. All investment decisions and recommendations are made and approved by Abacus.
The use of AI tools does not guarantee the accuracy of analyses or the success of any investment strategy. Clients
should not assume that reliance on AI tools results in better performance or reduces risk. AI tools involve limitations
and risks that Abacus monitors and manages. These risks include, but are not limited to, data security concerns,
potential inaccuracies, and possible algorithmic biases. To mitigate these risks, Abacus has implemented controls
such as pre-approval requirements for AI tools, restrictions on providing nonpublic personal information to public AI
systems, vendor due diligence, review of AI-generated materials, and employee training on appropriate AI usage.
socially responsible (ESG) investing limitations | Socially Responsible Investing involves the incorporation of
Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG
investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e.,
considers how a company safeguards the environment); Social (i.e., the manner in which a company manages
relationships with its employees, customers, and the communities in which it operates); and Governance (i.e.,
company management considerations). The number of companies that meet an acceptable ESG mandate can be
limited when compared to those that do not, and could underperform broad market indices. Investors must accept
these limitations, including potential for underperformance. As with any type of investment (including any
investment and/or investment strategies recommended and/or undertaken by Abacus), there can be no assurance
that investment in ESG securities or funds will be profitable, or prove successful. Abacus does not maintain or
advocate an ESG investment strategy, but will seek to employ ESG if directed by a client to do so. If implemented,
Abacus shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or
separate account manager to determine that the fund’s or portfolio’s underlying company securities meet a socially
responsible mandate.
ByAllAccounts | Abacus, in conjunction with the services provided by ByAllAccounts, Inc., may also provide periodic
comprehensive reporting services which can incorporate all of the client’s investment assets, including those
investment assets that are not part of the assets managed by Abacus (the “Excluded Assets”). The client and/or their
other advisors that maintain trading authority, and not Abacus, shall be exclusively responsible for the investment
performance of the Excluded Assets. Unless otherwise specifically agreed to, in writing, Abacus’ service relative to
the Excluded Assets is limited to reporting only. The sole exception to the above shall be if Abacus is specifically
engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away at the custodian
directed by the client’s employer. As such, except with respect to the client’s 401(k) account (if applicable), Abacus
does not maintain any trading authority for the Excluded Assets. Rather, the client and/or the client’s designated
other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. If
Abacus is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to
accept the recommendation, and Abacus shall not be responsible for any implementation error (timing, trading, etc.)
relative to the Excluded Assets. In the event the client desires that Abacus provide investment management services
for the Excluded Assets, the client may engage Abacus to do so pursuant to the terms and conditions of the
Investment Advisory Agreement between Abacus and the client.
cross transactions | In limited circumstances, when determined to be in the best interest of its clients, Abacus may
engage in a cross-transaction pursuant to which Abacus may effect transactions between two of its managed client
accounts (i.e., arranging for the clients’ securities trades by “crossing” these trades when Abacus believes that such
transactions [generally, thinly traded bonds] are beneficial to its clients). For all such transactions, neither Abacus
nor any affiliate will be acting as a broker. Abacus will not receive any commission or transaction-based
compensation, although Abacus has an interest in the price at which the cross trades are conducted since Abacus'
asset-based fees will be negatively impacted by lower bond values. This may present a conflict of interest. These
transactions will be generally effected through Schwab, the account custodian, or a prime broker. The client may
revoke Abacus’ cross-transaction authority at any time upon written notice to Abacus.
custodian charges – additional fees | Broker-dealers such as Schwab charge brokerage commissions,
transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction
fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types
of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees)
shall differ depending upon the broker-dealer/custodian. While certain custodians, including Schwab, generally (with
the potential exception for large orders) do not currently charge fees on individual equity transactions (including
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ETFs), others do. There can be no assurance that Schwab will not change their transaction fee pricing in the future.
Schwab may also assess fees to clients who elect to receive trade confirmations and account statements by regular
mail rather than electronically.
investment risk | Different types of investments involve varying degrees of risk, and it should not be assumed that
future performance of any specific investment or investment strategy (including the investments and/or investment
strategies recommended or undertaken by Abacus) will be profitable or equal any specific performance level(s).
client obligations | In performing our services, Abacus shall not be required to verify any information received from
the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client
is advised that it remains their responsibility to promptly notify us if there is ever any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating, or revising our previous
recommendations or services.
disclosure brochure | A copy of Abacus’ written Brochure as set forth on Part 2A of Form ADV and Form CRS
(Client Relationship Summary) shall be provided to each client prior to, or contemporaneously with, the execution of
an agreement between the client and Abacus.
amount of managed assets | As of December 31, 2025, we were actively managing $2,074,247.209 of clients'
assets on a discretionary basis and $81,559,540 on a non-discretionary basis for a total of $2,155,806.749 in assets
under management.
item 5 fees and compensation
financial planning fees and annual recurring fees
Abacus calculates a financial planning fee or an annual recurring fee based on the nature of the services and the
complexity of each client’s circumstances.
The annual recurring financial planning fee generally ranges from $8,000 to $200,000.
portfolio management services fees
The annualized fee for investment advisory services is charged as a percentage of assets under management. The
specific rate of the fee depends upon the size and complexity of each client. Abacus determines the fee annually.
The rate of the fee will generally fall under the following ranges:
Investment Advisory and Financial Planning
| assets under management
| first $2,000,000
| $2,000,000 but less than $10,000,000
| more than $10,000,000
annual fee
0.60 to 1.00% per year
0.50% per year
0.25% per year
Investment Only
| assets under management
annual fee
1.00% per year
| first $2,000,000
| $2,000,000 to $10,000,000 0.50% per year
0.25% per year
| more than $10,000,000
ERISA-Qualified Plan Only
annual fee
0.60 per year
| assets under management
| first $2,000,000
| $2,000,000 but less than $10,000,000 0.50% per year
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| $10,000,000 but less than $20,000,000 0.30% per year
0.20% per year
|more than $20,000,000
If a client chooses to custody their investments other than at Schwab, they are subject to an additional 0.10%
fee per year. The minimum annual investment advisory and financial planning fee is $18,000, subject to the
caveats in the grandfathering of minimum account requirements noted below.
Abacus’ investment advisory fee is negotiable at Abacus’ discretion, depending upon objective and subjective
factors. As a result of these factors, similarly situated clients could pay different fees, the services to be provided
by Abacus to any particular client could be available from other advisers at lower fees, and certain clients may
have fees different than those specifically set forth above.
general information
Termination of the Advisory Relationship | Either party may cancel a client agreement at any time, for any
reason, upon receipt of 30 days written notice. Upon termination of any account, any prepaid, unearned fees will
be promptly refunded to the client. The amount to be refunded will be the fee actually paid less the portion of
that fee earned to the date of termination.
mutual fund fees | All fees paid to Abacus for investment advisory services are separate and distinct from the
fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are
described in each fund's prospectus and will generally include a management fee, other fund expenses, and a
possible distribution fee. A client could invest in a mutual fund directly, without our services. In that case, the
client would not receive the services provided by our firm which are designed, among other things, to assist the
client in determining which mutual fund or funds are most appropriate to each client's financial condition and
objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully
understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being
provided. Abacus will provide this analysis to each prospective client.
In addition, some clients may invest in fund-of-fund products that carry an additional layer of fees to the advisor
who manages the allocation to each fund in the product. Therefore, these clients effectively pay three layers of
fees in the context of fund-of-fund products.
additional fees and expenses | In addition to our advisory fees, clients are also responsible for the fees and
expenses charged by custodians and imposed by broker dealers, including, but not limited to, any transaction
charges imposed by a broker-dealer with which an independent investment manager effects transactions for the
client's account(s).
Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for effecting
certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups
and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees,
commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the
broker-dealer/custodian. While certain custodians, including Schwab, generally (with the potential exception for
large orders) do not currently charge fees on individual equity transactions (including ETFs), others do. There
can be no assurance that Schwab will not change their transaction fee pricing in the future. Schwab may also
assess fees to clients who elect to receive trade confirmations and account statements by regular mail rather
than electronically.
Please refer to the "Brokerage Practices" section (Item 12) of this brochure for additional information.
Clients who invest in affiliated private fund limited partnerships are not charged any additional advisory fees.
The limited partnerships do not pay, nor does Abacus receive, any fees for the services Abacus provides the
limited partnership as general partner. (The limited partnerships do reimburse Abacus for direct expenses paid
initially by Abacus on behalf of the partnerships.)
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grandfathering of minimum account requirements | Pre-existing advisory clients are subject to Abacus's
minimum account requirements and advisory fees in effect at the time the client entered into the advisory
relationship. Therefore, our firm's minimum account requirements will differ among clients.
advisory fees in general | Clients should note that similar advisory services may be available from other
registered investment advisers for similar or lower fees.
limited prepayment of fees | Under no circumstances do we require or solicit payment of fees more than four
months in advance of services rendered.
Clients are typically billed three times per year in advance.
item 6 performance-based fees and side-by-side management
Abacus does not charge performance-based fees. Abacus does not receive any fees from any parties except our
clients.
item 7 types of clients
Abacus provides advisory services to the following types of clients:
| high-net-worth individuals
| pension and profit-sharing plans (other than plan participants)
| charitable organizations
item 8 methods of analysis, investment strategies and risk of loss
methods of analysis
Abacus calculates the financial planning fee based on the nature of the services and the complexity of each
client’s circumstances. All fees are agreed upon prior to entering into a written agreement.
asset allocation | Abacus focuses its time and talents on thinking through the optimal allocation of a client’s
investment portfolio among the vast opportunity set of asset classes including but not limited to US equities,
international equities, emerging market stocks, real estate, commodities, bonds or cash. Abacus includes asset
classes in a client’s portfolio that it believes will improve the client’s probability of achieving his or her goals at
the appropriate risk level for that client. Abacus evaluates a wide variety of data from macro economic trends to
current valuations of an asset class to set portfolio policy and adjust portfolio policy over time.
manager selection | Abacus employs a number of strategies in selecting an execution strategy for investing in
a specific investment class. In many instances, Abacus employs a passive strategy believing that a client is best
served by a low-cost, low-income tax impact investment strategy. When Abacus believes a manager can bring
either additional return or added risk control to the return of an asset class, it will assess the managers which
meet a set of quantitative criteria, including risk-adjusted returns in comparison with peer managers, low-cost
structure, sensitivity to income tax impact when executing the strategy, and longevity of manager executing
strategy, among other factors. Abacus also evaluates a manager on a number of qualitative issues such as
adherence to strategy during out of favor periods, firm culture, team longevity, ability to communicate a
strategy effectively, and a history of consumer-friendly decisions such as closing a fund to new investors when
appropriate.
risks for all forms of analysis | Abacus is attune to the multiple risks that a client’s portfolio may face
including a) volatility risk, b) interest rate risk, c) risk associated with deflation or inflation, d) liquidity risk,
e) the risk of increasing withdrawal demands during protracted negative returns in the markets, f) changing risk
capacity of a client due to personal life changes, g) changing risk perception of a client due to emotional
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response to market changes, negative or positive or h) regulatory risk. Abacus thinks carefully about the
proper asset allocation to mitigate each of these risks dependent on the unique goals and needs of each client.
Our portfolio analysis methods rely on the assumption that the mutual funds, ETFs, and debt instruments that
we purchase and sell, the rating agencies that review these securities, and other publicly-available sources of
information about these securities, are providing accurate and unbiased data. While we are alert to indications
that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or
misleading information.
investment strategies
Abacus embraces the following asset management tenets in managing a client’s portfolio:
| Allocate funds across asset classes for optimal risk-adjusted returns 90% of Abacus investment
recommendations are long-term, i.e., based on a three to five-year economic outlook.10% of Abacus
investment recommendations are short-term or tactical in nature, i.e., based on unusual short-term
valuations or opportunities in the markets with an expected holding period of less than 18 months.
| Diversify extensively across multiple asset classes, managers, and time periods for optimal risk-adjusted
returns.
| Employ portfolio management tools to protect portfolios against downside volatility.
| Insulate the portfolio against a variety of future economic scenarios, especially unexpected inflation or
deflation, through hedging techniques and other strategies.
| Execute and follow written investment policy guidelines.
| Seek opportunities to globalize the portfolio holdings across all asset classes.
| Seek broad exposure to non-traditional investments such as real estate, venture capital, or commodities.
| Employ low-cost investment products as a bottom-line strategy for increasing returns.
| Rebalance the portfolio methodically to the investment policy guideline asset allocation targets.
| Manage clients’ decision-making behaviors for successful portfolio outcomes.
borrowing against assets | A client who has a need to borrow money could determine to do so by using:
margin | The account custodian or broker-dealer lends money to the client. The custodian charges the client
interest for the right to borrow money, and uses the assets in the client’s brokerage account as collateral;
and,
pledged assets loan | In consideration for a lender (i.e., a bank, etc.) to make a loan to the client, the
client pledges its investment assets held at the account custodian as collateral;
These above-described collateralized loans are generally utilized because they typically provide more favorable
interest rates than standard commercial loans. These types of collateralized loans can assist with a pending
home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing
account positions and incurring capital gains taxes. However, such loans are not without potential material risk
to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the client’s
investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Abacus
does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase
a new residence). Abacus does not recommend such borrowing for investment purposes (i.e., to invest borrowed
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funds in the market). Regardless, if the client was to determine to utilize margin or a pledged assets loan, the
following economic benefits would inure to Abacus:
| by taking the loan rather than liquidating assets in the client’s account, Abacus continues to earn a fee on
such Account assets
| if the client invests any portion of the loan proceeds in an account to be managed by Abacus, Abacus will
receive an advisory fee on the invested amount
| if Abacus’s advisory fee is based upon the higher margined account value, Abacus will earn a
correspondingly higher advisory fee. This could provide Abacus with a disincentive to encourage the client
to discontinue the use of margin.
item 9 disciplinary information
Abacus management personnel have no disciplinary events to disclose.
On September 9, 2024, the SEC identified failures by the Firm to comply with Advisers Act Rule 206(4)-1 (the
"Marketing Rule"). Specifically, after the compliance deadline for the Marketing Rule on November 4, 2022, and
continuing through June 27, 2024, the SEC alleged that the Firm disseminated an advertisement containing an
untrue statement of material fact regarding third-party ratings the advertisement stated the Firm had received.
Further, the Firm disseminated an advertisement containing third-party ratings that did not clearly and
prominently disclose the date on which the rating was given and the period of time upon which the rating was
based. As a result, the Firm violated section 206(4) of the Advisers Act and Rules 206(4)-1(a) and 206(4)-1(c)
thereunder.
item 10 other financial industry activities and affiliations
Abacus has a minority ownership interest (less than 1%) in a savings and loan holding company, National
Advisors Holdings, Inc. (NAH) that has formed a federally chartered trust company, National Advisors Trust
Company (NATC). NAH and NATC are regulated by the Office of the Comptroller of the Currency (OCC), a bureau
of the U.S. Treasury Department. The trust company intends to provide a low-cost alternative to traditional trust
service providers. Where appropriate, Abacus may refer clients to NATC for custody and/or trust services.
Abacus does not receive any direct compensation for making these recommendations to clients. However,
Abacus will participate in profits and losses of NAH as a result of its minority ownership stake in the company.
Therefore, Abacus has a conflict of interest in referring clients to NAH for custody and trust services. Clients are
not obligated to utilize these services.
Our firm and our related persons are not engaged in any other financial industry activities and have no other
industry affiliations.
item 11 code of ethics, participation or interest in client transactions and personal trading
The Code of Ethics adopted by Abacus demands high ethical standards of business conduct by our employees
and careful compliance with applicable federal securities laws.
Abacus believes we have a duty to our clients to be loyal, fair, and act in good faith. Abacus accepts the
obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that
form its foundation.
Our Code of Ethics includes policies and procedures for the review of monthly securities transactions reports as
well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. It
requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an
initial public offering. The code also incorporates oversight, enforcement, and recordkeeping provisions.
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Abacus's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information.
While we do not believe that we have any particular access to non-public information, all employees are
reminded that such information may not be used in a personal or professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy
by email sent to marc@abacusplanninggroup.com, or by calling 803-933-0054.
Abacus is the managing partner of Terrum Real Estate Partnership I, LP, Tyche Opportunity Fund I, LP,
Periculum, LP, Series A, Periculum, LP, Series B, and Periculum, LP, Series C. As General Partner of these limited
partnerships, Abacus has primary responsibility for investment management and administrative matters, such as
accounting, tax and periodic reporting pertaining to the limited partnership. Abacus and our members, officers
and employees will devote to the limited partnerships as much time as we deem necessary and appropriate to
manage the limited partnership's business. Abacus and our affiliates are not restricted from forming additional
investment funds, entering into other investment advisory relationships or engaging in other business activities,
even though such activities may be in competition with the limited partnerships and/or may involve substantial
time and resources of our firm. Potentially, such activities could be viewed as creating a conflict of interest in the
time and effort of our management personnel and employees will not be devoted exclusively to the business of
the limited partnerships, but could be allocated between the business of the limited partnerships and our other
business activities.
The limited partnerships are not required to register as an investment company under the Investment Company
Act of 1940 in reliance upon an exemption available to entities whose securities are not publicly offered. Abacus
manages the limited partnerships on a discretionary basis in accordance with the terms and conditions of the
limited partnerships’ offering and organizational documents.
Clients who invest in these limited partnerships are not charged any additional advisory fees. The limited
partnerships do not pay, nor does Abacus receive, any fees for the services Abacus provides the limited
partnership as general partner. (The limited partnerships do reimburse Abacus for direct expenses paid initially
by Abacus on behalf of the partnerships.)
Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our
employees will not interfere with 1| making decisions in the best interest of advisory clients and
2| implementing such decisions while, at the same time, allowing employees to invest for their own accounts.
Our firm and/or individuals associated with our firm may buy or sell for their personal accounts securities
identical to or different from those recommended to our clients. In addition, any related person(s) may have an
interest or position in a certain security which may also be recommended to a client.
It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a
transaction(s) being implemented for an advisory account, thereby preventing such employee(s) from benefiting
from transactions placed on behalf of advisory accounts.
As these situations represent conflicts of interest to our clients, we have established the following policies and
procedures for implementing our firm’s Code of Ethics, to ensure our firm complies with its regulatory
obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest:
| No principal or employee of our firm may put his or her own interest above the interest of an advisory
client.
| No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their
decision is a result of information received as a result of his or her employment unless the information is
also available to the investing public.
| It is the expressed policy of our firm that no person employed by us may purchase or sell any security
prior to a transaction(s) being implemented for an advisory account. This prevents such employees from
benefiting from transactions placed on behalf of advisory accounts.
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| Our firm requires prior approval for any IPO or private placement investments by related persons of the
firm.
| Abacus has established procedures for the maintenance of all required books and records.
| All of our principals and employees must act in accordance with all applicable Federal and State
regulations governing registered investment advisory practices.
| Abacus requires delivery and acknowledgement of the Code of Ethics by each supervised person of our
firm.
| Abacus has established policies requiring the reporting of Code of Ethics violations to our senior
management.
| Any individual who violates any of the above restrictions may be subject to termination.
Abacus has voluntarily subscribed to the “Real Fiduciary™ Practices” published by the Institute for the Fiduciary
Standard. Real Fiduciary™ Practices offer a simple code of conduct and outline a commitment to clients of
subscribing financial advisors. They seek to clearly articulate what a client can expect to receive from a
subscribing financial advisor. These Real Fiduciary™ Practices do not replace our regulatory compliance
obligations or duties to clients under relevant laws, rules, or regulations. The Institute for the Fiduciary
Standard’s role is limited to publishing the practices as well as maintaining a corresponding register of
subscribing financial advisors. You can verify our affirmation of Real Fiduciary™ Practices on our website or at
the Institute for the Fiduciary Standard website at www.thefiduciaryinstitute.org. The practices can be found at
https://thefiduciaryinstitute.org/wp-content/uploads/2019/03/Real-Fiduciary-Practices-2019-02-22.pdf
item 12 brokerage practices
Abacus recommends that all clients establish brokerage accounts with either the Schwab Institutional division of
Charles Schwab & Company, Inc. (Schwab), a FINRA registered broker-dealer, and SIPC member, to maintain
custody of the client’s assets and to effect trades for their accounts. Although we recommend this custodian for
operational efficiencies, it is the client's decision to custody assets with Schwab or another custodian. If a client
chooses to custody their assets with another broker-dealer, the client is subject to additional fees from Abacus.
Abacus is independently owned and operated and not affiliated with Schwab.
Schwab provides Abacus with access to their institutional trading and custody services, which are typically not
available to Schwab retail investors. These services generally are available to independent investment advisers
on an unsolicited basis, at no charge to them. These services are not contingent upon our firm committing to
Schwab any specific amount of business (such as assets in custody or trading commissions.)
Some of the services provided by Schwab are beneficial to both the client and Abacus in managing and
administering a client’s account. Examples of these services include:
| trade executions
| trade confirmations and account statements
| custody
| research, pricing and other market data
| access to certain mutual funds and other investments normally only available to institutional investors
| facilitation of the payment of Abacus fees from a client’s account
For our client accounts maintained in its custody, Schwab generally does not charge separately for custody
services but is compensated by account holders through commissions and other transaction-related fees for
securities trades that are executed through Schwab.
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Schwab also makes available to our firm other products and services intended to assist Abacus in managing and
developing our business enterprise. These products and services may not directly benefit any specific client
accounts, but generally may be used to service all or a substantial number of our client accounts, including
accounts not maintained at Schwab. These services may include:
| compliance, legal and business consulting
| publications and conferences on practice management and business succession
| access to employee benefits providers, human capital consultants and insurance providers
| educational events
In evaluating whether to recommend clients custody their assets at Schwab or any other custodian, we may
take into account the availability of some of the previously listed products and services and other arrangements
as part of the total mix of factors we consider. This could create a conflict of interest.
Abacus believes the receipt of additional services does not diminish our duty to act in the best interests of our
clients, including seeking best execution of trades for client accounts.
In addition to Schwab being a recommended custodian for traditional investments, Abacus recommends National
Advisors Trust Company of Overland Park, Kansas, to house non-traditional investments, such as limited
partnerships. National Advisors Trust Company is typically compensated for their services based upon a charge
to the client calculated as a percentage of assets held in custody.
Abacus does not generally accept directed brokerage arrangements (when a client requires that account
transactions be affected through a specific broker-dealer). In such client directed arrangements, the client will
negotiate terms and arrangements for their account with that broker-dealer, and Abacus will not seek better
execution services or prices from other broker-dealers or be able to "batch" the client's transactions for
execution through other broker-dealers with orders for other accounts managed by Abacus. As a result, client
may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices,
on transactions for the account than would otherwise be the case. Also, as discussed above in item 5, if a client
chooses to custody their investments other than at Schwab, they will subject to an additional 0.10% fee per
year charged by Abacus.
In the event that the client directs Abacus to effect securities transactions for the client's accounts through a
specific broker-dealer, the client correspondingly acknowledges that such direction may cause the accounts to
incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined
to effect account transactions through alternative clearing arrangements that may be available through Abacus.
Higher transaction costs adversely impact account performance. Transactions for directed accounts will generally
be executed following the execution of portfolio transactions for non-directed accounts.
item 13 review of accounts
portfolio management services
reviews | While the underlying securities within Individual Portfolio Management Services accounts are
continually monitored and rebalanced, accounts are reviewed three times per year. Accounts are reviewed in the
context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by
material changes in variables such as the client's individual circumstances, or the market, political or economic
environment.
These accounts are reviewed by:
| Cheryl R. Holland, Principal
| Charles B. Flowers, Principal
| William R. Jeter, Portfolio Manager
| Stephen J. (Scotty) Scott, Portfolio Manager
| Bailey O. Davis, Assistant Portfolio Manager
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reports | In addition to the monthly statements and confirmations of transactions that clients receive from their
broker-dealer, Abacus will normally provide portfolio performance reports two times per year summarizing
account portfolio performance, asset allocation and portfolio balances.
financial planning services
reviews | While reviews may occur at different stages depending on the nature and particulars of each client,
when engaged on an ongoing basis, we typically review in detail and update each client’s financial plan twice per
year.
reports | Abacus will typically create a comprehensive financial plan for each client in their first year with
Abacus. The content of each client’s financial plan will vary according to the individual client’s needs.
Subsequent updates to the plan will be reported to the client in various formats and methods, as dictated by
each client’s individual circumstances.
item 14 client referrals and other compensation
Abacus does not engage promoters or pay related or non-related persons for referring potential clients to our
firm.
Abacus does not accept or allow our employees or related persons to accept any form of compensation, including
cash, sales awards, or other prizes, from a non-client in connection with the advisory services we provide to our
clients. One of Abacus’ employees may receive compensation that is specifically related to obtaining clients for
the firm. Certain Abacus employees act as court-appointed trustees for trusts.
item 15 custody
Abacus previously disclosed in the "Fees and Compensation" section (item 5) of this brochure that our firm
directly debits advisory fees from client accounts.
As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from the
client's account. On at least a quarterly basis, but typically monthly, the custodian is required to send the client
a statement showing all transactions within the account during the reporting period.
Because the custodian does not calculate the amount of the fee to be deducted, Abacus strongly recommends
clients carefully review their custodial statements to verify the accuracy of the fee calculation and any other
transactions. Clients should contact us directly if they believe there may be an error in their statement.
In addition to the periodic statements that clients receive directly from their custodians, Abacus also sends
portfolio statements directly to our clients three times per year. Abacus urges our clients to carefully compare
the information provided on these statements to ensure portfolio values are correct and current.
Abacus discloses at item 9 of ADV Part 1 that it has custody as a result of its relationship to the affiliated funds
as well as other relationships.
item 16 investment discretion
All Abacus clients are required to provide discretionary asset management authorization allowing us to place
trades in a client's account without contacting the client prior to each trade to obtain permission. Abacus’s
discretionary authority includes the ability, without contacting the client, to determine the security to buy or sell;
and determine the amount of the security to buy or sell. This discretion is limited to the guidelines set forth in
each client’s investment policy guidelines which are signed by the client and the client’s respective portfolio
manager.
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item 17 voting client securities
As a matter of firm policy, Abacus generally does not vote proxies on behalf of clients. Therefore, although our
firm may provide investment advisory services relative to client investment assets, unless otherwise agreed,
clients maintain exclusive responsibility for: 1[directing the manner in which proxies solicited by issuers of
securities beneficially owned by the client shall be voted, and 2[making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment
assets. Clients are responsible for instructing each custodian of the assets, to forward to the client copies of all
proxies and shareholder communications relating to the client’s investment assets. Abacus welcomes client
questions in making these decisions.
In extremely limited situations, Abacus may accept proxy voting responsibilities on behalf of a client. In these
limited situations, Abacus shall maintain records pertaining to proxy voting as required pursuant to Rule 204-2
(c)(2) under the Advisers Act. Copies of Rules 206(4)-6 and 204-2(c)(2) are available upon written request. In
addition, information pertaining to how any specific proxy issue was voted on is also available upon written
request. Requests should be made by contacting Abacus’s Chief Compliance Officer.
item 18 financial information
Under no circumstances does Abacus require or solicit payment of fees more than four months in advance of
services rendered. Therefore, Abacus is not required to include a financial statement with this brochure.
Abacus has not been the subject of a bankruptcy petition at any time. Abacus has no additional financial
condition to report that may cause a reasonable likelihood to impair our ability to meet our contractual
obligations.
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