Overview
- Headquarters
- Wichita, KS
- Total Firm Assets
- $10 million
- Average High-Net-Worth Client Portfolio Size
- $2.4 million
Fee Structure
Primary Fee Schedule (AC ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.25% |
| $500,001 | $1,000,000 | 1.10% |
| $1,000,001 | $4,000,000 | 1.00% |
| $4,000,001 | and above | 0.90% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,750 | 1.18% |
| $5 million | $50,750 | 1.02% |
| $10 million | $95,750 | 0.96% |
| $50 million | $455,750 | 0.91% |
| $100 million | $905,750 | 0.91% |
Clients
- High-Net-Worth Share of Firm Assets
- 74.14%
- Number of High-Net-Worth Clients
- 3
- Total Client Accounts
- 7
- Discretionary Accounts
- 7
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 327013
Primary Brochure: AC ADV PART 2A (2026-08-28)
View Document Text
Part 2A of Form ADV: Firm Brochure
Form ADV, Part 2A, Item 1
Cover Page
Access Capital, LLC
1601 E. Douglas Avenue
Wichita, Kansas 67211
Tel: (316) 633-8013
August 28, 2026
FORM ADV PART 2
FIRM BROCHURE
This brochure provides information about the qualifications and business practices of Access
Capital, LLC. If you have any questions about the contents of this brochure, please contact us at
(316) 633-8013. 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.
Additional information about Access Capital, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Access Capital, LLC is 327013.
Access Capital, LLC is a Registered Investment Adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain
level of skill or training.
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Form ADV, Part 2A, Item 2
Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure. Each year, we will ensure that
you receive a summary of any material changes to this and subsequent brochures by April 30th.
We will further provide you with our most recent brochure at any time at your request, without
charge. You may request a brochure by contacting us at (316) 633-8013.
Material Changes since the Last Update
Access Capital, LLC was established as a new Registered Investment Advisor in June 2023 with
the Securities and Exchange Commission (“SEC”), under the rules and regulations of the US
Investment Advisers Act of 1940, as amended (the "Advisers Act") and moved to registration
with the Kansas Securities Commissioner and subject to the state’s rules and regulations.
The firm has had the following material changes since the last filing March 12, 2026:
• None.
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Form ADV, Part 2A, Item 3
Table of Contents
Advisory Business…………………………………………………………… 4
Fees and Compensation…………………………………………………….. 5
Performance-Based Fees and Side-By-Side Management……………. 7
Types of Clients………………………………………………………………. 7
Methods of Analysis, Investment Strategies, and Risk of Loss……… 8
Disciplinary Information…………………………………………………….. 10
Other Financial Industry Activities and Affiliations……………………. 10
Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading………………………………………………………………
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Brokerage Practices………………………………………………………….. 11
Review of Accounts………………………………………………………….. 13
Client Referrals and Other Compensation……………………………….. 13
Custody………………………………………………………………………… 13
Investment Discretion……………………………………………………….. 14
Voting Client Securities……………………………………………………… 14
Financial Information………………………………………………………… 14
Requirements for State-Registered Advisers…………………………… 14
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Form ADV Part 2A, Item 4
Advisory Business
Access Capital, LLC (hereinafter called “AC”) is a Registered Investment Adviser based in
Wichita, Kansas, and incorporated under the laws of the State of Kansas. AC is wholly owned
by Sean Spencer. AC is registered with the State of Kansas and subject to its rules and
regulations. Founded in June 2023, AC provides investment advisory services, which may
include, but are not limited to, the review of client investment objectives and goals,
recommending asset allocation strategies of managed assets among investment products such as
cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment strategies.
Our investment advice is tailored to meet our clients’ needs and investment objectives. Clients
may impose restrictions on investing in certain securities or types of securities (such as a product
type, specific companies, specific sectors, etc.) by providing a signed and dated written
notification, of which an e-mail is also an acceptable form of notification. AC also provides
financial planning consulting services including, but not limited to, risk assessment/management,
investment planning, estate planning, financial organization, or financial decision
making/negotiation.
AC provides investment advisory and other financial services through its Investment Advisory
Representatives ("IAR") to accounts opened with AC. Managed Accounts are available to
individuals and high net worth individuals.
AC provides discretionary and non-discretionary investment advisory services to some of its
clients through various managed account programs. AC will assist clients in determining the
suitability of the Managed Account Programs for the client. The IAR is compensated through a
comprehensive single fee and the account may be assessed other charges associated with
conducting a brokerage business. AC and its IAR, as appropriate, will be responsible for the
following:
• Performing due diligence
• Recommending strategic asset and style allocations
• Providing research on investment product options, as needed
• Providing client risk profile questionnaire
• Obtaining investment advisory contract from client with required financial, risk tolerance,
suitability and investment vehicle selection information for each new account
• Performing client suitability check on account documentation, review the investment
objectives and evaluate the investment vehicle selections
• Providing Firm Brochure (this document)
Held Away Accounts
We use a third-party platform (Pontera, formerly FeeX) to facilitate management of held away
assets such as defined contribution plan participant accounts, with discretion. The platform
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allows us to avoid being considered to have custody of Client funds since we do not have direct
access to Client log-in credentials to affect trades. We are not affiliated with the platform in any
way and receive no compensation from them for using their platform. A link will be provided to
the Client allowing them to connect an account(s) to the platform. Once Client account(s) is
connected to the platform, Adviser will review the current account allocations. When deemed
necessary, Adviser will rebalance the account considering client investment goals and risk
tolerance, and any change in allocations will consider current economic and market trends. The
goal is to improve account performance over time and manage internal fees that harm account
performance. Client account(s) will be reviewed at least quarterly and allocation changes will be
made as deemed necessary.
As of August 26, 2026, the firm has assets under management of Discretionary: $9,889,326
AUM and no Non-Discretionary AUM.
Form ADV, Part 2A, Item 5
Fees and Compensation
The following types of fees will be assessed:
Asset Management – Fees are charged monthly in advance and are based primarily on asset size
and the level of complexity of the services provided. In individual cases, AC has the sole
discretion to negotiate fees that are lower than the standard fee shown or to waive fees. Fees are
not based on the share of capital gains or capital appreciation of the funds or any portion of the
funds. Comparable services for lower fees may be available from other sources. Fees for the
initial month will be prorated based upon the number of calendar days in the calendar month that
the advisory agreement is in effect. Fees are based on the average monthly value of the previous
month. Annual fees range from .90% - 1.25%, depending on the amount of assets under
management (“AUM”) – See chart below. Consulting services are included in these fees for
asset management services with the exception of unique circumstances that may require a
separate agreement for financial planning services (description and fees are discussed below). If
the situation warrants separate financial planning fees, it will be discussed upfront and a separate
agreement will be negotiated.
Fee Schedule for Asset Management:
Maximum Annual Advisory Fee
Total Account Value
Under $500,000 1.25%
$500,000 – $1,000,000 1.10%
$1,000,001 – $4,000,000 1.00%
0.90%
Over $4,000,000
As authorized in the client agreement, the account custodian withdraws Access Capital, LLC’s
advisory fees directly from the clients’ accounts according to the custodian’s policies, practices,
and procedures. The custodial statement includes the amount of any fees paid to AC for
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advisory services. You should carefully review the statement from your custodian/broker-
dealer’s statement and verify the calculation of fees. Your custodian/broker-dealer does not
verify the accuracy of fee calculations.
Fees are charged in advance on a monthly basis, meaning that advisory fees for a month are
charged on the first day of the month. Clients may terminate investment advisory services
obtained from AC, without penalty, upon written notice within five (5) business days after
entering into the advisory agreement with AC. The client is responsible for any fees and charges
incurred by the client from third parties as a result of maintaining the account such as transaction
fees for any securities transactions executed and account maintenance or custodial fees.
Thereafter, the client may terminate advisory services upon written notice delivered to and
received by AC. Clients who terminate investment advisory services during a month are charged
a prorated advisory fee based on the date of AC’s receipt of client’s written notice to terminate.
Any earned but unpaid fees are immediately due and payable, and any prepaid and unearned fees
will be immediately refunded.
Financial Planning – Financial planning services are charged in advance through a fixed fee
arrangement or in arrears through an hourly arrangement as agreed upon between the client and
Access Capital, LLC. There will never be an instance where $500 or more in fees is charged six
or more months in advance. Hourly fees are generally charged when the scope of services
cannot be determined or if the services are limited to one meeting. Fixed fees are generally
quoted to the client for longer term consulting projects. Fees are negotiable and vary depending
upon the complexity of the client situation and services to be provided. Hourly fees range from
$300 - $400 per hour, depending on what is negotiated between AC and the client. Similar
financial planning services may be available elsewhere for a lower cost to the client. Fixed fees
for longer-term consulting projects range from $1,000 to $5,000 per project. An estimate for
total hours and charges is determined at the start of the advisory relationship.
Typically, clients will be invoiced monthly for all time spent by AC as agreed upon by client or
upon completion of the services if less than a month. Clients who wish to terminate the planning
process prior to completion may do so with written notice. The client may obtain a refund of a
pre-paid fee if the advisory contract is terminated before the end of the billing period by
contacting Sean Spencer at (316) 633-8013. Upon receipt of written notification, any earned fee
will immediately become due and payable, and any prepaid and unearned fees will be
immediately refunded. A client may terminate an advisory agreement without being assessed
any fees or expenses within five (5) days of its signing.
Additional Fees and Expenses
In addition to advisory fees paid to AC as explained above, clients may pay custodial service,
account maintenance, transaction, and other fees associated with maintaining the account. These
fees vary by broker and/or custodian. Clients should ask AC for details on transaction fees or
other custodial fees specific to their account, as these fees are not included in the annual advisory
fee. AC does not share any portion of such fees. Additionally, for any mutual funds purchased,
the client may pay their proportionate share of the funds’ distribution, internal management,
investment advisory and administrative fees. Such fees are not shared with AC and are
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compensation to the fund manager. Clients are urged to read the mutual fund prospectus prior to
investing.
Mutual fund companies impose internal fees and expenses on clients. These fees are in addition
to the costs associated with the investment advisory services as described above. Complete
details of such internal expenses are specified and disclosed in each mutual fund company’s
prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such
securities.
Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that
would not exist if the purchase or sale were made directly with the mutual fund company.
Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund
management fees may be more or less than the mutual fund management fees charged if the
client held the mutual fund directly with the mutual fund company.
Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal
underwriter, or a distributor without purchasing the services of AC or paying the advisory fee on
such shares (but subject to any applicable sales charges). Certain mutual funds are offered to the
public without a sales charge. In the case of mutual funds offered with a sales charge, the
prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the
applicable advisory fee. However, clients would not receive AC’s assistance in developing an
investment strategy, selecting securities, monitoring performance of the account, and making
changes as necessary.
Please refer to Item 12 “Brokerage Practices” of this brochure for additional information.
Form ADV, Part 2A, Item 6
Performance-Based Fees and Side-By-Side Management
Access Capital, LLC does not charge performance-based fees or participate in side-by-side
management. Side-by-side management refers to the practice of managing accounts that are
charged performance-based fees while at the same time managing accounts that are not charged
performance-based fees. Performance-based fees are fees that are based on a share of capital
gains or appreciation of the assets of a client. Our fees are calculated as described in Fees and
Compensation section above, and are not charged on the basis of performance of your advisory
account.
Form ADV, Part 2A, Item 7
Types of Clients
AC offers investment advisory services to individuals and high net worth individuals. There is
no minimum account size to open and maintain an advisory account.
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Form ADV, Part 2A, Item 8
Methods of Analysis, Investment Strategies, and Risk of Loss
AC’s methods of analysis and investment strategies incorporate the client’s needs and investment
objectives, time horizon, and risk tolerance. AC is not bound to a specific investment strategy
for the management of investment portfolios, but rather consider the risk tolerance levels pre-
determined gathered at the account opening, as well as on an on-going basis. Examples of
methodologies that our investment strategies may incorporate include:
Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix
of asset classes and the efficient allocation of capital to those assets by matching rates of return
to a specified and quantifiable tolerance for risk.
Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount
of securities at regularly scheduled intervals, regardless of the price per share. This will
gradually, over time, decrease the average share price of the security. Dollar-cost averaging
lessens the risk of investing a large amount in a single investment at the wrong time.
Technical Analysis – involves studying past price patterns and trends in the financial markets to
predict the direction of both the overall market and specific stocks.
Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
Short-Term Purchases – securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities’
short term price fluctuations.
Our strategies and investments may have unique and significant tax implications. Regardless of
your account size or other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.
Investing in securities involves risk of loss that clients should be prepared to bear. Although we
manage your portfolio with strategies and in a manner consistent with your risk tolerances, there
can be no guarantee that our efforts will be successful. You should be prepared to bear the risk
of loss.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
future earnings. These risks include market risk, interest rate risk, issuer risk, and general
economic risk. Regardless of the methods of analysis or strategies suggested for your particular
investment goals, you should carefully consider these risks, as they all bear risks.
AC’s primary goal for investing is to help the client maintain purchasing power over the long
term. This may result in short term variability and loss of principal. Time horizon and risk
tolerance are key determinates of the proper asset allocation. AC’s approach focuses on taking
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appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or
eliminate risks that do not provide compensation over the long term (i.e. individual stock risk or
lack of portfolio risk).
Below are some more specific risks of investing:
Market Risk. The prices of securities in which clients invest may decline in response to certain
events taking place around the world, including those directly involving the companies whose
securities are owned by the client or an underlying fund; conditions affecting the general
economy; overall market changes; local, regional or global political, social or economic
instability; and currency, interest rate and commodity price fluctuations. Investors should have a
long-term perspective and be able to tolerate potentially sharp declines in market value.
Management Risk. AC’s investment approach may fail to produce the intended results. If our
perception of the performance of a specific asset class or underlying fund is not realized in the
expected time frame, the overall performance of client’s portfolio may suffer.
Equity Risk. Equity securities tend to be more volatile than other investment choices. The value
of an individual mutual fund or ETF can be more volatile than the market as a whole. This
volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are
subject to additional risks. Smaller companies may experience greater volatility, higher failure
rates, more limited markets, product lines, financial resources, and less management experience
than larger companies. Smaller companies may also have a lower trading volume, which may
disproportionately affect their market price, tending to make them fall more in response to
selling pressure than is the case with larger companies.
Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and
principal payments when due. Generally, the lower the credit rating of a security, the greater the
risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower
rating, the value of the debt security will decline because investors will demand a higher rate of
return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.
Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may
be affected by adverse political, legislative and tax changes, as well as by financial developments
that affect the municipal issuers. Because many municipal obligations are issued to finance
similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.),
conditions in the sector related to the project can affect the overall municipal market. Payment
of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue
generated by a specific project, the operator of the project, or government appropriation or aid.
There is a greater risk if investors can look only to the revenue generated by the project. In
addition, municipal bonds generally are traded in the “over-the-counter” market among dealers
and other large institutional investors. From time to time, liquidity in the municipal bond market
(the ability to buy and sell bonds readily) may be reduced in response to overall economic
conditions and credit tightening.
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Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the
client indirectly bears its proportionate share of any fees and expenses payable directly by those
funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In
addition, the client’s overall portfolio may be affected by losses of an underlying fund and the
level of risk arising from the investment practices of an underlying fund (such as the use of
derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a
market price that is above or below their net asset value; (ii) the ETF may employ an investment
strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the
listing exchange’s officials deem such action appropriate, the shares are de-listed from the
exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases
in stock prices) halts stock trading generally. AC has no control over the risks taken by the
underlying funds.
Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by the
Firm to service client accounts have artificial intelligence components. The use of artificial
intelligence and machine learning includes increased risk of data inaccuracies and security
vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks
related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our
clients, the Firm performs periodic due diligence of our service providers for assurance that the
service providers have appropriate controls in place to protect our clients’ information and to
limit data inaccuracies when artificial intelligence is used by the service provider.
Form ADV, Part 2A, Item 9
Disciplinary Information
Access Capital, LLC or its Principal Executive Officers have not had any reportable disclosable
events in the past ten years.
Form ADV, Part 2A, Item 10
Other Financial Industry Activities and Affiliations
Sean Spencer, owner and sole IAR of AC, is not currently registered with any broker dealer.
Neither AC nor its representatives are registered as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Advisor.
Sean Spencer is also a licensed insurance agent. From time to time, he will offer clients advice or
products from those activities. Clients should be aware that these services pay a commission and
involve a possible conflict of interest, as commissionable products can conflict with the fiduciary
duties of a registered investment adviser. AC always acts in the best interest of the client;
including the sale of commissionable products to advisory clients. Clients are in no way required
to implement the plan through any representative of AC in their capacity as an insurance agent.
Not more than 30% of Sean Spencer’s time is spent on this activity.
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Form ADV, Part 2A, Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
AC’s Code of Ethics includes guidelines for professional standards of conduct for our Associated
Persons. Our goal is to protect client interests at all times and to demonstrate our commitment to
fiduciary duties of honesty, good faith, and fair dealing. All of AC’s Associated Persons are
expected to strictly adhere to these guidelines. Persons associated with Access Capital, LLC are
also required to report any violations to the Code of Ethics. Additionally, the firm maintains and
enforces written policies reasonably designed to prevent the misuse or dissemination of material,
non-public information about our clients or client accounts by persons associated with our firm.
AC and its employees may buy or sell securities that are also held by clients. It is the expressed
policy of the advisor that no person employed by our firm purchase or sell any security prior to the
transaction being implemented for an advisory account; therefore, preventing such employees
from benefiting from transactions placed on behalf of the advisory clients.
The advisor may have an interest or position in a certain security, which may also be recommended
to the client. As these situations may present a conflict of interest, the advisor has established the
following restrictions in order to ensure its fiduciary responsibilities should this issue ever arise:
1. A director, officer or employee of the advisor shall not buy or sell a security for their
personal portfolio(s) where their decision is substantially derived, in whole or part, by
reason of his or her employment, unless the information is also available to the investing
public. No owner/employee of AC shall prefer their own interest to that of the client.
2. The advisor maintains a list of all securities held by the company and all directors, officers,
and employees. These holdings are reviewed on a quarterly basis by the principal of the
firm.
3. The advisor requires that all employees must act in accordance with all applicable Federal
and State regulations governing registered investment advisors.
4. The advisor may block personal trades with those of clients but will ensure that clients are
not at a disadvantage.
AC’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of
Ethics by contacting Sean Spencer at (316) 633-8013.
Form ADV, Part 2A, Item 12
Brokerage Practices
In order for AC to provide asset management services, we request you utilize the brokerage and
custodial services of Raymond James & Associates, Inc. (“RJA”), member New York Stock
Exchange/SIPC for which we have an existing relationship. AC is not an affiliated company
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with RJA. In considering which independent qualified custodian will be the best fit for AC’s
business model, we are evaluating the following factors, which is not an all-inclusive list:
➢ Financial strength
➢ Reputation
➢ Reporting capabilities
➢ Execution capabilities
➢ Pricing, and
➢ Types and quality of research
While you are free to choose any broker-dealer or other service provider, we recommend that
you establish an account with a brokerage firm with which we have an existing relationship.
Such relationships may include benefits provided to our firm, including, but not limited to
research, market information, and administrative services that help our firm manage your
account(s). We believe that recommended broker-dealers provide quality execution services for
our clients at competitive prices. Price is not the sole factor we consider in evaluating best
execution. We also consider the quality of the brokerage services provided by the recommended
broker-dealers, including the value of research provided, the firm’s reputation, execution
capabilities, commission rates, and responsiveness to our clients and our firm.
You may direct us in writing to use a particular broker-dealer to execute some or all of the
transactions for your account. If you do so, you are responsible for negotiating the terms and
arrangements for the account with that broker-dealer. We may not be able to negotiate
commissions, obtain volume discounts, or best execution. In addition, under these circumstances
a difference in commission charges may exist between the commissions charged to clients who
direct us to use a particular broker or dealer and other clients who do not direct us to use a
particular broker or dealer.
AC does not receive client referrals from broker-dealers in exchange for cash or other
compensation, such as brokerage services or research.
AC does not have any formal soft dollar arrangements.
When AC buys or sells the same security for two or more clients (including our personal
accounts), we may place concurrent orders to be executed together as a single “block” in order to
facilitate orderly and efficient execution. Each client account will be charged or credited with
the average price per unit. We receive no additional compensation or remuneration of any kind
because we aggregate client transactions. No client is favored over any other client. If an order
is not completely filled, it is allocated pro-rata based on an allocation statement prepared by AC
prior to placing the order. Because of an order’s aggregation, some clients may pay higher
transaction costs, or greater spreads, or receive less favorable net prices on transactions than
would otherwise be the case if the order had not been aggregated.
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Form ADV, Part 2A, Item 13
Review of Accounts
Client accounts are reviewed at least quarterly by Sean Spencer, Principal Executive Officer of
the firm. Sean Spencer reviews clients’ accounts with regards to their investment policies and
risk tolerance levels. All accounts at AC are assigned to this reviewer.
All financial planning accounts are reviewed upon financial plan creation and plan delivery by
Sean Spencer, Principal Executive Officer of the firm. There is only one level of review and that
is the total review conducted to create the financial plan.
Reviews may be triggered by material market, economic or political events, or by changes in
client's financial situations (such as retirement, termination of employment, physical move, or
inheritance).
Each client will receive at least quarterly a written report that details the clients’ account which
may come from the custodian. Clients are encouraged to review these statements to verify
accuracy and calculation correctness.
Clients are provided a one-time financial plan concerning their financial situation. After the
presentation of the plan, there are no further reports. Clients may request additional plans or
reports for a fee.
Form ADV, Part 2A, Item 14
Client Referrals and Other Compensation
AC does not compensate any individual or firm for client referrals. In addition, AC does not
receive compensation for referring clients to other professional service providers.
Form ADV, Part 2A, Item 15
Custody
AC does not have physical custody of any client funds and/or securities, and does not take
custody of client accounts at any time. Client funds and securities will be held with a bank,
broker dealer, or other independent qualified custodian. However, by granting AC written
authorization to automatically deduct fees from client accounts, AC is deemed to have limited
custody. You will receive account statements from the independent, qualified custodian holding
your funds at least quarterly. The account statement from your custodian will indicate the
amount of advisory fees deducted from your account(s) each billing cycle. Clients should
carefully review statements received from the custodian.
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Form ADV, Part 2A, Item 16
Investment Discretion
Before AC can buy or sell securities on your behalf, you must first sign our discretionary
management agreement, a limited power of attorney, and/or trading authorization forms. By
choosing to do so, you may grant the firm discretion over the selection and amount of securities
to be purchased or sold for your account(s) without obtaining your consent or approval prior to
each transaction. Clients may impose limitations on discretionary authority for investing in
certain securities or types of securities (such as a product type, specific companies, specific
sectors, etc.), as well as other limitations as expressed by the client. Limitations on discretionary
authority are required to be provided to the IAR in writing. Please refer to the “Advisory
Business” section of this Brochure for more information on our discretionary management
services.
Form ADV, Part 2A, Item 17
Voting Client Securities
We do not vote proxies on behalf of your advisory accounts. At your request, we may offer you
advice regarding corporate actions and the exercise of your proxy voting rights. If you own
shares of common stock or mutual funds, you are responsible for exercising your right to vote as
a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in
the event we were to receive any written or electronic proxy materials, we would forward them
directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in
which case, we would forward any electronic solicitation to vote proxies.
Form ADV, Part 2A, Item 18
Financial Information
AC is not required to provide financial information to our clients because we do not require or
solicit the prepayment of more than $500 six or more months in advance.
Form ADV, Part 2A, Item 19
Requirements for State-Registered Advisers
Principal Executive Officers and Management Persons Education and Business Background:
Sean Spencer
Managing Principal and CCO
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Business Background:
• Access Capital, LLC, Managing Principal / CCO, July 2023 - Present
•
IMA Wealth, Inc., Vice President / Financial Advisor / Portfolio Manager, July 2015 –
July 2023
Educational Background:
• Wichita State University, Bachelor of Science in Chemical / Business, Graduated: 2007
None of the Principal Executive Officers and Management persons listed have had any
complaints or any events required to be disclosed in this section.
Neither AC nor any of its Management persons have any relationships or arrangements with any
issuers of securities.
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