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Item 1 Cover Page
Part 2A of Form ADV: Firm Brochure
Accordant Advisory Group, Inc.
309 Third Street
Annapolis, MD 21403-2509
Telephone: 410-348-1499
Facsimile: 703-783-8733
Email: dmckee@planaccordingly.com
February 13, 2026
This brochure provides information about the qualifications and business practices of
Accordant Advisory Group, Inc. If you have any questions about the contents of this
brochure, please contact us at 410-348-1499 or E-mail us at
dmckee@planaccordingly.com. 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 Accordant Advisory Group, Inc. also is available on the
SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique
identifying number, known as a CRD number. Our firm's CRD number is 117474.
Registration as an investment adviser does not imply a certain level of skill or training.
Item 2 Material Changes
We have the following material changes to report since the last annual filing of this
Firm Brochure on 02/05/2025:
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Item 1: We have moved from the Independent Contractor Division to the RIA
and Custody Services Division of Raymond James Financial Services. As a
result, we have updated the information on the Raymond James Ambassador
Program, as well as our email addresses.
Item 4 and 5: We have added ERISA Retirement Plan Services to our service
offerings.
Item 5: Our hourly fee has been updated to $500.
Item 15: We have disclosed that for certain accounts, the Firm has authority to
transfer client funds to third parties pursuant to standing letters of authorization.
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Table of Contents
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Item 5
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Item 11
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Cover Page
Material Changes
Table of Contents
Advisory Business
Fees and Compensation
Performance-Based Fees and Side-By-Side Management
Types of Clients
Methods of Analysis, Investment Strategies and Risk of Loss
Disciplinary Information
Other Financial Industry Activities and Affiliations
Code of Ethics, Participation or Interest in Client Transactions,
Personal Trading
Brokerage Practices
Review of Accounts
Client Referrals and Other Compensation
Custody
Investment Discretion
Voting Client Securities
Financial Information
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Item 4 Advisory Business
Accordant Advisory Group, Inc. (“AAG”) is a registered investment adviser with its
principal place of business located in Annapolis, Maryland. AAG began conducting
business in 2000.
Listed below are the firm's principal shareholders (i.e., those individuals and/or
entities controlling 25% or more of this company).
·
David R. McKee, CFP, President, Chief Compliance Officer
AAG offers the following advisory services to our clients:
INDIVIDUAL PORTFOLIO MANAGEMENT
Ambassador Investment Account Program
The Ambassador Investment Account Program is a fee-based wrap fee program
sponsored by Raymond James & Associates, Inc. (“RJA”), member New York Stock
Exchange/SIPC. The Client is provided with ongoing investment advice and monitoring
of securities holdings including portfolio reviews and recommendations. AAG provides
continuous advice to the Client regarding the investment of client funds based on the
individual needs of the Client. Through personal discussions in which goals and
objectives based on the Client's particular circumstances are established, we develop
the Client's personal investment policy and create and manage a portfolio based on
that policy. During our data-gathering process, we determine the Client’s individual
objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also
review and discuss the Client's prior investment history, as well as family composition
and background.
We generally construct portfolios using individual stocks, ETFs (equity, fixed income
and commodities), actively managed traditional mutual funds, passively managed index
funds, fee based index annuities and individual fixed income securities. AAG will
manage the account on a discretionary or non-discretionary basis in accordance with
the Client Agreement. Any changes to investment objectives shall be provided to AAG
in writing. Clients may impose reasonable restrictions on investing in certain securities,
types of securities, or industry sectors.
As RJA is the sponsor of the wrap fee program, clients will receive a Wrap Fee Program
Brochure (Form ADV Part 2A Appendix 1) prepared by RJA. The Wrap Fee Program
Brochure describes in detail the services offered within the program. Clients are
encouraged to review the Wrap Fee Program Brochure to learn more about the
particular characteristics of the services offered within the program. RJA is an
investment adviser registered with the SEC that is independent of AAG.
FINANCIAL PLANNING
We provide financial planning services. Financial planning is a comprehensive
evaluation of a client’s current and future financial state by using currently known
variables to predict future cash flows, asset values and withdrawal plans. Through the
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financial planning process, all questions, information and analysis are considered as
they impact and are impacted by the entire financial and life situation of the client.
Clients purchasing this service receive a written report which provides the client with a
detailed financial plan designed to assist the client achieve his or her financial goals and
objectives.
In general, the financial plan can address any or all of the following areas:
PERSONAL: We review family records, budgeting, personal liability, estate
·
information and financial goals.
TAX & CASH FLOW: We analyze the client’s income tax and spending and
·
planning for past, current and future years; then illustrate the impact of various
investments on the client's current income tax and future tax liability.
INVESTMENTS: We analyze investment alternatives and their effect on the
·
client's portfolio.
INSURANCE: We review existing policies to ensure proper coverage for life,
·
health, disability, long-term care, liability, home and automobile.
RETIREMENT: We analyze current strategies and investment plans to help the
·
client achieve his or her retirement goals.
DEATH & DISABILITY: We review the client’s cash needs at death, income
·
needs of surviving dependents, estate planning and disability income.
·
ESTATE: We assist the client in assessing and developing long-term strategies,
including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset
protection plans, nursing homes, Medicare and elder law.
We gather required information through in-depth personal interviews. Information
gathered includes the client's current financial status, tax status, future goals, returns
objectives and attitudes towards risk. We carefully review documents supplied by the
client, including a questionnaire completed by the client, and prepare a written report.
Should the client choose to implement the recommendations contained in the plan, we
suggest the client work closely with his/her attorney, accountant, insurance agent,
and/or stockbroker. Implementation of financial plan recommendations is entirely at the
client's discretion.
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Typically the financial plan is presented to the client within six months of the contract
date, provided that all information needed to prepare the financial plan has been
promptly provided.
Financial Planning recommendations are not limited to any specific product or service
offered by a broker-dealer or insurance company. All recommendations are of a generic
nature.
ERISA RETIREMENT PLAN SERVICES
The Employee Retirement Income Security Act of 1974 ("ERISA”) is the law governing
the operation of employee benefit plans. AAG provides investment advisory and
consulting services to Plan Sponsors of ERISA plans under Sections 3(21) of ERISA.
When providing services to a Plan Sponsor, the Plan Sponsor is the client. AAG
provides ongoing investment monitoring and investment recommendation services as
outlined in the written agreement between AAG and the Plan Sponsor. Under the 3(21)
Service, AAG does not have investment discretion and does not have the power to
manage, acquire, or dispose of any plan assets. The Plan Sponsor retains ultimate
decision-making authority for the investments and may accept or reject the
recommendations of AAG under this Service.
As part of this service, AAG may assist the Plan Sponsor with Plan Participant
enrollment and Plan education. If the services selected by the Plan Sponsor include
enrollment and investment education to Plan Participants, the services do not include
any individualized investment advice within the meaning of ERISA to Plan Participants
with respect to their Plan assets.
WRAP FEE PROGRAMS
A wrap fee program is a comprehensive advisory account with a single fee that covers
both asset management fees and trade ticket execution charges. AAG does not
sponsor or act as the portfolio manager of a wrap fee program, however, when using
Raymond James Ambassador Investment Account Program, clients will be participating
in a wrap fee program
AMOUNT OF MANAGED ASSETS
As of December 31, 2025, we were actively managing $218,889,201 of client assets
on a discretionary basis plus $59,084,171 of client assets on a non-discretionary basis.
Item 5
Fees and Compensation
INDIVIDUAL PORTFOLIO MANAGEMENT
Ambassador Investment Account Program
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The annualized fees for Individual Portfolio Management services in the Ambassador
program are charged as a percentage of assets under management, according to
the following schedules:
Account Value
Up to $1 million
$1 million up to $2 million
$2 million up to $5 million
$5 million up to $10 million
$10 million and up
Quarterly Fee
.5625%
.5
.4375
.375
.3125
Annualized Fee
2.25%
2.00%
1.75%
1.50%
1.25%
The fee is a “wrap fee” and, therefore, includes all execution and clearing charges
except: (1) certain dealer markups and odd lot differentials, transfer taxes, exchange
fees mandated by the Securities and Exchange Act of 1934 and any other charges
imposed by law with regard to any transactions in the account; and (2) offering
concessions and related fees for purchases of public offerings of securities.
There is a minimum account size of $10,000 required for the Ambassador program.
The client will receive RJA’s Wrap Fee program Brochure (Form ADV Part 2A Appendix
1), which describes the Ambassador program’s services and fees.
Fees Billed in Advance: The advisory fee will be billed quarterly in advance at the
beginning of each calendar quarter based upon the asset value (market or fair market
value in the absence of market value, plus any credit balance or minus any debit
balance), of the client's account value as of the last day of the previous calendar
quarter.
Clients authorize and direct AAG and RJA to deduct asset based advisory fees from the
client’s account. The custodian, Raymond James & Associates, sends statements at
least quarterly to the client which shows all amounts disbursed from the client’s account,
including the advisory fees paid to AAG. Clients understand that the brokerage
statement will show the amount of the asset-based fee, the value of the assets on which
the fee was based, and the specific manner in which the fee was calculated.
FINANCIAL PLANNING
Our Financial Planning service fee is calculated and charged on an hourly basis at the
rate of $500 per hour. All fees are agreed upon prior to entering into a contract with any
client.
The client is billed quarterly in arrears based on actual hours accrued.
ERISA RETIREMENT PLAN SERVICES
Fees for retirement plan services provided to ERISA Plan Sponsors are negotiated by
AAG and the Plan Sponsor and will not exceed 0.50% A Plan Sponsor’s agreement with
the recordkeeper will determine the frequency at which fees are paid. For example, fees
may be calculated and billed quarterly in arrears; however, some recordkeepers may
calculate and bill more frequently.
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ADDITIONAL COMPENSATION
The principal executive officer is separately licensed as an insurance agent or broker for
one or more insurance companies. As such, this individual, in their separate capacities
as insurance agent or broker, will be able to purchase insurance products for clients. As
a result, these individuals will receive separate, yet customary compensation (i.e.,
commissions. This individual spends approximately two hours per month on this related
activity.
A conflict of interest exists between the interests of these individuals, and those of the
advisory clients, creating an incentive for them to recommend insurance products based
on the compensation received through various insurance companies, rather than on a
client’s needs. However, clients are under no obligation to act upon any
recommendations of these individuals or to effect any transactions through them if they
decide to follow the recommendations.
GENERAL INFORMATION
Limited Negotiability of Advisory Fees: Although AAG has established the
aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees
on a client-by-client basis. Client facts, circumstances and needs are considered in
determining the fee schedule. These include the complexity of the client, assets to be
placed under management, anticipated future additional assets; related accounts;
portfolio style, account composition, reports, among other factors. The specific annual
fee schedule is identified in the contract between the adviser and each client.
We may group certain related client accounts for the purposes of achieving the
minimum account size requirements and determining the annualized fee.
Termination of the Advisory Relationship: A client agreement may be canceled at
any time, by either party, for any reason upon receipt of written notice. Upon termination
of any account, AAG will refund to the client the prorated portion of the advisory fee for
the quarter of termination.
Mutual Fund Fees: All fees paid to AAG 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. These fees will generally include
management and operating expenses of open-end, closed-end and exchange traded
funds; short-term trading charges of certain mutual funds, and a possible distribution
fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales
charge. 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.
ERISA Accounts: AAG is deemed to be a fiduciary to advisory clients that are
employee benefit plans or individual retirement accounts (IRAs) pursuant to the
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Employee Retirement Income Security Act of 1974 (ERISA), and regulations under the
Internal Revenue Code of 1986 (the “Code”), respectively. As such, our firm is subject
to specific duties and obligations under ERISA and the Code that include among other
things, restrictions concerning certain forms of compensation.
Additional Fees and Expenses: In addition to our advisory fees, clients may also
incur charges for other services not directly related to the execution and clearing
of transactions including wire transfer fees and interest charges on margin loans.
Advisory Fees in General: Clients should note that similar advisory services may (or
may not) be available from other registered (or unregistered) investment advisers for
similar or lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit
payment of fees in excess of $1,200 more than six months in advance of
services rendered.
Item 6 Performance-Based Fees and Side-By-Side Management
AAG does not charge performance-based fees, and therefore does not engage in
side-by-side management.
Item 7 Types of Clients
AAG provides advisory services to the following types of clients:
·
Individuals
·
High net worth individuals
·
Pension and profit sharing plans
·
Charitable organizations
·
Corporations
There is a minimum account size of $10,000 required for the Ambassador program.
Please refer to Item 5 of this disclosure brochure for more information.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
METHODS OF ANALYSIS
We use the following methods of analysis in formulating our investment advice and/or
managing client assets:
Fundamental Analysis. We attempt to measure the intrinsic value of a security by
looking at economic and financial factors (including the overall economy, industry
conditions, and the financial condition and management of the company itself) to
determine if the company or market sector is underpriced (indicating it may be a good
time to buy) or overpriced (indicating it may be time to sell).
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Fundamental analysis does not attempt to anticipate market movements. This presents
a potential risk, as the price of a security can move up or down along with the overall
market regardless of the economic and financial factors considered in evaluating the
security.
Technical Analysis. We analyze past market movements and apply that analysis to
the present in an attempt to recognize recurring patterns of investor behavior and
potentially predict future price movement. Technical analysis does not consider the
underlying financial condition of a company. This presents a risk in that a
poorly-managed or financially unsound company may underperform regardless of
market movement.
Risks for all forms of analysis. Our securities analysis methods rely on the
assumption that the companies whose securities 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
We use the following strategy(ies) in managing client accounts, provided that such
strategy(ies) are appropriate to the needs of the client and consistent with the client's
investment objectives, risk tolerance, and time horizons, among other considerations:
Long-term purchases. We purchase securities with the idea of holding them in the
client's account for a year or longer. Typically we employ this strategy when:
·
we believe the securities to be currently undervalued, and/or
we want exposure to a particular asset class over time, regardless of the current
·
projection for this class.
Short-term purchases. When utilizing this strategy, we purchase securities with the
idea of selling them within a relatively short time (typically a year or less). We do this in
an attempt to take advantage of conditions that we believe will soon result in a price
swing in the securities we purchase.
Risk of Loss. Securities investments are not guaranteed and you may lose money on
your investments. We ask that you work with us to help us understand your tolerance
for risk.
Security-Specific Risks. Most of the time your account will be invested in a
combination of mutual funds, exchange –traded funds (ETFs), and individual securities
such as common stocks, bonds, and American Depository Receipts (ADRs).
Mutual funds and ETFs carry product-specific risks and you should review the
applicable prospectuses for the funds in your portfolio in order to have a complete
understanding of these risks. Some of these funds invest in specific sectors or parts of
the world and as such carry additional concentration risks related to fundamental or
technical factors that are unique to that sector or geographic area.
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While mutual funds are purchased and redeemed directly from the issuing company at
net asset value (NAV), they are not traded throughout the day and can only be bought
or sold at the market close, typically 4PM Eastern Time. While ETFs can typically be
bought and sold on an exchange throughout the day there is no guarantee that an
investor will be able to do so at or near net asset value. While mutual funds and ETFs
will typically be purchased in order to participate in a specific segment of the market,
these products carry additional fees and there is no guarantee that the funds will
achieve their objectives and realized returns may be below what one would expect
given the prevailing market conditions.
Common stocks and bonds carry risks specific to the issuer. While a mutual fund or ETF
is typically invested across a significant number of different securities, when one invests
directly in the securities of a specific corporation or government entity they assume
some concentration risk. Often specific issues will arise that are specific to that issuer
which will negatively impact the value of their securities, but not necessarily those of
other similar issuers. ADRs hold securities of non-US issuers and therefore carry
additional risks present in foreign securities, including political risk and currency risk.
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's
or prospective client's evaluation of our advisory business or the integrity of our
management.
Our firm and our management personnel have no reportable disciplinary events to
disclose.
Item 10 Other Financial Industry Activities and Affiliations
The principal executive officer of AAG, David McKee, is licensed insurance agent. Mr.
McKee may receive compensation for his activities as an insurance agent. Mr. McKee
spends approximately 1-2 hours per month on this activity.
Clients should be aware that the receipt of additional compensation by AAG and its
management persons or employees creates a conflict of interest that may impair the
objectivity of our firm and these individuals when making advisory recommendations.
AAG endeavors at all times to put the interest of its clients first as part of our fiduciary
duty as a registered investment adviser; we take the following steps to address this
conflict:
● we disclose to clients the existence of all material conflicts of interest, including the
potential for our firm and our employees to earn compensation from advisory clients
in addition to our firm's advisory fees;
● we disclose to clients that they are not obligated to purchase recommended
investment products from our employees or affiliated companies;
● we collect, maintain and document accurate, complete and relevant client
background information, including the client’s financial goals, objectives and risk
tolerance;
● our firm's management conducts regular reviews of each client account to verify
that all recommendations made to a client are suitable to the client’s needs and
circumstances;
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● we require that our employees seek prior approval of any outside employment
activity so that we may ensure that any conflicts of interests in such activities are
properly addressed;
● we periodically monitor these outside employment activities to verify that any
conflicts of interest continue to be properly addressed by our firm; and
● we educate our employees regarding the responsibilities of a fiduciary, including
the need for having a reasonable and independent basis for the investment advice
provided to clients.
Item 11 Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Our firm has adopted a Code of Ethics which sets forth high ethical standards
of business conduct that we require of our employees, including compliance
with applicable federal securities laws.
AAG and our personnel owe a duty of loyalty, fairness and good faith towards our
clients, and have an obligation to adhere not only to the specific provisions of the Code
of Ethics but to the general principles that guide the Code.
Our Code of Ethics includes policies and procedures for the review of quarterly
securities transactions reports as well as initial and annual securities holdings reports
that must be submitted by the firm’s access persons. Among other things, our Code
of Ethics also requires the prior approval of any acquisition of securities in a limited
offering (e.g., private placement) or an initial public offering. Our code also provides
for oversight, enforcement and recordkeeping provisions.
AAG’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 dmckee@planaccordingly.com.com,
or by calling us at 410-348-1499.
Our Code of Ethics is designed to assure that the personal securities transactions,
activities and interests of our employees will not interfere with (i) making decisions in the
best interest of advisory clients and (ii) 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(ies)
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.
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Item 12 Brokerage Practices
AAG does not have any soft-dollar arrangements and does not receive any soft-dollar
benefits.
Client assets will be custodied at Raymond James & Associates, Inc. (“RJA”).
AMBASSADOR PROGRAM CLIENTS
The Ambassador program is a fee-based account in which the Client is provided with
ongoing investment advice and monitoring of securities holdings. AAG will manage the
account on a discretionary or non-discretionary basis according to your objectives.
Clients may impose reasonable restrictions on investing in certain securities, types of
securities, or industry sectors.
BEST EXECUTION
Obtaining best execution for our clients is an important aspect of our fiduciary duty. We
review the quality of services provided by RJFS including the accuracy and speed of
execution, fee rates, reputation and integrity, reporting, fairness in resolving disputes,
financial responsibility and responsiveness. In seeking best execution, the
determinative factor is not the lowest possible cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of a
broker/dealer’s services, including the value of research provided, execution capability,
fee rates, and responsiveness.
We receive economic benefits through our relationship with RJFS that are typically not
available to RJFS retail investors. These benefits may include the following products
and services (provided without cost or at a discount): duplicate client statements and
confirmations; research related products and tools; consulting services; access to a
trading desk serving adviser participants; access to block trading (which provides the
ability to aggregate securities transactions for execution and then allocate the
appropriate shares to client accounts); the ability to have advisory fees deducted
directly from client accounts; access to an electronic communications network for client
order entry and account information; access to mutual funds with no transaction fees
and to certain Institutional money managers; and discounts on compliance, marketing,
research, technology, and practice management products or services provided to AAG
by third party vendors. RJFS may also pay for business consulting and professional
services received by AAG’s related persons and may also pay or reimburse expenses
(including travel, lodging, meals and entertainment expenses) for RJFS’s personnel to
attend conferences or meetings relating to the program or to RJFS’s adviser custody
and brokerage services generally.
Some of the products and services made available by RJFS may benefit AAG but may
not benefit our client accounts. These products or services may assist us in managing
and administering client accounts. Other services made available by RJFS are intended
to help us manage and further develop our business enterprise. The benefits received
by AAG or our personnel through participation in the program do not depend on the
amount of brokerage transactions directed to RJFS. Clients should be aware, however,
that the receipt of economic benefits by AAG or our related persons in and of itself
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creates a potential conflict of interest and may indirectly influence our choice of RJFS
for custody and brokerage services. As a result of receiving services for no additional
cost, we may have an incentive to select or recommend RJFS based on our interest in
receiving the research or other products or services, rather than on the clients’ interest
in receiving most favorable execution. We examined this potential conflict of interest
when we chose to enter into the relationship with RJFS and have determined that the
relationship is in the best interests of AAG clients and satisfies our client obligations,
including our duty to seek best execution.
BLOCK TRADING
AAG will block trades where possible and when advantageous to clients. This blocking
of trades permits the trading of aggregate blocks of securities composed of assets
from multiple client accounts, so long as transaction costs are shared equally and on a
pro-rated basis between all accounts included in any such block.
Block trading may allow us to execute equity trades in a timelier, more equitable
manner, at an average share price. We will typically aggregate trades among clients
whose accounts can be traded at a given broker. Our block trading policy and
procedures are as follows:
Transactions for any client account may not be aggregated for execution if the
1)
practice is prohibited by or inconsistent with the client's advisory agreement with AAG,
or our firm's order allocation policy.
2)
The portfolio manager must determine that the purchase or sale of the particular
security involved is appropriate for the client and consistent with the client's investment
objectives and with any investment guidelines or restrictions applicable to the client's
account.
3)
The portfolio manager must reasonably believe that the order aggregation will
benefit, and will enable AAG to seek best execution for each client participating in the
aggregated order. This requires a good faith judgment at the time the order is placed
for the execution. It does not mean that the determination made in advance of the
transaction must always prove to have been correct in the light of a "20-20 hindsight"
perspective. Best execution includes the duty to seek the best quality of execution, as
well as the best net price.
4)
Prior to entry of an aggregated order, an order ticket must be completed which
identifies each client account participating in the order and the proposed allocation of
the order, upon completion, to those clients.
If the order cannot be executed in full at the same price or time, the securities
5)
actually purchased or sold by the close of each business day must be allocated pro rata
among the participating client accounts in accordance with the initial order ticket or
other written statement of allocation. However, adjustments to this pro rata allocation
may be made to participating client accounts in accordance with the initial order ticket
or other written statement of allocation. Furthermore, adjustments to this pro rata
allocation may be made to avoid having odd amounts of shares held in any client
account, or to avoid excessive ticket charges in smaller accounts.
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6)
Generally, each client that participates in the aggregated order must do so at the
average price for all separate transactions made to fill the order, and must share in the
commissions on a pro rata basis in proportion to the client's participation. Under the
client’s agreement with the custodian/broker, transaction costs may be based on the
number of shares traded for each client.
If the order will be allocated in a manner other than that stated in the initial
7)
statement of allocation, a written explanation of the change must be provided to and
approved by the Chief Compliance Officer no later than the morning following the
execution of the aggregate trade.
AAG client account records separately reflect, for each account in which the
8)
aggregated transaction occurred, the securities which are held by, and bought and sold
for, that account.
9)
Funds and securities for aggregated orders are clearly identified on AAG’s
records and to the broker-dealers or other intermediaries handling the transactions, by
the appropriate account numbers for each participating client.
10) No client or account will be favored over another.
Item 13 Review of Accounts
INDIVIDUAL PORTFOLIO MANAGEMENT
REVIEWS: While the underlying securities within Ambassador accounts are continually
monitored, these accounts are reviewed at least quarterly. 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.
REPORTS: Clients will receive monthly or quarterly statements and confirmations of
transactions directly from their broker-dealer. AAG will provide performance reports
upon client request..
FINANCIAL PLANNING SERVICES
REVIEWS: While reviews may occur at different stages depending on the nature and
terms of the specific engagement, typically no formal reviews will be conducted for
Financial Planning clients unless otherwise contracted for.
REPORTS: Financial Planning clients will receive a completed financial plan. Additional
reports will not typically be provided unless otherwise contracted for.
All accounts are reviewed by David McKee, President of AAG.
Item 14 Client Referrals and Other Compensation
CLIENT REFERRALS
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AAG does not compensate any person for client referrals.
OTHER COMPENSATION
AAG does not receive any economic benefit directly or indirectly from any third party
for advice rendered to its clients.
Item 15 Custody
We previously disclosed in the "Fees and Compensation" section (Item 5) of this
Brochure our advisory fees may be directly debited client accounts.
As part of this billing process, the client's custodian is advised of the amount of the fee
to be deducted from that client's account. On at least a quarterly basis, the custodian is
required to send to the client a statement showing all transactions within the account
during the reporting period.
It is important for clients to carefully review their custodial statements from Raymond
James in order to verify the accuracy of the calculation, among other things. Clients
should contact us directly if they believe that there may be an error in their statement.
Custody is also disclosed in Form ADV because AAG has standing letters of
authorization set up to transfer funds from client account(s) to third-parties. On
February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to the Rule
206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940. The letter
provided guidance on the Custody Rule as well as clarified that an adviser who has the
power to disburse client funds to a third party under a standing letter of authorization
(“SLOA”) is deemed to have custody. As such, our firm has adopted the following
safeguards in conjunction with our custodians:
1) The client provides an instruction to the qualified custodian, in writing, that
includes the client’s signature, the third party’s name, and either the third
party’s address or the third party’s account number at a custodian to which the
transfer should be directed;
2) The client authorizes the investment adviser, in writing, either on the qualified
custodian’s form or separately, to direct transfers to the third party either on a
specified schedule or from time to time;
3) The client’s qualified custodian performs appropriate verification of the
instruction, such as a signature review or other method to verify the client’s
authorization, and provides a transfer of funds notice to the client promptly
after each transfer;
4) The client has the ability to terminate or change the instruction to the client’s
qualified custodian;
5) The investment adviser has no authority or ability to designate or change the
identity of the third party, the address, or any other information about the third
party contained in the client’s instruction;
6) The investment adviser maintains records showing that the third party is not a
related party of the investment adviser or located at the same address as the
investment adviser; and
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7) The client’s qualified custodian sends the client, in writing, an initial notice
confirming the instruction and an annual notice reconfirming the instruction.
Accordingly, AAG will comply with the SEC’s seven conditions as listed above rather
than undergo an annual audit.
Investment Discretion
Item 16
Clients may hire us to provide discretionary asset management services, in which case
we place trades in a client's account without contacting the client prior to each trade to
obtain the client's permission.
Our discretionary authority includes the ability to do the following without contacting the
client:
·
determine the security to buy or sell; and/or
·
determine the amount of the security to buy or sell
Clients give us discretionary authority when they sign a discretionary agreement with
our firm, and may limit this authority by giving us written instructions. Clients may also
change/amend such limitations by once again providing us with written instructions.
Item 17 Voting Client Securities
As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore,
although our firm may provide investment advisory services relative to client investment
assets, 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.
We may provide clients with consulting assistance regarding proxy issues if they contact
us with questions at our principal place of business.
Item 18 Financial Information
Under no circumstances do we require or solicit payment of fees in excess of $1,200
per client more than six months in advance of services rendered. Therefore, we are not
required to include a financial statement.
As an advisory firm that maintains discretionary authority for client accounts, we are
also required to disclose any financial condition that is reasonably likely to impair our
ability to meet our contractual obligations. AAG has no additional financial
circumstances to report.
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AAG has not been the subject of a bankruptcy petition at any time during the past ten
years.
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