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F O R M A D V P A R T 2 A
D I S C L O S U R E B R O C H U R E
Advanced Planning Advisors Group Inc.
Office Address:
400 East Diehl Road
Suite 240
Naperville, IL 60563
rob@apadvisorsgroup.com
Tel: 630-780-1099
www.apadvisorsgroup.com
APRIL 9, 2026
This brochure provides information about the qualifications and business practices of Advanced
Planning Advisors Group Inc. Being registered as a registered investment adviser does not imply a
certain level of skill or training. If you have any questions about the contents of this brochure,
please contact us at 630-780-1099. 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 Advanced Planning Advisors Group Inc. (CRD #313101) is available
on the SEC’s website at www.adviserinfo.sec.gov
i
Item 2: Material Changes
Annual Update
Material Changes since the Last 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.
Since the last filing of this brochure on February 26, 2026, the following items have been
•
updated:
•
Item 4 has been updated with the firm’s most recent assets under management
calculation.
Full Brochure Available
Item 5: Gradient Investments Co-Advisor fee schedule updated.
This Firm Brochure being delivered is the complete brochure for the Firm.
ii
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................................... ii
Material Changes since the Last Update.................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Full Brochure Available .................................................................................................................................................. ii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions ............................................................................... 1
Wrap Fee Programs ......................................................................................................................................................... 1
Item 5: Fees and Compensation ....................................................................................................... 2
Client Assets under Management .............................................................................................................................. 1
Method of Compensation and Fee Schedule .......................................................................................................... 2
Client Payment of Fees ................................................................................................................................................... 3
Additional Client Fees Charged ................................................................................................................................... 3
Prepayment of Client Fees ............................................................................................................................................ 3
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 4
External Compensation for the Sale of Securities to Clients ........................................................................... 4
Item 7: Types of Clients ....................................................................................................................... 4
Sharing of Capital Gains ................................................................................................................................................. 4
Description .......................................................................................................................................................................... 4
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 4
Account Minimums .......................................................................................................................................................... 4
Methods of Analysis ......................................................................................................................................................... 4
Investment Strategy ........................................................................................................................................................ 4
Item 9: Disciplinary Information ..................................................................................................... 5
Security Specific Material Risks .................................................................................................................................. 5
Criminal or Civil Actions ................................................................................................................................................ 5
Administrative Enforcement Proceedings ............................................................................................................. 5
iii
Item 10: Other Financial Industry Activities and Affiliations................................................ 5
Self- Regulatory Organization Enforcement Proceedings ............................................................................... 5
Broker-Dealer or Representative Registration .................................................................................................... 5
Futures or Commodity Registration ......................................................................................................................... 5
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 5
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 6
Trading ..................................................................................................................................................... 6
Code of Ethics Description ............................................................................................................................................ 6
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest.... 7
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ... 7
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Item 12: Brokerage Practices ........................................................................................................... 7
Transactions and Conflicts of Interest ..................................................................................................................... 7
Factors Used to Select Broker-Dealers for Client Transactions .................................................................... 7
Item 13: Review of Accounts ............................................................................................................. 8
Aggregating Securities Transactions for Client Accounts ................................................................................ 8
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ................................................................................................................................................................................ 8
Review of Client Accounts on Non-Periodic Basis .............................................................................................. 8
Item 14: Client Referrals and Other Compensation .................................................................. 8
Content of Client Provided Reports and Frequency ........................................................................................... 8
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest .................................................................................................................................................................................. 8
Item 15: Custody .................................................................................................................................. 10
Advisory Firm Payments for Client Referrals ....................................................................................................... 9
Item 16: Investment Discretion ..................................................................................................... 10
Account Statements ...................................................................................................................................................... 10
Item 17: Voting Client Securities ................................................................................................... 10
Discretionary Authority for Trading...................................................................................................................... 10
Item 18: Financial Information ...................................................................................................... 10
Proxy Votes ...................................................................................................................................................................... 10
Balance Sheet .................................................................................................................................................................. 10
iv
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 10
Bankruptcy Petitions during the Past Ten Years .............................................................................................. 10
Item 19: Requirements for State Registered Advisors ........
Principal Executive Officers and Management Persons ...................
Error! Bookmark not defined.
Error! Bookmark not defined.
Error! Bookmark not defined.
Error! Bookmark not defined.
Outside Business Activities ...........................................................................
Performance Based Fee Description.........................................................
Error! Bookmark not defined.
Disclosure of Material Facts Related to Arbitration or Disciplinary Actions Involving
Management Persons ......................................................................................
Error! Bookmark not defined.
Material Relationship Maintained by this Advisory Business or Management Persons with
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 12
Issuers of Securities .........................................................................................
Principal Executive Officer – Patrick R. Kirvan ................................................................................................. 12
Item 2 - Educational Background and Business Experience ....................................................................... 12
Item 3 - Disciplinary Information ........................................................................................................................... 12
Item 4 - Other Business Activities ........................................................................................................................... 13
Item 5 - Additional Compensation .......................................................................................................................... 13
Error! Bookmark not defined.
Item 6 - Supervision ..................................................................................................................................................... 13
Item 7 - Requirements for State-Registered Advisors ......................
v
Item 4: Advisory Business
Firm Description
Types of Advisory Services
Advanced Planning Advisors Group Inc. (“APAG”) was founded in 2017 and became
registered to provide advisory services in 2021. Patrick R. Kirvan is 100% owner.
ASSET MANAGEMENT- CO-ADVISOR
APAG has entered into a Co-Advisor relationship with a Third Party Manager (“TPM”),
Gradient Investments, LLC (“GI”). APAG will provide information to each Client regarding
the services offered by GI as the portfolio manager. APAG will assist the Client to determine
the appropriate model selection based on the Client’s investment objectives and risk
tolerance. APAG will have full discretion on an ongoing basis to select suitable models to
maintain Client’s risk tolerance. APAG will share in the management fees charged by GI as
described in Item 5 of this brochure.
FINANCIAL PLANNING AND CONSULTING
Financial planning services are included at no additional cost for advisory Clients of APAG.
If financial planning services are needed by advisory Clients, an evaluation of an investor's
current and future financial state will be provided by using currently known variables to
predict future cash flows, asset values and withdrawal plans. APAG will use current net
worth, tax liabilities, asset allocation, and future retirement and estate plans in developing
financial plans. Typical topics reviewed in a financial plan may include but are not limited
to: Financial goals, Personal net worth statement, Cash flow analysis, Retirement strategy,
Comprehensive risk management plan, Long-term investment plan, Tax reduction strategy
and Estate preservation. Financial planning services are provided at no additional cost to
advisory Clients. If a conflict of interest exists between the interests of APAG and the
is under no obligation to act upon APAG’s
interests of the Client, the Client
recommendation. If the Client elects to act on any of the recommendations, the Client is
Client Tailored Services and Client Imposed Restrictions
under no obligation to effect the transaction through APAG.
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities.
Wrap Fee Programs
Agreements may not be assigned without written Client consent.
Client Assets under Management
APAG does not sponsor any wrap fee programs.
APAG has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$120,429,005
$0
Date Calculated:
March 31, 2026
- 1 -
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT- CO-ADVISOR
APAG has entered into a Referral Agreement with Gradient Investments, LLC (“GI”). GI is a
Registered Investment Advisor registered with the Securities and Exchange Commission
that provides investment portfolio advice and supervisory services.
GI Fee*
GI offers an actively managed program of mutual fund and stock portfolios. The fee will be
disclosed to the Client in the Investment Advisory Agreement and are negotiable. The
Clients fee for these services will be based on a percentage of assets under management as
Portfolio
follows:
Asset
Valuation
Stated Total
Annual Fee
APAG Fee
(Negotiable)
Custom Indexing - Strategic
All Assets
1.65%
0.65%
1.00%
Strategic
All Assets
1.50%
0.50%
1.00%
Custom Indexing - Allocation
All Assets
1.65%
0.65%
1.00%
Allocation
All Assets
1.50%
0.50%
1.00%
Tactical
All Assets
1.50%
0.50%
1.00%
Defined Outcome
All Assets
1.50%
0.50%
1.00%
Private Wealth
All Assets
1.50%
0.50%
1.00%
Preservation
All Assets
1.00%
0.40%
0.60%
Client Directed Accounts
All Assets
$300
$300
$0
rd
For Client Directed Accounts (CDA), GI will assist in the opening, closing and transferring of
accounts. GI will not have discretion at any time on these accounts. Client is solely
responsible for the assets held within the accounts and their values which could increase or
decrease (potential loss of principal). GI will not execute trades in CDA accounts. GI
exceptions will be made for withdrawals to client or assets transferred into a GI managed
portfolio. GI will also provide performance reporting on these accounts and can furnish
party analysis reports per the client’s request. Similar services may be available
3
through other sources for a lower fee.
- 2 -
These are flat fee schedules, the entire portfolio is Example:
Portfolio
Calculation
Quarterly
Fee
Custom Indexing – Strategic
($750,000x1.65%) x (91/365)
$3,085.27
Strategic Portfolio:
($750,000*1.50%) * (91/365)
$2,804.79
Tactical Portfolio:
($750,000*1.50%) * (91/365)
$2,804.79
Custom Indexing – Allocation
($750,000x1.65%) x (91/365)
$3,085.27
Allocation & Defined Outcome Portfolio: ($750,000*1.50%) * (91/365)
$2,804.79
Private Wealth Portfolio:
($750,000*1.5%) * (91/365)
$2,804.79
($750,000*1.0%) * (91/365)
$1,869.86
Preservation Portfolio:
$15 Quarterly Service Fee*
Fee Calculation: (Quarter End Value x Annual Fee %) x (Days in Quarter/Days in Year)
+
* The $15 Quarterly Service Fee is the technology fee charged per account or investment
strategy for performance and other reporting. This fee is disclosed in our ADV Part 2A (Item 5:
Fees and Compensation) and in our Investment Proposal and Contract (Schedule D: Schedule of
Fees).
The above fees are negotiable. Fees are assessed quarterly in arrears based on the amount of the
assets managed as of the end of the previous quarter and will take into account additions and
withdrawals in the time period. All management fees are withdrawn from the Client’s account
unless otherwise noted. GI will receive written authorization from the Client to deduct advisory
fees from their account held by a qualified custodian. GI will pay APAG their share of the fees.
APAG does not have access to deduct Client fees. Clients may terminate their account within five
(5) business days of signing the investment advisory agreement without penalty or obligation.
For terminations after the initial five business days, GI will be entitled to a pro-rata fee for the
days service was provided in the final quarter. GI will pay APAG their portion of the final fee.
Client Payment of Fees
FINANCIAL PLANNING AND CONSULTING
Financial planning services are included at no additional cost for asset management Clients
of APAG.
Additional Client Fees Charged
Fees for asset management services provided by TPM are deducted from a designated
Client account by TPM to facilitate billing. The Client must consent in advance to direct
debiting of their investment account.
Prepayment of Client Fees
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, and exchange-traded funds. These charges may include mutual fund transaction
fees, postage and handling fees. For more details on the brokerage practices, see Item 12 of
this brochure.
APAG does not require any prepayment of fees.
- 3 -
External Compensation for the Sale of Securities to Clients
Investment Advisor Representatives of APAG receive external compensation sales of
investment related products such as insurance as licensed insurance agents. This
represents a conflict of interest because it gives an incentive to recommend products based
on the commission received. This conflict is mitigated by disclosures, procedures, and
APAG’s fiduciary obligation to place the best interest of the Client first and Clients are not
required to purchase any products or services. Clients have the option to purchase these
products through another insurance agent of their choosing.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
APAG does not use a performance-based fee structure because of the conflict of interest.
Performance based compensation may create an incentive for APAG to recommend an
investment that may carry a higher degree of risk to the Client.
Item 7: Types of Clients
Description
APAG generally provides investment advice to individuals, high net worth individuals,
trusts and estates.
Account Minimums
Client relationships vary in scope and length of service.
APAG does not require a minimum to open an account.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
TPMs utilized by APAG may use various methods of analysis to determine the proper
strategy for the Client referred and these will be disclosed in the TPM’s Form ADV Part 2.
Investing in securities involves risk of loss that Clients should be prepared to bear. Past
performance is not a guarantee of future returns. Other strategies utilized by TPMs may
include long-term purchases, short-term purchases, trading, and option writing (including
covered options, uncovered options or spreading strategies).
In developing a financial plan for a Client, APAG’s analysis may include cash flow analysis,
investment planning, risk management, tax planning and legacy planning. Based on the
information gathered, a detailed strategy is tailored to the Client’s specific situation.
Investment Strategy
The main sources of information used may include financial newspapers and magazines,
research materials prepared by others, corporate rating services, annual reports,
prospectuses, and filings with the Securities and Exchange Commission.
The investment strategy for a specific Client is based upon the objectives stated by the
Client during consultations. The Client may change these objectives at any time. Each Client
- 4 -
executes a Client profile form or similar form that documents their objectives and their
Security Specific Material Risks
desired investment strategy.
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind.
•
The risks associated with utilizing TPMs include:
o
Manager Risk
•
TPM fails to execute the stated investment strategy
o
Business Risk
•
TPM has financial or regulatory problems
The specific risks associated with the portfolios of the TPM’s which is disclosed in
the TPM’s Form ADV Part 2.
Item 9: Disciplinary Information
Criminal or Civil Actions
Administrative Enforcement Proceedings
APAG and its management have not been involved in any criminal or civil action.
Self- Regulatory Organization Enforcement Proceedings
APAG and its management have not been involved in administrative enforcement
proceedings.
APAG and its management have not been involved in legal or disciplinary events that are
material to a Client’s or prospective Client’s evaluation of APAG or the integrity of its
management.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Futures or Commodity Registration
APAG is not registered as a broker-dealer and no affiliated representatives of APAG are
registered representatives of a broker-dealer.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Neither APAG nor its affiliated representatives are registered or have an application
pending to register as a futures commission merchant, commodity pool operator, or a
commodity trading advisor.
President Patrick R. Kirvan is also a licensed insurance agent with Advanced Planning
Advisors Group Inc. Approximately 10% of Patrick R. Kirvan’s time is spent in this practice.
He will offer Clients products from this activity and receive separate compensation.
This practice represents a conflict of interest because it gives an incentive to recommend
products based on the commission amount received. This conflict is mitigated disclosures,
procedures and the firm’s fiduciary obligation to place the best interest of the Client first
- 5 -
and the Clients are not required to purchase any products. Clients have the option to
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
purchase these products through another insurance agent of their choosing.
Clients placed with TPMs will be billed in accordance with the TPM’s fee schedule which
will be disclosed to the Client prior to signing an agreement. When referring Clients to a
TPM, the Client’s best interest will be the main determining factor of APAG. APAG ensures
that before selecting other advisors for Client that the other advisors are properly licensed
or registered as an investment advisor.
These practices represent conflicts of interest because APAG is paid a Referral Fee for
recommending the TPMs and may choose to recommend a particular TPM based on the fee
APAG is to receive. This conflict is mitigated by disclosures, procedures and the firm’s
fiduciary obligation to act in the best interest of his Clients. Clients are not required to
accept any recommendation of TPMs given by APAG and have the option to receive
investment advice through other money managers of their choosing.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
include employees and/or
independent
The affiliated persons (affiliated persons
contractors) of APAG have committed to a Code of Ethics (“Code”). The purpose of our Code
is to set forth standards of conduct expected of APAG affiliated persons and addresses
conflicts that may arise. The Code defines acceptable behavior for affiliated persons of
APAG. The Code reflects APAG and its supervised persons’ responsibility to act in the best
interest of their Client.
One area which the Code addresses is when affiliated persons buy or sell securities for
their personal accounts and how to mitigate any conflict of interest with our Clients. We do
not allow any affiliated persons to use non-public material information for their personal
profit or to use internal research for their personal benefit in conflict with the benefit to
our Clients.
APAG’s policy prohibits any person from acting upon or otherwise misusing non-public or
inside information. No advisory representative or other employee, officer or director of
APAG may recommend any transaction in a security or its derivative to advisory Clients or
engage in personal securities transactions for a security or its derivatives if the advisory
representative possesses material, non-public information regarding the security.
APAG’s Code is based on the guiding principle that the interests of the Client are our top
priority. APAG’s officers, directors, advisors, and other affiliated persons have a fiduciary
duty to our Clients and must diligently perform that duty to maintain the complete trust
and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s
interests over the interests of either affiliated persons or the company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have
access to non-public information regarding any Clients' purchase or sale of securities, or
non-public information regarding the portfolio holdings of any reportable fund, who are
- 6 -
involved in making securities recommendations to Clients, or who have access to such
recommendations that are non-public.
APAG will provide a copy of the Code of Ethics to any Client or prospective Client upon
Investment Recommendations Involving a Material Financial Interest and Conflict of
request.
Interest
APAG and its affiliated persons do not recommend to Clients securities in which we have a
material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
APAG and its affiliated persons may buy or sell securities that are also held by Clients. In
order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated
persons are required to disclose all reportable securities transactions as well as provide
APAG with copies of their brokerage statements.
The Chief Compliance Officer of APAG is Patrick R. Kirvan. He reviews all trades of the
affiliated persons each quarter. The personal trading reviews ensure that the personal
trading of affiliated persons does not affect the markets and that Clients of the firm receive
preferential treatment over affiliated persons’ transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
APAG does not maintain a firm proprietary trading account and does not have a material
financial interest in any securities being recommended and therefore no conflicts of
interest exist. However, affiliated persons may buy or sell securities at the same time they
buy or sell securities for Clients. In order to mitigate conflicts of interest such as front
running, affiliated persons are required to disclose all reportable securities transactions as
well as provide APAG with copies of their brokerage statements.
The Chief Compliance Officer of APAG is Patrick R. Kirvan. He reviews all trades of the
affiliated persons each quarter. The personal trading reviews ensure that the personal
trading of affiliated persons does not affect the markets and that Clients of the firm receive
preferential treatment over associated persons’ transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
APAG uses the custodian required by TPM, therefore APAG does not recommend the use of
• Directed Brokerage
a particular broker-dealer.
• Brokerage for Client Referrals
APAG utilizes TPMs and therefore it does not take direction from Clients as to what
broker-dealer to use.
APAG does not receive Client referrals from any custodian in exchange for using that
broker-dealer.
- 7 -
• Best Execution
• Soft Dollar Arrangements
Investment advisors who manage or supervise Client portfolios have a fiduciary
obligation of best execution. APAG does not trade individual securities in Client
accounts.
Aggregating Securities Transactions for Client Accounts
APAG does not receive soft dollar benefits.
APAG does not trade individual securities therefore aggregation of securities transactions
is not applicable.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Review of Client Accounts on Non-Periodic Basis
Account reviews are performed on a quarterly basis by the Chief Compliance Officer,
Patrick R. Kirvan. Account reviews are performed more frequently when market conditions
dictate. Financial plans generated are updated as requested by the Client.
Content of Client Provided Reports and Frequency
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws,
new investment information, and changes in a Client's own situation.
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by the TPM’s custodian. Client receives confirmations of
each transaction in account from Custodian and an additional statement during any month
in which a transaction occurs. APAG does not provide additional reports to Clients.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest
APAG utilizes the services of a Third Party Manager (“TPM”) to manage Client accounts. In
such circumstances, APAG receives Co-Advisor fees from the TPM. This situation creates a
conflict of interest. However, when referring Clients to a TPM, the Client’s best interest will
be the main determining factor of APAG. These fees do not include brokerage fees that may
be assessed by the custodian. Fees for these services are based on a percentage of assets
under management not to exceed any limit imposed by any regulatory agency. The final fee
schedule is disclosed in the Client agreement.
This Co-Advisor relationship is disclosed to the Client in each contract between APAG and
TPM. Client's signature is required to confirm consent for services within Third Party
Investment Agreement. Client
initials APAG's Investment Advisory Agreement to
acknowledge receipt of TPM fee schedule and required documents including Form ADV
Part 2 disclosures.
- 8 -
APAG Quarterly AUM with GI
Participation rate in GI’s fee
Incentive Program - GI
In addition to the regular advisory fee, GI has instituted a long-term incentive arrangement
where APAG may share in GI’s portion of the management fee. This does not change the
cost to the Client; it is a sharing arrangement paid from GI’s portion of the advisory fee. The
incentive arrangement will be paid annually according to the following table:
$10,000,000
3.00%
$25,000,000
10.00%
$50,000,000
12.50%
$75,000,000
15.00%
Once APAG reaches and maintains the thresholds listed above, the participation rate
applies to all of the AUM for the quarter.
To receive the incentive award, APAG needs to meet two qualifications. First, the quarter
end billable AUM must be above the threshold amounts specified. Second, APAG must be an
advisor “in good standing” with GI at the time the annual checks are issued. “In good
standing” means the advisor is proactively placing assets with GI.
This relationship will be disclosed to the Client in each contract between APAG and TPM.
Client's signature is required to confirm consent for services within Third Party Investment
Agreement. Client will initial APAG Investment Advisory Agreement to acknowledge
receipt of TPM fee schedule and required documents including Form ADV Part 2
disclosures.
This situation creates a conflict of interest because APAG and/or its Investment Advisor
Representative have an incentive to decide what TPMs to use because of the higher referral
fees to be received by APAG. However, when referring Clients to a TPM, the Client’s best
interest will be the main determining factor of APAG.
Advisory Firm Payments for Client Referrals
APAG’s investment advisor representatives may receive certain benefits from Gradient
Investments, LLC (and/or its affiliated companies) based on achieving certain production
thresholds. These thresholds are not based on the sale of any specific product or specific
product type. These incentives include marketing assistance, access to technology, office
support, and business trainings and trips. While some of these benefit the client, such as
technology and training, some do not. This creates a conflict of interest because it gives an
incentive to the representative to meet this threshold.
This conflict is mitigated by
disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the
Client first. Clients are not required to use Gradient Investments, LLC or any of its affiliated
companies.
APAG does not compensate for Client referrals.
- 9 -
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to Clients at their address of record at least quarterly. Clients are urged
to compare the account statements received directly from their custodians to any
documentation or reports prepared by TPM.
Item 16: Investment Discretion
Discretionary Authority for Trading
APAG has discretion to select appropriate portfolios for Clients when using GI portfolios,
but does not have the discretion to select specific securities within the portfolios.
APAG allows Client’s to place certain restrictions, as outlined in the Client’s Investment
Policy Statement or similar document. These restrictions must be provided to APAG in
writing.
Item 17: Voting Client Securities
Proxy Votes
APAG does not vote proxies on securities. Clients are expected to vote their own proxies.
The Client will receive their proxies directly from the custodian of their account or from a
transfer agent.
When assistance on voting proxies is requested, APAG will provide recommendations to
the Client. If a conflict of interest exists, it will be disclosed to the Client.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided to Clients because APAG does not serve as a
custodian for Client funds or securities and APAG does not require prepayment of fees of
more than $1200 per Client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
Bankruptcy Petitions during the Past Ten Years
APAG has no condition that is reasonably likely to impair our ability to meet contractual
commitments to our Clients.
APAG has not had any bankruptcy petitions in the last ten years.
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S U P E R V I S E D P E R S O N B R O C H U R E
Item 1 Cover Page
F O R M A D V P A R T 2 B
Patrick R. Kirvan
Advanced Planning Advisors Group Inc.
Office Address:
400 East Diehl Road
Suite 240
Naperville, IL 60563
Tel: 630-780-1099
rob@apadvisorsgroup.com
www.apadvisorsgroup.com
APRIL 9, 2026
This brochure supplement provides information about Patrick R. Kirvan and supplements the Advanced
Planning Advisors Group Inc. brochure. You should have received a copy of that brochure. Please contact
Patrick R. Kirvan if you did not receive the brochure or if you have any questions about the contents of
this supplement.
Additional information about Patrick R. Kirvan (CRD #6135958) is available on the SEC’s website at
www.adviserinfo.sec.gov.
- 11 -
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer – Patrick R. Kirvan
•
Item 2 - Educational Background and Business Experience
Year of birth: 1971
•
Educational Background:
Carleton University; area of study-Business; attended 1990; no degree obtained
•
Business Experience:
•
•
•
Item 3 - Disciplinary Information
Advanced Planning Advisors Group Inc.; CCO/Investment Advisor Representative;
04/2021 – Present
Advanced Planning Advisors Group Inc.; President/Insurance Agent; 12/2017 –
Present
Gradient Advisors, LLC; Investment Advisor Representative; 11/2012 – 04/2021
Patrick R. Kirvan; Independent Insurance Agent; 09/2010 – 11/2017
A.
Mr. Kirvan has never been involved in a criminal or civil action in a domestic,
foreign or military court of competent jurisdiction for which he:
1.
2.
3.
4.
Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any
felony; (b) misdemeanor that involved investments or an investment-related
business, fraud, false statement or omissions, wrongful taking of property,
bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any
of these offenses;
Is the named subject of a pending criminal proceeding that involves an
investment-related business, fraud, false statements or omissions, wrongful
taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a
conspiracy to commit any of these offenses;
Was found to have been involved in a violation of an investment-related statute
or regulation; or
Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order.
B.
Mr. Kirvan never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory
authority in which he:
1.
2.
Was found to have caused an investment-related business to
lose its
authorization to do business; or the subject of an order by the agency or
authority;
Was found to have been involved in a violation of an investment-related statute
or regulation or was the subject of an order by the agency or authority
(a)denying, suspending or revoking the authorization of the supervised person
to act in an investment-related business; (b) barring or suspending his
association with an investment-related business; (c) otherwise significantly
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limiting his investment-related activities; or (d) imposing a civil money penalty
of more than $2,500 on him.
C.
Mr. Kirvan has never been the subject of a self-regulatory organization (SRO)
proceeding in which he:
1.
lose its
2.
Was found to have caused an investment-related business to
authorization to do business; or
Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members,
or was expelled from membership; (b) otherwise significantly limited from
investment-related activities; or (c) fined more than $2,500.
D.
Item 4 - Other Business Activities
Mr. Kirvan has not been involved in
any other hearing or formal adjudication in
which a professional attainment, designation, or license of the supervised person
was revoked or suspended because of a violation of rules relating to professional
conduct.
Patrick R. Kirvan is also a licensed insurance agent with Advanced Planning Advisors Group
Inc. Approximately 10% of Patrick R. Kirvan’s time is spent in this practice. He will offer
Clients products from this activity and receive separate compensation.
Item 5 - Additional Compensation
This practice represents a conflict of interest because it gives an incentive to recommend
products based on the commission amount received. This conflict is mitigated disclosures,
procedures and the firm’s fiduciary obligation to place the best interest of the Client first
and the Clients are not required to purchase any products. Clients have the option to
purchase these products through another insurance agent of their choosing.
Item 6 - Supervision
Patrick R. Kirvan receives commissions on the insurance he sells. He does not receive any
performance-based fees. He does not receive any additional compensation for performing
advisory services other than what is disclosed in Item 5 of Part 2A.
Patrick R. Kirvan is the Chief Compliance Officer of APAG. He is solely responsible for all
supervision and formulation and monitoring of investment advice offered to Clients. He
will adhere to the policies and procedures as described in the firm’s Compliance Manual.
He can be reached at rob@apadvisorsgoup.com or 630-780-1099.
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