Overview
- Headquarters
- Dallas, TX
- Average Client Assets
- $0.9 million
- SEC CRD Number
- 164109
Recent Rankings
Forbes 2025: 197
Fee Structure
Primary Fee Schedule (07.01.2025 ARC FORM ADV PART 2A APPENDIX 1 WRAP FEE BROCHURE FINAL - AMENDED)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 2.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $25,000 | 2.50% |
| $5 million | $125,000 | 2.50% |
| $10 million | $250,000 | 2.50% |
| $50 million | $1,250,000 | 2.50% |
| $100 million | $2,500,000 | 2.50% |
Clients
- HNW Share of Firm Assets
- 53.82%
- Total Client Accounts
- 11,836
- Discretionary Accounts
- 10,843
- Non-Discretionary Accounts
- 993
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection
Regulatory Filings
Additional Brochure: ADV PART 2A APPENDIX 1 WRAP-FEE BROCHURE (2026-03-31)
View Document Text
Item 1: Cover Page
Form ADV Part 2A Appendix 1
Wrap-Fee Program Brochure
Annual Update March 2026
ADVISOR RESOURCE COUNCIL
15110 Dallas Pkwy Ste 500
Dallas, TX 75248
(972) 421-1360
www.advisorresourcecouncil.com
This Wrap-Fee Program Brochure (“Wrap Brochure” or “Brochure”) provides information about the
qualifications and business practices of Advisor Resource Council (“ARC”, “the Firm “, “we”, “us”, “our”)
(“we”, “us”, “our”). If you have any questions about the contents of this Brochure, please contact Angie
Alexander, Chief Compliance Officer (972) 421-1381 or RIACompliance@thearcfirm.com.
Additional information about Advisor Resource Council and employees affiliated with the firm is also
available on the SEC’s website at https://adviserinfo.sec.gov/firm/164109. Registration for the Firm
and/or its employees do not imply approval by any regulator or that a certain level of skill or training has
been obtained.
Other Names Under Which Business is Conducted:
360 Wealth Management, 360 Wealth Partners, 360 Wealth Planners LLC, Abacus Wealth
Builders, AIQ Asset Management, ARK Capital, Ashley Hodge, Azalea Wealth Partners,
Barfield Wealth Management, Benge Financial Group, Bigg Financial, Carroll Wealth
Management, CSB Wealth Management, Dallas Financial Planner, Don Hubbard Investment
Services, Encore Wealth Management, Foundation Wealth Partners, Frontline Advisor Group,
Generations Financial Management, Jackson Wealth Management, Lemoine Wealth
Management, Lightforce Financial, McLemore Financial Group, Napa Valley Financial, Parsons
Wealth Management, Ridgemark Financial, RLBrown Financial, Royal Stone Wealth
Management, Simmons Wealth Management, The Texas Money Manager,
Valtrum, Values First Planning, and VTI Financial
Firm Contact: Angie Alexander, 972-421-1381
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
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Item 2: Material Changes
Material Changes Since the Last Annual Update
Since our last annual amendment filing, dated March 14, 2025, Advisor Resource Council (“ARC”,
“the Firm “, “we”, “us”, “our”) has no material changes to report. The information in this Brochure has
not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by
any state securities authority.
Full Brochure Available
Any updated version of this Brochure may be requested at any time, without charge, by contacting
Angie Alexander, Chief Compliance Officer at (972) 421-1381 or via email at
RIACompliance@thearcfirm.com.
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
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Item 3: Table of Contents
Item 1: Cover Page
1
Item 2: Material Changes
2
Item 3: Table of Contents
3
Item 4: Services, Fees and Compensation
4
Item 5: Account Requirements and Types of Clients
8
Item 6: Portfolio Manager Selection and Evaluation
8
Item 7: Client Information Provided to Portfolio Managers
9
Item 8: Client Contact with Portfolio Managers
16
Item 9: Additional Information
16
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
3
Item 4: Services, Fees and Compensation
Advisor Resource Council (the “Firm,” “ARC,” “we,” “us,” or “our”) is an SEC-Registered Investment
Advisor “RIA” under the Investment Advisers Act of 1940. It is important to note that registration for
the Firm and/or its employees does not imply approval by any regulator or that a certain level of skill
or training has been attained.
This Wrap Fee Program Brochure provides more information about our Wrap Fee Program. More
detailed information about our other types of investment advisory and consulting services we
provide may be found in our Form ADV Part 2 Brochure, which may be requested at any time,
without charge, by contacting Angie Alexander, Chief Compliance Officer at (972) 421-1381 or via email
at RIACompliance@thearcfirm.com.
Portfolio Management Services
Our wrap fee program is an investment advisory program that “wraps” or “bundles” services
together. Participation in a wrap fee program may be appropriate for clients who desire the
benefit of an ongoing advisory relationship, are interested in discretionary asset management,
intend to actively engage in buy and sell investment strategies (whether discretionary or
nondiscretionary) or who do not intend to maintain substantial positions in cash or cash
equivalents. This section of the Brochure describes the general structure and operation of our
program.
Wrap Accounts and Portfolio Managers
As part of our wrap fee program, we create individual accounts, called “wrap accounts,” which
are individually managed investment portfolios that may consist of individual stocks or bonds,
mutual funds, exchange traded funds (“ETFs”), options, unit investment trusts, alternative
investments and other public or private securities or investments.
Usually, wrap accounts are managed by our individual investment advisor representatives, or
“IARs,” who act as discretionary portfolio managers. Alternatively, clients may elect to manage
the assets held in their wrap account or impose reasonable limits on the discretion exercised by
their advisor.
More information about the services provided by IARs under our wrap fee program may be
found below in Item 6. Specific information about each IAR who is providing advisory services
through our wrap fee program may be obtained in the Brochure Supplement for the IAR, Form
ADV Part 2B, which will be provided before or at the time of engagement. Each IAR has
different licenses and training and has attained different educational levels. Clients should
carefully review the applicable Brochure Supplement before an IAR is engaged.
Custody
We do not hold or custody client securities and other funds. When we establish a wrap account,
we ordinarily designate a qualified custodian to custody the securities and other property held in
the account, or our clients may instead designate another custodian that is acceptable to us.
Program Services
At the onset of each relationship, the client and the client’s IAR agree upon the services that we
will provide, which may include some or all of the following:
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
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Access to a designated IAR, who will oversee the wrap account;
Determining the client’s particular investment strategy and investment goals, based on a
client profile and other information we obtain when the wrap account is first established;
Determining any restrictions or limits that will be placed on the management of the wrap
account; while we attempt to accommodate each client, the restrictions and limits must
be reasonable and not unduly burdensome;
Access to discretionary portfolio management, including portfolio monitoring and
rebalancing, provided at the frequency we agree upon with each client;
Periodic performance reviews, annually or at more frequent intervals, as requested by
our client;
Custody of assets;
Execution of transactions; and
Delivery of required documents, such as mutual fund prospectuses.
Fees
Each client will pay an asset-based fee, calculated as either a percentage of assets or a flat fee
based on the size of assets under management. Our maximum asset-based fees are negotiable
under appropriate circumstances. When we negotiate fees, we may consider factors such as the
fees that our client has paid to a competitor for similar services, the totality of our relationship
with the client, the potential for future business, the complexity of the client’s investment
strategy, and the degree to which we provide discretionary asset management.
Our maximum asset-based fees are below; more information about our billing procedures and
practices may be found in our Form ADV Part 2A Brochure, Item 5, “Fees and Compensation,”
in the Section titled “Calculation and Payment of Fees.”
TRADITIONAL ASSET MANAGEMENT
PERCENTAGE OF ASSETS UNDER MANAGEMENT*
Assets Under Management Maximum Annual Fee
$0 to $499,999
$500,000 to $999,999
$1,000,000 to $1,999,999
$2,000,000 to $4,999,999
Over $5,000,000
2.25%
2.25%
2.25%
2.25%
2.25%
*Fees are prorated and billed quarterly in advance, based on the value of each client’s account on the last day
of the previous quarter.
FLAT ANNUAL FEE*
Assets Under Management
$0 to $499,999
$500,000 to $999,999
$1,000,000 to $1,999,999
$2,000,000 to $4,999,999
Over $5,000,000
Maximum Annual Fee
$11,500
$22,000
$42,000
$100,000
Max of $100,000 for each $5,000,000 increment
*Flat fees are billed in arrears, quarterly, semi-annually or annually.
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
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These fees are negotiable under appropriate circumstances. When we negotiate fees, we may consider
factors such as the fees that our client has paid to a competitor for similar services, the totality of our
relationship with the client, the potential for future business, the complexity of the client’s investment
strategy, and the degree to which we provide discretionary asset management. The annual fee rate is
subject to change based on the client’s asset levels and any associated risks. This includes scenarios
where a client’s fee rate, as a percentage of assets under management, may substantially increase if
their assets decrease. The Firm will calculate the flat fee as a fixed dollar amount, which, when divided by
a lower asset base, results in a higher percentage fee.
Asset-based fees are deducted from each client’s wrap account and directly remitted to us. When a
wrap account is established, each client determines the method for calculating the wrap fee,
authorizes the deduction of fees from the account, and directs the custodian to deduct and remit
fees to us. Each client receives a quarterly statement from the custodian that reflects all amounts
disbursed from the account, including the amount of our fee.
Comparing Fee Arrangements
Before deciding to participate in our wrap fee program, clients should evaluate our fees and
expenses. The same or similar services may be available from other advisors for a lower fee. Fees
associated with our wrap fee program may be more or less costly than the fees charged separately
for each service provided through our wrap fee program, such as fees for investment advice and
costs associated with trading activity. Clients should consider the need for ongoing investment
advice, the number of transactions that are likely to be executed, whether buy and hold investment
strategies will be used, the need to hold cash balances and similar factors before deciding to
participate in our wrap fee program.
When deciding between our fee arrangements, clients should consider the following:
Clients who elect an asset-based conventional wrap and pay a conventional wrap fee, with
no transaction- based charges, should understand that the wrap account’s transaction
charges will be allocated to the client’s IAR. While these charges may be less than
conventional brokerage costs, they may be a factor when an advisor decides which securities
or mutual funds to purchase or sell and whether to place transactions for the account. Clients
should also consider that these conflicts may have an impact on the investment performance
of their account.
Clients who elect a traditional asset-based management account and incur transaction-based
charges (but do not pay a wrap fee) should consider the number of transactions that are
anticipated. More information about the Firm’s relationship with the approved custodian may
be found below in Item 9.
Additional Costs and Expenses
All clients who participate in our wrap fee program, should expect to pay additional expenses
charged by third parties, including the following:
Clients remain responsible for custodial and similar fees and costs customarily associated with the
maintenance of a brokerage account.
Clients will be charged internal expenses associated with investment products such as
mutual funds and ETFs, including investment management and 12b-1 fees. These internal
expenses are typically calculated as a percentage of the fund’s assets under management.
Some of these fees are retained by the product issuers, and some are paid to third parties for
services such as the maintenance of shareholder accounts and the distribution of
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
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prospectuses and similar items. More information about specific expenses charged by a fund
or ETF may be found in the applicable prospectus. Because these expenses are directly
deducted from a fund’s assets, they have the effect of reducing the performance of the
investment.
Products, primarily mutual funds, may have multiple share classes, each class with a
different fee and compensation structure, which may include deferred sales charges.
Charges for internal expenses may also differ among share classes, including investment
management fees and 12b-1 fees. Mutual fund shares acquired in a wrap account may be
subject to these fees and expenses, and we may acquire shares in a class other than those
designated specifically for advisory or institutional accounts. Clients should not assume that
the share class with the lowest fees and costs will be acquired.
Other types of charges and expenses may be incurred under our wrap fee program, including
mark-ups and mark-downs, odd-lot differentials, spreads paid to market makers from whom
securities were are obtained, transfer taxes, wire transfer and electronic fund fees, and other
fees and taxes on brokerage and securities transactions.
Transaction Charges
The Firm pays the custodians (Schwab and LPL) transaction costs for each executed trade in Wrap
Fee accounts. As a result, we have a financial incentive to limit orders for Wrap Fee accounts
because trades increase our transaction costs. Thus, an incentive exists to trade less frequently in a
Wrap Fee program.
Mutual Fund Share Classes
As explained above, mutual funds generally offer multiple share classes, with each class subject to
certain eligibility or purchase requirements (such as minimum investment or participation in an
investment advisory program) and different expense ratios and costs. In some circumstances, our
advisors may receive additional compensation from a mutual fund based on the share class that is
acquired. When designating a share class for purchase, our advisors typically evaluate factors such
as the amount of any asset-based advisory fee that is paid by a client or account, whether the
purchase or sale of the fund is subject to transaction charges, and operational considerations
related to a fund or share class (such as access to a particular class through a custodian).
The Firm has taken further steps to minimize this conflict by providing IARs with guidance and by
conducting periodic reviews of client accounts to ensure the appropriateness of share class
holdings. Regardless of these actions, our clients should not assume that the share class with the
lowest expense ratio or charges will be acquired.
Compensation Paid to our Investment Advisor Representatives
Our IARs receive a portion of the wrap fee that is paid to the Firm, either directly as a percentage of
the fee or indirectly in the form of salary paid by the Firm. If an IAR is directly paid a percentage of
the wrap fee, the advisor may earn more compensation through the wrap fee program than would be
paid in another type of advisory arrangement, and clients may pay more under our wrap fee
program than would be charged separately for advice and transactions. Clients should be aware that
the potential for increased compensation may create an incentive to recommend the wrap-fee
program over other types of transaction-based accounts.
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
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Item 5: Account Requirements and Types of Clients
The following types of clients may participate in our wrap fee program:
Individuals, including high net worth individuals;
•
• Retirement plans, such as 401(k), pension and profit-sharing plans;
• Charitable organizations; and
• Business enterprises, including corporations, limited liability companies, and partnerships.
We do not impose minimum requirements for participating in our program.
Item 6: Portfolio Manager Selection and Evaluation
Third Party Managers
The Firm does not use third party portfolio managers in connection with our wrap fee program. All
discretionary wrap accounts are managed by one of our investment advisor representatives, who is
designated by the client when a wrap account is established. Clients may also elect to establish
nondiscretionary wrap accounts (meaning that our IAR will oversee the wrap account and act as
instructed by the client).
Investment Advisor Representatives
The Firm does not select or otherwise limit the IARs who may participate in our wrap fee program.
Each advisor has an individual asset management philosophy and strategy. Each advisor
possesses the discretion to negotiate fees. Clients should be aware that our advisors have
completed different levels of education and have acquired different designations and licenses. More
information about each IAR may be found in the Brochure Supplement for the IAR, Form ADV Part
2B, which will be provided by the IAR before or at the time the IAR is engaged.
Clients may change a previously selected IAR or obtain information about additional advisors by
contacting the Firm at (972) 421-1360 or by e-mail at RIACompliance@thearcfirm.com. We will
provide a list of advisors based on client preferences such as location, education and licensure, and
the ability of each advisor to accept new business.
Separately Managed Accounts
We manage individual investment portfolios, which may consist of individual stocks or bonds, exchange
traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. Each
client’s portfolio is invested using an individual investment strategy that addresses specific goals and
objectives and may include some or all of the previously mentioned securities. Once the appropriate
portfolio has been determined, we review the portfolio at least annually and, as necessary, we rebalance
the portfolio based upon the client’s needs and stated goals and objectives. Our advisors may exercise
discretion over the investment of the portfolio, the portfolio may be subject to the discretion of a third-party
investment manager or a portfolio may be maintained on a nondiscretionary basis. Information about the
fees we receive for our investment advisory services is included in Item 5.
If appropriate, AIQ Asset Management offers actively managed investment strategies as separately
managed accounts primarily via model portfolios (AIQ Advanced, AIQ Focused, AIQ Essentials, and
AIQ Foundations), but also through custom solutions, including advanced option trading strategies
for certain high wealth clients. Each of the strategies outlined below are managed by one or more of
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
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our advisors.
AIQ Advanced, Focused, and SMA Strategies: AIQ Asset Management offers a diverse
set of strategies designed to meet the investment objectives of a wide range of clients. The
strategies are offered within separately managed accounts (i.e., not within a mutual fund or
ETF) on a stand-alone basis or in combination with one another via its Advanced ($1 million
and above in invested assets) or Focused ($200,000 - $1 million in invested assets) models.
Benchmarks for individual strategies are based on the specific asset class while model
portfolio benchmarks are a blend of the individual strategies based on the risk objective of the
strategy (capital preservation, conservative, moderate, growth, aggressive growth). Asset
allocation decisions (for the models) as well as individual security selection for all portfolios
are based on a combination of artificial intelligence tools and traditional fundamental analysis
performed by the team’s highly experienced investment professionals.
Model portfolios are generally invested in a combination of individual stocks, bonds, mutual
funds, ETFs, structured products, and may use options and other custodian approved
alternative securities to reduce risk. Individual accounts assigned to a specific model will
generally be invested in the same manner, but holdings within each account may vary in
terms of both individual securities and the relative weightings of those holdings based on the
size and risk profile of the account, client specific tax situations, the timing of specific
investments, and other factors. A minimum investment of $200,000 is required to establish a
model portfolio, although in some circumstances the minimum may be lower. Minimums for
custom strategies vary depending on the specific strategy.
AIQ Essentials: The AIQ Essentials models consist of a series of actively managed model
portfolios invested in mutual funds or Exchange Traded Funds (ETFs). Each model is tuned
to a specific risk tolerance, from capital preservation to aggressive growth, while providing
diversified exposure to different asset classes, potentially including, but not limited to, fixed
income, equity, hedged equity, alternatives, international securities, and commodities. The
model portfolios are generally invested in similar mutual funds or ETFs; however, the
weightings of each investment vary according to the model’s specific risk tolerance. Asset
allocation decisions are made using a combination of artificial intelligence tools and
traditional fundamental analysis performed by the team’s highly experienced investment
professionals. The investment team may also evaluate criteria such as assets under
management, performance relative to peers, consistency, standard deviation,
upside/downside capture, beta, and scenarios analyses utilizing Bloomberg Multi-asset risk
testing model, as well as conversations with managers when considering potential funds for
investment. A minimum investment of $25,000 is required to establish a model portfolio,
although in some circumstances the minimum may be lower.
AIQ Foundations: The AIQ Foundations models are specifically designed for smaller accounts
and consist of a series of separate actively managed model portfolios primarily invested in mutual
funds but could also include Exchange Traded Funds (ETFs). Each model is tuned to a specific
risk tolerance, from capital preservation to aggressive growth, while providing diversified exposure
to different asset classes, including, but not limited to, fixed income, equity, hedged equity,
alternatives, international securities, and commodities. The model portfolios are generally invested
in similar mutual funds or ETFs; however, the weightings of each investment vary according to the
model’s specific risk tolerance. Asset allocation decisions are made using a combination of
artificial intelligence tools and traditional fundamental analysis performed by the team’s highly
experienced investment professionals. The investment team may also evaluate criteria such as
assets under management, performance relative to peers, consistency, standard deviation,
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
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upside/downside capture, beta, and scenarios analyses utilizing Bloomberg Multi-asset risk
testing model, as well as conversations with managers when considering potential funds for
investment. Relative to other models offered by AIQ, Foundations models tend to have fewer
securities so that they can accommodate accounts as small as $500. The minimum investment
size is taken into consideration when selecting holdings, which could mean fewer funds than the
standard model for smaller accounts.
Advisory Business
This section of the Brochure is intended to provide more information about our advisory services,
including the investment analysis and strategies commonly used by our individual advisor
representatives. The following information is general; clients should consult their individual advisor
for a complete understanding of the advisor’s particular investment strategy and the risks associated
with the strategy.
Other Advisory Services
In addition to the wrap fee program described in this Brochure, we offer the following types of
advisory services:
Asset management on a discretionary basis;
Asset management on a nondiscretionary basis;
Financial planning and consulting;
Direct-at-Fund account consultation and management;
Retirement plan consulting; and
Referrals to third-party money managers.
More detailed information about each of these advisory services may be found in our Form ADV,
Part 2 Brochure, which can be obtained by contacting us by telephone at (972) 421-1360 or by e-
mail at RIACompliance@thearcfirm.com.
Our advisory services, including our wrap fee program, do not involve the sale of insurance, financial
planning, legal or accounting advice, although some of our IARs are licensed to sell insurance and
may recommend the purchase of insurance.
Individual Advice; Restrictions on Investing
All of our advice is based upon a client’s individual needs, which we identify at the onset of each
relationship using, as appropriate, client questionnaires and profiles, a review of existing
investments and financial status, and other means. We review each client’s investment profile at
least as frequently as annually and modify our advice as appropriate.
When we provide advisory services, we construct individual investment portfolios that may consist of
individual stocks or bonds, mutual funds, ETFs, options, unit investment trusts, alternative
investments and other public and private securities or investments. Portfolios are based upon
information we receive from each client and the investment philosophy of each IAR. The
considerations and process used by an IAR are substantially the same whether or not the client is
participating in our wrap fee program.
In our wrap fee program and all of our advisory accounts, each client may impose limits and
restrictions on the types of investments that are acquired or held in the account. These restrictions
must be reasonable and practicable and permit us to manage the account without undue difficulty.
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
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Performance-Based Fees and Side-by-Side Management
“Performance-based fees” are fees based on the capital gains or capital appreciation in an account.
We do not charge performance-based fees. “Side-by-side management” refers to the practice of
managing both accounts that are charged a performance-based fee and accounts that are charged
other types of fees, such as asset-based fees and hourly fees. Because we do not charge
performance-based fees, we do not engage in side-by-side management.
Methods of Analysis, Investment Strategies and Risk of Loss
As explained above, wrap accounts that are subject to our discretion will be managed by an IAR
who uses methods of analysis and investment strategies that may be the same as or different from
the analysis and strategies used by other advisors. Before selecting an advisor, each client should
obtain specific information about the investment analysis and strategies used by a particular advisor
and consider the risk of loss associated with the advisor’s strategies. Below is general information
about the analysis and strategies that may be used by our advisors and the risk of loss associated
with various types of investments.
Methods of Analysis
Our IARs may use all or any of the following methods of analysis to evaluate securities and other
investment products.
Charting: Charting refers to a review of charts of market and security activity in an attempt to
identify when the market may be moving up or down, to predict when or how long the trend may last,
and to estimate when that trend might reverse.
Fundamental Analysis: Fundamental analysis is used 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 security is
underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell).
Fundamental analysis does not attempt to anticipate market movements, which may present a
potential risk since the price of a security may move up or down with the overall market regardless
of the economic and financial factors considered in evaluating the stock.
Technical Analysis: Technical analysis involves the study of past market movements and is
intended to recognize recurring patterns of investor behavior and to predict future price movement.
Technical analysis does not consider the intrinsic value of a security, which may present a risk since
a poorly managed or financially unsound company may underperform regardless of market
movement.
Cyclical Analysis: Cyclical analysis is used to measure the movement of a particular stock against
the overall market in an attempt to predict the price movement of the security.
Investment Strategies
Our advisors may use any or all of the following strategies to manage wrap accounts, provided that
the strategies are appropriate to the needs of the client and consistent with the client's investment
objectives, risk tolerance, time horizons, investment restrictions, and other considerations.
Long-Term and Short-Term Purchases: An advisor may purchase securities to hold for a
relatively long time (typically for more than one year). Risks associated with a long-term purchase
strategy include loss of short-term gains that could be profitable to a client or that a security may
decline sharply in value before we make the decision to sell. An advisor may also purchase
securities with the idea of selling them within a relatively short time (typically one year or less),
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
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attempting to take advantage of conditions that may soon result in a price swing.
Margin Transactions: We may purchase stocks with money borrowed from a brokerage account. This
may allow the purchase of more stock than could be purchased with available cash and the purchase of
stock without the liquidation of other holdings. Margin transactions include a risk that any loss will be
magnified or that margin calls will occur if the securities pledged to collateralize the loans decline in value.
Option Writing: We may use options as an investment strategy. An option is a contract that provides the
right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or
before a certain date (this is when you own the option “long”). An option, just like a stock or bond, is a
security. An option is also considered a derivative because it derives its value from the underlying stock or
other asset. Options can be used to speculate, which is a relatively risky practice, can be used as a
replacement security owning the option rather than the stock (stock replacement), or they can be used to
hedge to reduce the risk of holding an asset. In terms of speculation, option buyers and writers have
conflicting views regarding the performance of:
Call Option: A “call” is the right to buy an asset at a certain price within a specific period of time,
so the call buyer would want the stock, index, or underlying security to go up. Conversely, an
option seller would need to provide the underlying shares in the event the option gets exercised by
the holder which can happen when the security’s market price exceeds the strike price, when an
expected dividend payment exceeds the extrinsic value of the option, or other unique
circumstances. An option seller who sells a call will do so for a variety of reasons: to generate
income, to profit from a near-term consolidation in the stock where seller believes that the
underlying stock’s price will stay flat (below strike price) or drop in value during the life of the
option, as that is how he will profit. That is the opposite outlook of the option buyer. The buyer
believes that the underlying stock will rise, if this happens, the buyer will be able to acquire the
stock for a lower price and then sell it for a profit. However, if the underlying stock does not close
above the strike price on the expiration date, the option buyer would lose the premium paid for the
call option.
Put Option: A “put” option is the right to sell an asset at a certain price within a specific period of
time, so the buyer would want the stock to go down. The opposite is true for put option writers. For
example, a put option buyer believes the underlying stock will fall or at risk of falling below the
specified strike price on or before the contract’s specified date. An option writer who sells a put
option believes that the underlying stock’s price will increase or stay above a specified price on or
before the expiration date. If the underlying stock’s price closes above the specified strike price on
or before the expiration date, the put option writer will profit. A put option holder would only benefit
from a fall in the underlying stock’s price below the strike price. If the underlying stock’s price falls
below the strike price, the put option writer is obligated to purchase shares of the underlying stock
at the strike price.
The potential risks associated with these transactions are:
All options expire. The closer the option gets to expiration, the quicker the premium in the option
deteriorates; and
Prices can move very quickly. Depending on factors such as time until expiration and the
relationship of the stock price to the option’s strike price, small movements in a stock can translate
into big movements in the underlying options.
We primarily use options to:
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
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“Hedge" the purchase of an underlying security; “hedging” occurs because the option limits the
potential upside due to the cost of purchase put options but also limits the downside risk of the
security.
Write "covered calls," which are options written on a security owned by an account. Using this
strategy, an account receives a fee for selling an option covering a security that it owns, and the
person purchasing the option has the right to buy the security at a specified price during a
specified period.
Implement a “collar” strategy in which covered calls are written on a security and protective put
options on the same security are purchased. This limits both upside and downside risk of the
singular security.
Implement a "spread strategy," in which two or more option contracts (puts or calls) on the same
security. This is similar to buying a call or a put; however, the benefit is capped by the second
option that creates the spread. In the case of a long call option spread, the buyer would benefit
from the gap between the long call strike price and the sold/written strike price less the option
premium paid to enter the position.
In rare instances for clients with investment objectives of aggressive growth we may purchase
calls or sell puts in an attempt to generate income.
Risk of Loss
All investing involves a risk of loss that clients should be prepared to bear, including the risk that the entire
amount invested may be lost.
Our investment strategies involve active management and could lose money over short or long periods of
time. There are no assurances that our investment strategies will succeed, and we cannot guarantee that
we will achieve the investment objectives established by a client, or that any client will receive a return on
investment. Our investment decisions and recommendations consider both the prospect for return and
the risk of loss. In considering the risk of loss, we contemplate both the probability of loss and the
potential magnitude of any loss. Some of the risks associated with our strategies and analysis are
summarized below.
Risk Associated with Debt Obligations: In addition to the risks generally applicable to an investment in
securities, an investment in debt obligations and instruments may be further subject to some unique risks:
•
If debt obligations are downgraded by ratings agencies, go into default or if management,
legislation or other action reduces the issuer’s ability to pay principal and interest when due, the
value of debt obligations may decline. Because the ability to pay principal and interest when due is
typically less certain for an issuer of lower-rated or unrated obligations (including “junk” or “high
yield” bonds), when compared to an issuer of higher-rated obligations, lower-rated and unrated
obligations are generally more vulnerable to default, ratings downgrades, and liquidity risk.
• Political risk may adversely affect governmental issues, in addition to risks associated with the
economy and similar factors.
• When interest rates increase, the value of interest-bearing investments may decline. This effect is
typically more pronounced for intermediate and long-term obligations and for mortgage and other
asset-backed securities.
• When interest rates decrease, current income may decline.
• Decreases in interest rates may result in the prepayment of debt obligations and may result in
reinvestment at lower rates.
Derivatives Risk: Investments in derivatives involve risks associated with the securities or other assets
underlying the derivatives, as well as risks that are different or greater than the risks affecting the
underlying assets. Risks unassociated with the underlying assets include the inability or unwillingness of
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
13
the counterparty to perform its obligations, inability or delay in selling or closing positions, and difficulties
in valuation.
Foreign Investment Risk: Investments in the securities of foreign issuers may involve risks including
adverse fluctuations in currency exchange rates, political instability, confiscations, taxes or restrictions on
currency exchange, liquidity risk, and reduced legal protection. These risks may be more pronounced for
investments in developing or emerging countries.
Liquidity Risk: Due to a lack of demand or other factors, there may be no market for particular
investments. In that event, sales may not occur, or sales may be made at less than desired prices.
Market and Economic Risk: An account’s value may decline due to changes in general economic and
market conditions. The value of a security may change in response to developments affecting entire
economies, markets or industries, including changes in interest rates, political and legal developments,
and general market volatility.
Risks Affecting Specific Issuers: The value of an equity security or debt obligation may decline in
response to developments affecting the issuer of the security or obligation, even if the overall industry or
economy is unaffected, such as management issues, corporate disruption, political factors adversely
affecting governmental issuers, a decline in revenues or profitability, an increase in costs, or adverse
changes in the issuer’s competitive position.
Smaller Company Risk: Investments in smaller companies may involve additional risks attributable to
limited product lines, limited access to markets and financial resources, greater vulnerability to
competition and changes in markets, lack of management depth, increased volatility in share price, and
possible difficulties in valuing or selling the investments.
ETF Risk: In addition to the investment risks generally applicable to all securities, investment in an
exchange-traded fund, or ETF, may involve unique risks:
• ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent net asset value, or NAV, which is
calculated at least once daily for indexed-based ETFs and more frequently for actively managed
ETFs. Certain market inefficiencies may cause the shares to trade at a premium or discount to
NAV.
• An ETF redeems shares on an aggregate basis (usually 20,000 shares or more). If a liquid
secondary market ceases to exist, shares may not be timely sold (redeemed), or the value of the
shares may decline.
Master Limited Partnerships (MLPs) Risks: MLPs are collective investment vehicles publicly traded on
a national securities exchange. MLPs invest primarily in companies in the energy sector or that are
engaged in natural resource production and mineral refinement. MLPs are subject to the underlying
volatility of these industries and may be adversely affected by changes in supply and demand, regional
instability, currency spreads, and inflation and interest rate fluctuations, among other factors. In addition,
MLPs operate as pass-through tax entities, meaning that investors may be liable for their pro rata share
of the partnership’s items of gain and loss, regardless of the type of account in which the interests are
held.
Real Estate and Real Estate Investment Trusts (REITs) Risks: We may recommend an investment in
one or more real estate investment trusts (“REITs”), the shares of which may be publicly traded or
privately placed. REITs are collective investment vehicles with portfolios comprised primarily of real estate
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
14
and mortgage related holdings. REITs may hold concentrated investments in commercial and/or
residential developments, which inherently subject investors to risk associated with a downturn in the real
estate market. Real estate investments concentrated in particular geographic regions that experience
volatility may experience fluctuations in value. Mortgage related holdings may give rise to additional
concerns related to interest rates, inflation, liquidity and counterparty risk.
Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality
over a wide geographic area, crossing international boundaries, and causing significant economic, social,
and political disruption.
Cybersecurity Risk: A breach in cyber security refers to both intentional and unintentional events that
may cause an account to lose proprietary information, suffer data corruption, or lose operational capacity.
This in turn could cause an account to incur regulatory penalties, reputational damage, and additional
compliance costs associated with corrective measures, and/or financial loss.
Custodial Risk: This risk is the probability that a party to a transaction will be unable or unwilling to fulfill
its contractual obligations either due to technological errors, control failures, malfeasance, or potential
regulatory liabilities.
It is not possible to list all risks associated with each class of securities or assets or each market sector.
Clients should consult their IAR for more information about specific risks that may be associated with the
advisor’s investment strategy.
Proxy Voting
We do not vote proxies on behalf of clients and do not provide guidance on how clients should vote
proxies. Clients retain exclusive responsibility for receiving and voting all proxies and other
shareholder communications for securities held in their accounts.
For clients who engage a third-party money manager or turnkey asset management programs
(“TAMP”), certain managers may offer proxy-voting services as part of their own advisory program.
Any proxy-voting authority, responsibilities, and related policies will be defined in the separate
agreement executed between the client and each third-party manager or TAMP. Clients should
review those documents carefully to understand whether the manager will vote proxies on their
behalf and under what conditions.
Clients may contact the applicable third-party manager or TAMP directly for information regarding
their proxy-voting policies and procedures, including how a particular proxy was voted. Because our
firm does not assume proxy-voting authority, we do not maintain proxy-voting records.
Item 7: Client Information Provided to Portfolio Managers
Each client’s financial history and personal information, such Social Security numbers, identify
verification information, and account numbers, are obtained and used as necessary to manage and
administer the wrap account. This information is held by the Firm and communicated to third parties,
such as a custodian or broker/dealer, only as necessary to administer the account. Non- public
information will not be disclosed to any third party, unless required by law or to provide services that
have been requested or are necessary for the administration of the account.
A client may update information at any time by contacting the IAR for the wrap account. At least as
frequently as annually, the IAR will offer to meet with each client, whether in person or via
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
15
telephone, to update personal information, to review the wrap account, and to determine if the
management of the account remains suitable for the client’s current financial situation. If a client’s
financial situation or investment goals or objectives change, the client should promptly notify the
advisor.
Item 8: Client Contact with Portfolio Managers
As explained above, our wrap fee program does not involve third-party portfolio managers. Clients
are encouraged to contact the IAR assigned to the wrap account at any time, without restriction.
Item 9: Additional Information
We are required to disclose all pertinent facts regarding any legal, regulatory or disciplinary events
that would be material to your evaluation of the Firm or the integrity of our management.
In 2024, we settled an enforcement action by the Securities and Exchange
Commission, Division of Enforcement (the “SEC”) arising out of a since
terminated` Investment Advisor Representative’s cherry picking, which occurred
in 2020 and without the firm’s knowledge. As part of the settlement, we
consented to the entry of a final judgment, without admitting or denying the
allegations of the SEC’s complaint. The court’s final judgment dated February 16,
2024 ordered: (i) that the firm is permanently restrained and enjoined from
violating Section 17(a)(2) of the Securities Act of 1933; (ii) the firm is permanently
restrained from violating Sections 204(a) and 206(2)&(4) of the Investment
Advisers Act of 1940 and its implementing rules; and (iii) the firm is to pay a civil
penalty of $300,000 to the SEC. Additionally, the court’s final judgment ordered
the firm to retain an outside compliance consultant to review the firm’s policies
and procedures, as well as its customer disclosures.
ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
16
Additional Brochure: FORM ADV PART 2A (2026-03-31)
View Document Text
Item 1: Cover Page
Form ADV Part 2A
Investment Advisor Brochure
Annual Update March 2026
ADVISOR RESOURCE COUNCIL
15110 Dallas Pkwy Ste 500
Dallas, TX 75248
(972) 421-1360
www.advisorresourcecouncil.com
This Brochure provides information about the qualifications and business practices of Advisor Resource
Council. If you have any questions about the contents of this Brochure, please contact Angie Alexander,
Chief Compliance Officer at (972) 421-1381 or RIACompliance@thearcfirm.com. The information in this
Brochure has not been approved or verified by the United States Securities and Exchange Commission
(“SEC”) or by any state securities authority.
Additional information about Advisor Resource Council and employees affiliated with the firm is also
available on the SEC’s website at https://adviserinfo.sec.gov/firm/164109.
Other Names Under Which Business is Conducted:
360 Wealth Management, 360 Wealth Partners, 360 Wealth Planners LLC, Abacus Wealth
Builders, AIQ Asset Management, ARK Capital, Ashley Hodge, Azalea Wealth Partners,
Barfield Wealth Management, Benge Financial Group, Bigg Financial, Carroll Wealth
Management, CSB Wealth Management, Dallas Financial Planner, Don Hubbard Investment
Services, Encore Wealth Management, Foundation Wealth Partners, Frontline Advisor Group,
Generations Financial Management, Jackson Wealth Management, Lemoine Wealth
Management, Lightforce Financial, McLemore Financial Group, Napa Valley Financial, Parsons
Wealth Management, Ridgemark Financial, RLBrown Financial, Royal Stone Wealth
Management, Simmons Wealth Management, The Texas Money Manager,
Valtrum, Values First Planning, and VTI Financial
Firm Contact: Angie Alexander, 972-421-1381
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
Item 2: Summary of Material Changes
Material Changes Since the Last Annual Update
Since our last annual amendment filing, dated March 14, 2025, Advisor Resource Council (“ARC”,
“the Firm “, “we”, “us”, “our”) has no material changes to report.
Annual Update
Each year you will receive a summary of any material changes to our Form ADV Brochure within
120 days of our fiscal year end. We may also provide updated disclosure information about material
changes on a more frequent basis. Any summaries of changes will include the date of the last
annual update of the Brochure. The Supplement to our Form ADV Brochure (Form ADV Part 2B)
provides you with information regarding our employees who are registered as Investment Adviser
Representatives.
We encourage you to review this Brochure and the Brochure Supplement(s) to learn more
information on the qualifications of the Firm and our employees who advise our clients, we
encourage you to review this Brochure and the Brochure Supplement(s).
Full Brochure Available
Any updated version of the Firm’s Form ADV Brochure may be requested at any time, without
charge, by contacting Angie Alexander, Chief Compliance Officer at (972) 421-1381 or via email at
RIACompliance@thearcfirm.com.
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
Item 3: Table of Contents
Item 1: Cover Page
1
Item 2: Summary of Material Changes
2
Item 3: Table of Contents
3
Item 4: Advisory Business
4
Item 5: Fees and Compensation
12
Item 6: Performance-Based Fees and Side-by-Side Management
18
Item 7: Types of Clients
19
Item 8: Methods of Analysis, Investment Strategies, Risk of Loss
19
Item 9: Disciplinary Information
23
Item 10: Other Financial Industry Activities and Affiliations
24
Item 11: Code of Ethics, Participation or Interest in Client Transactions, Personal Trading
25
Item 12: Brokerage Practices
26
Item 13: Review of Accounts and Plans
29
Item 14: Client Referrals and Other Compensation
29
Item 15: Custody
31
Item 16: Investment Discretion
32
Item 17: Voting Client Securities
32
Item 18: Financial Information
32
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Item 4: Advisory Business
Information about the Firm
Advisor Resource Council (the “Firm,” “ARC,” “we,” “us,” or “our”) is an SEC-Registered Investment
Advisor “RIA” under the Investment Advisers Act of 1940. It is important to note that registration for
the Firm and/or its employees does not imply approval by any regulator or that a certain level of skill
or training has been attained.
The Firm is a Limited Liability Company formed in the State of Texas. We have been a federally
registered investment advisor since 2012.
As explained more fully in this Brochure, we provide retail and institutional clients with asset
management services, financial planning and consulting, retirement plan consulting, and referrals to
third-party money managers. We are dedicated to providing individuals, including families, high net
worth individuals, retirement plans, and business enterprises, with a wide array of investment
advisory services.
We provide our services through Investment Advisor Representatives (“IARs” or “advisors”). More
information about each advisor may be obtained in the Form ADV Part 2B Brochure Supplement for
the IAR, which is provided by the IAR before or at the time of client engagement. IARs are required
to obtain training and licenses to sell certain investments and services. Clients should carefully
review the IAR’s 2B Brochure Supplement prior to engagement to assess the investments and
services the IAR is licensed or qualified to sell, as well as any conflicts of interest that may exist.
In some circumstances, investment advisory services may be provided by third-party money
managers. These relationships are summarized below in this Item 4. Additional information about
any third party providing advisory services may be obtained by requesting a brochure and related
supplements directly from the third-party money manager.
Fiduciary Statement
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice regarding your retirement plan account or individual retirement account, we are also
fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”),
and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement
accounts.
Under the Investment Advisers Act of 1940, we are required to act in your best interest and not put
our interest ahead of yours. At the same time, the way we make money may create some conflicts
with your interests. We must disclose any potential conflicts an IAR may have. We take into
consideration each client’s objectives and act in the best interests of the client. We are prohibited
from engaging in any activity that is in conflict with the interests of the client without full disclosure.
We have the following responsibilities when working with a client:
▪ To render impartial advice;
▪ To make appropriate recommendations based on the client’s needs, financial circumstances,
and investment objectives;
▪ To exercise a high degree of care and diligence to ensure that information is presented in an
accurate manner and not in a way to mislead;
▪ To have a reasonable basis, information, and understanding of the facts in order to provide
appropriate recommendations and representations;
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
▪ Disclose any material conflict of interest in writing; and
▪ Treat clients fairly and equitably.
▪ Regulations prohibit us from:
▪ Employing any device, scheme, or artifice to defraud a client;
▪ Making any untrue statement to a client or omit any statement of a material fact when
communicating with a client;
▪ Engaging in any act, practice, or manner of business which operates or would operate as
fraud or deceit upon a client; or
▪ Engaging in any manipulative act or practice with a client.
We are dedicated to acting with competence, dignity, integrity, and in an ethical manner, when
working with clients. We will use reasonable care and exercise independent professional judgement
when conducting investment analyses, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Advisory Services
We provide asset management services, financial planning and consulting, retirement plan
consulting, and/or referrals to third-party money managers, including referrals to LPL Financial, LLC,
referred to as “LPL.” Our services may be provided on a discretionary basis, meaning that we, or a
third-party manager, have been granted with the discretion to buy and sell individual stocks, bonds,
and other investments. Our services may also be nondiscretionary, meaning that our client retains
the authority to make buy and sell decisions. The asset management services we offer are
summarily described below.
AIQ Asset Management
We manage individual investment portfolios, which may consist of individual stocks or bonds,
exchange traded funds (“ETFs”), options, mutual funds, and other public and private securities or
investments. Each client’s portfolio is invested using an individual investment strategy that
addresses specific goals and objectives and may include some or all of the previously mentioned
securities. Once the portfolio has been determined, we review the portfolio at least annually, and
more frequently as necessary depending on market circumstances and/or changes to a client’s
financial situation. We rebalance the portfolio as needed to maintain asset ratios established by the
client’s stated goals and objectives. Our advisors may exercise discretion over the investments of
the portfolio, and the portfolio may be subject to the discretion of a third-party investment manager.
Client portfolios may also be maintained on a nondiscretionary basis. Information about the fees we
receive for our investment advisory services is included in Item 5.
If appropriate, AIQ Asset Management offers actively managed investment strategies as separately
managed accounts primarily via model portfolios (AIQ Advanced, AIQ Focused, AIQ Essentials, and
AIQ Foundations), but also through custom solutions, including advanced option trading strategies
for certain high wealth clients. Each of the strategies outlined below are managed by one or more of
our advisors.
AIQ Advanced, Focused, and SMA Strategies: AIQ Asset Management offers a diverse
set of strategies designed to meet the investment objectives of a wide range of clients. The
strategies are offered within separately managed accounts (i.e., not within a mutual fund or
ETF) on a stand-alone basis or in combination with one another via its Advanced ($1 million
and above in invested assets) or Focused ($200,000 - $1 million in invested assets) models.
Benchmarks for individual strategies are based on the specific asset class while model
portfolio benchmarks are a blend of the individual strategies based on the risk objective of the
strategy (capital preservation, conservative, moderate, growth, aggressive growth). Asset
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
allocation decisions (for the models) as well as individual security selection for all portfolios
are based on a combination of artificial intelligence tools and traditional fundamental analysis
performed by the team’s highly experienced investment professionals.
Model portfolios are generally invested in a combination of individual stocks, bonds, mutual
funds, ETFs, structured products, and may use options and other custodian approved
alternative securities to reduce risk. Individual accounts assigned to a specific model will
generally be invested in the same manner, but holdings within each account may vary in
terms of both individual securities and the relative weightings of those holdings based on the
size and risk profile of the account, client specific tax situations, the timing of specific
investments, and other factors. A minimum investment of $200,000 is required to establish a
model portfolio, although in some circumstances the minimum may be lower. Minimums for
custom strategies vary depending on the specific strategy.
AIQ Essentials: The AIQ Essentials models consist of a series of actively managed model
portfolios invested in mutual funds or Exchange Traded Funds (ETFs). Each model is tuned
to a specific risk tolerance, from capital preservation to aggressive growth, while providing
diversified exposure to different asset classes, potentially including, but not limited to, fixed
income, equity, hedged equity, alternatives, international securities, and commodities. The
model portfolios are generally invested in similar mutual funds or ETFs; however, the
weightings of each investment vary according to the model’s specific risk tolerance. Asset
allocation decisions are made using a combination of artificial intelligence tools and
traditional fundamental analysis performed by the team’s highly experienced investment
professionals. The investment team may also evaluate criteria such as assets under
management, performance relative to peers, consistency, standard deviation,
upside/downside capture, beta, and scenarios analyses utilizing Bloomberg Multi-asset risk
testing model, as well as conversations with managers when considering potential funds for
investment. A minimum investment of $25,000 is required to establish a model portfolio,
although in some circumstances the minimum may be lower.
AIQ Foundations: The AIQ Foundations models are specifically designed for smaller accounts
and consist of a series of separate actively managed model portfolios primarily invested in mutual
funds but could also include Exchange Traded Funds (ETFs). Each model is tuned to a specific
risk tolerance, from capital preservation to aggressive growth, while providing diversified exposure
to different asset classes, including, but not limited to, fixed income, equity, hedged equity,
alternatives, international securities, and commodities. The model portfolios are generally invested
in similar mutual funds or ETFs; however, the weightings of each investment vary according to the
model’s specific risk tolerance. Asset allocation decisions are made using a combination of
artificial intelligence tools and traditional fundamental analysis performed by the team’s highly
experienced investment professionals. The investment team may also evaluate criteria such as
assets under management, performance relative to peers, consistency, standard deviation,
upside/downside capture, beta, and scenarios analyses utilizing Bloomberg Multi-asset risk
testing model, as well as conversations with managers when considering potential funds for
investment. Relative to other models offered by AIQ, Foundations models tend to have fewer
securities so that they can accommodate accounts as small as $500. The minimum investment
size is taken into consideration when selecting holdings, which could mean fewer funds than the
standard model for smaller accounts.
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
Financial Planning and Consulting
We provide a variety of financial planning and consulting services to individuals, families and other
clients based upon an analysis of each client’s current situation, goals, and objectives. Generally,
our financial planning services involve the preparation of a financial plan or a less formal financial
consultation. Our plan or consultation may encompass one or more of the following: investment
planning; retirement planning; estate planning; charitable planning; education planning; corporate
and personal tax planning; cost segregation study; corporate structure; real estate analysis;
mortgage/debt analysis; insurance analysis; lines of credit evaluation; and other business and
personal financial planning. Our written financial plans or consultations usually include general
recommendations for a course of activity and may suggest more specific actions. For example, we
may advise clients to begin or revise investment programs, create or revise wills or trusts, obtain or
revise insurance coverage, commence or alter retirement savings rates or establish education or
charitable giving programs.
▪ For financial planning engagements, we provide our clients with a written summary of their
financial situation, including our observations and recommendations. We may also refer
clients to an accountant, attorney or other specialist, as necessary, for non-advisory services.
▪ For consulting engagements, which are less formal than our planning services, we may
provide our clients with a written summary of our observations and recommendations,
including financial advice about assets or accounts that are not in our custody (or in the
custody of a custodian we have selected). For financial consulting engagements, we have no
obligation to instruct any broker or custodian to take any action in furtherance of any advice
we provide.
We do not provide accounting, legal, tax or similar professional advice and may recommend non-
affiliated professionals for these purposes.
Estate Planning Services
Our Firm does not employ or oversee estate planning attorneys; however, some of our Investment
Adviser Representatives may help coordinate estate planning document preparation services
through professional arrangements with independent attorneys or law firms. The legal services
provided by any such attorney or law firm are entirely separate and independent from the investment
advisory and financial planning services we provide. Each party will require its own engagement
agreement and will maintain its own fee structure for the services it delivers. At our discretion, and
based on a client’s investment management asset level, we may elect to pay a portion of, or the full
amount of, the fee associated with these specific legal services. We do not share common
ownership with, nor do we engage in revenue-sharing or similar compensation arrangements with,
any attorney or law firm to which we may refer clients.
Retirement Plan Consulting
We provide investment consulting services to the sponsors or other fiduciaries of retirement plans,
primarily defined contribution plans with participant-directed investments that are subject to the
provisions of the Employee Retirement Income Security Act of 1974, as amended, or ERISA. As
requested by the sponsor or other fiduciary, our retirement plan consulting services may include:
▪ The development of an investment policy statement, including periodic reviews and
modifications of the statement;
▪ The designation of investment options, including periodic investment reviews and monitoring;
▪ The conduct of investment searches, as appropriate;
▪ The conduct of participant education;
▪ The analysis and benchmarking of fees; and
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
▪ Additional consulting services, such as third-party provider searches, assistance with plan
conversions, and review of plan provisions.
There are some asset classes for which we do not provide retirement plan consulting services,
including participant loans, employer securities, real estate (except real estate acquired through a
publicly traded REIT or similar fund), individual brokerage accounts or “windows,” non-publicly
traded securities and similar property, and hard-to-value or illiquid securities.
We provide retirement plan consulting services as a “3(21) fiduciary” within the meaning of ERISA.
As a 3(21) fiduciary, we monitor the plan’s investment options and provide advice and
recommendations, but the plan sponsor or other designated fiduciary makes all final determinations
about matters affecting the investments offered under the plan. Alternatively, we may provide
retirement plan consulting services as a “3(38) fiduciary” within the meaning of ERISA. In this
capacity, we monitor the plan’s investment options, and we possess the discretion to designate,
substitute or replace investment options, change the investment policy statement to add or remove
asset classes, and take similar discretionary actions.
The Firm may make referrals to and/or work in coordination with a third-party retirement plan
advisor. These arrangements are performed pursuant to separate agreements executed between
the retirement plan advisor and the client.
Referrals to Third-Party Managers
We may refer clients to independent third-party money managers rather than providing ongoing
discretionary portfolio management directly. In these arrangements, we assist clients in identifying an
appropriate third-party manager based on the client’s financial situation, investment objectives, risk
tolerance, time horizon, and any stated investment restrictions. For clients who engage a third-party
manager, we do not provide advice regarding specific securities or implement trades in the account. All
investment advice, portfolio construction, and trading activities are conducted by the selected third-party
manager pursuant to its own advisory agreement with the client.
We periodically review the reports and other information provided by third-party managers to our clients,
no less than annually. We also contact clients from time to time to review their financial circumstances
and objectives, communicate with the third-party managers as appropriate, and assist clients in
evaluating the services being provided.
Clients are responsible for promptly notifying us of any material changes to their financial situation,
investment objectives, or other factors that may affect the management of their accounts. Clients are also
expected to provide similar updates directly to the third-party manager.
Our firm does not vote proxies for client accounts in connection with these advisory services. Certain
third-party asset managers may provide proxy-voting services as part of their own offering. Any
proxy-voting responsibilities, policies, and client acknowledgements will be governed by the separate
agreement executed between the client and each third-party manager.
Portfolio Management Services Through LPL Financial, LLC
Depending on a client’s investment goals and objectives, our advisors may recommend advisory
services using programs sponsored by LPL. The LPL advisory programs currently available to our
clients are outlined below:
▪ Manager Access Select Network (MAN)
▪ Optimum Market Portfolios (OMP)
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
▪ Personal Wealth Portfolios (PWP)
▪ Model Wealth Portfolios (MWP)
▪ Guided Wealth Portfolios (GWP)
These programs are summarized below and general information about the fees we receive from LPL
is below in Item 5. For more detailed information about any LPL advisory program, including
information about the services that are provided, fees, the types of investments that are available in
each program, and potential conflicts of interest, please see the LPL Financial, LLC Form ADV Part
2, including any applicable Wrap Fee Program Brochure and client agreement, which may be
obtained directly from LPL or upon request from an IAR.
Manager Access Select (MAS): MAS is a fee-based LPL advisory program that offers high net
worth investors to access a variety of institutional portfolio managers at lower account
minimums. This access may enable clients to enjoy a broader level of specialization and service
through the ownership of individual securities. A range of portfolio managers and multiple
investment styles including equity, fixed income, balanced, international, ETF, REIT, and socially
responsible portfolios. A minimum of $50,000 is generally required to participate in MAS for
equity securities and $250,000 for fixed income strategies.
Optimum Market Portfolios (OMP): OMPs are managed accounts that provide a diversified
asset allocation program using Optimum Fund shares. We assist our clients in determining the
suitability of OMPs and recommend an asset allocation portfolio that is consistent with their
investment goals and objectives. In these automatically rebalanced portfolios, LPL has the
discretion to purchase and sell Optimum Funds, subject to the mandate of each allocation
portfolio. A minimum account value of $10,000 is required for OMPs, but under certain
circumstances a lower minimum may be acceptable.
Personal Wealth Portfolios (PWP): PWP is an LPL advisory program that offers our clients the
ability to participate in diversified asset allocation portfolios that invest in mutual funds, ETFs,
and investment models provided by third-party managers. We assist our clients to determine the
suitability of PWP based on their specific investment goals and objectives. LPL possesses the
discretion to administer the portfolios, including the authority to purchase and sell mutual funds
and equity and fixed income securities held in the accounts and portfolios. A minimum account
value of $250,000 is required for PWP, although in some circumstances a lower minimum may
be acceptable.
Model Wealth Portfolios (MWP): MWP is an LPL advisory program that offers our clients a
structured asset allocation program based on their stated objectives and risk profile. We work
with our clients to help determine the suitability of the MWP program. We then have the
discretion to select a model portfolio designed by LPL, consistent with our clients’ particular
investment objectives and risk tolerance. The client authorizes LPL to act on a discretionary
basis to purchase and sell mutual funds and ETFs, to liquidate previously purchased securities,
and to rebalance accounts. The minimum required for MWP is $25,000, although in certain
circumstances a lesser amount may be acceptable.
Guided Wealth Portfolios (GWP): GWP is an LPL advisory program that offers our clients the
ability to participate in an algorithm-based investment program using an interactive account
management portal. We assist our clients to determine the suitability of GWP based on their
objectives, risk tolerance, investment horizon and anticipated retirement age. Consistent with the
objective, each client is invested in a model portfolio that has been constructed by LPL.
Recommendations to buy and sell exchange-traded funds and open-end mutual funds are
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generated through the proprietary, automated, computer algorithms of Xulu, Inc., doing business
as FutureAdvisor. LPL possesses the discretion to purchase and sell securities for the portfolio
and rebalance the portfolio’s asset allocation as our client’s investment horizon changes. A
minimum account value of $5,000 is required to enroll in GWP.
A preview of GWP is available for up to 45 days, during which interested clients may determine
whether participation in GWP and the receipt of ongoing advice from LPL and FutureAdvisor
through GWP is appropriate. Users of the GWP preview do not enter into an advisory agreement
with LPL and are not considered clients of LPL, FutureAdvisor or our Firm and they do not
receive ongoing investment advice, supervision of their assets or trading services once the
preview period ends.
Direct-at-Fund Investment Solutions
For certain accounts, our advisors may recommend a “Direct-at-Fund” account solution offered by
Capital Group’s American Funds Service Company (“American Funds”). In these instances, client
assets are invested directly with American Funds rather than a Qualified Custodian, which is
designed to offer a lower-cost alternative. Please see Item 15 for details regarding custody details.
The Direct-At-Fund solutions we offer are described below.
American Funds Direct-at-Fund Advisory Solution
Consistent with our fiduciary duty, American Funds’ Direct-at-Fund advisory assets are invested
F-2 mutual fund shares, which are designed to provide cost efficiencies and diversification for
smaller accounts that may not be achievable through traditional advisory platforms.
The Firm’s use of Direct-at-Fund management is generally limited to advisory accounts with a total
market value under $50,000. The advisor’s selection of this service is based on a thorough cost-
benefit analysis to ensure the fee structure and investment access remain in the client’s best interest
given the account size. Once an account reaches or exceeds the $50,000 threshold—whether
through capital appreciation, additional principal investment, or both—the advisor will reassess the
cost-efficiency use of a Direct-to-Fund program provides and consider transitioning the account
to one of our affiliated custodians that will allow access to broader investment diversification at a
competitive cost structure better suited for larger investment pools.
Capital Group CollegeAmerica Direct-at-Fund 529 Qualified Tuition Savings Solution
Our advisors may recommend Capital Group’s CollegeAmerica 529 Plans that enable direct
investment in 529-F-2 mutual fund shares that are invested directly with American Funds. A 529
tuition savings plan is a flexible, tax-advantaged account for educational savings. Like other 529
plans, any earnings in the funds grow tax-deferred, and withdrawals used for qualified
educational expenses are free from federal taxes, and state tax treatment varies by state.
Individual Advice; Restrictions on Investing
All of our advice is based on an assessment of each client’s individual needs, which we identify at
the onset of each relationship using, as appropriate, client questionnaires and profiles, a review of
existing investments and financial status, and other means. We review each client’s individual
investments and investment profile at least as frequently as annually. When a client’s investment
profile or needs change and we have notice or receive additional information, we modify our advice
as appropriate.
If we manage a client’s portfolio, we may permit a client to impose restrictions on the types of
investments that are acquired or held. These restrictions must be reasonable and practicable and
permit us to manage the account without undue difficulty. If we do not directly manage a client’s
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
portfolio, such as when a third-party manager is designated, individually imposed restrictions on
investments are generally not permitted.
Wrap Fee Program
We offer a wrap fee program as further described in Part 2A, Appendix 1 of our Brochure (the
“Wrap-Fee Program Brochure”). Investment advice for our wrap and non-wrap fee accounts is
provided on an individual basis, based upon each client’s investment objectives, financial goals, risk
tolerance, and similar factors.
The benefits under a wrap fee program depend, in part, upon the size of the account, the costs
associated with managing the account, and the frequency or type of securities transactions
executed in the account.
For example, a wrap fee program may not be suitable for all accounts, including but not limited to
accounts holding primarily, and for any substantial period of time, cash or cash equivalent
investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security
that can be traded without commissions or other transaction fees.
In order to evaluate whether a wrap fee arrangement is appropriate for you, you should compare the
agreed-upon wrap program fee and any other costs associated with participating in our wrap fee
program with the amounts that would be charged by other advisers, broker-dealers, and custodians,
for advisory fees, brokerage and execution costs, and custodial services comparable to those
provided under the wrap fee program. In evaluating the wrap fee program, a client should consider
that, depending upon the level of the wrap fee, the amount of portfolio activity in the client’s account,
and other factors, the wrap fee may or may not exceed the aggregate cost of such services if they
were to be provided separately.
Conflict of Interest
When managing a client's account on a wrap-fee basis, we receive as compensation for our
investment advisory services, the balance of the total wrap fee you pay after custodial, trading, and
other management costs (including execution and transaction fees) have been deducted.
Accordingly, we have a conflict of interest because we have a financial incentive to maximize our
compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to
a wrap fee. Clients are advised to carefully consider the total costs and benefits of the wrap fee
program compared to paying for advisory services, brokerage, and custodial services separately.
The Firm regularly reviews and monitors the performance of client accounts and the
appropriateness of the wrap fee program for their investment needs. However, clients are
encouraged to review their account statements and performance reports to ensure that the wrap fee
program continues to meet their investment objectives.
We do not manage wrap-fee accounts in a different fashion than non-wrap fee accounts. As further
described in our Wrap-Fee Program Brochure, we receive a portion of the wrap fee for our services.
Assets Under Management
As of February 11, 2026, we had approximately $3,486,476,415 in assets under management;
$3,365,655,964 is managed on a discretionary basis and $120,820,451 is managed on a
nondiscretionary basis.
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Item 5: Fees and Compensation
This item describes the fees we charge for our advisory services, including general descriptions of
the fees charged by third-party money managers and how our fees are calculated and paid.
Investment Advisory Services
Fees for Advisory Services
For investment advisory services that we provide, clients pay fees based on assets under our
management, using one of the methods below. The maximum fee schedules are as follows:
WRAP FEE PROGRAM
PERCENTAGE OF ASSETS UNDER MANAGEMENT*
Assets Under Management Maximum Annual Fee
$0 to $499,999
$500,000 to $999,999
$1,000,000 to $1,999,999
$2,000,000 to $4,999,999
Over $5,000,000
2.50%
2.50%
2.50%
2.50%
2.50%
Please note that the Firm’s internal strategies are only available in the Wrap Fee Program.
TRADITIONAL ASSET MANAGEMENT
PERCENTAGE OF ASSETS UNDER MANAGEMENT*
Assets Under Management Maximum Annual Fee
$0 to $499,999
$500,000 to $999,999
$1,000,000 to $1,999,999
$2,000,000 to $4,999,999
Over $5,000,000
2.25%
2.25%
2.25%
2.25%
2.25%
*Fees are billed quarterly in advance, based on the value of each client’s account on the last day of
the previous quarter. More information about how fees are calculated and paid is provided below the
Section “Calculation and Payment of Fees.”
FLAT ANNUAL FEE*
Maximum Annual Fee
Assets Under Management
$0 to $499,999
$500,000 to $999,999
$1,000,000 to $1,999,999
$2,000,000 to $4,999,999
Over $5,000,000
$11,500
$22,000
$42,000
$100,000
Max of $100,000 for each $5,000,000 increment
*Fees are billed in arrears, quarterly, semi-annually or annually. More information about how fees
are calculated and paid is provided below in the Section “Calculation and Payment of Fees.”
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
Our maximum fees (above) are negotiable under appropriate circumstances. When we negotiate
fees, we may consider factors such as the fees that our client has paid to a competitor for similar
services, the totality of our relationship with the client, the potential for future business, the
complexity of the client’s investment strategy, and the degree to which we provide discretionary
asset management. The annual fee rate is subject to change based on the client’s asset levels and
any associated risks. This includes scenarios where a client’s fee rate, as a percentage of assets
under management, may substantially increase if their assets decrease. The Firm will calculate the
flat fee as a fixed dollar amount, which, when divided by a lower asset base, results in a higher
percentage fee.
Financial Planning and Consulting Fees
For financial planning and consulting services, we charge an hourly or flat fee. The total estimated
fee, as well as the actual fee, is based upon the scope and complexity of the engagement. Our
hourly fees range between $100 and $500 based upon the experience of a client’s advisor. Our flat
fees range between $50 and $15,000. Fees are charged in advance.
Retirement Plan Consulting Fees
Fees for retirement plan consulting may be charged using one or more of the following methods:
▪ An hourly fee or fixed fee for a specific transaction or project;
▪ An ongoing fixed fee, charged quarterly or annually;
▪ An ongoing fixed fee for each participant in the plan, charged quarterly or annually; and/or
▪ An ongoing asset-based fee.
Our fees for retirement plan consulting services (both the amount and type) are negotiated, taking
into consideration factors such as the size of the retirement plan, the number of participants in the
plan, whether we serve as a 3(21) or a 3(38) fiduciary, the size of individual accounts maintained in
the plan, fees previously paid by the plan for similar services, total fees paid by the plan, and similar
factors. If we charge an asset- based fee, the fee will not exceed the asset-based fees we charge for
other investment advisory services (described above under the heading “Fees for Advisory
Services”), taking into account other forms of fees we may be paid for our retirement plan consulting
services.
When providing consulting services to retirement plans, we do not receive additional compensation,
whether direct or indirect, from any third-party vendor providing services to a retirement plan for
which we provide consulting services, nor do we share or receive revenue from any mutual fund,
exchange traded fund or similar investment offered under a plan.
Referrals to Third-Party Money Managers
If advisory services are provided by a third-party money manager, including LPL, fees will be paid to
that manager. Fees charged by third-party managers are included in each manager’s Form ADV
Part 2, including any relevant supplement.
We are paid by third-party money managers when we make a referral to them and a managed
account is opened or an LPL program is selected and funded, usually between 1.00% and 1.70% of
the fee that our client pays to the third-party manager. We generally receive these fees while the
managed account or LPL program remains open and is funded. When we refer a client to a third-
party manager, the manager does not charge our client a higher fee because of our referral.
We may receive additional types of compensation from LPL, summarized below in Item 10.
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Capital Group’s American Funds Direct-at-Fund Management
American Funds’ Direct-at-Fund managed account solution utilizes F-2 mutual fund shares, which
are no-load fund shares with no 12b-1 fees or up-front sales charges. Advisory fees for these
accounts are based on a quarterly flat-fee arrangement of no more than 1.25% of the total invested
assets. Fee details regarding calculation, billing, and payment method options are fully disclosed to
the client on the American Funds F-2 Share Account Application executed directly with American
Funds.
CollegeAmerica 529 Qualified Tuition Direct-at-Fund Savings Savings Plan
Capital Group’s CollegeAmerica 529 Plan enables direct investment in 529-F-2 mutual fund shares
that are invested directly with AmericanFunds. Any earnings in these plans grow tax-deferred, and
withdrawals used for qualified educational expenses are free from federal taxes, and state tax
treatment varies by state. Direct-at-Fund investment programs are designed to provide a cost-
efficient savings plan to help families save for higher education
Calculation and Payment of Fees
Fees for Our Advisory Services
Each client selects a billing method (and in some circumstances the manner in which fees will be
calculated) and provides us with the authorization for the direct (account) billing of our fee and other
applicable fees and charges (primarily transaction charges) when an account is first established.
Statements are provided at least quarterly by each account’s custodian, which indicate all
disbursements, including advisory fees paid to us.
Depending upon the type of fee selected by a client, billing and collection periods may be as follows:
▪ On a quarterly basis payable in advance, based on the value of the account on the last
business day of the previous quarter;
▪ On a quarterly basis payable in arrears, based on the value of the account on the last
business day of the quarter;
▪ On a semi-annual basis payable in arrears, based on the value of the account on the last
business day of the semi-annual period; or
▪ On an annual basis payable in arrears based on the value of the account on the last business
day of the year.
Fees for accounts that are maintained for less than a full billing period will be prorated. Fees that are
collected in advance will be prorated and returned, without interest, if an account is terminated
before the billing period ends.
Fees for Financial Planning and Consulting
We generally require a retainer of 50% of the estimated financial planning or consulting fee, with the
remainder of the fee due 30 days after the financial plan or consultation is completed. In all cases,
we do not require a retainer in excess of $1,200 if our services cannot be rendered within six
months.
Fees for Retirement Plan Consulting
Our asset-based fees, at the election of each client, may be paid:
▪ Quarterly or monthly arrears, based on the value of the plan’s assets as of the last business
day of the quarter or month; or
▪ Quarterly or monthly in advance, based on the value of the plan’s assets as of the last
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business day of the preceding quarter or month.
The calculation of our asset-based fees does not include the value of assets for which we do not
provide advisory services, such as participant loans, employer securities and brokerage windows.
▪ Project-based fees, whether hourly fees or fixed fees, are usually due when invoiced and
may be subject to a retainer. Retainers in excess of $1,200 are not required if the services
will not be completed within six months. Annualized fees, whether calculated on a fixed fee
basis or by the number of participants, may be paid quarterly or monthly in arrears or in
advance, similar to the payment of asset-based fees.
▪ As directed by each client, fees may be billed to and directly paid by a retirement plan’s
sponsor or fees may be equitably deducted from participants’ accounts. Fees for less than a
full billing period will be prorated. Fees collected in advance will be prorated and returned,
without interest, if an engagement is terminated before the billing period ends.
Billing Procedures of Third-Party Money Managers
Third-party money managers, including LPL, establish and maintain their own billing processes and
procedures, which we do not control. Information about the billing practices of LPL and other third-
party money managers may be found in their separate written disclosure documents.
Other Charges and Expenses
As applicable, all clients should expect to pay the following additional expenses charged by third
parties:
▪ Clients remain responsible for custodial and similar fees and costs customarily associated
with the maintenance of custodied assets or brokerage account.
▪ Clients will be charged internal expenses associated with products such as mutual funds and
ETFs, including investment management and 12b-1 fees. These internal expenses are
typically calculated as a percentage of the fund’s assets under management. Some of these
fees are retained by the product issuers, and some are paid to third parties, such as a
custodian, for services including the maintenance of shareholder accounts and the
distribution of prospectuses and similar items. More information about specific expenses
charged by a fund or ETF may be found in the applicable prospectus. Because these
expenses are directly deducted from a fund’s assets, they have the effect of reducing the
performance of the investment.
▪ Products, primarily mutual funds, may have multiple share classes, each class with different
fee and compensation structures, including deferred sales charges. Charges for internal
expenses may also differ among share classes, including investment management fees and
12b-1 fees. Mutual fund shares may be subject to these varying fees and expenses, and we
may acquire shares other than those with the lowest fees and costs (those commonly
designated for advisory or institutional accounts). More information about compensation
related to mutual fund share classes may be found below, under the heading “Compensation
for the Sale of Securities and Similar Items.”
▪ Other types of charges and expenses may be incurred, including mark-ups and mark- downs,
odd-lot differentials, spreads paid to market makers from whom securities are obtained,
transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
and securities transactions.
Advisory clients who do not participate in our wrap fee program will also be responsible for
brokerage and other transaction costs incurred for trades executed in their accounts. Brokerage and
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
transaction costs are separate from our fees and will be disclosed by the firm that executes the
trades. Clients participating in our wrap fee program will have no separate brokerage or transaction
charges.
With respect to wrap fee accounts, the Firm has a potential conflict of interest in selecting No-
Transaction Fee (NTF) funds, which may have higher expense ratios compared to Transaction Fee
(TF) funds. To mitigate this conflict, the Firm’s policy is to select the mutual fund share class that is
in the best interest of the client, considering both the advisory fee structure and the total cost of
ownership in light of the client’s anticipated holding period.
Regardless of the fee arrangement, applicable brokerage and transaction charges will be deducted
from each client’s account and reflected in quarterly statements delivered by the account’s
custodian. More information about our brokerage practices may be found below in Item 12.
Advisory clients representing retirement plans remain responsible for the items listed above, as
applicable, as well as all administrative and trustee fees and specific costs associated with the
maintenance and administration of the plan and individual participant accounts, such as distribution
fees, fees for participant loans, fees for the processing of domestic relations orders and similar
items.
Cash Balances
Some of your assets may be held as cash and remain uninvested. Holding a portion of your assets
in cash and cash alternatives, i.e., money market fund shares, may be based on your desire to have
an allocation to cash as an asset class, to support a phased market entrance strategy, to facilitate
transaction execution, to have available funds for withdrawal needs or to pay fees or to provide for
asset protection during periods of volatile market conditions. Your cash and cash equivalents will be
subject to our investment advisory fees unless otherwise agreed upon. You may experience
negative performance on the cash portion of your portfolio if the investment advisory fees charged
are higher than the returns you receive from your cash.
Retirement Plan Rollover Recommendations
As part of our investment advisory services to our clients, we may recommend that clients roll assets
from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively,
a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional
IRA, or Roth IRA (collectively, an “IRA Account”) that we will advise on the client’s behalf. We may
also recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan
Accounts, and from IRA Accounts to IRA Accounts.
If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge the
client an asset-based fee as set forth in the advisory agreement the client executed with our firm.
This creates a conflict of interest because it creates a financial incentive for our firm to recommend
the rollover to the client (i.e., receipt of additional fee-based compensation). Clients are under no
obligation, contractually or otherwise, to complete the rollover. Moreover, if clients do complete the
rollover, clients are under no obligation to have the assets in an IRA advised on by our firm. Due to
the foregoing conflict of interest, when we make rollover recommendations, we operate under a
specific rule that requires us to act in our clients’ best interests and not put our interests ahead of
our clients’.
Under this rule’s provisions, we must:
▪ Meet a professional standard of care when making investment recommendations (give
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
prudent advice);
▪ Never put our financial interests ahead of our clients’ when making recommendations
(give loyal advice);
▪ Avoid misleading statements about conflicts of interest, fees, and investments;
▪ Follow policies and procedures designed to ensure that we give advice that is in our
clients’ best interests;
▪ Charge no more than a reasonable fee for our services; and
▪ Give clients basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire or
change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, clients should consider the costs and benefits of a rollover. Note that
an employee will typically have four options in this situation:
1. Leaving the funds in the employer’s (former employer’s) plan;
2. Moving the funds to a new employer’s retirement plan;
3. Cashing out and taking a taxable distribution from the plan; or
4. Rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide clients with an
explanation of the advantages and disadvantages of both account types and document the basis for
our belief that the rollover transaction we recommend is in your best interests.
Payments and Refunds
In the Section above, “Calculation and Payment of Fees,” under the headings “Fees for our Advisory
Services” and “Fees for Retirement Plan Consulting,” we describe when fees will be paid (in
advance or in arrears) and under what circumstances a refund of fees paid in advance will be
provided. Third-party money managers may have different procedures for the payment and refund of
fees.
Compensation for the Sale of Securities and Similar Items
Below is information about compensation we or our IARs may receive for the sale of securities and
investment products, which are in addition to the advisory fees that are described above. Clients
may purchase securities and investment products that we recommend through brokers and agents
that are not affiliated with the Firm; other brokers and agents may have different fee and
compensation structures.
Commissions
Certain of our IARs are also registered representatives of LPL and are subject to LPL’s policies
and procedures when acting in that capacity. When acting as an LPL-registered representative,
advisors may receive normal and customary commissions and other types of compensation,
including mutual fund 12b-1 fees or variable annuity trails. This compensation is in addition to
the advisory fees described below.
The potential for receipt of commissions and other compensation may give such IARs an
incentive to recommend investment products based on compensation, rather than clients’
needs, and may create a conflict of interest. We address this conflict by requiring our IARs to
evaluate the suitability of products considering various factors such as clients’ investment
objectives, financial goals, and risk tolerance to ensure our clients’ interests are always
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
considered ahead of personal gain. Clients have the right to request and receive information
about commissions and other compensation in respect of any recommendation we make.
Fee-Based Arrangements
Clients who receive asset management from our IARS may elect one of two fee arrangements,
which may result in different compensation considerations:
▪ Clients who elect to pay a comprehensive wrap fee, with no transaction-based charges,
should understand that the wrap account transaction charges will be allocated to the
account’s IAR. While these charges may be less than conventional brokerage costs, they
may be a factor when an advisor decides which securities or mutual funds to purchase or sell
and whether to place transactions for the account. Clients should also consider that these
conflicts may have an impact on the investment performance of their wrap account.
▪ Clients who elect to pay separate transaction-based charges should consider any
requirements that LPL or Schwab may impose when acting as custodian of the account, as
well as the number of transactions that are anticipated. More information about the Firm’s
custodial relationships with LPL and Schwab may be found below in Item 10. More
information about our wrap-fee program may be found in our Wrap-Fee Program Brochure,
which may be requested by telephone at (972) 421-1360 or at
RIACompliance@thearcfirm.com
Mutual Fund Share Classes
As explained above, mutual funds generally offer multiple share classes, with each class subject to
certain eligibility or purchase requirements (such as minimum investment or participation in an
investment advisory program) and different expense ratios and costs. In some circumstances, our
advisors may receive additional compensation from a mutual fund based on the share class that is
acquired, which creates a conflict of interest in the share class selection process. Even though the
transaction fees are payable to the account custodian, and not the Firm or any of its members, the
Firm will conduct periodic reviews of client accounts to ensure the appropriateness of share class
holdings to mitigate any possible conflicts, considering such factors as the intended purchase
amount, the amount of the transaction fee, the difference in expense ratios, the intended holding
period, and the availability of the institutional share class. Regardless of these actions, our clients
should not assume that the share class with the lowest expense ratio or charges will be acquired.
Actively Managed Investment Strategies
We may pay a portion of the investment advisory fees we receive for our actively managed
investment strategies to our investment advisor representatives who provide advisory services for
the strategy. Although this practice does not increase the advisory fees we charge our clients who
invest in these strategies, it may be a factor when an advisor recommends investment in one of the
strategies. Clients should determine whether their advisor also provides advisory services to one of
our investment strategies and whether fees paid to the advisor with respect to the strategy are
material.
Item 6: Performance-Based Fees and Side-by-Side Management
“Performance-based fees” are fees based on the capital gains or capital appreciation in an account.
We do not charge performance-based fees. “Side-by-side management” refers to the practice of
managing accounts that are charged a performance-based fee and accounts that are charged other
types of fees, such as asset-based fees and hourly fees. Because we do not charge performance-
based fees, we do not engage in side-by-side management.
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Item 7: Types of Clients
We have the following types of clients:
Individuals, including high net worth individuals;
▪
▪ Retirement plans, such as 401(k), pension and profit-sharing plans;
▪ Charitable organizations; and
▪ Business enterprises, including corporations, limited liability companies, and partnerships.
Account Minimums
Account minimums may be imposed by third-party money managers or in LPL advisory programs,
which are disclosed above in Item 4.
Item 8: Methods of Analysis, Investment Strategies, Risk of Loss
When providing investment advice, each of our IARs uses methods of analysis and investment
strategies that may be the same or different from the analysis and strategies used by other advisors.
Before selecting an advisor, each client should obtain specific information about the investment
analysis and strategies used by a particular advisor and consider the risk of loss associated with the
advisor’s strategies. Below is general information about the analysis and strategies that may be
used by our advisors and the risk of loss associated with various types of investments.
Methods of Analysis
Our IARs may use all or any of the following methods of analysis to evaluate securities and other
investment products.
Charting: When using charting, we review charts of market and security activity in an attempt to
identify when the market may be moving up or down, to predict when or how long the trend may last,
and to estimate when that trend might reverse.
Fundamental Analysis: Fundamental analysis is used 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 security is
underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell).
Fundamental analysis does not attempt to anticipate market movements, which may present an
additional risk since the price of a security may move up or down with the overall market regardless
of the economic and financial factors considered in evaluating the stock.
Technical Analysis: Using technical analysis, we analyze past market movements and use the
analysis to recognize recurring patterns of investor behavior to predict future price movement.
Technical analysis does not consider the intrinsic value of a security, which may present a risk since
a poorly managed or financially unsound company may underperform regardless of market
movement.
Cyclical Analysis: Cyclical analysis is used to measure the movement of a particular stock against
the overall market in an attempt to predict the price movement of the security.
Investment Strategies
Each of our advisors may use any or all of the following strategies to manage accounts, provided
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that the strategies are appropriate for the needs of a client and consistent with the client's
investment objectives, risk tolerance, time horizons, investment restrictions, and other
considerations.
Long-Term and Short-Term Purchases: We may purchase securities to hold for a relatively long
time (typically for more than one year). Risks associated with long-term purchase include that we
may not take advantage of short-term gains that could be profitable or that a security may decline
sharply in value before we make the decision to sell. We may also purchase securities with the idea
of selling them within a relatively short time (typically one year or less). We do this in an attempt to
take advantage of conditions that we believe will soon result in a price swing.
Margin Transactions: We may purchase stocks with money borrowed from a brokerage account.
This may allow the purchase of more stock than could be purchased with available cash and the
purchase of stock without the liquidation of other holdings. Margin transactions include a risk that
any loss will be magnified or that margin calls will occur if the securities pledged to collateralize the
loans decline in value.
Option Writing: We may use options as an investment strategy. An option is a contract that
provides the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a
specific price on or before a certain date (this is when you own the option “long”). An option, just like
a stock or bond, is a security. An option is also considered a derivative because it derives its value
from the underlying stock or other asset. Options can be used to speculate, which is a relatively
risky practice, can be used as a replacement security owning the option rather than the stock (stock
replacement), or they can be used to hedge to reduce the risk of holding an asset. In terms of
speculation, option buyers and writers have conflicting views regarding the performance of:
▪ Call Option: A “call” is the right to buy an asset at a certain price within a specific period of
time, so the call buyer would want the stock, index, or underlying security to go up.
Conversely, an option seller would need to provide the underlying shares in the event the
option gets exercised by the holder which can happen when the security’s market price
exceeds the strike price, when an expected dividend payment exceeds the extrinsic value of
the option, or other unique circumstances. An option seller who sells a call will do so for a
variety of reasons: to generate income, to profit from a near-term consolidation in the stock
where seller believes that the underlying stock’s price will stay flat (below strike price) or drop
in value during the life of the option, as that is how he will profit. That is the opposite outlook
of the option buyer. The buyer believes that the underlying stock will rise, if this happens, the
buyer will be able to acquire the stock for a lower price and then sell it for a profit. However, if
the underlying stock does not close above the strike price on the expiration date, the option
buyer would lose the premium paid for the call option.
▪ Put Option: A “put” option is the right to sell an asset at a certain price within a specific
period of time, so the buyer would want the stock to go down. The opposite is true for put
option writers. For example, a put option buyer believes the underlying stock will fall or at risk
of falling below the specified strike price on or before the contract’s specified date. An option
writer who sells a put option believes that the underlying stock’s price will increase or stay
above a specified price on or before the expiration date. If the underlying stock’s price closes
above the specified strike price on or before the expiration date, the put option writer will
profit. A put option holder would only benefit from a fall in the underlying stock’s price below
the strike price. If the underlying stock’s price falls below the strike price, the put option writer
is obligated to purchase shares of the underlying stock at the strike price.
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The potential risks associated with these transactions are:
▪ All options expire. The closer the option gets to expiration, the quicker the premium in the
option deteriorates; and
▪ Prices can move very quickly. Depending on factors such as time until expiration and the
relationship of the stock price to the option’s strike price, small movements in a stock can
translate into big movements in the underlying options.
We primarily use options to:
▪
“Hedge" the purchase of an underlying security; “hedging” occurs because the option limits
the potential upside due to the cost of purchase put options but also limits the downside risk
of the security.
▪ Write "covered calls," which are options written on a security owned by an account. Using
▪
▪
▪
this strategy, an account receives a fee for selling an option covering a security that it owns,
and the person purchasing the option has the right to buy the security at a specified price
during a specified period.
Implement a “collar” strategy in which covered calls are written on a security and protective
put options on the same security are purchased. This limits both upside and downside risk of
the singular security.
Implement a "spread strategy," in which two or more option contracts (puts or calls) on the
same security. This is similar to buying a call or a put; however, the benefit is capped by the
second option that creates the spread. In the case of a long call option spread, the buyer
would benefit from the gap between the long call strike price and the sold/written strike price
less the option premium paid to enter the position.
In rare instances for clients with investment objectives of aggressive growth we may
purchase calls or sell puts in an attempt to generate income.
Risk of Loss
All investing involves a risk of loss that clients should be prepared to bear, including the risk that the
entire amount invested may be lost.
Our investment strategies involve active management and could lose money over short or long
periods of time. There are no assurances that our investment strategies will succeed, and we cannot
guarantee that we will achieve the investment objectives established by a client, or that any client
will receive a return on investment. Our investment decisions and recommendations consider both
the prospect for return and the risk of loss. In considering the risk of loss, we contemplate both the
probability of loss and the potential magnitude of any loss. Some of the risks associated with our
strategies and analysis are summarized below.
Risk Associated with Debt Obligations: In addition to the risks generally applicable to an
investment in securities, an investment in debt obligations and instruments may be further subject to
some unique risks:
▪
If debt obligations are downgraded by ratings agencies, go into default or if management,
legislation or other action reduces the issuer’s ability to pay principal and interest when due,
the value of debt obligations may decline. Because the ability to pay principal and interest
when due is typically less certain for an issuer of lower-rated or unrated obligations (including
“junk” or “high yield” bonds), when compared to an issuer of higher-rated obligations, lower-
rated and unrated obligations are generally more vulnerable to default, ratings downgrades,
and liquidity risk.
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▪ Political risk may adversely affect governmental issues, in addition to risks associated with
the economy and similar factors.
▪ When interest rates increase, the value of interest-bearing investments may decline. This
effect is typically more pronounced for intermediate and long-term obligations and for
mortgage and other asset-backed securities.
▪ When interest rates decrease, current income may decline.
▪ Decreases in interest rates may result in the prepayment of debt obligations and may result
in reinvestment at lower rates.
Derivatives Risk: Investments in derivatives involve risks associated with the securities or other
assets underlying the derivatives, as well as risks that are different or greater than the risks affecting
the underlying assets. Risks unassociated with the underlying assets include the inability or
unwillingness of the counterparty to perform its obligations, inability or delay in selling or closing
positions, and difficulties in valuation.
Foreign Investment Risk: Investments in the securities of foreign issuers may involve risks
including adverse fluctuations in currency exchange rates, political instability, confiscations, taxes or
restrictions on currency exchange, liquidity risk, and reduced legal protection. These risks may be
more pronounced for investments in developing or emerging countries.
Liquidity Risk: Due to a lack of demand or other factors, there may be no market for particular
investments. In that event, sales may not occur, or sales may be made at less than desired prices.
Market and Economic Risk: An account’s value may decline due to changes in general economic
and market conditions. The value of a security may change in response to developments affecting
entire economies, markets or industries, including changes in interest rates, political and legal
developments, and general market volatility.
Risks Affecting Specific Issuers: The value of an equity security or debt obligation may decline in
response to developments affecting the issuer of the security or obligation, even if the overall
industry or economy is unaffected, such as management issues, corporate disruption, political
factors adversely affecting governmental issuers, a decline in revenues or profitability, an increase in
costs, or adverse changes in the issuer’s competitive position.
Smaller Company Risk: Investments in smaller companies may involve additional risks attributable
to limited product lines, limited access to markets and financial resources, greater vulnerability to
competition and changes in markets, lack of management depth, increased volatility in share price,
and possible difficulties in valuing or selling the investments.
ETF Risk: In addition to the investment risks generally applicable to all securities, investment in an
exchange-traded fund, or ETF, may involve unique risks:
▪ ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent net asset value, or NAV,
which is calculated at least once daily for indexed-based ETFs and more frequently for
actively managed ETFs. Certain market inefficiencies may cause the shares to trade at a
premium or discount to NAV.
▪ An ETF redeems shares on an aggregate basis (usually 20,000 shares or more). If a liquid
secondary market ceases to exist, shares may not be timely sold (redeemed), or the value of
the shares may decline.
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Master Limited Partnerships (MLPs) Risks: MLPs are collective investment vehicles publicly
traded on a national securities exchange. MLPs invest primarily in companies in the energy sector or
that are engaged in natural resource production and mineral refinement. MLPs are subject to the
underlying volatility of these industries and may be adversely affected by changes in supply and
demand, regional instability, currency spreads, and inflation and interest rate fluctuations, among
other factors. In addition, MLPs operate as pass-through tax entities, meaning that investors may be
liable for their pro rata share of the partnership’s items of gain and loss, regardless of the type of
account in which the interests are held.
Real Estate and Real Estate Investment Trusts (REITs) Risks: We may recommend an
investment in one or more real estate investment trusts (“REITs”), the shares of which may be
publicly traded or privately placed. REITs are collective investment vehicles with portfolios
comprised primarily of real estate and mortgage related holdings. REITs may hold concentrated
investments in commercial and/or residential developments, which inherently subject investors to
risk associated with a downturn in the real estate market. Real estate investments concentrated in
particular geographic regions that experience volatility may experience fluctuations in value.
Mortgage related holdings may give rise to additional concerns related to interest rates, inflation,
liquidity and counterparty risk.
Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and
mortality over a wide geographic area, crossing international boundaries, and causing significant
economic, social, and political disruption.
Cybersecurity Risk: A breach in cyber security refers to both intentional and unintentional events
that may cause an account to lose proprietary information, suffer data corruption, or lose operational
capacity. This in turn could cause an account to incur regulatory penalties, reputational damage, and
additional compliance costs associated with corrective measures, and/or financial loss.
Custodial Risk: This risk is the probability that a party to a transaction will be unable or unwilling to
fulfill its contractual obligations either due to technological errors, control failures, malfeasance, or
potential regulatory liabilities.
It is not possible to list all risks associated with each class of securities or assets or each market
sector. Clients should consult their IAR for more information about specific risks that may be
associated with the advisor’s investment strategy.
Item 9: Disciplinary Information
We are required to disclose all pertinent facts regarding any legal, regulatory or disciplinary events
that would be material to your evaluation of the Firm or the integrity of our management.
In 2024, we settled an enforcement action by the Securities and Exchange
Commission, Division of Enforcement (the “SEC”) arising out of a since
terminated` Investment Advisor Representative’s cherry picking, which occurred
in 2020 and without the firm’s knowledge. As part of the settlement, we
consented to the entry of a final judgment, without admitting or denying the
allegations of the SEC’s complaint. The court’s final judgment dated February 16,
2024 ordered: (i) that the firm is permanently restrained and enjoined from
violating Section 17(a)(2) of the Securities Act of 1933; (ii) the firm is permanently
restrained from violating Sections 204(a) and 206(2)&(4) of the Investment
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
Advisers Act of 1940 and its implementing rules; and (iii) the firm is to pay a civil
penalty of $300,000 to the SEC. Additionally, the court’s final judgment ordered
the firm to retain an outside compliance consultant to review the firm’s policies
and procedures, as well as its customer disclosures.
Item 10: Other Financial Industry Activities and Affiliations
Broker/Dealer and Registered Representatives
The Firm is not registered as a broker-dealer. Some of our Investment Advisor Representatives are
registered as registered representatives of LPL, an unaffiliated SEC registered broker-dealer and
FINRA member, and some of our advisors may not be registered representatives.
Material Relationships
Relationships with LPL
As described above in Item 5 our IARs may sell securities through LPL and receive normal and
customary commissions and other types of compensation, including mutual fund 12b-1 fees or
variable annuity trails. The potential for receipt of commissions and other compensation may give
our IARs an incentive to recommend investment products based on compensation, rather than
needs, and may create a conflict of interest. We address this conflict by ensuring that our clients’
interests are always considered ahead of personal gain.
When our clients engage LPL, we receive a portion of the fees paid to LPL by our clients. We
believe that this conflict of interest is mitigated since our clients pay no more than would be charged
for participation in an LPL advisory program absent our referral. However, our receipt of a portion of
the fees paid to LPL by our clients creates incentives for our IARs to recommend LPL advisory
programs over similar advisory programs offered by other investment advisory firms.
While LPL does not participate in, or influence the formulation of, the investment advice we provide,
certain of our supervised persons are “dually registered persons.” Dually registered persons are
registered representatives with LPL who also serve as our Investment Advisor Representatives.
These persons are restricted by FINRA rules and policies from maintaining client accounts at
another custodian or executing client transactions through a broker-dealer or custodian that is not
approved by LPL. As a result, the use of trading platforms other than LPL must be approved not only
by us, but also by LPL.
As explained below in Item 14 some of our IARs who are dually registered persons may receive
monetary payments and other forms of consideration from LPL as transition assistance. This
arrangement presents a potential conflict of interest because dually registered IARs have financial
incentives to trade on the LPL platform in order to receive transition assistance. Clients should
review an advisor’s Brochure Supplement to determine whether assistance is provided and the
potential for conflicts of interest that may arise from the assistance.
We allow our IARs to select LPL or Schwab to custody client assets. Clients should understand that
LPL is responsible under FINRA rules for supervising certain business activities of the Firm and the
trading activity of our dually registered persons that is conducted through broker-dealers and
custodians other than LPL. LPL charges a fee for its oversight and supervision. This arrangement
presents a conflict of interest for IARs that custody client assets at LPL because we have a financial
incentive to avoid the oversight fee by recommending that accounts be maintained with LPL, rather
than with another broker-dealer or custodian. For some clients and trading strategies, other broker-
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
dealers may have lower costs than LPL. We mitigate this conflict through a periodic review of best
execution at LPL and Schwab, and by sharing those results with our IARs.
Insurance Company or Agency
The Firm owns a majority position in ARC Insurance Ventures (ARC IV), an insurance agency
selling life and health insurance, which also provides merchant services. ARC IV owns 50% of ARC
Insurance Consultants, an insurance agency selling property and casualty insurance.
Insurance
Many IARs are licensed insurance agents or brokers. In such capacity, they may offer fixed and
variable life insurance products and receive normal and customary commissions as a result of any
purchase. We also own interests in two insurance brokerage businesses. In the course of providing
advisory services, our IARs may recommend the purchase of insurance products from these related
entities and may use any insurance agent or broker they choose. Other insurance agencies may
offer similar products that cost more or less. Clients should obtain quotes from more than one
insurance professional before any purchase is made or authorized.
Insurance compensation, including commissions and trails, is separate from any investment
advisory fee charged by the Firm. The potential for receipt of commissions and other compensation
when acting as an insurance agent may provide an incentive to recommend insurance products
based on the compensation received, rather than on a client's needs.
Other IAR Considerations
Many of our Investment Advisor Representatives are independent contractors and conduct or
engage in other businesses, such as other advisory programs. Some of our IARs are advisory
representatives of LPL’s registered investment advisor and may offer advisory programs sponsored
and/or offered by LPL. Fees for programs offered through us, as compared to LPL, may be higher or
lower.
Our IARs generally provide services in an advisory capacity. In certain cases, this may present a
conflict of interest. In an advisory account, a client is provided with ongoing investment advice, and
we receive an ongoing advisory fee for that service. If a client intends to follow a buy and hold
strategy or does not wish to purchase ongoing investment advice or management services, an
advisory account may not be appropriate.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions, Personal Trading
Code of Ethics
We have a duty to exercise our authority and responsibility for the benefit of our clients, to place the
interests of our clients first, and to refrain from having outside interests that conflict with the interests
of our clients. We, our employees, and all affiliated Investment Advisor Representatives avoid any
circumstances that might adversely affect, or appear to affect, our duty of loyalty. To address
potential conflicts, we have adopted a Code of Ethics (the Code); the Code’s key provisions include:
• A statement of general principles;
• A policy concerning the reporting of personal securities transactions;
• A prohibition on insider trading;
• Restrictions on the acceptance of significant gifts;
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ADVISOR RESOURCE COUNCIL FORM ADV PART 2A
• Procedures to detect and deter misconduct and violations; and
• A requirement to maintain the confidentiality of client information.
Our employees and all affiliated Investment Advisor Representatives must acknowledge the terms of
the Code at least annually. Any individual not in compliance with the Code may be subject to
termination. We will provide a copy of our Code upon request.
Participation or Interest in Client Transactions and Principal/Agency Cross Trades
We do not recommend any securities to our clients in which we have a material financial interest.
“Cross trading” refers to the practice of buying and selling securities between advisory accounts or
between us (acting as principal or agent) and advisory accounts, rather than buying and selling
securities in the market. We do not engage in principal or agency cross trading and we do not cross
trade between client accounts.
Personal Trading Practices
Both the Firm and our employees may invest in the same securities at the same time as the securities we
recommend to our clients. This practice presents an inherent conflict of interest, as our employees may
have a financial incentive to favor their personal accounts. To mitigate this conflict, we have implemented
policies and procedures designed to ensure that client interests are placed ahead of personal gain. These
include pre-trade approval requirements, restrictions on trading certain securities, and regular reviews of
personal trading activities, including but not limited to, any personal trades allocated through block trades,
by our Compliance staff.
Item 12: Brokerage Practices
Research and Other Soft Dollar Benefits
The term “soft dollar” generally refers to the practice of using client brokerage commissions to obtain
research and other services used in the conduct of our business, rather than purchasing the
services directly. We do not receive formal soft dollar benefits other than execution from
broker/dealers in connection with client securities transactions. See disclosure below in “Brokerage
– Other Economic Benefits”
Brokerage for Client Referrals
We do not receive client referrals from broker/dealers.
Directed Brokerage
We generally recommend Charles Schwab & Co., Inc. (“Schwab”) or LPL Financial, LLC (“LPL”),
each a member FINRA/SIPC, and independent and unaffiliated broker-dealers (“Broker-Dealers”).
Broker-Dealers provide us with access to its institutional trading and custody services, which are
typically not available to retail investors. These services generally are available to independent
investment advisors on an unsolicited basis and are not otherwise contingent upon our commitment
to each Broker-Dealer for any specific amount of business (assets in custody or trading). Broker-
Dealer services include the execution of securities transactions, custody, research, and access to
mutual funds and other investments that are otherwise generally available only to institutional
investors or would require a significantly higher minimum initial investment.
For our client accounts maintained there, each Broker-Dealer is compensated through commissions
or other transaction-related fees for securities trades that are executed through that Broker-Dealer
or that settle into Broker-Dealer accounts. The brokerage commissions and/or transaction fees
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charged by Schwab or any other designated broker-dealer are exclusive of and in addition to our
fees.
Directed Brokerage – Other Economic Benefits
We may receive from Broker-Dealers, at no cost to us, professional services, computer software and
related system support, enabling us to better monitor client accounts maintained at each Broker-
Dealer. We may receive this support without cost because of the portfolio management services
rendered to clients that maintain assets at each Broker-Dealer. The support provided may benefit
us, but not our clients directly. In fulfilling our duties to our clients, we endeavor at all times to put the
interests of our clients first. Clients should be aware, however, that our receipt of economic benefits
from a broker-dealer may create a conflict of interest since these benefits may influence our choice
of broker-dealer over another broker-dealer that does not furnish similar services, software and
systems support.
The commissions paid by our clients shall comply with our duty to obtain “best execution.” However,
a client may pay a commission that is higher than another qualified broker-dealer might charge to
effect the same transaction where we determine, in good faith, that the commission is reasonable in
relation to the value of the brokerage and research services received. 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
among others, the value of research provided, execution capability, commission rates, and
responsiveness. Consistent with the foregoing, while we will seek competitive rates, we may not
necessarily obtain the lowest possible commission rates for client transactions.
Broker-Dealers also make available to us other products and services that benefit us but may not
directly benefit our clients’ accounts. Many of these products and services may be used to service
all or some substantial number of our accounts, including accounts not maintained at each Broker-
Dealer.
Broker-Dealer products and services that assist us in managing and administering clients’ accounts
include software and other technology that (i) provide access to client account data (such as trade
confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade
orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate
payment of our fees from our clients’ accounts; and (v) assist with back-office functions,
recordkeeping and client reporting.
LPL Advisory Programs
Clients who participate in one of the LPL advisory programs and some of the arrangements
available under our wrap fee program must designate LPL to custody assets and execute trades as
a condition of participation. Clients should be aware that if LPL serves as custodian, we are limited
to offering services and investment vehicles approved by LPL. Services and investment vehicles
available through broker-dealers and custodians other than LPL may be more suitable than the
services and investment vehicles offered through LPL. We cannot ensure that all trades executed by
LPL are on most favorable terms; better terms may be offered through other broker-dealers. Clients
should understand that not all investment advisors recommend or require that clients custody their
accounts and trade through specific broker-dealers, and other arrangements may be available.
LPL charges us an asset-based administration fee for the administrative services it provides. This
fee is not a brokerage or transaction fee, and it is not directly paid by our clients but may be
considered when we negotiate advisory fees with clients.
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Trade Allocation and Aggregation
We allocate client investments based on factors including investment objectives, account size, and
risk tolerance, ensuring that each client’s portfolio aligns with their specific financial goals, needs
and objectives. Allocation decisions are also influenced by other relevant parameters such as time
horizon, liquidity needs, and market conditions. These factors are carefully considered to tailor
investment strategies that are suitable and appropriate for each client’s unique circumstances.
Orders for the same security entered on behalf of more than one client may be aggregated (i.e.,
blocked or bunched), subject to the aggregation being in the best interests of all participating clients.
Aggregation typically applies to equities, fixed income, and other publicly traded securities when
doing so achieves more favorable execution for clients, such as better pricing or reduced transaction
costs. Aggregation is conducted under conditions where all clients benefit equally, ensuring that no
single account gains an advantage or incurs a disadvantage relative to others in the aggregated
order. Trades are aggregated only when we reasonably believe that the combination of orders will
result in an overall economic benefit, including lower transaction costs or improved execution
quality, compared to placing orders separately. Exceptions to aggregation may occur in cases where
specific client instructions, account restrictions, or unique investment needs necessitate
individualized execution.
If an order is filled at different prices during a single day, the prices are averaged for the day, so that
all participating accounts receive the same price. If an order has not been filled completely, so that
there are not enough shares to allocate among all clients equally, shares will be allocated in good
faith, based on the following considerations: the amount of cash in the account; existing asset
allocation and industry exposure; risk profile; and type of security. If partial execution is attained at
the end of a trading day, we generally will allocate shares on a pro rata basis but may fill small
orders entirely before applying the pro rata allocation. Pro rata allocation is used to distribute shares
proportionally based on the size of each participating account's order, ensuring a fair and consistent
approach where each client receives an equitable portion of the available shares relative to their intended
purchase. This method helps maintain fairness, prevent favoritism, and align allocations with each client’s
original investment intent. However, alternative allocation methods, such as filling smaller orders entirely
or adjusting for specific account requirements, may be applied in certain scenarios where pro rata
distribution is impractical or would disadvantage certain clients. All clients participating in an aggregated
order receive the average price and subject to minimum ticket charges, pay a pro-rata portion of
commissions. Our allocation procedure seeks to be fair and equitable to all clients with no particular
group or client being favored or disfavored over any other. To prevent cherry-picking, we have
specific policies and procedures in place. These include pre-allocation of shares prior to block
trading when practicable, the review of trade data reflecting the time of order entry and time the
trade was allocated to the accounts to ensure that allocations are performed consistent with pre-
trade instructions and our fiduciary duty. Any deviations from these procedures are subject to review
and possible disciplinary action.
Prior to execution, we review orders to ensure they align with the client’s investment profile and
strategy, and after execution, we monitor and verify trade allocations to confirm adherence to our
policies and to address any discrepancies promptly. Accounts for the Firm or our employees may be
included in a block trade with client accounts, provided that such inclusion does not disadvantage
any client and is conducted in a manner consistent with our fiduciary duty.
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Item 13: Review of Accounts and Plans
Generally, our IARs or portfolio managers review accounts with clients at least annually. The nature
of our review is to determine whether each client’s account remains invested in a manner consistent
with the client’s investment objectives and is appropriately positioned based on our analysis of
market conditions and other factors. We may review client accounts more frequently, based on
major market or economic events, a client’s life events or at a client’s specific request. Our advisory
clients receive periodic reports in the form of quarterly statements from their custodian or other plan
provider. We do not separately provide written periodic reports.
Financial planning clients do not receive reviews of their written plans unless they schedule a
financial consultation with us, or they have contracted with us for periodic review. We may also meet
as requested to update financial plans and discuss changes in circumstances and similar factors.
Financial planning clients who have contracted with us for a post-financial plan meeting or an update
to their initial written financial plan will receive a written plan or update.
Retirement plan consulting clients receive periodic reviews of their investment policies and
designated investment options for the duration of our consulting service, annually or at the
frequency requested by the client. We also provide additional services upon request, for items such
as vendor reviews, fee review and benchmarking, and updates to plan document provisions.
Retirement plan consulting clients receive written reports, at the frequency requested.
Item 14: Client Referrals and Other Compensation
Other Compensation for Advisory Services
This Item 14 describes the compensation or economic benefits we and our IARs may receive from
others when we provide advisory services to our clients. These amounts are in addition to the fees
and other amounts described above in Item 5.
Non-Soft Dollar Compensation
We receive economic benefits from LPL and Schwab in the form of the support products and
services they make available to us and other independent investment advisors whose clients
maintain their accounts at each firm. You do not pay more for assets maintained at these custodians
as a result of these arrangements. However, we benefit from the referral arrangement because the
cost of these services would otherwise be borne directly by us. You should consider these conflicts
of interest when selecting a custodian. The products and services provided by both LPL and
Schwab, how they benefit us, and the related conflicts of interest are described above in Item 12.
Compensation – Client Referral Arrangements
We have a written arrangement to receive compensation from a bank (“Bank”) to whom we refer
clients to for commercial lending. If a referred client receives a loan from the Bank, our IAR will
receive a referral fee equal to up to 1.0% of the loan amount. Referral fees paid by the Bank are not
charged to the client. We will provide a written disclosure document, which explains to the client the
terms under which we are working with the Bank and the fact that the IAR is being compensated for
the referral activities. This written disclosure document will be signed by both the IAR and the client.
We have a written arrangement to receive compensation from an unaffiliated internet-based lending
platform (“Platform”) providing a network of lenders who can assist clients with a variety of different
types of personal and business loans (i.e., mortgage, home equity, auto, commercial, working
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capital, etc.).The Platform seeks to match the client with those lenders who can best fulfill the
client’s borrowing needs. Once matched with a lender, the Platform serves to help facilitate the loan
application and fulfillment process. If a referred client receives a loan from a Platform lender, our
IAR will receive a referral fee equal to up to 0.025% of the loan amount. Referral fees paid by the
Platform not charged to the client. We will provide a written disclosure document, which explains to
the client the terms under which we are working with the Platform and the fact that the IAR is being
compensated for the referral activities. This written disclosure document will be signed by both the
IAR and the client.
We have a written arrangement to receive compensation from a cash management platform
(“Platform 2") to whom we refer clients to for cash management solutions. We will assist clients in
the onboarding and ongoing account maintenance that is associated with Platform 2. If a referred
client uses the cash management program, our IAR will receive a referral fee equal to up to 0.47%
of the interest earned by the client. The interest earned by the client from Platform 2 is net of all
fees, including the referral fee to us.
Transition Assistance Benefits Provided by LPL to Dually Registered Persons
A “dually registered person” is an Investment Advisor Representative for the Firm and is also a
Registered Representative with LPL, a broker-dealer. LPL provides various benefits and payments
to dually registered persons that are new to the LPL platform, primarily to assist with the costs
(including foregone revenues during account transition) associated with transitioning to the LPL
platform. Transition assistance is intended to be used for a variety of purposes, including to provide
working capital, to satisfy outstanding indebtedness owed to a prior firm, to offset account transfer
fees (ACATs) payable to LPL when clients transition to the LPL platform, and to offset technology
set-up fees, marketing and mailing costs, stationary and licensure transfer fees, moving expenses,
office space expenses, staffing support and termination fees.
The amount of the transition assistance provided by LPL is often significant in relation to the overall
revenue earned or compensation received by an advisor at his or her prior firm. Payments are
generally based on the size of the advisor’s business at the prior firm or assets under custody on the
LPL platform. Please refer to the relevant Brochure Supplement for more specific information about
any transition assistance an advisor receives.
Transition assistance payments and similar benefits may create a conflict of interest relating to our
advisory business because the payments and benefits may create a financial incentive to
recommend LPL. We attempt to mitigate these conflicts by evaluating and recommending that
clients use LPL based on the benefits LPL provides to our clients, rather than the payments and
benefits LPL may provide to us and our advisors. Among the benefits of LPL are:
• The ability to seek best execution;
• The financial strength, reputation, pricing, research, and service of LPL; and
• The ability to obtain many mutual funds without transaction charges and to obtain other funds
and securities at nominal transaction charges.
Transition Assistance Benefits Provided by Schwab Advisor Services
Schwab Advisor Services provides transition assistance to use toward technology, research,
marketing, or compliance-related expenses. In evaluating whether to recommend or require that
clients custody their assets at Schwab, we may take into account the availability of some of the
foregoing products and services and other arrangements as part of the total mix of factors we
consider, and not solely the nature, cost or quality of custody and brokerage services provided by
Schwab, which may create a potential conflict of interest.
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Referrals to Third-Party Money Managers
We are paid by third-party money managers when we refer a client that opens a managed account.
Information about these payments is summarized above in Item 5. Clients who are referred to third-
party money managers will be provided with the money manager’s Form ADV Part 2, all relevant
brochures and disclosures, which will include the specific fees we are paid.
Referral Fees
We may pay fees to other independent professionals (“Promotors”) for the referral of clients to our
Firm. Promotor fees represent a share of the investment advisory fee that we charge to our clients,
but do not result in higher costs. Any client who is referred to to us by another professional will be
given full written disclosure describing the terms and fee arrangements.
Item 15: Custody
Rule 206(4)-2 under the Investment Advisers Act of 1940, as amended (the “Custody Rule”) governs
whether a registered investment adviser has “custody” of client assets (i.e., holding, directly or
indirectly, client funds or securities, or having any authority to obtain possession of them). We do not
custody client securities and other funds. Instead, pursuant to the Custody Rule, client securities
and other funds are held in a custody arrangement with a Qualified Custodian (as defined under the
Custody Rule), with the exception of accounts managed in Capital Group’s American Funds’ Direct-
at-Fund programs, including their CollegeAmerica 529 Savings Plan.
American Funds Service Company is a transfer agent, which is not a Qualified Custodian. The SEC
Custody Rule has a specified carve-out permitting mutual fund transfer agents to hold fund shares in
lieu of a Qualified Custodian arrangement. Our firm has no control over or responsibility for assets
held directly with Capital Group’s AmericanFunds, and clients enter into a signed agreement directly
with Capital Group’s American Funds or their CollegeAmerica 529 Savings Plan that details the
arrangements for assets held in their funds. This agreement details how clients will receive account
statements and pay advisory fees, which are described in more detail in Item 5.
For accounts held with one of our custodians, clients receive written account statements directly
from the custodian at least quarterly. We recommend that our clients review each custodial
statement carefully and promptly notify us and the custodian if any statement is not timely received
or includes errors or inconsistencies.
IARs may select between the Firm’s approved Qualified Custodians (i.e., LPL, Schwab, or both) for
client assets based on a variety of factors to ensure that the chosen custodian provides the best
possible service to the applicable client. These factors include, but are not limited to, fees, best
execution, facilitation of trading, research, client preferences, technology and tools, regulatory
compliance, security and safekeeping, customer service, and corporate actions management.
Specific client needs or preferences for a custodian are addressed on a case-by-case basis in
consultation with the Chief Compliance Officer. Certain restrictions imposed by a specific custodian
may impact the flexibility and cost-effectiveness of a client’s investment strategies. For example,
LPL prohibits trading away and Schwab charges a per trade fee for allocating any trades done
away. Consequently, IARs might select one custodian over the other based on these restrictions.
The Firm will provide clear and comprehensive disclosures to clients regarding any such restrictions
to ensure clients are fully informed about any limitations that may materially affect their investment
decisions or strategy.
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Our retirement plan consulting clients maintain their own trust and custody arrangements directly with the
retirement plan or its designated service providers. We do not have authority over, or responsibility for,
these custodial relationships.
Item 16: Investment Discretion
For advisory accounts and certain retirement plan consulting engagements, the Firm is granted a
Limited Power of Attorney, permitting us to exercise full discretion as to the nature, type and amount
of securities to be purchased without preapproval by the client. Our exercise of discretion may be
limited by any investment guidelines and objections that are furnished by a client or that we develop
with the client and by any restrictions on investment that we have accepted and agreed to
administer.
If we have not been given discretionary authority, we will consult with the client prior to each trade.
Item 17: Voting Client Securities
Proxy Voting
We do not vote proxies on behalf of clients and do not provide guidance on how clients should vote
proxies. Clients retain exclusive responsibility for receiving and voting all proxies and other
shareholder communications for securities held in their accounts.
For clients who engage a third-party money manager or turnkey asset management programs
(“TAMP”), certain managers may offer proxy-voting services as part of their own advisory program.
Any proxy-voting authority, responsibilities, and related policies will be defined in the separate
agreement executed between the client and each third-party manager or TAMP. Clients should
review those documents carefully to understand whether the manager will vote proxies on their
behalf and under what conditions.
Clients may contact the applicable third-party manager or TAMP directly for information regarding
their proxy-voting policies and procedures, including how a particular proxy was voted. Because our
firm does not assume proxy-voting authority, we do not maintain proxy-voting records.
Item 18: Financial Information
We have no financial commitment that impairs our ability to meet contractual and fiduciary
commitments to clients and have not been the subject of any bankruptcy proceedings.
We are not required to provide a balance sheet; we do not serve as a custodian for client funds or
securities and do not require prepayment of fees of both more than $1,200 per client, and more than
six months in advance.
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