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900 Ashwood Parkway
Suite 500
Atlanta, GA 30338
770.352.0449
Disclosure Brochure
August 1, 2025
This brochure provides information about the qualifications and business practices of Advisory
Services Network, LLC (“ASN”). If you have any questions about the contents of this brochure, please
contact Thomas C. Prescott, Managing Member, at 770.352.0449. 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.
ASN is an investment adviser registered with the SEC. Registration of an investment adviser does not
imply any level of skill or training. The oral and written communications of an investment adviser are
intended to provide you with information to assist in your determination as to whether or not to retain
the services of that investment adviser.
Additional information about ASN, CRD Number 146051, also is available on the SEC’s website at:
www.adviserinfo.sec.gov.
Item 2 Material Changes
Advisory Services Network has made no material changes to its brochure since
its last annual update, dated March 28, 2024.
Currently, our brochure may be requested by contacting our compliance department by
phone at (770) 352-0449 or by e-mail at compliance@advservnet.com. We will provide
you with a copy of our current brochure at any time without charge.
Additional information about us and about our investment advisory representatives
(“IARs”) is also available via the SEC’s website at www.adviserinfo.sec.gov.
Information about your IAR may be found in the IAR’s supplement to our brochure.
Advisory Services Network, LLC
SEC Number 801-71112
CRD Number 146051
Item 3 Table of Contents
Item 4 Advisory Business .................................................................................................................................................. 1
Portfolio Management Services ............................................................................................................................................. 1
Wrap Fee Program ............................................................................................................................................................. 2
Assets Under Management ................................................................................................................................................. 3
Third Party Investment Advisory Services ............................................................................................................................ 3
Financial Planning Services ................................................................................................................................................. 3
Investment Consulting Services ............................................................................................................................................. 4
Retirement Plan Consulting Services .................................................................................................................................... 5
Item 5 Fees and Compensation ........................................................................................................................................ 6
Fees for Portfolio Management Services ................................................................................................................................ 6
Fees for Third Party Investment Management Services ......................................................................................................... 7
Fees for Financial Planning Services .................................................................................................................................... 8
Fees for Investment Consulting Services ................................................................................................................................ 8
Fees for Retirement Plan Consulting Services ....................................................................................................................... 9
Prepayment of Fees .............................................................................................................................................................. 9
General Fee Information ..................................................................................................................................................... 9
Other Compensation.......................................................................................................................................................... 10
Item 6 Performance-Based Fees ..................................................................................................................................... 11
Item 7 Types of Clients .................................................................................................................................................... 11
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................... 12
Item 9 Disciplinary Information .................................................................................................................................... 14
Item 10 Other Financial Industry Activities and Affiliations .................................................................................... 14
Recommendation of Other Advisers ........................................................................................................................ 15
Item 11 Code of Ethics; Participation or Interest in Client Transactions and Personal Trading ........................ 15
Item 12 Brokerage Practices............................................................................................................................................ 17
Item 13 Review of Accounts ........................................................................................................................................... 19
Item 14 Client Referrals and Other Compensation .................................................................................................... 20
Item 15 Custody ................................................................................................................................................................ 21
Item 16 Investment Discretion ....................................................................................................................................... 22
Item 17 Voting Client Securities ..................................................................................................................................... 23
Item 18 Financial Information ........................................................................................................................................ 23
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Item 4 Advisory Business
Advisory Services Network, LLC (“ASN”, we, us, our, ours), located in Atlanta,
Georgia, is a Limited Liability Company organized under the laws of the State of
Georgia. Thomas C. Prescott and David E. Paulukaitis founded ASN in 2009 and are
our principal owners. ASN is registered as an investment adviser with the Securities
and Exchange Commission (“SEC”).
We offer investment advisory services through a network of independent Investment
Adviser Representatives (“IARs”, advisory representative) who conduct business under
the ASN name or another of our branded business names. For more information about
the IAR providing advisory services, you should refer to the Brochure Supplement for
the IAR. The Brochure Supplement is provided by the IAR along with this brochure
before or at the time you engage the IAR. If you did not receive a Brochure Supplement
for the IAR, you should contact the IAR or ASN at compliance@advservnet.com.
Our IARs who use branded business names are noted as a member of the Advisory
Services Network, LLC because they are registered with and offer advisory services
through us. The term “member” does not imply any ownership interest in or control
of ASN.
Our IARs may individually manage the investment assets of their clients as well as
recommend or select independent third-party investment managers to manage all or a
portion of client investment assets. Our IARs work with you to identify your
investment goals, objectives, and risk tolerances in order to structure an investment
account and an investment strategy that is consistent with your stated investment
objectives.
Our IARs also provide investment consulting services that may include comprehensive
financial planning or may address specific needs you identify.
Portfolio Management Services
The investment accounts managed by our IARs may consist of stocks, bonds, mutual
funds, exchange-traded funds (ETFs”), options, and alternative investments such as
limited partnerships and real estate investment trusts.
Our IARs may also recommend that a portion of your portfolio be allocated to a third-
party manager as described below under the heading, “Third-Party Investment
Advisory Services.” The services and fees of such manager will be fully described in its
disclosure brochure. Under Portfolio Management Services, the third party manager’s
fees will be separate and distinct from our advisory fee.
Your investment accounts and the investment strategies utilized are based upon your
specific individual investment objectives, goals and risk tolerances. Our IARs may
periodically adjust your account (a process referred to as “rebalancing”) to help ensure
that your investment account remains consistent with your objectives, goals, and risk
tolerances.
Our IARs rely upon you to notify them of any changes in your objectives, goals and
risk tolerances, as well as any other material changes in your personal circumstances
(such as your employment, marital status, financial condition, etc.). These changes may
require changes in your investment account and the investment strategies employed.
Our IARs may manage your investment account on either a discretionary basis
(meaning that you authorize your IAR to make specific investment decisions on your
behalf) or non-discretionary basis (meaning that your IAR must obtain your specific
prior approval before each transaction can be effected for your investment account).
Whether your IAR is authorized to exercise discretion with respect to your investment
account is your choice. When you establish an advisory relationship with us, we will
ask that you authorize us in writing through the ASN investment advisory agreement
how you would like your IAR to handle your account.
The scope of the discretionary authority that you may grant to one of our IARs is
limited to selecting specific investments for your account and deciding how to allocate
your assets among those investments. Your IAR may decide if and when to buy, hold,
or sell those investments. Once you have granted discretionary authority to your IAR,
it is effective until you change it or revoke it in writing.
You may impose any reasonable restrictions upon the manner in which your IAR
manages your investment account. For example, you may restrict the management of
your account to certain types of investment products or investment strategies.
Wrap Fee Program
ASN offers a wrap fee program through which we provide portfolio management
services as outlined above, for one fee. The wrap fee includes our advisory fee, custodial
and brokerage fees. This program is more fully described in our Advisory Services
Network, LLC Wrap Fee Program Brochure. This brochure will be provided to clients
utilizing our wrap fee program and free of charge to any client upon request.
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A wrap fee program may cost you more or less than purchasing these services
separately, depending on the amount of trading activity in your account, the value of
services that are provided to you under this program, and other factors. Therefore,
IARs may have a financial incentive to recommend the wrap fee program over other
programs or services. Generally, wrap programs may result in higher overall costs to
you in accounts that experience little trading activity. Please review the costs carefully
with your IAR to determine whether our wrap fee program is appropriate for your
circumstances.
We do not manage wrap accounts differently from how we manage non-wrap accounts.
Assets Under Management
As of December 31, 2024, we managed approximately $8.5 billion in client assets on a
discretionary basis (meaning our advisory representatives made all of the investment
decisions). Approximately $106 million in client assets were managed on a non-
discretionary basis (meaning our clients made the investment decisions based upon our
recommendations).
Third Party Investment Advisory Services
Our IARs may recommend that all or a portion of your portfolio be allocated to
unaffiliated third party investment managers. We have entered into agreements with
various third-party investment managers to provide investment management services
for our clients. Your IAR will use the information you have provided about your
investment objectives, goals, and risk tolerances, as well as other relevant information,
to identify a third-party investment manager(s) whose investment strategies appear
appropriate for you.
Some of the other relevant information considered in recommending a third-party
investment manager include (but are not limited to):
your preference for certain types of investments or investment strategies;
your investment time horizon;
the size and composition of your investment account;
your tax considerations;
your IAR’s prior experience with and preferences for particular investment
managers;
the fees charged by the investment manager; and
the experience and capabilities of the investment manager.
Financial Planning Services
Your IAR may prepare and provide you with a comprehensive, written financial plan
designed to help you achieve your financial goals and investment objectives. The
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preparation of such a plan requires that you provide your IAR with personal data such
as family records, employment records, budgeting, assets, liabilities, estate information,
and tax information. The financial plan may address any or all of the following as you
request and/or direct:
multi-generational planning
wealth transfer
charitable gifting
long-term care and disability
planning
retirement planning
insurance planning
asset allocation comparisons
asset protection
tax planning
business succession
strategies for exercising stock
options
cash flow
education planning
estate planning
risk management
Should you choose to implement the recommendations contained in your financial
plan, we encourage you to work closely with your attorney, accountant, insurance agent,
and other advisers. Your IAR will assist you to the extent you choose.
Although you may choose to implement the recommendations made in your financial
plan through your IAR, you are free to employ the services of any advisor or registered
representative of your choice, regardless of whether or not that person is associated
with ASN.
Investment Consulting Services
Our IARs may offer investment consulting services that are limited to the specific areas
you identify. These services are not considered financial planning services because we
will not perform a comprehensive analysis of your financial position and will not
prepare a written report documenting our review.
The consulting services our IARs provide may include (but are not limited to):
Assisting you in the preparation of an investment policy statement;
Reviewing and recommending changes to an existing investment policy
statement (or similar guidelines, policies, and/or investment allocation that you
are employing);
Reviewing existing contracts you have with service providers such as managers
and consultants, and making recommendations for changes;
Assisting you in renegotiating the fees you pay to service providers and/or
assisting you in conducting a search for new service providers;
Analyzing the performance of your current investment manager;
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Advising you regarding the manner in which your investment account is being
managed and, at your request, assisting you in searching for a new investment
manager;
Advising you on the purchase and sale of particular individual investments;
Monitoring your transaction costs; and
Monitoring compliance by your investment managers with your investment
policy statement.
As noted above, regardless of the services you choose, we strongly encourage you to
notify your IAR promptly if there are any changes in your personal circumstances,
financial situation, investment objectives, or risk tolerances.
Retirement Plan Consulting Services
Our IARs may offer retirement plan consulting services to employer sponsored
qualified retirement plans. Depending upon the services the client selects pursuant to
the Retirement Plan Consulting Agreement, the IAR may be engaged to perform
ERISA 3(21)(A)(ii) fiduciary services and/or non-ERISA fiduciary services. The
retirement plan consulting services our IARs provide may include (but are not limited
to):
Plan Participant Investment Education and Communication services;
Investment Selection Services;
Investment Monitoring and Review Services;
Establishment or Revision of the Plan’s Investment Policy Statement; and
Allocate to and Rebalance Model Asset Allocation Portfolios.
Retirement Plan Rollovers
A client leaving an employer typically has four (4) options for their retirement plan:
Leave the money in their former employer’s plan, if permitted:
Rollover the assets to their new employer’s plan, if one is available and rollovers
are permitted;
Rollover to an Individual Retirement Account (“IRA”); or
Cash out the account value (which could, depending upon the client’s age, result
in adverse tax consequences).
An IAR may recommend that a client or prospective client roll over plan assets to an
IRA managed by the IAR. As a result, the IAR may earn an asset-based fee. IARs have
an incentive to recommend a rollover that the IAR will manage based on the
compensation received, which is mitigated by the fiduciary duty to act in a client’s best
interest. No client is under any obligation to roll over plan assets to an IRA managed
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by the IAR.
There are various factors that the IAR may consider before recommending a rollover,
including, but not limited to: i) the investment options available in the plan versus the
investment options available in an IRA, ii) fees and expenses in the plan versus the fees
and expenses in an IRA, iii) the services of the plan’s investment professionals versus
those of the IAR, iv) employer stock tax consequences, if any.
Item 5 Fees and Compensation
Fees for Portfolio Management Services
We offer our portfolio management services on a fee-only basis. All fees are negotiable
at our sole discretion. Our fees may be charged based on a tiered schedule or a floating
flat schedule. In a tiered schedule, a different rate is applied to different portions of
your assets, based on established breakpoints. If a floating flat schedule is applied, the
same rate is applied to all assets, based on the total account assets. Please see the
examples following each schedule.
Tiered Schedule. Our maximum annual fees for the direct management of your account
under a Tiered Schedule are as follows:
Assets Under Management
Maximum Annual Fee*
First $500,000
2.25%
Next $1,500,000 (up to $2,000,000)
1.75%
Next $3,000,000 (up to $5,000,000)
1.50%
Assets Over $5 million
1.25%
*All fees are negotiable and defined in your Investment Advisory Agreement.
Example Tiered Fee Calculation based on $2,015,000 assets:
Annual Fee = ($500,000 x 2.25%) + ($1,500,000 x 1.75%) + (15,000 x 1.50%)
Floating Flat Rate Schedule. Our maximum fees for the direct management of your
account under a Floating Flat Rate Schedule are as follows:
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Assets Under Management
Maximum Annual Fee*
0 - $500,000
2.25%
$500,001 - $2,000,000
1.75%
$2,000,0001 to $5,000,000
1.50%
Over $5 million
1.25%
*All fees are negotiable and defined in your Investment Advisory Agreement.
Example Floating Flat Fee Calculation based on $2,015,000 assets:
Annual Fee = $2,000,015 x 1.50%
We require that you authorize us in writing to direct your custodian to pay our
investment advisory fees directly to us by charging your account. This authorization is
set forth in the investment advisory agreement you will execute to retain our services.
Our fees may be higher or lower than the fees charged by other advisors for similar
services.
Our fee is calculated based upon the net market value of the investment assets in your
account. One-fourth of our fee is billed each calendar quarter based on the value of
your account on the last day of that quarter.
Broker-dealers and other financial institutions that hold investment accounts for
advisory clients are referred to as custodians. Your custodian will determine the values
of the assets in your account. We use values provided by the custodian in the calculation
of our fee.
Your custodian will provide you with statements that show the amount of the advisory
fees paid directly to us. Your custodian does not verify the accuracy of our fee
calculations so please review your statements carefully.
Fees for Third Party Investment Management Services
The advisory services provided by third-party investment managers and the fees they
charge for those services are detailed in their respective disclosure brochures. Your
IAR will provide you with a copy of the brochure for each investment manager
recommended to you. The fees paid to third-party investment managers are in addition
to the fees paid to ASN for the advisory services provided by your IAR and will appear
separately on your custodial statement. Under a wrap fee arrangement, the total fees
specified in your investment advisory agreement will include the sum of the fees payable
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to the third party asset manager and those paid to ASN. However, the respective
amounts will show separately on your custodial statement.
Fees for Financial Planning Services
Fees for financial planning services are charged on an hourly or fixed-fee basis. On-
going financial planning services may be charged based as a percentage of the value of
your investment account. All fees are negotiable. The manner in which you are charged
and the amount you will be charged are described in your financial planning agreement.
Generally, the amount of our fees will depend upon the complexity of the services you
need. Fixed fees may range from $1,000 to $40,000 per plan and hourly fees may range
from $150 - $400 per hour. Your IAR will provide you with an estimate of the cost of
the services to be provided to you prior to beginning the financial planning process.
Financial planning fees are billed to the client either monthly, quarterly, or upon
completion of the plan. The financial planning agreement will set forth the terms and
conditions of the engagement and will describe the scope of services to be provide
upon, the agreed upon, negotiable, estimated fee to be paid.
The financial planning agreement may be terminated upon written notice by either
party. Unearned fees paid in advance will be refunded pro rata, based on the work
completed.
Fees for Investment Consulting Services
The amount of the fee for investment consulting services will be negotiated between
you and your IAR and will depend on the scope and complexity of the services to be
provided, and the estimated amount of time it will take to provide those services. All
fees are negotiable. Fees may be charged on a fixed or hourly basis. The services and
the fees for those services will be described in the investment consulting agreement.
Generally, the amount of our fees will depend upon the complexity of the services you
need. Fixed fees may range from $1,000 to $40,000 per service and hourly fees may
range from $150 - $400 per hour. Your IAR will provide you with an estimate of the
cost of the services to be provided to you prior to beginning the investment consulting
process.
Monthly Subscription Fee. We offer a monthly subscription fee-based advice service
that includes advice from the IAR, helping clients address anything from routine
questions to more complex life-changing events, and access to financial technology for
client account aggregation, spending and budgeting, and tracking progress toward
financial goals. The monthly subscription fee may range from $35 to $250 per month.
Subscription fees are billed in arrears and paid via a third-party payment method.
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The investment consulting agreement may be terminated upon written notice by either
party. Unearned fees paid in advance will be refunded pro rata, based on the work
completed.
Whether you implement any investment recommendations resulting from the financial
planning or investment consulting services provided by your IAR is entirely at your
discretion. If you implement those recommendations, you may do so through the
financial professional of your choice. If you implement those recommendations
through your IAR, we will receive compensation for the services provided in
conjunction with that implementation.
Fees for Retirement Plan Consulting Services
We do not have a standard fee schedule for retirement plan consulting services,
however the maximum annual fee that may be charged for asset-based fees is 1.50%.
The amount of the fee for retirement plan consulting services will be negotiated
between you and your IAR and will depend on the scope and complexity of the services
to be provided, and the estimated amount of time it will take to provide those services.
Fees may be charged on fixed fee or an asset-based basis. Fixed fees may either be
billed upon completion or with a partial up-front payment. Asset-based retirement plan
consulting fees are billed quarterly in arrears. The services and the fees for those
services will be described in the Retirement Plan Consulting Services Agreement.
Prepayment of Fees
We charge our investment management fees in advance, meaning that we charge our
fees before we have provided our services to you. Our initial fee will be calculated on
the day your investment assets are received by your custodian. The amount of the fee
will be calculated based on the number of days remaining in that quarter.
Should either one of us terminate the advisory agreement we have entered into before
the end of a billing period, any unearned fees that were deducted from your account
will be returned to you by us. The amount refunded to you is calculated by dividing the
most recent advisory fee you paid by the total number of days in the quarter. This daily
fee is then multiplied by the number of calendar days in the quarter that our agreement
was in effect. This amount, which equals the amount we earned for the partial quarter,
is subtracted from the total fee you paid in advance to determine your refund.
General Fee Information
In addition to our fee, you may be required to pay other charges such as:
custodial fees;
brokerage commissions;
transaction fees;
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internal fees and expenses charged by mutual funds, ETFs and variable annuities;
fees charged by third party money managers;
maintenance and termination fees for IRAs, certain retirement and qualified
accounts; and,
other fees and taxes on brokerage accounts and securities transactions.
Please be sure to read the section entitled “Brokerage Practices,” which follows later in
this brochure.
Fees paid to us are also separate and distinct from fees and expenses charged by mutual
funds, ETFs, and variable annuity issuers charge internal fees and expenses for their
products. Complete details of these internal fees and expenses are explained in the
prospectuses for each investment. You should read these documents and review all
fees charged by funds, issuers and ASN to fully understand the total amount of fees
that you may incur before making or authorizing any investments. Your IAR will be
available to answer any questions you have about fees and expenses.
Other Compensation
Our IARs may also be registered representatives of broker-dealers that are members of
Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor
Protection Corporation (“SIPC”). Those broker-dealers are not affiliated with us.
If you choose to effect securities transactions through your IAR in his/her capacity as
a registered representative of a broker-dealer, your IAR may receive commissions and
other compensation from those transactions. For example, your IAR may receive 12b-
1 fees, which are fees paid by mutual fund companies for the on-going marketing of
their investment products.
We do not permit our IARs to manage client investment accounts through the broker-
dealers with which they are associated. We do, however, permit them to implement the
recommendations from a financial plan through such arrangements. Thus, your IAR
could receive both a fee for financial planning services and commissions from the
transactions effected to implement the recommendations from the financial plan.
Our IARs may also be licensed to sell insurance products through various insurance
companies that are unaffiliated with us. As such, they may receive commissions from
any insurance products you purchase through them.
Our IARs may also be registered to recommend or offer futures and commodities
products through Introducing Brokers registered with the Commodity Futures Trading
Commission (“CTFC”) and the National Futures Association (“NFA”). Those
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Introducing Brokers are not affiliated with us. ASN does not offer advice related to
commodities and futures products.
If you choose to effect commodities or futures transactions through your IAR in
his/her capacity as an associated person of an Introducing Broker, your IAR may
receive commissions or other compensation from those transactions.
The arrangements described above may present a conflict of interest because they could
create an incentive for your IAR to make recommendations based upon the amount of
compensation he or she could receive rather than based upon your particular needs.
We are nonetheless committed to acting in your best interests at all times.
Your IAR will explain to you the specific costs associated with any investments
recommended to you.
You are under no obligation to purchase investment or insurance products or to
implement any financial plan recommendations through your IAR. You may purchase
those products and implement financial plan recommendations through the investment
or insurance professional of your choice.
Item 6 Performance-Based Fees
Performance-based fees are designed to give a portion of the return of an investment
to the investment adviser as a reward for positive performance. The fee is generally
based on a percentage of the capital gains on and/or appreciation of the client account
assets. We do not charge performance-based fees on any of our client accounts.
Item 7 Types of Clients
We provide advisory services primarily to individuals and families, including their trusts,
estates, and retirement accounts. We also provide services to corporations or other
entities.
As a condition for starting and maintaining an advisory relationship with us, we
generally require that you have a minimum investment account of $25,000. We, at our
sole discretion, may allow you to engage our services if you have a smaller account.
Some of the factors we consider in making this determination include pre-existing client
relationships we may have with you or your family members, any additional assets you
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are anticipated to receive in the future, your account composition, and your anticipated
future earning capacity.
At our discretion, we may consider the accounts of your family members in determining
whether your account meets our minimum account size requirement.
Item 8 Methods of Analysis, Investment Strategies and Risk of
Loss
Our IARs may use a wide range of methods of analysis to determine an appropriate
investment strategy for your portfolio. The analysis performed may include the
following:
Fundamental Analysis – This type of analysis concentrates on earnings, a company’s
financial statements, and the quality of a company’s management. These quantitative
factors are then used to attempt to determine the financial strength of the company.
Technical Analysis - This type of analysis utilizes statistics, such as past price and trading
volume, to determine trends in security prices. Technical analysts do not attempt to
measure a security's intrinsic value, but instead use charts and other tools to identify
patterns that can suggest future performance.
Asset Allocation - Asset Allocation is the process of selecting a mix of asset classes that
are consistent with the client’s investment goals and risk tolerance.
Long-Term Purchases – securities purchased with the expectation that the value of
those securities will growth over a relatively long time period, generally greater than one
year.
Short-Term Purchases – securities purchased with the expectation that they will be sold
within a relatively short period of time, generally less than one year, do take advantage
of the securities’ short-term price fluctuations.
Third Party Investment Manager Analysis - IARs analyze individual investment
managers based upon their investment strategies, experience, performance track record,
reputations, and fee arrangements. IARs may monitor the manager’s underlying
holdings, strategies and concentrations.
The main sources of information used to formulate investment advice and/or manage
assets includes financial publications, research materials prepared by others, corporate
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rating services, annual reports, prospectuses, filings with the SEC, company press
releases and timing services.
Risk of Loss
Although we manage your account in a manner we believe is consistent with your
specific investment objectives and risk tolerances, there can be no guarantee that our
efforts will be successful. General economic conditions, current interest rates, the
performance of a particular industry or a particular company, and any number of other
factors can affect investment performance.
You should be prepared to bear the risk of loss. All investments are subject to loss,
including (among other things) loss of principal, a reduction in earnings (including
interest, dividends and other distributions), and the loss of future earnings.
The use of margin, options and short sales are higher risk strategies. It is possible to
lose all of the principal you invest, and sometimes more. In a cash account, your risk is
limited to the amount of money that you have invested. In a margin account, your risk
includes the amount of money invested plus the amount that has been loaned to you.
When you short sell, your losses can be infinite.
You should also be aware that transactions in the account (including account
reallocations and rebalancing) may trigger a taxable event for you (unless your account
is a qualified retirement account).
You may place reasonable restrictions on the strategies to be employed by your IAR in
your account (such as, for example, the types of investments to be held in your account).
Product Risk – Your IAR may recommend many different types of securities. Our IARs
do not necessarily recommend one particular type of security, since each client has
different financial situations, investment objectives, experience, time horizons and
tolerance for risk. Each type of security has its own risks. Similar investment types can
have risks that vary widely. Generally, the higher the anticipated or expected return of
an investment, the higher the potential risk of loss that may be associated with it.
Cyber Security Risk - As the use of technology has become more prevalent in the course
of business, ASN has become more susceptible to operational and financial risks
associated with cyber security. Failures or breaches of the electronic systems of ASN,
its services providers, securities market participants or the issuers of securities can cause
significant losses for investors. Unintentional cyber events, such as the inadvertent
release of confidential information, could also adversely impact investor account. Any
cyber event could result in the loss or theft of investor data or cause investors financial
loss and expense. While measures have been developed which are designed to reduce
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the risks associated with cyber security, there is no guarantee that those measures will
be effective, particularly since ASN does not directly control the cyber security defenses
or plans of its service providers, financial intermediaries, and companies in which we
invest or with which we do business.
Item 9 Disciplinary Information
We have not been the subject of any legal or disciplinary events that would be material
to your evaluation of our business or the integrity of our management.
Item 10 Other Financial Industry Activities and Affiliations
Our Managing Members, Thomas C. Prescott and David E. Paulukaitis, also own
Mainstay Capital Markets Consultants, Inc. (“Mainstay”). Mainstay provides
compliance consulting services to broker-dealers and investment advisers. The
activities of Mainstay are wholly independent from our activities.
As previously noted, certain of our IARs are registered representatives of broker-dealers
unaffiliated with us. Certain of our IAR’s are licensed separately as insurance agents to
sell insurance products through various insurance companies that are unaffiliated with
us. Certain IARs are separately associated with a commodities and futures Introducing
Broker that is unaffiliated with us. You are under no obligation to utilize the services
of your IAR in the purchase or sales of securities, insurance or futures products through
his/her association with a broker-dealer, insurance company or Introducing Broker.
However, any transactions you may effect through your IAR in conjunction in their
separate capacities as registered representatives and or insurance agents may result in
the receipt of commissions and other compensation in addition to any advisory fees
that we charge. We do not receive any portion of the commissions or other
compensation resulting from these activities.
Certain IARs are also associated with another Registered Investment Adviser and are
thus considered dually registered. These dually registered persons do not provide
investment advice in their capacity with the other Registered Investment Adviser. ASN
is not affiliated with any other Registered Investment Adviser through common
ownership or control and does not share clients with other Registered Investment
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Advisers. We do not receive any portion of the fees or other compensation resulting
from this activity.
Certain IARs also practice as attorneys, accountants, and tax preparers. You are under
no obligation to utilize services of your IAR for these services; however any services
you may utilize through your IAR in conjunction with those separate activities may
result in compensation additional to any advisory fees that we charge. We do not receive
any portion of the fees that are paid to receive these services.
These arrangements present a conflict of interest because they create an incentive to
make recommendations based upon the amount of compensation your advisory
representative can receive rather than based upon your needs. These activities are
separate and apart from the advisory activities of ASN. And because these
activities do not involve ASN, we do not monitor, oversee or supervise them in
any way.
Information about your IAR’s financial industry activities and affiliations is disclosed in
the IAR’s Supplement which you will receive with this brochure. Additional
information about your IAR is also available at www.adviserinfo.sec.gov.
Recommendation of Other Advisers
Your IAR may recommend that you use an unaffiliated third party asset manager
(“TPAM”) based upon your needs and suitability. We share in the compensation paid
to the third party asset manager for recommending that you use their services. These
compensation arrangements present a conflict of interest because we have a financial
incentive to recommend the services of the TPAM. Compensation paid to us by third
party asset managers may vary, and therefore there may be a conflict of interest in
recommending one third party asset manager over another. The fees you pay are the
same as you would pay had you obtained the services directly from the TPAM. The
discretionary authority you may grant to your IAR will include the discretion to hire
and fire the third party asset managers.
Item 11 Code of Ethics; Participation or Interest in Client
Transactions and Personal Trading
We have adopted a Code of Ethics (“Code”) to address the standard of business conduct
required of our IARs and employees. An Investment Adviser is considered a fiduciary.
As a fiduciary, it is our responsibility to provide fair and full disclosure of all material
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facts and to act solely in the best interest of each of our clients at all times. Our fiduciary
duty is the core underlying principal for our Code of Ethics.
The Code includes our policies and procedures developed to protect your interests in
relation to the following:
the duty at all times to place your interests ahead of ours;
that all personal securities transactions of our IARs and employees be conducted
in a manner consistent with the Code and avoid any actual or potential conflict of
interest, or any abuse of an IAR’s or employee’s position of trust and
responsibility;
that IARs may not take inappropriate advantage of their positions;
that information concerning the identity of your security holdings and financial
circumstances are confidential; and
that independence in the investment decision-making process is paramount.
We will provide a copy of the Code to you or any prospective client upon request.
We do not buy or sell securities for our own account that we also recommend to you.
Our IARs and employees are permitted to buy or sell the same securities for their
personal and family accounts that are bought or sold for your account.
The personal securities transactions of our IARs and employees may raise potential
conflicts of interest when they trade in a security that is owned by you or is being
considered for purchase or sale for your account.
We have adopted policies and procedures that are intended to address these conflicts
of interest. These policies and procedures:
require our IARs and employees to act in your best interest,
prohibit favoring one client over another, and
provide for the review of transactions to discover and correct any trade in an
IAR’s or employee’s account that is effected in a manner inconsistent with our
Code.
Our IARs and employees must follow our procedures when purchasing or selling the
same securities purchased or sold for your account.
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Item 12 Brokerage Practices
We will generally recommend that the custodian and broker-dealer for your account be
either Fidelity Brokerage Services, LLC (“Fidelity”), Schwab Advisor Services division
of Charles Schwab & Co., Inc. (“Schwab”), or Pershing LLC (“Pershing”) (together
“custodians”) although we may agree to employ the services of one or more other
custodians.
We are independently owned and operated and not affiliated with the custodian we
recommend. Our use of a particular custodian is, however, a beneficial business
arrangement for us and for the custodian. Information regarding the benefits of this
relationship is described below.
Our recommendation of a specific custodian is based in part on our existing
relationships, the custodian’s financial strength, reputation, breadth of investment
products, and, the cost and quality of custody and brokerage services provided to you
and our other clients. The final decision to custody assets with any custodian is at the
discretion of the client.
In addition to brokerage and custody services, services customarily made available to
advisers include access to investments generally available to institutional investors;
research; software; and, educational opportunities. Custodians may also make available
or arrange for these types of services to be provided to us by independent third parties.
Custodians may discount or waive the fees they would otherwise charge for some of
the services they make available to us. They may also pay all or a part of the fees of a
third party providing these services to us. Custodians may also reimburse or otherwise
pay for client events held by our IARs.
We receive economic benefits as a result of our relationship with the custodians because
we do not have to produce or purchase the products and services listed above. These
services are not contingent upon us committing any specific amount of business to the
custodians in trading commissions. We do not enter into soft-dollar arrangements with
custodians or brokers. We do not receive client referrals from the custodians or broker
dealers we recommend.
Because the number of products or services we receive may vary depending on the
custodian we recommend to be used by our clients and the amount of client assets in
accounts at that custodian, we may have a conflict of interest in making that
recommendation. Our recommendation of specific custodians may be based in part on
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the economic benefit to us and not solely on the nature, cost or quality of custody and
brokerage services provided to you and our other clients. We nonetheless strive to act
in your best interests at all times.
The custodians do not charge separately for holding our client accounts but may be
compensated by you through other transaction-related fees associated with the
securities transactions they execute for your account.
Commissions and other fees for transactions executed through the custodians we
recommend may be higher than commissions and other fees available if you use another
custodian or firm to execute transactions and maintain custody of your account. We
believe, however, that the overall level of services and support provided to our clients
by our recommended custodians outweighs the benefit of possibly lower transactions
cost which may be available under other brokerage arrangements.
Many of the services described above may be used to benefit all or a substantial number
of our accounts, including accounts not maintained through our recommended
custodians. We do not attempt to allocate these benefits to specific clients.
Third party asset managers may require the use of certain custodians. Please refer to
the Brokerage Practices sections of their respective brochures for more information.
We may also receive economic and non-economic benefit from some of the third-party
asset managers we utilize in the form of the support products and services it makes
available to use, such as research, technology or administrative support. The availability
of these products and services are not based upon us giving particular investment
advice, such as buying particular securities for our clients. The total advisory fee the
client pays will not be higher because we accept these benefits.
Directed Brokerage
In some cases, you may direct us in writing to use a particular custodian that is not one
with which ASN has an existing relationship to execute some or all of the transactions
for your account. If you do so, you should understand that we will not have the
authority to negotiate the terms and arrangements for the account with that custodian
and you may pay higher servicing fees to or receive less favorable prices from the
custodian of your choice.
Trade Aggregation
We may engage in “block trading,” which is the purchase or sale of a security for the
accounts of multiple clients in a single transaction. If a block trade is executed, each
participating client receives a price that represents the average of the prices at which all
of the transactions in a given bunch were executed.
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Executing a block trade allows transaction costs to be shared equally and on a pro rata
basis among all of the participating clients. If the order is not completely filled, the
securities purchased or sold are distributed among participating clients on a pro rata
basis or in some other equitable manner.
Block trades are placed only when we reasonably believe that the combination of the
transactions provides better prices for clients than had individual transactions been
placed for clients.
Transactions for non-discretionary client accounts are generally not block traded with
transactions for discretionary client accounts. Transactions for the accounts of our
IARs and employees may be included in block trades. They will receive the same
average price and pay the same commissions and other transaction costs, as clients.
Transactions for the accounts of our IARs or employees will not be favored over
transactions for client accounts.
We are not obligated to include any client transaction in a block trade. Block trades will
not be effected for any client’s account if doing so is prohibited or otherwise
inconsistent with that client’s investment advisory agreement. No client will be favored
over any other client.
Item 13 Review of Accounts
Our IARs review your account on a periodic basis to determine whether your
investments and investment strategies are performing in a manner consistent with your
stated objectives. Your IAR will contact you at least annually (or more often as agreed
upon with you) to review your account with you and to update your financial status,
goals, objectives, and risk tolerances. These reviews also consider any investment
restrictions you have requested and how your investments meet your investment time
horizons, liquidity needs, tax considerations and other circumstances unique to you.
Changes in your investments and your investment strategies will be made or
recommended by your IAR as they are deemed appropriate.
As previously noted, we strongly encourage you to advise your IAR of any changes in
your personal circumstances, your investment goals or objectives, and your risk
tolerances to ensure that your investments and investment strategies are most
appropriate for you.
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In addition to the reviews done by your IAR, ASN staff monitor client accounts on a
periodic basis to help ensure that the investments and transactions in those accounts
appear consistent with the information you have provided.
Third Party Investment Management Services
Our IARs will regularly review the reports provided to you by any third-party
investment managers that are managing assets for you. Your IAR will contact you at
least annually (or more often as agreed upon with you) to review your financial situation,
investment goals and objectives and risk tolerances, and the performance of the third-
party investment manager to help monitor that your account is being managed in a
manner consistent with your objectives.
Again, we strongly encourage you to advise your IAR of any changes in your personal
circumstances, your investment goals or objectives, and your risk tolerances to help
ensure that your investments and investment strategies are appropriate for you.
You will receive statements on at least a quarterly basis from the custodian holding your
account. These statements will identify your current investment holdings, the cost of
each of those investments, and their current market values.
Item 14 Client Referrals and Other Compensation
We may enter into written agreements with certain unaffiliated investment advisers and
other professionals (such as CPAs, attorneys, etc.) to compensate them for referring
clients to us. We will pay these individuals (referred to as “promotors”) a percentage
of the advisory fee that you pay us if it is determined that you have become a client of
ours as a result of their direct or indirect efforts.
The payments we make to a promotor will not result in an increase in the amount of
the advisory fee that the referred client will pay.
Our promotor or referral arrangements will comply with applicable laws that govern:
the nature of the services provided;
the fees to be paid;
disclosure of promotor arrangements to clients; and
client consents, as required.
We receive certain economic benefits as a result of our participation in custodians’
institutional brokerage programs. Those benefits are described in detail in the
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preceding section entitled “Item 12 Brokerage Practices.” The availability of the
custodians’ products and services is based solely on our participation in their programs,
and not on the provision of any particular investment advice.
As noted above in Items 5 and 10, we receive compensation by referring you to third
party asset managers. This creates a conflict of interest because we have an incentive
to recommend those third party asset managers based on the compensation we receive
rather than what’s in your best interest. We address this conflict by disclosing it to you.
Additionally, as fiduciaries we place your interests above our own in determining
whether a referral to a third party asset manager is appropriate for you. You are under
no obligation to use the services of a third party asset manager we recommend.
ASN occasionally engages unaffiliated professional recruiters to introduce ASN to
prospective IARs. In the event an introduced IAR elects to join ASN, ASN will pay a
referral fee to the recruiter based upon the amount of assets managed by the IAR.
Payments made by ASN to recruiters will not result in any increase in the amount of
the advisory fee charged to any client of the introduced IAR.
Item 15 Custody
Custody, as it applies to investment advisors, has been defined by regulators as having
access or control over client funds and/or securities. In other words, custody is not
limited to physically holding client funds or securities. Under government regulations,
we are deemed to have custody of your assets when you authorize us to instruct the
account custodian to deduct our advisory fees directly from your account. Additionally,
ASN will be deemed to have custody when ASN executes authorized transactions (such
as wire transfers, standing authority to move money to a third party account, etc.) on
behalf of clients. To the extent ASN is deemed to have custody of client funds and
securities within the meaning of Rule 206(4)-2 under the Investment Advisers Act of
1940, ASN will comply with the requirements of such rule.
In order for the client to move money from their account to a third party including, but
not limited to standing authority to move money, clients must provide instructions to
the qualified custodian in writing. These written instructions will be required to include
such details as the name of the third party, the address or account number of the third
party, the amount of the money to be moved and the client signature. Clients are able
to terminate or change these instructions with the custodian at any time. Account
statements are delivered directly from the qualified custodian to each client at least
quarterly. The statements will show any and all money movement in the account.
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Your assets are maintained with a qualified custodian. You will receive statements
from your account custodian on at least a quarterly basis. We urge you to carefully
review these statements. You should verify that the transactions in your account are
consistent with your investment goals and the objectives for your account. Clients are
also asked to promptly notify ASN if the custodian fails to provide statements on each
account held.
We also encourage you to contact your IAR or our Chief Compliance Officer should
you have any questions or concerns regarding your account.
Item 16 Investment Discretion
As previously noted in the section entitled “Advisory Business”, we offer our advisory
services on a discretionary basis (meaning that we do not need advance approval from
you to determine the type and amount of securities to be bought and sold for your
account) and on a non-discretionary basis (meaning that we need advance approval
from you to determine the type and amount of securities to be bought and sold for each
transaction in your accounts).
We may only exercise discretion if you have provided that authority to us in writing.
This authorization is typically included in the investment advisory agreement you enter
into with us.
The discretionary authority you grant to us does not provide us the ability to choose
the custodian through which transactions for your account will be executed or to
negotiate brokerage fees or expenses. Additionally, our discretionary authority does
not provide us the ability to withdraw funds from your account (other than to withdraw
our advisory fees which may only be done with your prior written authorization).
We will exercise discretion in a manner consistent with the stated investment objectives
for your account.
Typically, under third-party investment management arrangements the third-party
investment manager exercises discretion in the management of your account. All
securities transactions are selected and executed by that manager. We do not manage
or obtain discretionary authority over the assets in those accounts. You may, however,
grant us the discretionary authority to hire and fire such third-party managers on your
behalf.
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Item 17 Voting Client Securities
ASN and its IARs do not take any action or give any advice with respect to voting of
proxies solicited by or with respect to the issuers of securities in which your accounts
may be invested. In addition, we do not take any action or give any advice with respect
to any securities held in any accounts that are named in or subject to class action
lawsuits.
You will receive information related to proxies directly from your account custodian.
We will forward to you any information received by us regarding proxies and class
action legal matters involving any securities held in your accounts.
Item 18 Financial Information
We have no financial commitment that impairs our ability to meet contractual and
fiduciary commitments to you. We have not been the subject of any bankruptcy
proceedings.
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