Overview
- Headquarters
- Little Rock, AR
- Average Client Assets
- $2.0 million
- Minimum Account Size
- $100,000
- SEC CRD Number
- 166175
Fee Structure
Primary Fee Schedule (ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 1.00% |
| $250,001 | $500,000 | 0.90% |
| $500,001 | $1,000,000 | 0.80% |
| $1,000,001 | $2,000,000 | 0.70% |
| $2,000,001 | $3,000,000 | 0.60% |
| $3,000,001 | $4,000,000 | 0.50% |
| $4,000,001 | $5,000,000 | 0.40% |
| $5,000,001 | and above | 0.30% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $8,750 | 0.88% |
| $5 million | $30,750 | 0.62% |
| $10 million | $45,750 | 0.46% |
| $50 million | $165,750 | 0.33% |
| $100 million | $315,750 | 0.32% |
Clients
- HNW Share of Firm Assets
- 53.63%
- Total Client Accounts
- 2,200
- Discretionary Accounts
- 2,200
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
Additional Brochure: ADV PART 2A (2026-03-10)
View Document Text
Applied Capital LLC
Form ADV Part 2A
Applied Capital LLC
Firm Brochure – Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Applied Capital
LLC. If you have any questions about the contents of this brochure, please contact Chris Williams,
Chief Compliance Officer, at (501) 500-0897 or by email at: chris.williams@appliedcapital.com. The
information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority. Registration does not imply a certain level
of skill or training.
Additional information about Applied Capital LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. Applied Capital LLC’s CRD number is: 166175. www.appliedcapital.com.
Little Rock Office
415 N. McKinley Street
Suite 1045
Little Rock, AR 72205
501.500.0890
Nashville Office
40 Music Square East
Suite 102
Nashville, TN 37203
615.800.6105
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Item 2: Material Changes
The following material changes have been made in the brochure since the last updating amendment
as of August 2025. Material changes relate to Applied Capital LLC’s policies, practices, or conflicts of
interests.
Item 4: Advisory Services
• Estate Planning - Added basic estate planning as part of advisory services utilizing
Wealth.com.
• SyntheticFi – Clarified usage for a securities-backed lending solution.
Item 5: Fees and Compensation
• Fee Schedule – Updated to new fee schedule to account for additional advisory
services.
• Financial & Estate Planning – Discusses adjusted pricing under the financial planning
agreement reflecting services listed in Item 4, how clients are billed for Wealth.com
and SytheticFi solution, and the manner in which fees are calculated for Financial
Planning, Estate Planning, and SyntheticFi securities-backed lending.
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss
• Digital Assets – Updated guidance to note that the Firm generally discourages direct
crypto-asset exposure in managed portfolios due to volatility, custody, and regulatory
risks.
Item 12: Brokerage Practices
• Factors Used to Select Custodians – Updated the list of custodians used by the Firm.
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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: Advisory Business……………………………………………………………………………………....…5
Item 5: Fees and Compensation……….………………………………………………………...………………7
Item 6: Performance-Based Fees and Side-By-Side Management………………………..…………….....10
Item 7: Types of Clients………………………………………………………………………………………….10
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss……………...….……10
Item 9: Disciplinary Information…………………………………………………………………...…………..11
Item 10: Other Financial Industry Activities and Affiliations……………………...……………………..….12
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading……....12
Item 12: Brokerage Practices…………………………………………………….……………........…………..13
Item 13: Review of Accounts………………………………………………….……………........…………..…14
Item 14: Client Referrals and Other Compensation…………………….……………........…...………...…15
Item 15: Custody…………………………………………………………………………………………………15
Item 16: Investment Discretion…………………………………………….…………….........…….……....…15
Item 17: Voting Client Securities (Proxy Voting) ………………………….…………….........……….….…15
Item 18: Financial Information…………………………………………….…………….........…………..…....16
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Item 4: Advisory Business
A. DESCRIPTION OF THE ADVISORY FIRM
Applied Capital LLC is a Limited Liability Company organized in the state of Arkansas. The firm
was established in January 2013, and the principal owner is Brad Raines.
B. TYPES OF ADVISORY SERVICES
Applied Capital LLC (hereinafter “AC”) offers the following services to advisory clients:
Investment Advisory Services
AC provides continuous investment management and client education regarding the relevant
types of accounts and investment options available. AC assists the client in selecting an
appropriate model portfolio for each account based upon their objectives, time horizon,
experience, and risk tolerance. AC regularly monitors accounts and makes adjustments as
needed. Investment management services include, but are not limited to the following:
1. Investor education
4. Asset allocation
2. Risk tolerance
5. Investment selection
3. Investment strategy
6. Portfolio monitoring
Services Limited to Specific Types of Investments
AC primarily utilizes mutual funds, ETFs, equities, and bonds, but may use other securities
when appropriate to further diversify a portfolio or achieve the client’s investment objective.
The supplemental security types that AC may use when appropriate include, but are not
limited to, private Real Estate Investment Trusts (REITs), interval funds, private credit funds and
structured notes.
Selection of Other Advisors (Sub-Advisors)
We have a sub-advisory relationship with SyntheticFi LLC, an unaffiliated investment advisor
(CRD# 330200/SEC# 801-129765). In exercising our discretion in making investment decisions
for our clients, we may determine if it is in a client’s best interest to engage SyntheticFi to
implement trades in all or a portion of the client’s account. If AC determines that engaging
SyntheticFi is in a client’s best interest, we will provide the client with SyntheticFi’s relevant
disclosure documents, including Form ADV 2A, and any other documents necessary to
provide a complete description of SyntheticFi’s services and fees.
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C. CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS
AC offers the same suite of services to all its clients. However, the implementation of investment
management strategies are dependent upon a client’s specific needs. Clients may impose
restrictions on investing in certain types of securities, in accordance with their values or beliefs.
However, if the restrictions prevent AC from properly servicing the client account, or if the
restrictions would require AC to deviate from its standard suite of services, AC reserves the right to
end the relationship.
D. WRAP FEE PROGRAMS
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and any other administrative fees.
AC does not participate in any wrap fee programs to allow the client to see the different costs of
investing and what is provided in return.
E. AMOUNTS UNDER MANAGEMENT
AC has the following assets under management:
Discretionary Amounts Non-Discretionary Amounts Date
Calculated
$384,567,299
$0
02/28/2026
F. FINANCIAL PLANNING
Financial planning may include the following areas: Retirement planning, investment strategy and
analysis, tax planning and coordination with a CPA or tax professional, education planning, estate
planning, risk management and insurance review, and charitable giving and legacy planning.
Applied Capital will not collect any fee in excess of $1,200 for services to be performed six (6)
months or more in the future.
Clients are under no obligation to act upon the financial planning recommendations provided. In
the event a client elects to implement any such recommendations, there is no requirement to utilize
Applied Capital’s investment advisory services for that purpose. Upon request, we may refer clients
to other qualified professionals. Should the client engage any such recommended professionals,
and a dispute subsequently arises concerning that engagement, the client agrees to pursue
resolution solely with the engaged professional.
Estate Planning
The Firm utilizes the services of Wealth.com, a third-party technology platform that provides
digital estate planning document preparation and related services. Wealth.com offers tools
that assist clients in creating basic estate planning documents (e.g., wills, revocable living
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trusts, powers of attorney, healthcare directives) through an automated document preparation
process. The Firm’s Role is limited to:
• Coordinating access to the platform;
• Assisting clients in understanding how estate planning considerations may relate to
their overall financial plan; and
• Facilitating communication between the client and the platform, where applicable.
Wealth.com is not affiliated with the Firm. The Firm does not provide legal advice and does
not act as an attorney in connection with estate planning matters. The Firm also does not
draft legal documents, provide legal opinions, or guarantee the legal sufficiency of any
documents generated through Wealth.com. Clients are encouraged to consult with their
own attorney regarding the preparation, execution, and suitability of any estate planning
documents. The fee for access is bundled within our financial planning fee. Clients do not pay
Wealth.com directly.
Item 5: Fees and Compensation
A. FEE SCHEDULE
Advisory Fees
Total Assets Under Management
Advisory Fee Tiers
First
Next
Next
Next
Next
Next
Next
Annual
Rate
1.00%
0.90%
0.80%
0.70%
0.60%
0.50%
0.40%
$1,000,000
$0
$2,000,000
$1,000,000
$3,000,000
$2,000,000
$4,000,000
$3,000,000
$4,000,000
$5,000,000
$5,000,000 $10,000,000
$10,000,000
+
Fees are negotiable depending upon the needs of the client and complexity of the situation.
AC has adopted a firmwide tiered fee schedule for consistency and uniformity within the
industry. Only utilizing a tiered fee schedule structure will make it easier for current or
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prospective clients to compare AC’s fees to other firm’s fees within the industry. All legacy fee
schedules are in the process of being phased out and cannot be used for new clients.
Financial Planning Fees
Financial Planning engagements administered by a separate Financial Planning Agreement
are classified into four tiers: Core, Advanced, Strategic, and Collaborative. After reviewing a
client’s circumstances, Applied Capital will provide an annual Financial Planning quote in
advance, based on the anticipated complexity, scope, and objectives of the engagement. The
minimum annual Financial Planning fee is $1,500. The Collaborative category is the most
comprehensive and involves participation from external specialists, such as CPAs and
attorneys. Annual fees for Collaborative engagements may exceed $15,000.
The Financial Planning fee automatically increases annually by three percent. If the client’s
planning needs become more complex, additional increases in the fee amount may apply.
Any changes will be discussed in advance.
Minimum Fee Offset
When a client does not have the required AUM to warrant all the included financial planning
services, a minimum fee offset will facilitate the transition from financial planning services to full
advisory services. The financial planning fee is offset by advisory (AUM) fees paid. If the
advisory fee collected exceeds the financial planning fee, no financial planning fee is charged.
If the advisory fee is less than the financial planning fee, the client is billed the difference.
Quarterly Billing Components:
Financial Planning (quarterly charge)
- Advisory Fee (AUM quarterly fee)
= Net Fee
SyntheticFi
The Firm only utilizes the SyntheticFi platform to offer securities-backed lending solutions
collateralized by the client’s investment portfolio as a similar but more efficient alternative to
traditional margin loans. For billing purposes, the Firm will bill on the amount of the client’s
investment account irrespective of the margin or options loan balance. For example, If the
client has $1,000,000 in an investment account and takes out a $200,000 options loan, the
Firm will bill on the $1,000,000 investment account balance and exclude the $200,000 loan
balance from billing. The Firm does not receive any direct or indirect compensation, revenue
share, or non-cash benefits from SyntheticFi.
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Wealth.com
The Firm pays Wealth.com a licensing / subscription fee for access to the platform. In some
cases, the Firm may absorb this cost as part of its advisory fee. Alternatively, clients are
charged separately for use of the platform.
The Firm does not receive compensation from Wealth.com for recommending or utilizing the
platform. If this arrangement changes and the Firm receives any direct or indirect
compensation, such compensation would create a conflict of interest and would be disclosed
herein.
Legacy Clients
For existing clients, AC’s adoption of a firmwide fee schedule may result in a nominal decrease
or increase to investment management fees charged. To implement this update, existing
clients will be required to sign the current Client Agreement containing the new firmwide fee
schedule. All legacy fee schedules are in the process of being phased out and cannot be used
for new clients.
Client’s total advisory fee may exceed 3.00% annually when accounts are cross billed. Cross-
billing can occur when advisory fees accrued in one account are withdrawn from an alternate
account. Cross-billing may result in an individual account advisory fee in excess of the industry
norm and lower fees for comparable services may be available from other sources.
Clients may terminate their relationship with AC within 10 days of signing the client agreement
with no advisory fees assessed. Either party may terminate the client agreement at any time
with written notice. Advisory fees are paid quarterly in arrears; therefore, no refund policy is
necessary.
In cases where advisory fees are directly deducted, AC will obtain client authorization and
request custodian to deduct advisory fees from client accounts. Advisory fees are itemized on
monthly custodian statements which serve as the invoice.
B. FEE CALCULATION & VALUATION
The firm’s investment advisory fees have always been charged quarterly in arrears using the
average daily balance. When an account’s daily valuation is not attainable as with some held-away
accounts (i.e. 401k, 403b, TSP, 529), account values will be generated from monthly or quarterly
statements. The period used to calculate fees will be the annual fee divided by 4 equal quarters
versus days in the quarter. An advisor may exclude specific holdings or accounts from billing. A
new client agreement is required to change the fee schedule.
The CCO will periodically review the pricing data of holdings at the custodian. A random sampling
of securities will be selected from the custodian, and the pricing data will be compared to a few
other sources. Any significant differences will be investigated.
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Financial Planning
For Financial planning, an annual fixed fee, paid monthly, for ongoing planning and advisory
services is charged. Fees are based on the complexity of the client’s needs and automatically
adjust annually.
Minimum Fee Offset
Refer to the description and calculation of the minimum fee offset in Section 5.A above. Our
advisory clients who also use our financial planning services are billed quarterly in arrears through
AdvicePay, by ACH, credit card, or debit card.
C. PAYMENT OF FEES
Payment of Investment Advisory Fees
Advisory fees are withdrawn directly from the Accounts with client’s written authorization. Under
special circumstances, clients may choose to have their advisory fees invoiced and billed directly
with payment due within thirty days of invoice date.
Additionally, fees accrued by one account may be allocated to other client accounts to better
achieve client’s investment objective or improve tax efficiency.
D. CLIENTS ARE RESPONSIBLE FOR THIRD-PARTY FEES
Clients are responsible for the payment of all third-party fees (i.e., custodian fees, brokerage fees,
mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and
expenses charged by AC. Please see Item 12 of this brochure regarding broker/custodian.
E. PREPAYMENT OF FEES
AC collects its fees in arrears. The Firm does not collect fees in advance.
G. OUTSIDE COMPENSATION FOR THE SALE OF SECURITIES TO CLIENTS
AC’s investment advisors may be licensed insurance agents and could accept compensation for
the sale of insurance products to AC clients.
This is a Conflict of Interest
The investment advisor may accept compensation for the sale of insurance products in their
capacity as a licensed insurance agent. This presents a conflict of interest and gives the advisor
an incentive to recommend products based on the compensation received rather than on the
client’s needs. We mitigate this risk by disclosing the conflict, placing the client’s interests first,
and making recommendations consistent with the client’s plan.
Clients Have the Option to Purchase Recommended Products From Other Brokers
Clients always have the option to purchase AC recommended products through other brokers
or agents that are not affiliated with AC.
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Commissions are not the Primary Source of Income for AC
Commissions are not accepted by AC, as they are only paid to individually licensed agents for
insurance products only.
Advisory Fees in Addition to Commissions or Markups
Advisory fees that are charged to clients are not reduced to offset the commissions or markups
on insurance products or investment products recommended to clients.
Item 6: Performance-Based Fees and Side-By-Side
Management
AC does not accept performance-based fees or other fees based on a share of capital gains on or
capital appreciation of the assets of a client.
Item 7: Types of Clients
AC generally provides investment advice and/or management supervisory services to the following
types of clients: Individuals and High-Net-Worth Individuals.
Minimum Account Size
AC has a preferred account minimum of $100,000.
Item 8: Methods of Analysis, Investment Strategies, and Risk
of Investment Loss
A. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
Methods and Strategies
AC primarily utilizes long-term asset allocation and diversification, informed by historical index
performance and capital market assumptions. Portfolios may use market-cap-weighted index
exposures and, where appropriate, modest tilts toward factors with higher expected returns.
B. MATERIAL RISKS INVOLVED
A diversified, index-based approach can underperform historical returns or concentrated
strategies. All investing involves risk, including the possible loss of principal.
C. RISKS OF SPECIFIC SECURITIES
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AC generally seeks investment strategies that do not involve significant or unusual risk beyond
that of the general equity and fixed income markets. However, AC may recommend vetted
alternative investments to select clients that complement their core portfolio.
Alternative Investments
Alternative investments such as REIT funds, interval funds, private credit funds, and structured
notes may involve additional risk primarily due to their lack of daily liquidity. The market to resell
these assets under applicable securities laws may be less liquid, and liquidation may be taken at a
substantial discount to the underlying value or result in the entire loss of the value of such assets.
Structured Notes
Structured notes can provide capital appreciation tied to equity indices, various levels of downside
protection to said index, and income or principal protection. However, structured notes also
expose investors to credit risk. If the structured note issuer defaults on these obligations, investors
may lose some, or all, of the principal amount they invested in the structured notes as well as any
payments that may be due on the structured notes. If a structured note has a “call provision” and
the issuer “calls” the structured note, investors may not be able to reinvest their money at the same
rate of return provided by the structured note that the issuer redeemed. When a client agrees to a
structured note investment strategy, the firm executes a structured notes agreement which
describes in detail the risks and rewards associated with this particular investment strategy.
Digital Assets
We advise clients against allocating to or holding direct crypto assets within their investment
portfolios due to heightened volatility, custody and operations risks, regulatory uncertainty,
valuation complexities, and potential concentration risk.
Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss
that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. CRIMINAL OR CIVIL ACTIONS
There are no criminal or civil actions to report.
B. ADMINISTRATIVE PROCEEDINGS
There are no administrative proceedings to report.
C. SELF-REGULATORY ORGANIZATION (SRO) PROCEEDINGS
There are no self-regulatory organization proceedings to report.
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Item 10: Other Financial Industry Activities and Affiliations
A. REGISTRATION AS A BROKER/DEALER OR BROKER/DEALER REPRESENTATIVE
Neither AC nor its representatives are registered as or have pending applications to become a
broker/dealer or as representatives of a broker/dealer.
B. REGISTRATION AS A FUTURES COMMISSION MERCHANT, COMMODITY POOL OPERATOR,
OR A COMMODITY TRADING ADVISOR
Neither AC nor its representatives are registered as or have pending applications to become a
Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor.
C. REGISTRATION RELATIONSHIPS MATERIAL TO AC AND POSSIBLE CONFLICTS OF
INTEREST
All investment advisors in their roles as licensed insurance agents may accept compensation for
the sale of insurance products to AC clients.
David Cleveland is the owner of Cleveland Accounting & Consulting, PA. From time to time, he
may offer clients advice or products from those activities and clients should be aware that these
services may involve a conflict of interest. AC always acts in the best interest of the client and
clients always have the right to decide whether or not to utilize the services of any representative
of AC in such individual’s outside capacities.
David Cleveland is a certified accountant. From time to time, they will offer clients advice or
products from this activity. AC always acts in the best interest of the client. Clients are in no way
required to utilize the services of any representative of AC in their capacity as an accountant.
SyntheticFi, a sub-advisor / platform may be engaged to implement certain strategies or facilitate
services such as securities-backed lines of credit secured by portfolio assets. AC and its
supervised persons do not receive compensation, revenue share, or non-cash benefits in
connection with SyntheticFi. Clients pay interest and any lender-program fees. Borrowing against
securities magnifies risk; market declines can trigger collateral call or forced liquidation.
Borrowing may have tax consequences. The Firm will bill AUM fees on gross asset value,
irrespective of the margin balance.
D. SELECTION OF OTHER ADVISORS AND HOW THIS ADVISOR IS COMPENSATED FOR
THOSE SELECTIONS
AC may utilize or recommend third-party sub-advisors (e.g., SyntheticFi) when we believe it is in
the client’s best interest. We conduct due diligence and monitor any sub-advisor engaged. We
do not receive compensation for such selections.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. CODE OF ETHICS
We have a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales,
Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities,
Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors,
Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting,
Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and
Education, Recordkeeping, Annual Review, and Sanctions. Our Code of Ethics is available free
upon request to any client or prospective client.
B. RECOMMENDATIONS INVOLVING MATERIAL FINANCIAL INTERESTS
AC does not recommend that clients buy or sell any security in which a related person to AC or AC
has a material financial interest.
C. INVESTING PERSONAL MONEY IN THE SAME SECURITIES AS CLIENTS
From time to time, representatives of AC may buy or sell securities for themselves that they also
recommend to clients. This may provide an opportunity for representatives of AC to buy or sell the
same securities before or after recommending the same securities to clients resulting in
representatives profiting off the recommendations they provide to clients. Such transactions may
create a conflict of interest. AC mitigates this risk through our Code of Ethics and by placing client
transactions ahead of personal transactions. AC will always document any transactions that could
be construed as conflicts of interest and will always transact client business before their own when
similar securities are being bought or sold.
D. TRADING SECURITIES AT/AROUND THE SAME TIME AS CLIENT’S SECURITIES
From time to time, representatives of AC may buy or sell securities for themselves at or around the
same time as clients. This may provide an opportunity for representatives of AC to buy or sell
securities before or after recommending securities to clients resulting in representatives profiting
off the recommendations they provide to clients. Such transactions may create a conflict of
interest. AC will always transact client’s transactions before its own when similar securities are
being bought or sold.
Item 12: Brokerage Practices
A. FACTORS USED TO SELECT CUSTODIANS
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The following custodians are recommended by AC: Charles Schwab & Co., Inc. (CRD #5393), TIAA
Individual & Institutional Services, LLC (CRD #20472), Fidelity Investments Institutional Services
Company, Inc. (CRD #17507), and Altruist LLC (CRD #299398). These are recommended based on
their relatively low transaction fees, access to mutual funds and ETFs and industry reputation. AC
will never charge a premium or commission on transactions, beyond the actual cost imposed by
custodian.
Research and Other Soft-Dollar Benefits
AC receives research, products, or other services from its custodian or another third-party in
connection with client securities transactions (“soft dollar benefits”). There is no minimum client
number or dollar number that AC must meet to receive free research from the custodian.
There is no incentive for AC to direct clients to a particular custodian over other custodians
who offer the same services. However, because this firm does not have to produce or pay for
services or products it has an incentive to choose a custodian that provides those services
based on its interests rather than the clients’ interests. The first consideration when
recommending custodians to clients is best execution. AC always acts in the best interest of
the client.
Brokerage for Client Referrals
AC receives no referrals from a custodian or third party in exchange for using that custodian or
third-party.
Clients Directing Which Custodian to Use
AC recommends the use of the custodians mentioned above in part A. When clients choose to
direct brokerage, AC may be unable to achieve most favorable execution of client transactions.
This may cost clients’ money because without the ability to direct brokerage, AC may not be
able to aggregate orders to reduce transactions costs resulting in higher brokerage
commissions and less favorable prices. Not all investment advisors allow their clients to direct
brokerage.
B. AGGREGATING (BLOCK) TRADING FOR MULTIPLE CLIENT ACCOUNTS
AC maintains the ability to block trade purchases across accounts. Block trading may benefit a
large group of clients by providing AC the ability to purchase larger blocks resulting in smaller
transaction costs to the client. Declining to block trade can cause more expensive trades for
clients.
Item 13: Review of Accounts
A. FREQUENCY AND NATURE OF PERIODIC REVIEWS AND WHO MAKES THOSE REVIEWS
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AC’s Principal Financial Advisors will perform periodic reviews of their office’s client accounts at
least monthly regarding the client's stated investment objectives and risk tolerance.
B. FACTORS THAT WILL TRIGGER A NON-PERIODIC REVIEW OF CLIENT ACCOUNTS
Reviews may also be triggered by material market, economic or political events, or by changes in
client's financial situations.
C. CONTENT AND FREQUENCY OF REGULAR REPORTS PROVIDED TO CLIENTS
Each client whose assets are managed by AC will receive a paper or electronic statement from the
custodian at least monthly with details of the client’s account including assets held and asset value.
Item 14: Client Referrals and Other Compensation
A. ECONOMIC BENEFITS PROVIDED BY THIRD PARTIES FOR ADVICE RENDERED TO CLIENTS
AC does not receive any economic benefit, directly or indirectly from any third party for advice
rendered to AC clients, other than the services/benefits described in item 12.
B. COMPENSATION TO NON-ADVISORY PERSONNEL FOR CLIENT REFERRALS
AC does not compensate third parties for client referrals.
Item 15: Custody
AC, with client written authority, has limited custody of client’s assets through direct fee deduction of
AC’s fees only. If fees are withdrawn directly from the client’s account at the custodian, AC would
have constructive custody over that account and must have written authorization from the client to do
so. Clients will receive all account statements and billing invoices that are required in each jurisdiction,
and they should carefully review those statements for accuracy.
Item 16: Investment Discretion
For those client accounts where AC will have investment discretion, the client has given AC written
discretionary authority over the client’s accounts with respect to securities to be bought or sold and
the amount of securities to be bought or sold. Details of this relationship are fully disclosed to the
client before any advisory relationship has commenced. The client provides AC discretionary authority
via a discretionary investment management clause in the Client Agreement and/or a limited power of
attorney clause in the contract between the client and the custodian.
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Item 17: Voting Client Securities (Proxy Voting)
AC will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly
from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer
of the security.
Item 18: Financial Information
A. BALANCE SHEET
AC does not require nor solicit prepayment of more than $1,200 in fees per client, six months or
more in advance and therefore does not need to include a balance sheet with this brochure.
B. FINANCIAL CONDITIONS REASONABLY LIKELY TO IMPAIR ABILITY TO MEET
CONTRACTUAL COMMITMENT TO CLIENTS
Neither AC nor its management have any financial conditions that is likely to reasonably impair our
ability to meet contractual commitments to clients.
C. BANKRUPTCY PETITIONS IN PREVIOUS TEN YEARS
AC has never been the subject of a bankruptcy petition.
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