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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 material changes in the brochure from the last updating amendment of Applied Capital LLC as of
July 2024 are described below. Material changes relate to Applied Capital LLC’s policies, practices,
or conflicts of interests.
• Applied Capital LLC has updated the following sections:
o
o
Item 4: Advisory Business
Item 5: Fees and Compensation
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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
A. Description of the Advisory Firm……………………………………………………………………...…5
B. Types of Advisory Services……………………………………………………………………...………..5
C. Client Tailored Services and Client Imposed Restrictions…………………………………...……….6
D. Wrap Fee Programs……………………………………………………………………………………….6
E. Amounts Under Mangement..…………………………………………………………...........…………6
F. Financial Planning…………………………………………………………………………………………6
Item 5: Fees and Compensation……….………………………………………………………...………………7
A. Fee Schedule…………………………………………………………………………………………...….7
Investment Advisory Fees…………………………………………………………...…………………7
Fee-for-Service Model………………………………………………………………………………….7
Full-Service Model………………………………………………………………………………………8
Legacy Clients………………………………………………………………………………………...…8
B. Fee Calculation and Valuation……………………..………………………………………………...….8
Fee-for-Service Model………………………………………………………………………………….9
Full Service Model………………………………………………………………………….………...…9
C. Payment of Fees………………………………………………………………………………….……..…9
D. Clients are Responsible for Third-Party Fees…………………………………………………………..9
E. Prepayment of Fees……………………………………………………………………………………….9
F. Outside Compensation for the Sale of Securities to Clients…………………………………………9
This is a Conflict of Interest………………………………………………………………………….…9
Clients Have the Option to Purchase Recommended Products From Other Brokers……..…10
Commissions are not the Primary Source of Income for AC…………………………….……….10
Advisory Fees in Addition to Commissions or Markups…………………………………….…....10
Item 6: Performance-Based Fees and Side-By-Side Management………………………..…………….....10
Item 7: Types of Clients……………………………………………………………………………………….…10
Minimum Account Size……………………………………………………………………………..…10
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss……………...….……10
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A. Methods of Analysis and Investment Strategies……………………………………………………10
Methods of Analysis…………………………………………………………………………….……10
Investment Strategies……………………………………………………………………………..…10
B. Material Risks Involved………………………………………………………………………..………..11
Methods of Analysis………………………………………………………………….………..……..11
Investment Strategies………………………………………………………………………………..11
C. Risks of Specific Securities…………………………………………………………………………..…11
Item 9: Disciplinary Information…………………………………………………………………...………..…11
A. Criminal or Civil Actions………………………………………………………….………………….…11
B. Administrative Proceedings………………………………………………………….…………..……11
C. Self Regulatory Organizations (SRO) Proceedings……………………………………..…………..12
Item 10: Other Financial Industry Adtivities and Affiliations……………………...……………………..…12
A. Registration as a Broker/Dealer or Broker/Dealer Representative……………………...……..…12
B. Registration as a Futures Commission Merchant, Commodity Pool Operator
or a Commodity Trading Advisor…………………………………………………………………..…12
C. Registration Relationships Material to AC and Possible Conflicts of Interest…………….…..…12
D. Selection of Other Advisors and How This Advisor Is Compensated For Those Selections…..12
Item 11: Code of Ethics, Partiicpation or Interest in Client Transactions and Personal Trading……....12
A. Code of Ethics……………………………………………………………….……………........………..13
B. Recommendations Involving material Financial Interests…………………………..……………..13
C. Investing Personal Money in the Same Securities as Clients………….……………........………..13
D. Trading Securities At/Around the Same Time as Client’s Securities….……………........…….....13
Item 12: Brokerage Practicies…………………………………………………….……………........…………13
A. Factors Used to Select Custodians………………………….………….………...……..........………13
Research and Other Soft-Dollar Benefits………………………………….……………........………14
Brokerage for Client Referrals……………………………………………….……………........……...14
Clients Directing Which Custodian to Use………………...…………….……………........…….….14
B. Aggregating (Block) Trading for Multiple Client Accounts………….……………........…….…....14
Item 13: Review of Accounts………………………………………………….……………........…………..…14
A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews........……………..14
B. Factors That will Trigger a Non-periodic Review of Client Accounts…………….......…………..14
C. Content and Frequency of Regular Reports Proided to Clients.……………........………………14
Item 14: Client Referrals and Other Compensation…………………….……………........………………..15
A. Ecomonomic Benefits Provided by Third Parties for Advice Rendered to Clients……………..15
B. Compensation to Non-Advisory Personnel For Client Referrals…………........………….………15
Item 15: Custody…………………………………………………………………………………………………15
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Item 16: Investment Discrection…………………………………………….…………….........………….….15
Item 17: Voting Client Securities (Proxy Voting) ………………………….…………….........……….….…15
Item 18: Financial Information…………………………………………….…………….........…………..…...16
A. Balance Sheet………………………………………………………….……………........……………..16
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual
Commitment to Clients………………………………………………………………………………...16
C. Bankruptcy Petitions in Previous 10 Years…………………….…………….........…………………16
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 Supervisory 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
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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, Privacy policy and any other documents
necessary to provide a complete description of SyntheticFi’s services and fees.
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 is dependent upon the client specific needs, objectives, time horizon, experience,
and risk tolerance. Clients may impose restrictions in investing in certain securities or 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
$293,411,421
$0
12/31/2024
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,
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and a dispute subsequently arise concerning that engagement, the client agrees to pursue
resolution solely with the engaged professional.
Item 5: Fees and Compensation
A. FEE SCHEDULE
Investment Advisory Fees
Total Assets Under Management
First
Next
Next
Next
Next
Next
Next
Next
Annual Rate
1.00%
0.90%
0.80%
0.70%
0.60%
0.50%
0.40%
0.30%
Advisory Fee Tiers
$250,000
$0
$500,000
$250,000
$1,000,000
$500,000
$1,000,000 $2,000,000
$2,000,000 $3,000,000
$3,000,000 $4,000,000
$4,000,000 $5,000,000
$5,000,000
+
Fees are negotiable depending upon the needs of the client and complexity of the situation.
After previously utilizing both breakpoint and tiered fee schedules, 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 prospective clients to compare AC’s
fees to other firm’s fees within the industry. All breakpoint fee schedules are in the process of
being phased out and cannot be used for new clients.
Fee-for-Service Model
Fee-for-Service engagements are classified into four categories: Core, Advanced, Strategic,
and Collaborative. After reviewing a client’s circumstances, Applied Capital will provide an
annual Fee-for-Service quote in advance, based on the anticipated complexity, scope, and
objectives of the engagement. The minimum annual Fee-for-Service 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.
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The Fee-for-Service Model fee automatically increases annually by three percent. If the client’s
planning needs become more complex, additional increases in the Fee-for-Service amount
may apply. Any changes will be discussed in advance.
Full-Service Model
This model bundles financial planning and investment management together. The Fee-for-
Service amount is offset by investment management (AUM) fees paid. If the AUM fee collected
exceeds the planning fee, no Fee-for-Service fee is charged. If the AUM fee is less than the
planning fee, the client is billed the difference.
Quarterly Billing Components:
Fee-for-Service (quarterly charge)
- Assets Under Management (quarterly fee)
= Net Fee-for-Service
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. The quarter-end balance is used when an account’s daily valuation is not
attainable as with linked 401(k) or 403(b) accounts. 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.
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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.
Fee-for-Service Model
This model charges an annual fixed-fee, paid monthly, for ongoing planning and advisory services.
Fees are based on the complexity of the client’s needs and automatically adjust annually.
Full-Service Model
Investment Management clients who also use our financial planning services are billed quarterly in
arrears by ACH, credit card, or debit card, rather than monthly as with Fee-for-Service–only clients.
A Fee-for-Service quote is provided in advance and is based on the expected complexity, scope,
and objectives of the engagement.
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. It 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
supervised person an incentive to recommend products based on the compensation received
rather than on the client’s needs. When recommending the sale of insurance products for
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which the investment advisor will receive compensation, they will inform the client of the
conflict of interest.
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.
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 of Analysis
AC primarily utilizes historical index performance data to determine an optimal risk-adjusted
projected return for the investment allocation.
Investment Strategies
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AC primarily focuses on asset allocation and diversification. AC may then employ a market-cap
weighted index approach or moderately tilt towards areas of higher expected return.
B. MATERIAL RISKS INVOLVED
Methods of Analysis
The primary risk in utilizing a diversified, index-based approach to asset allocation is that future
returns of the indices are lower than their historical performance.
Investment Strategies
The risk of a diversified asset allocation is that the market fluctuation or return may be
noticeably different than that of a concentrated investment or type of security.
C. RISKS OF SPECIFIC SECURITIES
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 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 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.
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
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There are no administrative proceedings to report.
C. SELF-REGULATORY ORGANIZATION (SRO) PROCEEDINGS
There are no self-regulatory organization proceedings to report.
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.
D. SELECTION OF OTHER ADVISORS AND HOW THIS ADVISOR IS COMPENSATED FOR
THOSE SELECTIONS
AC does not utilize nor select third-party investment advisors. All assets are directly managed by
AC.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
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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 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
The following custodians are recommended by AC: TD Ameritrade Institutional, a division of TD
Ameritrade Inc. (CRD #7870) Member FINRA/SIPC, TIAA Individual & Institutional Services, LLC
(CRD #20472), Fidelity Investments Institutional Services Company, Inc. (CRD #17507), and
Charles Schwab & Co., Inc. (CRD #5393). 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.
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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
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
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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.
B. COMPENSATION TO NON-ADVISORY PERSONNEL FOR CLIENT REFERRALS
AC may compensate individuals for client referrals for a predetermined fixed fee. Clients will never
incur higher fees due from a referral relationship and any referral relationship will be fully
disclosed to each referred client. AC will always act in the best interest of the client.
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.
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.
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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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