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FIRM BROCHURE
(Part 2A of Form ADV)
January 23, 2026
ASCENSION WEALTH PARTNERS, LLC
CORPORATE HEADQUARTERS:
391 Taylor Boulevard, Suite 125
Pleasant Hill, CA 94523
Telephone (925) 798-7200
Fax (925) 798-7272
www.ascensionwp.com
Part 2A of Form ADV (the “Brochure”) provides information about the qualifications and
business practices of Ascension Wealth Partners, LLC. If you have any questions about the
contents of this Brochure, please contact us at (925) 798-7200. 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.
Ascension Wealth Partners, LLC is registered as an investment adviser with the Securities
and Exchange Commission (“SEC”); however, such registration does not imply a certain
level of skill or training and no inference to the contrary should be made.
Additional information about Ascension Wealth Partners, LLC and our investment adviser
representatives are also available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 1: COVER PAGE
Please refer to previous page.
ITEM 2: MATERIAL CHANGES
Ascension Wealth Partners, LLC, (“Ascension” or “the Firm”) has made the following amendments
to this Brochure:
Item 4 – Advisory Business – To reflect the Firm’s updated assets under management;
The last version of this Brochure was dated March 7, 2025. Our prospective clients are strongly
encouraged to read this Brochure in its entirety prior to engaging Ascension for any advisory services.
Pursuant to state regulations, Ascension will ensure that clients receive a summary of any materials
changes to this Brochure within 120 days of the close of Ascension’s fiscal year, along with a copy of
this Brochure or an offer to provide the Brochure. Ascension’s Brochure and Supplemental Brochures
(information regarding Ascension’s investment adviser representatives) are available anytime upon
request or at the SEC’s website at www.adviserinfo.sec.gov.
Ascension Wealth Partners, LLC
Form ADV Part 2A
ITEM 3: TABLE OF CONTENTS
Item Number
Page
ITEM 1: COVER PAGE ................................................................................................................................................... 2
ITEM 2: MATERIAL CHANGES .................................................................................................................................. 2
ITEM 3: TABLE OF CONTENTS .................................................................................................................................. 3
ITEM 4: ADVISORY BUSINESS .................................................................................................................................... 4
ITEM 5: FEES AND COMPENSATION ........................................................................................................................ 5
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................. 7
ITEM 7: TYPES OF CLIENTS ....................................................................................................................................... 7
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .............................. 8
ITEM 9: DISCIPLINARY INFORMATION ............................................................................................................... 12
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 ......................................................................................................................... 19
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ................................................................... 19
ITEM 15: CUSTODY ..................................................................................................................................................... 20
ITEM 16: INVESTMENT DISCRETION ................................................................................................................... 20
ITEM 17: VOTING CLIENT SECURITIES .............................................................................................................. 21
ITEM 18: FINANCIAL INFORMATION ................................................................................................................... 21
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Item 4: Advisory Business
A. Description of Firm
Ascension Wealth Partners, LLC (“Ascension”) is a Pleasant Hill, California-based investment
advisory firm, founded in 2008. Ascension offers investment management services to individuals,
high net worth individuals, trusts, estates, pension and profit-sharing plans, and various business
entities like corporations, partnerships and limited liability companies.
We are currently registered with the SEC as an investment adviser and conduct business in the State
of California as reflected in Part 1 of our Form ADV, a copy of which can be found on
www.adviserinfo.sec.gov.
B. Principal Owners
Kory K. Swekla and Michael R. Sappington are the principal owners (each owning over 25%) of the
firm, and as such are control persons of Ascension.
C. Types of Advisory Services Offered
Ascension offers investment management services on a discretionary basis. At the beginning of the
client relationship, a representative of Ascension will conduct a personal interview with the client to
discuss and evaluate the client’s investment objectives, individual risk tolerance, investment timeline,
specific restrictions and any other information relevant to the management of the client’s account.
Ascension also requires each client to complete an Account Questionnaire, which assists us with
determining a client’s overall investment guidelines and asset allocation strategy. Ascension
summarizes all collected information in a written Investment Policy Statement that outlines how
Ascension will managed the client’s assets.
Ascension then constructs and manages each client’s account in accordance with:
- The client’s investment objectives and other guidelines contained in their Investment Policy
Statement and Account Questionnaires; and
- Ascension’s investment policies, strategies and investment management techniques.
The securities utilized by Ascension for investment in client accounts mainly consist of registered
mutual funds, but we can also include exchange traded funds (ETFs), equity securities, corporate
bonds, foreign securities, municipal securities and variable annuities, among others, if we determine
such investments fit within a client’s objectives and are in the best interest of our clients. Please refer
to Item 8 for detailed information on our method of analysis and the risks involved with these types of
securities.
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D. Advisory Agreements
Prior to engaging Ascension to provide investment management services, clients are required to enter
into an Investment Management Agreement (the “Agreement”) with Ascension setting forth the terms
and conditions of the engagement, the fees to be paid and the scope of the services to be provided.
A client can terminate their Agreement by providing Ascension with a written notice of termination.
Upon receipt of written notice of termination from the client, we will immediately cease to actively
manage the client’s account and will cease assessment of advisory fees as of that date.
E. Amount of Client Assets Managed
As of December 31, 2025, the following represents the total amount of client assets under
management (“AUM”) by Ascension on a discretionary and non-discretionary basis:
Type of Account
Assets Under Management
(“AUM”)
Discretionary
Non-Discretionary
Total
$ 136,895,746.00
$0
$ 136,895,746.00
ITEM 5: FEES AND COMPENSATION
A. Advisory Fees
Ascension charges a quarterly advisory fee, which is billed in arrears and based upon a percentage of
a client’s assets under management with Ascension. Fees are calculated as follows:
Advisory Fee (% AUM)
The greater of 0.275%
0.25%
0.2125%
0.1625%
Assets Under Management
Up to the first $1,000,000
Assets exceeding $1,000,000 up
to $2,000,0000
Assets exceeding $2,000,000 up
to $5,000,000
Assets exceeding $5,000,000 up
to $10,000,000
Assets exceeding $10,000,000
0.125%
For purposes of calculating assets under management and advisory fees, Ascension will consider all
investment management accounts which constitute the “household” of the client’s assets. Typically, a
client’s household consists of any spouse, parent, child, partner or sibling who resides at the same
mailing address as the client. In certain circumstances, we can or will, from time-to-time discount
advisory fees for non-household relatives of the client as determined in our sole discretion. For
family members and long-term friends of Ascension, this fee can be zero. All advisory fees are
negotiable in the sole discretion of Ascension.
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B. Other Fees or Expenses
The actual fees charged a client will be outlined in the written Agreement entered into between
Ascension and the client.
All fees paid to Ascension for the various services we provide to clients are separate and distinct from
the fees and expenses charged by third parties. These separate fees and expenses include, but are not
limited to, custodial fees, execution costs, and mutual fund fees and expenses. Client assets also can
or will be subject to transaction fees, brokerage fees and commissions, retirement plan administration
fees (if applicable), trustee fees, deferred sales charges on mutual funds initially deposited in the
account, 12b-1 fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and
other fees and taxes on brokerage accounts and securities transactions. For mutual funds and
exchange traded funds, a client can be charged internal management fees, distribution fees,
redemption fees and other expenses, which are fully described in the applicable fund’s prospectus.
Notably, Ascension does not receive any portion of these other fees and expenses.
Clients should review the fees charged to their account(s) to fully understand the total amount of all
fees charged. Clients should understand that lower fees for comparable services can be available from
other investment advisory firms.
C. Billing Arrangements
Unless otherwise arranged by the client, our advisory fees are automatically deducted from a client’s
account by the custodian of the account upon receipt of an invoice from us and as soon as reasonably
practicable after the end of each calendar quarter. For accounts opened or closed after the beginning
of a new calendar quarter, our fees will be prorated.
Ascension will remit a copy of the invoice to the client showing the amount of the fee, the value of
the client’s assets on which the fee was based, and the specific manner in which the fee was
calculated. It is the client’s responsibility to verify the accuracy of the fee calculation as the custodian
will not determine whether the fee is properly calculated. Clients authorize their custodian in writing
to deduct our advisory fees from their account upon execution of the Agreement with Ascension. All
investment advisory fees paid directly to Ascension will be clearly reflected on the client’s periodic
brokerage statements that are prepared and sent to the client by the custodian. In the event that
Ascension is unable to collect from the custodian any advisory fees due, Ascension will bill the client
for that amount.
D. Important Considerations
Ascension will provide a current copy of Form ADV Part 2A and relevant brochure supplements
(Form ADV Part 2B) to each client or prospective client prior to or as the same time as the execution
of a written Agreement with us. Any client who has not received a copy of our Form ADV Part 2A at
least forty-eight (48) hours prior to executing an Agreement with us, shall have five (5) business days
after executing the agreement to terminate our services without penalty. After that, the written
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agreement between Ascension and the client will continue in effect until terminated by either party
pursuant to the terms of the Agreement. Any pre-paid unearned advisory fees will be refunded to the
client.
Neither Ascension nor the client can assign the written agreement without the consent of the other
party. Transactions that do not result in a change of actual control or management of Ascension shall
not be considered an assignment.
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Ascension does not charge performance-based fees (i.e., fees calculated based on a share of capital
gains on or capital appreciation of the client’s assets or any portion of the client’s assets).
Consequently, we do not engage in side-by-side management of accounts that are charged a
performance-based fee with accounts that are charged another type of fee (such as assets under
management). As described above, we provide our services for an advisory fee that is based upon a
percentage of a client’s assets under management, which is in accordance with state and federal
requirements. Notably, accounts that are managed in the same style (e.g., moderately aggressive)
perhaps will not be managed the same way due to the client's overall investment objective, discretion
of the investment professional assigned to the account, asset size and account restrictions.
ITEM 7: TYPES OF CLIENTS
A. Description
Ascension generally provides investment advice to individuals, trusts, estates, pension and profit-
sharing plans, and various business entities like corporations, partnerships and limited liability
companies.
B. Conditions for Managing Accounts
Although Ascension does not have an account minimum dollar requirement, all client relationships
(households) are subject to a minimum quarterly fee. See “Fees and Compensation” under Item 5
above.
There can be times when certain restrictions are placed by a client, which prevents us from accepting
or continuing to manage their account. Ascension reserves the right to not accept and/or terminate
management of a client’s account if we feel that the client-imposed restrictions would limit or prevent
us from meeting and/or maintaining the client’s overall investment guidelines or our investment
strategies.
C. Disclosure to ERISA Plan Sponsors under Section 408(b)(2)
If a Client’s account is a pension or other employee benefit plan governed by the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”), Ascension can be a fiduciary to the
plan. In providing our investment management services, the sole standard of care imposed upon us is
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to act with the care, skill, prudence and diligence under the circumstances then prevailing that a
prudent man acting in a like capacity and familiar with such matters would use in the conduct of an
enterprise of a like character and with like aims. Ascension will provide certain required disclosures
to the “responsible plan fiduciary” (as such term is defined in ERISA) in accordance with Section
408(b)(2), regarding the services we provide and the direct and indirect compensation we receive by
such clients. Generally, these disclosures are contained in this Form ADV Part 2A, the client
agreement and/or in separate ERISA disclosure documents and are designed to enable the ERISA
plan’s fiduciary to: (1) determine the reasonableness of all compensation received by Ascension; (2)
identify any potential conflicts of interests; and (3) satisfy reporting and disclosure requirements to
plan participants.
D. Disclosure of Investment Retirement Accounts (“IRAs”)
Ascension provides advice relative to individual Investment Retirement Accounts (“IRA”) and is
dedicated to assisting clients with making informed decisions about their retirement needs. The Firm
will discuss the pros and cons of moving assets from a retirement plan (e.g., 401(k)/403b/457 plans)
to an IRA rollover managed by Ascension versus leaving the assets within the retirement plan.
When the Firm provides investment advice regarding retirement plan accounts or individual
retirement accounts, we are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way we make money creates some conflicts with the interests of our clients,
so we operate under a special rule that requires us to act in the client’s best interest and not put our
interest ahead of the client. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of the client when making recommendations (give
loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in the client’s
best interest;
• Charge no more than is reasonable for our services; and
• Give the client basic information about conflicts of interest.
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
A. Methods of Analysis
Ascension will primarily invest in client’s assets in registered mutual funds. We conduct a thorough
analysis of all securities purchased for client accounts. When evaluating the merits of a mutual fund,
Ascension focuses on two aspects, the fund’s investment adviser and the fund itself.
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Mutual Fund Investment Adviser
Ascension reviews the following aspects of each fund’s investment adviser to assess its efficiency and
effectiveness:
- Management Structure;
- Financial Condition; and
- Operating Procedures.
Mutual Fund
For each mutual fund, Ascension generally reviews the following aspects:
- Adherence to the investment objectives stated in its prospectus;
- Portfolio of securities;
- Past performance;
- Portfolio turnover;
- Growth in total assets;
- Management expense;
- Purchase and sale fees; and
- Administrative fees.
Ascension uses the following sources of information to analyze securities:
- Financial newspapers and magazines;
- Research materials provided by others including information provided by subscription
services;
- SEC filings;
- Company press releases;
- Sales activities data;
-
-
Interviews with mutual fund investment advisers and sponsoring organizations; and
Information provided by mutual funds’ investment advisers (e.g. prospectuses and interim
and annual reports).
B. Investment Strategies
Ascension follows a general systematic investment strategy using the following steps:
- Based on a client’s investment objectives and risk tolerance, Ascension will determine a
suitable allocation between fixed income investments and equities, mainly utilizing mutual
funds. This allocation should not change unless the client’s investment objectives or risk
tolerance changes.
- For each client account, Ascension will determine strategic asset allocation targets for each
asset class utilized in a client’s account. This will partly be based on the client’s
investment objectives and risk tolerance but will also be based on Ascension’s analysis of
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the long-term risk/return characteristics of each asset class. We will not begin constructing
a client’s account portfolio until the client approves the asset class allocation model.
- Once the asset class allocation model is approved by the client, we begin constructing the
client’s account portfolio in accordance with the model.
- Once the portfolio is constructed, Ascension rebalances the account by utilizing
“Tolerance Bands.” By specifying a Tolerance Band for each asset class and rebalancing
as needed, Ascension is able to maintain the client’s portfolio in-line with the original
asset allocation model. Not only will this approach control portfolio drift, we believe it
can provide return improvements by capturing buy low/sell high opportunities.
When selecting mutual funds, Ascension will consider all of the factors described above and will also
consider:
- How efficiently the fund matches the asset class;
- The correlation between the fund and the client’s other investments; and
- The fund’s risk profile.
We prefer to invest in funds that are indexed to specific asset classes because they generally have
lower operating expenses and generate lower capital gains than actively managed funds. If such a
fund is not available for an asset class, we generally will select a fully invested, low turnover, broadly
diversified fund within the asset class. We also consider after-tax returns for taxable accounts and if
possible or suitable for a client, we can or will purchase Tax-Managed Funds.
A further feature of Ascension’s investment strategy is our emphasis on broad global diversification
and selecting asset classes which have a relatively low correlation with each other.
C. Risk of Loss
Ascension’s investment recommendations are subject to various markets, currency, economic,
political and business risks, and such investment decisions perhaps will not always be profitable.
Clients should be aware that there can be a loss or depreciation to the value of the client’s account,
which clients should be prepared to bear. There can be no assurance that a client’s investment
objectives will be obtained and no inference to the contrary is being made.
In addition, generally, the market value of securities will fluctuate with market conditions and certain
types of securities can be more volatile than others. For example, small cap stock prices generally
will move up and down more than large cap stock prices. The market value of bonds will generally
fluctuate inversely with interest rates and other market conditions prior to maturity and will equal par
value (face value) at maturity. Interest rates for bonds can be fixed at the time of issuance or
purchase, and payment of principal and interest can be guaranteed by the issuer and, in the case of
U.S. Treasury obligations, backed by the full faith and credit of the U.S. Treasury. The market value
of Treasury bonds will generally fluctuate more than Treasury bills, since Treasury bonds have longer
maturities. High yield bonds are considered to be predominantly speculative with respect to the
payment of interest and repayment of principal. Such securities can also be subject to greater
volatility as a result of changes in prevailing interest rates than other debt securities. Investments in
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overseas markets (international securities) also pose special risks, including currency fluctuation and
political risks, and such investment can be more volatile than that of a U.S. only investment. The
risks are generally intensified for investments in emerging markets.
In addition, there is no assurance that a mutual fund will achieve its investment objective. Past
performance of investments is no guarantee of future results. Mutual fund investments also can result
in unexpected tax liabilities which cannot be controlled by Ascension or the client.
Some additional investment risks a client should be aware of include, but are not limited, to the
following:
• Business Risk: These risks are associated with a particular industry or a particular company
within an industry. For example, oil-drilling companies depend on finding oil and then
refining it, a lengthy process, before they can generate a profit. They carry a higher risk of
profitability than an electric company, which generates its income from a steady stream of
customers who buy electricity no matter what the economic environment is like.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar
against the currency of the investment’s originating country. This is also referred to as
exchange rate risk.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of
profitability, because the company must meet the terms of its obligations in good times and
bad. During periods of financial stress, the inability to meet loan obligations can result in
bankruptcy and/or a declining market value.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally,
assets are more liquid if many traders are interested in a standardized product. For example,
Treasury Bills are highly liquid, while real estate properties are not.
• Political and Legislative Risk: Companies face a complex set of laws and circumstances in
each country in which they operate. The political and legal environment can change rapidly
and without warning, with significant impact, especially for companies operating outside of
the United States or those companies who conduct a substantial amount of their business
outside of the United States.
• Reinvestment Risk: This is the risk that future proceeds from investments perhaps will have
to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to
fixed income securities.
Prior to entering into an Agreement with us, a client should carefully consider: (1) committing to
management only those assets that the client believes will not be needed for current purposes and that
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can be invested on a long-term basis, usually a minimum of three to five years, (2) that volatility from
investing in the stock market can occur, and (3) that over time the client’s assets can fluctuate and at
anytime be worth more or less than the amount invested.
We do not represent, guarantee or imply that the services or methods of analysis employed by us can
or will predict future results, successfully identify market tops or bottoms, or insulate clients from
losses due to market corrections or declines.
ITEM 9: DISCIPLINARY INFORMATION
Registered investment advisers such as Ascension are required to disclose all material facts regarding
any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation
of us or the integrity of our management. We do not have any such legal or disciplinary events and
thus has no information to disclose with respect to this Item.
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Ascension and our associated persons do not have any financial industry activities, financial industry
affiliations, nor do we recommend other advisers.
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING
A. Description of Code of Ethics
As a registered investment adviser, Ascension has a fiduciary duty to act in the best interest of our
clients. Ascension’s clients therefore entrust us to use the highest standards of integrity when dealing
with their assets and making investments that impact their financial future. Our fiduciary duty
compels all employees to act with integrity in all of our dealings.
Because Ascension’s investment professionals can transact in the same securities for their personal
accounts as they can buy or sell for client accounts, it is important to mitigate potential conflicts of
interest. To that end, we have adopted personal securities transaction policies in the form of a Code
of Ethics (“Code”), which all our associated persons must follow. This Code provides such personnel
with guidance in their ethical obligations regarding their personal securities transactions and fiduciary
duties formulating the basis of all of our client dealings. Specifically, the Code requires certain
personnel to report personal trades and holdings and prohibits or requires pre-clearance for certain
trades in certain circumstances. The Code also contains procedures for reporting violations and
enforcement. The Code is reviewed and distributed to our associated persons annually. Ascension
will provide a copy of the Code to any client or prospective client upon written request or by calling
our main office.
Ascension obtains information from a wide variety of publicly available resources. Ascension and
our personnel do not have, nor claim to have, insider or private knowledge. To ensure insider trading
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does not take place and to address the conflict of interest regarding obtaining confidential
information, we have adopted a firm wide policy statement outlining insider-trading compliance by
Ascension, our associated persons and other employees. This statement has been distributed to all
associated persons and other employees of Ascension and has been signed and dated by each such
person.
Participation or Interest in Client Transactions
Because the Code would permit associated persons of Ascension to invest in the same securities as
clients, there is a possibility that our associated person could benefit from market activity by a client
in a security held by that person. Employee trading is continually monitored under the Code, with an
eye to reasonably prevent conflicts of interest between Ascension and our clients.
Ascension does not affect any principal or agency cross securities transactions for client accounts, nor
do we affect cross-trades between client accounts. Principal transactions are generally defined as
transactions where an adviser, acting as principal for its own account or the account of an affiliated
broker-dealer, buys from or sells any security to any advisory client. An agency cross transaction is
defined as a transaction where a person acts as an investment adviser in relation to a transaction in
which the investment adviser, or any person controlled by or under common control with the
investment adviser, acts as broker for both the advisory client and for another person on the other side
of the transaction. Should we ever decide to affect principal trades or cross-trades in client accounts,
we will comply with all state and federal regulations pertaining to such activity.
ITEM 12: BROKERAGE PRACTICES
The following discussion summarizes the material aspects of Ascension’s practices for the
recommendation of custodians and the selection of broker-dealers to execute client transactions.
A. Selection Criteria
The Custodian and Brokers We Use
Ascension does not maintain custody of our clients’ assets that we manage, although we can be
deemed to have custody of your assets if you give us authority to withdraw assets from your account
(see Item 15 Custody, below). Your assets must be maintained in an account at a “qualified
custodian,” generally a broker-dealer or bank. The custodian that Ascension recommends that clients
use is Charles Schwab & Co., Inc. (“Schwab”), a FINRA registered broker-dealer and member of
SIPC. Ascension is independently owned and operated and not affiliated with Schwab. Schwab will
hold client assets in a brokerage account and buy and sell securities when we instruct them to. While
Ascension recommends that clients use Schwab as a custodian of their account, the client will decide
whether to open an account by entering into an account agreement directly with Schwab. Even though
your account is typically maintained at Schwab, we can still use other brokers to execute trades for
your account, as described in the next paragraph.
How We Select Brokers/Custodians to Recommend
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We seek to recommend a custodian/broker who will hold your assets and execute transactions on
terms that are overall most advantageous when compared to other available providers and their
services. We consider a wide range of factors, including, among others, the following:
• combination of transaction execution services along with asset custody services (generally
without a separate fee for custody)
• capability to execute, clear and settle trades (buy and sell securities for your account)
• capabilities to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• breadth of investment products made available (stocks, bonds, mutual funds, exchange
traded funds (ETFs), etc.)
• availability of investment research and tools that assist us in making investment decisions
• quality of services
• competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate them
reputation, financial strength and stability of the provider
their prior service to us and our other clients
•
•
• availability of other products and services that benefit us, as discussed below.
Schwab Custodian Arrangement
Your Custody and Brokerage Costs
For our clients’ accounts it maintains, Schwab generally does not charge you separately for custody
services but is compensated by charging you commissions or other fees on trades that it executes or
that settle into your Schwab account. Schwab’s commission rates applicable to our client accounts
were negotiated based on our commitment to maintain $10 million of our clients’ assets in accounts at
Schwab. This commitment benefits you because the overall commission rates you pay are lower than
they would be if we had not made the commitment. In addition to commissions Schwab charges you a
flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a
different broker-dealer but where the securities bought or the funds from the securities sold are
deposited (settled) into your Schwab account. These fees are in addition to the commissions or other
compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading
costs, we have Schwab execute most trades for your account.
Products and Services Available to Us from Schwab
Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving
independent investment advisory firms like us. They provide us and our clients with access to its
institutional brokerage – trading, custody, reporting and related services – many of which are not
typically available to Schwab retail customers. Schwab also makes available various support services.
Some of those services help us manage or administer our clients’ accounts while others help us
manage and grow our business. Schwab’s support services generally are available on an unsolicited
basis (we don’t have to request them) and at no charge to us as long as we keep a total of at least $10
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million of our clients’ assets in accounts at Schwab. If we have less than $10 million in client assets at
Schwab, it can charge us quarterly service fees. Below is a more detailed description of Schwab’s
support services:
Services that Benefit You. Schwab’s institutional brokerage services include access to a broad range
of investment products, execution of securities transactions, and custody of client assets. The
investment products available through Schwab include some to which we might not otherwise have
access or that would require a significantly higher minimum initial investment by our clients.
Schwab’s services described in this paragraph generally benefit you and your account.
Services that perhaps will not Directly Benefit You. Schwab also makes available to us other
products and services that benefit us but perhaps will not directly benefit you or your account. These
products and services assist us in managing and administering our clients’ accounts. They include
investment research, both Schwab’s own and that of third parties. We can use this research to service
all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab.
In addition to investment research, Schwab also makes available software and other technology that:
• provide access to client account data (such as duplicate trade confirmations and account
statements);
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
facilitate payment of our fees from our clients’ accounts; and
•
• provide pricing and other market data;
•
• assist with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Us. Schwab also offers other services intended to help us
manage and further develop our business enterprise. These services include:
technology, compliance, legal, and business consulting;
• educational conferences and events
•
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants and insurance providers.
Schwab can provide some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Schwab can also discount or waive its fees for some of these
services or pay all or a part of a third party’s fees. Schwab can also provide us with other benefits
such as occasional business entertainment of our personnel.
Our Interest in Schwab’s Services. The availability of these services from Schwab benefits us
because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services so
long as we keep a total of at least $10 million of client assets in accounts at Schwab. Beyond that,
these services are not contingent upon us committing any specific amount of business to Schwab in
trading commissions or assets in custody. The $10 million minimum can give us an incentive to
recommend that you maintain your account with Schwab based on our interest in receiving Schwab’s
services that benefit our business rather than based on your interest in receiving the best value in
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custody services and the most favorable execution of your transactions. This is a potential conflict of
interest.
We believe, however, that our selection of Schwab as custodian and broker is in the best interests of
our clients. It is primarily supported by the scope, quality and price of Schwab’s services (based on
the factors discussed above – see “How We Select Brokers/Custodians to Recommend”) and not
Schwab’s services that benefit only us. We do not believe that maintaining at least $10 million of our
clients’ assets at Schwab in order to avoid paying Schwab quarterly service fees presents a material
conflict of interest.
We perform periodic evaluations of the transaction costs and services provided by Schwab and
compare those with other broker custodians to evaluate whether overall best qualitative execution
could be achieved elsewhere. In performing such an evaluation, Ascension considers some additional
factors, such as:
- Historical execution prices
- Execution and correction capabilities
- The size and difficulty of transactions
- Reliability and financial stability
- Other services that can be provided to the client and to Ascension
If a client specifically directs Ascension to use a particular broker-dealer, Ascension will not be able
to seek best execution on the client’s behalf. Such a client can end up paying higher commissions
than other Ascension clients and their trades can be executed on less favorable terms than other
clients. Please refer to “Directed Brokerage” below.
B. Directed Brokerage
In some instances, because of a prior relationship between a client and one or more brokers, or for
other reasons, a client can instruct Ascension to execute some or all securities transactions for its
account with or through one or more brokers designated by the client.
In such cases, the client is responsible for negotiating the terms and conditions (including, but not
limited to, commission rates) relating to all services to be provided by such broker and his or her own
satisfaction with such terms and conditions.
We do not assume any responsibility for obtaining the best prices or any particular commission rates
for transactions with or through any such broker for such client’s account. The client must recognize
that it perhaps will not obtain commission rates as low as it might otherwise obtain if we had discretion
to select broker/dealers other than those chosen by the client and, as a result can or will not receive best
execution on transactions due to the client’s direction. Clients should also be aware that conflicts can
arise between a client’s interest in receiving best execution with respect to transactions effected for the
client’s account and our interest in potentially receiving future client referrals from the broker.
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Any client providing instructions to us regarding direction of brokerage transactions must be in
writing. If the client desires Ascension to cease executing transactions with or through any such
broker/dealer, the client also must communicate this to us in writing.
C. Best Execution
Except as otherwise provided in the client’s investment advisory agreement, Ascension has full
discretion to place buy and sell orders with or through such brokers or dealers as it can or will deem
appropriate. It is the policy and practice of Ascension to strive for the best price and execution that are
competitive in relation to the value of the transaction (“best execution”). In order to achieve best
execution, Ascension will use its best judgment to choose the broker-dealer most capable of providing
the brokerage services necessary to obtain the best overall qualitative execution. Although Ascension
will strive to achieve the best execution possible for client securities transactions, this does not require
it to solicit competitive bids and Ascension does not have an obligation to seek the lowest available
commission cost. In seeking best execution, the determinative factor is not the lowest possible cost,
but whether the transaction represents the overall best qualitative execution, taking into consideration
the full range of a broker-dealer’s services, including among other things, the value of research
provided, execution capability, commission rates, and responsiveness. Consistent with the foregoing,
while Ascension will seek competitive rates, it perhaps will not necessarily obtain the lowest possible
commission rates for client transactions. Ascension is not required to negotiate "execution only"
commission rates, thus the client can be deemed to be paying for research and related services (i.e.,
"soft dollars") provided by the broker which are included in the commission rate. Please refer to
“Soft Dollar Considerations” section below.
To help ensure that brokerage firms recommended by Ascension are conducting overall best
qualitative execution, Ascension will periodically (and no less often than annually) evaluate the
trading process and brokers utilized. Ascension’s evaluation will consider the full range of brokerage
services offered by the brokers, which can include, but is not limited to price, commission, timing,
research, aggregated trades, capable floor brokers or traders, competent block trading coverage,
ability to position, capital strength and stability, reliable and accurate communications and settlement
processing, use of automation, knowledge of other buyers or sellers and administrative ability.
D. Soft Dollar Considerations
Section 28(e) of the Exchange Act (“Section 28(e)”) allows investment advisers to use client
commissions to pay for brokerage and research services under certain circumstances without
breaching their fiduciary duties to clients. This practice is commonly referred to as "soft dollars".
Brokerage and research services can include, among other things, effecting securities transactions
and performing services incidental thereto (such as clearance, settlement and custody) and providing
research information regarding the economy, industries, sectors of securities, individual companies,
statistical information, taxation; political developments, legal developments, technical market action,
pricing and appraisal services, credit analysis; risk measurement analysis and performance analysis.
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Such research information can be received in the form of written reports, telephone conversations,
personal meetings with security analysts and/or individual company management and attending
conferences. The research services provided by a broker can be proprietary (i.e., provided by the
broker providing the execution services) and/or provided by a third party (i.e., originates from a party
independent from the broker providing the execution services, commonly referred to as a third-party
soft dollar arrangement).
As permitted under Section 28(e), we can or will cause clients to pay brokerage commissions that are
in excess of commissions that another broker might have charged for effecting the same transaction,
but only in circumstances where we have made a good faith determination that the amount of
commissions paid are reasonable in relation to the value of the brokerage and research services
received. We view this in terms of either the specific transactions or our overall responsibility to the
accounts for which we exercise investment discretion.
Section 28(e) also permits us to use the research services provided by brokers to service any or all of
our clients, and the services also can be used in connection with clients other than those making the
payment of commissions.
Ascension has access to proprietary research from Schwab due to the fact that some of our clients
custody their account assets at Schwab. In addition, we receive certain other indirect benefits from
Schwab due to this arrangement, which are outlined above and can be deemed to fall outside the safe
harbor of Section 28(e).
Importantly, clients should understand that the use of soft dollars by Ascension can be deemed to be
an indirect economic benefit to us, which creates a conflict of interest between us and our clients. To
address this conflict of interest, we perform periodic reviews of the quality of execution and services
provided by Schwab (and other broker custodians) to help ensure that clients are receiving the best
overall deal (also known as “best execution”).
Ascension does not currently have any other soft dollar arrangements in place.
E. Order Aggregation
Generally, based on the types of investment vehicles that Ascension utilizes, trade aggregation and
trade allocation are not possible unless there are unique circumstances whereby, when able to, we can
or will aggregate trades of accounts. Trade aggregation, or “bunching of orders,” can result in better
execution and/or better realized prices. Because of prevailing market conditions, it perhaps will not
be possible to execute all shares of an aggregated trade, in which case Ascension will allocate the
trade among participating accounts in an equitable manner determined prior to execution of the trade.
Ordinarily, the executing broker-dealer will provide an average price that will be allocated to all
accounts participating in the aggregated trade.
If a client specifically directs Ascension to use a particular broker-dealer, they will not be able to
participate in aggregate trades and can incur higher commission rates.
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F. Handling Trade Errors
In resolving any trading error, Ascension’s policy is that its clients’ interests always come first.
Generally, this means placing the client in the same position that it would have been in had the error
not occurred. Any losses incurred due to an Ascension trading error are the responsibility of
Ascension. Any gains resulting from an Ascension trade error will remain with the client. Errors do
not include administrative changes to the trade.
ITEM 13: REVIEW OF ACCOUNTS
A. Review of Accounts
All accounts are reviewed at least quarterly by the Portfolio Manager assigned to the client’s account.
The review is conducted to ensure that the mandates outlined in the Investment Policy Statement are
followed. Furthermore, accounts will be reviewed in the following circumstances:
- When Ascension’s investment strategy changes;
- When a client’s investment objectives or risk tolerance changes; and/or
- When there is a significant cash flow into or out of an account.
B. Reports to Clients
Ascension delivers computer generated reports to clients as soon as practically possible after the end
of each calendar quarter. Each report sets out amongst other things, the client’s holdings, any
expenses (including management fees) incurred during the preceding calendar quarter, and the value
of the account as of the last business day of the preceding calendar quarter. Clients are urged to
compare the reports received from Ascension to those received from their custodian.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
A. Economic Benefits Received
As mentioned in Item 12 above, Ascension generally recommends that clients use Schwab as their
custodian and broker of record. While there is no direct link between the investment advice given to a
client and our recommendation to clients to use Schwab as their custodian, certain indirect economic
benefits are received by us due to these arrangements. We receive an economic benefit in the form of
the support products and services such custodians make available to us and other independent
investment advisers that have their clients maintain accounts at Schwab. These products and services,
how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage
Practices). The availability to us of Schwab’s products and services is not based on us giving
particular investment advice, such as buying particular securities for our clients.
While Ascension and our associated persons endeavor at all times to put the interest of the clients
first, as part of our fiduciary duty, clients should be aware that receipt of additional compensation
itself creates a conflict of interest. To help ensure that clients are receiving best execution and to
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address the conflict of interest surrounding this arrangement, we perform periodic reviews of the
quality of execution and services provided by Schwab.
B. Compensation for Client Referrals
Ascension can enter into contractual agreements with individuals and organizations that refer clients
to us. If a client is introduced to Ascension, we can or will pay that promoter a referral fee.
All “promoter agreements” will be in writing and comply with applicable state and federal
requirements. While the specific terms of each promoter agreement can differ, generally, a promoter’s
compensation is based upon Ascension’s engagement of new clients and the retention of those clients
and is calculated using a varying percentage interest in the fees paid to us by such clients. Any
compensation shall be paid solely from Ascension’s investment management fee and shall not result
in any additional charge to the client. At this time, Ascension does not have any such arrangements in
place.
ITEM 15: CUSTODY
Pursuant to the Investment Advisers Act of 1940, Ascension is deemed to have custody of client
funds because the firm has the authority and ability to debit its fees directly from clients’ accounts. To
mitigate any potential conflicts of interests, all Ascension client account assets will be maintained
with an independent qualified custodian. Generally, Ascension recommends Schwab for custodial
services, but from time to time, other custodians can be used by Ascension to custody assets.
Notably, in most cases a client’s broker-dealer also can act as the custodian of the client’s assets for
little or no extra cost. Clients should be aware, however, of the differences between having their
assets held at a broker-dealer versus at a bank or trust company. Some of these differences include,
but are not limited to, custodian costs, trading issues, security of assets, client reporting and
technology.
Ascension can only implement its investment management recommendations after the client has
arranged for and furnished Ascension with all information and authorization regarding its accounts
held at the designated qualified custodian.
Clients will receive statements on at least a quarterly basis directly from the qualified custodian that
holds and maintains their assets. Clients are urged to carefully review all custodial statements and
compare them to the reports and/or statements provided by Ascension. Ascension’s statements can
vary from custodial statements based on accounting procedures, reporting dates, or valuation
methodologies of certain securities. Please refer to Item 12 for additional important disclosure
information relating to Ascension’s practices and relationships with custodians.
ITEM 16: INVESTMENT DISCRETION
A. Discretionary Authority; Limitations
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Ascension has complete discretion over the selection and amount of securities to be bought or sold
without obtaining specific client consent. The only limitation on this discretion is that Ascension
must manage a client’s account in accordance with the client’s investment objectives and individual
risk tolerance as established and agreed upon in the Investment Policy Statement and Account
Questionnaires.
Ascension also has full discretion to choose broker-dealers for effecting client transactions. However,
under limited circumstances Ascension can, in its sole discretion permit the use of a particular broker-
dealer if specifically directed by a client to do so.
B. Limited Power of Attorney
For each account Ascension manages, the client will establish a Limited Power of Attorney with their
custodian authorizing us to give the custodian instructions for the purchase, sale, conversion,
redemption, exchange or retention of any security, cash or cash equivalent for the account.
Additionally, each client will authorize their custodian to debit the client’s account for the fees and
charges invoiced to them by Ascension.
ITEM 17: VOTING CLIENT SECURITIES
Proxy Voting Policy
Ascension does not accept proxy voting authority with respect to client securities holdings and will
direct the custodian to forward all shareholder related materials directly to the client’s address on
record. In the event a proxy solicitation is sent to Ascension on a client’s behalf, Ascension will
forward the solicitation to the client’s address of record immediately so that they can cast the proxy
vote.
Proxy voting for plans governed by ERISA must conform to the plan document in effect. In case
where the investment manager is listed as the fiduciary responsible for voting proxies, the
responsibility will be designated to another fiduciary and reflected in the plan document.
Ascension shall not be deemed to have proxy voting authority solely as a result of providing advice or
information about a particular proxy vote to a client.
ITEM 18: FINANCIAL INFORMATION
Ascension does not require or solicit prepayment of more than $1,200 in fees per client, six months or
more in advance and therefore is not required to provide, and has not provided, a balance sheet.
Ascension does not have any financial commitments that impair our ability to meet contractual and
fiduciary obligations to clients, and we have not been the subject of a bankruptcy proceeding.
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