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Part 2A of Form ADV: Firm Brochure
BCG SECURITIES, INC.
51 Haddonfield Road
Suite 210
Cherry Hill, NJ 08002
Telephone: (856) 393-1950
Facsimile: (856) 824-1475
E-mail: info@bcgsecurities.com
Web Address: www.bcgsecurities.com
Amended January 13, 2025
This brochure provides information about the qualifications and business practices of BCG Securities, Inc.
(hereinafter “BCG” or “firm” or “we”). If you have any questions about the contents of this brochure, please
contact us at (856) 393-1950 or at info@bcgsecurities.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.
Additional information about BCG is available on the SEC’s website at www.adviserinfo.sec.gov. You can
search this site by a unique identifying number, known as a CRD number. The CRD number for BCG is
70.
Item 2.
Summary of Material Changes
None in the prior 12 months.
Item 3.
Table of Contents
Item Section
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Cover Page
Material Changes
Table of Contents
Advisory Business
Fees and Compensation
Performance-Based Fees and Side-by-Side Management
Types of Clients
Methods of Analysis, Investment Strategies and Risk of Loss
Disciplinary Information
Other Financial Industry Activities and Affiliations
Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Brokerage Practices
Review of Accounts
Client Referrals and Other Compensation
Custody
Investment Discretion
Voting Client Securities
Financial Information
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Item 4.
Advisory Business
BCG is a SEC-registered investment adviser (SEC file number 801-56943) with its
principal place of business located in Cherry Hill, New Jersey. We have been in business
since 1968. Horace Mann Educators Corp. is the direct owner of BCG Securities. Adam
Paglione is CEO and Holley Taylor is Chief Compliance Officer.
Assets under our firm’s management were approximately $740,027,520 as of December
31, 2025.
Portfolio Management Services
Our firm provides continuous advice to a client regarding the investment of client funds
based on the individual needs of the client. Through personal discussions in which goals
and objectives based on a client's particular circumstances are established, we develop
and manage a portfolio based on those discussions. During our data-gathering process,
we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity
needs. We may also review and discuss a client’s prior investment history, as well as
family composition and background. We charge an asset-based fee for the management
of these accounts, a portion of which is kept by the Investment Advisor Representative
and by the firm. Section 5 provides more information regarding the fee structure.
We will manage advisory accounts on a non-discretionary and discretionary basis.
Account supervision is guided by the stated objectives of the client (i.e. preservation,
conservative, moderate, moderately aggressive, or aggressive strategies), as well as tax
considerations. Clients may impose reasonable restrictions on investing in certain
securities, types of securities, or industry sectors.
Use of Sub-Advisers and Third-Party Managers
We may also, when appropriate, sub-advise certain portions of a client portfolio to
independent third-party managers or recommend direct investment with independent
third-party managers, typically when those managers demonstrate knowledge and
expertise is a particular investment strategy.
As part of this service, we perform management searches of various unaffiliated third-
party managers. Based on a client's individual circumstances and needs, we will
determine which selected manager’s portfolio management style is appropriate for that
client. Factors considered in making this determination include account size, risk
tolerance, the opinion of each client and the investment philosophy of the selected
manager. We encourage clients to review each third-party manager’s disclosure
document regarding the particular characteristics of any program and managers selected
by us.
Once we determine which selected third-party manager(s) are most appropriate for the
client, we will provide the selected registered investment adviser(s) with the client's
investment goals and risk tolerance. The selected manager(s) will then create and
manage the client's portfolio based upon the client's individual needs as exhibited in the
client's IPS or investment plan.
We will regularly and continuously monitor the performance of the selected third-party
manager(s). If we determine that a particular selected manager(s) are not providing
sufficient management services to the client, or are not managing the client's portfolio in
a manner consistent with the client's IPS or investment plan, we will remove the client's
assets from that selected manager(s) and place the client's assets with another third-
party manager(s) at our discretion and without prior consent from the client.
Our firm will conduct appropriate due diligence on all independent third-party managers,
making reasonable inquiries into their performance calculations, policies and procedures,
Code of Ethics, and other operational and compliance matters deemed important to
account performance and risk management.
Financial Planning Services
Financial planning is a comprehensive evaluation of a client’s current and future financial
state by using currently known variables to predict future cash flows, asset values and
withdrawal plans. The key defining aspect of financial planning is that through the financial
planning process, all questions, information and analysis will be considered as they
impact and are impacted by the entire financial and life situation of the client. Clients
purchasing this service will receive a written report, providing the client with a detailed
financial plan designed to achieve his or her stated financial goals and objectives.
In general, the financial plan will address any or all of the following areas of concern:
• Personal: Family records, budgeting, personal liability, estate information and
financial goals;
• Tax & Cash Flow: Income tax and spending analysis and planning for past, current
and future years. We will illustrate the impact of various investments on a client's
current income tax and future tax liability;
• Death & Disability: Cash needs at death, income needs of surviving dependents,
estate planning and disability income analysis;
• Retirement: Analysis of current strategies and investment plans to help the client
achieve his or her retirement goals;
•
Investments: Analysis of investment alternatives and their effect on a client's
portfolio;
• Estate: Analysis of financial issues with respect to living trusts, wills, estate tax,
powers of attorney, asset protection plans, nursing homes, Medicaid and elder law;
•
Insurance: Review of existing policies to ensure proper coverage for life, health,
disability, long-term care, liability, home and automobile; and/or
• Business Planning: Employee benefits analysis, executive compensation planning,
risk management, real estate planning, business transfer planning, employee
recruiting needs, and expansion planning.
Typically, if requested, the financial plan will be presented to the client within six months
of the contract date, provided that all information needed to prepare the financial plan has
been promptly provided by the client.
Pension Consulting Services
We provide several consulting services separately or in combination. Clients may choose
to use any or all of these services.
Investment Policy Statement (“IPS”) Development or Review
We will meet with the client (in person and/or over the telephone) to determine or review
the client’s investment needs and goals. For clients needing an IPS, we will prepare a
written IPS stating their needs and goals and encompassing a policy under which these
goals are to be achieved. The IPS will also list the criteria for the selection of investment
vehicles and the procedures and timing interval for monitoring investment performance.
Selection of Investment Vehicles and Independent Money Managers
We will review various investments, consisting primarily of mutual funds, service providers
and strategies to determine which ones are appropriate to implement the client’s IPS.
The nature and selection of investments and service providers to be recommended will
be determined by the client, based on the IPS.
Based on a client’s individual circumstances and needs, we will determine which
independent manager’s portfolio is appropriate for that client. Factors we consider in
making this determination include account size, risk tolerance, the opinion of each client
and the investment philosophy of the independent adviser. If we believe that a selected
independent adviser is not performing adequately or if we believe that a different manager
is more suitable for a client’s particular needs, then we may suggest that a client contract
with a different adviser. While we may assist the client in selecting a new adviser, any
move to a new adviser is solely at the discretion of the client.
Monitoring of Investment Procedures and Performance
We will monitor client investments continuously based on the procedures and timing
intervals delineated in the IPS. Although we will not be involved in any way in the
purchase or sale of these investments, we will monitor the client's portfolio and will make
recommendations to the client as market factors and the client's needs dictate. The
frequency of reviews will be determined by the client’s needs and the IPS.
Employee Communications:
For pension, profit sharing and 401(k) plan clients in self-directed plans, we will provide
periodic educational support and investment workshops designed for the plan
participants. Topics to be discussed will be determined in conjunction with the plan
sponsor and in accordance with guidelines established in ERISA Section 404(c). The
educational support and investment workshops will not provide plan participants with
individualized, tailored investment advice or individualized, tailored asset allocation
recommendations.
Wealth Management/Consulting Services
We provide wealth management services for individuals and businesses. Wealth
management services are generally provided over the course of a year, and may be
continued from year to year by mutual agreement. Depending on each client's
circumstances and needs, our wealth management services may include: an evaluation
of the likelihood of the client meeting certain financial goals or objectives, based on the
client’s assets, liabilities, and relevant economic assumptions (a “Capital Needs
Analysis”); tax planning; insurance planning; estate planning; risk management needs
analysis; assessment of mortgages, debt refinancing, and loan alternatives; bill paying
and budgeting analysis; strategies for philanthropic and multigenerational planning;
gifting strategies, including amounts, form of gift (monetary or securities), and the
manner of making the gifts, such as through trusts and foundations; family business
succession planning; coordination of external advisors; and financial reporting.
Services in General
We tailor all of our investment recommendations and advice to the individual needs of
each client. All investment recommendations and advice are based on information
gathered through client questionnaires, electronic communications, telephone and in-
person discussions.
Our investment recommendations are not limited to any specific product or service offered
by a broker dealer or insurance company and will primarily include advice regarding no-
load or load-waived mutual funds, exchange-traded funds (ETFs), equity securities, and
independent third-party managers.
Occasionally, we may also advise on or recommend investments in the following
instruments:
• Fixed income securities
Interests in pooled investment vehicles
• Certificates of deposit
• Warrants
• Commercial paper
• Municipal securities
• Variable life insurance
• Variable annuities
• United States government securities
•
Item 5.
Fees and Compensation
Portfolio Management Services
Our fees for Portfolio Management Services are based upon a percentage of assets
under management. The following fee schedule is indicative of a typical wealth
management account; however your actual fee may vary depending upon your specific
portfolio, the complexity of the portfolio and overall management. The fee schedule may
be negotiated with the client on a case by case basis. No fee will be in excess of 1.50%
without specific approval by the firm’s Compliance Officer.
Assets Under Management ($)
Approximate Annual Fee (%)
Under $100,000
$100,000 to 1,000,000
Over $1,000,000
Less than 1.50%
Approximately 1.00%
1.00% or individually negotiated
Portfolio management fees are deducted in advance of each quarterly, based upon the
net value of the assets in the client account on the last business day of the previous
quarter, pro-rated for additions and withdrawals.
Depending on the particular arrangement with each client, we will generally debit their
custodial accounts for portfolio management fees. The firm may also receive periodic
money market distribution assistance from our custodian, Pershing for assets held in a
money market sweep account. Currently the distribution assistance is 0% for retirement
accounts and .035% for taxable accounts. This revenue is retained only by the firm and
not shared with any other person. Pershing provides full disclosure and details regarding
this assistance to all customers via statement inserts.
Some asset classes are generally not charged an asset based fee or are exempt from
the quarterly fee. Typically these asset types are annuities, insurance products,
alternative investment products, certain fixed income positions, certain cash or money
market positions, and certain share classes of mutual funds. You may contact the firm or
your IAR regarding your specific account.
Financial Planning Services:
We charge Financial Planning clients based on an hourly fee of up to $500 per hour or a
fixed fee based on the client’s net worth and in accordance with the fee schedule below.
The entire fee is due and payable at the commencement of the financial planning service
if the project is done on a fixed fee basis. If the project is done on an hourly basis, the
client will pay our reasonable estimate of the total fee at the time the advisory contract is
signed, and when the financial planning project is completed, will pay any balance due or
will receive a refund of any amount overpaid.
The length of time it will take us to complete a particular financial planning project will
depend on the nature and complexity of the individual client's personal circumstances.
An estimate for total hours will be determined at the start of the advisory relationship.
Fees in General
Fees and account minimums for all services are negotiable based upon certain criteria
(i.e. anticipated future earning capacity, anticipated future additional assets, dollar
amount of assets to be managed, related accounts, account composition, negotiations
with client, etc.). Discounts, not generally available to our advisory clients, may be offered
to family members and friends of BCG or its staff.
We may group certain related client accounts for the purposes of determining the account
size and/or annualized fee.
Certain legacy client agreements may be governed by fee schedules different from those
listed above.
Account Termination
Clients will have a period of five (5) business days from the date of signing the agreement
to unconditionally rescind the agreement and receive a full refund of all fees. Thereafter,
the client may terminate the agreement by providing us with a 7-day written notice at our
principal place of business. Upon termination of any account, any prepaid, unearned fees
will be promptly refunded, and any earned, unpaid fees will be due and payable.
Mutual Fund and ETF Fees and Expenses: All fees paid to our firm for investment
advisory services are separate and distinct from the fees and expenses charged by
mutual funds and ETFs to their shareholders. These fees and expenses are described
in each fund's prospectus. These fees will generally include a management fee, other
fund expenses, and a possible distribution fee. A client could invest in a mutual fund or
and ETF directly, without the services of our firm. In that case, the client would not receive
the services provided by us which are designed, among other things, to assist the client
in determining which mutual fund or funds or ETFs are most appropriate to each client's
financial condition and objectives. Accordingly, the client should review both the fees
charged by the funds and ETFs and the fees charged by us to fully understand the total
amount of fees to be paid by the client and to thereby evaluate the advisory services
being provided.
Brokerage, Custodial, and Third-Party Manager Fees
In addition to advisory fees paid to our firm, clients will also be responsible for all
transaction, brokerage, trade-away and custodial fees incurred as part of their account
management with the selected third-party investment advisers. Please see Item 12 of
this Brochure for important disclosures regarding our brokerage practices. All advisory
fees charged by selected third-party managers and/or programs are incurred by clients
in addition to our advisory fees.
Item 6.
Performance-Based Fees and Side-By-Side Management
We do not charge any fees based on a share of capital gains on or capital appreciation
of the assets of a client.
Item 7.
Types of Clients
Our primary clients groups are retirement plans such as 401(k) plans, and individual
accounts with assets exceeding $25,000.
Third-party managers we select may impose additional and different minimum account
sizes and/or fee minimums. Such requirements will be described in each manager’s
disclosure documents and/or advisory agreement.
Item 8.
Methods of Analysis, Investment Strategies and Risk of Loss
Our firm employs the following types of analysis to formulate client recommendations.
Fundamental Analysis: Fundamental analysis of a business involves analyzing its income
statement, financial statements and health, its management and competitive advantages,
and its competitors and markets. Fundamental analysis school of thought maintains that
markets may mis-price a security in the short run but that the "correct" price will eventually
be reached. Profits can be made by trading the mis-priced security and then waiting for
the market to recognize its "mistake" and re-price the security. We would typically
categorize our individual stock discipline as Middle-to-Large Capitalization Growth.
Fundamental analysis does not attempt to anticipate market movements. This presents
a potential risk, as the price of a security can move up or down along with the overall
market regardless of the economic and financial factors considered in evaluating the
stock. Therefore, unforeseen market conditions and/or company developments may
result in significant price fluctuations that can lead to investor losses.
Mutual fund and/or ETF analysis: We look at the experience and track record of the
manager of the mutual fund or ETF in an attempt to determine if that manager has
demonstrated an ability to invest over a period of time and in different economic
conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt
to determine if there is significant overlap in the underlying investments held in other funds
in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if
they are continuing to follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful
may not be able to replicate that success in the future. In addition, as we do not control
the underlying investments in a fund or ETF, managers of different funds held by the client
may purchase the same security, increasing the risk to the client if that security were to
fall in value. There is also a risk that a manager may deviate from the stated investment
mandate or strategy of the fund or ETF, which could make the fund or ETF less suitable
of the client’s portfolio.
Technical analysis. We analyze past market movements and apply that analysis to the
present in an attempt to recognize recurring patterns of investor behavior and to
potentially predict future price movement.
Technical analysis does not consider the underlying financial condition of a company.
This presents a risk in that a poorly-managed or financially unsound company may
underperform regardless of market movement.
Third-Party Manager Analysis: We examine the experience, expertise, investment
philosophies, and past performance of independent third-party investment managers in
an attempt to determine if that manager has demonstrated an ability to invest over a
period of time and in different economic conditions. We monitor the manager’s underlying
holdings, strategies, concentrations and leverage as part of our overall periodic risk
assessment. Additionally, as part of our due-diligence process, we survey the manager’s
compliance and business enterprise risks.
A risk of investing with a third-party manager who has been successful in the past is that
he/she may not be able to replicate that success in the future. In addition, as we do not
control the underlying investments in a third-party manager’s portfolio, there is also a risk
that a manager may deviate from the stated investment mandate or strategy of the
portfolio, making it a less suitable investment for our clients. Moreover, as we do not
control the manager’s daily business and compliance operations, it is possible for us to
miss the absence of internal controls necessary to prevent business, regulatory or
reputational deficiencies.
Risks for all forms of analysis: Our securities analysis method relies on the assumption
that the companies whose securities we purchase and sell, the rating agencies that
review these securities, and other publicly-available sources of information about these
securities, are providing accurate and unbiased data. While we are alert to indications
that data may be incorrect, there is always a risk that our analysis may be compromised
by inaccurate or misleading information.
Our firm employs the following investment strategies to formulate and/or implement
investment advice given to clients:
Long-term purchases: We or third-party managers selected by us mostly purchase
securities with the idea of holding them in the clients account for a year or longer. We/they
may do this because we believe the securities to be currently undervalued. We/they may
do this because we want exposure to a particular asset class over time, regardless of the
current projection for this class.
A risk in a long-term purchase strategy is that, by holding the security for this length of
time, we may not take advantages of short-term gains that could be profitable to a client.
Moreover, if our/their predictions are incorrect, a security may decline sharply in value
before we/they make the decision to sell.
Short-term purchases: At times, we or third-party managers selected by us may also
purchase securities with the idea of selling them within a relatively short time (typically a
year or less). We/they do this in an attempt to take advantage of conditions that we/they
believe will soon result in a price swing in the securities we purchase.
A risk in a short-term purchase strategy is that, should the anticipated price swing not
materialize, we/they are left with the option of having a long-term investment in a security
that was designed to be a short-term purchase, or potentially taking a loss. In addition,
this strategy involves more frequent trading than does a longer-term strategy, and will
result in increased brokerage and other transaction-related costs, as well as less
favorable tax treatment of short-term capital gains.
Short sales: We or third-party managers selected by us borrow shares of a stock for your
portfolio from someone who owns the stock on a promise to replace the shares on a future
date at a certain price. We/they then sell the shares we have borrowed. On the agreed-
upon future date, we/they buy the same stock and return the shares to the original owner.
We/they engage in short selling on based on our determination that the stock will go down
in price after we/they have borrowed the shares. If the stock has gone down since we/they
purchased the shares from the original owner, we/they keep the difference.
One risk in selling short is that losses are theoretically unlimited; we are obligated to
repurchase the stock no matter how much the price has climbed. In addition, even if
we/they are correct in determining that the price of a stock will decline, we/they run the
risk of incorrectly determining when the decline will take place. Short selling may not be
appropriate in times of inflation, as prices may adjust upwards regardless of the value of
the stock.
Margin transactions: We or third-party managers selected by us may purchase stocks for
your portfolio with money borrowed from your brokerage account. This allows you to
purchase more stock than you would be able to with your available cash, and allows
us/them to purchase stock without selling other holdings.
A risk in margin trading is that, in volatile markets, securities prices can fall very quickly.
If the value of the securities in your account minus what you owe the broker falls below a
certain level, the broker will issue a “margin call”, and you will be required to sell your
position in the security purchased on margin or add more cash to the account. In some
circumstances, you may lose more money than you originally invested.
Item 9.
Disciplinary Information
Our firm has no reportable disciplinary events to disclose.
Item 10.
Other Financial Industry Activities and Affiliations
Neither our firm nor our employees have any other financial industry affiliations or are
engaged in any other financial industry activities.
Item 11.
Code of Ethics, Participation in Client Transactions and Personal
Trading
Code of Ethics Disclosure
Our firm has adopted a Code of Ethics which sets forth high ethical standards of business
conduct that we require of our employees, including compliance with applicable federal
securities laws. Our Code of Ethics includes policies and procedures for the review of
quarterly securities transactions reports as well as initial and annual securities holdings
reports that must be submitted by the firm’s access persons. Among other things, our
Code of Ethics also requires the prior approval of any acquisition of securities in a limited
offering (e.g., private placement) or an initial public offering. Our code provides for
oversight, enforcement and recordkeeping provisions. A copy of our Code of Ethics is
available to our advisory clients and prospective clients upon request to Adam Paglione,
President and Chief Compliance Officer, at the firm’s principal office address.
Our firm or individuals associated with our firm may buy or sell securities identical to those
recommended to or purchased for customers for their personal accounts. In addition, any
related person(s) may have an interest or position in a certain security(ies) which may
also be recommended to a client. This practice results in a potential conflict of interest,
as we may have an incentive to manipulate the timing of such purchases, to the extend
possible, to obtain a better price or more favorable allocation in rare cases of limited
availability.
We may aggregate our employee trades with client trades. In case there is a partial fill of
a particular batch order, we will allocate all the purchases pro-rata, with each account
paying average price. Our clearing firm, Pershing, may execute trades on a riskless
principal basis. This is generally done for fixed income transactions when a fee is not
being charged.
To mitigate these potential conflicts of interest and ensure the fulfillment of our fiduciary
responsibilities, we have established the following restrictions:
1. No principal or employee of our firm may buy or sell securities for their personal
portfolio(s) where their decision is substantially derived, in whole or in part, by
reason of his or her employment unless the information is also available to the
investing public on reasonable inquiry. No principal or employee of our firm may
the advisory client;
prefer his or her own
interest
to
that of
2. It is the expressed policy of our firm that no person employed by us may purchase
or sell any security prior to a transaction(s) being implemented for an advisory
account, and therefore, preventing such employees from benefiting from
transactions placed on behalf of advisory accounts;
3. We maintain a list of all securities holdings for our firm and anyone associated with
this advisory practice with access to advisory recommendations. These holdings
are reviewed on a regular basis by our compliance staff;
4. In case of partial fills, client accounts will receive preference over employee
accounts;
5. We emphasize the unrestricted right of the client to decline to implement any
advice rendered, except in situations where our firm is granted discretionary
authority;
6. All of our principals and employees must act in accordance with all applicable
Federal and State regulations governing registered investment advisory practices;
and
7. Any individual not in observance of the above may be subject to disciplinary action
or termination.
Item 12.
Brokerage Practices
In most instances any brokerage transactions will take place through our own
broker/dealer. All BCG Securities broker/dealer transactions are executed and held by
our clearing firm, Pershing, LLC. As broker/dealer, BCG Securities does not receive any
“soft dollar” compensation from any investment company. Clients may use an outside
broker/dealer at their own discretion. In some instances, such as a high frequency trading
client, we may request or suggest the client use an outside broker/dealer as the fees may
be significantly less.
Third-Party Manager Practices
While we do not have any direct control over third-party manager brokerage or
aggregation practices, we will review their respective policies to ensure that they are
reasonable and in the overall best interest of our clients prior to placing client assets with
any third-party manager.
Item 13.
Review of Accounts
Portfolio Management Services
The firm’s Chief Compliance Officer and the IAR are responsible for all account reviews.
These persons and their designees will monitor the underlying securities in client
accounts and perform periodic reviews of account holdings for all clients. Various
exception and production reports produced by the system are reviewed and addressed.
We will also monitor the performance of third-party managers on a periodic basis.
Accounts are reviewed periodically for consistency with client investment strategy, asset
allocation, risk tolerance and performance relative to the appropriate benchmark.
Account reviews may be in writing or may be done electronically without a written report.
More frequent reviews may be triggered by changes in an account holder’s personal, tax
or financial status. Significant domestic, geopolitical and macroeconomic events may
also trigger reviews.
In addition to the monthly statements and confirmations of transactions that clients
receive from their custodian and/or broker dealer, our firm may provide quarterly holdings
and/or performance reports depending upon the account type selected by the client.
Pension Consulting Services
For these clients, we will review the client’s IPS whenever the client indicates a change
in circumstances regarding the needs of the plan. We will also review the investment
options of the plan according to the agreed-upon time intervals established in the IPS.
Such reviews will generally occur quarterly.
In addition to the monthly statements and confirmations of transactions that clients
receive from their custodian and/or broker dealer, our firm will provide quarterly holdings,
manager monitoring and/or performance reports.
Financial Planning/Wealth Management/Consulting Services
We will review these client accounts as contracted for at the inception of the advisory
relationship, typically at least annually. We will provide Financial Planning clients with a
completed financial plan. We will provide additional reports as contracted for at the
inception of the advisory relationship.
Item 14.
Client Referrals and Other Compensation
Other than that already described in this Brochure, our firm does not receive any
additional compensation from third parties for providing investment advice to its clients
and does not compensate anyone for client referrals.
Item 15.
Custody
Custody is defined as any legal or actual ability by our firm to access client funds or
securities. BCG Securities, Inc. does not hold custody of any client assets. Assets are
held by our clearing firm, Pershing, LLC, a third-party asset manager, or in the case of
retirement plans, a designated trust company. All statement will be prepared and sent by
the applicable custodian.
Item 16.
Investment Discretion
For clients granting us discretionary authority to determine which securities and the
amounts of securities that are to be bought or sold for their account(s) or which third-party
managers to hire and fire, we request that such authority be granted in writing, typically
in the executed investment management agreement.
Should the client wish to impose reasonable limitations on this discretionary authority,
such limitations shall be included in this written authority statement. Clients may
change/amend these limitations as desired. Such amendments must be submitted to us
by the client in writing.
Item 17.
Voting Client Securities
BCG, as a matter of policy and practice, has no authority to vote proxies on behalf of
advisory clients. The firm may offer assistance as to proxy matters upon a client's
request, but the client always retains the proxy voting responsibility.
Item 18.
Financial Information
Under no circumstances will we earn fees in excess of $5,000 more than six months in
advance of services rendered, notwithstanding automated asset based fees charged to
customer accounts.