Overview
- Headquarters
- Newport Beach, CA
- Average Client Assets
- $3.7 million
- Minimum Account Size
- $1,000,000
- SEC CRD Number
- 119290
Recent Rankings
Forbes 2025: 6
Forbes 2024: 9
Barron's 2025:
7
Barron's 2024:
7
Fee Structure
Primary Fee Schedule (BEACON POINTE ADVISORS, LLC FORM ADV PART 2)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.50% |
Minimum Annual Fee: $5,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $75,000 | 1.50% |
| $10 million | $150,000 | 1.50% |
| $50 million | $750,000 | 1.50% |
| $100 million | $1,500,000 | 1.50% |
Clients
- HNW Share of Firm Assets
- 78.45%
- Total Client Accounts
- 29,892
- Discretionary Accounts
- 29,800
- Non-Discretionary Accounts
- 92
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Companies, Portfolio Management for Pooled Investment Vehicles, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection, Educational Seminars
Regulatory Filings
Additional Brochure: BEACON POINTE ADVISORS, LLC FORM ADV PART 2 (2026-03-31)
View Document Text
Form ADV, Part 2A
March 31, 2026
Main Office:
24 Corporate Plaza, Suite 150
Newport Beach, CA 92660
949-718-1600
www.beaconpointe.com
This brochure provides information about the qualifications and business practices of Beacon Pointe Advisors, LLC. If you have any
questions about the contents of this brochure, please contact us at 949-718-1600. 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. Any reference to or use of
the terms “registered investment adviser” or “registered,” does not imply that Beacon Pointe Advisors, LLC, or any person associated
with Beacon Pointe Advisors, LLC has achieved a certain level of skill or training.
Additional information about Beacon Pointe Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov
ITEM 2 - MATERIAL CHANGES
The purpose of this page is to inform you of the material changes made to our brochure since
the previous annual update. The last annual update was March 31, 2025. There have been no
material changes since that filing.
2
Beacon Pointe Advisors, LLC
March 2026
ITEM 3 - TABLE OF CONTENTS
ITEM 2 - MATERIAL CHANGES ............................................................................................................ 2
ITEM 3 - TABLE OF CONTENTS ........................................................................................................... 3
ITEM 4 - ADVISORY BUSINESS ............................................................................................................. 7
Description of Advisory Firm .................................................................................................................... 7
Advisory Services Offered ......................................................................................................................... 7
Envestnet UMA ...................................................................................................................................... 8
SEI .......................................................................................................................................................... 9
Wrap Fee Program ................................................................................................................................. 9
Participant Account Management (Discretionary) ................................................................................ 9
Consulting Services ................................................................................................................................... 9
Investment Policy Development ............................................................................................................ 9
Asset Allocation ................................................................................................................................... 10
Manager and/or Mutual Fund Search .................................................................................................. 10
Ongoing Monitoring of Managers ....................................................................................................... 10
Performance Evaluation ....................................................................................................................... 10
Custodial Search ................................................................................................................................... 10
Financial Planning Services (Stand-Alone) ............................................................................................. 11
Retirement Plan Services (RPS) Platform: .............................................................................................. 11
Fiduciary Investment Advisory Services ............................................................................................. 11
Retirement Plan Vendor Search & Benchmarking .............................................................................. 11
Plan Design & Compliance Consulting ............................................................................................... 11
Participant Engagement & Education .................................................................................................. 12
Plan Sponsor Governance & Fiduciary Oversight ............................................................................... 12
Ongoing Retirement Plan Monitoring & Analytics ............................................................................. 12
Outsourced Chief Investment Officer Services (OCIO) .......................................................................... 12
Proprietary Private Funds ........................................................................................................................ 12
Interval Fund ............................................................................................................................................ 12
Assets Under Management ...................................................................................................................... 13
ITEM 5 - FEES AND COMPENSATION ............................................................................................... 13
Fee Schedule ............................................................................................................................................ 13
Wealth Advisory Services .................................................................................................................... 13
3
Beacon Pointe Advisors, LLC
March 2026
Consulting Services ............................................................................................................................. 15
Financial Planning Services (Stand-Alone) ......................................................................................... 15
Retirement Plan Consulting Services ................................................................................................... 16
Outsourced Chief Investment Officer Services (OCIO) ...................................................................... 16
Proprietary Private Funds .................................................................................................................... 16
Interval Funds ...................................................................................................................................... 16
Billing Method ......................................................................................................................................... 17
Financial Planning Services ................................................................................................................. 18
Retirement Plan Consulting Services ................................................................................................... 18
Other Fees and Expenses ..................................................................................................................... 18
Termination .............................................................................................................................................. 19
Other Compensation ................................................................................................................................ 19
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ....................... 20
ITEM 7 - TYPES OF CLIENTS ............................................................................................................... 20
Account Requirements ............................................................................................................................. 20
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ....... 20
Methods of Analysis ................................................................................................................................ 20
Investment Strategies ............................................................................................................................... 21
Manager Selection Process .................................................................................................................. 21
Investing Involves Risk ............................................................................................................................ 22
Specific Security Risks ............................................................................................................................ 23
General Risks of Owning Securities .................................................................................................... 23
Independent Manager Strategies and Risks ......................................................................................... 23
Alternative Asset Classes ..................................................................................................................... 23
Structured Notes ................................................................................................................................... 24
Mutual Funds (Open-end Investment Company) ................................................................................ 24
Exchange-Traded Funds (ETFs) .......................................................................................................... 25
Real Estate Investment Trusts (REIT) ................................................................................................. 25
Interval Fund Risks .............................................................................................................................. 26
Private Funds ....................................................................................................................................... 26
Margin Risk ......................................................................................................................................... 27
Values-based Investing, Environmental, Social and Governance “ESG” ........................................... 27
Digital Assets Risk ............................................................................................................................... 27
Tax-Loss Harvesting Risk .................................................................................................................... 27
Allocation and Planning Tools ................................................................................................................. 28
4
Beacon Pointe Advisors, LLC
March 2026
ITEM 9 - DISCIPLINARY INFORMATION ........................................................................................ 28
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ...................... 28
Related Insurance Agency ....................................................................................................................... 28
Related Investment Adviser ..................................................................................................................... 28
Port Street Investments LLC ................................................................................................................ 28
Other Related Businesses ......................................................................................................................... 29
BPMAX Fund ...................................................................................................................................... 29
Agents of Unaffiliated Broker-Dealer ................................................................................................. 30
Investment by the KKR Stockholder ....................................................................................................... 30
Other Activities and Affiliations .............................................................................................................. 31
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING .................................................................................................................. 32
Code of Ethics .......................................................................................................................................... 32
Personal Trading Practices ................................................................................................................... 32
Participation or Interest in Client Transactions ....................................................................................... 33
Beacon Pointe Private Funds ............................................................................................................... 33
Beacon Pointe Interval Fund ................................................................................................................ 33
Port Street Investments, LLC ............................................................................................................... 33
ITEM 12 - BROKERAGE PRACTICES ................................................................................................ 34
Factors Considered in Selecting Broker-Dealers for Client Transactions ............................................... 34
Research and Other Benefits ................................................................................................................ 34
Brokerage for Client Referrals ................................................................................................................. 37
Schwab Advisor Network .................................................................................................................... 37
Fidelity Wealth Advisor Solutions®.................................................................................................... 37
Directed Brokerage .................................................................................................................................. 38
Aggregation and Allocation of Transactions ........................................................................................... 39
ITEM 13 - REVIEW OF ACCOUNTS .................................................................................................... 39
Account Reviews ..................................................................................................................................... 39
Account Reporting ................................................................................................................................... 40
Financial Plan Reviews ............................................................................................................................ 40
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ............................................... 40
Benefits We Receive from Custodial Brokers ..................................................................................... 40
Client Referrals .................................................................................................................................... 40
Interval Fund ........................................................................................................................................ 41
Sponsorship of Corporate Events ......................................................................................................... 41
5
Beacon Pointe Advisors, LLC
March 2026
ITEM 15 - CUSTODY ............................................................................................................................... 41
ITEM 16 - INVESTMENT DISCRETION ............................................................................................. 42
ITEM 17 - VOTING CLIENT SECURITIES ......................................................................................... 43
Proxy Voting ............................................................................................................................................ 43
Class Actions ........................................................................................................................................... 43
ITEM 18 - FINANCIAL INFORMATION ............................................................................................. 44
6
Beacon Pointe Advisors, LLC
March 2026
ITEM 4 - ADVISORY BUSINESS
Description of Advisory Firm
Beacon Pointe Advisors, LLC (“Beacon Pointe,” “we,” “our,” or “us”) is an independently owned
limited liability company headquartered in Newport Beach, California. In February 2002, Beacon
Pointe Advisors, LLC started operating as an investment advisor registered with the U.S. Securi-
ties and Exchange Commission. KKR Polyphony Aggregator L.P. (“KKR Stockholder”), an
investment vehicle beneficially owned by investment funds and entities managed or sponsored
by Kohlberg Kravis Roberts & Co. L.P., owns a stake in Beacon Pointe.
Beacon Pointe’s principal business includes providing investment advisory services and consult-
ing services to individual and institutional investors. We focus on asset preservation and growth
through the implementation of investment strategies and the selection of third-party investment
managers, for which we have developed our own proprietary process.
Advisory Services Offered
Beacon Pointe’s service offerings include (1) Wealth advisory services (2) Consulting services
on investment and non-investment related matters, (3) Financial planning services (4) Retirement
Plan Services (“RPS”) Platform, and (4) Outsourced Chief Investment Officer Services
(“OCIO”).
Wealth Advisory Services
A client can engage Beacon Pointe to implement investment recommendations on a fee basis with
Beacon Pointe actively managing client assets under our Wealth Advisory Agreement (the “Ad-
visory Agreement”). Under the Advisory Agreement, Beacon Pointe will:
1. Manage a portion or all the assets designated by the client in accordance with the terms
and conditions of the Advisory Agreement. Additionally, we may recommend clients au-
thorize the discretionary management of a portion of their assets by certain unaffiliated
third-party investment managers (“Independent Managers”) where appropriate based on
the client’s stated investment objectives.
2. Provide ongoing monitoring and reviewing of each Independent Manager.
3. In some cases, manage a portion of the client’s assets by primarily allocating the assets
among various classes of shares of no-load mutual funds, Exchange Traded Funds (ETFs),
real estate investment trusts (REITs), direct equities/bonds or private funds. From time-
to-time Beacon Pointe invests our clients’ assets in a mutual fund advised by a related
investment adviser. See Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading for our policies surrounding this practice.
4. Provide financial planning services for certain clients, subject to certain conditions as
noted below.
We offer these services on a discretionary basis, including the hiring and/or firing of Independent
Managers, in accordance with the client’s investment objectives and any reasonable restrictions
the client wishes to place on the account. Beacon Pointe reserves the right to not accept and/or
terminate management of a client’s account if we feel that the client-imposed restrictions would
7
Beacon Pointe Advisors, LLC
March 2026
limit or prevent us from meeting or maintaining the client’s investment strategy. Clients should
notify us promptly in writing if there are any changes in their financial situation, investment ob-
jectives, or if they wish to impose or change any restriction(s) on their account.
Beacon Pointe primarily invests client accounts by utilizing Independent Managers to manage
the various asset classes determined in the client’s asset allocation. Generally, client portfolios
are managed by the Independent Managers through separate accounts or through mutual funds,
depending on the vehicles offered by the Independent Managers and account size or other con-
siderations specific to each client. Beacon Pointe may also directly manage the client’s account
utilizing mutual funds, ETFs, REITs, and private funds. In addition, client portfolios at times utilize
other strategies or contain securities not included on the recommended list during an acquisition
or at the direction of the client; typically, these assets will be transitioned over time to the Inde-
pendent Managers or securities that are recommended by Beacon Pointe. Clients may place rea-
sonable restrictions on the management of their account with the Independent Managers. We
describe our process for selecting managers and the material investment risks for our strategies
under Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss, below.
Beacon Pointe may offer investment advice on any investment held by the client at the start of
the advisory relationship. Beacon Pointe occasionally offers advice regarding additional types of
investments if they are appropriate to address the individual needs, goals, and objectives of the
client or in response to client inquiry.
We discuss our discretionary authority below under Item 16 - Investment Discretion.
Private clients will be provided with comprehensive financial planning advice, upon client re-
quest and subject to the minimum account size, in accordance with the Advisory Agreement. To
provide this comprehensive financial planning advice, we gather information regarding the cli-
ent’s current and historical status in the areas of net worth, income, expenses, taxes, investments,
retirement plans and insurance, as well as future goals and objectives. We then develop a written
personalized plan, which includes specific recommendations in applicable areas. Areas of focus
may include retirement planning, education funding, survivor needs analysis, risk management,
or wealth transfers planning. These financial planning services do not include legal or tax advice,
preparation of any kind of income tax, gift, or estate tax returns, or preparation of any legal doc-
uments, including wills or trusts. Clients may enter into separate agreements with Beacon Pointe
affiliates for tax services.
Envestnet UMA
Beacon Pointe works with a third-party service provider, Envestnet, Inc., to help support the oper-
ational needs of managing and servicing our advisory accounts. Envestnet performs operational
functions including but not limited to fee billing, portfolio reporting, account rebalancing and
trade execution, based on instructions provided by Beacon Pointe and/or the Independent Man-
ager(s). When providing these services, Envestnet acts as an agent of Beacon Pointe. Envestnet
charges a tiered platform fee based on assets under management. As assets on the Envestnet plat-
form increase, the fee decreases. There is a minimum annual fee of $50 per account. The Envestnet
fees are separate from, and in addition to, custodial fees and Independent Manager fees.
Additional services are available on the UMA platform for an additional fee at the client's request.
These services include, but are not limited to, tax overlay and impact overlay.
8
Beacon Pointe Advisors, LLC
March 2026
SEI
In limited instances, Beacon Pointe uses SEI Investments Corporation (SIMC) as a sub-adviser.
Clients on the SIMC platform pay a 0.08% fee, in addition to the advisory fee paid to Beacon
Pointe. This fee typically covers trading and transaction costs and custodial fees. Clients on the
SIMC platform will also incur other fees related to the investments on the platform, such as but
not limited to mutual fund and ETF fees.
Wrap Fee Program
Certain legacy clients of firms acquired by Beacon Pointe participate in the Wrap Fee Program.
The Wrap Fee Program is not offered to any new or prospective clients of Beacon Pointe.
Participant Account Management (Discretionary)
We offer management of certain held-away retirement plan accounts, such as 401(k), 403(b), or
other employer-sponsored plan accounts, on a discretionary basis. In these instances, we may use
a third-party platform, Pontera, to facilitate view-and-trade access to these accounts without re-
quiring or retaining client log-in credentials to affect trades.
We are not affiliated with the platform in any way and receive no compensation from them for
using their platform. A link is provided to the Client, allowing them to connect an account(s) to
the platform. Once Client account(s) are connected to the platform, Beacon Pointe will review
the current account allocations. When deemed necessary, Beacon Pointe will rebalance the ac-
count considering client investment goals and risk tolerance, and any change in allocations will
consider current economic and market trends. The goal is to improve account performance over
time, minimize loss during difficult markets, and manage internal fees that harm account perfor-
mance. Client accounts will be reviewed at least annually, and allocation changes will be made
as deemed necessary.
American Funds F-2 Direct-at-Fund Program
Beacon Pointe has entered into an agreement with American Funds Service Company through
which it can provide its clients with access to funds within the American Funds Family, specifi-
cally F-2 and F-2 529 share classes. The F-2 Direct-at-Fund Program offers investors the ability
to invest directly at American Funds, with fee-based options rather than commissions or sales
charges. F-2 shares do not have an up-front or contingent deferred sales charge, and they do not
carry a 12b-1 fee, but they may have slightly higher administrative costs than other share classes.
Clients in this program should refer to the fund’s prospectus to better understand the costs and
expenses of the specific mutual fund, including the expenses of the F-2 share class.
Consulting Services
Beacon Pointe offers the following consulting services, usually on a non-discretionary basis. We
offer one or more of these services to a client depending on the client’s needs at the time of the
initial consultation.
Investment Policy Development
Beacon Pointe works with clients to develop an investment policy and corresponding guidelines
that are consistent with the client’s goals and objectives.
9
Beacon Pointe Advisors, LLC
March 2026
Asset Allocation
Beacon Pointe assists clients in making asset allocation decisions for their investment portfolios.
The goal of asset allocation is to assist clients in finding the asset mix that is most likely to achieve
their investment objective within acceptable risk parameters. Clients receive a report illustrating
historical data of portfolio combinations compared against the client’s existing mix, including,
but not limited to, recommendations on a prospective asset allocation combination.
Manager and/or Mutual Fund Search
Beacon Pointe may recommend multiple investment management firms or mutual funds to indi-
vidual and/or institutional clients. We segregate and classify managers and/or mutual funds by
investment style or class. Generally, Beacon Pointe will present the client with a report showing
firm ownership, key employees, assets under management, investment process description, port-
folio characteristics, portfolio returns, and fees. Additional factors, such as minimum and maxi-
mum account size, location of the firm, stability of performance, dispersion among published
returns, investment philosophy, and accounts gained or lost, may be considered when recom-
mending investment managers and/or mutual funds. We describe our process for selecting man-
agers under Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss, below.
Ongoing Monitoring of Managers
Beacon Pointe will monitor, on an ongoing basis, each manager that we select to manage client’s
assets and provide periodic reports and/or recommendations to the client.
Performance Evaluation
We offer performance measurement services to clients on a quarterly basis depending upon the
client’s preference. Performance reporting varies depending upon client needs, but usually in-
cludes time-weighted returns for each portfolio shown against an appropriate benchmark, asset
allocation of the client’s total account, percentage of the client’s assets allocated among various
investment managers or securities, cash flow summary, and the standard deviation of returns ver-
sus an appropriate benchmark.
Custodial Search
Beacon Pointe offers to provide clients with recommendations, comparisons, and analysis of var-
ious custodial facilities.
Under this service, Beacon Pointe will perform a custodial search – like a manager search – and
present a group of custodial candidates to our client for review and selection. Beacon Pointe’s
professionals have extensive experience conducting custodial searches for our clients. Custodial
searches typically include the following information:
• History (Ownership of Firm)
• Key Personnel
• Systems utilized
• Size of Firm
• Average Client Size
• Fees
10
Beacon Pointe Advisors, LLC
March 2026
• Master Trust Capabilities
• Accrual Account Methods
• Conversion Process
• Technology Plans (5 Years)
• Online Capabilities
Financial Planning Services (Stand-Alone)
Beacon Pointe provides clients with comprehensive financial analyses, including non-invest-
ment-related matters. This service includes gathering information about the client’s net worth,
income, expenses, taxes, investments, retirement plans, insurance, goals, and objectives. We then
develop a personalized written plan, which includes specific recommendations. Focus areas may
include retirement planning, education funding, survivor needs analysis, risk management or
wealth transfers planning. Our financial planning services do not include preparing income tax,
gift or estate tax returns or preparing any legal documents, including wills or trusts.
In some instances, Beacon Pointe provides limited-scope financial planning focused on specific
planning topics such as assessing progress towards goals like funding retirement, college educa-
tion, or survivor’s needs.
Retirement Plan Services (RPS) Platform:
Beacon Pointe offers consulting and advisory services for employer-sponsored retirement plans,
including 401(k), 403(b), 457, Defined Benefit, SIMPLE IRA, SEP IRA, and Nonqualified De-
ferred Compensation plans. These services are designed to support plan sponsors in fulfilling
their fiduciary obligations under the Employee Retirement Income Security Act (ERISA).
Fiduciary Investment Advisory Services
Beacon Pointe’s RPS Platform offers investment advisory services to plan sponsors in both a
discretionary (ERISA 3(38)) and non-discretionary (ERISA 3(21)) capacity. As a 3(38)-invest-
ment manager, the firm takes responsibility for selecting, monitoring, and adjusting the plan’s
investments according to the Investment Policy Statement (IPS). The firm provides investment
recommendations in a 3(21)-advisory role, while the plan sponsor retains decision-making au-
thority. Beacon Pointe also offers fiduciary education and best practices guidance to assist plan
sponsors in managing their responsibilities under ERISA.
Retirement Plan Vendor Search & Benchmarking
Beacon Pointe assists plan sponsors with evaluating and selecting recordkeepers, third-party ad-
ministrators (TPAs), trustees, and fund managers. The firm conducts vendor searches, due dili-
gence, and benchmarking services. Beacon Pointe facilitates request-for-proposal (RFP) pro-
cesses, negotiates service agreements, and performs cost analyses to help plan sponsors assess
and document the reasonableness of plan fees.
Plan Design & Compliance Consulting
Beacon Pointe offers guidance to plan sponsors on plan design, regulatory compliance, and op-
erational efficiency for various employer-sponsored plans. The firm works with third-party
11
Beacon Pointe Advisors, LLC
March 2026
administrators, ERISA attorneys, and recordkeepers to evaluate plan structure and perform com-
pliance testing. We also assist with plan governance, document updates, and audit preparation.
Participant Engagement & Education
Beacon Pointe offers participant engagement and education programs to help employees under-
stand their retirement benefits and plan their finances. These services may include group semi-
nars, one-on-one financial wellness coaching, and digital learning tools tailored to each plan’s
demographics.
Plan Sponsor Governance & Fiduciary Oversight
Beacon Pointe supports plan sponsors in fulfilling their fiduciary responsibilities under ERISA
Sections 404(a) and 404(c). The firm facilitates investment committee meetings, prepares fiduci-
ary review materials, and implements governance best practices to help plan sponsors document
decision-making processes and mitigate fiduciary risk.
Ongoing Retirement Plan Monitoring & Analytics
Beacon Pointe provides ongoing monitoring and analytics to help plan sponsors assess invest-
ment performance, participant trends, and overall plan health. The firm utilizes plan-level and
participant-level analytics to evaluate investment effectiveness, track participation rates, and con-
tribution behaviors, and measure retirement readiness.
Outsourced Chief Investment Officer Services (OCIO)
Beacon Pointe offers OCIO services on a discretionary basis, primarily to institutional clients that
seek to delegate the implementation of investment management services. The scope of services
Beacon Pointe offers to OCIO clients may include, but is not limited to:
Investment Policy Development and Review
•
• Asset Allocation Modeling
•
Investment Manager Selection and Monitoring
• Performance Measurement and Portfolio Oversight
We describe the fees charged for our consulting services below under Item 5 - Fees and Com-
pensation.
Proprietary Private Funds
Beacon Pointe GP, LLC acts as the general partner of proprietary private funds (the BP Real
Estate Opportunities Fund, L.P., BP Real Estate Opportunities Fund II, L.P., BP Credit Oppor-
tunities Fund, L.P., BP Credit Opportunities Fund (BVI), LP (“BPCOF (BVI)”), BP Credit Op-
portunities Fund II, L.P., BP Credit Opportunities Fund II (BVI), LP (“BPCOF II (BVI)”), and
the BP GIM Opportunities Fund, L.P. (“BPGIM”), organized to invest in real estate, credit-ori-
ented, and Environmental, Social, Governance (“ESG”) vehicles respectively (the “Private
Funds”). The Private Funds are available only to “Accredited Investors,” as the term is defined
by Rule 501 of the Securities Act of 1933, and only by a private offering memorandum. Addi-
tional information on these standards is provided in the offering documents for the Private Funds.
Interval Fund
12
Beacon Pointe Advisors, LLC
March 2026
Beacon Pointe Multi-Alternative Fund (“BPMAX” or the “Fund”) is a continuously offered, non-
diversified, closed-end interval fund registered under the Investment Company Act of 1940 (the
“1940 Act”). The Fund is an interval fund that will provide limited liquidity by offering to make
quarterly repurchases of shares at net asset value (“NAV”), which will be calculated on a daily
basis. The Fund’s investment objective is to seek to achieve long-term capital appreciation by
pursuing positive absolute returns across market cycles.
The Fund pursues its investment objective by strategically investing in a portfolio of closed-end
interval funds (“Underlying Funds”) that invest in a variety of asset classes. While the Fund will
primarily invest indirectly through the Underlying Funds, the Fund may also invest directly in
the underlying holdings of the Underlying Funds alongside the Underlying Funds (the “Co-In-
vestments”). The Fund may also invest, directly or indirectly through mutual funds and ETFs, in
treasuries and short-term bonds with up to 15% of the Fund’s net assets for liquidity management
purposes. The Fund expects to invest in both domestic and foreign securities.
Assets Under Management
Beacon Pointe manages client assets on a continuous and regular basis. As of 12/31/2025, the
total amount of assets under our management was:
Discretionary Assets
Non-Discretionary Assets
Total Assets
$50,539,424,600
$ 4,333,110,114
$54,872,534,714
ITEM 5 - FEES AND COMPENSATION
Fee Schedule
Wealth Advisory Services
Beacon Pointe charges an annualized asset-based fee for our advisory services. Our fees will vary
by client based on the services provided and other relevant considerations. Fees are negotiable
and generally are charged based on a percentage of the market value of the portfolio under man-
agement. The specific fees and way fees are charged and calculated are described in the Advisory
Agreement between Beacon Pointe and the client.
The advisory fee for private clients generally ranges from 0.50% to a maximum of 1.50% of
assets under management, subject to a minimum quarterly fee of $1,250, and can be waived at
our discretion.
Generally, Beacon Pointe requires clients to maintain a minimum account size of $1 million but
reserves the right to reduce or waive the minimum account requirement at our discretion. The
advisory fees noted above do not include the investment management fees charged by Independ-
ent Managers. In some cases, the fees charged by the Independent Manager may be greater than
those charged by Beacon Pointe. Solely with respect to certain private fund investments made in
the past, clients have negotiated to pay a percentage of profits from such investments in lieu of a
management fee.
Many client relationships predate the implementation of Beacon Pointe's current fee schedule.
For this reason, clients' fees are sometimes higher or lower than those reflected in the previous
13
Beacon Pointe Advisors, LLC
March 2026
schedule or are subject to additional or differing terms. Moreover, legacy clients originating from
firms acquired by Beacon Pointe have fee schedules that differ from Beacon Pointe's standard fee
schedule, as most clients maintain their previous fee schedule. In some cases, a post-acquisition
/new Beacon Pointe client may be so connected to an acquired/legacy client that for asset house-
holding/billing purposes, it makes sense that both the new client and legacy client's fee schedule
reflects that of the legacy client. Once the clients sign Beacon Pointe’s Advisory Agreement, we
will work with the client to transition the fees to our standard procedure.
Envestnet UMA
Beacon Pointe charges advisory fees to clients in the Envestnet UMA program. The advisory fees
are negotiable and charged based on a percentage of the market value of the portfolio under man-
agement, per a tiered fee schedule set forth in the agreement between Beacon Pointe and the
client.
Envestnet charges a tiered platform fee ranging from 0.02% to a maximum of 0.04% per account
per year. As assets on the Envestnet platform increase, the program fee decreases. However, there
is a minimum annual fee of $50 per account.
The Envestnet fees noted above do not include the investment management fees charged by In-
dependent Managers.
Wrap Fee Program
As noted above in Item 4 Advisory Business Certain legacy clients of firms acquired by Beacon
Pointe participate in the Wrap Fee Program. The Wrap Fee Program is not offered to any new or
prospective clients of Beacon Pointe.
Beacon Pointe charges advisory fees to clients in the Wrap Fee Program. The advisory fees are
negotiable and are charged based on a percentage of the market value of the portfolio under man-
agement, per a tiered fee schedule set forth in the Advisory Agreement between Beacon Pointe
and the client. The Wrap Fee Program fee ranges from 0.50% to a maximum of 2.0% of assets
under management.
Client participation in the Wrap Fee Program will generally cost less than the same services would
for an account outside of the Wrap Fee Program, although the amount of savings will depend on
the volume of trading in the client’s account, advisory fees for unbundled services, and the cus-
todian transaction and execution fees charged for a non-wrap fee program account. Under the
terms of the Wrap Fee Program, Beacon Pointe will pay trading and execution costs imposed by
the custodian for transactions in the client’s account directly managed by Beacon Pointe. This
arrangement may present a potential conflict of interest for us, as we have a financial disincentive
to engage in active trading. However, transaction fees are not a material consideration for Beacon
Pointe in deciding whether to engage in any trading or the level of trading activity through the
custodian.
Participant Account Management (Dis-
cretionary)
Beacon Pointe charges our standard advisory fee as described above under “Wealth Advisory
Services”.
14
Beacon Pointe Advisors, LLC
March 2026
American Funds F-2 Direct-at-Fund
Program
Beacon Pointe charges an advisory fee to clients that ranges from 0.25% to 1.0% of value of the
assets invested in the American Funds F-2 Direct Program.
SEI
Clients in the sub-advisory program through SEI pay a 0.08% fee, which is in addition to the
advisory fee paid to Beacon Pointe. This fee typically covers trading and transaction costs and
custodial fees. Clients on the SIMC platform will also incur other fees related to the investments
on the platform such as but not limited to mutual fund and ETF fees.
Consulting Services
Beacon Pointe charges either an annual retainer fee, project fee, or hourly fee, depending on
which types of consulting services are being provided. For ongoing consulting services, Beacon
Pointe charges an annual retainer fee. A tiered fee schedule is charged to each client based on a
percentage of the client’s assets under supervision.
For discretionary portfolios, the annual retainer fee generally ranges from 0.20% to 0.50% of
assets under supervision.
For non-discretionary portfolios, the annual retainer fee generally ranges from 0.08% to 0.50%
of plan assets or assets under supervision.
Generally, we will charge clients who have assets over $500 million a fixed fee, which we base
on the scope of work. All retainer fees are subject to negotiation and could vary depending on the
client’s specific circumstances.
Beacon Pointe may enter into an agreement with a client to perform services on a project or one-
time basis. In these instances, Beacon Pointe charges a project fee. The minimum project fee per
client is generally $25,000, and consulting project components are also subject to a minimum fee
and/or minimum term commitments. All fees are subject to negotiation and can vary depending on
the client’s specific circumstances.
Hourly fees will typically range between $350 and $500 per hour, depending on the expertise of
the persons providing the services and the nature and complexity of each client’s circumstances.
The hourly fee and payment terms are negotiable and, at our discretion, waived. The terms will
be stated in the consulting services agreement. Generally, we offer educational seminars on a
fixed fee basis. We will quote clients a fixed fee based on the estimated time to complete the
seminar multiplied by our hourly rate. This fee may be negotiable depending on the nature and
complexity of the seminar.
Financial Planning Services (Stand-Alone)
Financial planning services are generally paid on a project fee or hourly basis. Fees are determined
based on the nature and complexity of the planning services provided. Fees are subject to nego-
tiation and could vary depending on the client’s specific circumstances. The project fee includes
the development and delivery of the plan. Beacon Pointe will also periodically review plans upon
request of the client on an hourly basis.
15
Beacon Pointe Advisors, LLC
March 2026
Retirement Plan Consulting Services
Beacon Pointe charges advisory fees for retirement plan consulting services. The advisory fees
are negotiable and are charged based on a percentage of plan assets under the management per a
tiered fee schedule. Our current advisory fee generally ranges from 0.05% to 0.50% of the plan
assets or assets under management.
Outsourced Chief Investment Officer Services (OCIO)
For OCIO services, the annual retainer fee generally ranges from 0.20% to 0.50% of assets under
supervision.
Proprietary Private Funds
The general partner for each of the Private Funds is Beacon Pointe GP, LLC:
• BP Real Estate Opportunities Fund, LP (“BPREOF”)
• BP Real Estate Opportunities Fund II, LP (“BPREOF II)
• BP Credit Opportunities Fund, LP (“BPCOF”)
• BP Credit Opportunities Fund (BVI), LP (“BPCOF (BVI)”)
• BP Credit Opportunities Fund II, LP (“BPCOF II)
• BP Credit Opportunities Fund II (BVI), LP (“BPCOF II (BVI)”)
• BP GIM Opportunity Fund, LP (“BPGIM”)
The general partner is entitled to receive a 1.00% annual management fee from each of the Private
Funds; however, this fee is waived for limited partners who are also clients of Beacon Pointe.
Management fees for the BPREOF are based on the sum of (a) the uncalled capital of such limited
partner as of the last business day of the previous calendar quarter plus (b) the unreturned invested
capital of the Partnership allocable to such limited partner as of the last business day of the previ-
ous calendar quarter. For the BPCOF, BPCOF II, BPCOF(BVI), BPCOF II (BVI), and the
BPREOF II, the management fee will equal 1% per annum of capital commitment of such limited
partner as of the last business day of the previous calendar quarter, and following the expiration
of the investment period, the management fee will be calculated based on the unreturned invested
capital of the Partnership allocable to such limited partner as of the last business day of the pre-
vious calendar quarter. For the BPGIM Opportunity Fund, LP, the management fee will be 1%
per annum of the capital commitment of such limited partner as of the last business day of the
previous quarter. Fees are assessed quarterly in advance and prorated, as applicable. Each of the
Private Funds will pay for all ordinary and extraordinary fees, costs, and expenses incurred by it
or on its behalf. Additional information regarding fund fees and expenses is further outlined in the
offering
for the Private Funds.
documents
Interval Funds
Beacon Pointe serves as the investment adviser to the BPMAX Fund. We have an active interest
in this Fund. BPMAX is a continuously offered, non-diversified, closed-end interval fund regis-
tered under the Investment Company Act of 1940 (the “1940 Act”). The Fund pursues its invest-
ment objective by strategically investing in a portfolio of closed-end interval funds (“Underlying
Funds”) that invest in various asset classes.
16
Beacon Pointe Advisors, LLC
March 2026
The Fund has retained Beacon Pointe as its investment adviser, and subject to the supervision of
the Fund Trust’s Board of Trustees, we provide a continuous program of supervision for the
Fund’s assets. In addition, Beacon Pointe will supervise and provide oversight of the Fund’s ser-
vice providers, and furnish the Fund office facilities, equipment and personnel for servicing the
management of the Fund. Under our advisory agreement with the Fund, Beacon Pointe is entitled
to compensation for our management services, a monthly management fee based on the Fund’s
daily average net assets at the following annual rate: 0.95%. We may recommend that current
and prospective clients invest in the Fund instead of investing in an independently managed ac-
count. This creates a conflict that we believe is mitigated because BPA clients may choose an-
other Fund at their discretion. In addition, Beacon Pointe does not charge an additional advisory
fee to clients for assets invested in the BPMAX Fund.
It is important to note that the Fund’s management fee may sometimes be higher or lower than
the advisory fee clients might otherwise pay to Beacon Pointe for non-fund assets. This means
that depending on the fee structure, clients may end up paying more or less by investing in
BPMAX than they would if their assets were managed outside the Fund. Clients should carefully
review the Fund’s prospectus, particularly the fees and expenses associated with an investment
in BPMAX and consider their overall investment objectives and financial situation when deter-
mining whether an investment in the Fund is appropriate.
Billing Method
Wealth Advisory Services
Beacon Pointe’s advisory fees are generally payable quarterly in advance or in arrears, depending
on the client agreement. We charge one fourth of the annual fee each quarter based on the market
value of the client’s portfolio as of the last day of the calendar quarter. For some custodians we
work with, such as SEI, fees are paid quarterly in arrears based on the average daily balances in
a client’s account.
If a client contributes capital to the account, including the initial capital, on a date other than the
last day of a calendar quarter, we will charge the account a prorated portion of the fees for that
calendar quarter for that contribution based on the number of days remaining in that calendar
quarter. Similarly, if a client withdraws a portion of the assets from the account on any date other
than the last day of a calendar quarter, we will prorate the fees previously paid for that calendar
quarter based on the number of days elapsed in that quarter before the withdrawal and we will
refund the unearned portion to the client’s account. Fees for the initial quarter under management
are pro-rated and charged in arrears with the next quarter’s advance payment.
Our advisory fee is calculated based on all assets in the portfolio unless expressly excluded. This
means that fee calculations include cash balances invested in money market funds, short-term
investment funds, ETFs, mutual funds, the entire market value of margined assets and short po-
sitions (if any), alternative investments (if any), and all other investment holdings. In low-yield
environments, your advisory fee may sometimes exceed the money market yield.
Beacon Pointe aggregates related client accounts for the purpose of calculating the advisory fees
applicable to each client. Beacon Pointe also reserves the right to reduce or waive our fees for
employee or family accounts and certain client accounts. With client authorization, Beacon Pointe
will automatically withdraw Beacon Pointe’s advisory fee from the client’s account held by an
independent custodian. Typically, the custodian withdraws advisory fees from the client’s ac-
count during the first month of each quarter based on Beacon Pointe’s instruction. All clients will
17
Beacon Pointe Advisors, LLC
March 2026
receive brokerage statements from the custodian no less frequently than quarterly. The custodian
statement will show the deduction of the advisory fee. We will make rare exceptions to this policy
and bill clients directly. In these rare cases, Beacon Pointe will send an invoice to the client who
chooses not to have advisory fees withdrawn directly from their custodian account. The invoice
is payable upon receipt and will include the fee calculation and amount due.
For clients that maintain margin accounts, Beacon Pointe will include the margin balance in the
total billable value of a client’s account. Therefore, the market value of the client’s account and
corresponding fee payable by the client will increase. Clients authorizing margin are advised of
the potential conflict of interest whereby the client’s decision to employ margin will correspond-
ingly increase the management fee payable to us. For more information, please refer to Item 8 –
Methods of Analysis, Investment Strategies, and Risk of Loss.
The billing practices applicable to legacy clients of firms acquired by Beacon Pointe may deviate
from the general practices described above, as the operations of the acquired firm are transitioned
and integrated into Beacon Pointe. Clients should refer to their applicable Agreements to under-
stand the specific billing practices applicable to their assets.
Consulting Services
Clients with project-based consulting services under a retainer will generally be billed quarterly
in advance based on one fourth of the annual fee. Project fees are payable upon submission of the
final bill once the project is completed. The fee and payment terms for hourly engagements are
negotiable.
Financial Planning Services
Financial planning services are generally paid for on an hourly or fixed fee basis. Total hourly
fees or stated fixed fee are due and payable at the time of execution of the consulting agreement.
All consultations/plans shall be rendered within six months of the execution of the consulting
agreement.
Retirement Plan Consulting Services
Retirement plan services are generally paid in equal quarterly installments, payable in arrears on
the 15th business day of each calendar quarter during the term of the agreement.
Other Fees and Expenses
Beacon Pointe’s fees do not include custodian fees, or the fees charged by Independent Managers.
Clients should review the Independent Manager’s ADV 2 Brochure regarding fee schedules,
other fees charged by Independent Managers, and applicable billing methods. Certain custodial
platforms (including Raymond James) may charge asset-based program or platform fees for cus-
tody, execution, administration, and/or manager services. These fees are separate from Beacon
Pointe’s advisory fee and may be billed together with our advisory fee depending on the platform
and account structure.
Except for the Wrap Fee Program (as described above), clients pay all brokerage commissions,
stock transfer fees, and/or other similar charges incurred in connection with transactions in the
accounts managed by Beacon Pointe from the assets in the account, which are in addition to the
fees the client pays to Beacon Pointe. See Item 12 - Brokerage Practices below for more
18
Beacon Pointe Advisors, LLC
March 2026
information. Clients, including those in the Envestnet UMA Program, and Wrap Fee Program also
pay management fees of Independent Managers, as well as all brokerage commissions, stock trans-
fer fees, and/or other similar charges incurred in connection with transactions in the accounts
managed by the Independent Managers.
In addition, any mutual fund shares held in a client’s account may be subject to deferred sales
charges, 12b-1 fees, and other fund-related expenses. The fund’s prospectus fully describes the
fees and expenses. All fees paid to Beacon Pointe for advisory services are separate and distinct
from the fees and expenses charged by mutual funds. Mutual funds pay advisory fees to their
managers, which are indirectly charged to all holders of the mutual fund shares. Consequently,
clients with mutual funds in their portfolios are effectively paying both Beacon Pointe and the
mutual fund manager for the management of their assets.
In certain limited circumstances, Beacon Pointe receives advisory compensation from unaffili-
ated third-party firms for providing advisory services related to held-away assets, including leg-
acy commission-based annuities. These arrangements and the related conflicts of interest are de-
scribed in Item 10 – Other Financial Industry Activities and Affiliations.
Termination
Wealth Advisory Services
Either party may terminate the Advisory Agreement at any time. Clients are requested to provide
thirty (30) days’ written notice of termination to the other party; however, the 30-day notice may
be waived at Beacon Pointe’s sole discretion.
Beacon Pointe will refund any prepaid, unearned advisory fees based on the effective date of
termination. Upon termination of the agreement, we will send the client a prorated refund of un-
earned advisory fees using the following formula: (Fees Paid) x (Days Remaining in Quarter) /
(Total Number of Days in Quarter).
Consulting Services
Either party may terminate the consulting agreement upon thirty (30) days written notice to the
other party, however the 30-day notice may be waived at Beacon Pointe’s sole discretion.
Upon notice of termination, Beacon Pointe will calculate fees due for services provided through
the date of termination. Any fees that we have earned for the services provided will be due upon
termination. If the client paid fees in advance that were more than the amount due for services,
Beacon Pointe will refund any unearned fees to the client. We will pro-rate the refund based on
the effective date of termination.
Other Compensation
Beacon Pointe does not accept compensation for the sale of securities or other investment prod-
ucts, including asset-based sales charges or service fees from the sale of mutual funds.
Beacon Pointe may recommend that clients invest in mutual funds and interval funds managed by
Beacon Pointe or a related adviser. While Beacon Pointe does not directly receive additional
compensation resulting from the use of products managed by related firms, our related adviser
receives management fees from the mutual fund.
19
Beacon Pointe Advisors, LLC
March 2026
Beacon Pointe receives a management fee for our services as the adviser to the BPMAX interval
fund. However, the advisory fee is waived for clients of Beacon Pointe.
Additionally, Beacon Pointe receives fees through its affiliated general partner of the Private
Funds, even though the management fee is waived for clients of Beacon Pointe, Beacon Pointe
has an interest in recommending the Private Funds for reasons of larger size, better deals, cost
savings, etc. We describe our policies in recommending related products in Item 11 – Code of
Ethics, Participation or Interest in Client Transactions and Personal Trading. For more infor-
mation on our relationships with related advisers, see Item 10 – Other Financial Industry Activ-
ities and Affiliations, below.
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Solely with respect to certain private fund investments made in the past, clients have negotiated
to pay a percentage of profits from such investments in lieu of a management fee. Beacon Pointe
does not otherwise charge 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
Beacon Pointe generally provides investment advisory and consulting services to individual and
institutional clients. Institutional clients include trusts, estates, charitable organizations, corpora-
tions, pension and profit-sharing plans, state or municipal organizations, other business entities,
a proprietary closed-end interval fund, and Private Funds.
Account Requirements
Generally, Beacon Pointe requires clients to maintain a minimum account size of $1 million.
Significant fund withdrawals will result in a request for additional fund deposits, if necessary, to
continue with management of accounts. We generally combine family accounts to meet the ac-
count size minimum. Beacon Pointe reserves the right to reduce or waive the account minimum
requirements at our discretion.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK
OF LOSS
The descriptions in Item 8 pertain only to wealth advisory services, including the Envestnet UMA
Program and Wrap Fee Program.
Methods of Analysis
In beginning a new client relationship, Beacon Pointe seeks to fully understand each client’s
needs, circumstances, priorities, and goals. We work with clients to develop an investment strategy
that reflects the client’s current objectives, time horizon, risk tolerance, income needs, and incor-
porates any restrictions the client wishes to impose on the account.
Beacon Pointe utilizes modeling techniques to determine an optimal target allocation for the cli-
ent’s assets. For this process, Beacon Pointe uses both asset allocation-modeling programs as well
as our own analysis to develop what we believe is a meaningful plan for our clients, including
target asset class mixes.
20
Beacon Pointe Advisors, LLC
March 2026
The “core” asset classes we follow and typically include in our recommended investment portfo-
lios include the following:
• US Equity
• Non-US Equity (Developed Markets)
• Non-US Equity (Emerging Markets)
• US Fixed Income
• Global Fixed Income
• Private Real Estate
• Private Equity
• Private Credit
• Hedge Funds
• Hedged Equity
• Real Assets
We track various categories and investment styles within each category (i.e., value, growth, small
versus large, etc.) Based on each client’s customized asset allocation plan, we seek out investment
managers in each asset class to implement the investment strategy, based on Beacon Pointe’s due
diligence. The client’s investments will draw from our Focus List, which comprises a select group
of firms that meet or exceed our performance and qualitative criteria (see our Manager Selection
Process, below).
Investment Strategies
Beacon Pointe is a firm believer in risk control through proper portfolio diversification. Diversi-
fication, or allocating client portfolios across a broad range of asset classes and investment man-
agers, is generally considered an essential component of the effectiveness of an investment port-
folio. Proper diversification minimizes or reduces the volatility and risk associated with a client’s
investments. We believe proper asset allocation diversification produces a portfolio with more
appealing risk/return characteristics than investing in one single asset class or with one invest-
ment manager.
Beacon Pointe utilizes both active and passive management. For active management, our research
process seeks managers who, we believe, can outperform their respective (index) benchmarks on
a risk- adjusted basis, net of fees, over long periods of time.
Manager Selection Process
Beacon Pointe has a “Focus List” for selecting managers. To be included managers must com-
plete our due diligence process, which involves the step outlined below. This process applies to
all types of investments, including active, passive, and alternative investments. While there is
overlap, not all steps apply to passive and alternative investments.
• Manager Sourcing – from referrals, industry contacts, manager databases, and directed
outreach. We gather basic information from public databases and incorporate data into
our internal database of investment manager information.
• Quantitative Analysis – we assess manager performance with an emphasis on long-term
consistency, risk-adjusted returns, up and down-market capture and peer group ranks.
21
Beacon Pointe Advisors, LLC
March 2026
Beacon Pointe requires firms to adhere to the Global Investment Performance Standards
and undergo third party verification or have an SEC-registered mutual fund.
• Qualitative Analysis – we meet, either virtually or in person, with members of the in-
vestment team, and review the firm’s ownership and compensation structure, investment
philosophy, portfolio construction process, risk controls, research and back-office re-
sources, and trading capabilities.
• Portfolio Analysis – our assessment typically includes discussions regarding specific
portfolio holdings, holdings-based style analysis (when available), and in some cases on-site
visits where we may request full access to the investment manager firm’s records, valua-
tion models, personnel, and research reports. Most due diligence is conducted virtually
with video and phone conferences.
• Product Evaluation – we review the manager’s Form ADV Part 2A Brochure, negotiate
management fees and account minimums, and perform final scoring and research.
• Beacon Pointe Investment Committee Decision – a careful review by key investment
personnel determines if the manager qualifies for our Focus List or is moved to our ‘Man-
ager Bench’ for later consideration.
Clients of firms acquired by Beacon Pointe may continue to use their existing managers. We honor
these arrangements for legacy clients who are typically limited to holding these investments with-
out making new purchases. Occasionally, we conduct a limited-scope due diligence process to
approve the legacy client or office to invest in the strategy or use the manager and place them on
our "Approved List."
Investing Involves Risk
All Beacon Pointe clients should understand that investing in securities involves the risk of loss,
and clients should be prepared to bear that risk, including the risk of your original principal Past
performance is not indicative of future results, therefore, you should not assume that future per-
formance of any specific investment or investment strategy will be profitable. We do not provide
any representation or guarantee that your goals will be achieved.
Due to the inherent risk of loss associated with investing, the Firm cannot represent, guarantee,
or imply that our services and methods of analysis can or will predict future results, successfully
identify market peaks or bottoms, or insulate you from losses due to market corrections or de-
clines. There are certain additional risks associated with investing in securities.
Prior to entering into an agreement with Beacon Pointe, the client should carefully consider all
the following:
• The client should commit to management only those assets that the client believes will
not be needed for current purposes and that can be invested on a long-term basis, usually
a minimum of five to seven years.
• Volatility from investing in the stock market can occur.
• Over time the value of the client’s assets will fluctuate and at any time may be worth more
or less than the amount invested.
22
Beacon Pointe Advisors, LLC
March 2026
Specific Security Risks
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in re-
sponse to certain events taking place around the world. These include events directly involving
the issuers of the securities held as underlying assets of the mutual funds in a client’s account,
conditions affecting the general economy, and overall market changes. Other contributing factors
include local, regional, or global political, social, or economic instability and governmental or
governmental agency responses to economic conditions. Finally, currency, interest rate, and com-
modity price fluctuations can also affect security prices and income.
Independent Manager Strategies and Risks
The Independent Managers Beacon Pointe recommends utilize their own investment process and
methods of analysis. The strategies and securities these managers invest in may have different or
additional risks than those described in this brochure. For example, while Beacon Pointe does not
implement investment advice using margin transactions, some Independent Managers appointed
for the client utilize margin transactions in the discretionary management of client cash and se-
curities. Use of margin can increase volatility and magnify any investment losses in a client’s
account. Similarly, options are utilized in certain strategies. Options are complex financial instru-
ments and not suitable for all investors. Investing in options carries unique risks that can result in
the loss of all the invested principal. Clients can find more information about the strategies and
related risks of the Independent Managers in Item 8 – Methods of Analysis, Investment Strate-
gies and Risk of Loss in each manager’s Form ADV disclosure brochure.
Alternative Asset Classes
For those clients and portfolios, we have deemed it appropriate to include alternatives, we rec-
ommend the following alternative asset classes – real assets, private real estate, private equity,
private credit, hedged equity, and hedge funds.
Hedge funds and private equities can appear opaque as there are no high-quality established da-
tabases in existence like the public sector. This makes it more difficult to assess who is doing
well and, more importantly, who is doing poorly. This obscurity makes it more essential to un-
derstand the firms with whom you are doing business and affirms the importance of a solid qual-
itative as well as quantitative assessment.
Unlike other alternative investments, most hedge funds do not invest in private securities. Instead,
they apply alternative strategies to the traditional public equity and fixed income markets. The
benefits hedge funds can add to a portfolio include their return potential, lower volatility, and
relatively low correlation with equities and other market-driven investments.
In the alternative investment area, historical information is very limited. While longer return series
exist for some alternative strategies (such as venture capital), we feel that the data is of question-
able usefulness. Using venture capital as an example, performance is very dependent on the timing
of specific investments. In addition, since most venture capital investments are accounted for at
cost, the asset category has an artificially low volatility of returns. A common failing of asset
allocation models is their inability to distinguish if low volatility is inherent to the asset class, or
if it is because the asset is infrequently valued (e.g., not exchange-traded).
23
Beacon Pointe Advisors, LLC
March 2026
There are also unique manager selection issues in the alternative investment area. Although there
is no shortage of managers from which to choose, few have historical track records longer than a
few years. Even among more seasoned managers, it is difficult to compare performance on an
“apples to apples” basis. Since the investment vehicles are generally unregulated partnerships,
the methodologies used to calculate performance vary from manager to manager. Common per-
formance reporting problems include:
• Calculating “creative” internal rates of return (IRR).
• Presenting results before the deduction of substantial fees.
• Carrying “unrealized” investments at cost for long periods.
•
Ignoring the opportunity cost of holding cash while waiting for the managers to call for
capital.
Because of the lack of standards in reporting performance, a meaningful comparison of managers
may only be possible if returns are recalculated using consistent assumptions and practices.
Our research professionals ask the following questions, among others, when evaluating alterna-
tive managers:
•
Illiquidity – how often and under what circumstances can the client withdraw invested
capital?
• Lack of transparency – is the client comfortable investing with a manager who does not
•
reveal their holdings or activities?
Incentives – are there incentives for the manager to take undue risk given the perfor-
mance-based fee structure?
Structured Notes
Beacon Pointe may recommend the use of structured notes issued by unaffiliated domestic and
international banks. Structured notes are not bank deposits and are not insured by the Federal
Deposit Insurance Corporation or any other governmental agency. The terms and risks of each
structured note vary materially depending on the nature and volatility of the referenced asset, the
creditworthiness of the issuer, and the maturity of the instrument, among other factors. The gen-
eral risks associated with this type of investment include, but are not limited to, non-payment risk
(payment of interest and return of principal may be reduced, in whole or in part, due to underper-
formance of the referenced asset); counter-party risk (for reasons such as bankruptcy, the issuer
of the structured note may fail to pay all or a portion of the principal and interest due on the
structured note); and underperformance risk (depending on market conditions, the structured note
may underperform alternative allocations to traditional bonds, the referenced asset, or a combi-
nation of such investments). Structured notes are significantly riskier than conventional debt in-
struments. There is a risk of loss of some or all the principal at maturity.
Mutual Funds (Open-end Investment Company)
A mutual fund is a company that pools money from many investors and invests the money in
stocks, bonds, short-term money-market instruments, other securities or assets, or some combina-
tion of these investments. The portfolio of the fund consists of the combined holdings it owns.
Each share represents an investor’s proportionate ownership of the fund’s holdings and the in-
come those holdings generate. The price that investors pay for mutual fund shares is the fund’s
24
Beacon Pointe Advisors, LLC
March 2026
per share net asset value (NAV) plus any shareholder fees that the fund imposes at the time of
purchase (such as sales loads).
The benefits of investing through mutual funds include professional management, diversification,
affordability, and liquidity. Mutual funds also have features that some investors might view as
disadvantages:
Costs Despite Negative Returns
Mutual funds pay operating and other expenses from fund assets regardless of how the fund per-
forms, which are indirectly charged to all holders of the mutual fund shares. Depending on the
timing of their investment, investors may also have to pay taxes on any capital gains distribution
they receive. This includes instances where the fund went on to perform poorly after purchasing
shares.
Lack of Control
Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time, nor
can they directly influence which securities the fund manager buys and sells or the timing of those
trades.
Price Uncertainty
With a mutual fund, the price at which an investor purchases or redeems shares will typically de-
pend on the fund’s NAV, which the fund might not calculate until many hours after the investor
placed their order. In general, mutual funds must calculate their NAV at least once every business
day, typically after the major U.S. exchanges close.
Exchange-Traded Funds (ETFs)
An ETF is a type of Investment Company (usually, an open-end fund or unit investment trust)
containing a basket of stocks. Typically, the objective of a passively managed ETF is to achieve
returns similar to a particular market index, including sector indexes. A passively managed ETF
is like an index fund in that it will primarily invest in securities of companies that are included in
a selected market. ETFs may also be actively managed. Unlike traditional mutual funds, which
can only be redeemed at the end of a trading day, ETFs trade throughout the day on an exchange.
Like stock mutual funds, the prices of the underlying securities and the overall market can affect
ETF prices. Similarly, factors affecting a particular industry segment can affect ETF prices that
track that particular sector.
Real Estate Investment Trusts (REIT)
Securities issued by real estate investment trusts (REITs) primarily invest in real estate or real
estate- related loans. Equity REITs own real estate properties, while mortgage REITs hold con-
struction, development and/or long-term mortgage loans. Changes in the value of the underlying
property of the trusts, the creditworthiness of the issuer, property taxes, interest rates, tax laws,
and regulatory requirements, such as those relating to the environment all can affect the values
and liquidity of REITs. Both types of REITs are dependent upon management skill, the cash
flows generated by their holdings, the real estate market in general, and the possibility of failing
to qualify for any applicable pass-through tax treatment or failing to maintain any applicable ex-
emptive status afforded under relevant laws.
25
Beacon Pointe Advisors, LLC
March 2026
Interval Fund Risks
Interval funds are classified as closed-end funds but have some distinctive features that make
them different. Interval funds continuously or periodically offer their shares at a price based on
the fund’s net asset value. However, most do not trade on a national securities exchange and
instead buy back or “repurchase” shares directly from investors. Repurchases are offered period-
ically (often quarterly), so investors are provided with limited liquidity. Accordingly, investments
in interval funds can expose investors to liquidity risk. For example, if redemption requests ex-
ceed the repurchase thresholds, the manager will limit redemptions by “gating.” That risk is more
significant in funds that invest in securities of companies with smaller market capitalizations,
derivatives, or securities with substantial market and/or credit risk. There is no guarantee that
investors can sell their shares at any given time or in the desired amount. Interval funds may offer
to repurchase as low as 5% of shares in each quarter. If many investors attempt to exit their
positions during market stress, the fund manager may only be able to accommodate this slowly
over multiple quarters. In these instances, the fund manager may limit redemptions by “gating”
the fund to allow for orderly liquidation. Because of this, it’s best to consider investments in
interval funds to be illiquid.
Private Funds
A private fund is an investment vehicle that pools capital from a number of investors and invests
in securities and other instruments. In almost all cases, a private fund is a private investment
vehicle that is typically not registered under federal or state securities laws. So that private funds
do not have to register under these laws, issuers make the funds available only to certain sophis-
ticated or accredited investors and cannot be offered or sold to the general public. Private funds
are generally smaller than mutual funds because they are often limited to a small number of in-
vestors and have a more limited number of eligible investors. Many, but not all, private funds use
leverage as part of their investment strategies. Private funds management fees typically include
a base management fee along with a performance component. In many cases, the fund’s managers
become “partners” with their clients by making personal investments of their own assets in the
fund. Most private funds offer their securities by providing an offering memorandum or private
placement memorandum, known as “PPM” for short. The PPM covers important information for
investors and investors should review this document carefully and should consider conducting
additional due diligence before investing in private funds. The primary risks of private funds
include the following:
• Private funds do not sell publicly and are therefore illiquid. An investor may not be able
to exit a private fund or sell its interests in the fund before the fund closes.
• Private funds are subject to various other risks, including risks associated with the types
of securities in which the private fund invests.
Derivatives
Derivatives, including forward currency contracts, futures, options and commodity-linked deriv-
atives and swaps, may be riskier than other types of investments because they may be more sen-
sitive to changes in economic and market conditions, and could result in losses that significantly
exceed the investor’s original investment in the derivative. Many derivatives create leverage
thereby causing a portfolio to be more volatile than it would have been if it had not been exposed
to such derivatives. Derivatives also expose a portfolio to counterparty risk (the risk that the
26
Beacon Pointe Advisors, LLC
March 2026
derivative counterparty will not fulfill its contractual obligations), including the credit risk of the
derivative counterparty.
Margin Risk
Margin trading involves interest charges and risks, including the potential to lose more than the
amount deposited or the need to deposit additional collateral in a falling market. A margin trans-
action occurs when an investor uses borrowed assets by using other securities as collateral to
purchase financial instruments. When a security is purchased using margin, any gains or losses
from the financial instruments are magnified. If a client authorizes the use of margin, and margin
is used by the firm in managing the client’s investment portfolio, the market value of the client’s
account and the corresponding fee payable to the firm will generally increase, unless the accounts
hold options, in which case the fee may be decreased under certain market conditions. Therefore,
in addition to understanding and assuming the additional principal risk associated with the use of
margin, clients authorizing margin are advised of the potential conflict of interest, whereby the
client’s decision to employ margin will correspondingly increase the advisory fee payable to the
firm.
Values-based Investing, Environmental, Social and Governance “ESG”
Values-based or ESG Based Investing Risk – When directed by the client, ESG investments may
be included in the client’s portfolio. It is important to note that fund managers consider ESG
factors to varying degrees. Not every fund incorporates ESG factors in the same manner or de-
gree, which can cause difficulty comparing different funds. As such, there is no standard matrix
or benchmark upon which ESG factors affecting performance can be compared. ESG funds may
include or exclude securities based on ESG practices vs. other investment methodologies, im-
pacting performance, fund expenses, and investment risk. The use of ESG factors could result in
selling or avoiding investments that subsequently perform well or purchasing investments that
subsequently underperform. As a result, accounts that take ESG factors into account could under-
perform similar accounts that do not consider ESG factors. In addition, to the extent ESG factors
are considered when voting proxies, doing so may not always be consistent with maximizing per-
formance of the issue or the account holding such security. We base our ESG recommendations
on the information provided to us by the issuers.
Digital Assets Risk
Digital assets are an emerging asset class that has yet to be fully defined. There is still a lack of
clarity regarding the regulatory framework that will govern this investment sector. In addition,
there are various risk factors, including but not limited to valuation risk, liquidity risk, volatility
risk, technology risk, and legal, tax, and regulatory risk, each with its own probability and po-
tential impact.
Tax-Loss Harvesting Risk
This strategy intends to sell an ETF or mutual fund at a taxable loss and replace those positions
with a holding that has similar historical and expected future performance, thereby having minor
impact on the overall strategic allocation but capturing the tax loss. Because past performance is
not indicative of future performance, there is potential for the future performance of the replace-
ment position to differ from that of the initial holding. This strategy may also increase trading
frequency and transaction costs.
27
Beacon Pointe Advisors, LLC
March 2026
Allocation and Planning Tools
The modeling tools Beacon Pointe uses to create financial plans and asset allocations for clients
rely on various assumptions, such as estimates of inflation, risk, economic conditions, and rates
of return on security asset classes. All return assumptions use asset class returns, not returns of
actual investments, and do not include fees or expenses that clients would pay if they invested in
specific products.
Modeling software is only a tool used to help guide Beacon Pointe and the client in developing
an appropriate plan, and we cannot guarantee that clients will achieve the results shown in the plan.
Results will vary based on the information provided by the client regarding the client’s assets, risk
tolerance, and personal information. Changes to the program’s underlying assumptions or differ-
ences in actual personal, economic, or market outcomes may result in materially different results
for the client. Clients should carefully consider the assumptions and limitations of the software
as disclosed on the analysis reports and should discuss the results of the plan with a qualified in-
vestment professional before making any changes in their investment or allocation program.
ITEM 9 - DISCIPLINARY INFORMATION
Beacon Pointe and our personnel seek to maintain the highest level of business professionalism,
integrity, and ethics. Beacon Pointe does not have any disciplinary information to disclose.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Related Insurance Agency
Beacon Pointe is a related person of Beacon Pointe Insurance Services, LLC (“BPIS”), a Califor-
nia licensed insurance agency. Beacon Pointe and BPIS are under joint ownership and control.
Certain personnel of Beacon Pointe are also licensed insurance agents of BPIS and sell insurance
products to advisory clients and then receive commissions on the sale of insurance products. The
insurance commissions are separate from and in addition to any advisory fees that a client pays
to Beacon Pointe for investment advisory services. A conflict of interest may arise as potential
BPIS insurance sales might create an incentive to recommend products based on compensation
our personnel may earn. Clients are under no obligation to act on our personnel’s insurance rec-
ommendations or to effect the transactions through BPIS or our personnel if they decide to follow
the recommendations. In all cases, we fully disclose insurance commissions to the client.
Related Investment Adviser
Port Street Investments LLC
Beacon Pointe is a related person of Port Street Investments, LLC (“PSI”), an SEC registered
investment adviser that acts as investment adviser to a registered investment company (mutual
fund). Beacon Pointe Holdings, LLC is the majority shareholder of PSI. In some cases, Beacon
Pointe recommends that our clients invest in a fund advised by PSI. PSI receives investment
management fees from the funds it manages. Due to the common ownership between Beacon
Pointe and PSI, we have a conflict of interest in recommending mutual funds managed by this
related firm. See Item 11 – Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading for our policies addressing these conflicts of interest.
28
Beacon Pointe Advisors, LLC
March 2026
A Partner/Managing Director of Beacon Pointe serves as a trustee for the Managed Portfolio Series
Trust (the “Trust”), of which Port Street Investments, LLC is the adviser to a mutual fund within the
trust. This employee is recused from voting on any Port Street related items under his duties as a
trustee for the Trust.
Other Related Businesses
Beacon Pointe has a related entity, Beacon Pointe GP, LLC, which acts as the general partner of
the Private Funds. The Private Funds are not publicly offered or traded and are only available to
“Accredited Investors” as the term is defined by Rule 501 of the Securities Act of 1933. The
confidential offering memorandum and subscription agreement (the “Offering Documents”) pro-
vide additional information on these standards. Prospective investors in the Private Funds receive
the Offering Documents. Beacon Pointe or its related entity receives fees in connection with man-
agement services rendered to the Private Funds and therefore has an interest in recommending the
Private Funds to Beacon Pointe’s clients. See Item 11 – Code of Ethics, Participation or Interest
in Client Transactions and Personal Trading for our policies addressing these conflicts of in-
terest.
Some offices of Beacon Pointe provide tax preparation and accounting services. These offices
may recommend these services to advisory clients when appropriate. Accounting and tax prepa-
ration services are separate and distinct from the advisory services offered and are provided for
separate and typical compensation. Clients are under no obligation to use our firm for accounting
and/or tax preparation services. Beacon Pointe may also recommend the services of other non-
affiliated professionals to provide tax services. Our clients are under no obligation to engage the
services of any recommended professional. It is at the sole discretion of the client whether they
accept any recommendation made by Beacon Pointe. Beacon Pointe does not receive any referral
fees when we recommend non-affiliated professionals.
BPMAX Fund
Beacon Pointe serves as the investment adviser to the BPMAX Fund. We have an active interest
in this Fund. BPMAX is a continuously offered, non-diversified, closed-end interval fund regis-
tered under the Investment Company Act of 1940 (the “1940 Act”). The Fund pursues its invest-
ment objective by strategically investing in a portfolio of closed-end interval funds (“Underlying
Funds”) that invest in various asset classes.
The Fund has retained Beacon Pointe as its investment adviser, and subject to the supervision of
the Fund Trust’s Board of Trustees, we provide a continuous program of supervision for the
Fund’s assets. In addition, Beacon Pointe will supervise and provide oversight of the Fund’s ser-
vice providers, and furnish the Fund office facilities, equipment and personnel for servicing the
management of the Fund. Under our advisory agreement with the Fund, Beacon Pointe is entitled
to compensation for our management services, a monthly management fee based on the fund’s
daily average net assets at the following annual rate: 0.95%
Certain principals of our firm are officers of the Fund. Additionally, our retirement plans as well
as our employees may be shareholders in the Fund. We may recommend that current and pro-
spective clients invest in the Fund instead of investing in an independently managed account.
This creates a conflict that we believe is mitigated because BPA clients may choose another fund
at their discretion. In addition, Beacon Pointe does not charge an additional advisory fee to clients
for assets invested in the BPMAX Fund. See Item 11 – Code of Ethics, Participation or Interest
29
Beacon Pointe Advisors, LLC
March 2026
in Client Transactions and Personal Trading for our policies addressing these conflicts of in-
terest.
Agents of Unaffiliated Broker-Dealer
Certain of Beacon Pointe’s personnel are also licensed as registered representatives with Purshe
Kaplan Sterling Investments (“PKS”), a broker-dealer member of FINRA/SIPC. Beacon Pointe is
not affiliated with PKS. In their capacity as registered representatives, these individuals receive
trailing compensation from prior sales of securities. They may also receive usual and customary
commissions for sales of securities through PKS. Receipt of commissions for securities sales is
a conflict of interest as it gives these registered representatives an incentive to recommend in-
vestment products based on the additional compensation received. Beacon Pointe’s advisory cli-
ents are not charged both advisory fees and transaction-related fees on investment products that
these registered representatives recommend. When client portfolios hold securities for which re-
lated registered representatives receive commissions and/or trailing 12b-1 fees Beacon Pointe
does not charge advisory fees on those securities.
Certain representatives of Beacon Pointe Advisors, LLC are also Registered Representatives of-
fering securities through APW Capital, Inc., a broker-dealer member of FINRA/SIPC. Beacon
Pointe is not affiliated with APW Capital. In their capacity as registered representatives, these
individuals receive trailing compensation from prior sales of securities. They may also receive
usual and customary commissions for sales of securities through APW Capital. Receipt of com-
missions for securities sales is a conflict of interest as it gives these registered representatives an
incentive to recommend investment products based on the additional compensation received.
Beacon Pointe’s advisory clients are not charged both advisory fees and transaction-related fees
on investment products that these registered representatives recommend.
Investment by the KKR Stockholder
The KKR Stockholder has purchased a stake in Beacon Pointe. The KKR Stockholder, which is
owned by investment funds and other entities managed or sponsored by Kohlberg Kravis Roberts
& Co. L.P. for the benefit of its third-party investors, holds its stake in Beacon Pointe for invest-
ment purposes. Beacon Pointe is not a direct or indirect subsidiary of KKR & Co. Inc. or of
Kohlberg Kravis Roberts & Co. L.P. (together with their affiliates, including the KKR Stock-
holder and the funds and other entities that own it, the “KKR Group”). The KKR Group does not
participate in or manage the day-to-day management or operations of Beacon Pointe. Beacon
Pointe acts autonomously and separately from the KKR Group, subject to and in compliance with
its own separate compliance policies and procedures (including an information barrier that sepa-
rates the investment activities of the KKR Group and Beacon Pointe), and Beacon Pointe has
agreed to indemnify the KKR Group for certain matters arising from its business and operations.
Moreover, no member of the KKR Group: (i) is directly or indirectly a sponsor of or investment
adviser to any Beacon Pointe client (including any Beacon Pointe sponsored private funds); and
(ii) has or will have any obligations (contractual, fiduciary, or otherwise) to Beacon Pointe’s
clients, operations, or investments. The KKR Group expressly disclaims any and all liability for
or obligations with respect to Beacon Pointe’s clients, operations or investments.
KKR & Co. Inc. and its subsidiaries (the “KKR Corporate Group”) sponsor investment funds that
invest in private equity, credit, and real assets and have strategic partners that manage hedge
funds. The KKR Corporate Group also sponsors and manages investment funds and other vehi-
cles that facilitate co-investment alongside proprietary investments or in specific or multiple
30
Beacon Pointe Advisors, LLC
March 2026
portfolio companies and other assets invested in investment funds managed by KKR. The KKR
Corporate Group also includes KKR Capital Markets LLC and MCS Capital Markets LLC, each
of which is a U.S. registered broker-dealer, and certain non-US entities authorized to conduct
broker-dealer activities.
Although Beacon Pointe and the KKR Group operate independently, their affiliation may, in
certain circumstances, create conflicts of interest or the appearance of conflicts of interest. The
KKR Corporate Group will continue to engage in its other investment and financial activities (for
its own account and the account of others) and is permitted from time to time to enter into trans-
actions with, or otherwise deal with, Beacon Pointe, its clients or with companies in which Bea-
con Pointe clients invest and take actions (or omit to take actions) in connection with any such
transactions or other dealings that are contrary to (or otherwise conflict with) a Beacon Pointe
client’s interests. The KKR Corporate Group is also permitted from time to time to provide ser-
vices to Beacon Pointe, its clients, and companies in which Beacon Pointe clients invest, and in
such cases, generally will be paid fees (which may include warrants or other securities) for such
services, and no Beacon Pointe client will receive the benefit of such fees. In addition, Beacon
Pointe clients may make investments in companies in which the KKR Group has also invested (and
such investments by the KKR Group may be in the same or different levels of the capital struc-
ture), and in connection with such investments, the KKR Group may take actions (or omit to take
actions) that are contrary to (otherwise conflict with) Beacon Pointe clients’ interests. The KKR
Group is expected to pursue a broad range of investment strategies and invest in a broad range of
securities, instruments, and other assets globally. From time to time, investment opportunities
pursued by KKR Group may overlap or compete with the investment opportunities pursued by
Beacon Pointe. As noted above, because the businesses of the KKR Group and Beacon Pointe
will be operated separately and independently from each other, the KKR Group will not be pro-
hibited from pursuing its own investment opportunities and may do so without regard to consid-
erations for Beacon Pointe’s clients. Beacon Pointe recommends the KKR Global Impact Fund
when appropriate for clients. KKR Global Impact Fund is owned and managed by Beacon Pointe’s
majority owner, KKR Stockholder, which presents a conflict of interest. Beacon Pointe receives
no financial benefit from KKR in our recommendation of the KKR Global Impact Fund or as a
result of being partially owned by a KKR affiliate entity. Lastly, they do not have any role on the
investment committee. However, KKR’s affiliated advisers earn certain fees (i.e., management
fees, incentive fees) in connection with investments in KKR Funds and, therefore, will benefit
from investments in the Global Impact Fund.
Other Activities and Affiliations
For an asset-based fee, Beacon Pointe may contract directly with third party firms, including
broker- dealers, to provide advisory consulting services related to certain held-away, commis-
sion-based annuity contracts for which those third-party firms (and their affiliated broker-deal-
ers) serve as the agent of record and maintain the client relationship with respect to the annuity
assets.
Those services do not include any assumption of discretionary authority over any brokerage
accounts and do not involve Beacon Pointe Advisors receiving brokerage or securities transac-
tion commissions in connection with these arrangements.
Beacon Pointe’s role is limited to providing advisory and consulting services related to such
held-away annuities, and any implementation of client-authorized actions occurs through the ap-
plicable broker-dealer or carrier. This compensation arrangement creates a potential conflict of
31
Beacon Pointe Advisors, LLC
March 2026
interest, which Beacon Pointe addresses through its fiduciary obligations, supervision, and poli-
cies designed to ensure advice is provided in the client’s best interest.
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
Beacon Pointe believes that we owe clients the highest level of trust and fair dealing. As part of
our fiduciary duty, we place the interests of our clients ahead of the interests of the firm and our
personnel. Beacon Pointe’s personnel are required to always conduct themselves with integrity
and follow the principles and policies detailed in our Code of Ethics. Beacon Pointe’s Code of
Ethics attempts to address specific conflicts of interest that either we have identified or that could
likely arise. Beacon Pointe’s personnel are required to follow clear guidelines from the Code of
Ethics in areas such as gifts and entertainment, other business activities, and adherence to applica-
ble federal securities laws. Additionally, individuals who make securities recommendations to
clients or who have access to nonpublic information regarding any clients’ purchase or sale of
securities are subject to personal trading policies governed by the Code of Ethics (see below).
Beacon Pointe will provide a complete copy of the Code of Ethics to any client or prospective
client upon request.
Personal Trading Practices
Beacon Pointe and our personnel can purchase or sell securities for ourselves, regardless of
whether the transaction would be appropriate for the client account. Beacon Pointe and our per-
sonnel can purchase or sell securities for ourselves that we also recommend to clients. This in-
cludes related securities (e.g., warrants, options, or futures). This presents a conflict of interest as
we may have the incentive to take investment opportunities from clients for our own benefit,
favor our personal trades over client transactions when allocating trades, or use the information
about the transactions we intend to make for clients to our personal benefit by trading ahead of
clients.
Our policies to address these conflicts include the following:
• Personal securities transactions will never adversely affect clients. Beacon Pointe will
monitor the trading activity of our personnel to confirm that the interests of clients come
first, and that the trading activity complies with applicable securities laws. All securities
transactions and holdings in any account of our personnel, including accounts for which
the individual is considered a beneficial owner, are subject to review by Beacon Pointe.
• Day trading (buying and selling in the same security on the same business day) of any
security is strictly prohibited.
• Conflicts of interest also can arise when Beacon Pointe’s personnel become aware of
Limited Offerings or IPOs, including private placements or offerings of interests in lim-
ited partnerships or any thinly traded securities, whether public or private. Given the in-
herent potential for conflict, Limited Offerings and IPOs demand extreme care. Beacon
Pointe’s personnel are required to obtain pre-approval from the Chief Compliance Officer
before trading in these types of securities.
32
Beacon Pointe Advisors, LLC
March 2026
For the clients for which Beacon Pointe assigns a sub-adviser, Beacon Pointe’s personnel do not
have access to the transactions in client accounts until after the trades have been placed. There-
fore, we cannot take advantage of client trades in accounts managed by sub-advisers.
Participation or Interest in Client Transactions
Beacon Pointe Private Funds
Beacon Pointe may recommend the Private Funds, which are managed by Beacon Pointe GP,
LLC, a related entity, to clients whom Beacon Pointe believes the investment is suitable. Beacon
Pointe only recommends a Private Fund to clients who satisfy the requisite income and/or net
worth requirements and for whom Beacon Pointe believes the investment is appropriate based on
the client’s ability to accept the risk. Clients will receive the confidential offering memorandum
and disclosure of known risks before investing. A conflict exists because Beacon Pointe stands to
benefit from additional investments in the Private Funds. To address this conflict, when Beacon
Pointe recommends a Private Fund to an advisory client that invests in the Private Fund, that
client’s Private Fund management fees will be waived.
Beacon Pointe Interval Fund
Beacon Pointe may recommend that its clients invest in the BPMAX Fund, a closed-end interval
fund registered under the Investment Company Act of 1940 (the “1940 Act”), if we believe the
investment is suitable for the clients. Beacon Pointe serves as the investment adviser to the
BPMAX Fund.
As the investment adviser to the Fund, Beacon Pointe receives a monthly management fee at the
annual rate of 0.95% of the Fund’s daily net assets for the services it provides to the Fund.
This arrangement creates a potential conflict of interest, as Beacon Pointe has a financial incen-
tive to recommend investments in the Fund. To mitigate this conflict, Beacon Pointe does not
charge an additional advisory fee to clients for assets invested in the BPMAX Fund. Instead,
clients will incur only the management fee charged at the fund level.
It is important to note that the Fund’s management fee may sometimes be higher or lower than
the advisory fee clients might otherwise pay to Beacon Pointe for non-fund assets. This means
that depending on the fee structure, clients may end up paying more or less by investing in
BPMAX than they would if their assets were managed outside the Fund.
Clients should carefully review the Fund’s prospectus, particularly the fees and expenses associ-
ated with an investment in BPMAX and consider their overall investment objectives and financial
situation when determining whether an investment in the Fund is appropriate.
Port Street Investments, LLC
Additionally, Beacon Pointe may recommend that its clients invest in a mutual fund advised by
Port Street Investments, LLC, (“PSI”), a related investment adviser. Due to the common owner-
ship between Beacon Pointe and PSI, Beacon Pointe has a conflict of interest in recommending
mutual funds managed by this related firm. If Beacon Pointe utilizes mutual funds or investment
products managed by related firms’ clients will not be charged Beacon Pointe’s asset-based advi-
sory fee on the portion of the client’s assets invested in the fund.
33
Beacon Pointe Advisors, LLC
March 2026
ITEM 12 - BROKERAGE PRACTICES
We generally recommend that clients maintain their assets through either Charles Schwab & Co.,
Inc. (“Schwab”), member FINRA/SIPC, Fidelity Investments Institutional Operations Company,
Inc. (“Fidelity”), member FINRA/SIPC, SEI Private Trust Company (“SEI”), Pershing Advisor
Solutions, LLC (“Pershing”), or Raymond James & Associates, Inc. (“Raymond James”).
Schwab, Fidelity, SEI, Pershing, and Raymond James are unaffiliated, SEC-registered broker-
dealers and FINRA (Financial Industry Regulatory Authority) member firms and are qualified
custodians. They offer services to independently registered investment advisors, including but not
limited to, custody of securities, trade execution, and clearance and settlement of transactions.
We are independently owned and operated, and unaffiliated with Schwab, Fidelity, SEI, Pershing
or Raymond James.
In addition to the above-listed custodians, Beacon Pointe has entered into an agreement with
HSBC to maintain the accounts of certain legacy clients acquired by the firm. Generally, Beacon
Pointe does not utilize HSBC’s custodian services for new or existing clients.
Client accounts enrolled in the Wrap Fee Program are maintained through Schwab, Fidelity, or
Pershing. Under certain rare circumstances, Beacon Pointe will make exceptions to the recom-
mended custodians and broker-dealers and permit clients to select their own.
Factors Considered in Selecting Broker-Dealers for Client Transactions
We seek to recommend a custodian/broker who hold client assets and execute transactions on terms
that are, overall, most advantageous compared to other available providers and their services. We
consider a wide range of factors, including, among others, their respective financial strength, rep-
utation, execution, pricing, commissions for transactions, research, and service. Prior to engaging
Beacon Pointe to provide asset management services the client will be required to enter into a
formal agreement with Beacon Pointe setting forth the terms and conditions under which Beacon
Pointe shall manage the client’s assets. The client will also execute a brokerage/custodial/clearing
agreement between the client and custodian.
Under certain circumstances Beacon Pointe will have discretionary authority to determine the
securities to buy and/or sell and the amount of such securities. In those circumstances, such secu-
rities will primarily be limited to various classes of shares of no-load mutual funds and Exchange
Traded Funds (ETFs). Beacon Pointe will generally execute such purchases or sales with Schwab,
Fidelity, SEI, or Pershing. Beacon Pointe will also have discretionary authority for Wrap Fee Pro-
gram clients, but all purchases and sales will be executed with Schwab, Fidelity, or Pershing.
Research and Other Benefits
Beacon Pointe participates in the Schwab Advisor Services™ (formerly called Schwab Institu-
tional®) program. Schwab offers services to independent investment advisors, including custody
of securities, trade execution, clearance, and settlement of transactions. Beacon Pointe receives
some benefits from Schwab through its participation in these programs. The additional economic
benefits (“Additional Services”) received by Beacon Pointe or our personnel through participa-
tion in the program do not depend on the amount of brokerage transactions directed to Schwab.
The Additional Services we receive from Schwab may or may not be offered to any other inde-
pendent investment Advisors participating in the program. The Additional Services provided al-
low us to better monitor and service client accounts maintained at the respective broker-
dealer/custodian. Beacon Pointe does not consider this a primary factor when determining
34
Beacon Pointe Advisors, LLC
March 2026
whether to recommend that a client utilize or select the services of a certain broker-dealer/custo-
dian. There is no direct link between our participation in these programs and the investment advice
we give to our clients. However, we receive economic benefits through our participation in the
program that are typically not available to Schwab retail investors. Schwab provides Additional
Services to Beacon Pointe at their sole discretion, and at their own expense. Beacon Pointe does
not pay any fees to Schwab for Additional Services.
Beacon Pointe’s receipt of Additional Services raises conflicts of interest. Schwab’s assistance
with our technology-related expenses is based on the expectation that Beacon Pointe will main-
tain a certain level of client assets under custody at Schwab. Schwab has offered to pay $125,000
annually towards our technology-related expenses for the length of our relationship with Schwab
if we maintain a minimum of $3 billion of client assets in accounts with Schwab in perpetuity.
Schwab’s offer is not limited to a specific time frame, and Schwab may modify or terminate the
agreement at its sole discretion. Beacon Pointe’s receipt of Additional Services does not diminish
our duty to act in the best interests of our clients, including seeking best execution of trades for
client accounts.
Beacon Pointe recommends Schwab (to clients for custody and brokerage services. The broker-
age services include the execution of securities transactions, custody, research, and access to mu-
tual funds and other investments that are otherwise generally available only to institutional in-
vestors or would require a significantly higher minimum initial investment.
Schwab also makes available various support services. Some of those services help us manage or
administer our clients’ accounts; others help us manage and grow our business. Schwab generally
does not charge separately for custody services. However, they do receive compensation by
charging commissions or other fees on the trades they execute or that settle into clients’ Schwab
accounts. These services are generally available to independent investment advisors on an unso-
licited basis, at no charge to them, so long as a total of at least $10 million of Beacon Pointe’s
clients’ assets are maintained in accounts at Schwab. This commitment benefits our clients be-
cause the overall commission rates clients pay are lower than they would be otherwise.
In addition to commissions, Schwab charges 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 secu-
rities bought or the funds from the securities sold are deposited (settled) into a client’s brokerage
account. These fees are in addition to the commission or other compensation the client pays the
executing broker-dealer. Because of this, we have Schwab execute most trades for client accounts
to minimize trading costs. Schwab also makes available to us other products and services that
benefit us but may not directly benefit our clients or their accounts. These products and services
assist us in managing and administering our clients’ accounts. They include investment research,
both Schwab’s research and that of third parties. We use this research to service all or a substantial
number of our client’s accounts, including accounts not maintained at Schwab. In addition to
investment research, Schwab also makes available software and other technology that:
1. Provide access to client account data (such as duplicate trade confirmations and account
statements).
2. Access to an electronic communications network for client order entry and account infor-
mation.
3. Facilitate trade execution and allocate aggregated trade orders for multiple client accounts.
4. Provide pricing and other market data.
5. Facilitate payment of our fees from our clients’ accounts; and
35
Beacon Pointe Advisors, LLC
March 2026
6. Assist with back-office functions, recordkeeping, and client reporting.
Schwab also offer other services intended to help us manage and further develop our business
enterprise. These services may include:
1. Educational conferences and events.
2. Consulting on technology, compliance, legal, and business needs.
3. Publications and conferences on practice management and business succession; and
4. Access to employee benefits providers, human capital consultants, and insurance provid-
ers.
Schwab provides some of these services themselves. In other cases, they will arrange for third-
party vendors to provide the services to us. Schwab also discounts or waives its fees for some of
these services or pays all or a part of a third party’s fees. They also provide other benefits, such
as occasional business entertainment for our personnel. By receiving Additional Services, Beacon
Pointe will receive additional economic benefits, which may or may not be offered to any other
independent advisor. In evaluating whether to recommend that client’s custody their assets
Schwab, we may consider the availability of some of the foregoing products and services and other
arrangements as part of the total mix of factors we consider and not solely the nature, cost or
quality of custody and brokerage services provided by Schwab, which creates a conflict of interest.
Clients should refer to the Independent Manager’s ADV 2 Brochure for information regarding
soft dollar benefits that Independent Managers may receive.
Beacon Pointe participates in the Raymond James service program. While there is no direct link
between the investment advice the Adviser provides and participation in the Raymond James
program, the Adviser receives certain economic benefits from the Raymond James program.
These benefits may include software and other technology that provides access to client account
data (such as trade confirmations and account statements), facilitates trade execution (and allo-
cation of aggregated orders for multiple client accounts), provides research, pricing information
and other market data, facilitates the payment of the Adviser’s fees from its clients’ accounts, and
assists with back-office functions, recordkeeping, and client reporting. Many of these services
may be used to service all or a substantial number of the Adviser’s accounts, including accounts
not held at Raymond James. Raymond James may also make available to the Adviser other ser-
vices intended to help the Adviser manage and further develop its business. These services may
include consulting, publications and conferences on practice management, information technol-
ogy, business succession, and marketing. In addition, Raymond James may make available, ar-
range and/or pay for these types of services to be rendered to the Adviser by independent third
parties. Raymond James may discount or waive fees it would otherwise charge for some of these
services, pay all or a part of the fees of a third-party providing these services to the Adviser,
and/or Raymond James may pay for travel expenses relating to participation in such training.
Finally, participation in the Raymond James program provides the Adviser with access to mutual
funds which normally require significantly higher minimum initial investments or are normally
available only to institutional investors. The benefits received through participation in the Ray-
mond James program do not necessarily depend upon the proportion of transactions directed to
Raymond James.
The benefits are received by the Adviser, in part because of commission revenue generated for
Raymond James by the Adviser’s clients. This means that the investment activity in client ac-
counts is beneficial to the Adviser, because Raymond James does not assess a fee to the Adviser
36
Beacon Pointe Advisors, LLC
March 2026
for these services. This creates an incentive for the Adviser to continue to recommend Raymond
to its clients. While it may be possible to obtain similar custodial, execution and other services
elsewhere at a lower cost, the Adviser believes that Raymond provides an excellent combination
of these services. These services are not soft dollar arrangements but are part of the institutional
platform offered by Raymond James.
Brokerage for Client Referrals
Schwab Advisor Network
Beacon Pointe receives client referrals from Charles Schwab & Co., Inc. (“Schwab”) through our
participation in the Schwab Advisor Network® (“the Service”). Schwab designed the Service to
help investors find an independent investment advisor. Schwab is a broker-dealer independent
of, and unaffiliated with, Beacon Pointe. Schwab does not supervise us and has no responsibility
for our management of clients’ portfolios or other advice or services we provide. Beacon Pointe
pays Schwab fees to receive client referrals through the Service. Our participation in the Service
raises conflicts of interest, as described below.
Participation Fee
Beacon Pointe pays Schwab a Participation Fee on all referred clients’ accounts custodied at
Schwab and a Non-Schwab Custody Fee on all accounts maintained at, or transferred to, another
custodian. The Participation Fee we pay is a percentage of the fees the client pays to us or a
percentage of the value of the assets in the client’s account subject to a minimum Participation
Fee. Beacon Pointe pays Schwab the Participation Fee if the referred client’s account remains in
custody at Schwab. Schwab bills us the Participation Fee quarterly and may increase, decrease,
or waive the fee from time to time. Beacon Pointe pays the Participation Fee and not the client.
We have agreed not to charge clients referred through the Service, fees, or costs greater than those
fees or costs we normally charge to clients with similar portfolios who were not referred through
the Service.
Non-Schwab Custody Fee
Beacon Pointe generally pays Schwab a Non-Schwab Custody Fee if Schwab does not maintain
custody of a referred client’s account or if we transfer assets in the account away from Schwab.
This Fee does not apply if the client was solely responsible for the decision not to maintain cus-
tody at Schwab. The Non-Schwab Custody Fee is a one-time payment equal to a percentage of
the assets placed with a custodian other than Schwab. The Non-Schwab Custody Fee is higher
than the Participation Fees we generally pay in a single year. This means we have an incentive to
recommend that referred clients maintain custody of their accounts at Schwab.
Schwab bases the Participation Fee and Non-Schwab Custody Fee on assets in accounts of our
clients referred by Schwab and those referred clients’ family members living in the same house-
hold. This means that we have an incentive to encourage household members of clients referred
through the Service to maintain custody of their accounts, execute transactions at Schwab, and
instruct Schwab to debit our fees directly from their accounts.
Fidelity Wealth Advisor Solutions®
Beacon Pointe participates in the Fidelity Wealth Advisor Solutions Program (the “WAS Pro-
gram”), through which Beacon Pointe receives referrals from Fidelity Personal and Workplace
37
Beacon Pointe Advisors, LLC
March 2026
Advisors, LLC (“FPWA”), a registered investment adviser and Fidelity Investments company.
Beacon Pointe is independent and not affiliated with FPWA or any Fidelity Investments com-
pany. FPWA does not supervise or control Beacon Pointe, and FPWA has no responsibility or
oversight for Beacon Pointe’s provision of investment management or other advisory services.
Under the WAS Program, FPWA acts as a solicitor for Beacon Pointe. Beacon Pointe pays referral
fees to FPWA for each referral received based on Beacon Pointe’s assets under management
attributable to each client referred by FPWA or members of each client’s household. The WAS
Program is designed to help investors find an independent investment advisor. Any referral from
FPWA to Beacon Pointe does not constitute a recommendation or endorsement by FPWA of
Beacon Pointe’s particular investment management services or strategies.
More specifically, Beacon Pointe pays the following amounts to FPWA for referrals: for referrals
made prior to April 1, 2017, an annual percentage of 0.20% of all assets in client accounts; for
referrals made after April 1, 2017, the sum of (i) an annual percentage of 0.10% of all assets in
client accounts where such assets are identified as “fixed income” assets by FPWA and (ii) an
annual percentage of 0.25% of all other assets held in client accounts. For referrals made prior to
April 1, 2017, these fees are payable for a maximum of seven years. Fees with respect to referrals
made after that date are not subject to the seven-year limitation. In addition, Beacon Pointe has
agreed to pay FPWA a minimum annual fee in connection with our participation in the WAS
Program. These referral fees are paid by Beacon Pointe and not the client.
To receive referrals from the WAS Program, Beacon Pointe must meet certain minimum partici-
pation criteria, but we may have been selected for participation in the WAS Program because of
our other business relationships with FPWA and its affiliates, including Fidelity Brokerage Ser-
vices, LLC (“FBS”). As a result of our participation in the WAS Program, Beacon Pointe has a
conflict of interest with respect to our decision to use certain affiliates of FPWA, including FBS,
for execution, custody and clearing for certain client accounts. Beacon Pointe has an incentive to
suggest the use of FBS and its affiliates to our advisory clients, whether or not those clients were
referred to Beacon Pointe as part of the WAS Program. Under an agreement with FPWA, Beacon
Pointe has agreed that we will not charge clients more than the standard range of advisory fees
disclosed in our Form ADV 2A Brochure to cover solicitation fees paid to FPWA as part of the
WAS Program. Pursuant to these arrangements, Beacon Pointe has agreed not to solicit clients to
transfer their brokerage accounts from affiliates of FPWA or establish brokerage accounts at other
custodians for referred clients other than when our fiduciary duties would so require, and Beacon
Pointe has agreed to pay FPWA a one-time fee equal to 0.75% of the assets in a client account
that is transferred from FPWA’s affiliates to another custodian; therefore, Beacon Pointe has an
incentive to suggest that referred clients and their household members maintain custody of their
accounts with affiliates of FPWA. However, participation in the WAS Program does not limit
Beacon Pointe’s duty to select brokers based on best execution.
As noted above, the Adviser may receive some benefits from Raymond James based on the
amount of client assets held at Raymond James. Please see Item 12 - Brokerage Practices for
more information. However, neither Raymond nor any other party is paid to refer clients to the
Adviser.
Directed Brokerage
Beacon Pointe generally recommends that Schwab, Fidelity, SEI, Pershing, or Raymond James
serve as the broker- dealer/custodian for fee-based clients’ accounts. Schwab, Fidelity, and Per-
shing serve as the broker-dealer/custodian for accounts under the Wrap Fee Program. Under
38
Beacon Pointe Advisors, LLC
March 2026
limited circumstances, Beacon Pointe will permit clients to appoint which broker-dealer to exe-
cute securities transactions for client accounts in which Beacon Pointe has discretionary authority
(“Directed Brokerage”). If the client elects to direct brokerage transactions to a particular broker-
dealer, Beacon Pointe will not negotiate specific brokerage commission rates with the broker on
the client’s behalf, and Beacon Pointe may not be able to obtain the best execution for that client.
Further, a client that directs brokerage may pay higher commissions than otherwise charged by
another broker or dealer.
When clients elect to have their assets managed by an investment manager separate from Beacon
Pointe, clients may instruct the investment manager to direct trades through third party commis-
sion recapture programs.
Beacon Pointe does not recommend initial public offerings (“IPOs”) to clients. However, Beacon
Pointe may, when consistent with a client’s investment objectives and restrictions, and when
specifically requested by a client, seek to purchase on behalf of the client the requested security
in an IPO for the client’s account. We require that the client initiate such requests. Beacon Pointe
will not seek to obtain shares for clients who do not initiate such a request. If a client seeks to
purchase an IPO Beacon Pointe will not give advice on that purchase and if a client purchases an
IPO Beacon Pointe will not manage that security.
Aggregation and Allocation of Transactions
The majority of trades implemented by us are completed on an individual basis. In cases when
we need to implement buys or sells of the same security for numerous accounts, we may elect to
purchase or sell such securities at approximately the same time by block trade. This process is
also referred to as aggregating orders and batch trading and is used by our firm when we believe
such action may prove advantageous to clients. When we aggregate client orders, allocating se-
curities among client accounts is done on a fair and equitable basis. The process of aggregating
client orders is done to achieve better execution across client accounts. We may also do it to
achieve more favorable commission rates or to allocate orders among clients on a more equitable
basis to avoid differences in prices and transaction fees or other transaction costs that might be
obtained when orders are placed independently. We use the pro rata allocation method for trans-
action allocation. Under this procedure, pro-rata trade allocation means an allocation of the trade
is issued among applicable advisory clients in amounts that are proportional to the participating
advisory client’s intended investable assets. We will calculate the pro rata share of each transac-
tion included in a block order and assign the appropriate number of shares of each allocated
transaction executed for the client’s account. This process is executed on a per-custodian basis.
For example, all clients held at Charles Schwab would receive the average price of all shares
block traded at Charles Schwab by us. It is possible that clients at different custodians receive
different average prices for block trades executed on the same trading day. Neither we nor our
employees receive any additional compensation as a result of block trades. Trading Practices of
Independent Managers
Accounts may be managed by Independent Managers who may have different policies than those
adopted by Beacon Pointe when managing client accounts. Beacon Pointe recommends that cli-
ents review the Independent Managers’ ADV Part 2 Brochures.
ITEM 13 - REVIEW OF ACCOUNTS
Account Reviews
39
Beacon Pointe Advisors, LLC
March 2026
For accounts under Beacon Pointe’s management and for consulting accounts where we provide
ongoing investment supervision, the primary consultant/advisor assigned to the account reviews
accounts. Account reviews typically consider account performance, asset allocation, and overall
portfolio construction. Accounts are reviewed when requested by a client, during significant mar-
ket changes, and at least annually.
Clients are encouraged to meet with Beacon Pointe on at least an annual basis to review any
changes to investment objectives, account performance, and financial planning issues.
Account Reporting
Clients receive at least quarterly statements from the qualified custodian(s) regarding their assets
showing the portfolio inventory and transactions during that period We urge clients to carefully
review such statements and compare such official custodial records to the account statements that
we provide to clients. Reports we provide at the request of our clients can vary from custodial
statements based on accounting procedures, reporting dates, or valuation methodologies of certain
securities.
Consulting clients where Beacon Pointe provides ongoing investment supervision generally re-
ceive quarterly reports that contain at least the same information described above.
Financial Plan Reviews
A Managing Director, Financial Planner or the primary consultant/advisor assigned to the account
is responsible for creating and reviewing clients’ financial plans, as applicable. Beacon Pointe
reviews financial plans on an as needed basis upon request of the client.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
Benefits We Receive from Custodial Brokers
We receive an economic benefit from Schwab in the form of support products and services they
make available to us and other independent investment advisers whose clients maintain their ac-
counts in Schwab’s custody. These products and services, how they benefit us, and the related
conflicts of interest are described under Item 12 – Brokerage Practices. The availability of these
products and services is not based on us giving particular investment advice, such as buying se-
curities for our clients.
Client Referrals
We have entered into numerous referral agreements whereby we pay a referral fee to Promoters,
in accordance with the requirements of Rule 206(4)-1 of the Investment Advisers Act of 1940, and
any corresponding state securities law requirements. All such referral fees shall be paid solely
from our advisory fee and will not result in an additional charge to the client. Promoters may
receive additional compensation, such as incentive trips and gratis attendance at conferences,
including payment for meals, activities, airfare or accommodations. If an unaffiliated or an affil-
iated Promoter introduces a client to Beacon Pointe, that Promoter will disclose the nature of their
relationship with Beacon Pointe at the time of the solicitation. The Promoter will provide each
prospective client with a written disclosure statement disclosing the terms and conditions of the
arrangement between Beacon Pointe and the Promoter, including the compensation that Beacon
Pointe pays the Promoter.
40
Beacon Pointe Advisors, LLC
March 2026
We compensate eligible employees for engaging in business development activities, including
referring a new client. In such cases, the referring employee receives compensation in the form
of a percentage of the estimated first year net revenue for the clients they refer to Beacon Pointe.
This creates an incentive for employees to refer prospective clients to our firm; however, our
fiduciary duty requires that we recommend our services only when we believe they are appropri-
ate for the client.
Occasionally, we may receive indirect compensation from service providers or third-party ven-
dors in the form of gifts, entertainment, and complimentary attendance at industry conferences,
meetings, or other educational events. When this occurs, we carefully assess the value and nature
of these offerings to ensure that they are reasonable and customary, and to avoid any conflicts of
interest.
Interval Fund
As the Adviser to the BPMAX Fund, BPA may enter into arrangements with broker-dealers and
other financial institutions, including banks and insurance companies, to provide services to the
Fund or its shareholders, such as administrative services, shareholder sub-accounting services,
and sales and marketing-related services and activities. These organizations may be compensated
for such services by BPA, the Fund, or both, as described in the Fund’s prospectus and Statement
of Additional Information. These arrangements create a conflict of interest because they may
provide these organizations with a financial incentive to recommend or maintain investments in
BPMAX.
These arrangements may include:
• Administrative services,
• Shareholder sub-accounting services
• Sales and marketing-related services and activities.
Sponsorship of Corporate Events
Companies that manage securities and other assets used in Beacon Pointe accounts, such as cus-
todians, mutual funds, and Independent Managers, may sponsor or host Beacon Pointe events,
such as conferences and seminars. They may directly pay vendors or reimburse expenses incurred
for hosting education, training, or other events for clients or employees. These arrangements give
rise to conflicts of interest (or the appearance of conflicts of interest) that could influence us to
include or recommend products and services offered by the sponsoring companies. Beacon Pointe
does not receive any financial incentive or revenue-sharing fee for recommending specific in-
vestments or Independent Managers to its clients.
For more information on client referrals and specific solicitation arrangements, see “Brokerage
for Client Referrals” under Item 12 – Brokerage Practices.
ITEM 15 - CUSTODY
Beacon Pointe is deemed to have custody of a client’s funds or securities when the client has a
standing written authorization with its custodian to move money from the client’s account to
designated third parties (“SLOA”), and under that SLOA authorizes Beacon Pointe to designate
the amount or timing of such transfers to those third parties with the custodian. The SEC staff has
41
Beacon Pointe Advisors, LLC
March 2026
published a set of standards intended to protect client assets in such situations, which Beacon
Pointe follows.
Additionally, Beacon Pointe has limited custody of some of our client’s funds or securities when
the clients authorize us to deduct our management fees directly from the client’s accounts. A
qualified custodian (generally a broker-dealer, bank, trust company, or other financial institution)
holds the clients’ funds and securities. Clients will receive statements directly from the qualified
custodian at least quarterly. The statements will reflect the client’s funds and securities held with
the qualified custodian as well as any transactions that occurred in the account, including the de-
duction of Beacon Pointe’s fee. Clients should carefully review the account statements they re-
ceive from your qualified custodian.
When clients receive statements from Beacon Pointe as well as from their qualified custodian,
clients should compare these two reports carefully. Clients with any questions about their state-
ments should contact us at the address or phone number on the cover of this brochure. Clients
who do not receive their statement from their qualified custodian at least quarterly should also
notify us.
Beacon Pointe GP, LLC has custody of the assets in the Private Funds as the general partner of the
Private Funds and has the ability to request funds from the custodians out of the Private Funds’
accounts. Beacon Pointe has put controls in place, in compliance with federal rules, to protect
investors’ assets in the Private Funds. Independent qualified custodians hold the assets in the
Private Funds. In addition, investors receive annual audited financials prepared by an independent
accountant.
In limited circumstances, for legacy clients of firms acquired by Beacon Pointe, we are deemed
to have custody due to client log-in credentials, bill pay abilities and serving as a trustee or co-
trustee of client accounts. In these instances, Beacon Pointe obtains a surprise exam annually by
an independent accountant for these accounts/clients.
ITEM 16 - INVESTMENT DISCRETION
For most clients Beacon Pointe has full discretion to select, change, and remove Independent
Managers for the client’s account. When Beacon Pointe manages accounts directly using mutual
funds or other securities, we have discretion to decide the specific security to trade, the quantity,
and the timing of transactions for client accounts. Beacon Pointe is not required to contact clients
before making changes to the Independent Managers or placing trades in their accounts. Certain
securities, including private funds, require the client’s written agreement to participate in the
investment. Independent Managers investing client assets will also have full discretionary author-
ity over the portion of the client’s account they manage.
Clients will receive confirmation directly from the broker for any trades placed. Clients grant us
discretionary authority in the contracts they sign with us. Clients also give the Independent Man-
agers or us trading authority over their accounts when they sign the custodian paperwork.
However, certain client-imposed conditions limit Beacon Pointe’s discretionary authority, such as
where the client places restrictions on account investments or directs Beacon Pointe to execute
transactions through specific broker-dealers. See also Item – 12 Brokerage Practices, above.
In rare circumstances, Beacon Pointe will recommend Independent Managers and investments in
mutual funds or other securities on a non-discretionary basis. Beacon Pointe is required to get
42
Beacon Pointe Advisors, LLC
March 2026
client approval before selecting or making changes to the Independent Mangers or placing trades
in their account. When the client approves the recommended Independent Manager, they give the
Independent Manager trading authority over their accounts when they sign the custodian paper-
work.
For clients under consulting arrangements, Beacon Pointe will recommend managers for portions
of the client’s account on a non-discretionary basis. It is up to the client to approve these recom-
mendations.
ITEM 17 - VOTING CLIENT SECURITIES
Proxy Voting
Unless otherwise requested by a client, Beacon Pointe is responsible for voting proxies for securi-
ties held in certain clients’ accounts where Beacon Pointe was responsible for selecting the in-
vestment. The appointed Independent Manager is responsible for voting proxies for securities
selected by the Independent Manager that are held in clients’ accounts.
For the proxies that Beacon Pointe is responsible for voting, Beacon Pointe has retained, at its
expense, a third -party proxy voting service (“vendor”) to handle the voting of proxies. The ven-
dor provides written vote recommendations and guidelines. The vendor is not affiliated with Bea-
con Pointe. Beacon Pointe has adopted the vendor’s policy guidelines, and client proxies will be
voted according to these guidelines. Beacon Pointe believes that the vendor has developed policies
and procedures that ensure that client proxies are voted in the best interest of our clients. Beacon
Pointe reviews vendor yearly. Clients may retain the authority to vote all proxies in their account,
but a client may not otherwise direct Beacon Pointe’s vote for particular solicitations.
In cases where proxy voting authority for an ERISA Plan’s holdings rests with Beacon Pointe, such
proxies will be voted in accordance with the vendor’s policy guidelines unless outlined otherwise
in the plan’s governing documents and subject to the fiduciary responsibility standards of ERISA.
If Beacon Pointe becomes aware of any type of potential or actual conflict of interest relating to
a particular proxy proposal, Beacon Pointe’s Chief Compliance Officer or designee will be re-
sponsible for resolving the conflict. Beacon Pointe can resolve the conflict in a number of ways
depending on the type and materiality. The method selected by Beacon Pointe will depend upon
the facts and circumstances of each situation and the requirements of applicable laws.
Clients can obtain information on how their proxies were voted by contacting Beacon Pointe at
the principal office and place of business indicated on page 1 of this form. In their request, clients
should include their name and the account and security for which they are making the request.
For information regarding proxies voted by Independent Managers, clients should refer to the
Independent Manager’s ADV 2 Brochure.
Legacy clients of firms acquired by Beacon Pointe may have their proxies voted by the acquired
firm according to the proxy voting arrangements of the acquired firm. This practice may continue
temporarily following the acquisition until the proxy voting arrangement can be transitioned at
the custodian by Beacon Pointe.
Class Actions
43
Beacon Pointe Advisors, LLC
March 2026
A securities “class action” lawsuit is a civil suit brought by one or more individuals (“Plaintiffs”)
on behalf of themselves and others who have the same grievance against the issuer of a certain
security. When a class action is filed, a written notice of filing and/or settlement is prepared (the
“Notice”), which outlines the reasons for the lawsuit, the parameters for qualification as a member
of the class, and certain legal rights that need to be considered before becoming a member of the
class (i.e., participating in the settlement). In addition, the Notice will contain instructions issued
by the court or broker/dealers and/or other nominees (e.g., custodians) who receive the Notice and
who hold the security on behalf of the owner/beneficiary to either (1) provide the Claims Admin-
istrator (usually the attorney for the Plaintiffs) with the name and address of each such owner/ben-
eficiary so the Claims Administrator can send the Notice directly to such owner/beneficiary, or
(2) request additional copies of the Notice and send the Notice directly to the owner/beneficiary.
In cases where Beacon Pointe is responsible for filing class actions on behalf of clients, we have
selected an unaffiliated third-party vendor to provide class action litigation monitoring and secu-
rities claim filing services on behalf of our clients. The vendor will monitor class actions for
which our clients may be eligible. Upon learning of any such class actions, the vendor will collect
the applicable documentation, interpret the terms of each settlement, file the appropriate claim
form, interact with the administrators, and distribute the award to applicable clients. The vendor
charges clients a contingency fee which is subtracted from the award at the time of payment. Cli-
ents can opt out entirely or list specific companies against which claims should not be filed on their
behalf. Clients may change their opt-out election at any time by notifying Beacon Pointe in writ-
ing. Because Beacon Pointe provides this service to our clients through a third-party vendor, we
will not monitor class action suits or process any claim forms on clients’ behalf, whether or not
they opt out of this service. If a client chooses to opt out, the vendor will not monitor any class
action suits from which the client may be entitled to awards, and the vendor will not process any
claim forms on the client’s behalf. Clients who opt out are entitled to pursue securities claims them-
selves.
ITEM 18 - FINANCIAL INFORMATION
Registered investment advisers are required to provide clients with certain financial information
or disclosures about the firm’s financial condition. Beacon Pointe does not foresee any financial
condition that is reasonably likely to impair our ability to meet contractual commitments to cli-
ents.
44
Beacon Pointe Advisors, LLC
March 2026
Additional Brochure: BEACON POINTE ADVISORS, LLC FORM ADV PART 2 - APPENDIX 1 (2026-03-31)
View Document Text
Form ADV, Part 2A Appendix 1
Wrap Fee Program Brochure
March 31, 2026
Main Office:
24 Corporate Plaza
Suite 150
Newport Beach, CA
92660
949-718-1600
www.beaconpointe.com
This wrap fee program brochure provides information about the qualifications and business practices of Beacon Pointe Advisors, LLC.
If you have any questions about the contents of this brochure, please contact us at 949-718-1600. 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. Any
reference to or use of the terms “registered investment adviser” or “registered,” does not imply that Beacon Pointe Advisors, LLC or
any person associated with Beacon Pointe Advisors, LLC has achieved a certain level of skill or training.
Additional information about Beacon Pointe Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov
ITEM 2 - MATERIAL CHANGES
The purpose of this page is to inform you of the material changes made to our brochure since the previous annual
update. The last annual update was March 31, 2025. There have been no material changes since that filing.
2
Beacon Pointe Advisors,
LLC
March 2026
ITEM 3 - TABLE OF CONTENTS
ITEM 2 - MATERIAL CHANGES ........................................................................................................... 2
Contents
ITEM 3 - TABLE OF CONTENTS .......................................................................................................... 3
ITEM 4 – SERVICES, FEES AND COMPENSATION ......................................................................... 5
Wrap Fee Program Services ...................................................................................................................... 5
Fees for the Wrap Fee Program ................................................................................................................ 6
Billing Method .......................................................................................................................................... 7
Other Fees and Expenses .......................................................................................................................... 7
Termination ............................................................................................................................................... 8
Other Compensation ................................................................................................................................. 8
ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS .............................................. 8
Account Requirements .............................................................................................................................. 8
Types of Clients ........................................................................................................................................ 9
ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION ......................................... 9
Methods of Analysis ................................................................................................................................. 9
Investment Strategies ................................................................................................................................ 9
Manager Selection Process ................................................................................................................. 10
Investing Involves Risk ........................................................................................................................... 10
Specific Security Risks ........................................................................................................................... 11
General Risks of Owning Securities ................................................................................................... 11
Independent Manager Strategies and Risks ........................................................................................ 11
Alternative Asset Classes .................................................................................................................... 11
Structured Notes.................................................................................................................................. 12
Mutual Funds (Open-end Investment Companies) ............................................................................. 13
Costs Despite Negative Returns.......................................................................................................... 13
Lack of Control ................................................................................................................................... 13
Price Uncertainty ................................................................................................................................ 13
Exchange-Traded Funds (ETFs) ......................................................................................................... 13
Real Estate Investment Trusts (REIT) ................................................................................................ 14
Interval Fund Risks ............................................................................................................................. 14
Private Funds ...................................................................................................................................... 14
Margin Risk ........................................................................................................................................ 15
3
Beacon Pointe Advisors,
LLC
March 2026
Allocation and Planning Tools ................................................................................................................ 16
Proxy Voting ........................................................................................................................................... 16
Class Actions .......................................................................................................................................... 17
ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ...................... 18
ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................................. 18
ITEM 9 – ADDITIONAL INFORMATION .......................................................................................... 18
Disciplinary Information ......................................................................................................................... 18
Other Financial Industry Activities and Affiliations .............................................................................. 19
Related Insurance Agency .................................................................................................................. 19
Related Investment Adviser ................................................................................................................ 19
Other Related Businesses .................................................................................................................... 19
BPMAX Fund ..................................................................................................................................... 19
Agents of Unaffiliated Broker-Dealer ................................................................................................ 20
Code of Ethics ......................................................................................................................................... 20
Personal Trading Practices .................................................................................................................. 21
Participation or Interest in Client Transactions ...................................................................................... 21
Beacon Pointe Private Funds .............................................................................................................. 21
Beacon Pointe Interval Fund ............................................................................................................... 22
Port Street Investments, LLC .............................................................................................................. 22
Review of Accounts ................................................................................................................................ 22
Account Reviews ................................................................................................................................ 22
Account Reporting .............................................................................................................................. 22
Financial Plan Reviews ....................................................................................................................... 23
Client Referrals and Other Compensation .............................................................................................. 23
Benefits We Receive from Custodial Brokers .................................................................................... 23
Payment for Client Referrals .............................................................................................................. 23
Sponsorship of Corporate Events........................................................................................................ 24
Financial Information .............................................................................................................................. 24
4
Beacon Pointe Advisors,
LLC
March 2026
ITEM 4 – SERVICES, FEES AND COMPENSATION
Wrap Fee Program Services
Beacon Pointe Advisors, LLC (“Beacon Pointe,” “we,” “our,” or “us”) manages a wrap fee
program (the “Wrap Fee Program”) for certain legacy clients of firms acquired by Beacon Pointe.
The Wrap Fee Program is not offered to new or prospective clients of Beacon Pointe. Accounts
participating in the Wrap Fee Program are managed in the same way as our non-wrap accounts
described below. Under the Wrap Fee Program, however, a client may transact in investment
products without incurring separate brokerage commissions or transaction fees in the client’s
custodial account managed by Beacon Pointe, as described further below.
Wealth Advisory Services
A client can engage Beacon Pointe to implement investment recommendations on a fee basis with
Beacon Pointe actively managing client assets under our Wealth Advisory Agreement (“Advisory
Agreement”). Under the Advisory Agreement, Beacon Pointe will:
1. Manage a portion or all the assets designated by the client in accordance with the terms and
conditions of the Advisory Agreement. Additionally, we may recommend clients authorize
the discretionary management of a portion of their assets by certain unaffiliated third-party
investment managers (“Independent Managers”) where appropriate based on the client’s
stated investment objectives.
2. Provide ongoing monitoring and reviewing of each Independent Manager
3. In some cases, manage a portion of the client’s assets by primarily allocating the assets
among various classes of shares of no-load mutual funds, Exchange Traded Funds (ETFs),
real estate investment trusts (REITs), or private funds. From time-to-time Beacon Pointe
invests our clients’ assets in a mutual fund advised by a related investment adviser. See Item
9 – Additional Information for our policies surrounding this practice.
4. Provide financial planning services for certain clients subject to certain conditions as
noted below.
We offer these services on a discretionary basis, including the hiring and/or firing of Independent
Managers, and in accordance with the client’s investment objectives and any reasonable
restrictions the client wishes to place on the account. Beacon Pointe 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 or maintaining the client’s investment strategy. Clients
should notify us promptly in writing if there are any changes in their financial situation or
investment objectives, or if they wish to impose or change any restriction(s) on their account.
Beacon Pointe primarily invests client accounts by utilizing Independent Managers to manage the
various asset classes determined in the client’s asset allocation. Generally, client portfolios are
managed by the Independent Managers through separate accounts or through mutual funds,
depending on the vehicles offered by the Independent Managers and account size or other
considerations specific to each client. Beacon Pointe may also directly manage the client’s account
utilizing mutual funds, ETFs, REITs, and private funds. In addition, client portfolios at times utilize
other strategies or contain securities not included on the recommended list during an acquisition
or at the direction of the client; typically, these assets will be transitioned over time to the
5
Beacon Pointe Advisors,
LLC
March 2026
Independent Managers or securities that are recommended by Beacon Pointe. Clients may place
reasonable restrictions on the management of their account with the Independent Managers. We
describe our process for selecting managers and the material investment risks for our strategies
under Item 6 – Portfolio Manager Selection and Evaluation.
Beacon Pointe may offer investment advice on any investment held by the client at the start of the
advisory relationship. Beacon Pointe occasionally offers advice regarding additional types of
investments if they are appropriate to address the individual needs, goals, and objectives of the
client or in response to client inquiry.
Private clients will be provided with comprehensive financial planning advice, upon client request
and subject to the minimum account size or minimum annual advisory fee in accordance with the
client’s agreement. In order to provide this comprehensive financial planning advice, we gather
information regarding the client’s current and historical status in the areas of net worth, income,
expenses, taxes, investments, retirement plans and insurance, as well as future goals and objectives.
We then develop a written personalized plan, which includes specific recommendations in
applicable areas. Areas of focus may include retirement planning, education funding, survivor
needs analysis, risk management or wealth transfers planning. These financial planning services
do not include preparation of any kind of income tax, gift, or estate tax returns nor preparation of
any legal documents, including wills or trusts.
Fees for the Wrap Fee Program
Beacon Pointe charges advisory fees to clients who are in the Wrap Fee Program. The advisory
fees are negotiable and are charged based on a percentage of the market value of the portfolio under
management, per a tiered fee schedule set forth in the agreement between Beacon Pointe and the
client.
The Wrap Fee Program fee ranges from 0.50% to a maximum of 2.0% of assets under management.
Client participation in the Wrap Fee Program will generally cost less than the same services would
for an account participating in an account outside of the Wrap Fee Program, although the amount
of savings will depend on the volume of trading in the client’s account, advisory fees for unbundled
services, and the custodian transaction and execution fees charged for a non-wrap fee program
account. Under the terms of the Wrap Fee Program, Beacon Pointe will pay trading and execution
costs imposed by the custodian for transactions in the client’s account directly managed by Beacon
Pointe. This arrangement may present a potential conflict of interest for us, as we have a financial
disincentive to engage in active trading. However, transaction fees are not a material consideration
for Beacon Pointe in deciding whether to engage in any trading or the level of trading activity
through the custodians, Charles Schwab & Co., Inc. (“Schwab”), Fidelity, or Pershing Advisor
Solutions, LLC (“Pershing”).
Schwab has eliminated commissions for online trades of equities, ETFs and options (subject to a
$0.65 contract fee). This means that, in most cases, when we buy and sell these types of securities,
we will not have to pay any commissions to the custodian of your account. Beacon Pointe
encourages prospective clients to review your custodian’s pricing to compare the total costs of
entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter
into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage
and advisory services separately. To see what you would pay for transactions in a non-wrap
schedules, available at
account, please
refer
to Schwab’s most
recent pricing
6
Beacon Pointe Advisors,
LLC
March 2026
schwab.com/aspricingguide.
Billing Method
Beacon Pointe’s advisory fees are generally payable quarterly in advance at the beginning of each
calendar quarter. We charge one fourth of the annual fee each quarter based on the market value
of the client’s portfolio as of the last day of the prior calendar quarter. If a client contributes capital
to the account, including the initial capital, on a date other than the last day of a calendar quarter,
we will charge the account a prorated portion of the fees for that calendar quarter for that
contribution based on the number of days remaining in that calendar quarter. Similarly, if a client
withdraws a portion of the assets from the account on any date other than the last day of a calendar
quarter, we will prorate the fees previously paid for that calendar quarter based on the number of
days elapsed in that quarter before the withdrawal and we will refund the unearned portion to the
client’s account. Fees for the initial quarter under management are pro-rated and charged in arrears
with the next quarter’s advance payment.
Beacon Pointe aggregates related client accounts for purposes of calculating the advisory fees
applicable to each client. Beacon Pointe also reserves the right to reduce or waive our fees for
employee or family accounts and certain client accounts.
With client authorization, Beacon Pointe will automatically withdraw Beacon Pointe’s advisory
fee from the client’s account held by an independent custodian. Typically, the custodian withdraws
advisory fees from the client’s account during the first month of each quarter based on Beacon
Pointe’s instruction. All clients will receive brokerage statements from the custodian no less
frequently than quarterly. The custodian statement will show the deduction of the advisory fee. We
will make rare exceptions to this policy and bill clients directly. In these rare cases, Beacon Pointe
will send an invoice to the client who chooses not to have advisory fees withdrawn directly from
their custodian account. The invoice is payable upon receipt and will include the fee calculation
and amount due.
Other Fees and Expenses
Beacon Pointe’s fees do not include the fees charged by Independent Managers or their custodians.
Clients should review the Independent Manager’s ADV 2 Brochure regarding fee schedules, other
fees charged by Independent Managers, and applicable billing methods. Clients in the Wrap Fee
Program pay the management fees of Independent Managers as well as the trading and execution
costs imposed by the custodians for transactions in the client’s accounts managed by Independent
Managers. In some cases, the fees charged by the Independent Manager may be greater than those
charged by Beacon Pointe.
Other fees not included in the advisory fee for our Wrap Fee Program are charges imposed directly
by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s
prospectus (i.e., fund management fees and other fund expenses), fees for trades executed away
from the custodian, mark-ups and mark-downs, spreads paid to market makers, wire transfer fees,
and other fees and taxes on brokerage accounts and securities transactions. Any mutual fund shares
held in a client’s account may be subject to deferred sales charges, 12b-1 fees, and other fund-
related expenses. The fund’s prospectus fully describes the fees and expenses. All fees paid to
Beacon Pointe for advisory services are separate and distinct from the fees and expenses charged
by mutual funds. Mutual funds pay advisory fees to their managers, which are indirectly charged
to all holders of the mutual fund shares. Consequently, clients with mutual funds in their portfolios
7
Beacon Pointe Advisors,
LLC
March 2026
are effectively paying both Beacon Pointe and the mutual fund manager for the management of
their assets.
Termination
Either party may terminate the wrap fee program agreement at any time. Clients are requested to
provide thirty (30) days’ written notice of termination to the other party; however, the 30-day
notice may be waived at Beacon Pointe’s sole discretion.
Beacon Pointe will refund any prepaid, unearned advisory fees based on the effective date of
termination. Upon termination of the agreement, we will send the client a prorated refund of
unearned advisory fees using the following formula: (Fees Paid) x (Days Remaining in Quarter) /
(Total Number of Days in Quarter).
Other Compensation
Beacon Pointe does not accept compensation for the sale of securities or other investment products,
including asset-based sales charges or service fees from the sale of mutual funds.
Beacon Pointe may recommend that clients invest in mutual funds and interval funds managed by
Beacon Pointe or a related adviser. While Beacon Pointe does not directly receive additional
compensation resulting from the use of products managed by related firms, our related adviser
receives management fees from the mutual fund. Beacon Pointe receives a management fee for our
services as the adviser to the BPMAX interval fund. However, the advisory fee is waived for clients
of Beacon Pointe.
Additionally, Beacon Pointe receives fees through its affiliated general partner of certain private
funds sponsored by Beacon Pointe. Even though such private fund fees are waived for clients of
Beacon Pointe, Beacon Pointe has an interest in recommending the private funds for reasons of
larger size, better deals, costs savings, etc. We describe our policies in recommending related
products, as well as our relationships with related advisers, in Item 9 – Additional Information.
In certain limited circumstances, Beacon Pointe also receives advisory compensation from
unaffiliated third-party firms for providing advisory services related to assets that are held-away
from Beacon Pointe, including legacy commission-based annuity assets, as described in Item 10
of Beacon Pointe’s Form ADV Part 2A disclosure brochure. Clients participating in the Wrap Fee
Program are not charged an additional advisory fee by Beacon Pointe on such assets. These
arrangements may create a potential conflict of interest, which Beacon Pointe addresses through
its fiduciary obligations, supervision, and policies designed to ensure advice is provided in the
client’s best interest.
ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
Account Requirements
Generally, Beacon Pointe requires Wrap Fee Program clients to maintain a minimum account size
of $1 million but reserves the right to reduce or waive the account minimum requirements at our
discretion. Some accounts are under different fee schedules; the maximum fee rate is 2.00%.
8
Beacon Pointe Advisors,
LLC
March 2026
Types of Clients
Under the Wrap Fee Program, Beacon Pointe’s services are offered to individuals, trusts, estates,
charitable organizations, corporations, pension and profit-sharing plans, and other business
entities.
ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION
Methods of Analysis
In beginning a new client relationship, Beacon Pointe seeks to fully understand each client’s needs,
circumstances, priorities. We work with clients to develop an investment strategy that reflects the
client’s current objectives, time horizon, risk tolerance, income needs, and incorporates any
restrictions the client wishes to impose on the account. Beacon Pointe utilizes modeling techniques
to determine an optimal target allocation for the client’s assets. For this process, Beacon Pointe
uses both asset allocation-modeling programs as well as our own analysis to develop what we
believe is a meaningful plan for our clients, including target asset class mixes.
The “core” asset classes we follow and typically include in our recommended investment portfolios
include the following:
• US Equity
• Non-US Equity (Developed Markets)
• Non-US Equity (Emerging Markets)
• US Fixed Income
• Global Fixed Income
• Private Real Estate
• Private Equity
• Hedge Funds
• Hedged Equity
• Real Assets
We track various categories and investment styles within each category (i.e., value, growth, small
versus large, etc.) Based each client’s customized asset allocation plan, we seek out investment
managers in each asset class to implement the investment strategy, based on Beacon Pointe’s due
diligence The client’s investments will draw from our Focus List, which comprises a select group
of firms that meet or exceed our performance and qualitative criteria (see our Manager Selection
Process below).
Investment Strategies
Beacon Pointe is a firm believer in risk control through proper portfolio diversification.
Diversification, or allocating client portfolios across a broad range of asset classes and investment
managers, is generally considered an essential component of the effectiveness of an investment
portfolio. Proper diversification minimizes or reduces the volatility and risk associated with a
client’s investments. We believe proper asset allocation diversification produces a portfolio with
more appealing risk/return characteristics than investing in one single asset class or with one
investment manager.
9
Beacon Pointe Advisors,
LLC
March 2026
Beacon Pointe utilizes both active and passive management. For active management, our research
process seeks managers who we believe can outperform their respective (index) benchmarks on a
risk-adjusted basis, net of fees, over long periods of time.
Manager Selection Process
Beacon Pointe has a “Focus List” for selecting managers. To be included managers must complete
our due diligence process, which involves the step outlined below. This process applies to all types
of investments, including active, passive, and alternative investments. While there is overlap, not
all steps apply to passive and alternative investments.
• Manager Sourcing – from referrals, industry contacts, manager databases, and
directed outreach. We gather basic information from public databases and incorporate
data into our internal database of investment manager information.
• Quantitative Analysis – we assess manager performance with an emphasis on long-
term consistency, risk-adjusted returns, up and down-market capture and peer group
ranks. Beacon Pointe requires firms to adhere to the Global Investment Performance
Standards and undergo third party verification.
• Qualitative Analysis – we meet with members of the investment team, conduct interviews
with analysts, and review the firm’s ownership and compensation structure, investment
philosophy, portfolio construction process, risk controls, research and back-office
resources, and trading capabilities.
• Portfolio Analysis – our assessment typically includes discussions regarding specific
portfolio holdings, holdings-based style analysis (when available), and in some cases on-site
visits where we may request full access to the investment manager firm’s records,
valuation models, personnel, and research reports. Most due diligence is conducted
virtually with video and phone conferences.
• Product Evaluation – we review the manager’s ADV 2A Brochure, negotiate
management fees and account minimums, and perform final scoring and research.
• Beacon Pointe Investment Committee Decision – a careful review by key investment
personnel determines if the manager qualifies for our Focus List or is moved to our
‘Manager Bench’ for later consideration.
Clients of firms acquired by Beacon Pointe may continue to use their existing managers. We honor
these arrangements for legacy clients who are typically limited to holding these investments
without making new purchases. Occasionally, we conduct a limited-scope due diligence process
to approve the legacy client or office to invest in the strategy or use the manager and place them
on our "Approved List."
Investing Involves Risk
All Beacon Pointe clients should understand that investing in securities involves risk of loss, and
clients should be prepared to bear that risk, including the risk of your original principal Past
performance is not indicative of future results, therefore, you should not assume that future
performance of any specific investment or investment strategy will be profitable. We do not
provide any representation or guarantee that your goals will be achieved.
10
Beacon Pointe Advisors,
LLC
March 2026
Due to the inherent risk of loss associated with investing, the Firm cannot represent, guarantee, or
imply that our services and methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate you from losses due to market corrections or declines.
There are certain additional risks associated with investing in securities.
Prior to entering into a managed account agreement with Beacon Pointe, the client should carefully
consider all of the following:
• The clients should commit to management only those assets that the client believes will not
be needed for current purposes and that can be invested on a long-term basis, usually a
minimum of five to seven years,
• Volatility from investing in the stock market can occur, and
• Over time the value of client’s assets will fluctuate and at any time may be worth more or
less than the amount invested.
Specific Security Risks
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in
response to certain events taking place around the world. These include events directly involving
the issuers of the securities held as underlying assets of the mutual funds in a client’s account,
conditions affecting the general economy, and overall market changes. Other contributing factors
include local, regional, or global political, social, or economic instability and governmental or
governmental agency responses to economic conditions. Finally, currency, interest rate, and
commodity price fluctuations can also affect security prices and income.
Independent Manager Strategies and Risks
The Independent Managers Beacon Pointe recommends utilize their own investment process and
methods of analysis. The strategies and securities these managers invest in may have different or
additional risks than those described in this brochure. For example, while Beacon Pointe does not
implement investment advice using margin transactions, some Independent Managers appointed
for the client utilize margin transactions in the discretionary management of client cash and
securities. Use of margin can increase volatility and magnify any investment losses in a client’s
account. Similarly, options are utilized in certain strategies. Options are complex financial
instruments and not suitable for all investors. Investing in options carries unique risks that can
result in the loss of all invested principal. Clients can find more information about the strategies
and related risks of the Independent Managers in Item 8 – Methods of Analysis, Investment
Strategies and Risk of Loss in each manager’s Form ADV disclosure brochure.
Alternative Asset Classes
For those clients and portfolios, we have deemed appropriate to include alternatives, we will
recommend the following alternative asset classes–private real estate, private equity, private credit,
hedged equity, and hedge funds.
Hedge funds and private equities can appear opaque as there are no high-quality established
databases in existence like the public sector. This makes it more difficult to assess who is doing
well and, more importantly, who is doing poorly. This obscurity makes it more essential to
11
Beacon Pointe Advisors,
LLC
March 2026
understand the firms with whom you are doing business and affirms the importance of a solid
qualitative as well as quantitative assessment.
Unlike other alternative investments, the majority of hedge funds do not invest in private securities.
Instead, they apply alternative strategies to the traditional public equity and fixed income markets.
The benefits hedge funds can add to a portfolio include their return potential, lower volatility, and
relatively low correlation with equities and other market-driven investments.
In the alternative investment area, historical information is very limited. While longer return series
exist for some alternative strategies (such as venture capital), we feel that the data is of questionable
usefulness. Using venture capital as an example, performance is very dependent on the timing of
specific investments. In addition, since most venture capital investments are accounted for at cost,
the asset category has an artificially low volatility of returns. A common failing of asset allocation
models is their inability to distinguish if low volatility is inherent to the asset class, or if it is
because the asset is infrequently valued (e.g., not exchange-traded).
There are also unique manager selection issues in the alternative investment area. Although there
is no shortage of managers from which to choose, few have historical track records longer than a
few years. Even among more seasoned managers, it is difficult to compare performance on an
“apples to apples” basis. Since the investment vehicles are generally unregulated partnerships, the
methodologies used to calculate performance vary from manager to manager. Common
performance reporting problems include:
• Calculating “creative” internal rates of return (IRR).
• Presenting results before the deduction of substantial fees;
• Carrying “unrealized” investments at cost for long periods.
•
Ignoring the opportunity cost of holding cash while waiting for the managers to call for
capital.
Because of the lack of standards in reporting performance, a meaningful comparison of managers
may only be possible if returns are recalculated using consistent assumptions and practices.
Our research professionals ask the following questions, among others, when evaluating alternative
managers:
•
Illiquidity – how often and under what circumstances can the client withdraw invested
capital?
• Lack of transparency – is the client comfortable investing with a manager who does
not reveal their holdings or activities?
•
Incentives – are there incentives for the manager to take undue risk given the
performance-based fee structure?
Structured Notes
Beacon Pointe may recommend the use of structured notes issued by unaffiliated domestic and
international banks. Structured notes are not bank deposits and are not insured by the Federal
Deposit Insurance Corporation or any other governmental agency. The terms and risks of each
structured note vary materially depending on the nature and volatility of the referenced asset, the
creditworthiness of the issuer, and the maturity of the instrument, among other factors. The general
12
Beacon Pointe Advisors,
LLC
March 2026
risks associated with this type of investment include, but are not limited to, non-payment risk
(payment of interest and return of principal may be reduced, in whole or in part, due to
underperformance of the referenced asset); counter-party risk (for reasons such as bankruptcy, the
issuer of the structured note may fail to pay all or a portion of the principal and interest due on the
structured note); and underperformance risk (depending on market conditions, the structured note
may underperform alternative allocations to traditional bonds, the referenced asset, or a
combination of such investments). Structured notes are significantly riskier than conventional debt
instruments. There is a risk of loss of some or all the principal at maturity.
Mutual Funds (Open-end Investment Companies)
A mutual fund is a company that pools money from many investors and invests the money in
stocks, bonds, short-term money-market instruments, other securities or assets, or some
combination of these investments. The portfolio of the fund consists of the combined holdings it
owns. Each share represents an investor’s proportionate ownership of the fund’s holdings and the
income those holdings generate. The price that investors pay for mutual fund shares is the fund’s
per share net asset value (NAV) plus any shareholder fees that the fund imposes at the time of
purchase (such as sales loads).
The benefits of investing through mutual funds include professional management, diversification,
affordability, and liquidity. Mutual funds also have features that some investors might view as
disadvantages:
Costs Despite Negative Returns
Mutual funds pay operating and other expenses from fund assets regardless of how the fund
performs, which are indirectly charged to all holders of the mutual fund shares. Depending on the
timing of their investment, investors may also have to pay taxes on any capital gains distribution
they receive. This includes instances where the fund went on to perform poorly after purchasing
shares.
Lack of Control
Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time, nor
can they directly influence which securities the fund manager buys and sells or the timing of those
trades.
Price Uncertainty
With a mutual fund, the price at which an investor purchases or redeem shares will typically depend
on the fund’s NAV, which the fund might not calculate until many hours after the investor placed
the order. In general, mutual funds must calculate their NAV at least once every business day,
typically after the major U.S. exchanges close.
Exchange-Traded Funds (ETFs)
An ETF is a type of Investment Company (usually, an open-end fund or unit investment trust)
containing a basket of stocks. Typically, the objective of a passively managed ETF is to achieve
returns similar to a particular market index, including sector indexes. A passively managed ETF is
like an index fund in that it will primarily invest in securities of companies that are included in a
13
Beacon Pointe Advisors,
LLC
March 2026
selected market. ETFs may also be actively managed. Unlike traditional mutual funds, which can
only be redeemed at the end of a trading day, ETFs trade throughout the day on an exchange. Like
stock mutual funds, the prices of the underlying securities and the overall market can affect ETF
prices. Similarly, factors affecting a particular industry segment can affect ETF prices that track
that particular sector.
Real Estate Investment Trusts (REIT)
Securities issued by real estate investment trusts (REITs) primarily invest in real estate or real
estate- related loans. Equity REITs own real estate properties, while mortgage REITs hold
construction, development and/or long-term mortgage loans. Changes in the value of the
underlying property of the trusts, the creditworthiness of the issuer, property taxes, interest rates,
tax laws, and regulatory requirements, such as those relating to the environment all can affect the
values and liquidity of REITs. Both types of REITs are dependent upon management skill, the cash
flows generated by their holdings, the real estate market in general, and the possibility of failing to
qualify for any applicable pass-through tax treatment or failing to maintain any applicable
exemptive status afforded under relevant laws.
Interval Fund Risks
Interval funds are classified as closed-end funds but have some distinctive features that make them
different. Interval funds continuously or periodically offer their shares at a price based on the
fund’s net asset value. However, most do not trade on a national securities exchange and instead
buy back or “repurchase” shares directly from investors. Repurchases are offered periodically
(often quarterly), so investors are provided with limited liquidity. Accordingly, investments in
interval funds can expose investors to liquidity risk. For example, if redemption requests exceed
the repurchase thresholds, the manager will limit redemptions by “gating.” That risk is more
significant in funds that invest in securities of companies with smaller market capitalizations,
derivatives, or securities with substantial market and/or credit risk. There is no guarantee that
investors can sell their shares at any given time or in the desired amount. Interval funds may offer
to repurchase as low as 5% of shares in each quarter. If many investors attempt to exit their
positions during market stress, the fund manager may only be able to accommodate this slowly
over multiple quarters. In these instances, the fund manager may limit redemptions by “gating” the
fund to allow for orderly liquidation. Because of this, it’s best to consider investments in interval
funds to be illiquid.
Private Funds
A private fund is an investment vehicle that pools capital from a number of investors and invests
in securities and other instruments. In almost all cases, a private fund is a private investment vehicle
that is typically not registered under federal or state securities laws. So that private funds do not
have to register under these laws, issuers make the funds available only to certain sophisticated or
accredited investors and cannot be offered or sold to the general public. Private funds are generally
smaller than mutual funds because they are often limited to a small number of investors and have
a more limited number of eligible investors. Many, but not all private funds use leverage as part of
their investment strategies. Private funds management fees typically include a base management
fee along with a performance component. In many cases, the fund’s managers become “partners”
with their clients by making personal investments of their own assets in the fund. Most private
funds offer their securities by providing an offering memorandum or private placement
memorandum, known as “PPM” for short. The PPM covers important information for investors
14
Beacon Pointe Advisors,
LLC
March 2026
and investors should review this document carefully and should consider conducting additional
due diligence before investing in private funds. The primary risks of private funds include the
following:
1. Private funds do not sell publicly and are therefore illiquid. An investor may not be able to
exit a private fund or sell its interests in the fund before the fund closes.
2. Private funds are subject to various other risks, including risks associated with the types of
securities in which the private fund invests.
Derivatives
Derivatives, including forward currency contracts, futures, options and commodity-linked
derivatives and swaps, may be riskier than other types of investments because they may be more
sensitive to changes in economic and market conditions, and could result in losses that significantly
exceed the investor’s original investment in the derivative. Many derivatives create leverage
thereby causing a portfolio to be more volatile than it would have been if it had not been exposed
to such derivatives. Derivatives also expose a portfolio to counterparty risk (the risk that the
derivative counterparty will not fulfill its contractual obligations), including the credit risk of the
derivative counterparty.
Margin Risk
Margin trading involves interest charges and risks, including the potential to lose more than the
amount deposited or the need to deposit additional collateral in a falling market. A margin
transaction occurs when an investor uses borrowed assets by using other securities as collateral
to purchase financial instruments. When a security is purchased using margin, any gains or losses
from the financial instruments are magnified. If a client authorizes the use of margin, and margin
is used by the firm in managing the client’s investment portfolio, the market value of the client’s
account and the corresponding fee payable to the firm will generally increase, unless the accounts
hold options, in which case the fee may be decreased under certain market conditions. Therefore,
in addition to understanding and assuming the additional principal risk associated with the use
of margin, clients authorizing margin are advised of the potential conflict of interest, whereby the
client’s decision to employ margin will correspondingly increase the advisory fee payable to the
firm.
Values-based Investing, Environmental, Social and Governance “ESG”
Values-based or ESG Based Investing Risk – When directed by the client, ESG investments may
be included in the client’s portfolio. It is important to note that fund managers consider ESG factors
to varying degrees. Not every fund incorporates ESG factors in the same manner or degree, which
can cause difficulty comparing different funds. As such, there is no standard matrix or benchmark
upon which ESG factors affecting performance can be compared. ESG funds may include or
exclude securities based on ESG practices vs. other investment methodologies, impacting
performance, fund expenses, and investment risk. The use of ESG factors could result in selling or
avoiding investments that subsequently perform well or purchasing investments that subsequently
underperform. As a result, accounts that take ESG factors into account could underperform similar
accounts that do not consider ESG factors. In addition, to the extent ESG factors are taken into
account when voting proxies, doing so may not always be consistent with maximizing performance
15
Beacon Pointe Advisors,
LLC
March 2026
of the issue or the account holding such security. We base our ESG recommendations on the
information provided to us by the issuers.
Digital Assets Risk
Digital assets are an emerging asset class that has yet to be fully defined. There is still a lack of
clarity regarding the regulatory framework that will govern this investment sector. In addition,
there are various risk factors, including but not limited to valuation risk, liquidity risk, volatility
risk, technology risk, and legal, tax, and regulatory risk, each with its own probability and
potential impact.
Tax-Loss Harvesting Risk
This strategy intends to sell an ETF or mutual fund at a taxable loss and replace those positions
with a holding that has similar historical and expected future performance, thereby having minor
impact on the overall strategic allocation but capturing the tax loss. Because past performance is
not indicative of future performance, there is potential for the future performance of the
replacement position to differ from that of the initial holding. This strategy may also increase
trading frequency and transaction costs.
Allocation and Planning Tools
The modeling tools Beacon Pointe uses to create financial plans and asset allocations for clients
rely on various assumptions, such as estimates of inflation, risk, economic conditions, and rates of
return on security asset classes. All return assumptions use asset class returns, not returns of actual
investments, and do not include fees or expenses that clients would pay if they invested in specific
products.
Modeling software is only a tool used to help guide Beacon Pointe and the client in developing an
appropriate plan, and we cannot guarantee that clients will achieve the results shown in the plan.
Results will vary based on the information provided by the client regarding the client’s assets, risk
tolerance, and personal information. Changes to the program’s underlying assumptions or
differences in actual personal, economic, or market outcomes may result in materially different
results for the client. Clients should carefully consider the assumptions and limitations of the
software as disclosed on the analysis reports and should discuss the results of the plan with a
qualified investment professional before making any changes in their investment or allocation
program.
Proxy Voting
Unless otherwise requested by a client, Beacon Pointe is responsible for voting proxies for
securities held in certain clients’ accounts where Beacon Pointe was responsible for selecting the
investment. The appointed Independent Manager is responsible for voting proxies for securities
selected by the Independent Manager that are held in clients’ accounts.
For the proxies that Beacon Pointe is responsible to vote, Beacon Pointe has retained, at its expense,
a third-party proxy voting service (“vendor”) to handle the voting of proxies. The vendor provides
written vote recommendations and guidelines. The third party is not affiliated with Beacon Pointe.
Beacon Pointe has adopted the vendor’s policy guidelines and client proxies will be voted on
according to these policy guidelines. Beacon Pointe believes that this vendor has developed
16
Beacon Pointe Advisors,
LLC
March 2026
policies and procedures that ensure that client proxies are voted in the best interest of our clients.
Beacon Pointe reviews the vendor yearly. Clients may retain the authority to vote all proxies in
their account, but a client may not otherwise direct Beacon Pointe’s vote for particular solicitations.
In cases where proxy voting authority for an ERISA Plan’s holdings rests with Beacon Pointe,
such proxies will be voted in accordance with the vendor’s policy guidelines unless outlined
otherwise in the plan’s governing documents and subject to the fiduciary responsibility standards
of ERISA.
If Beacon Pointe becomes aware of any type of potential or actual conflict of interest relating to a
particular proxy proposal, Beacon Pointe’s Chief Compliance Officer or designee will be
responsible for resolving the conflict. Beacon Pointe can resolve the conflict in a number of ways
depending on the type and materiality. The method selected by Beacon Pointe will depend upon
the facts and circumstances of each situation and the requirements of applicable laws.
Clients can obtain information on how their proxies were voted by contacting Beacon Pointe at the
principal office and place of business indicated on page 1 of this form. In their request, clients
should include their name and the account and security for which they are making the request.
For information regarding proxies voted by Independent Managers, clients should refer to the
Independent Manager’s ADV 2 Brochure.
Legacy clients of firms acquired by Beacon Pointe may have their proxies voted by the acquired
firm according to the proxy voting arrangements of the acquired firm. This practice may continue
temporarily following the acquisition until the proxy voting arrangement can be transitioned at the
custodian by Beacon Pointe.
Class Actions
A securities “class action” lawsuit is a civil suit brought by one or more individuals (“Plaintiffs”)
on behalf of themselves and others who have the same grievance against the issuer of a certain
security. When a class action is filed, a written notice of filing and/or settlement is prepared (the
“Notice”), which outlines the reasons for the lawsuit, the parameters for qualification as a member
of the class and certain legal rights that need to be considered before becoming a member of the
class (i.e., participating in the settlement). In addition, the Notice will contain instructions issued
by the court or broker/dealers and/or other nominees (e.g. custodians) who receive the Notice and
who hold the security on behalf of the owner/beneficiary, to either (1) provide the Claims
Administrator (usually the attorney for the Plaintiffs) with the name and address of each such
owner/beneficiary so the Claims Administrator can send the Notice directly to such
owner/beneficiary, or (2) request additional copies of the Notice and send the Notice directly to
the owner/beneficiary.
In cases where Beacon Pointe is responsible for filing class actions on behalf of clients, we have
selected an unaffiliated third-party vendor to provide class action litigation monitoring and
securities claim filing services on behalf of our clients. The vendor will monitor for class actions
for which our clients may be eligible. Upon learning of any such class actions, the vendor will
collect the applicable documentation, interpret the terms of each settlement, file the appropriate
claim form, interact with the administrators, and distribute the award to applicable clients. The
vendor charges clients a contingency fee which is subtracted from the award at the time of payment.
Clients can opt out entirely or list specific companies against which claims should not be filed on
17
Beacon Pointe Advisors,
LLC
March 2026
their behalf. Clients may change their opt-out election at any time by notifying Beacon Pointe in
writing. Because Beacon Pointe provides this service to our clients through a third-party vendor,
we will not monitor class action suits or process any claim forms on clients’ behalf, whether or not
they opt-out of this service. If a client chooses to opt-out, the vendor also will not monitor any class
action suits from which the client may be entitled to awards, and the vendor will not process any
claim forms on the client’s behalf. Clients who opt out are entitled to pursue securities claims
themselves.
ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS
Beacon Pointe collects information from clients about their financial situation, goals, and risk
tolerance. Our firm communicates such non-public client information with Independent Managers
on a regular basis as needed to confirm that each client’s current investment goals and objectives
are understood. Clients are encouraged to contact Beacon Pointe whenever investment goals and
objectives change. In most cases, we will communicate such information as part of our regular
investment duties. However, we will also communicate information to Independent Managers
when market or economic conditions make it prudent to do so.
ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS
Beacon Pointe has full discretion to select, change, and remove Independent Managers for the
client’s account. When Beacon Pointe manages accounts directly using mutual funds or other
securities, we have discretion to decide the specific security to trade, the quantity, and the timing
of transactions for client accounts. Beacon Pointe is not required to contact clients before making
changes to the Independent Managers or placing trades in their account. Certain securities,
including private funds, require the client’s written agreement to participate in the investment.
Independent Managers investing client assets will also have full discretionary authority over the
portion of the client’s account they manage.
Clients will receive confirmations directly from the broker for any trades placed. Clients grant us
discretionary authority in the contracts they sign with us. Clients also give us or the Independent
Managers trading authority over their accounts when they sign the custodian paperwork.
However, certain client-imposed conditions limit Beacon Pointe’s discretionary authority, such as
where the client places restrictions on the account investments or directs Beacon Pointe to execute
transactions through specific broker-dealers.
In rare circumstances, Beacon Pointe will recommend Independent Managers and investments in
mutual funds or other securities on a non-discretionary basis. In such cases, Beacon Pointe is
required to get client approval before selecting or making changes to the Independent Mangers or
placing trades in their account. When the client approves the recommended Independent Manager,
the client gives the Independent Manager trading authority over their accounts when they sign the
custodian paperwork.
ITEM 9 – ADDITIONAL INFORMATION
Disciplinary Information
Beacon Pointe and our personnel seek to maintain the highest level of business professionalism,
18
Beacon Pointe Advisors,
LLC
March 2026
integrity, and ethics. Beacon Pointe does not have any disciplinary information to disclose.
Other Financial Industry Activities and Affiliations
Related Insurance Agency
Beacon Pointe is a related person of Beacon Pointe Insurance Services, LLC (“BPIS”), a California
licensed insurance agency. Beacon Pointe and BPIS are under joint ownership and control. Certain
personnel of Beacon Pointe are also licensed insurance agents of BPIS and sell insurance products
to advisory clients and then receive commissions on the sale of insurance products. The insurance
commissions are separate from and in addition to any advisory fees that a client pays to Beacon
Pointe for investment advisory services. A conflict of interest may arise as potential BPIS insurance
sales might create an incentive to recommend products based on compensation our personnel may
earn. Clients are under no obligation to act on our personnel’s insurance recommendations or to
effect the transactions through BPIS or our personnel if they decide to follow the recommendations.
In all cases, we fully disclose insurance commissions to the client.
Related Investment Adviser
Beacon Pointe is a related person of Port Street Investments, LLC (“PSI”), an SEC registered
investment adviser that acts as investment adviser to a registered investment company (mutual
fund). Beacon Pointe Holdings, LLC is the majority shareholder of PSI. In some cases, Beacon
Pointe recommends that our clients invest in a fund advised by PSI. PSI receives investment
management fees from the funds it manages. Due to the common ownership between Beacon
Pointe and PSI, we have a conflict of interest in recommending mutual funds managed by this
related firm.
Other Related Businesses
Beacon Pointe has a related entity, Beacon Pointe GP, LLC, which acts as the general partner of
certain private funds (the “Private Funds”). The Private Funds are not publicly offered or traded
and are only available to “Accredited Investors” as the term is defined by Rule 501 of the Securities
Act of 1933. The confidential offering memorandum and subscription agreement (the “Offering
Documents”) provide additional information on these standards. Prospective investors in the
Private Funds receive the Offering Documents. Beacon Pointe or its related entity receives fees in
connection with management services rendered to the Private Funds and therefore has an interest
in recommending the Private Funds to Beacon Pointe’s clients.
Other entities related to Beacon Pointe through common ownership: Beacon Pointe Captive
Insurance and Beacon Pointe Investment Holdings, LLC. These entities do not currently offer
products or services to Beacon Pointe’s clients.
BPMAX Fund
Beacon Pointe serves as the investment adviser to the BPMAX Fund. We have an active interest
in this Fund. BPMAX is a continuously offered, non-diversified, closed-end interval fund
registered under the Investment Company Act of 1940 (the “1940 Act”). The Fund pursues its
investment objective by strategically investing in a portfolio of closed-end interval funds
(“Underlying Funds”) that invest in various asset classes.
19
Beacon Pointe Advisors,
LLC
March 2026
The Fund has retained Beacon Pointe as its investment adviser, and subject to the supervision of
the Fund Trust’s Board of Trustees, we provide a continuous program of supervision for the Fund’s
assets. In addition, Beacon Pointe will supervise and provide oversight of the Fund’s service
providers, and furnish the Fund office facilities, equipment, and personnel for servicing the
management of the Fund. Under our advisory agreement with the Fund, Beacon Pointe is entitled
to compensation for our management services, a monthly management fee based on the fund’s
daily average net assets at the following annual rate: 0.95%
Certain principals of our firm are officers of the Fund. Additionally, our retirement plans as well
as our employees may be shareholders in the Fund. We may recommend that current and
prospective clients invest in the Fund instead of investing in an independently managed account.
This creates a conflict that we believe is mitigated because BPA clients may choose another Fund
at their discretion. In addition, Beacon Pointe does not charge an additional advisory fee to clients
for assets invested in the BPMAX Fund.
Agents of Unaffiliated Broker-Dealer
Certain of Beacon Pointe’s personnel are also licensed as registered representatives with Purshe
Kaplan Sterling Investments (“PKS”), a broker-dealer member of FINRA/SIPC. Beacon Pointe is
not affiliated with PKS. In their individual capacity as registered representatives, these individuals
receive trailing compensation from prior sales of securities and may also receive usual and
customary commissions for sales of securities through PKS. Receipt of commissions for securities
sales is a conflict of interest as it gives these registered representatives an incentive to recommend
investment products based on the additional compensation received. Beacon Pointe’s advisory
clients are not charged both advisory fees and transaction-related fees on investment products that
these registered representatives recommend. When client portfolios hold securities for which
related registered representatives receive commissions and/or trailing 12b-1 fees Beacon Pointe
does not charge advisory fees on those securities.
Certain representatives of Beacon Pointe Advisors, LLC are also Registered Representatives
offering securities through APW Capital, Inc., a broker-dealer member of FINRA/SIPC. Beacon
Pointe is not affiliated with either APW Capital. In their individual capacity as registered
representatives, these individuals receive trailing compensation from prior sales of securities and
may also receive usual and customary commissions for sales of securities through APW Capital.
Receipt of commissions for securities sales is a conflict of interest as it gives these registered
representatives an incentive to recommend investment products based on the additional
compensation received. Beacon Pointe’s advisory clients are not charged both advisory fees and
transaction-related fees on investment products that these registered representatives recommend.
Code of Ethics
Beacon Pointe believes that we owe clients the highest level of trust and fair dealing. As part of
our fiduciary duty, we place the interests of our clients ahead of the interests of the firm and our
personnel. Beacon Pointe’s personnel are required to always conduct themselves with integrity and
follow the principles and policies detailed in our Code of Ethics. Beacon Pointe’s Code of Ethics
attempts to address specific conflicts of interest that either we have identified or that could arise.
Beacon Pointe’s personnel are required to follow clear guidelines from the Code of Ethics in areas
such as gifts and entertainment, other business activities, and adherence to applicable federal
securities laws. Additionally, individuals who make securities recommendations to clients, or who
have access to nonpublic information regarding any clients’ purchase or sale of securities, are
20
Beacon Pointe Advisors,
LLC
March 2026
subject to personal trading policies governed by the Code of Ethics (see below).
Beacon Pointe will provide a complete copy of the Code of Ethics to any client or prospective
client upon request.
Personal Trading Practices
Beacon Pointe and our personnel can purchase or sell securities for ourselves, regardless of whether
the transaction would be appropriate for the client account. Beacon Pointe and our personnel can
purchase or sell securities for ourselves that we also recommend to clients. This includes related
securities (e.g., warrants, options, or futures). This presents a conflict of interest as we may have
an incentive to take investment opportunities from clients for our own benefit, favor our personal
trades over client transactions when allocating trades, or use the information about the transactions
we intend to make for clients to our personal benefit by trading ahead of clients.
Our policies to address these conflicts include the following:
• Personal securities transactions will never adversely affect clients. Beacon Pointe will monitor
trading activity of our personnel to confirm that the interests of clients come first, and that the
trading activity complies with applicable securities laws. All securities transactions and
holdings in any account of our personnel, including accounts for which the individual is
considered a beneficial owner, are subject to review by Beacon Pointe.
• Day trading (buying and selling in the same security on the same business day) of any security
is strictly prohibited.
• Conflicts of interest also can arise when Beacon Pointe’s personnel become aware of Limited
Offerings or IPOs, including private placements or offerings of interests in limited partnerships
or any thinly traded securities, whether public or private. Given the inherent potential for
conflict, Limited Offerings and IPOs demand extreme care. Beacon Pointe’s personnel are
required to obtain pre-approval from the Chief Compliance Officer or designee before trading
in these types of securities.
• For the clients for which Beacon Pointe assigns a sub-adviser, Beacon Pointe’s personnel do
not have access to the transactions in client accounts until after the trades have been placed.
Therefore, we cannot take advantage of client trades in accounts managed by sub-advisers.
Participation or Interest in Client Transactions
Beacon Pointe Private Funds
Beacon Pointe may recommend the Private Funds, which are managed by Beacon Pointe GP, LLC,
a related entity, to clients for whom Beacon Pointe believes the investment is suitable. Beacon
Pointe only recommends a Private Fund to clients who satisfy the requisite income and/or net worth
requirements and for whom Beacon Pointe believes the investment is appropriate based on the
client’s ability to accept the risk. Clients will receive the confidential offering memorandum and
disclosure of known risks before investing. A conflict exists because Beacon Pointe stands to
benefit from additional investments in the Private Funds. To address this conflict, when Beacon
Pointe recommends a Private Fund to an advisory client and such client invests in the Private Fund,
that client’s Private Fund management fees will be waived.
21
Beacon Pointe Advisors,
LLC
March 2026
Beacon Pointe Interval Fund
Beacon Pointe may recommend that its clients invest in the BPMAX Fund, a closed-end interval
fund registered under the Investment Company Act of 1940 (the “1940 Act”), if we believe the
investment is suitable for the clients. Beacon Pointe serves as the investment adviser to the
BPMAX Fund.
As the investment adviser to the Fund, Beacon Pointe receives a monthly management fee at the
annual rate of 0.95% of the Fund’s daily net assets for the services it provides to the Fund.
This arrangement creates a potential conflict of interest, as Beacon Pointe has a financial incentive
to recommend investments in the Fund. To mitigate this conflict, Beacon Pointe does not charge
an additional advisory fee to clients for assets invested in the BPMAX Fund. Instead, clients will
incur only the management fee charged at the fund level.
It is important to note that the Fund’s management fee may sometimes be higher or lower than the
advisory fee clients might otherwise pay to Beacon Pointe for non-fund assets. This means that
depending on the fee structure, clients may end up paying more or less by investing in BPMAX
than they would if their assets were managed outside the Fund.
Clients should carefully review the Fund’s prospectus, particularly the fees and expenses
associated with an investment in BPMAX and consider their overall investment objectives and
financial situation when determining whether an investment in the Fund is appropriate.
Port Street Investments, LLC
Additionally, Beacon Pointe may recommend that its clients invest in a mutual fund advised by
Port Street Investments, LLC (“PSI”), a related investment adviser. Due to the common ownership
between Beacon Pointe and PSI, Beacon Pointe has a conflict of interest in recommending mutual
funds managed by this related firm. In the event that Beacon Pointe utilizes mutual funds or
investment products managed by related firms, clients will not be charged Beacon Pointe’s
investment management asset-based fees on the portion of the client’s assets invested in the fund.
Review of Accounts
Account Reviews
The primary consultant/advisor assigned to the account reviews accounts. Account reviews
typically consider account performance, asset allocation, and overall portfolio construction.
Accounts are reviewed when requested by a client, during significant market changes, and at least
annually.
Clients are encouraged to meet with Beacon Pointe on at least an annual basis to review any
changes to investment objectives, account performance, and financial planning issues.
Account Reporting
All Wrap Fee Program clients receive monthly reports from their custodian(s) regarding their
assets showing the portfolio inventory and transactions during that period. We urge clients to
carefully review such statements and compare such official custodial records to the account
22
Beacon Pointe Advisors,
LLC
March 2026
statements that we provide to clients. Reports we provide at the request of our clients can vary from
custodial statements based on accounting procedures, reporting dates, or valuation methodologies
of certain securities.
Financial Plan Reviews
A Managing Director, Financial Planner or the primary consultant/advisor assigned to the account
is responsible for creating and reviewing clients’ financial plans, as applicable. Beacon Pointe
reviews financial plans on an as needed basis upon request of the client.
Client Referrals and Other Compensation
Benefits We Receive from Custodial Brokers
We receive an economic benefit from Schwab in the form of the support products and services
they make available to us and other independent investment advisors whose clients maintain their
accounts in their custody. We describe these benefits in our Form ADV, Part 2A brochure under
Item 12 – Brokerage Practices. The availability of custodial brokers’ products and services to use
is not based on us giving particular investment advice, such as buying securities for our clients.
Payment for Client Referrals
We have entered into numerous referral agreements whereby we pay a referral fee to Promoters,
in accordance with the requirements of Rule 206(4)-1 of the Investment Advisers Act of 1940, and
any corresponding state securities law requirements. All such referral fees shall be paid solely by
our advisory fee and will not result in an additional charge to the client. Promoters may receive
additional compensation, such as incentive trips and gratis attendance at conferences, including
payment for meals, activities, airfare or accommodation. If an unaffiliated or an affiliated Promoter
introduces a client to Beacon Pointe, that Promoter will disclose the nature of their relationship
with Beacon Pointe at the time of the solicitation. The Promoter will provide each prospective
client with a written disclosure statement disclosing the terms and conditions of the arrangement
between Beacon Pointe and the Promoter, including the compensation that Beacon Pointe pays the
Promoter.
We compensate eligible employees for engaging in business development activities, including
referring a new client. In such cases, the referring employee receives compensation in the form of
a percentage of the estimated first year net revenue for the clients they refer to Beacon Pointe. This
creates an incentive for employees to refer prospective clients to our firm; however, our fiduciary
duty requires that we recommend our services only when we believe they are appropriate for the
client.
Occasionally, we may receive indirect compensation from service providers or third-party vendors
in the form of gifts, entertainment, and complimentary attendance at industry conferences,
meetings, or other educational events. When this occurs, we carefully assess the value and nature
of these offerings to ensure that they are reasonable and customary, and to avoid any conflicts of
interest.
Interval Fund
As the Adviser to the BPMAX Fund, BPA may enter into arrangements with broker-dealers and
23
Beacon Pointe Advisors,
LLC
March 2026
other financial institutions, including banks and insurance companies, to provide services to the
Fund or its shareholders, such as administrative services, shareholder sub-accounting services, and
sales and marketing-related services and activities. These organizations may be compensated for
such services by BPA, the Fund, or both, as described in the Fund’s prospectus and Statement of
Additional Information. These arrangements create a conflict of interest because they may provide
these organizations with a financial incentive to recommend or maintain investments in BPMAX.
These arrangements may include:
• Administrative services,
• Shareholder sub-accounting services
• Sales and marketing-related services and activities.
Sponsorship of Corporate Events
Companies that manage securities and other assets used in Beacon Pointe accounts, such as
custodians, mutual funds, and Independent Managers, may sponsor or host Beacon Pointe events,
such as conferences and seminars. They may directly pay vendors or reimburse expenses incurred
for hosting education, training, or other events for clients or employees. These arrangements give
rise to conflicts of interest (or the appearance of conflicts of interest) that could influence us to
include or recommend products and services offered by the sponsoring companies. Beacon Pointe
does not receive any financial incentive or revenue-sharing fee for recommending specific
investments or Independent Managers to its clients.
Financial Information
Registered investment advisers are required to provide clients with certain financial information
or disclosures about the firm’s financial condition. Beacon Pointe does not foresee any financial
condition that is reasonably likely to impair our ability to meet contractual commitments to clients.
24
Beacon Pointe Advisors,
LLC
March 2026