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Item 1. Cover Page
FORM ADV PART 2A (“Brochure”)
OnePoint BFG
300 Kimball Drive Suite 310
Parsippany, NJ 07054
(973) 575-4180
https://www.onepointbfg.com
July 22, 2025
This Brochure provides information about the qualifications and business practices of Bleakley
Financial Group, LLC, (d/b/a OnePoint BFG Wealth Partners). If you have any questions about
the contents of this Brochure, please contact us at (973) 575-4180 or
craig.weiss@onepointbfg.com. The information in this Brochure has not been approved or
verified by the United States Securities and Exchange Commission (“SEC”) or by any state
securities authority. Bleakley Financial Group, LLC (d/b/a OnePoint BFG Wealth Partners) shall
be referred to herein as “OnePoint BFG”.
Additional information about OnePoint BFG is available on the SEC's website at
www.adviserinfo.sec.gov.
References herein to Bleakley Financial Group, LLC or OnePoint BFG as a "registered
investment adviser" or any reference to being "registered" does not imply a certain level of skill
or training.
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Item 2. Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Brochure") and Part 2B (“Brochure
Supplement"). The Brochure provides information about a variety of topics relating to an
Advisor's business practices and conflicts of interest. The Financial Advisor’s Brochure
Supplement provides information about the Advisory Persons of OnePoint BFG.
The following changes have been made since OnePoint BFG’s last annual update on March 28,
2025
Bleakley Financial Group LLC. executed a branding and name change to conduct business as
OnePoint BFG Wealth Partners (“OnePoint BFG”) effective July 22, 2025.
Additional editorial and non-material changes were made throughout the Brochure. Periodically,
the Form ADV 2A may be amended to update disclosures referencing changes to our business
practices, industry regulations, or required annual updates by securities regulators. OnePoint BFG
will forward the updated ADV 2A or a Summary of Material Changes to each Client annually or
if a material change occurs.
At any time, you may contact Craig Weiss, OnePoint BFG’s Chief Compliance Officer at (973)
5754180 or craig.weiss@onepointbfg.com, if you have any questions about this Brochure. You
may also view the current ADV 2A on-line at the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching our firm name or our CRD #318366.
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Item 3. Table of Contents
Item 1. Cover Page ........................................................................................................................................ 1
Item 2. Material Changes ............................................................................................................................... 2
Item 3. Table of Contents .............................................................................................................................. 3
Item 4. Advisory Business ............................................................................................................................. 4
Item 5. Fees and Compensation ................................................................................................................... 16
Item 6. Performance-Based Fees and Side-by-Side management ............................................................... 28
Item 7. Types of Clients ............................................................................................................................... 28
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 29
Item 9. Disciplinary Information ................................................................................................................. 36
Item 10. Other Financial Industry Activities and Affiliations ..................................................................... 37
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................ 39
Item 12. Brokerage Practices ....................................................................................................................... 40
Item 13. Review of Accounts ...................................................................................................................... 43
Item 14. Client Referrals and Other Compensation ..................................................................................... 44
Item 15. Custody .......................................................................................................................................... 45
Item 16. Investment Discretion .................................................................................................................... 46
Item 17. Voting Client Securities ................................................................................................................ 46
Item 18. Financial Information .................................................................................................................... 47
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Item 4. Advisory Business
OnePoint BFG is an investment advisory firm providing customized financial planning and
wealth management services to a broad array of clients. Bleakley is a New Jersey limited
liability company that was founded in 1994 and is wholly owned by Bleakley Holdings LLC.
Additional information about OnePoint BFG’s direct and indirect owners and executive officers
may be found in Form ADV Part 1, Schedule A available at adviserinfo.sec.gov by searching
OnePoint BFG’s name or using OnePoint BFG’s CRD #318366.
Bleakley Financial Group LLC (“Bleakley”) is registered as an investment adviser with the SEC
and notice-filed in all states where advisory business is conducted. As of June 30, 2025,
OnePoint BFG managed $12,128,656,187 in total client assets. OnePoint BFG managed
$11,556,439,669 of client assets on a discretionary basis and $572,216,518 of client assets on a
non-discretionary basis.
OnePoint BFG serves as a fiduciary to Clients, as defined under the applicable laws and
regulations. As a fiduciary, OnePoint BFG and its Advisors must put the client’s best interests
ahead of their own. OnePoint BFG’s Code of Ethics further describes the firm’s commitment to
its duty of loyalty, fairness, and good faith to each client. This Brochure will disclose conflicts of
interest and OnePoint BFG’s commitment to mitigating each.
OnePoint BFG’s financial professionals, called Advisors (also referred to in this Brochure as
“OnePoint BFG’s Advisors,” “the Advisor” or “its Advisors”), offer its clients (individuals,
business entities, trusts, estates, charitable organizations, etc.) investment advisory services on a
discretionary basis. These investment advisory services also include wealth management,
retirement plan consulting and advisory, financial consulting and other consulting services to the
extent specifically requested by a client. OnePoint BFG Advisors also provide clients investment
advisory services on a non-discretionary basis. OnePoint BFG’s Advisors are independent
contractors or employees of OnePoint BFG and some of Bleakley’s Advisors operate under
other“doing business as” (“DBA”) firm(s). The investment advisory and financial planning
products and services offered through the DBA are provided through Bleakley.
OnePoint BFG works to provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an Advisor will discuss and review each
client’s particular investment objectives and risk tolerances. This information will include, but
not be limited to:
Investment objectives
Investment time horizon
• Retirement and financial goals
•
•
• Financial needs and goals and risk tolerance
• Other applicable financial information required by OnePoint BFG in order to provide the
investment advisory services requested.
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OnePoint BFG Advisors allocate each client's investment assets consistent with the client’s
designated investment objectives and risk tolerances. Clients may, at any time, impose
restrictions, in writing, on OnePoint BFG's services. Each client is responsible for promptly
notifying OnePoint BFG of any change in financial situation or investment objectives for the
purpose of reviewing and revising OnePoint BFG's previous recommendations and services.
OnePoint BFG and its Advisors will be in periodic contact with clients to discuss clients'
investments, investment objectives and risk tolerances (please see Item 13 for more information).
Clients should discuss with their OnePoint BFG Advisor what programs are appropriate based on
the client’s investment objectives and risk tolerances.
OnePoint BFG allows the use of Zocks, a tool that allows Financial Advisors to transcribe and
summarize meetings they host. Zocks utilizes artificial intelligence (“AI”) to generate meeting
transcripts that cover the topics discussed in the meeting. Clients are prompted with a disclaimer
to opt in to the use of the AI software at the start of the meeting. The meeting transcripts using
AI, with any edits made to the transcripts by employees (not by AI), are considered books and
records of OnePoint BFG and are maintained accordingly.
OnePoint BFG’s Chief Compliance Officer is available to address any questions that a client or
prospective client may have regarding any conflicts of interest associated with any particular
program or strategy or any information outlined in this Brochure.
A.
INVESTMENT ADVISORY ACCOUNTS
Prior to engaging OnePoint BFG to provide investment advisory services, including wealth
management, each client will be required to enter into OnePoint BFG’s written advisory
agreement setting forth the terms and conditions under which OnePoint BFG will manage the
client’s assets, including client specific fee and expense information. A client will also be
required to enter into a separate custodial agreement with each designated custodian.
Most clients engage OnePoint BFG on a discretionary basis, which means the Advisor will make
investment decisions without the client’s prior authorization. Clients that determine to engage
OnePoint BFG on a non-discretionary investment advisory basis must be willing to accept that
OnePoint BFG cannot affect any account transactions without obtaining the client’s prior
consent. Thus, in the event of a market correction during which the client is unavailable,
OnePoint BFG will be unable to affect any account transactions (as it would for its discretionary
investment advisory clients) without first obtaining the client’s verbal consent.
Typically, for investment advisory services including wealth management, OnePoint BFG will
charge a “wrapped” investment advisory fee based on a percentage of the assets to be managed,
also known as an asset-based fee (unless other services and/or fee structure have been negotiated
by the client and the OnePoint BFG Advisor). OnePoint BFG also offers a non-wrap investment
advisory fee for certain accounts that are not available as wrap accounts. The difference between
a wrap fee and a non-wrap fee is whether OnePoint BFG or the client pay for, as applicable, a
custodial asset-based charge or custodial transaction-based charges. For more information on
fees, including conflicts of interest, see Item 5.
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For certain accounts, OnePoint BFG utilizes custodian-sponsored programs and services, third-
party investment manager programs and/or Turnkey Asset Management Platforms (“TAMPs”).
These services may be offered as a separately managed account (commonly referred to as
SMAs) or as a unified managed account (or UMAs). OnePoint BFG will provide such
custodians, investment manager and TAMPs, as applicable, client-specific information to enable
that custodian, investment manager or TAMP to provide the elected services.
Additional information about OnePoint BFG’s investment advisory services is provided below.
B . C U S T O D I A N S
As part of OnePoint BFG’s investment advisory services, OnePoint BFG Advisors and Client
choose a qualified custodian, that is a broker-dealer and is also a member of FINRA and SIPC to
maintain custody of clients' assets and facilitate trades for the clients’ accounts (referred to as
“custodians” or “qualified custodians”). Currently, OnePoint BFG utilizes the following qualified
custodians:
• LPL Financial, LLC (“LPL”),
• Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”).
• Pershing Advisor Solutions, LLC (“PAS”),
• National Financial Services LLC , an affiliate of Fidelity Brokerage Services LLC.
(“Fidelity”), and
• Goldman Sachs (“Goldman”).
Please note: Before selecting a custodian, clients should discuss with their OnePoint BFG
Advisor the differing custodial accounts, programs, services, fees and costs. For example, a non-
wrap fee is not available for OnePoint BFG clients through LPL or Pershing. Additionally, the
custodians offer various third-party investment manager programs. The final decision to custody
assets with any custodian is made by OnePoint BFG's clients, including client accounts
established under Employee Retirement Income Security Act of 1974, as amended (“ERISA”) or
Individual Retirement Account (“IRA”) rules and regulations, in which case the client is acting
as either the plan sponsor or IRA accountholder. For more information about these custodians,
clients should refer to Investment Advisor Public Disclosure at www.adviserinfo.sec.gov or
FINRA BrokerCheck at https://brokercheck.finra.org/.
OnePoint BFG is independently owned and operated and not affiliated with any custodian;
however, certain of OnePoint BFG’s Advisors are also registered representatives of Purshe
Kaplan Sterling Investments (“PKS”). OnePoint BFG and PKS are not affiliated entities. Please
see Items 5 and 12 for more information on custodial fees, charges and conflicts of interest.
Held-Away Assets: Upon request, OnePoint BFG will provide investment advisory services on
client assets “held-away” at other custodians, administrators or product providers on a
discretionary or non-discretionary basis. Additional information on held-away assets is provided
in section I, below.
C.
CUSTODIAN-SPONSORED ADVISORY PROGRAMS AND SERVICES
OnePoint BFG Advisors also recommend and/or select custodian-sponsored advisory programs
and/or services. Some investments may be custodied by or through the issuer, for example
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mutual funds or variable annuity products. For additional information on OnePoint BFG’s
brokerage and custodial practices, see Items 12 and 15.
As part of these custodian-sponsored advisory programs and consistent with how OnePoint BFG
provides investment advisory services to all of its clients, the Advisor typically obtains the
necessary financial data from the client, assists the client in determining the suitability of the
program, assists the client in setting an appropriate investment objective and risk tolerance
parameters and assists the client in opening an account or accounts. In addition, depending on
the type of program, the Advisor may assist the client to select a model portfolio of securities or
select a portfolio management firm to provide discretionary asset management services.
Below is a brief description of some of the custodian-sponsored advisory programs and services
available through OnePoint BFG. Under some custodian-sponsored advisory programs, the
custodian is responsible for completing due diligence on the portfolio manager(s); in other
custodian-sponsored advisory programs, OnePoint BFG is responsible for conducting such due
diligence. For more information regarding these programs and services, including additional
information on the due diligence responsibilities, fees that are applicable, the types of
investments available in the programs and the potential conflicts of interest presented by the
programs, please refer to the information provided by the Advisor, including, but not limited to,
the applicable custodian’s Form ADV Part 2A brochure or the applicable program’s Form ADV
Part 2A brochure and applicable agreement(s).
i.
LPL Sponsored Advisory Programs
OnePoint BFG provides advisory services to clients through certain programs sponsored by LPL,
including, but not limited to:
• Optimum Market Portfolios Class I Shares Program (“OMP”) – OMP is a professionally
managed asset allocation program using Optimum Funds Class I shares. Under OMP, the
client authorizes LPL on a discretionary basis to purchase and sell Optimum Funds
pursuant to investment objectives chosen by the client. OnePoint BFG will assist the
client in determining the suitability of OMP for the client and assist the client in setting
an appropriate investment objective. OnePoint BFG will have discretion to select a
mutual fund asset allocation portfolio designed by LPL consistent with the client’s
investment objectives. LPL will have discretion to purchase and sell Optimum Funds
Class I shares pursuant to the portfolio selected for the client. LPL will also have
authority to rebalance the account. LPL sets a minimum account size (dollar value) for
OMP and changing account balances and minimum requirements may affect whether this
program is appropriate for a particular client and may affect the fees charged.
• Model Wealth Portfolios Program (“MWP”) – MWP is a professionally managed mutual
fund asset allocation program. OnePoint BFG will obtain the necessary financial data
from the client, assist the client in determining the suitability of the MWP program and
assist the client in setting an appropriate investment objective. OnePoint BFG will initiate
the steps necessary to open an MWP account and will have discretion to select a model
portfolio designed by LPL’s Research Department consistent with the client’s stated
investment objectives. LPL’s Research Department is responsible for selecting the
mutual funds within a model portfolio and for making changes to the mutual funds
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selected. The client will authorize LPL to act on a discretionary basis to purchase and sell
mutual funds (including in certain circumstances exchange traded funds) and to liquidate
previously purchased securities. The client will also authorize LPL to affect rebalancing
for MWP accounts. The MWP Program also offers model portfolios designed by
strategists other than LPL’s Research Department. OnePoint BFG can choose among the
available models designed by LPL and outside strategists. LPL sets a minimum account
size (dollar value) for MWP and changing account balances and minimum requirements
may affect whether this program is appropriate for a particular client and may affect the
fee charged.
• Manager Access Select Program (“MAS”) – MAS provides clients access to the
investment advisory services of professional portfolio management firms for the
individual management of client accounts. OnePoint BFG will assist clients in
identifying a third-party portfolio manager (each a “Portfolio Manager”) from a list of
Portfolio Managers made available by LPL. The Portfolio Manager manages the client’s
assets on a discretionary basis. OnePoint BFG will provide initial and ongoing
assistance regarding the Portfolio Manager selection process. LPL and Portfolio
Managers set a minimum account size (dollar value) for MAS and changing account
balances and minimum requirements may affect whether this program is appropriate for
a particular client and may affect the fee charged.
• Managed Accessed Network (“MAN”) – MAN provides clients access to the investment
advisory services of professional portfolio management firms for the individual
management of client accounts. OnePoint BFG will assist clients in identifying a third-
party portfolio manager (each a “Portfolio Manager”) from a list of Portfolio Managers
made available by LPL. The Portfolio Manager manages the client’s assets on a
discretionary basis. OnePoint BFG will provide initial and ongoing assistance regarding
the Portfolio Manager selection process. LPL and the Portfolio Managers set a minimum
account size (dollar value) for MAN and changing account balances and minimum
requirements may affect whether this program is appropriate for a particular client and
may affect the fee charged.
ii.
Schwab Sponsored Advisory Programs
OnePoint BFG provides advisory services to clients through certain programs sponsored by
Schwab, including, but not limited to:
• Managed Account Marketplace – The Managed Account Marketplace platform is a
“dual-contract” structure in which the Advisor negotiates directly with the third-party
investment manager of the Advisor’s choosing and the client benefits from the
brokerage and custody services of Schwab. This platform permits the Advisor to use
third-party money managers of the Advisor’s choosing and negotiate any arrangements
with the managers directly.
• Managed Account Select – Managed Account Select (“Select”) is the most
comprehensive managed account program at Schwab, with access to research and
ongoing due diligence of money managers and strategies provided by Schwab’s
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investment advisory group. Features and benefits of Select, include, but are not limited
to, a “single contract” structure, low account minimums, bundled fees and research.
• Managed Account Access – The Managed Account Access Program (“Access”) is a
“single contract” structure that allows the Advisor to work with an array of money
managers. Other features and benefits include, but are not limited to, low account
minimums, bundled fees and access to over 75 managers on this platform.
iii. Fidelity Sponsored Advisory Programs
OnePoint BFG provides advisory services to clients through certain programs sponsored by
Fidelity, including, but not limited to:
• Fidelity Separate Account Network® (“SAN”) program – The SAN Program enables
OnePoint BFG and its Advisors to build separately managed account portfolios from a
Fidelity network of managers to meet client needs which will be managed by designated
SAN Managers on a discretionary basis. The minimum investment required by each
individual SAN Manager must be met to participate with that respective SAN Manager in
this program. Some managers in the SAN program may require an additional agreement
directly with the client in addition to OnePoint BFG’s written advisory agreement.
OnePoint BFG and the client together determine which SAN Manager to engage.
iv.
PAS Managed Account Infrastructure
PAS offers OnePoint BFG the ability to utilize the PAS managed account infrastructure to assist
OnePoint BFG in meeting the investment objectives of its clients. A managed account is an
investment account where the Advisor selects and creates a portfolio or utilizes a model portfolio
developed by PAS.
D.
THIRD-PARTY INVESTMENT MANAGERS
OnePoint BFG and its Advisors recommend and/or select third-party investment managers to
handle all or a portion of the asset management process. These third-party investment managers,
sometimes referred to as sub-advisors or third-party asset managers, may be selected directly by
OnePoint BFG Advisors or available to OnePoint BFG through a custodian-sponsored program.
Certain sub-advisory arrangements require the client engage the third-party investment manager
directly and OnePoint BFG will help facilitate that arrangement. Under this scenario the client
will enter into a separate, written agreement with the third-party investment manager, detailing
the fees and expenses that the client will pay to such third-party investment manager.
TURNKEY ASSET MANAGEMENT PLATFORMS (“TAMPs”)
E.
OnePoint BFG and its Advisors recommend and/or select Turnkey Asset Management Platforms
(“TAMPs”) to handle all or a portion of the asset management process. TAMPs typically include
technology, investment research, portfolio management and other outsourcing services. TAMPs
generally provide services that enable the Advisors to integrate multiple providers, programs,
products, and custodians.
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OnePoint BFG currently offers advisory services through TAMPs sponsored by, among others:
Beacon Management and Simplicity Solutions, LLC. OnePoint BFG may offer the advisory
services of other TAMPs in the future. For more information regarding these programs,
including additional information on the advisory services and fees that are applicable, the types
of investments available in the programs and the potential conflicts of interest presented by the
programs, please refer to the information provided by the Advisor, including, but not limited to,
the applicable TAMP sponsor’s Form ADV Part 2A brochure or the applicable program’s Form
ADV Part 2A brochure and applicable agreement(s).
PROPRIETARY INVESTMENT STRATEGIES
F.
OnePoint BFG Advisors may allocate client investable assets within one or more of the
following proprietary investment strategies:
• OnePoint BFG Global Macro Strategy (“Global Macro”) - Global Macro is a diversified
investment strategy that utilizes a macro, top-down fundamental view alongside a
research selection process. The strategy is invested mostly in equities and fixed income
securities but also can hold positions in commodity ETFs. The equity portion focuses on
among other things, competitive advantages, cash flow, and dividends/returns. Fixed
income takes into account views on interest rates, monetary policy, credit risks and
foreign exchange.
• OnePoint BFG Target Income Portfolio Strategy (“Target Income”) - The Target Income
strategy is a thematic macro investment strategy with a sole focus on dividend paying
securities and interest coupon paying bonds. Exposures in the strategy include companies
that in OnePoint BFG’s view have strong competitive advantages, strong free cash flow
and high returns on equity.
• OnePoint BFG Benestar Investment Strategy (“Benestar”) - The Benestar strategy invests
in a portfolio of disruptive growth companies and attractively valued multi-year earnings
compounders across the vast and diverse Healthcare, Life Sciences and Wellness Sectors.
For Benestar, OnePoint BFG believes that companies with strong attributes and sources of
sustainable competitive advantage, that are levered to long-term demographic tailwinds,
are driving technological and therapeutic innovation, and can capitalize on evolving
reimbursement and delivery models, and changing consumer behaviors, will generate
highly compelling investment opportunities. The Benestar strategy utilizes a deep bottom-
up fundamental research process, complimented by a comprehensive knowledge of the
complex health policy, legislative and regulatory landscape, to identify those companies
from across the strategy’s focus sectors that are best positioned to benefit from these
long-term secular trends and drivers of value creation, and which offer superior
risk/reward profiles.
• OnePoint BFG Managed Asset Program (“BMAP”) – BMAP is a OnePoint BFG
proprietary investment model program that utilizes low cost-efficient access to the
market through ETFs with over 10,000 underlying stocks and bonds. Allocations under
BMAP are monitored daily if investments drift outside of tolerance bands set by
OnePoint BFG and are adjusted on a daily basis if necessary.
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• OnePoint BFG Firm Model Program (“BFMP”) – BFMP is a OnePoint BFG proprietary
investment model program that utilizes a blend of actively and passively managed mutual
funds, offering a diversified portfolio with over 10,000 underlying stocks and bonds.
Allocations under BFMP are monitored weekly if investments drift outside of tolerance
bands set by OnePoint BFG and are adjusted on a weekly basis if necessary.
• OnePoint BFG Unified Managed Account Program (“UMA”) – UMA is a OnePoint BFG
proprietary investment model program which utilizes sleeves of any (or all) of the
OnePoint BFG Proprietary Strategy Models, as well as certain third-party strategies
offered through the Orion Portfolio Solutions, LLC Communities Platform. Allocations
are monitored using a systematic process of coordinating investment transactions across
the Strategist Model(s) within the UMA, and will be rebalanced as needed to maintain the
chosen investment allocation strategy.
In addition to the advisory fee charged by your advisor, OnePoint BFG will receive a
management fee for the proprietary programs as well as an additional management fee for the
UMA. This presents a conflict of interest in recommending proprietary programs to increase the
total fees charged by OnePoint BFG on the same assets. To mitigate this conflict, OnePoint
BFG’s Advisors are fiduciaries and required to act in the best interest of the client ahead of their
own best interests. For additional information on the management of OnePoint BFG’s
proprietary investment strategies, including fees, risks, and conflicts of interest, see Items 5, 8
and 10.
OnePoint BFG’s Chief Compliance Officer is available to address any questions that a client or
prospective client may have regarding the above conflicts of interest, or any information outlined
in this Brochure.
G.
RETIREMENT PLAN CONSULTING AND ADVISORY SERVICES
OnePoint BFG’s Advisors assist clients that are trustees of retirement plans or other fiduciaries
to retirement plans (referred to within this section as “plan” and as “client”) by providing fee-
based consulting and/or advisory services. OnePoint BFG Advisors perform one or more of the
following services, as selected by the client in OnePoint BFG's written agreement:
• Assistance in the preparation or review of an investment policy statement (“IPS”) for the
plan based upon consultation with client to ascertain plan investment objectives and
constraints.
• Acting as a liaison between the plan and service providers, product sponsors or vendors.
• Ongoing monitoring of investment managers or investments in relation to the criteria
specified in the plan’s IPS or other written guidelines provided by the client to Advisor.
• Preparation of reports describing the performance of plan investment manager(s) or
investments, as well as comparing the plan performance to benchmarks.
• Ongoing recommendations, for consideration and selection by client, about specific
investments to be held by the plan or, in the case of a participant- directed defined
contribution plan, to be made available as investment options under the plan.
• Training for the members of the plan committee regarding the service on the committee,
including education and consulting with respect to committee members’ responsibilities.
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• Assistance in enrolling plan participants in the plan, including conducting an agreed upon
number of enrollment meetings. As part of such meetings, Advisors provide participants
with information about the plan, which may include information on the benefits of plan
participation, the benefits of increasing plan contributions, the impact of pre-retirement
withdrawals on retirement income, the terms of the plan and the operation of the plan.
• Assistance with investment education seminars and meetings for plan participants. Such
meetings may be on a group or individual basis and may include information about the
investment options under the plan (e.g., investment objectives, risk/return characteristics,
and historical performance), investment concepts (e.g., diversification, asset classes, and
risk and return), and how to determine investment time horizons and assess risk tolerance.
Such meetings do not include specific investment advice about investment options under
the plan as being appropriate for a particular participant.
• Assistance at client’s direction in making changes to investment options under the plan.
• As part of the ongoing investment recommendation service set out above, assistance in
identifying investment options in connection with the “broad range” requirement of
Section 404(c) of ERISA.
• As part of the ongoing investment recommendation service set out above, assistance in
identifying an investment fund product or model portfolio in connection with the
definition of a “Qualified Default Investment Alternative” (“QDIA”) under ERISA.
• Assistance with the preparation, distribution and evaluation of “Request for Proposals,”
finalist interviews, and conversion support in connection with vendor analysis and
service provider support.
• Preparation of comparisons of plan data (e.g., regarding fees and services and participant
enrollment and contributions) to data from the plan’s prior years and/or a benchmark
group of similar plans.
• Assistance in identifying the fees and other costs borne by the plan for, as specified by
client, investment management, recordkeeping, participant education, participant
communication and/or other services provided with respect to the plan.
When engaged by the client to do so, a OnePoint BFG Advisor will meet with plan participants,
upon request, to collect information necessary to identify plan participants’ investment
objectives, risk tolerance, time horizon, etc. and/or provide plan participants with educational
information. Unless engaged by the client or the plan participant (individually) to do so,
OnePoint BFG Advisors do not provide individualized investment advice to plan participants
regarding the participant’s plan assets.
If the plan makes available publicly traded employer stock as an investment option under the
plan, OnePoint BFG Advisors do not provide investment advice regarding company stock and
are not responsible for the decision to offer company stock as an investment option.
To the extent requested by a client, OnePoint BFG and its Advisors will also perform:
•
investment consulting services for the plan, such services will constitute “investment
advice” under Section 3(21)(A)(ii) of ERISA. Therefore, OnePoint BFG and its
Advisors will be deemed a “fiduciary” as such term is defined under Section 3(21)(A)(ii)
of ERISA in connection with those services. OnePoint BFG and its Advisors will service
these accounts on a non-discretionary basis;
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•
investment advisory services for the plan and participants of the plan, such services will
be performed as an “investment manager” under Section 3(38) of ERISA. Therefore,
OnePoint BFG and its Advisors will be deemed a “fiduciary” as such term is defined
under Section 3(38) of ERISA in connection with those services. OnePoint BFG and its
Advisors will service these accounts on a discretionary basis and/or other plan-related
services, such as plan participant education or retirement and/or savings analysis,
OnePoint BFG is not acting as an “investment manager” under ERISA and OnePoint
BFG and its Advisors will not be a “fiduciary” under ERISA with respect to those other
services.
Non-Discretionary Advice to Plan Participants: If you, a plan participant, engage OnePoint
BFG to provide non-discretionary, individualized investment advice for your retirement
accounts, such as 401(k)s and 403(b)s, a OnePoint BFG Advisor’s advice is generally limited to
the investment options approved by the plan. Because of this, OnePoint BFG’s investment
advisory services to plan participants is limited to those available investment options and will be
reviewed by OnePoint BFG and a OnePoint BFG Advisor will generally advise on allocation
changes or rebalancing strategies, if necessary. Additionally, if the plan is paying for non-
discretionary, individualized investment advice for the plan’s participants, OnePoint BFG and its
Advisors have a conflict of interest. This conflict of interest creates an incentive for OnePoint
BFG and its Advisors to potentially prioritize the plan (that pays OnePoint BFG) over that of the
plan participant. OnePoint BFG addresses this conflict of interest by disclosing the relationship
to the plan participant within a written agreement.
H.
FINANCIAL PLANNING AND INVESTMENT CONSULTING SERVICES
To the extent requested by a client, a OnePoint BFG Advisor will make a determination
whether to provide financial planning and/or investment consulting services on a standalone
fee basis. OnePoint BFG's planning and consulting fees are negotiable, depending upon the
level and scope of the service(s) required and the professional(s) rendering the service(s).
Prior to engaging OnePoint BFG to provide financial planning or consulting services, clients
are generally required to enter into OnePoint BFG’s written agreement setting forth the terms
and conditions of the engagement (including termination), describing the scope of the
services to be provided, and establishing the fee.
If requested by a client, a OnePoint BFG Advisor may recommend the services of other
professionals for implementation purposes, including OnePoint BFG's Advisors in their
individual capacities as broker-dealer registered representatives of PKS. See disclosure below
in Item 10.
HELD-AWAY ASSET MANAGEMENT
I.
Upon request, OnePoint BFG will provide investment advisory services on client assets “held-
away” at other custodians, administrators or product providers on a discretionary or non-
discretionary basis.
Non-discretionary, investment advisory services related to held-away assets generally applies to
retirement accounts, such as 401(k)s and 403(b)s, and variable insurance products and other
client accounts where OnePoint BFG is providing very limited services. In this regard,
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investment selection is generally limited to the investment options approved by the plan
administrator or product provider. Because of this, OnePoint BFG’s investment advisory
services to held-away accounts are limited to those available investment options and may be
subject to other service limitations, as disclosed to the client in a separate written agreement.
If a client elects to engage OnePoint BFG’s discretionary, investment advisory services for held-
away assets, OnePoint BFG may use a third-party intermediary’s order management system to
facilitate trading activities. Under this arrangement, the client will be required to enter a user-
agreement with the third-party, detailing the arrangement. For additional information regarding
costs and potential conflicts of interest, see Item 5.
We provide an additional service for accounts not directly held in our custody, but where we do
have discretion, and may leverage an Order Management System to implement tax-efficient asset
location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k)
accounts, HSA’s, and other assets we do not custody. We regularly review the available
investment options in these accounts, monitor them, and rebalance and implement our strategies in
the same way we do other accounts, though using different tools as necessary.
OTHER CONSULTING SERVICES
I.
If requested by a client, OnePoint BFG will recommend other consulting services regarding
non-investment-related matters, such as but not limited to, estate planning, tax planning,
insurance, Medicare and social security planning, and life coaching, Clients may obtain other
consulting services recommended by OnePoint BFG or its Advisors through other, non-
affiliated firms.
OnePoint BFG does not serve as an accountant for any client and no portion of OnePoint
BFG’s services should be construed as the same. Some of OnePoint BFG’s supervised persons
recommend tax preparation services and any such services is not provided by or through
OnePoint BFG. See Item 10 for additional information.
OnePoint BFG does not serve as an attorney-at-law for any client and no portion of OnePoint
BFG’s services should be construed as the same. Certain of OnePoint BFG’s supervised persons
are attorneys-at-law, in their individual capacities, separate and apart from OnePoint BFG, and
any services or advice rendered in that capacity is not provided by or through OnePoint BFG.
OnePoint BFG does not sell insurance and no portion of OnePoint BFG’s services should be
construed as the same. OnePoint BFG is affiliated through common ownership with an insurance
agency. Additionally, certain of OnePoint BFG’s supervised persons and Advisors are licensed
to sell insurance, in their individual capacities, and any such sale of insurance in that capacity is
not provided by or through OnePoint BFG. See Item 10 for additional information.
OnePoint BFG’s life coaching services are provided by a OnePoint BFG employee (supervised
person) who is a certified life coach through the International Coaching Federation.
To the extent requested by a client, OnePoint BFG will recommend the services of other
professionals for certain non-investment implementation purposes (i.e., attorneys, accountants,
insurance, etc.). The client is under no obligation to engage the services of any such
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recommended professional. The client retains absolute discretion over all such implementation
decisions and is free to accept or reject any recommendation from OnePoint BFG in this regard.
Please Note: If the client engages any such recommended professional as set forth above, and a
dispute arises thereafter relative to such engagement, the client agrees to seek recourse
exclusively from and against the engaged professional. In addition, the client should perform their
own due diligence on any recommended professional.
Upon review of an investor's financial status, the company may propose that the investor include,
as part of his or her financial portfolio, one or more types of products that are not part of the
investment advisory services provided by the company, such as insurance or some annuity
products. If the investor chooses to include such a product in his or her financial portfolio, the
company recommends that the investor work closely with his or her attorney, accountant,
insurance agent and other related professionals. Incorporation of the non-advisory financial
product into the investor's financial plan is entirely at the client's discretion.
DPL Specific Insurance Products
• For insurance or some annuity products, the company provides access to a platform
of products by DPL Financial Partners, LLC ("DPL"). The investor is under no
obligation to use DPL's service and may seek advice from any licensed agent. The
insurance or annuity products and fee structures available from DPL may differ from
those available from other third-party insurance agents. The company recommends
that the investor fully evaluate products and fee structures to determine which
arrangements are most favorable to the investor prior to making an investment
decision. The company does not receive compensation for insurance products or some
annuities selected by the investor, whether secured through DPL or any other agent.
Item 5. Fees and Compensation
OnePoint BFG endeavors at all times to put the interests of its clients first. Clients should be
aware, however, that the receipt of economic or other benefits by OnePoint BFG in and of itself
creates a conflict of interest and may influence OnePoint BFG’s choices for investments,
custodial services, third-party investment managers and TAMPs. Additionally, the receipt of
economic or other benefits by OnePoint BFG’s Advisors in and of itself creates a conflict of
interest and may influence the Advisors’ recommendations to clients.
Furthermore, a conflict of interest arises in that OnePoint BFG’s Advisors have an incentive to
increase the assets held in a OnePoint BFG advisory account (wrap or non-wrap) as it increases
the investment advisory fee paid to OnePoint BFG and its Advisors. Similarly, a conflict of
interest arises in that OnePoint BFG’s Advisors have a disincentive to trade securities in order to
reduce the custodial transaction-based charges in a wrap account, thereby increasing the wrap fee
amount retained by OnePoint BFG and its Advisors. Wrap fees and custodial charges may be
higher or lower than those charged by other investment advisers. The investment strategy,
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investments and related transactions will impact whether a client will pay more in a non-wrap
versus a wrap fee account. Additional information is provided below.
OnePoint BFG does not require an annual minimum fee or minimum asset level for investment
advisory services. However, custodian-sponsored programs, third-party investment managers
and TAMPs may require a minimum asset level or charge a minimum fee, and clients should be
aware that the imposition of minimum fees by another entity will result in a higher fee being
charged than is described in this Brochure. Clients may invest in many of the securities and
investment products that OnePoint BFG makes available through another broker-dealer,
custodian, investment adviser or another financial institution.
In addition to disclosing these conflicts of interest, OnePoint BFG has created and implemented a
compliance and supervisory program to mitigate such conflicts through the oversight of client
accounts and investment advisory activities. OnePoint BFG mitigates these conflicts of interest, in
part, by endeavoring to act in each client’s best interest and through the adoption and
implementation of OnePoint BFG’s Code of Ethics and other policies and procedures. See Item
11 for additional information.
The terms and conditions for client participation in advisory programs or relative to any OnePoint
BFG services are set forth in OnePoint BFG's written agreements and the account paperwork for
the specific advisory programs or services. The written agreement, between OnePoint BFG and
the client, will continue in effect until terminated by either party by written notice in accordance
with the terms and conditions of the written agreement. Following the receipt of a notice of
termination, OnePoint BFG will refund the portion of the advanced investment advisory fee paid
based upon the number of days remaining in the billing period.
All prospective clients should read this Brochure, all relevant brochure supplements, and any
documentation for the specific advisory programs or services, and ask any corresponding
questions, prior to participation in any advisory program or service provided by or through
OnePoint BFG. Clients may inquire at any time with the OnePoint BFG Advisor as to client-
specific fees and costs.
A. OVERVIEW OF FEES AND CHARGES
Under either a wrap or non-wrap account, OnePoint BFG will charge an annual investment
advisory fee. Custodial account and other service fees are paid by the client in either a wrap fee
account or non-wrap fee account. The difference between a wrap fee account and a non-wrap fee
account is whether OnePoint BFG or the client pay for the custodial asset-based charge or the
custodial transaction-based charges.
Additional information about OnePoint BFG’s investment advisory fee, wrap and non-wrap
accounts, custodial asset-based charge, custodial transaction-based charges, and custodial
account and service charges is provided below.
Clients may inquire at any time with the OnePoint BFG Advisor as to client-specific fees and
costs.
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B. ONEPOINT BFG’S INVESTMENT ADVISORY FEE
Under either a wrap or non-wrap account, OnePoint BFG will charge an annual investment
advisory fee based on a percentage of the assets to be managed, also known as an asset-based fee,
unless other services and/or fee structure have been negotiated by the client and the OnePoint BFG
Advisor. Agreeing to an asset-based fee may create a disincentive for OnePoint BFG or its
Advisors to perform additional work for a client because that work will not increase the
compensation to be paid or may lead OnePoint BFG or its Advisors to perform less work for clients
with fewer assets. OnePoint BFG’s Advisors at the Advisor’s discretion negotiate an annual
investment advisory fee up to a maximum of two percent (2.00%) of assets managed by the
Advisor.
Clients will typically be billed in one of the following billing methods utilized at OnePoint BFG:
• Fixed Percentage – OnePoint BFG applies a fixed percentage to client account(s) total
assets under management (“AUM”). For example:
Advisory Fee
2.00% (maximum)
*Advisory fee is negotiated
• Tiered Fee Schedule – OnePoint BFG applies its fee to the client account(s) based on
achieving certain asset tiers in two different ways. The primary way is similar to the tax
code where specific tax rates are applied to each level of gross income. Under this method,
OnePoint BFG will apply a different fee to each corresponding level of AUM and the total
fee is a blend based on the total AUM. Certain advisors may negotiate a linear tiered
approach where all of the AUM is charged the advisory fee for the asset level reached in
the tier. The tiered fee schedule will be identified in the Investment Advisory Agreement
and agreed to by the client. For example:
ASSET TIER
$500,000
$500,001 - $1,000,000
$1,00,001 - $5,000,000
$5,000,000
ADVISORY FEE*
2.00%
1.85%
1.70%
Negotiable
OnePoint BFG’s annual investment advisory fee is negotiated based upon various objective and
subjective factors, including, but not limited to, the amount of the assets placed under OnePoint
BFG’s direct management, the amount of the assets placed under OnePoint BFG’s advisement
(e.g., non-discretionary or held-away), the complexity of the engagement, and the level and
scope of the overall investment advisory services to be rendered by the OnePoint BFG Advisor.
Additionally, some OnePoint BFG Advisors may have client relationships that pre-date such
Advisor’s association with OnePoint BFG and, as a result, such clients' annual investment
advisory fee may not align with the schedule outlined above.
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OnePoint BFG’s investment advisory fees are billed quarterly in advance. The valuation of the
account, upon which OnePoint BFG’s investment advisory fee is calculated, is based on the
values as assessed by the custodian on the last business day of the calendar quarter (e.g.,
December 31, March 31, June 30, and September 30) and collected in the following month (e.g.,
January, April, July, and October). Note: At LPL, a OnePoint BFG Advisor may, at the
Advisor’s sole discretion, choose a different billing cycle (e.g., February, May, August,
November or March, June, September, December); however, OnePoint BFG’s investment
advisory fee will still be calculated using the last valuation date in the 3-month period and billed
in advance.
If negotiated by the client and the OnePoint BFG Advisor, OnePoint BFG will charge a fixed or
flat fee for its investment advisory or other services, charging a specific dollar amount for a
specific time period (e.g., quarterly). Agreeing to a fixed fee may create a conflict of interest
where OnePoint BFG or its Advisors have no incentive to perform additional work for the client
since they will earn no additional compensation for that work.
Generally, clients elect to have OnePoint BFG’s investment advisory fees deducted from the
client’s custodial account(s). Both OnePoint BFG’s written advisory agreement and the custodial
agreement(s) authorize the custodian(s) to debit the account(s) for the amount of OnePoint
BFG’s investment advisory fee and to directly remit that fee to OnePoint BFG. Where OnePoint
BFG bills the client directly, payment is typically due within seven days of the OnePoint BFG
invoice and payable directly to OnePoint BFG.
Held-Away Assets: As described in Item 4, OnePoint BFG may charge a fee on the client’s held-
away assets or separately provide the client with a written invoice. Based on a client’s instruction,
this fee could be deducted from another account that the OnePoint BFG Advisor manages for the
client (held at one of OnePoint BFG’s custodians) or paid directly by the client to OnePoint BFG.
The specific fee schedule is established in the OnePoint BFG written advisory agreement.
Additionally, if a client elects to engage OnePoint BFG’s discretionary, investment advisory
services for held-away assets, the cost of the third-party intermediary’s order management system
and OnePoint BFG’s associated administrative cost, both included in OnePoint BFG’s advisory fee,
are outlined in the client’s investment advisory agreement.
C. WRAP FEES
The corresponding terms and conditions pertaining to wrap fee account are discussed in
OnePoint BFG’s Wrap Fee Program Brochure, a copy of which is presented to all prospective
clients considering a wrap fee account.
Under a OnePoint BFG wrap fee account a client is charged a single or “wrap” fee that includes
OnePoint BFG’s investment advisory fee and either the custodial asset-based charge or the
custodial transaction-based charges, as applicable. When managing a client’s account on a wrap
fee basis, OnePoint BFG receives the balance of the wrap fee after deducting, as applicable, the
custodial asset-based charge or the custodial transaction-based charges. OnePoint BFG’s
Advisors at their discretion negotiate an annual wrap fee up to a maximum of two percent
(2.00%) of assets managed by OnePoint BFG.
Clients will typically be billed in one of the following billing methods utilized at OnePoint BFG:
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• Fixed Percentage – OnePoint BFG applies a fixed percentage to client account(s)
regardless of total assets under management (“AUM”). For example:
Advisory Fee
2.00% (maximum)
*Advisory fee is negotiated
• Tiered Fee Schedule – OnePoint BFG applies its fee to the client account(s) based on
achieving certain asset tiers in two different ways. The primary way is similar to the tax
code where specific tax rates are applied to each level of gross income. Under this method,
OnePoint BFG will apply a different fee to each corresponding level of AUM and the total
fee is a blend based on the total AUM. Certain advisors may negotiate a linear tiered
approach where all of the AUM is charged the advisory fee for the asset level reached in
the tier. The tiered fee schedule will be identified in the Investment Advisory Agreement
and agreed to by the client. For example:
ASSET TIER
$500,000
$500,001 - $1,000,000
$1,00,001 - $5,000,000
$5,000,000
ADVISORY FEE*
2.00%
1.85%
1.70%
Negotiable
*Advisory fee is negotiated.
The negotiated wrap fee is disclosed in the Investment Advisor Agreement signed by Client.
Custodial account and other service fees are not covered by the annual wrap fee, including, but
not limited to, mutual fund fees and exchange traded fund charges imposed directly at the fund
level (e.g., management fees and other fund expenses), margin interest, account activity fees, and
any fee associated with maintaining a retirement account charged by the custodian of the
qualified account. Additionally, for wrap accounts held at LPL the client will incur a ticket charge
for foreign stocks transactions. Furthermore, OnePoint BFG’s proprietary investment strategy
fees, UMA fees, and third-party investment manager or sub-advisor fees are not included in the
annual wrap fee or OnePoint BFG’s annual investment advisory fee. See Other Fee Information
below.
D. NON-WRAP FEES
Under a non-wrap fee account, OnePoint BFG’s annual investment advisory fee (as outlined
above) is separate from, and in addition to, as applicable, either the custodial asset-based charge
or the custodial transaction-based charges. A non-wrap fee account will be charged other
custodial charges, such as ticket charges for foreign stocks and American Depositary Receipts
(“ADRs”).
Clients in a non-wrap fee account will pay custodial account and other service fees, including,
but not limited to, mutual fund fees and exchange traded fund charges imposed directly at the
fund level (e.g., management fees and other fund expenses), margin interest, account activity
fees, and any fee associated with maintaining a retirement account charged by the custodian of
the qualified account. Additionally, OnePoint BFG’s proprietary investment strategy fees and
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third-party investment manager or sub-advisor fees are not included in OnePoint BFG’s annual
investment advisory fee. See Other Fee Information below.
Note: LPL and Pershing only offer wrap fee accounts to clients of OnePoint BFG.
E. CUSTODIAL CHARGES
Client-specific custodial asset-based charges or, as applicable, custodial transaction-based charges
and custodial account and other service charges are detailed in the client’s custodial agreement(s)
or client’s custodial quarterly statements. A general description of such charges is provided
below. The investment strategy, investments and related transactions will impact whether a client
will pay more in custodial asset-based charge or the custodial transaction-based charges, as
applicable. Furthermore, the custodial charges will differ by custodian and may be higher or
lower depending on the investment, transaction, or custodial service. As a result, OnePoint
BFG’s clients will pay diverse custodial charges that may be higher or lower than those charged
by other investment advisers.
Clients may inquire at any time with the OnePoint BFG Advisor as to client-specific custodial
charges.
Custodial Asset-Based Charge
i.
LPL, Goldman Sachs and Schwab offer custodial asset-based pricing. The custodial asset-based
charge is paid to the custodian, based on the assets held within the account. The custodial asset-
based charge covers various transaction costs, such as mutual fund fees, brokerage commissions
and mark-ups/mark-downs for fixed income securities. The investment strategy, investments and
related transactions will impact whether a client will pay more in custodial asset-based charge or
a custodial transaction-based charge. LPL’s custodial asset-based charge is billed quarterly in
arrears and deducted from OnePoint BFG’s wrap fee; Schwab’s custodial asset-based charge is
billed monthly in arrears and either deducted from OnePoint BFG’s wrap fee or, as applicable,
deducted from the client’s non-wrap fee account.
Note: At Schwab, a OnePoint BFG Advisor may, at the Advisor’s sole discretion, choose either
custodial asset-based pricing or custodial transaction-based pricing (as discussed below). Clients
may inquire at any time with the OnePoint BFG Advisor as to client-specific custodial charges
and should discuss these differences with the OnePoint BFG Advisor.
Note: A client will be charged Asset Based Pricing at Pershing if using an SMA manager
through their SMA platform.
ii. Custodial Transaction-based Charges
Schwab, Pershing and Fidelity offer custodial transaction-based pricing. The custodial
transaction-based charges are billed by and paid to the custodian, on trade date, when a
transaction is executed through the custodian and is based on the specific security or
investment involved in the transaction. Custodial transaction-based charges are deducted from
OnePoint BFG’s wrap fee or, as applicable, deducted from the client’s non-wrap fee account.
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The custodial transaction-based charges cover various transaction costs, such as mutual fund
fees, brokerage commissions and mark-ups/mark-downs for fixed income securities.
iii. Custodial Account and Other Charges
Each of the custodians utilized by OnePoint BFG have miscellaneous account and other charges
that are borne solely by the client and are deducted from the client’s wrap fee account or, as
applicable non-wrap fee account. These custodial account and other service charges are billed by
and paid to the custodian, based upon the specific custodial account or service, including, but not
limited to, wire fees, transfer fees, margin interest, account activity fees, and any fee associated
with maintaining a retirement account charged by the custodian of the qualified account.
Custodians may waive custodian account and other service charges based on a level of assets
maintained in the account, and the asset level or other conditions for a fee waiver may be higher
or lower than those required by other custodians. Furthermore, a OnePoint BFG Advisor, at the
Advisor’s sole discretion, may pay any custodial account and other charge.
F. PROPRIETARY INVESTMENT STRATEGIES FEES
As is the case with allocations to third-party investment management strategies, OnePoint
BFG’s annual investment advisory fee (or wrap fee) is separate and apart from fees related to
any allocations to a OnePoint BFG proprietary investment strategy (as described in Item 4). The
investment management fees (asset-based) charged on Global Macro, Target Income, and
Benestar range from 0.015% to 0.075% (15bps to 75bps), depending on the strategy and as
established by OnePoint BFG (the firm). The OnePoint BFG UMA fee is a weighted average
sum (total) of the fees charged for each strategist model. OnePoint BFG’s written advisory
agreement, requiring the client’s affirmative consent prior to allocating client assets to any of
OnePoint BFG’s proprietary investment strategies, outlines the specific investment management
fees that the client will incur when participating in any OnePoint BFG proprietary investment
strategy.
As these are OnePoint BFG’s proprietary investment strategies, a client investment creates a
conflict of interest. The investment management fees charged on Global Macro, Target Income,
and Benestar are paid directly to OnePoint BFG, and a material share of that internal
management fee is paid to the respective OnePoint BFG portfolio managers for their security
selection and services relative to the proprietary investment strategies. Some of OnePoint
BFG’s portfolio managers also serve as OnePoint BFG Advisors. This conflict of interest
creates an incentive for a OnePoint BFG Advisor (also serving as a portfolio manager to a
OnePoint BFG proprietary strategy) to recommend and/or utilize one of these proprietary
investment strategies versus other similar, non-affiliated investment strategies. OnePoint BFG
discloses this conflict of interest to the client within OnePoint BFG’s written advisory
agreement, requiring the client’s affirmative consent prior to allocating the client’s assets to any
of OnePoint BFG’s proprietary investment strategies. The OnePoint BFG UMA Fee is paid to
the Manager, who (in turn) pays a portion to Orion, who then pays a portion to any third-party
Strategist Model provider. The Manager, Orion, and any Strategist Model provider participate
(share in) the Annual Fee. For the avoidance of doubt, Client shall not be separately charged by
Orion or a Strategist Model provider for managing assets within a UMA Sleeve under a
OnePoint BFG UMA. With OnePoint BFG’s proprietary investment strategies inside OnePoint
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BFG’s UMA, a conflict creates an incentive for OnePoint BFG and its Advisors to recommend
these strategies for OnePoint BFG to collect portions of the investment advisory fees,
investment management fees, and the UMA fee. See Items 8 and 10 for additional information.
G. RETIREMENT PLAN CONSULTING AND ADVISORY FEES
OnePoint BFG’s retirement plan consulting and/or advisory fees are typically based on a
percentage of the assets held in the plan (up to 1.50% annually) or on a flat rate basis as
negotiated between the plan (client) and the Advisor. Fees will be payable to OnePoint BFG,
typically in arrears, on the frequency (e.g., quarterly, monthly, etc.) agreed upon by the client
and the Advisor. If asset-based fees are negotiated, payment generally will be based on the value
of the plan assets as of the close of business on the last business day of the period as valued by
the custodian of the assets and billed by the plan’s custodian. Certain third-party service
providers may use daily average balance to calculate the fees. If the fee is paid by the plan or
the plan through a third-party service provider, such fee will generally be valued, calculated and
billed by the third-party service provider. The specific calculation structures is defined in the
third-party service provider’s agreement. Please ask your Advisor if you have any questions
regarding the calculations of fees.
Clients will incur fees and charges imposed by third-parties other than OnePoint BFG and its
Advisors in connection with investments recommended by OnePoint BFG. These third-party fees
can include fund or annuity subaccount management fees, 12b-1 fees and administrative servicing
fees, plan recordkeeping and other service provider fees, as applicable. If a plan makes available a
variable annuity as an investment option, there are mortality, expense and administrative charges,
fees for additional riders on the contract, and charges for excessive transfers within a calendar
year imposed by the variable annuity sponsor. If a plan makes available a pooled guaranteed
investment contract (“GIC”) fund, there are investment management and administrative fees
associated with the pooled GIC fund. Further information regarding charges and fees assessed by
a fund or annuity are available in the appropriate prospectus or contract and should be considered
by the plan before making the investment. See also Other Fee Information discussed below.
Clients should understand that the fee that a client negotiates with a OnePoint BFG Advisor may
be higher than the fees charged by other investment advisers, consultants or investment
managers for similar services. This is the case, in particular, if the fee is at or near the maximum
fees set forth herein. The Advisor is responsible for determining the fee to charge each client
based on factors such as total amount of assets involved in the relationship, the complexity of the
services, and the number and range of supplementary advisory, consultancy, and client-related
services to be provided by the Advisor. Clients (e.g., plan trustees) should consider the level and
complexity of the consulting and/or advisory services to be provided when negotiating the fee
with a OnePoint BFG Advisor.
Non-Discretionary Advice to Plan Participants: As described in Item 4, if a retirement plan is
paying OnePoint BFG to provide non-discretionary, individualized investment advice for the
plan’s participants, OnePoint BFG and its Advisors have a conflict of interest. This conflict of
interest creates an incentive for OnePoint BFG and its Advisors to potentially prioritize the plan
(that pays OnePoint BFG’s fee) over that of the plan participant. OnePoint BFG discloses this
conflict of interest to the plan participant within OnePoint BFG’s written agreement with the plan
participant.
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H. FINANCIAL PLANNING, INVESTMENT CONSULTING AND OTHER
CONSULTING SERVICES FEES
To the extent requested by a client and agreed upon by OnePoint BFG, OnePoint BFG will
provide financial planning, investment consulting or other consulting services for an additional
fee. OnePoint BFG’s financial planning and consulting fees are typically negotiable on a flat fee
basis, depending upon the level and scope of the services required and the professionals
rendering the services. OnePoint BFG will also charge an hourly or asset-based fee for financial
planning consulting services, as negotiated by the client and the OnePoint BFG Advisor.
Agreeing to an hourly fee can create a conflict of interest because OnePoint BFG or its Advisors
have an incentive to perform additional work for the client because it will earn additional
compensation for any additional work. OnePoint BFG has created and implemented a
compliance and supervisory program to address such conflicts through the oversight of client
accounts and client engagements.
For financial planning, investment consulting or other consulting services, OnePoint BFG may
bill the client directly. In this case, payment is due within seven days of the OnePoint BFG
invoice and payable directly to OnePoint BFG.
I. OTHER FEE INFORMATION
i. Dually Registered Persons’ Commissions
As referenced in Item 4, some OnePoint BFG Advisors are also broker-dealer registered
representatives of PKS (commonly referred to as a “dually registered person”). If so, a client’s
Advisor may offer the client investment advisory services through OnePoint BFG or brokerage
services through PKS (as a registered representative). Brokerage services and investment
advisory services are different, and the fees charged for those services are separate. In
particular, a OnePoint BFG Advisor will earn investment advisory fees on an account managed
under a written advisory agreement and, in the capacity as a registered representative with PKS,
earn transaction-based compensation or commissions on a separate and distinct client brokerage
account at PKS.
A dually registered person has a conflict of interest, as the dually registered person has an
incentive to recommend investment products or services based on the relationship (either as a
registered representative of PKS or as a OnePoint BFG Advisor) that creates the greatest
compensation for the dually registered person.
When OnePoint BFG’s Advisors sell a security or investment product through PKS, they do so
solely as a dually registered person of PKS. In such instances, OnePoint BFG does not charge an
asset-based fee in addition to the commissions paid to the dually registered person by the client
for such product. Clients of a dually registered person will have separate brokerage (through
PKS) and advisory (through OnePoint BFG) accounts, whereby the client will receive
notification of brokerage commissions charged by PKS and separate custodial statements
reflecting advisory fees for OnePoint BFG advisory accounts. Furthermore, clients are not under
any obligation to purchase or sell commission products from PKS and have the option of
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purchasing many of the securities and investment products that OnePoint BFG makes available
through another broker-dealer, custodian, investment adviser or another financial institution.
In the event the client chooses to purchase or sell securities or investment products through a
dually registered person, PKS will charge brokerage commissions to facilitate securities
transactions, a portion of which will be paid to the PKS registered representatives who facilitate
the transaction. The brokerage commissions charged by PKS may be higher or lower than those
charged by other broker-dealers. In addition, PKS may also receive additional ongoing mutual
fund 12b-1 fees directly from the mutual fund company during the period that the client
maintains the mutual fund investment in a brokerage relationship, and OnePoint BFG’s Advisors
who are dually registered persons may receive a portion of those additional ongoing 12b-1 fees
directly from the mutual fund company in their roles as registered representatives of PKS. Please
note that OnePoint BFG and PKS are not affiliated entities.
To determine whether a OnePoint BFG Advisor is a dually registered person, clients should
review the Advisor’s Form ADV Part 2B Brochure Supplement. If a client has not received a
copy of that document, the client should contact OnePoint BFG’s Chief Compliance Officer
using the information on the cover page of this Brochure. OnePoint BFG’s Chief Compliance
Officer is available to address any questions that a client or prospective client may have
regarding the above conflict of interest, or any information outlined in this Brochure.
ii. Custodian-sponsored programs, third-party investment managers, and
TAMPs fees
Custodian-sponsored programs, third-party investment managers and TAMPs may require a
minimum asset level or charge a minimum fee, and clients should be aware that the imposition
of minimum fees by another entity will result in a higher fee being charged than is described in
this Brochure, particularly where partial withdrawals by the client reduce asset levels. These
additional fees and charges will be set forth in the information provided by the Advisor,
including, but not limited to, the applicable custodian’s, third-party investment manager, and/or
TAMP’s Form ADV Part 2A brochure or the applicable agreement(s).
Clients typically authorize the deduction of third-party investment managers’ and/or TAMPs’
fees from the client’s custodial account(s). For more information about the fees of a third-party
investment manager or TAMP, clients should refer to the information provided by the Advisor,
including, but not limited to, the applicable program’s Form ADV Part 2A brochure and
applicable agreement(s).
iii. Mutual Funds and Exchange Traded Funds (ETFs) Costs
Mutual funds and/or ETFs pass along costs to investors by imposing fees and expenses, such as
shareholder fees, operating expenses and/or transaction costs. These costs reduce the returns on
mutual funds and ETFs. Therefore, clients should fully understand the costs incurred through
these investments, as more fully described in the mutual fund or ETF prospectus that is available
upon request from the OnePoint BFG Advisor, and fully discuss these costs with the OnePoint
BFG Advisor.
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For example, a client invested in a mutual fund or ETF will pay at least two layers of fees. The
client will pay the mutual fund or ETF underlying investment management fees and will also pay
OnePoint BFG’s annual investment advisory fee (or wrap fee). Clients may invest in many of the
ETFs and mutual funds that OnePoint BFG makes available through another broker-dealer,
custodian, investment adviser or another financial institution and, as a result the client’s fees may
be higher or lower than those charged by a OnePoint BFG Advisor.
Some mutual funds charge 12b-1 fees to cover the costs of marketing and selling fund shares.
Some custodians may receive ongoing mutual fund 12b-1 fees directly from the mutual fund
company during the period that the client maintains the mutual fund investment in a brokerage
relationship, and OnePoint BFG’s Advisors who are dually registered persons may receive a
portion of those additional ongoing 12b-1 fees directly from the mutual fund company solely in
their roles as registered representatives (as more fully described in this Brochure and the
Advisor’s Brochure Supplement).
If a client transfers a previously purchased mutual fund, and there is an applicable contingent
deferred sales charge on the fund, the client will pay that charge when the mutual fund is sold. If
the account is invested in a mutual fund that charges a fee if a redemption is made within a
specific time period after the investment, the client will be charged a redemption fee. If a mutual
fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the
fund (e.g., for rebalancing, liquidations, deposits or tax harvesting).
Furthermore, mutual funds and ETFs have different share classes with different fee structures
and costs. Some share classes of a fund charge higher internal expenses, whereas other share
classes of a fund charge lower internal expenses. Institutional and advisory share classes
typically have lower expense ratios and are less costly for a client to hold than Class A shares or
other share classes that are eligible for purchase in an advisory account. In some instances, a
mutual fund offers only Class A Shares, but another similar mutual fund may be available that
offers institutional shares. Clients should understand that another investment adviser may offer
the same mutual fund or ETF at a lower overall cost than is available through OnePoint BFG as
provided by the custodian(s) utilized by OnePoint BFG.
Some share classes incur a ticket charge (commonly described as TF shares). Other share classes
incur no ticket charges (commonly described as NTF shares), but usually have higher underlying
costs, and the associated costs would ultimately be incurred by the client. As previously
discussed, costs impact the return on the investment. In addition, where OnePoint BFG or its
Advisors incur these costs (e.g., through the wrap fee), there is a conflict of interest that can
influence the Advisor when deciding which investments to select and how frequently to place
transactions in the account. To mitigate this conflict, OnePoint BFG has a policy that Advisors
recommend the lowest cost share class reasonably available at the time through the client’s
custodian. Furthermore, OnePoint BFG conducts surveillance to test this policy and maintains a
process to reasonably conduct conversions to the lower cost share class, where applicable and
possible depending on the specific facts and circumstances, applicable to the client.
For additional information about mutual fund and ETF related risks, including share class risk,
see Item 8.
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iv. Variable Annuities and Other Pooled Investment Funds Costs
If a client holds a variable annuity that is managed as part of advisory account, there are
mortality, expense and administrative charges, fees for additional riders on the contract and
charges for excessive transfers within a calendar year imposed by the variable annuity sponsor.
If a client holds a Unit Investment Trust (“UIT”) in a program account, UIT sponsors charge
creation and development fees or similar fees.
Clients should understand the costs incurred through these investments, as more fully described
in the prospectus that is available upon request from the OnePoint BFG Advisor, and discuss
these costs and investment features with the OnePoint BFG Advisor.
Fee and Cost Differentials
v.
As indicated above, OnePoint BFG prices its services based upon various objective and subjective
factors. As a result, OnePoint BFG’s clients will pay diverse investment advisory fees based,
among other things, upon the complexity of the engagement and the level and scope of the overall
investment advisory and/or consulting services to be rendered by the OnePoint BFG Advisor.
Additionally, clients will pay diverse custodial asset-based charge or custodial transaction-based
charges, custodial account and service charges, and other investment-specific costs. For example,
as previously described, OnePoint BFG participates in several custodian-sponsored programs and
services, third-party investment manager programs and TAMPs which charge varying levels of
program fees and additional costs. As a result of these factors, the services to be provided by
OnePoint BFG and investments recommended to any particular client could be available from
other advisors at lower fees or costs. All clients and prospective clients should be guided
accordingly.
Clients may inquire at any time with the OnePoint BFG Advisor as to client-specific fees and
costs.
vi. Calculation of Advisory Fees include Cash Assets
OnePoint BFG calculates asset-based fees on assets placed under its management, including
cash, cash equivalents and/or money market funds. Depending on the client’s investment
objective and/or strategy, these cash balances could be relatively high and represent a material
portion of the overall account. Clients should understand that the asset-based fees charged on
these balances may exceed the returns provided by cash, cash equivalents or money market
funds, especially in low-interest rate environments. Clients should discuss the use of cash, cash
equivalents and/or money market funds with the Advisor.
vii. Trade Errors
OnePoint BFG reimburses client accounts for losses resulting from OnePoint BFG’s trade errors
but does not credit client accounts for trade errors resulting in market gains. OnePoint BFG’s
trade errors are processed and reconciled through a separate error account held with each
custodian. OnePoint BFG pays the custodian for any net losses. Either Custodian or OnePoint
BFG will forward any net gains from a trade error to a charity of their choice.
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viii. Securities-based Loans and Margin Loans
OnePoint BFG is not affiliated with any lender or custodian and does not receive compensation in
connection with any securities-based or margin loans. OnePoint BFG does not earn compensation
on securities-based loans or margin loans. When a client does not withdrawal assets, which would
diminish the assets held in the account, OnePoint BFG and its Advisors benefit from the potential
fees that could be earned by holding those assets within the client’s account. OnePoint BFG
further mitigates this conflict by taking the client’s net account value (gross less any margin or
financed amount), instead of gross, for purposes of calculating OnePoint BFG’s investment
advisory fee.
ix. Nontradable Assets in Advisory Accounts
In order to address a client’s specific situation, OnePoint BFG Advisors may recommend non-
tradable assets (e.g., annuities or structured products) be purchased in an advisory account. The
client would not be charged commissions for such investment products, but these products would
be subject to the advisory fees calculated based on assets held in the advisor account(s).
Pontera Accounts
x.
Please note, it is impossible to directly debit the fees from managed held-away accounts such as
401(k)s. As a result, those fees will be assigned to the client's taxable accounts on a pro-rata
basis. If the client does not have a taxable account, those fees will be billed directly to the client.
Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based
on the amount of time remaining in the billing period. An account may be terminated with
written notice at least 15 calendar days in advance. Since fees are paid in arrears, no rebate will
be needed upon termination of the account.
xi. American Funds 529s
The maximum advisory fee for 529 accounts held at American Funds Service Company (“AFS”)
is 50bps. 529 accounts that have authorized OnePoint BFG to bill the advisory fee from a
related account will follow the standard billing structure referenced above. Certain 529s have
authorized AFS to bill the 529 account directly. These fees will be billed quarterly in arrears.
The fees will be calculated by AFS for each quarter period ending the last business day of
February, May, August, and November and shall be the product of (i) the rate selected by
OnePoint BFG, (ii) the average daily net asset value of the Client’s assets invested in the Funds
through the Program during the quarter; divided by, (iii) the number of days in the year
multiplied by the number of days in the quarter.
AFS will deduct fees from Client accounts to pay OnePoint BFG.
If the Client’s assets in a fund account in the program are fully redeemed prior to the quarter
end, then the Client’s average daily net asset value of the fund account will be equal to the
Client’s average daily net asset value through the day prior to the total redemption.
Item 6. Performance-Based Fees and Side-by-Side management
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OnePoint BFG does not charge its clients performance-based fees. Performance-based fees are
based on a share of capital gains on or capital appreciation of the assets.
Item 7. Types of Clients
OnePoint BFG’s clients generally include:
•
Individuals (both high-net-worth (i.e., clients with a net worth of $2.2 million) and other
than high-net-worth)
• Pension and profits sharing plans and other qualified plans
• Trusts, estates, or charitable organizations
• Corporations and other business entities
OnePoint BFG does not require an annual minimum fee or minimum asset level for investment
advisory services. Certain investment programs or investment products require annual minimum
fees or minimum asset levels for participation. Clients should thoroughly review disclosure
materials or relevant Form ADV Part 2A brochures and consult with their Advisor about the
implications of such minimum requirements before investing in such programs or products.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
OnePoint BFG’s Advisors use a variety of methods of analysis, such as:
• Economic analysis. Economic analysis generally involves studying various factors in an
economy, including macro-economic factors (such as interest rates, inflation, and growth)
and micro-economic factors (such as market share, supply, and consumer demands)
specific to a particular industry, sector, or company.
• Fundamental analysis. Fundamental analysis generally involves assessing a company’s or
security’s value based on factors such as sales, assets, markets, management, products
and services, earnings and financial structure. Fundamental analysis does not attempt to
anticipate market movements. This presents a potential risk, as the price of a security can
move up or down along with the overall market regardless of the economic and financial
factors considered in evaluating the security.
• Technical market analysis and technical trend following. Technical analysis generally
involves studying trends and movements in a security’s price, trading volume, and other
market-related factors in an attempt to discern patterns. Technical analysis does not
consider the underlying financial condition of an issuer. This presents the risk that a
poorly managed or financially unsound issuer underperform regardless of market
conditions.
The Advisors’ investment strategies are based on the client’s specific situation, including
designated investment objectives and risk tolerances.
Investment activities involve a significant degree of risk. The performance of any investment is
subject to numerous factors which are neither within the control of, nor predictable by OnePoint
BFG. Such factors include a wide range of economic, political, competitive, technological and
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other conditions (including acts of terrorism and war or regional/global pandemic) that affect
investments in general or in specific industries or companies. The investment decisions made,
and the actions taken in managing client assets will be subject to various market, liquidity,
currency, economic, political and other risks. Investing in securities involves a risk of loss that
clients should be prepared to bear. The investment performance and the success of any
investment strategy or particular investment can never be predicted or guaranteed, and the value
of a client’s investments will fluctuate due to market conditions and other factors. Investments
may lose value and past performance is never a guarantee of future results.
The information contained in this Brochure cannot disclose every potential risk associated with
an investment strategy, nor all of the risks applicable to a particular manager, security or
investment. Risks vary by client according to their investment objectives, guidelines, liquidity
needs or risk tolerances and not every strategy or portfolio will be exposed to each of the risks
described in this Brochure. This list is not intended to be exhaustive of all of the risks associated
with investing in strategies or securities that are utilized or recommended by OnePoint BFG.
Rather, it is a general description of the nature and risks of the investment advisory services
provided by OnePoint BFG and the related investments.
This summary is qualified in its entirety by reference to the prospectuses and offering documents
that apply to the funds and/or strategies that OnePoint BFG recommends and/or in which a client
invests. Clients should carefully read any applicable prospectuses and/or offering documents.
A. GENERAL RISKS
Risks of Investing in Securities: Securities markets are volatile and investing in securities
involves the risk of loss that clients should be prepared to bear. OnePoint BFG cannot
guarantee that the strategies offered will be able to achieve a particular level of return or
maintain a particular risk profile.
Market Risk: The direction of the capital markets (e.g., stock, credit, interest rate, real estate,
private equity, volatility, etc.) are difficult to predict and are dependent upon changes in a
number of factors, including, but not limited to, interest rates, inflation, and a host of additional
economic and political factors. There is always a risk that the capital markets as a whole will
decline, bringing down the value of individual securities regardless of their fundamental
characteristics. Market risk is also known as systematic risk or undiversifiable risk. This risk is
both unpredictable and impossible to completely eliminate.
Investment Adviser Selection Risk: The investment performance of a client’s investment
program will vary with the success or failure of the investment adviser that OnePoint BFG or a
client selects to manage their assets. An investment adviser’s past performance is never
indicative of future results. Current and prospective clients should not assume that the future
performance of any specific investment adviser, investment strategy, recommendation or
investment will be profitable.
Asset Allocation Risk: A portfolio that holds large cash positions may deviate from the stated
benchmark and could underperform as a result. Differences in the security holdings and
weights of a portfolio versus the strategy benchmark will result in disparities between a
portfolio’s performance relative to its benchmark.
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A portfolio may perform better or worse than a similarly managed account for various reasons
including, but not limited to, the frequency and timing of rebalancing and trading each portfolio
and the size and number of positions in each portfolio.
Portfolio Concentration Risk: Strategies that are concentrated in only a few securities, sectors
or industries, regions or countries or asset classes could expose a portfolio to greater risk and
may cause the portfolio value to fluctuate more widely than a portfolio that is diversified.
Overexposure to certain sectors or asset classes (e.g., MLPs, REITs, etc.) may prove to be
detrimental to an investor if there is a negative sector move.
Company Specific Risk: The risk related to a firm’s business plans, stock valuation, profitability,
accounting practices, growth strategy, and other factors particular to a company rather than to the
overall market. Some of these risks cannot be predicted, such as the retirement or death of a
senior executive, which may lead to negative performance in the future.
Stock, Security, ETF or Fund Selection Risk: The risk that OnePoint BFG or a client chooses a
security that underperforms the market for unanticipated reasons. There can be no assurance that
clients will ever come to realize the value of some of these investments, and that the investment
will ever increase in value. During this time, the client may have funds locked up in an
underperforming investment, which presents an opportunity cost for other investments.
Timing Risk: The risk that an investment performs poorly after its purchase or better after its
sale. Moreover, if a redemption is required by the client, the client may face a loss due to poor
overall market performance or security performance at that time.
Data Risk: OnePoint BFG’s securities analysis relies on data that is provided by third-party
vendors and publicly available sources of information. Information that is incomplete,
inaccurate or outdated would affect the efficacy of that analysis.
Counterparty Risk: A portfolio is subject to risk with respect to the counterparties. Risks
affecting counterparties such as brokers, custodians, clearing banks or agents, escrow agents or
issuers, foreign exchanges or securities lending programs could result in failure by the
counterparty to honor its obligations. A portfolio may experience significant delays in obtaining
any recovery (including recovery of posted collateral) during insolvency, bankruptcy or other
reorganization proceedings and might realize only a limited recovery or no recovery at all. If the
credit rating of a counterparty is lowered, a portfolio would be exposed to any increased credit
risk associated with that counterparty.
Credit Risk: The credit rating of an issuer of a security is based on, among other things, the
issuer’s historical financial condition and the rating agencies’ investment analyses at the time of
rating. An actual or perceived deterioration of the ability of an issuer to meet its obligations
would have an adverse effect on the value of the issuer’s securities.
Liquidity Risk: Low trading volume, large positions or legal restrictions are some conditions
which could limit or prevent a portfolio manager from selling particular securities or closing
positions at desirable prices. Securities that are relatively liquid when acquired could become
illiquid over time. The sale of any such illiquid investment might be possible only at substantial
discounts or might not be possible at all. Further, such investments may be difficult to value.
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Global and National Crisis Risk: Ongoing or future global or national crises including, but not
limited to, pandemic, cyberattack, sabotage, terrorism, and acts of war could result in disruptions to
the economies of many nations, individual companies, and can negatively impact global markets
in an unforeseeable manner. Such disruptions include, but are not limited to, travel restrictions;
quarantines; supply chain disruptions; and workforce inefficiencies, absenteeism, distraction or
general anxiety. Such unpredictable, but no longer unprecedented, crises may exacerbate other
pre-existing political, social, and economic risks in certain countries. The impact of such crises
may be quick, severe and of unknowable duration. Ongoing or future crises could result in the
temporary or permanent disruption of OnePoint BFG’s ability to provide investment advice and
volatility in the financial markets and could have a negative impact on investment performance.
Artificial Intelligence Risk: OnePoint BFG uses artificial intelligence (“AI”) in our business
operations to promote operational efficiency and augment our client service. Currently we do not
utilize AI in our investment selection process or to formulate the specific investment advice we
render to you. AI models are highly complex and may result in output that is incomplete or
incorrect. Our use of AI includes certain third-party technologies aimed at pushing operational
efficiency by, but not limited to, automating meeting notes, assist with client communications,
identifying compliance risks, and summarizing and collecting data from internal documents. We
believe the use of this technology allows us to reduce administrative time, prepare for client
engagement, and improve the overall client experience. All AI generated outputs go through
human review at OnePoint BFG prior to dissemination or use. The use of AI poses risks related
to the challenges OnePoint BFG faces in properly managing its use. Content generated by AI
technologies may be deficient, inaccurate, or biased, and the use of AI tools may lead to errors in
decision-making. Use of AI tools could also pose risks related to the protection of clients or
proprietary information. Such risks may include the exposure of confidential information to
unauthorized recipients, violation of data privacy rights, or other data leakage events. The use of
AI may also expose us to litigation risk or regulatory risk. Due to the rapid advancement of
machine learning technologies, future risks related to artificial intelligence are unpredictable.
The regulatory environment relating to AI is rapidly evolving and could require changes in our
adoption and implementation of AI technology in the future. One way we reduce these risks
through the human review and editing prior to final use of an AI produced or enhanced
document.
B. INVESTMENT RISKS
Equity Securities: Equity instruments are subject to equity market risk, which is the risk that
common stock prices will fluctuate over short or even extended periods. Equity securities
generally have greater price volatility than fixed income securities. The market price of equity
securities may increase or decrease, sometimes rapidly or unpredictably. Equity securities may
decline in value due to factors affecting markets generally, particular industries, sectors or
geographic regions represented in those markets, or individual security concerns.
Debt or Fixed Income Securities: Debt securities are affected by changes in interest rates. When
interest rates rise, the value of debt securities are likely to decrease. Conversely, when interest
rates fall, the values of debt securities are like to increase. The values of debt securities may also
be affected by changes in the credit rating or financial condition of the issuing entities.
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Master Limited Partnerships (“MLPs”): MLPs are limited partnerships that trade on securities
exchanges similar to stocks. Issuers of MLPs are not subject to income tax, and shareholders in
MLPs are actually "limited partners" in that company. The issuers’ special tax designation
allows MLPs to pass the tax burden on to their shareholders which will result in higher tax
obligations for taxable clients.
Risks Associated with Exchange Traded Funds (“ETFs”) and Exchange Traded Notes
(“ETNs”): ETFs and ETNs are, by definition, portfolios of securities, and although the risk
associated with investments in ETFs and ETNs may be low relative to investments in securities
of individual issuers, there are events that can trigger sharp, and sometimes adverse, price
movements in ETFs and ETNs that are not related to movements of the markets in general.
These events include, but are not limited to, unanticipated dividends, changes to regular dividend
amounts, announcements of rights offerings and possible unexpected revisions to the net asset
values of the ETF and ETN. ETFs are subject to market risk, whereas ETNs are subject to both
market risk and the credit risk of the issuer of the ETN.
Further, certain client accounts may hold (or short sell) positions in certain volatility-related ETFs
and ETNs, and certain of those securities may be leveraged or have prices which are inversely
related to an underlying index or benchmark. These instruments pose unique risks which include,
amongst other things, market risk, compounding risk (e.g., the effect of daily compounding of
returns may result in returns over periods of longer than a single day which will likely differ in
amount and possibly even direction from the underlying benchmark), potential “acceleration” or
“termination” events associated with rapidly declining Net Asset Value (“NAV”), and extreme
price volatility. Acceleration or termination could result in a substantial or total loss of
investment. See Borrowing and Leverage Risk.
Mutual Funds Risk: The risks with mutual funds include the costs and expenses within the fund
that can impact performance, change of managers, and the fund straying from its objective (i.e.,
style drift). Mutual funds have certain costs associated with underlying transactions, as well as
operating costs such as marketing and distribution expenses and underlying advisory fees.
Mutual fund costs and expense vary from fund to fund and will impact a mutual fund’s
performance. Additionally, mutual funds typically have different share classes, as further
discussed below, that trade at different Net Asset Value (“NAV”) as determined at the daily
market close and have different fees and expenses.
Mutual Fund Share Classes: Mutual funds that offer different share classes are priced differently
and have varying levels of internal costs. For example, institutional share classes often have
higher trading costs; however, the internal costs of the fund are lower. Over a period of time,
certain share classes will become more expensive if held in an account for a long period of time.
Additionally, even though multiple share classes may be available, a custodian may only make
available a limited number of share classes, or a custodian may not choose to offer the least
expensive share class that is available. Other custodians and investment advisers may offer the
same mutual fund or a different mutual fund share class at a lower overall cost to the investor.
If a client is invested through a LPL Strategic Wealth Management (SWM) or SWM II account,
LPL makes available mutual funds that offer various classes of shares, including shares
designated as Class A Shares and shares designed for advisory programs, which can be titled,
for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative” or
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“platform” share classes (“Platform Shares”). The Platform Share class offered for a particular
mutual fund in SWM II in many cases will not be the least expensive share class that the mutual
fund makes available and was selected by LPL in certain cases because the share class pays
LPL compensation for the administrative and recordkeeping services LPL provides to the
mutual fund. Clients should understand that another financial services firm may offer the same
mutual fund at a lower overall cost to the investor than is available through SWM II. In other
instances, a mutual fund may offer only Class A Shares, but another similar mutual fund may be
available that offers Platform Shares. Class A Shares typically pay LPL a 12b-1 fee for
providing shareholder services, distribution, and marketing expenses (“brokerage-related
services”) to the mutual funds. Platform Shares generally are not subject to 12b-1 fees. As a
result of the different expenses of the mutual fund share classes, it is generally more expensive
for a client to own Class A Shares than Platform Shares. An investor in Platform Shares will
pay lower fees over time and keep more of his or her investment returns than an investor who
holds Class A Shares of the same fund.
Borrowing and Leverage Risk: If permitted by a client’s investment guidelines and by mutual
agreement with the client, a portfolio may include the purchase of securities on margin, engage
in short sales, borrow money or use derivatives, each of which will cause the portfolio to be
leveraged. Leverage exaggerates the effect on a portfolio’s value for any increase or decrease in
the market value of the portfolio’s investment value. Leveraging will also create interest expenses
for a portfolio which can exceed the investment return from the borrowed funds.
Short Sales: A client portfolio strategy may include short selling. OnePoint BFG makes no
assurance that a strategy utilizing short sales will be profitable. A short sale is affected by selling
a security which the seller does not own or selling a security which the seller owns but which it
does not deliver upon consummation of the sale. In order to make delivery to the buyer of a
security sold short, the prime broker or custodian on behalf of the seller must borrow the
security. In so doing, it incurs the obligation to replace that security, whatever its price may be,
at the time it is required to deliver it to the lender. The seller must also pay to the lender of the
security any dividends or interest payable on the security during the borrowing period and may
have to pay a premium to borrow the security. This obligation must, unless the seller then owns
or has the right to obtain, without payment, securities identical to those sold short, be
collateralized by a deposit of cash and/or marketable securities with the lender. Short selling is
subject to theoretically unlimited risk of loss because there is no limit on how much the price of
a security may appreciate before the “short” position is closed out.
Further, short sales of securities involve a form of investment leverage, and the amount of the
portfolio’s potential loss is theoretically unlimited. See Borrowing and Leverage Risk.
Options Trading: Certain OnePoint BFG advised portfolio strategies may include options
trading. The taker (the buyer) of an option pays a premium which entitles the taker to purchase
(in the case of a call) or sell (in the case of a put), from or to the grantor (the seller), a specified
number of securities at a specified price, during the specified period. Options are speculative in
that the whole cost of a purchased option is lost unless the price of the underlying security has
moved in the anticipated direction and the option is exercised or closed (but not allowed to
expire); however, liability is limited to the premium paid for the option. An option writer (or
seller) becomes obligated to purchase or sell the options contract or the underlying securities at a
specified price during a specified period. In exchange for the premium received upon writing an
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option, the Client bears the risk of loss from adverse price movements in the underlying
contracts or the underlying security so long as the position remains open. In the case of a sold
option, the seller could have unlimited risk exposure or the potential for a significant loss.
Options are complicated and risky investments and require an evaluation of whether the price of
a security is going up or down and also a prediction as to the amount and timing of that
movement. This requires a sophisticated understanding of the underlying security, as well as the
particular options strategy being used to speculate or hedge a security.
Before engaging in options trading or SpiderRock, a money manager utilized by OnePoint BFG,
a client must acknowledge that they have carefully read and understand the custodian’s
agreement. Once approved for options trading, the custodian will deliver the booklet entitled
“Characteristics and Risks of Standardized Options”
(http://www.optionsclearing.com/components/docs/riskstoc.pdf) to the client. OnePoint BFG
recommends clients also consult with their applicable legal, tax and financial advisors when in
engaging in options strategies.
Preferred Equity: Holders of preferred equity are positioned between the bondholders and
common stockholders within the liquidation of the capital structure. Preferred equity is
subordinate to various other levels of debt, so if a company declares bankruptcy, the holders of
preferred equity will not receive payment until all of the company’s secured creditors and
bondholders have received payment. Also, like debt securities, the values of preferred equities
are closely tied to interest rates. Typically, the longer the maturity, the more the preferred equity
is affected by changes in interest rates.
Foreign Markets: Investments in foreign companies and overseas markets may involve unique
risks, including, but not limited to, risks relating to changes in currency exchange rates, political,
economic and social events, different market operations and less information. Additional
information about the risks related to investing in foreign, emerging and frontier markets is
available upon request.
Alternative Investments: Alternative investments include other additional risks. Lock-up
periods and other terms obligate clients to commit their capital investment for a minimum period
of time, typically no less than one or two years and sometimes up to 10 or more years. Illiquidity
is considered to be a substantial risk and will restrict the ability of a client to liquidate an
investment early regardless of the success of the investment. Alternative investments are difficult
to value within a client’s total portfolio. There may be limited availability of suitable
benchmarks for comparison of performance; historical performance data may also be limited. In
some cases, there may be a lack of transparency and regulation providing an additional layer of
risk. Some alternative investments may involve use of leverage and other speculative techniques.
As a result, some alternative investments may carry substantial additional risks, which may
result in the loss of some or all of the investment. For tax-exempt investors, the use of leverage
and certain other strategies will result in adverse tax consequences, such as the possibility of
unrelated business taxable income, as defined under the U.S. Internal Revenue Code. Clients are
encouraged to seek professional tax advice. OnePoint BFG does not provide nor claim to provide
tax advice.
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OnePoint BFG’s Proprietary Investment Strategies: OnePoint BFG’s proprietary investment
strategies are developed by OnePoint BFG and managed by OnePoint BFG’s portfolio managers.
The portfolio managers have the sole authority to control the management of each strategy and
are key to the implementation, oversight and ongoing management of OnePoint BFG’s
proprietary investment strategies. As a result, the loss of a strategy’s portfolio manager would
have a material adverse effect on the strategy, including, but not limited to, the cessation of the
strategy. Additionally, because each strategy’s performance is based on a composite aggregation
of related portfolios managed by OnePoint BFG, the securities in the portfolio are directly owned
by the separate account’s owner(s) and the separate account’s owner(s) have the right to terminate
the investment advisory agreement with OnePoint BFG at any time. Investors in each strategy
will have slightly different weightings in holdings, asset classes and performance results,
primarily due to the timing of an investment (cash) into and out of the respective strategy.
Separate accounts are unregistered investment vehicles and do not have the legal or regulatory
requirements as registered securities.
C. PROCEDURAL AND OPERATIONAL RISKS
Operational Risk: Portfolios are exposed to operational risk introduced through human
intervention or the failure of automated processes. Operational risks include, but are not limited
to, reconciliation errors, trading the wrong security, trading a security for an unintended portfolio
or purchasing a security that a portfolio was intended to sell, or vice versa.
System Failures and Reliance on Technology Risks: OnePoint BFG relies on technology,
including hardware, software, telecommunications, internet-based platforms, and other electronic
systems. Additionally, some of the technology used is provided by third-party service providers
and is, therefore, beyond OnePoint BFG’s direct control. OnePoint BFG seeks to ensure
adequate backups of hardware, software, telecommunications, internet-based platforms, and
other electronic systems, through its vendor due diligence procedures, but there is no guarantee
that any or all third-party service provider risks will be mitigated. In addition, natural disasters,
power interruptions and other events may cause system failures, which will require the use of
backup systems. Backup systems may not operate as well as the primary systems and may fail to
properly operate, especially when used for an extended period. To reduce the impact a system
failure may have, OnePoint BFG continually evaluates its backup and disaster recovery systems
and performs periodic testing of its backup systems operations. Despite OnePoint BFG continued
monitoring of hardware, telecommunications, or other electronic systems malfunctions may be
unavoidable and result in consequences such as the inability to execute client transactions or
monitor client accounts.
Cybersecurity Risk: A portfolio is susceptible to operational and informational security risks due
to the increased use of the internet. In general, cyber incidents can result from deliberate attacks
or unintentional events. Cyberattacks include, but are not limited to, infection by computer
viruses or other malicious software code, gaining unauthorized access to systems, networks, or
devices through “hacking” or other means for the purpose of misappropriating assets or sensitive
information, corrupting data, or causing operational disruption. Cybersecurity failures or
breaches of third-party service providers may cause disruptions at third-party service providers
and impact OnePoint BFG’s business operations, potentially resulting in financial losses; the
inability to transact business; violations of applicable privacy and other laws, regulatory fines, or
penalties; reputational damage; unanticipated expenses or other compensation costs; and/or
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additional compliance costs. OnePoint BFG has an established business continuity and disaster
recovery plan and related cybersecurity procedures designed to prevent or reduce the impact of
such risks; there are inherent limitations in such plans and systems due in part to the evolving
nature of technology and cyberattack tactics.
Item 9. Disciplinary Information
Registered investment advisers are required to provide information about any disciplinary
information that would be material to a client’s evaluation of OnePoint BFG or the integrity of its
management. For more information, the client should refer to the Advisor’s Form ADV Part 2B
Brochure Supplement. If the client did not receive the Advisor’s Form ADV Part 2B Brochure
Supplement, the client should contact OnePoint BFG’s Chief Compliance Officer using the
information on the cover page of this Brochure. OnePoint BFG’s Chief Compliance Officer is
available to address any questions that a client or prospective client may have regarding the
above or any information outlined in this Brochure.
OnePoint BFG does not have any legal or disciplinary information to disclose.
Item 10. Other Financial Industry Activities and Affiliations
Clients should review the Advisor’s Form ADV Part 2B Brochure Supplement to determine
whether the client’s Advisor is engaged in any of the activities described below that may create a
conflict of interest. If the client did not receive the Advisor’s Form ADV Part 2B Brochure
Supplement, the client may contact OnePoint BFG’s Chief Compliance Officer using the
information on the cover page of this Brochure. OnePoint BFG’s Chief Compliance Officer is
available to address any questions that a client or prospective client may have regarding the
above conflicts of interest, or any information outlined in this Brochure.
Dually Registered Persons. Certain of OnePoint BFG’s Advisors are also registered with
Purshe Kaplan Sterling Investments (“PKS”) as broker-dealer registered representatives
(“dually registered persons”). PKS is independently owned and operated and is not affiliated
with OnePoint BFG. Clients may choose to engage OnePoint BFG’s Advisors in their
individual capacities as registered representatives of PKS and to implement investment
recommendations on a commission basis. Please refer to Item 12 for a discussion of the
benefits that dually registered persons receive from PKS, and the conflicts of interest
associated with the receipt of such benefits.
OnePoint BFG’s Proprietary Investment Strategies. OnePoint BFG’s proprietary investment
strategies are developed by One Point BFG and managed by OnePoint BFG’s portfolio
managers, which creates conflicts of interest. Specifically, the more assets held within OnePoint
BFG’s proprietary investment strategies, the more money OnePoint BFG (as a firm) makes.
While the investment management fees charged on Global Macro, Target Income, and Benestar
are paid directly to OnePoint BFG, a material share of that internal management fee is paid to the
respective OnePoint BFG portfolio managers for security selection and services relative to the
proprietary investment strategies. Certain OnePoint BFG portfolio managers also serve as
OnePoint BFG Advisors. This conflict of interest creates a further incentive for a OnePoint BFG
Advisor (also serving as a portfolio manager to a OnePoint BFG proprietary strategy) to
recommend and/or utilize one of these proprietary investment strategies versus other similar,
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non-affiliated investment strategies. OnePoint BFG discloses this conflict of interest to the client
within OnePoint BFG’s written advisory agreement, requiring the client’s affirmative consent
prior to allocating the client’s assets to any of OnePoint BFG’s proprietary investment strategies.
See Item 8 for additional information on investment risks.
Licensed Insurance Agents. Certain of OnePoint BFG’s supervised persons, in their individual
capacities, are licensed insurance agents, and recommend the purchase of certain insurance-
related products on a commission basis. As referenced in Item 4 above, clients can engage certain
of OnePoint BFG’s Advisors to purchase or sell insurance products on a commission basis. The
recommendation by OnePoint BFG’s Advisors that a client purchase or sell a security and/or
insurance commission product presents a conflict of interest, as the receipt of commissions may
provide an incentive to recommend investment products based on commissions received, rather
than on a particular client’s need. Furthermore, some of OnePoint BFG’s supervised persons, in
their individual capacities, offer and sell life insurance or other insurance products through
OnePoint BFG’s affiliate (as discussed below) or another insurance agency. Additionally, some of
OnePoint BFG’s supervised persons, in their individual capacities, refer clients to other insurance
agents and receive commissions through a commission-sharing arrangement. As a result,
OnePoint BFG’s Advisors may be incentivized to recommend one insurance agency over another.
Clients are not under any obligation to purchase or sell any commission products from OnePoint
BFG’s supervised persons or Advisors. Clients may purchase or sell investment products
recommended by OnePoint BFG’s Advisors through other, non-affiliated broker-dealers or
insurance agents.
Affiliated Insurance Agency. OnePoint BFG is affiliated through common ownership with an
insurance agency, Bleakley, Schwartz, Cooney & Finney, LLC (“BSCF”). BSCF is authorized
under the insurance laws of one or more states or other jurisdictions to solicit, sell, negotiate and
service insurance products. BSCF has an insurance products distribution agreement with Mass
Mutual Life Insurance Company. OnePoint BFG’s affiliation with BSCF creates a conflict of
interest, as OnePoint BFG or its Advisors are incentivized to recommend BSCF versus other
similar, nonaffiliated insurance agencies. Clients are not under any obligation to purchase or sell
any insurance products and may purchase or sell insurance products recommended by OnePoint
BFG’s Advisors through other, non-affiliated insurance agencies.
Certain New Client Relationships. A client’s primary contact is with an Advisor. The Advisor
may have recruited the client while the Advisor was affiliated with a previous broker-dealer or
investment adviser. When a client transfers or moves their account(s) to OnePoint BFG,
OnePoint BFG may be limited in its ability to negotiate (or re-negotiate) fees and costs on behalf
of the client. All clients when onboarding with OnePoint BFG will receive information and sign
agreements that provide details on the fees and charges specific to each client’s account with
OnePoint BFG.
Tax Preparation Services: OnePoint BFG has entered into separate agreements with KRS
CPAs, LLC (“KRS”) and Steven A. Reiss & Co., LLC (“SAR”) to provide tax, accounting and
consulting services (collectively, “tax preparation services”) to OnePoint BFG, its affiliate
(BSCF) and some OnePoint BFG Advisors. These agreements also allow OnePoint BFG
Advisors to offer OnePoint BFG clients tax preparation services performed by KRS and SAR. In
some instances, OnePoint BFG includes the tax preparation services fee in its investment
advisory services fee and directly pays KRS or SAR, as applicable, for the tax preparation
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services performed for the client. In all other circumstances, KRS or SAR, as applicable, will bill
the client directly for the tax preparation services performed for the client. This is a service of
convenience and neither OnePoint BFG nor its Advisors receive any economic benefit from
KRS or SAR under these agreements. SAR does, however, rent office space directly from
OnePoint BFG under a separate agreement.
Estate Planning Services: OnePoint BFG has entered into an agreement with Engel Devlin
Sgambati, LLC (“EDS”) to provide estate planning and legal services (collectively, “estate
planning services”) to OnePoint BFG and some OnePoint BFG Advisors. EDS will prepare
summary reviews for a OnePoint BFG Advisor that will outline what is stated in the estate
planning documents provided by a client to OnePoint BFG. EDS may make suggestions when
there are obvious errors in existing documents, point out possible issues with existing documents
(such as a contradiction in terms) and make due diligence recommendations (such as review of
client’s beneficiary designations or titling of assets). This review may include some analysis and
comments from EDS regarding key takeaways that will be reviewed with OnePoint BFG
Advisors should any questions arise. EDS will not engage directly with any OnePoint BFG
Clients regarding legal services provided to OnePoint BFG as part of this service. This is a
service of convenience and neither OnePoint BFG nor its Advisors receive any economic benefit
from EDS under this agreement. EDS will not be representing any clients under this service.
OnePoint BFG is EDS’s client. Clients are encouraged to discuss any takeaways with their own
legal and tax experts.
Item 11. Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
OnePoint BFG maintains an investment policy relative to personal securities transactions. This
investment policy is part of OnePoint BFG’s overall Code of Ethics, which serves to establish a
standard of business conduct for OnePoint BFG’s Advisors that is based upon fundamental
principles of openness, integrity, honesty and trust. A copy of OnePoint BFG’s Code of Ethics
is available upon request by contacting OnePoint BFG’s Chief Compliance Officer using the
information on the cover page of this Brochure.
OnePoint BFG has policies and procedures in place for: the protection of personal and
confidential information; the prevention of insider trading; gifts and entertainment; contributions
to elected public officials and personal securities trading practices. In accordance with Section
204A of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), OnePoint BFG
also maintains and enforces written policies reasonably designed to prevent the misuse of
material non-public information by OnePoint BFG or any person associated with OnePoint BFG.
The following includes a brief description of certain aspects of OnePoint BFG’s Code of Ethics.
A. Neither OnePoint BFG nor any related person of OnePoint BFG recommends,
purchases, or sells for client accounts, securities in which OnePoint BFG or any related
person of OnePoint BFG has a material financial interest.
B. OnePoint BFG and its Advisors may purchase or sell securities that are also recommended
to clients. This practice may create a situation where OnePoint BFG and its Advisors are
in a position to materially benefit from the sale or purchase of those securities. Therefore,
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this situation creates a potential conflict of interest. Practices such as “scalping” (i.e., a
practice whereby the owner of shares of a security recommends that security for
investment and then immediately sells it at a profit upon the rise in the market price which
follows the recommendation) could take place if OnePoint BFG did not have adequate
policies in place to detect such activities. In addition, these procedures are designed to
help detect insider trading, “front-running” (i.e., personal trades executed prior to those of
OnePoint BFG’s clients) and other potentially abusive practices.
C. OnePoint BFG has a personal securities transaction policy in place to monitor the
personal securities transactions and securities holdings of each of OnePoint BFG’s
“Access Persons;” that is persons who have access to the firm’s nonpublic information.
OnePoint BFG’s securities transaction policy requires that OnePoint BFG Access
Persons provide the Chief Compliance Officer with a written report of their current
securities holdings as part of the process of becoming an Access Person. Additionally,
each Access Person provides the Chief Compliance Officer with a written or electronic
report of the Access Person’s current securities holdings at least once each twelve (12)
month period thereafter on a date OnePoint BFG selects.
D. OnePoint BFG and its Advisors may purchase or sell securities, at or around the same
time as those securities are recommended to clients. This practice creates a situation
where OnePoint BFG and its Advisors are in a position to materially benefit from the sale
or purchase of those securities. Therefore, this situation creates a potential conflict of
interest. As indicated above in Item 11.B, OnePoint BFG has a personal securities
transaction policy in place to monitor the personal securities transactions and securities
holdings of each OnePoint BFG Access Person.
E. OnePoint BFG does not engage in principal or agency cross transactions for any client
account. OnePoint BFG does not cross trade between any client accounts.
Item 12. Brokerage Practices
Client transactions are executed through the designated custodian(s), third-party investment
manager(s) and/or TAMP(s). Clients should be aware that some third-party investment managers
and/or TAMPs execute trades away from the custodian. For more information about the
brokerage practices of a third-party investment manager or TAMP, clients should refer to the
information provided by the Advisor, including, but not limited to, the applicable custodian’s
Form ADV Part 2A brochure or the applicable program’s Form ADV Part 2A brochure and
applicable agreement(s).
Factors that OnePoint BFG considers in recommending a custodian facilitating transactions,
include the historical relationship with OnePoint BFG, financial strength, reputation, execution
capabilities, investment offerings, pricing, research, and service. A client may pay a commission
that is higher than another broker-dealer might charge to facilitate the same transaction where
OnePoint BFG determines, in good faith, that the commission and transaction fee is reasonable
in relation to the value of the brokerage and services received by the custodian. In seeking best
execution, the determinative factor is not the lowest possible cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of services.
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A. Directed Brokerage
OnePoint BFG does not generally accept directed brokerage arrangements, which is where a
client requires that account transactions be affected through a specific broker-dealer.
Furthermore, OnePoint BFG’s Advisors who are also broker-dealer registered representatives of
PKS are not able to participate in brokerage arrangements away from PKS. Typically, client
transactions are executed through the above referenced and designated custodian(s). In the event
OnePoint BFG accepts a client-directed brokerage arrangement, OnePoint BFG will not seek
alternative pricing from other executing broker-dealers.
Please Note: In the event that the client directs OnePoint BFG to affect securities transactions for
the client’s accounts through a specific broker-dealer, the client correspondingly acknowledges
that such direction may cause the accounts to incur higher commissions or transaction costs than
the accounts would otherwise incur had the client determined to affect account transactions
through alternative execution and clearing arrangements that may be available through OnePoint
BFG.
B. Omnibus Accounts
OnePoint BFG does not accept engagements with clients where client funds are pooled into an
omnibus account. Client assets are held at the designated custodian in individual accounts that
are identified to the client.
C. Order Aggregation
From an order aggregation perspective, individual OnePoint BFG Advisors generally operate
independently of other OnePoint BFG Advisors when implementing investment strategies
involving the purchase and sale of securities. In the case of OnePoint BFG proprietary investment
strategies, OnePoint BFG will aggregate or “bunch” client transactions, on a firm-wide basis at
each applicable custodian, for execution. OnePoint BFG has the ability to aggregate or “bunch”
any client transactions where practicable. Where orders are aggregated or “bunched,” transactions
will be averaged as to price and will be allocated among clients in proportion to the purchase and
sale orders placed for each client account on any given day. As a result, clients may pay higher
commissions or other transaction costs or greater spreads, or receive less favorable net prices, on
transactions for their account than would otherwise be the case. OnePoint BFG will not receive
any additional compensation or remuneration whether or not client orders are aggregated. Clients
should discuss OnePoint BFG’s order aggregation practices with their Advisor or with OnePoint
BFG’s Chief Compliance Officer.
D. Research and Other Benefits
Although not a material consideration when determining whether to recommend that a client
utilize the services of a particular custodian, OnePoint BFG receives research and other benefits
from the custodians.
Such research and other benefits include, but are not limited to, investment-related research,
pricing information and market data, software and other technology that provide access to client
account data, compliance and/or practice management-related publications, discounted or gratis
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consulting services, discounted and/ or gratis attendance at conferences, meetings, and other
educational and/or social events, marketing support, computer hardware and/ or software and/or
other products used by OnePoint BFG in furtherance of its investment advisory business
operations. Other benefits include, facilitating payment of OnePoint BFG’s fees from its clients’
accounts, assisting with back-office training and support functions, recordkeeping and client
reporting, and institutional trading and custody services, which are typically not available to retail
investors.
Many of these services are used to service all or some substantial number of OnePoint BFG’s
accounts, including accounts not maintained at the particular custodian that provide or pay for
the research or other benefit(s). The custodian also makes available to OnePoint BFG other
services intended to help OnePoint BFG manage and further develop its business enterprise.
These services include professional, compliance, legal and business consulting, publications and
conferences on practice management, information technology, business succession, regulatory
compliance, employee benefits providers, human capital consultants, insurance and marketing.
In addition, custodians make available, arrange and/or pay vendors for the above-referenced
types of services rendered to OnePoint BFG by independent third parties. Where such services
are provided by a third-party vendor, the custodian makes a payment to OnePoint BFG to cover
the cost of such services, reimburse OnePoint BFG for the cost associated with the services, or
pay the third-party vendor directly on behalf of. OnePoint BFG.
The products and services described above are provided to OnePoint BFG as part of its overall
relationship with the custodians. The receipt of these benefits creates a conflict of interest because
any advice from a OnePoint BFG Advisor that leads clients to custody their assets at a particular
custodian may be based in part on the benefit to OnePoint BFG or its Advisors and the
availability of the foregoing research and other benefits and not solely on the nature, cost or
quality of custody or brokerage services provided by the custodian. OnePoint BFG’s receipt of
some of these benefits may be based on the amount of OnePoint BFG’s advisory assets held at the
custodian. Furthermore, the receipt of some of these benefits by a dually registered person is
based on that person’s relationship with the qualified custodian and not as an Advisor of OnePoint
BFG.
OnePoint BFG’s Chief Compliance Officer is available to address any questions that a client or
prospective client may have regarding the above or any information outlined in this Brochure.
E. Transition Assistance
OnePoint BFG and/or a custodian provide benefits and payments to certain Advisors in order to
assist such Advisor with the costs associated with transitioning that individual’s business from
one entity to OnePoint BFG and/or a custodian (collectively referred to as “Transition
Assistance”).
The proceeds of such Transition Assistance payments are intended to be used for a variety of
purposes, including, but not necessarily limited to, providing working capital to assist in funding
the Advisor’s business, satisfying any outstanding debt owed to the Advisor’s prior firm,
offsetting account transfer fees, technology set-up fees, marketing and mailing costs, stationery
and licensure transfer fees, moving expenses, office space expenses, staffing support, termination
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fees associated with moving accounts and may include foregoing revenues during account
transition. OnePoint BFG may provide Transition Assistance to an Advisor in the form of
transition assistance payments or in the form of forgivable loans conditioned on the Advisor
remaining with OnePoint BFG to obtain the full value of the loan forgiveness.
The amount of the Transition Assistance payments is often significant in relation to the overall
revenue earned or compensation received by the Advisor. Such payments are generally based on
the size of the Advisor’s business established at the prior firm and/or assets held at the custodian.
The receipt of Transition Assistance creates a conflict of interest because it creates a financial
incentive for OnePoint BFG’s Advisors to recommend that its clients maintain their accounts
under the investment advisory service of OnePoint BFG and/or a particular custodian. The
opportunity for loan forgiveness presents a conflict of interest by presenting a financial incentive
for the registered person to remain with OnePoint BFG whether or not it is advantageous to the
dually registered person’s clients. In certain instances, OnePoint BFG receives a portion of a
Transition Assistance payment. In addition, OnePoint BFG benefits from the Transition
Assistance because the payment of such Transition Assistance increases OnePoint BFG’s ability
to attract new Advisors and thereby increase its assets under management.
OnePoint BFG attempts to mitigate these conflicts of interest by maintaining multiple custodial
relationships and OnePoint BFG Advisors are trained to recommend custodians based on the
benefits that such services provide to clients, rather than the Transition Assistance. Because the
final decision to custody assets with any custodian is made by the client and clients should be
aware of this conflict and take it into consideration in making a decision whether to engage
OnePoint BFG Advisors for investment advice and whether to custody their assets in a
brokerage or advisory account at any particular custodian.
Item 13. Review of Accounts
OnePoint BFG’s Advisors review client accounts on an ongoing basis; however, there is no
ongoing review for limited scope engagements, such as creating a financial plan or consulting
services.
OnePoint BFG and/or its Advisors document account reviews on an annual or other-than-
periodic basis upon the occurrence of a triggering event, such as a change in client investment
objectives and/or financial situation, a market correction or material market event or otherwise
by client request. Additionally, all clients are encouraged to review financial planning issues (to
the extent applicable), investment objectives and account performance with the Advisor on at
least an annual basis. These annual or other-than-periodic reviews are conducted in person, by
phone or via video conference (e.g., via Zoom).
Clients are provided written transaction confirmations and account statements directly from the
custodian. OnePoint BFG may also provide written periodic reports summarizing account
activities and performance. Clients are urged to compare any report provided by OnePoint BFG
with the confirmations and statements received from the custodian. The custodial statement is
the official record of the account.
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Please Note: Each client is responsible for promptly notifying OnePoint BFG of any change in
financial situation, investment objectives, or risk tolerance.
Item 14. Client Referrals and Other Compensation
A. Client Referrals
If a client is introduced to OnePoint BFG by a solicitor, OnePoint BFG may pay that solicitor a
referral fee in accordance with the Advisers Act, and any corresponding state securities law
requirements. Any such referral fee will be paid solely from OnePoint BFG’s investment
advisory fee and will not result in any additional charge to the client. If the client is introduced to
OnePoint BFG by an unaffiliated solicitor, the solicitor, at the time of the solicitation, will
disclose the nature of the solicitor relationship, and each prospective client will be provided with
a copy of OnePoint BFG’s disclosure brochure and with a copy of the written disclosure
statement disclosing the terms of the solicitation arrangement between OnePoint BFG and the
solicitor, including the compensation to be received by the solicitor from OnePoint BFG.
If OnePoint BFG introduces a client to another investment adviser or an investment manager,
OnePoint BFG may be paid a referral or solicitor fee in accordance with the Advisers Act, and
any corresponding state securities law requirements. Any such referral fee will be paid
according to a fee disclosure statement provided to the client at the time that the referral is
made. When OnePoint BFG is acting as an unaffiliated solicitor, OnePoint BFG, at the time of
the solicitation, will disclose the nature of its solicitor relationship, and will provide each
prospective client with a copy of OnePoint BFG’s written disclosure documents and with a copy
of a written disclosure statement disclosing the terms of the solicitation arrangement between
OnePoint BFG and the investment adviser or investment manager, including the compensation
to be received by OnePoint BFG.
B. Other Compensation
As detailed in Items 5, 10 and 12 above, OnePoint BFG and its Advisors receive direct and
indirect economic or other benefits from the custodians, including research, other benefits, and
transition assistance, as the case may be, and product sponsors (e.g., insurance companies,
mutual fund companies, sub-advisors, TAMPs or other vendors), as further described below.
Furthermore, certain Advisors of OnePoint BFG are also associated with Purshe Kaplan Sterling
Investments (“PKS”) as broker-dealer registered representatives (“dually registered persons”). In
their individual capacity as registered representatives of PKS, dually registered persons earn
commissions for the sale of securities or investment products that the dually registered person
recommends to clients. OnePoint BFG also collects an administrative service fee for brokerage
accounts opened and maintained by its Advisors who provide brokerage services (in their
individual capacity) through an unaffiliated broker dealer entity. LPL also provides other
compensation to OnePoint BFG and its Advisors, including, but not limited to, bonus payments,
forgivable and non-forgivable loans and other benefits. This compensation is based, in part, on
participation in advisory programs sponsored by LPL and derived from advisory fees paid to
LPL. The receipt of any such compensation creates a financial incentive for a OnePoint BFG
Advisor to recommend LPL as custodian for the assets in a client’s advisory account and as
advisory program sponsor. OnePoint BFG encourages clients to discuss any such conflicts of
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interest with its OnePoint BFG Advisor before making a decision to custody its assets at LPL
and utilize an LPL advisory program.
OnePoint BFG, through LPL and other qualified custodians, receives payment for or
reimbursement of the costs associated with education or training events that are hosted by
OnePoint BFG and attended by OnePoint BFG Advisors and associated persons. For example,
OnePoint BFG (through LPL) receives educational support payments, depending on the
anticipated nature and scope of the events, from product sponsors to assist training and educating
OnePoint BFG Advisors. Each product sponsor may provide OnePoint BFG (through LPL) up to
a maximum of $25,000 per calendar year. Any such support payments are not tied to the sales of
any products or client assets in the products. OnePoint BFG Advisors do not directly receive any
portion of these payments; however, OnePoint BFG Advisors indirectly benefit from these
payments through meals, lodging, events and other items.
From time to time, product sponsors pay for client luncheons, educational meetings, customer
appreciation events, marketing events or advertising initiatives, including services for identifying
prospective clients. This includes third-party speakers that OnePoint BFG or its Advisors do not
have to compensate (although OnePoint BFG or its Advisors may also pay consultants to attend
these events or other client meetings to offer their expertise). These arrangements may give rise
to conflicts of interest, or perceived conflicts of interest in that OnePoint BFG and its Advisors
have an incentive to invest client assets in investment products or services managed, sold or
offered by such product sponsors that provide these benefits to OnePoint BFG and/or its
Advisors. OnePoint BFG’s commitment to its clients and the policies and procedures it has
adopted that require the review of such arrangements are designed to limit any interference with
OnePoint BFG and its Advisors’ independent decision making when choosing investment
products and/or services for clients.
OnePoint BFG’s Chief Compliance Officer is available to address any questions that a client
or prospective client may have regarding the above or any information outlined in this
Brochure.
Item 15. Custody
OnePoint BFG does not have custody of client funds or securities, except in the circumstances
detailed below. Client investment funds are held by a qualified custodian in accounts identified
individually to the client. Some investments are custodied by or through the issuer, for example
mutual funds or variable annuity products.
OnePoint BFG has the ability to have its fees for each client debited by the custodians. Where
OnePoint BFG has the ability to have its fees debited in this manner, it is deemed to have custody
but is not subject to the regulatory surprise audit requirement. Please Note: The account custodian
does not verify the accuracy of OnePoint BFG’s fee calculation. In some cases, the payment of
fees will be made directly to OnePoint BFG by clients, but never directly by a client to a
OnePoint BFG Advisor.
Clients are provided written transaction confirmations and accounts statements directly from the
custodian. OnePoint BFG also provides written periodic reports summarizing account activities
and performance. Clients are urged to compare any report provided by OnePoint BFG with the
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confirmations and statements received from the custodian. Please Note: Each client is
responsible for promptly notifying OnePoint BFG of any change in financial situation,
investment objectives or risk tolerance. The custodial statement is the official record of the
account.
Item 16. Investment Discretion
A client can determine to engage OnePoint BFG to provide investment advisory services on a
discretionary basis. Prior to engaging to provide investment advisory services, the client will
be required to execute a OnePoint BFG written a OnePoint BFG agreement setting forth the
terms and conditions under which OnePoint BFG will manage the client’s assets, and a
separate custodial agreement(s), account application or other applicable documentation,
depending on the type of account, with each designated custodian. OnePoint BFG’s written
advisory agreement for discretionary investment advisory services designates OnePoint BFG as
the client’s agent and attorney-in-fact, granting OnePoint BFG and the client’s Advisor full
authority to purchase, sell, or otherwise facilitate investment transactions involving the assets
in the client’s name within the discretionary account.
Clients who engage OnePoint BFG on a discretionary basis may, at any time, impose
restrictions, in writing, on OnePoint BFG’s discretionary authority (e.g., limit the types/amounts
of particular securities purchased or sold for the account, exclude the ability to purchase or sell
securities with an inverse relationship to the market or proscribe OnePoint BFG’s use of margin,
etc.). Client restrictions can affect the account’s performance.
Item 17. Voting Client Securities
OnePoint BFG does not vote client proxies, except exclusively in the case of the OnePoint
BFGUMA strategy. For all other account types, clients maintain exclusive responsibility for: (1)
directing the manner in which proxies solicited by issuers of securities beneficially owned by
the client will be voted, and (2) making all elections relative to any mergers, acquisitions,
tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment
assets. Generally, clients will receive proxy materials directly from the applicable custodian(s)
or issuer’s proxy agent and should direct any questions as instructed in the specific proxy
matter. As with proxies, OnePoint BFG does not provide legal advice or represent or facilitate
class action claims or participate in other similar legal proceedings on behalf of clients except
for within the OnePoint BFG UMA. Furthermore, OnePoint BFG and its Advisors do not
instruct or give advice as to whether or not a client should participate as a member of a class
action lawsuit or participate in other legal proceedings and will not file claims on behalf of its
clients. The responsibility and authority for responding to class actions and other legal
proceedings rests solely with the registered shareholder (e.g., client) or legally appointed agent
(e.g., custodian) of the client or the client’s attorney.
As it pertains to proxy voting matters, class action claims, and other similar legal proceedings,
OnePoint BFG and its Advisors retain no authority, through the investment advisory
relationship, and therefore have no responsibility for reviewing any proxy materials, corporate
action materials, prospectuses and/or other offering documents and any other related information
related to such except as it pertains to the OnePoint BFG UMA.
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Specifically, within the OnePoint BFG UMA, clients will delegate the voting of proxies and
class action claims to Bleakley Financial Group. OnePoint BFG will utilize Broadridge
Financials’ ProxyEdge platform to facilitate voting. This means that for most votes, clients will
be voting with the money managers at the largest mutual funds. If there is ever a stock that is not
covered by Broadridge’s ProxyEdge service, the analysts at Bleakley Financial will research the
specific proxy and will vote in what is deemed to be in the clients’ best economic interest.
Clients should be aware that some third-party investment managers and/or TAMPs retain the
authority to vote proxies client securities. For more information about the practices of a third-
party investment manager or TAMP, clients should refer to the information provided by the
Advisor, including, but not limited to, the applicable third-party investment manager’s Form
ADV Part 2A brochure or the applicable program’s Form ADV Part 2A brochure and applicable
agreement(s).
Item 18. Financial Information
OnePoint BFG does not require or solicit prepayment of more than $1,200 in fees per client, six
months or more in advance.
OnePoint BFG has no financial commitment or condition that is reasonably likely to impair its
ability to meet contractual commitments to its clients.
OnePoint BFG has not been the subject of a bankruptcy petition at any time.
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