Overview
Assets Under Management: $202 million
Headquarters: CHARLOTTE, NC
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection
Fee Structure
Primary Fee Schedule (BFA FORM ADV 2A (JULY 15, 2025))
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.75% |
| $1,000,001 | $2,000,000 | 1.50% |
| $2,000,001 | and above | 1.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $17,500 | 1.75% |
| $5 million | $70,000 | 1.40% |
| $10 million | $132,500 | 1.32% |
| $50 million | $632,500 | 1.26% |
| $100 million | $1,257,500 | 1.26% |
Clients
Total Client Accounts: 1,298
Discretionary Accounts: 1,205
Non-Discretionary Accounts: 93
Regulatory Filings
CRD Number: 315570
Filing ID: 2010257
Last Filing Date: 2025-08-18 15:57:00
Website: https://blueprintip.com
Form ADV Documents
Additional Brochure: BFA FORM ADV 2A (JULY 15, 2025) (2025-07-15)
View Document Text
Part 2A of Form ADV: Firm Brochure
July 15, 2025
ITEM 1 COVER PAGE
BLUEPRINT FINANCIAL ADVISORS LLC
1100 Kenilworth Ave., Suite 210
Charlotte, NC 28204
844-200-2568
buildyourblueprint.com
This brochure provides information about the qualifications and business practices of Blueprint Financial Advisors
LLC. If you have any questions about the contents of this brochure, please contact us at 844-200-2568 or
brandon.langley@blueprintip.com. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission (the “SEC”) or by any state securities authority.
Additional information about Blueprint Financial Advisors, LLC (CRD #315570) is also available on the SEC’s website
at www.adviserinfo.sec.gov. Blueprint Financial Advisors, LLC is an investment adviser registered with the SEC.
Registration does not in any way constitute an endorsement by the SEC of an investment adviser’s ability.
Moreover, registration does not imply that a registered adviser has achieved a certain level of skill, competency,
expertise or training in providing professional advisory services to its clients.
ITEM 2 MATERIAL CHANGES
The purpose of Item 2 of the Brochure is to provide a summary of new and/or updated information that is
contained in the remainder of the Brochure since the filing of the previous annual amendment, dated March 26,
2025.
Since the date of the last Form ADV Part 2A Brochure on May 15, 2025, Blueprint Financial Advisors LLC ("BFA")
has had no material changes in its business. However, changes have been made to certain disclosures as follows:
• Under Item 15 “Custody”, BFA updated the types of arrangements at BFA that are deemed to be custody
of client assets.
To receive a complete copy of this brochure at no charge, please contact your Financial Advisor or the home office
at 844-200-2568.
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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 ......................................................................................................................... 6
ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................................... 9
ITEM 7 TYPES OF CLIENTS ........................................................................................................................................ 9
ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .................................................... 9
ITEM 9 DISCIPLINARY INFORMATION .................................................................................................................... 11
ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................................. 11
ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING 13
ITEM 12 BROKERAGE PRACTICES .......................................................................................................................... 14
ITEM 13 REVIEW OF ACCOUNTS ............................................................................................................................ 16
ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION .................................................................................. 16
ITEM 15 CUSTODY ................................................................................................................................................. 16
ITEM 16 INVESTMENT DISCRETION ....................................................................................................................... 16
ITEM 17 VOTING CLIENT SECURITIES .................................................................................................................... 17
ITEM 18 FINANCIAL INFORMATION ...................................................................................................................... 17
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ITEM 4 ADVISORY BUSINESS
Blueprint Financial Advisors, LLC (“BFA”) is a limited liability company formed in June 2021 in the State of North
Carolina. BFA became registered as an Investment Adviser Firm on July 23, 2021. BFA is principally owned by Jon
Robinson, Brandon Langley, and Tommy Mayes. The firm provides investment advisory services to clients of all
types including:
Individuals
•
• High-net-worth individuals
• Trusts
• Pension plans and other ERISA plans
• Foundations and endowments
INVESTMENT ADVISORY SERVICES
Client and BFA agree, in writing, to manage the client portfolio toward one or more objectives including any
reasonable unique preferences and restrictions. BFA will allocate investment assets consistent with the
designated investment objectives. BFA will monitor a client’s portfolio and make trades when necessary to meet
the investment objective.
BFA primarily allocates client investments among mutual funds, exchange traded funds (“ETFs”), structured notes,
stocks (common or preferred), bonds, option contracts, private placements or other illiquid investments,
certificates of deposit, and other securities and/or contracts relating to the same. Once allocated, BFA provides
ongoing monitoring and maintenance of account performance, asset allocation and client investment objectives.
The client can determine to engage BFA to provide discretionary investment advisory services on a fee basis. BFA’s
annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under
BFA’s management. Before engaging BFA to provide investment advisory services, clients are required to enter
into an Investment Advisory Agreement with BFA setting forth the terms and conditions of the engagement
(including termination), describing the scope of the services to be provided, and the fee that is due from the client.
See Item 5 for details.
FINANCIAL PLANNING & CONSULTATION SERVICES
BFA may provide its clients with a broad range of comprehensive financial planning and consulting services. These
services seek to address the education and retirement planning needs of the client. Financial plans and
consultation services can be comprehensive or focus only on specific areas of concern to the client. Examples of
financial planning and consultation services include retirement planning, tax-related investment planning, cash
flow management, risk management, education funding, and insurance planning. In general, a financial plan or
consultation service can address any or all of the following areas:
• Personal: Family records, budgeting, personal liability, estate information, divorce planning, college
planning, and financial goals analysis.
• Tax & Cash Flow: Income tax and spending analysis and planning for past, current, and future years.
• Death & Disability: Cash needs at death, the income needs of surviving dependents, estate planning, and
disability income analysis.
• Retirement: Analysis of current strategies and investment plans to help clients achieve their retirement
goals. Retirement planning could include reviewing qualified and non-qualified retirement plans and
strategies.
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•
Investments: Analysis of investment alternatives, asset allocation strategies, etc., and their effects on a
portfolio.
Life Insurance: Analysis of current and future insurance needs.
•
• College Planning: Analysis of college funding and planning situations and recommendations of academic
and financial strategies to increase cash flow, which can be used to reduce college expenses and help
maintain retirement goals.
BFA and its Supervised Persons may also provide financial planning and consultation services to business entities
and groups requesting educational services, financial planning seminars, or individual consulting and planning
services for employees or members.
The type and amount of financial planning or consultation services are the client's choice. BFA and its Supervised
Persons can assist the client in identifying what types of planning and how much the client needs. In some cases,
clients desire comprehensive financial planning and consultation services that range from investment advice,
insurance planning, education funding, retirement planning, and many more types of financial planning and
consultation services. Conversely, some clients may want to focus on a particular matter, such as insurance
planning, or have some time to speak to a financial planner about the specific matter they are concerned about.
When providing financial planning and consultation services, BFA and its Supervised Persons gather information
through interviews concerning the client's current financial status, future goals, attitude towards risk, and time
horizon. The client may be required to complete a questionnaire and provide additional documentation as
reasonably requested by BFA and its Supervise Persons.
In general, comprehensive financial planning will result in a written report, while an hourly consultation will not
unless otherwise agreed by the client and BFA.
In performing its services, BFA is not required to verify any information received from the client or from the client’s
other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. BFA
may recommend the services of itself, its Supervised Persons in their individual capacities as registered
representatives of a broker-dealer, and/or other professionals to implement its recommendations. Clients are
advised that a conflict of interest exists if BFA recommends its own services. The client is under no obligation to
act upon any of the recommendations made by BFA or its Supervised Persons under a financial planning or
consulting engagement or to engage the services of any such recommended professional, including BFA itself. The
client retains absolute discretion over all such implementation decisions and is free to accept or reject any of BFA’s
or its Supervised Persons recommendations. However, should the client choose to use BFA to implement all or
part of the recommendations obtained from the financial planning or consultation process, the client will need to
contract with BFA for one or more of the management services described in this document.
Clients are advised that it remains their responsibility to promptly notify BFA if there is ever any change in their
financial situation or investment objectives for the purpose of reviewing, evaluating, or revising BFA’s previous
recommendations and/or services.
RETIREMENT PLAN CONSULTING
BFA understands the unique needs and challenges investors face who are retired or about to retire. It’s important
to understand how the client will structure their retirement income, how long the income will last, and which
sources of income the client should tap into first to minimize taxes and maximize income potential. Through
comprehensive planning, we can help you prioritize the clients’ goals and develop a strategy that seeks to protect
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and grow the clients’ retirement assets. Whether you are in the accumulation phase or have already retired, a
comprehensive strategy is critical. BFA offers assistance to their clients with the following retirement plans and
strategies:
• Retirement Income Planning
• 401(k)/IRA Rollovers
• Traditional and Roth IRAs
• SEP IRAs
• SIMPLE IRAs
Retirement Rollovers-Potential for Conflict of Interest: When BFA provides investment advice to its clients
regarding a retirement plan account or individual retirement account, it is a fiduciary within the meaning of Title
I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are
laws governing retirement accounts. The way BFA makes money creates some conflicts with client interests, so it
operates under a special rule that requires BFA to act in the client’s best interest and not put its interests ahead
of the client. Under this special rule’s provisions, BFA must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put BFA’s financial interests ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that BFA gives advice that is in the client’s best interest.
• Charge no more than is reasonable for BFA services; and
• Give the client basic information about conflicts of interest.
No client is under any obligation to rollover retirement plan assets to an account managed by BFA. BFA’s Chief
Compliance Officer remains available to address any questions that a client or prospective client may have
regarding the potential for conflict of interest presented by such rollover recommendation.
ASSETS UNDER MANAGEMENT
As of the fiscal year ending on December 31, 2024, BFA has $201,503,941 million in assets under management, of
which $189,475,226 million is managed on a discretionary basis and $12,028,715 million on a non-discretionary
basis.
ITEM 5 FEES AND COMPENSATION
If a client determines to engage BFA to provide investment advisory services on a fee basis, BFA’s tiered annual
investment advisory fee is based upon a percentage (%) of the market value of the assets placed under BFA’s
management as follows. There is no minimum required assets under management. However, assets less than
$1,000,000 may be charged a quarterly minimum fee of $100. The Adviser may choose to charge this minimum
account fee or charge a lower asset-based fee at its sole discretion. All fees are negotiable between the client and
BFA with the maximum fee outlined in the schedule below. Assets are combined at the household level for
determining the appropriate fee when the schedule is used. Fees may be charged in advance or in arrears, though
typically accounts are billed in arrears. The timing of fees is outlined in the client advisory agreement.
In addition to the advisory fee, clients will also be charged an annual technology fee of $50 per account to cover
the cost of account aggregation software. If a client has a held-away account that it would like the advisor to
manage, the advisor will use the Pontera Order Management System to view and manage those assets. At no time
will the advisor accept, maintain possession, or have custodial responsibility for the client’s funds or securities.
Pontera charges a fee of 0.25% annually for the use of its order management system. The advisor will collect this
fee on Pontera’s behalf out of another custodial account either held or set up with the client for this purpose.
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BFA MAXIMUM FEE SCHEDULE
ANNUAL RATE(S)
1.75%
1.50%
1.25%
HOUSEHOLD ASSETS UNDER MANAGEMENT
Under $1,000,000
$1,000,001 to $2,000,000
$2,000,001 or more
OTHER COMPENSATION
Certain Principals and employees of BFA maintain licenses with various life and disability insurance companies. In
providing advisory services, these individuals may recommend the purchase of products under circumstances
where they would be entitled to receive a commission or other compensation in the transaction. In all such
circumstances, however, the client will be notified of this payment in advance of the transaction, and under no
circumstances will the client pay both a commission to these individuals and a management fee to BFA on the
same pool of assets.
FINANCIAL PLANNING AND CONSULATION SERVICES
BFA offers a variety of fee structures in connection with financial planning and consultation services. Among the
fee structures are: 1) hourly charges; 2) a one-time flat fee; and 3) a retainer fee that can be paid annually, semi-
annually, or quarterly. Financial planning and consultation services are negotiable and agreed upon prior to
entering into a contract.
Hourly fees and one-time flat fees are invoiced as charges are incurred, payable within 30 days of the invoice. For
retainer services, invoices will be sent out to the client on an annual, semi-annual, or quarterly basis, dependent
on the frequency of billing selected, and are payable within 30 days of the invoice. Payments can be made by
check or AdvicePay. Refunds are not available as the services have been performed at the time of invoicing.
Use of Third-Party Consultants - In select situations, BFA will enter into a written agreement with other third
parties for consulting services provided in support of BFA’s portfolio management services for certain accounts.
In these situations, a portion of the client’s advisory fee may be shared with the third-party consultant.
OTHER FEE CONSIDERATIONS
BFA receives its compensation through a combination of hourly, fixed, administrative, and asset-based fees. BFA’s
general policy is to charge fees in accordance with the fee schedule in effect at the time of the charge, however,
all fees are subject to negotiation. Asset Management services are provided on either a discretionary or non-
discretionary basis, as authorized by the client through the execution of each respective agreement. In the case
of non-discretionary services, the client must consent to each recommended securities transaction. In addition,
BFA may charge a relatively minor fee either as a flat fee percentage or a flat fee dollar amount for certain non-
discretionary accounts to cover the administrative and overhead expenses associated with servicing those
accounts outside of its discretionary management services.
BFA’s investment advisory and financial planning fees are negotiable at BFA’s discretion, depending upon
objective and subjective factors including but not limited to: the amount of assets to be managed; portfolio
composition; the scope and complexity of the engagement; the anticipated number of meetings and servicing
needs; related accounts; future earning capacity; anticipated future additional assets; the professional(s)
rendering the service(s); prior relationships with BFA and/or its representatives, and negotiations with the client.
Certain legacy clients have accepted different pre-existing service offerings from BFA and therefore receive
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services under different fee schedules than as set forth above. As a result of these factors, similarly situated clients
could pay different fees, the services to be provided by BFA to any particular client could be available from other
advisers at lower fees, and certain clients have fees different than those specifically set forth above.
BFA’s Chief Compliance Officer, Brandon Langley, remains available to address any questions that a client or
prospective client may have regarding the above fee determination.
Clients may elect to have BFA’s advisory fees deducted from their custodial account. Both BFA’s Investment
Advisory Agreement and the custodial/clearing agreement may authorize the custodian to debit the account for
the amount of BFA’s investment advisory and wealth management fees and to directly remit that management
fee to BFA in compliance with regulatory procedures. In the limited event that BFA bills the client directly, payment
is due upon receipt of BFA’s invoice. BFA will generally charge its annual investment advisory fee quarterly, in
arrears, based on the average daily balance of the preceding quarter. However, in select situations, BFA will deduct
fees and/or bill clients monthly or quarterly in advance, based upon the market value of the assets on the last
business day of the previous month or quarter in accordance with the firm’s portfolio management system. The
client advisory agreement outlines the exact timing of when fees will be collected. Any contributions made by the
client over the course of the month or quarter will typically result in an additional fee to BFA that is prorated to
the client account (or family of accounts) based on the timing of the contribution. Any withdrawals made by the
client over the course of a month or quarter will typically result in an additional credit that is prorated to the client
account (or family of accounts) based on the timing of the withdrawal and which will be applied to next months
or quarter’s fees. This will also include any increases or decreases in the valuations of certain securities which may
occur after the billing period (i.e. dividends received).
As discussed below, unless the client directs otherwise or an individual client’s circumstances require, BFA shall
generally recommend that Charles Schwab and Co., Inc. (“Schwab”), or similar national brokerage institution to
serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab
charge brokerage commissions and/or transaction fees for affecting certain securities transactions (i.e.
transaction fees are charged for certain no-load mutual funds, commissions are charged for options transactions).
In addition to BFA’s investment management fee, brokerage commissions and/or transaction fees, clients will also
incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g.
management fees and other fund expenses) and, for independent investment managers, the fees charged by each
separate manager who is engaged to manage the assets.
BFA, in its sole discretion, will charge a lesser investment management fee based upon certain criteria (including
but not limited to anticipated future earning capacity, anticipated future additional assets, dollar amount of assets
to be managed, related accounts, account composition, negotiations with client, etc.).
The Investment Advisory Agreement between BFA and the client will continue in effect until terminated by either
party by written notice in accordance with the terms of the Investment Advisory Agreement. For those clients
billed monthly or quarterly in advance, upon termination, BFA shall refund the prorated portion of the advisory
fee paid based upon the date of receipt of the client’s written notice. For those clients billed quarterly in arrears,
the client may receive an invoice for any amount owed after termination.
Neither BFA, nor its representatives accept compensation from the sale of securities or other investment products
sold through Blueprint Financial Advisors. Certain employees of BFA maintain licenses with various life and
disability insurance companies and serve as registered representatives of third-party broker-dealers. In providing
these services, these individuals may recommend the purchase of products under circumstances where they
would be entitled to receive a commission or other compensation in the transaction. In all such circumstances,
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however, the client will be notified of this payment in advance of the transaction, and under no circumstances will
the client pay both a commission to these individuals and a management fee to BFA on the same pool of assets.
BFA relies on pricing feeds from independent third-party custodians to value securities and other holdings in client
accounts for the purpose of calculating assets under management and investment advisory fees.
Certain legacy clients may have accepted different fees for the BFA’s investment advisory services and may
therefore receive services for a different fee than the fee ranges set forth above. As a result of these factors,
similarly-situated clients could pay different fees.
ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Neither BFA nor any supervised person of BFA accepts performance-based fees.
ITEM 7 TYPES OF CLIENTS
BFA’s clients shall generally include families, individuals, pension and profit-sharing plans, charitable organizations,
business entities, trusts and estates. BFA, in its sole discretion, may reduce its minimum asset requirement and/or
charge a lesser investment management fee based upon certain criteria (i.e. related accounts, anticipated future
additional assets, future earnings, negotiations, etc.).
ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
BFA advisors work with the client to develop an investment strategy appropriate to meet their financial goals.
Generally, Blueprint strategies are globally diversified, having the following asset classes:
Inflation-Protected Bonds (TIPS)
• US Equity
• Foreign Developed Equity
• Emerging Market Equity
• Real Estate
• US Bonds
• Global Bonds
•
• Alternatives
Each asset class has a target weight that is shifted based on Trend Following or Momentum-based factors focused
solely on the price of the asset. The extents to which asset class allocations are shifted depend on another macro-
level setting for each strategy:
• The Strategic Component
• The Tactical Component
The Strategic component is the portion of the strategy that remains static for each asset class. The strategic
allocation aligns with the client’s objectives for the particular strategy. Alternatively, the Tactical component is
the segment of the strategy allowed to shift based on Blueprint’s proprietary Trend Following techniques.
Adjusting these two components creates multiple sub-strategies that can be catered to the client’s needs.
Strategies with a higher tactical component are designed to be less correlated with the overall market direction,
particularly during bear markets.
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Blueprint builds its strategies by first establishing diversified portfolios matching the needs of clients across various
investment time horizons. It then overlays a set of rules using the asset price as the driver. Prices are monitored
daily, but rules are executed at month-end for existing accounts and intra-month for new accounts. Execution of
these rules allows the portfolio to tilt toward stronger performing assets and away from weaker segments.
The rules use average prices over multiple timeframes to reduce the impact of any one set of conditions. The first
timeframe, considered long-term, is designed to capture trends over months and years, should they persist. The
second is considered intermediate and captures trends over weeks and months. Focusing on longer rather than
shorter trends improves after-tax performance by holding winning trades for longer periods and exiting losing
trades quickly. This design also provides value to clients by reducing excess trades and statement activity. Investing
in securities involves the risk of loss that clients should be prepared to bear.
RISK OF LOSS
General Market Risks. Markets can, as a whole, go up or down on various news releases or for no explicable
reason. This uncertainty means that, at times, the price of specific securities could go up or down without real
reason and may take some time to recover any lost value. Adding additional securities may not help minimize this
risk since all securities may be affected by market fluctuations. Market fluctuations will ultimately affect a client’s
portfolio holdings.
Interest Rate Risks. Changes in interest rates will affect the value of a portfolio’s holdings invested in fixed income
securities. The value of fixed income securities is more inclined to decrease as interest rates increase. This
decrease in value may not be offset by income from new investments or other portfolio holdings. Interest rate
risk is generally greater for fixed-income securities with longer maturities or durations.
Credit Risks. An issuer or guarantor of a fixed-income security may be unable or unwilling to make timely
payments of interest or principal or honor its obligations otherwise. The issuer or guarantor may default, causing
a loss of the total principal amount of a security. The degree of risk for a particular security may be reflected in its
credit rating. There is the possibility that the credit rating of a fixed-income security may be downgraded after
purchase, which may adversely affect its value and a client’s portfolio holdings.
Asset Allocation Risks. The asset classes represented in a client’s portfolio holdings can perform differently from
each other at any given time, as well as over the long term. A client’s portfolio holdings will be affected by the
allocation among equity securities (stocks) and fixed income securities (bonds), cash equivalents, and occasionally,
alternative investments. If any asset class that comprises a client’s holdings underperforms, the performance of
other asset classes may suffer.
Time Horizon Risks. A client may require the liquidation of portfolio holdings at a time earlier than the anticipated
stated time horizon. If liquidations occur during a period that portfolio values are low, the client will not realize as
much value as he/she would have, had the portfolio holdings had the opportunity to gain value (or regain its value)
as investments frequently do.
Regulatory and Governmental Risk. Changes in laws and regulations can change the value of securities. Certain
industries are more susceptible to government regulation. If portfolio holdings are invested heavily in a particular
sector or industry, correlating changes in zoning, tax structure, or specific industry regulations could impact
returns or holdings.
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Risks of Investments in Mutual Funds, ETFs and Other Investment Pools. Blueprint will invest client portfolios in
mutual funds and ETFs. Investments in pooled investment funds are often less risky than investing in individual
securities because of their diversified portfolios; however, these investments are still subject to risks associated
with the markets in which they invest. In addition, pooled investment funds’ success will be related to the skills
of their particular managers and their performance in managing their funds. Pooled investment funds are also
subject to risks due to regulatory restrictions applicable to registered investment companies under the
Investment Company Act of 1940, as amended.
Cybersecurity Risk. Cybersecurity risk is the risk related to unauthorized access to the systems and networks of
BFA and its service providers. The computer systems, networks and devices used by BFA and service providers to
BFA and BFA’s clients to carry out routine business operations employ a variety of protections designed to prevent
damage or interruption from computer viruses, network failures, computer and telecommunication failures,
infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems,
networks or devices potentially can be breached. A client could be negatively impacted as a result of a
cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks or devices;
infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow or
otherwise disrupt operations, business processes or website access or functionality.
Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial
losses to a client; impediments to trading; the inability by BFA and other service providers to transact business;
violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement
or other compensation costs, or other compliance costs; as well as the inadvertent release of confidential
information. Similar adverse consequences could result from cybersecurity breaches affecting issues of securities
in which a client invests; governmental and other regulatory authorities; exchange and other financial market
operators, banks, brokers, dealers and other financial institutions; and other parties.
ITEM 9 DISCIPLINARY INFORMATION
Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to a client’s or prospective client’s evaluation of BFA or the integrity of BFA’s management.
BFA has no legal or disciplinary action that must be disclosed in response to this item. However, certain financial
professionals of BFA have legal or disciplinary history.
information, please
the
Investment Adviser Public Disclosure website at
For additional
see
www.adviserinfo.sec.gov and search the Advisor’s name or reach out to us 844-200-2568.
ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Robinson-Langley Capital Management. As discussed above, the primary co-owners of Blueprint, Mr. Robinson
and Mr. Langley, are also co-owners of Robinson-Langley Capital Management, LLC (“RL Capital”), which is a
former Commodity Trading Advisor (CTA) and Commodity Pool Operator (CPO). RL Capital ceased operations as
a CTA and CPO in May 2019; however, RL Capital and Blueprint maintain a shared services arrangement.
Blueprint Fund Management. BFA is under common control with its affiliated SEC registered investment adviser,
Blueprint Fund Management, LLC (“BFM”). Certain BFA personnel also serve as portfolio managers for BFM,
which is the investment adviser to the Blueprint Adaptive Growth Allocation Fund (the “Growth Fund”) and other
affiliated funds. Pursuant to advisory agreements and on a fully disclosed basis, clients may grant BFA the
authority to invest assets in the Growth Fund and other affiliated funds.
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A conflict of interest exists to the extent that BFA invests client assets in affiliated funds and Blueprint Investment
Partners (“BIP”) and/or its affiliated investment adviser, BFM, receive additional compensation on the same
assets. Please note, BIP and/or its personnel are directly compensated based on providing sub-advisory services
to BFM, which receives an advisory fee for services provided to the Growth Fund. Information about how BFM is
compensated by the Growth Fund is available in the Fund’s prospectus.
Blueprint Investment Partners. BFA is under common control with its affiliated SEC registered investment adviser,
Blueprint Investment Partners ("BIP"). BIP provides discretionary sub-advisory services to investment advisors and
brokerage service providers. When providing such services, BIP will enter into a separate, written sub-advisory
agreement with each advisor or broker. In providing sub-advisory services to its clients, BIP employs various
proprietary investment strategies (“Investment Strategies”) for the portfolios over which it has been delegated
discretionary authority (each, a “Portfolio”). BIP works with each client to determine which Investment Strategy
or Strategies will achieve the objectives of a particular Portfolio. BIP also provides advisory services as a Sub-
Advisor to OCIO ETF.
A conflict of interest exists to the extent that BFA uses Blueprint Investment Partners (“BIP”) to help manage
client portfolios and BIP receives additional compensation on the same assets.
Kingswood Capital Partners. Certain BFA personnel are registered representatives of Kingswood Capital Partners,
an SEC-registered broker-dealer and FINRA member that is independently owned and unaffiliated with BFA. Such
persons are subject to the general oversight of FINRA. See the Fees and Compensation section in this brochure for
more information on the compensation received by registered representatives who are affiliated with our firm,
and associated conflicts of interest.
Blueprint Insurance Services. BFA is affiliated with Blueprint Insurance Services, a registered insurance agency.
As indicated above, certain employees of BFA maintain licenses with various life and disability insurance
companies. These individuals will recommend the purchase of insurance products under circumstances where
they would be entitled to receive a commission or other compensation in the transaction. In all such
circumstances, however, the client will be notified of this payment in advance of the transaction, and under no
circumstances will the client pay both a commission to these individuals and a management fee to BFA on the
same pool of assets. Please note, clients are under no obligation to purchase any of the recommended life
insurance products.
CapInsights Partners, LLC. CapInsights Partners (“CIP”) is a Florida limited liability company formed in 2022 and is
under common control with BFA. CIP began providing investment advisory services as a related adviser for
Securities and Exchange Commission registration purposes of BFA in August 2023. CIP is owned and controlled by
Tommy Mayes and Steve Nelson. CapInsights was founded around the strategy of building a modern platform
focused on helping asset managers grow in the face of industry trends. To do so, CapInsights assembled a team
of professionals with track records in advising and leading investor relations for successful asset managers. The
firm’s focus is niche strategies, or firms launched by managers with long-term histories, who otherwise do not
employ investor relations teams of any significance. Currently, CIP services are limited to providing consulting and
referral services to third-party investment advisers (“TPIAs”).
MIAI, Inc. MIAI Inc. is a Texas Corporation and investment advisory firm registered with the Securities and
Exchange Commission since August 2002 that is under common control through indirect ownership with BFA. The
management of BFA also serves as management of MIAI. This creates a conflict of interest as management may
need to spend more time on one entity versus another, thus impacting the oversight and management of BFA and
its representatives. To address this conflict, BFA has hired a number of persons who serve in a compliance and/or
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executive management role, which assists in the allocation of resources to conduct various management
functions. MIAI is also a general insurance agency. Please note, clients are under no obligation to purchase any of
the recommended life insurance products.
Maplewood Investments, Inc. Certain BFA personnel are registered representatives of Maplewood Investments,
Inc. ("MPLW"), an SEC-registered broker-dealer and FINRA member that is under common control through indirect
ownership with BFA. Such persons are subject to the general oversight of FINRA. See the Fees and Compensation
section in this brochure for more information on the compensation received by registered representatives who
are affiliated with our firm, and associated conflicts of interest.
Other Affiliations. BFA may enter into a written agreement with a third-party investment adviser pursuant to
which BFA may refer clients to that third-party investment adviser for a fee. This compensation for referrals could
create a conflict of interest in BFA recommending one third-party adviser over another, however BFA will only
refer a client to a third-party investment adviser if it believes that such referral is in the best interest of the client.
BFA is dedicated to acting in our clients’ best interests based on fiduciary principles and will ensure the appropriate
client.
sub-advisor or
third-party money manager,
if any,
is utilized
for each
individual
In select situations, BFA will enter into a written agreement with other third parties for consulting services
provided in support of BFA’s portfolio management services for certain accounts. In these situations, a portion of
the client’s advisory fee may be shared with the third-party consultant.
In select situations, BFA enters into loan agreements with certain of its IARs to ensure the IAR has adequate
resources and financial support during their transition to BFA to continue providing advisory services in the best
interest of BFA clients. This arrangement creates a conflict of interest for the IAR to favor transactions and
strategies that increase revenue in firm strategies.
ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
As a fiduciary, BFA and its representatives have a duty of utmost good faith to act solely in the best interest of our
clients. Our clients entrust us with their funds, which in turn place a high standard on our conduct and integrity. Our
fiduciary duty compels all employees to act with the utmost integrity in all our dealings. This fiduciary duty underlies
our Code of Ethics and Personal Trading Policy and represents the expected basis of all our dealings with our clients.
This Code of Ethics consists of the following core principles:
• The interests of clients will be placed ahead of the firm’s or any employee’s own investments.
• Employees are expected to conduct their personal securities transactions in accordance with the Personal
Trading Policy and will strive to avoid any actual or perceived conflicts of interest with the client. Employees
with questions regarding the appearance of a conflict with a client should consult the Chief Compliance
Officer before taking any action that may result in an actual conflict.
• Employees will not take inappropriate advantage of their position with the firm.
• Employees are expected to act in the best interest of each of our clients.
• Employees are expected to comply with federal securities laws.
• Employees are expected to exercise diligence and care in maintaining and protecting our client’s non-public,
confidential information.
• Employees are also expected to not divulge information regarding BFA’s securities recommendations or
client securities holdings to any individual outside of the firm, except as necessary or permitted by law.
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The Code of Ethics addresses, among other things:
• Prohibited Activities;
• Gifts and Entertainment;
• Business Activities of Employees away from BFA;
• Political Contributions;
• Certification and Delivery of the Code of Ethics;
• Compliance with Laws and Regulations;
• Personal Securities Transactions, Reporting, and Review;
• Reporting of Violations of the Code of Ethics; and
• Training and Education
BFA permits employees of the firm to purchase or sell securities for personal accounts in which they recommend
to clients. This creates an inherent conflict in that an employee could attempt to obtain a better execution price
than that afforded to a client.
Employees are expected to purchase or sell a security for their personal accounts only after trading of that same
security has been completed in client accounts. Personal accounts of employees include all accounts for family
members living within the employee’s household and accounts over which the employee has authority even
though the account owner does not live within the same household as the employee.
Employees are required to report securities transactions and holdings for all accounts in which the employee has
a direct or indirect beneficial ownership interest. This includes personal securities information of any family
member living within the same household as the employee.
Under the Code of Ethics, BFA has adopted procedures designed to reduce or eliminate conflicts of interest that
this could potentially cause. These policies are designed to discourage and prohibit personal trading that would
disadvantage clients. The Code of Ethics also provides for disciplinary action as appropriate for violations.
A copy of BFA's Code of Ethics is available upon request to any client or prospective client. Requests should be
directed to Brandon Langley, Chief Compliance Officer and Managing Partner of Blueprint, at
Brandon.Langley@blueprintip.com.
ITEM 12 BROKERAGE PRACTICES
In the event that the client requests that BFA recommend a broker-dealer/custodian for execution and/or
custodial services (exclusive of those clients that may direct BFA to use a specific broker-dealer/custodian), BFA
generally recommends that investment management accounts be maintained at Charles Schwab (“Schwab”). Prior
to engaging BFA to provide investment management services, the client will be required to enter into a formal
Investment Advisory Agreement with BFA setting forth the terms and conditions under which BFA shall manage
the client’s assets, and a separate custodial/clearing agreement with each designated broker-dealer/custodian.
Factors that BFA considers in recommending Schwab (or any other broker-dealer/custodian to clients) include
historical relationship with BFA, financial strength, reputation, execution capabilities, pricing, research, and
service. Although the commissions and/or transaction fees paid by BFA’s clients shall comply with BFA’s duty to
obtain best execution, a client may pay a commission that is higher than another qualified broker-dealer might
charge to affect the same transaction where BFA determines, in good faith, that the commission/transaction fee
is reasonable in relation to the value of the brokerage and research services received. In seeking best execution,
the determinative factor is not the lowest possible cost, but whether the transaction represents the best
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qualitative execution, taking into consideration the full range of a broker dealer’s services, including the value of
research provided, execution capability, commission rates, and responsiveness. Accordingly, although BFA will
seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client account
transactions. The brokerage commissions or transaction fees charged by the designated broker-dealer/custodian
are exclusive of, and in addition to, BFA’s investment management fee. BFA’s best execution responsibility is
qualified if securities that it purchases for client accounts are mutual funds that trade at net asset value as
determined at the daily market close.
DIRECTED BROKERAGE
BFA does not generally accept directed brokerage arrangements (when a client requires that account transactions
be affected through a specific broker-dealer). In such client directed arrangements, the client will negotiate terms
and arrangements for their account with that broker-dealer, and BFA will not seek better execution services or
prices from other broker-dealers or be able to “batch” the client’s transactions for execution through other
broker-dealers with orders for other accounts managed by BFA. As a result, client may pay higher commissions or
other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account
than would otherwise be the case. Please Note: In the event that the client directs BFA to effect 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 effect account transactions through alternative clearing
arrangements that may be available through BFA.
TRADE AGGREGATION
To the extent that BFA provides investment management services to its clients, the transactions for each client
account generally will be affected independently, unless BFA decides to purchase or sell the same securities for
several clients at approximately the same time. In certain situations, BFA will (but is not obligated to) combine or
“bunch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate
equitably among BFA’s clients differences in prices and commissions or other transaction costs that might have
been obtained had such orders been placed independently. Under this procedure, 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. BFA shall not receive any additional compensation or remuneration as a result of such
aggregation.
TRADE ERRORS
As a fiduciary, BFA has the responsibility to execute orders correctly, promptly, and in the best interests of clients.
In the event an error occurs in the handling of client transactions due to the firm’s actions or inactions, BFA’s
policy is to identify and correct trade errors as promptly as possible without disadvantaging the client. If the trade
error is the responsibility of BFA, client transactions will be corrected and the firm will be responsible for any client
loss resulting from the error. BFA generally follows the error resolution practices that clients’ brokers and
custodians establish, which, for certain accounts, will result in BFA retaining de minimis gains that result from
trade errors.
SOFT DOLLARS
Consistent with obtaining best execution for clients, BFA directs certain brokerage transactions for client portfolios
to brokers (like Schwab) who provide various services to BFA and, indirectly, to its clients. These services are based
on the safe harbor requirements of Section 28(e) of the Securities Exchange Act of 1934 and are designed to
augment our own internal research, investment strategy, and other firm capabilities. Among the services BFA
receives from Schwab, if an account is transitioned from another broker-dealer/custodian to Schwab for execution
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and/or custodial services, BFA may receive reimbursement from Schwab to cover the expenses related to
facilitating this transition.
ITEM 13 REVIEW OF ACCOUNTS
For those clients to whom BFA provides investment supervisory services, account reviews are conducted on an
ongoing basis by BFA’s Principals and representatives. All investment supervisory clients are advised that it
remains their responsibility to advise BFA of any changes in their investment objectives and/or financial situation.
All clients (in person or via telephone) are encouraged to review financial planning issues (to the extent applicable),
investment objectives and account performance with BFA on an annual basis.
At the client’s request and typically no less than annually, BFA portfolio managers meet with their clients and
review their accounts.
ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION
As a matter of firm practice, BFA does not currently pay referral fees to affiliated or independent persons or firms
(“Solicitors”) for introducing certain clients to us.
BFA receives an economic benefit from Schwab in the form of the support products and services it makes available
to the firm and other independent investment advisors that have their clients maintain accounts at Schwab. These
products and services, how they benefit the firm, and the related conflicts of interest are described above (see
Item 12 – Brokerage Practices). The availability of Schwab’s products and services to the firm is not based on our
giving particular investment advice, such as buying particular securities for our client.
ITEM 15 CUSTODY
Custody is defined as any legal or actual ability by us to access client funds or securities. Since all client funds and
securities are maintained with a qualified custodian, we don’t take physical possession of client assets. However,
under government regulations, we are deemed to have custody of client assets due to various arrangements
which give us legal access to client funds.
For example, we are deemed to have custody of client assets when: (i) clients authorize us to instruct their
qualified custodian to deduct advisory fees directly from their account, when (ii) clients grant us authority to move
their money to another person’s account and when (iii) we or affiliated employees act as both trustee and adviser
to a trust. Each client’s institutional custodian maintains actual custody of the client’s assets. Clients receive
account statements directly from their account’s custodian at least quarterly. They will be sent to the postal
mailing address or email address that was provided to the custodian. Clients should carefully review those
statements promptly when they receive them. In addition, BFA submits itself to an annual surprise audit by an
independent accountant to verify client assets.
ITEM 16 INVESTMENT DISCRETION
The client determines whether to engage BFA to provide investment advisory services on a discretionary basis.
Prior to BFA assuming discretionary authority over a client’s account, the client shall be required to execute an
Investment Advisory Agreement, naming BFA as the client’s attorney and agent in fact, granting BFA full authority
to buy, sell, or otherwise effect investment transactions involving the assets in the client’s name found in the
discretionary account.
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Clients who engage BFA on a discretionary basis may, at any time, impose restrictions, in writing, on BFA’s
discretionary authority (i.e. limit the types/amounts of particular securities purchased for their account, exclude
the ability to purchase securities with an inverse relationship to the market, limit or proscribe BFA’s use of margin,
etc.).
ITEM 17 VOTING CLIENT SECURITIES
BFA has adopted policies and procedures with respect to the voting of proxies related to securities held in select
client accounts. (Please note, however, the client shall maintain exclusive responsibility for all legal proceedings
or other type events pertaining to the account assets, including, but not limited to, class action lawsuits.). If a
client delegates responsibility for voting proxies to BFA, the firm shall evaluate and vote proxies in a manner
consistent with the clients best interests. When requested to vote proxies, BFA will act in the best interest of the
client and vote in a manner that it determines best serves the interest of maximizing shareholder value for all
clients. The policy of BFA is to vote all proxies from a specific issuer the same way for each client absent qualifying
restrictions from a client.
BFA’s clients are permitted to place reasonable restrictions on its voting authority in the same manner that
restrictions are applied to all other aspects of account investment as dictated through the client’s unique
investment policy. Further, there may be times when BFA’s management determines that refraining from voting
a proxy is in a client’s best interest, such as when the cost of voting a proxy exceeds the expected benefit to the
client.
If BFA determines that a material conflict of interest exists in voting a proxy, then it will review the matter with
the client, who will then together determine whether to direct the affected client to vote their proxies themselves,
or to address the voting issues through other objective means such as voting in a manner consistent with a
predetermined voting policy or receiving an independent third party voting recommendation.
BFA’s Management Committee and the CCO are responsible for the implementation and monitoring of BFA’s
proxy voting process.
Clients may obtain information regarding how BFA voted their proxies, and/or request a copy of BFA’s Proxy
Voting Policy by contacting Brandon Langley, Chief Compliance Officer at Brandon.Langley@blueprintip.com.
ITEM 18 FINANCIAL INFORMATION
Under no circumstances does Blueprint require or solicit payment of fees in excess of $1,200 more than six months
in advance of services rendered. Blueprint does not have any financial issues that would impair its ability to
provide services to clients, and Blueprint has not been the subject of a bankruptcy petition at any time.
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