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WRAP BROCHURE
Peace of Mind Wealth Management (CRD 317067), brochure dated September 25, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
I T E M 1 – C O V E R P A G E
4101 Lake Boone Trail, Suite 111
Raleigh NC 27607
P: 919-787-8866
F: 919-944-4177
https://www.pomwealth.net
Appendix 1 of Form ADV: Wrap Fee Program Brochure
September 1, 2026
This wrap fee program brochure provides information about the qualifications and business practices of POM
Investment Strategies, LLC, which does business as, Peace of Mind Wealth Management (“POM”). If you have
any questions about the contents of this brochure, please contact us at 919-787-8866. The information in this
brochure has not been approved or verified by the United States Securities and Exchange Commission or by
any state securities authority. Additional information about POM also is available on the SEC’s website at
www.adviserinfo.sec.gov. 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. POM is a Registered
Investment Advisor. Registration as an Investment Advisor with the United States Securities and Exchange
Commission or any state securities authority does not imply a certain level of skill or training.
I T E M 2 - M A T E R I A L C H A N G E S
MATERIAL CHANGES SINCE THE LAST ANNUAL UPDATE
POM Investment Strategies, LLC was established as a new Registered Investment Advisor in November
2021 with the Securities and Exchange Commission (“SEC”), under the rules and regulations of the US
Investment Advisers Act of 1940, as amended (the "Advisers Act"). POM will provide updates to this
document annually within 120 days of the close of the fiscal year, or more frequently in the event of
material changes.
The following material changes have occurred since our previous annual amendment filing on March 9,
2026:
Our firm utilizes the services of Nationwide Annuities, where we offer commission-free
insurance products. Please refer to Items 4 and 9 of this brochure for more information.
ANNUAL UPDATE
The Material Changes section of this brochure will be updated annually or when material changes occur
since the previous release of the Firm Brochure. Each year, we will ensure that you receive a summary of
any material changes to this and subsequent brochures by April 30th. We will further provide you with
our most recent brochure at any time at your request, without charge. You may request a brochure by
contacting us at 919-787-8866.
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I T E M 3 - T A B L E O F C O N T E N T S
Item 1 – COVER PAGE ..................................................................................................................................................... 1
Item 2-MATERIAL CHANGES ........................................................................................................................................ 2
Item 3- TABLE OF CONTENTS ........................................................................................................................................ 3
Item 4- SERVICES, FEES AND COMPENSATION .......................................................................................................... 4
Item 5- ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ................................................................................... 9
Item 6- PORTFOLIO MANAGER SELECTION AND EVALUATION ............................................................................... 9
Item 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ............................................................... 14
Item 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS ...................................................................................... 14
Item 9-ADDITIONAL ITEMS ......................................................................................................................................... 14
PRIVACY POLICY .......................................................................................................................................................... 19
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I T E M 4 - S E R V I C E S ,
F E E S A N D C O M P E N S A T I O N
POM offers both wrap and non-wrap investment options. For accounts utilizing AEWM’s platform, those
accounts are available on a wrap fee program. A wrap fee program allows Clients to pay a specified fee for
investment advisory services and the execution of transactions. For accounts under the wrap program, POM is
the sponsor and manager of a wrap fee. Clients do not pay brokerage commissions, markups or transaction charges
for execution of transactions in addition to the advisory fee however, most investments trade without transaction
fees today, so the Firm’s payment of these and other incidental custodial related expenses should not be
considered a significant factor in determining the relative value of the Firm’s wrap program. Clients receive
investment management services through POM. POM utilizes a third-party, AEWM, for the billing of these
services through a wrap program. Fees will be calculated as a percentage of assets under management (AUM)
based on the average daily balance of the account(s) and deducted from Client account(s) in arrears on a monthly
basis. Although neither Client nor the Firm pay a transaction charge for transactions in the account(s), Client
should be aware that the Firm pays AEWM an annual administrative / asset-based pricing fee based upon a
percentage of assets under management within the wrap fee program account. Because the Firm pays an annual
administration / asset-based pricing fee in lieu of paying transaction charges, there is a conflict of interest. Client
understands that the cost to the Firm of the annual administration fee may be a factor that he/she considers when
deciding how much of an annual advisory fee to assess to the account(s).
INVESTMENT MANAGEMENT SERVICES
We manage advisory accounts on a non-discretionary and discretionary basis. Once we determine a client’s
profile, income need, and investment plan, we execute the day-to- day transactions with or without prior consent,
depending on the client’s agreement with our firm. Account supervision is guided by the client’s written profile
and investment plan. We primarily allocate client assets among various mutual funds, exchange-traded funds
(“ETFs”), cash, and individual debt (bonds) and equity securities in accordance with their stated investment
objectives. In some cases, our Firm does utilize pre-built portfolios for clients based on their risk tolerance and
time horizon.
In personal discussions with clients, we determine their objectives, time horizons, risk tolerance and liquidity and
income needs. As appropriate, we also review their prior investment history, as well as family composition and
background. Based on client needs, we develop the client’s personal profile and investment plan. We then create
and manage the client’s investments based on that policy and plan. It is the client’s obligation to notify us
immediately if circumstances have changed with respect to their goals and income needs.
When managing client accounts through our firm’s investment management services, we most often manage a
client’s Account in accordance with one or more investment models developed either internally by our Firm or
developed externally by Model Managers. When client Accounts are managed using models, investment selections
are based on the underlying model and we do not develop customized (or individualized) portfolio holdings.
With our discretionary investment management relationship, our Firm will make changes to the portfolio, as we
deem appropriate, to meet your financial objectives. We trade these portfolios based on the combination of our
market views and your objectives, using our investment philosophy and strategies as described in Item 8 of this
Brochure. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio
is managed in a manner consistent with those needs and objectives. You will have the ability to leave standing
instructions with us to refrain from investing in particular industries or invest in limited amounts of securities.
You are advised and are expected to understand that our past performance is not a guarantee of future results.
Certain market and economic risks exist that adversely affect an account’s performance. This could result in
capital losses in your account.
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If a non-discretionary relationship is in place, calls will be placed to the client presenting the recommendation
made including a rebalancing recommendation and only upon your authorization will any action be taken on your
behalf. Our clients should note that being in a discretionary or non-discretionary account does not affect the
management of the accounts. It is the decision of the client on what type account they elect to open with our Firm
– a discretionary account without prior notification of investment trades or a non- discretionary account as
described above.
We will not enter into an investment adviser relationship with a prospective client whose investment objectives
are considered incompatible with our investment philosophy or strategies or where the prospective client seeks
to impose unduly restrictive investment guidelines. However, Clients have the ability to impose reasonable
restrictions on the management of their accounts, including the ability to instruct the firm not to purchase certain
securities.
We do have limited authority to direct the Custodian to deduct our investment advisory fees from accounts, but
only with the appropriate written authorization from clients.
Clients may engage us to advise on certain investment products that are not maintained at our Firm’s
recommended custodian, such as variable life insurance, annuity contracts, and assets held in employer sponsored
retirement plans. Where appropriate, we provide advice about any type of held away account that is part of a client
portfolio.
You are advised and are expected to understand that our past performance is not a guarantee of future results.
Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital
losses in your account.
ADVISORY ANNUITIES SERVICES
The Firm may recommend advisory annuities, including products offered through Nationwide Advisory Solutions,
when appropriate for a client’s objectives, financial circumstances, time horizon, and need for retirement income
or other contract features. The client purchases the annuity directly from the issuing insurance company. The Firm
may assist with evaluating available contracts and features and, as agreed with the client, provide ongoing advice
regarding the annuity and its investment options.
USE OF THIRD-PARTY MONEY MANAGERS
If deemed appropriate, our Firm has the ability to utilize third party money mangers. The determination to use a
particular model or models is based on each client’s individual investment goals, objectives and mandates. Our
Firm has entered into an agreement with AE Wealth Management, LLC (“AEWM”), an SEC registered investment
adviser, to provide asset management services that include:
• Third party model money managers
• Portfolio managers
• Strategists
Through your Agreement with our Firm, clients authorize our Firm and AEWM discretion to select third party,
non-affiliated investment managers (“Model Managers”) to design and manage model portfolios.
Our Firm has access to AEWM’s reporting systems, client relationship management systems and workflow
systems to assist clients to establish an advisory account. Due to this arrangement, AEWM will have access to
client information, but AEWM will not serve as an investment advisor to our clients. Peace of Mind Wealth
Management and AEWM are non-affiliated companies. AEWM charges our Firm an annual fee for each account
administered by AEWM. The annual fee is paid from the portion of the management fee retained by us. Clients
receive continuous investment advice based on investment objective, risk profile and time-horizon. While
investment strategies and recommendations are tailored to the individual needs of each client, they consist of an
asset allocation consistent as outlined in Item 9 of this Brochure.
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WRAP FEE PROGRAM
POM offers both wrap and non-wrap investment options. For accounts utilizing AEWM’s platform, those
accounts are available on a wrap fee program. For accounts under the wrap program, POM is the sponsor and
manager of a wrap fee program (i.e., an arrangement where brokerage commissions and transaction costs are
absorbed by the Firm). The fee covers transaction costs or commissions resulting from the management of your
accounts. All other investment recommendations offered by Adviser will not be included as part of the wrap fee
program. It is important to note for accounts held in the wrap fee program, most investments trade without
transaction fees today, so our payment of these and other incidental custodial related expenses should not be
considered a significant factor in determining the relative value of our wrap program. The benefits under a wrap
fee program depend, in part, upon the size of the account, the costs associated with managing the account, and
the frequency or type of securities transactions executed in the account. For example, a wrap fee program may
not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial
period of time, cash or cash equivalent investments, fixed income securities or no-transaction-fee mutual funds,
or any other type of security that can be traded without commissions or other transaction fees. We have a conflict
of interest because we have a financial incentive to maximize our compensation by seeking to reduce or minimize
the total costs incurred in your account(s) subject to a wrap fee. In order to evaluate whether a wrap fee
arrangement is appropriate for you, you should compare the agreed-upon Wrap Program Fee and any other costs
associated with participating in our Wrap Fee Program with the amounts that would be charged by other advisers,
broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services
comparable to those provided under the Wrap Fee Program.
RELATIVE COST OF THE PROGRAM
Due to the relationship with our platform provider, our Firm provides its advisory services, for certain accounts,
on a wrap fee basis as a wrap program sponsor. Under our wrap program, you will receive advisory services,
financial planning services, the execution of securities brokerage transactions, custody and reporting services for
a single specified advisory fee. The benefits under a wrap fee program depend, in part, upon the size of the account,
the costs associated with managing the account, and the frequency or type of securities transactions executed in
the account. A wrap fee program may not be suitable for all accounts, including but not limited to accounts holding
primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or
no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other
transaction fees. We manage wrap accounts on a discretionary basis. When managing a client’s account on a wrap
fee basis, we receive as compensation for our advisory services, the balance of the total wrap fee you pay after
custodial, trading, and other management costs (including execution and transaction fees) have been deducted.
Accordingly, we have a conflict of interest because we have a financial incentive to maximize our compensation
by seeking to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee. Schwab and
other custodians have eliminated commissions for online trades of U.S. equities, ETFs, and options (subject to a
$0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not
have to pay any commissions to the Custodian. We encourage you to review the Custodian’s pricing to compare
the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter
into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory
services separately.
INVESTMENT MANAGEMENT SERVICE FEES
A wrap fee program allows Clients to pay a specified fee for investment advisory services and the execution of
transactions. Clients do not pay brokerage commissions, markups or transaction charges for execution of
transactions in addition to the advisory fee however, most investments trade without transaction fees today, so
the Firm’s payment of these and other incidental custodial related expenses should not be considered a significant
factor in determining the relative value of the Firm’s wrap program.
Clients receive investment management services through POM. POM utilizes a third-party IMO (AEWM) for the
billing of these services through a wrap program. Fees will be calculated as a percentage of assets under
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management (AUM) based on the average daily balance of the account(s) and deducted from Client account(s) in
arrears on a monthly basis.
Although neither Client nor the Firm pay a transaction charge for transactions in the account(s), Client should be
aware that the Firm pays AEWM an annual administrative / asset-based pricing fee based upon a percentage of
assets under management within the wrap fee program account. Because the Firm pays an annual administration
/ asset-based pricing fee in lieu of paying transaction charges, there is a conflict of interest. Client understands
that the cost to the Firm of the annual administration fee may be a factor that he/she considers when deciding
how much of an annual advisory fee to assess to the account(s).
POM’s annual fees are based upon a percentage of assets under management not to exceed 2.00%. If services
commenced in the middle of the billing period, then the prorated fee for that billing period and any fees due to the
Firm will be deducted from the Client’s account prior to termination. Clients whose assets under management do
not reach our portfolio minimum of $800,000 will pay a fixed fee of $12,000 a year until which time they meet the
minimum portfolio requirement.
Although POM has established a maximum annual fee as stated above, we retain the discretion to negotiate
alternative fees on a client-by-client basis. Client facts, circumstances and needs are considered in determining
the fee schedule. These factors include the complexity of the client, assets to be placed under management,
anticipated future additional assets, related accounts, portfolio style, account composition, reports, among others.
The specific annual fee schedule is identified in the contract between the adviser and the client. Fees are assessed
on all assets under management, including securities, cash and money market balances. Our employees and their
family-related accounts are charged a reduced fee for our services.
At our discretion, we may aggregate asset amounts in accounts from your same household together to determine
the advisory fee for all your accounts. We may do this, for example, where we also service accounts on behalf of
your minor children, individual and joint accounts for a spouse, and/or other types of related accounts. This
consolidation practice is designed to allow the client the benefit of an increased asset total, which could potentially
cause your account(s) to be assessed a lower advisory fee based on the asset levels under management with POM.
Either POM or the client may terminate the management agreement immediately upon written notice to the other
party. The management fee will be pro-rated to the date of termination. Upon termination, the client is
responsible for monitoring the securities in your account, and we will have no further obligation to act or advise
with respect to those assets.
ADVISORY ANNUITIES FEES
If the Firm provides ongoing advice regarding an advisory annuity, the contract value may be included in the assets
used to calculate the Firm’s advisory fee, as specified in the client’s advisory agreement. The advisory fee is
separate from charges imposed under the Nationwide annuity contract, which may include contract, investment
option, and optional benefit charges. These charges vary by product and are described in the applicable contract
documents and prospectus, if any. Clients should review the applicable contract documents and prospectus, if any,
before purchasing an annuity. With the client’s authorization, the Firm’s advisory fee may be deducted from the
annuity contract. The Firm does not receive an insurance commission from the sale of an advisory annuity
recommended under this arrangement. The Firm has a financial incentive to recommend including an annuity in
the assets on which it charges an advisory fee. The Firm addresses this conflict by evaluating whether the
recommendation and ongoing advisory services are appropriate for the client and by disclosing the applicable fees
before the client purchases the contract.
OTHER ADDITIONAL FEES
Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from
other registered (or unregistered) investment advisers for similar or lower fees.
Mutual Fund Fees: Mutual funds often offer multiple share classes with differing internal fee and expense
structures. POM endeavors to identify and utilize the share class with the lowest internal fee and expense
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structure for each mutual fund. However, instances occur in which the lowest cost share class is not used. These
instances include but are not limited to: Instances in which a certain custodian has a share class available that has
a lower internal fee and expense structure than is available for the same mutual fund at other custodians. In such
instances, POM will select the lowest cost share class available at the custodian that holds your account even
though a lower cost share class is available at another custodian. Instances in which the custodian that holds your
account offers others a share class with a lower internal fee and expense structure than what is available to POM
at the same custodian. In such instances, POM will select the lowest cost share class that the custodian makes
available. This situation sometimes occurs because the custodian places conditions on the availability of the lower
cost share class that POM has determined are not appropriate to accept due to additional costs imposed by said
conditions. Instances in which a share class with a lower internal fee and expense structure becomes available
after the share class you hold was purchased. POM periodically monitors this circumstance. However, a share class
with a lower internal fee may become available between the time of your purchase and POM’s next review.
Instances in which a share class with a lower internal fee and expense structure than the share class you currently
hold is available at your custodian, but where POM is prevented by either the custodian or the fund sponsor from
converting to the lower cost share class. Additionally, POM does not convert to a share class with a lower internal
fee and expense structure if the conversion will cause a taxable event or other expense/cost to you that negates
the advantage of the lower cost share class. Instances in which a Strategist selects a share class for inclusion in a
model that is not the lowest cost share class available. Whenever possible, POM works with Strategists to ensure
they are selecting the lowest cost share class available for inclusion in their model portfolios. However, certain
Strategists make their investment selections without any input from POM. In such cases, POM implements the
models as directed by the Strategist and does not screen for the lowest mutual fund share class available. Instances
in which you are a TPRIA Program Client or a Co-Adviser Program Client. In such circumstances, POM implements
the mutual fund selection instructions provided by your TPRIA or Co-Adviser Program Adviser and does not
screen for the lowest mutual fund share class available. Instances in which you make your own investment
selections in a Client-Directed Account. In such circumstances, POM does not screen for the lowest mutual fund
share class available.
Financial Institution Consulting Fees: For providing platform services to RIAs and ERAs, Nationwide receives
service fees from the insurers that offer their commission free products through the platform. These service fees
are based on the insurance premiums received by the insurers from Nationwide members’ clients. Nationwide is
licensed as an insurance producer in Ohio and other jurisdictions where required to perform the platform services.
Its representatives are also licensed as insurance producers, appointed as insurance agents of the insurers offering
their products through the platform, and registered representatives of various broker dealers.
Regulatory Fees To facilitate the execution of trades, regulatory Trading Activity Fees (TAF) are added to
applicable sales transactions. The Securities and Exchange Commission (SEC) regulatory fee is assessed on client
accounts for sell transactions, and a FINRA fee is assessed on client accounts for sell transactions, for certain
covered securities. This fee is not charged by our Firm but is accessed and collected by the custodian. The
Custodian that our Firm uses, is a FINRA member firm. These fees recover the costs incurred by the SEC and
FINRA, for supervising and regulating the securities markets and securities professionals. The fee rates vary
depending on the type of transaction and the size of that transaction. For more information on the SEC and FINRA
fees, please visit their websites:
www.sec.gov/fast-answers/answerssec31htm.html
www.finra.org/industry/trading-activity-fee
NON-TRANSACTION FEE (NTF) MUTUAL FUNDS
When selecting investments for our clients’ portfolios we might choose mutual funds on your account custodian’s
Non-Transaction Fee (NTF) list. This means that your account custodian will not charge a transaction fee or
commission associated with the purchase or sale of the mutual fund. The mutual fund companies that choose to
participate in your custodian’s NTF fund program pay a fee to be included in the NTF program. The fee that a
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mutual fund company pays to participate in the program is ultimately borne by the owners of the mutual fund
including clients of our Firm . When we decide whether to choose a fund from your custodian’s NTF list or not, we
consider our expected holding period of the fund, the position size and the expense ratio of the fund versus
alternative funds. Depending on our analysis and future events, NTF funds might not always be in your best
interest.
ADMINISTRATIVE SERVICES
Through the Firm’s relationship with AE Wealth Management (AEWM), the Firm utilizes AEWM’s technology
platform to support data reconciliation, performance reporting, fee calculation and billing, research, client database
maintenance, quarterly performance evaluations, payable reports, web site administration, models, trading
platforms, and other functions related to the administrative tasks of managing client accounts. Due to this
arrangement, AEWM will have access to client information, but AEWM will not serve as an investment Advisor
to Clients. POM and AEWM are non-affiliated companies. AEWM charges the Firm an annual fee for each account
administered by AEWM. The annual fee is paid from the portion of the management fee retained by us.
I T E M 5 - A C C O U N T R E Q U I R E M E N T S A N D T Y P E S O F
C L I E N T S
POM works with the following types of clients: individuals, high net-worth individuals, corporations, foundations,
trusts, and charitable organizations.
We impose a minimum household value of $800,000 to initiate our firm’s advisory and asset management services,
however, this minimum requirement is negotiable.
I T E M 6 - P O R T F O L I O M A N A G E R S E L E C T I O N A N D
E V A L U A T I O N
PORTFOLIO MANAGER SELECTION
Our Firm serves as the sponsor and portfolio manager for our Wrap Fee Program.
RELATED PERSONS
Our Firm’s investment adviser representatives serve as the portfolio manager for the services under this Wrap
Fee Program. We only manage this wrap fee program and we do not act as portfolio manager for any third-party
wrap fee programs.
SUPERVISED PERSONS
Our investment adviser representatives serve as the portfolio manager for the wrap fee program described in this
wrap fee program brochure. Please refer to the Items 4 and 8 of the Part 2A Disclosure Brochure for details on the
services provided by our Firm. For information related to the background of our supervised persons, please see
Items 9 and 11 of the Part 2A Disclosure Brochure.
ADVISORY BUSINESS
Refer to Item 4 of this Wrap Fee Brochure for information about our wrap fee advisory program.
Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the
portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the
level of difficulty this would entail in managing the account.
PARTICIPATION IN WRAP FEE PROGRAMS
We offer the wrap fee program to clients who our Firm utilizes a third-party sub-adviser through AEWM. Our
wrap fee program is managed on an individualized basis according to the client’s investment objectives, financial
goals, risk tolerance, etc.
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PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT
Our Firm does not engage in performance-based fees. No supervised person is compensated by performance-
based fees. Performance-based fees may create an incentive for the advisor to recommend an investment that
may carry a higher degree of risk.
POM takes a macro-environmental approach to tactical asset allocation with sector rotation and uses a relative
growth/value framework in determining sub-asset classes. This top-down method allows POM to assess the
investing landscape and provide recommendations as to when and where it may be advantageous to modify
exposures within the asset classes, market segments, and sectors.
PROXY VOTING
As a matter of POM policy, POM does not vote proxies on behalf of clients. Therefore, it is your responsibility to
vote all proxies for securities held in your Account. The client will receive proxies directly from the qualified
custodian or transfer agent; we will not provide the client with the proxies. Although we do not vote client proxies,
if the client does have a question about a particular proxy feel free to contact the custodian directly.
GROWTH STRATEGIES: POM’s growth strategies consist of investments spanning a broad range of asset classes
that are selected for their long-term and short-term risk/return characteristics as well as their correlation to the
overall markets and appropriateness for each client’s portfolio. The resulting blended allocation is used as the
foundation for the client's growth portfolio. Portfolio rebalancing is discretionary and will be based on individual
portfolio considerations. There is no guarantee as to the number of times a portfolio is rebalanced each year. Other
asset classes and opportunistic investments are added to the growth portfolio to create a customized allocation
that is appropriate for client’s investment objectives, time horizon, and risk tolerance. Examples of investments
which may be included as part of POM’s growth strategies include individual equities and exchange traded funds
(ETFs).
FIXED INCOME STRATEGIES: Fixed income investments such as bonds, structured notes, and certificates of
deposit are intended to provide diversification, generate income, and to preserve and protect assets. Generally,
the stabilizing influence of fixed income comes at the cost of lower returns relative to growth investments. POM’s
fixed income portfolios generally consist of high quality domestically issued bonds, both taxable and tax-free.
Examples of investments which may be included as part of POM’s fixed income strategies include individual
government, municipal, and corporate bonds, structured notes, certificates of deposits, exchange traded funds
(ETFs), and money markets.
METHODS OF ANALYSIS
While there may be some similarities in the portfolios created by our Firm, we understand that every client has
their own unique planning needs. We have the ability and flexibility to create portfolios to help our client achieve
their goals. We may utilize the following forms of analysis:
Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic
and financial factors (including the overall economy, industry conditions, and the financial condition and
management of the company itself) to determine if the company is underpriced (indicating it may be a
good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt
to anticipate market movements. This presents a potential risk, as the price of a security can move up or
down along with the overall market regardless of the economic and financial factors considered in
evaluating the stock.
Quantitative Analysis: We use mathematical ratios and other performance appraisal methods in an
attempt to obtain more accurate measurements of a model manager’s investment acumen, idea
generation, consistency of purpose and overall ability to outperform their stated benchmark throughout a
full market cycle. Additionally, we perform periodic measurements to assess the authenticity of returns. A
risk in using quantitative analysis is that the models used may be based on assumptions that prove to be
incorrect.
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Technical Analysis: We use this method of evaluating securities by analyzing statistics generated by
market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's
intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity.
Technical analysts believe that the historical performance of stocks and markets are indications of future
performance. Technical analysis is even more subjective than fundamental analysis in that it relies on
proper interpretation of a given security's price and trading volume data. A decision might be made based
on a historical move in a certain direction that was accompanied by heavy volume; however, that heavy
volume may only be heavy relative to past volume for the security in question, but not compared to the
future trading volume. Therefore, there is the risk of a trading decision being made incorrectly, since future
trading volume is unknown. Technical analysis is also done through observation of various market
sentiment readings, many of which are quantitative. Market sentiment gauges the relative degree of
bullishness and bearishness in a given security, and a contrarian investor utilizes such sentiment
advantageously. When most traders are bullish, then there are very few traders left in a position to buy the
security in question, so it becomes advantageous to sell it ahead of the crowd. When most traders are
bearish, then there are very few traders left in a position to sell the security in question, so it becomes
advantageous to buy it ahead of the crowd. The risk in utilization of such sentiment technical measures is
that a very bullish reading can always become more bullish, resulting in lost opportunity if the money
manager chooses to act upon the bullish signal by selling out of a position. The reverse is also true in that
a bearish reading of sentiment can always become more bearish, which may result in a premature purchase
of a security.
Asset Allocation: Rather than focusing primarily on securities selection, we attempt to identify an
appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk
tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular
security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will
change over time due to stock and market movements and, if not corrected, will no longer be appropriate
for the client’s goals.
RISK OF LOSS
A client’s investment portfolio is affected by general economic and market conditions, such as interest rates,
availability of credit, inflation rates, economic conditions, changes in laws and national and international political
circumstances.
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. POM will assist Clients in determining an appropriate strategy
based on their tolerance for risk.
Each Client engagement will entail a review of the Client’s investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client’s account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client’s account(s). POM shall rely on the financial and other information provided by the Client or
their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform POM of any changes in financial condition, goals or
other factors that may affect this analysis.
Our methods rely on the assumption that the underlying companies within our security allocations are accurately
reviewed by the rating agencies and other publicly available sources of information about these securities, are
providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always
a risk that our analysis may be compromised by inaccurate or misleading information.
Investors should be aware that accounts are subject to the following risks:
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MARKET RISK - Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-
specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will
fluctuate, there is the risk that you will lose money and your investment may be worth more or less upon
liquidation.
FOREIGN SECURITIES AND CURRENCY RISK - Investments in international and emerging-market securities include
exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets
and political instability.
CAPITALIZATION RISK - Small-cap and mid-cap companies may be hindered as a result of limited resources or less
diverse products or services Their stocks have historically been more volatile than the stocks of larger, more
established companies.
INTEREST RATE RISK - In a rising rate environment, the value of fixed-income securities generally declines, and the
value of equity securities may be adversely affected.
CREDIT RISK - Credit risk is the risk that the issuer of a security may be unable to make interest payments and/or
repay principal when due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial
strength may affect a security’s value and thus, impact the fund’s performance.
LIQUIDITY RISK: Liquidity risk is the risk that there may be limited buyers for a security when an investor wants to
sell. Typically, this results in a discounted sale price in order to attract a buyer.
DEFAULT RISK - A default occurs when an issuer fails to make payment on a principal or interest payment.
EVENT RISK - Event risk is difficult to predict because it may involve natural disasters such as earthquakes or
hurricanes, as well as changes in circumstance from regulators or political bodies.
POLITICAL RISK - Political risk is the risk associated with the laws of the country, or to events that may occur there.
Particular political events such as a government’s change in policy could restrict the flow of capital.
DURATION RISK - Duration is a way to measure a bond's price sensitivity to changes in interest rates. The duration
of a bond is determined by its maturity date, coupon rate, and call feature. Duration is a method to compare how
different bonds will react to interest rate changes. If a bond has a duration of five (5) years it means that the value
of that security will decline by approximately five percent (5%) for every one percent (1%) increase in interest
rates.
REINVESTMENT RISK: Reinvestment risk is the risk that future interest and principal payments may be reinvested
at lower yields due to declining interest rates.
TAX RISK: For municipal bonds, depending on the client’s state of residence, the interest earned on certain bonds
may not be tax-exempt at the state level. Also, changes in federal tax policy may impact the tax treatment of
interest and capital gains of an investment.
REGULATORY RISK: Market participants are subject to rules and regulations imposed by one or more regulators.
Changes to these rules and regulations could have an adverse effect on the value of an investment.
CONCENTRATION RISK: The risk of amplified losses that may occur from having a large portion of your holdings in
a particular investment, asset class or market segment relative to your overall portfolio.
SECURITIES LENDING RISK - Securities lending involves the risk that the fund loses money because the borrower
fails to return the securities in a timely manner or at all. The fund could also lose money if the value of the collateral
provided for loaned securities, or the value of the investments made with the cash collateral, falls. These events
could also trigger adverse tax consequences for the fund.
EXCHANGE-TRADED FUNDS - ETFs face market-trading risks, including the potential lack of an active market for
shares, losses from trading in the secondary markets, and disruption in the creation/redemption process of the
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ETF. Any of these factors may lead to the fund’s shares trading at either a premium or a discount to its “net asset
value.”
CYBERSECURITY RISK - In addition to the Material Investment Risks listed above, investing involves various
operational and “cybersecurity” risks. These risks include both intentional and unintentional events at our Firm or
one of its third-party counterparties or service providers, that may result in a loss or corruption of data, result in
the unauthorized release or other misuse of confidential information, and generally compromise our firm’s ability
to conduct its business. A cybersecurity breach may also result in a third-party obtaining unauthorized access to
our clients’ information, including social security numbers, home addresses, account numbers, account balances,
and account holdings. Our Firm has established business continuity plans and risk management systems designed
to reduce the risks associated with cybersecurity breaches. However, there are inherent limitations in these plans
and systems, including that certain risks may not have been identified, in large part because different or unknown
threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because
our Firm does not directly control the cybersecurity systems of our third-party service providers. There is also a
risk that cybersecurity breaches may not be detected.
COMMODITIES RISK - Exposure to commodities in Adviser Clients accounts is in non-physical form, such as ETFs
or mutual funds, there are risks associated with the movement in gold prices and the ability of the fund or trust
manager to respond or deal with those price movements. There also may be initial charges as well as annual
management fees associated with the fund or trust.
EXCHANGE-TRADED FUND (“ETF”) AND MUTUAL FUND RISK - Investments in ETFs and mutual funds have unique
characteristics, including, but not limited to, the ETF or mutual fund’s expense structure. Investors of ETFs and
mutual funds held within POM client accounts bear both their POM portfolio’s advisory expenses and, indirectly,
the ETF’s or mutual fund’s expenses. Because the expenses and costs of an underlying ETF or mutual fund are
shared by its investors, redemptions by other investors in the ETF or mutual fund could result in decreased
economies of scale and increased operating expenses for such ETF or mutual fund. Additionally, the ETF or mutual
fund may not achieve its investment objective. Actively managed ETFs or mutual funds may experience significant
drift from their stated benchmark.
STRUCTURED NOTES - Structured products are designed to facilitate highly customized risk- return objectives.
While structured products come in many different forms, they typically consist of a debt security that is structured
to make interest and principal payments based upon various assets, rates, or formulas. Many structured products
include an embedded derivative component. Structured products may be structured in the form of a security, in
which case these products may receive benefits provided under federal securities law, or they may be cast as
derivatives, in which case they are offered in the over-the-counter market and are subject to no regulation.
Investment in structured products includes significant risks, including valuation, liquidity, price, credit, and market
risks. One common risk associated with structured products is a relative lack of liquidity due to the highly
customized nature of the investment. Moreover, the full extent of returns from the complex performance features
is often not realized until maturity. As such, structured products tend to be more of a buy-and-hold investment
decision rather than a means of getting in and out of a position with speed and efficiency. Another risk with
structured products is the credit quality of the issuer. Although the cash flows are derived from other sources, the
products themselves are legally considered to be the issuing financial institution’s liabilities. The vast majority of
structured products are from high-investment- grade issuers only. Also, there is a lack of pricing transparency.
There is no uniform standard for pricing, making it harder to compare the net-of-pricing attractiveness of
alternative structured product offerings than it is, for instance, to compare the net expense ratios of different
mutual funds or commissions among broker-dealers.
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ALTERNATIVE INVESTMENTS: Our firm’s use of alternative assets would be through registered funds only, for
example ETFs and/or ’40 Act Funds offered through the recommended Custodian platform. Alternative assets
may include a broad range of underlying assets including, but not limited to, hedge funds, private equity, venture
capital, and registered, publicly traded securities. Alternative investments are speculative, not suitable for all
clients and intended for only experienced and sophisticated investors who are willing to bear the high risk of the
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investment, which can include: loss of all or a substantial portion of the investment due to leveraging, short-selling,
or other speculative investment practices; lack of liquidity in that there may be no secondary market for the fund
and none expected to develop; volatility of returns; potential for restrictions on transferring interest in the fund;
potential lack of diversification and resulting higher risk due to concentration of trading authority with a single
advisor; absence of information regarding valuations and pricing; potential for delays in tax reporting; less
regulation and typically higher fees than other investment options such as mutual funds. The SEC requires
investors be accredited to invest in these more speculative alternative investments. Investing in a fund that
concentrates its investments in a few holdings may involve heightened risk and result in greater price volatility.
ARTIFICIAL INTELLIGENCE AND MACHINE LEARNING: Certain service providers utilized by the Firm to service client
accounts have artificial intelligence components, such as our client relationship management system that utilizes
artificial intelligence to summarize client meeting notes. The use of artificial intelligence and machine learning
includes increased risk of data inaccuracies and security vulnerabilities. Due to the rapid advancement of machine
learning technologies, future risks related to artificial intelligence are unpredictable. As a measure to mitigate
these risks to our clients, our Firm performs periodic due diligence of our service providers for assurance that the
service providers have appropriate controls in place to protect our clients’ information and to limit data
inaccuracies when artificial intelligence is used by the service provider.
I N F O R M A T I O N P R O V I D E D T O
I T E M 7 – C L I E N T
P O R T F O L I O M A N A G E R S
Our Firm is required to describe the type and frequency of the information it communicates to external managers
that may be involved in managing its Clients' investment portfolios. Through your Agreement with our Firm,
clients authorize our Firm and AEWM discretion to select third party, non-affiliated investment managers (“Model
Managers”) to design and manage model portfolios.
Our Firm has access to AEWM’s reporting systems, client relationship management systems and workflow
systems to assist clients to establish an advisory account. Due to this arrangement, AEWM will have access to
client information, but AEWM will not serve as an investment advisor to our clients.
I T E M 8 – C L I E N T C O N T A C T W I T H P O R T F O L I O
M A N A G E R S
Our Firm does not place restrictions on the client’s ability to contact and consult their financial advisor. As the
portfolio manager, clients are free to contact us at any time.
I T E M 9 - A D D I T I O N A L I T E M S
DISCIPLINARY INFORMATION
We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's
evaluation of our advisory business or the integrity of our management. Our Firm and our management personnel
have no material reportable disciplinary events to disclose. You may visit advisorinfo.sec.gov to review each
investment advisors individual disclosures or POMs disclosures.
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Our management personnel and investment advisor representatives may engage in outside business activities. As
such, these individuals can receive separate, yet customary commission compensation resulting from
implementing product transactions on behalf of investment advisory Clients. Clients are not under any obligation
to engage these individuals when considering the implementation of these outside recommendations. The
implementation of any or all recommendations is solely at the discretion of the Client.
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POM does not have an application pending to register, as a futures commission merchant, commodity pool
operator, a commodity trading adviser, or an associated person of the foregoing entities. Neither our Firm nor any
of its management persons are registered or have an application pending to register as a broker-dealer.
Insurance
Annuity Recommendations
Most POM investment advisor representatives (IARs) also provide insurance or annuities to their clients when
appropriate. Insurance, including fixed index annuities, are not offered through POM but are sold by insurance
licensed agents using various insurance companies. The issuing insurance companies are not affiliated with POM.
However, sometimes the fixed insurance product could be used as a replacement or alternative to the POM fixed
income portion of a portfolio. However, annuity products present their own differences from traditional fixed
income securities, such as bonds, including, but not limited to liquidity, tax implications, and underlying fees.
Unlike bonds, there is no secondary market for annuity products. Annuities also may be subject to caps,
restrictions, fees and surrender charges as described in the annuity contract. Any annuity guarantees are backed
by the financial strength and claims paying ability of issuer. POM does not charge management fees on
commission based fixed index annuities. However, if the IAR/insurance agent implements an insurance
transaction, the agent will receive a sales commission from the recommendation of an insurance product, like a
fixed index annuity. This creates a conflict of interest since the IAR/insurance agent is incentivized and earns
insurance commission(s) for implementing insurance product recommendations. This conflict is mitigated by the
IAR/insurance agent always acting in the best interest of the client and providing full and frank disclosure to the
client when such a conflict exists. If a POM IAR is licensed as an insurance agent and makes a recommendation
for transacting in a fixed annuity and/or life insurance product, this gives rise to conflicts of interest due to the
fact that such POM IAR is receiving remuneration in the form of commission and in some cases, other
compensation (such as a percentage of an organizations’ profits for selling fixed annuities and/or life insurance)
which incentives such IAR to sell that product. POM IARs mitigate this conflict by making recommendations that
are in the client’s best interest and are suitable for them based on their investment objectives and needs outlined
in the client’s investment policy statement.
Tax Services
The Firm has an affiliated tax services entity under common ownership, POM Tax Strategies, LLC. Radon Stancil
is managing member of POM Tax Strategies, LLC. Clients who require tax return preparation and filing services
may engage directly with POM Tax Strategies under a separate agreement and fee structure. This includes the
preparation and filing of individual tax returns and any related compliance work. The Firm and its personnel may
recommend tax services to investment advisory clients. POM Tax Strategies, LLC. charges separate fees from
investment advisory fees. The Firm and its personnel have an incentive to recommend tax services and this
incentive creates a conflict of interest between your interests and the Firm. Clients should note that they have
the right to decide whether or not to engage the services of our personnel. Further, clients should note they have
the right to decide whether to act on the recommendations and the right to choose any professional to execute
the advice for any tax services through our personnel or any licensed tax agent not affiliated with our Firm. We
recognize the fiduciary responsibility to place your interests first and have established policies in this regard to
avoid any conflicts of interest.
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Financial Institution Insurance & Consulting Services
POM has an arrangement with Nationwide Annuities ("Nationwide") where Nationwide serves as the
Representative of Record for broker dealer products. In this arrangement, Nationwide hires POM to manage the
investments held within the product. Nationwide pays POM an asset-based fee against the cash value of the
policies. Nationwide has licensed insurance agents, who are also registered representatives of various broker
dealers who are unaffiliated SEC-registered broker-dealers, and FINRA members. Through this arrangement,
Nationwide may also serve as an outsourced insurance entity for commission free insurance products. In this
arrangement, the end client engages POM directly to manage the investments within the product. POM is not
affiliated with either Nationwide or various broker dealers. Clients do not incur any additional fees for these
services.
Third Party Marketing Organization (IMO) – Advisors Excel
The Firm will utilize the services of Advisors Excel, a third-party insurance marketing organization ("IMO") to
select appropriate products. Advisors Excel is an affiliate of AE Wealth Management and our decision to work
with AE Wealth Management is significantly based on our IMO relationship with Advisors Excel. IMO’s offers
special incentive compensation to meet certain overall sales goals by placing annuities and/or other insurance
products through the IMO. The receipt of commissions and additional incentive compensation itself creates a
conflict of interest. Clients are not required to purchase any insurance products through us in our separate capacity
as insurance agents. The purpose of the IMO is to assist us in finding the insurance company that best fits the
client’s situation.
Advisors Excel and Advisors Excel Wealth Management provides marketing assistance and business development
tools to acquire new clients, technology with the goal of improving the client experience and our firm’s efficiency,
back office and operations support to assist in the processing of our insurance (through Advisors Excel) and
investment services (Advisors Excel Wealth Management) for clients, business succession planning, business
conferences and incentive trips for our firm. Although some of these services can benefit a client, other services
obtained by us from Advisors Excel such as marketing assistance, business development and incentive trips will
not benefit an existing client. The Firm can also receive bonus payments from an insurance company for selling a
targeted number of annuities during a specified period of time which creates a conflict of interest. Our Firm has
taken steps to manage these conflicts of interest by requiring that each investment adviser representative:
- only recommend insurance and annuities when in the best interest of the client and without regard to
the financial interest of our Firm and its investment adviser representative.
- not recommend insurance and/or annuities which result in its investment adviser representative
and/or our Firm receiving unreasonable compensation related to the recommendation; and,
- disclose material conflicts of interest related to insurance or annuity recommendations.
OTHER AFFILIATIONS
Radon Stancil, Managing Member of POM, is the author of the following books, podcasts and YouTube: Secure
Your Retirement, Get Off the Retirement Rollercoaster and Take Control of Your Retirement Plan. Mr. Stancil
receives compensation from the promotion of his aforementioned activities. All marketing is reviewed and
maintained by Peace of Mind, and its compliance department. The compensation does not represent a substantial
source of revenue.
DISCLOSURE OF CONFLICTS OF INTEREST
Clients should be aware that the ability to receive additional compensation by our Firm and its management
persons or employees creates inherent conflicts of interest in the objectivity of the Firm and these individuals
when making advisory recommendations. Our Firm endeavors at all times to put the interest of its clients first as
part of our fiduciary duty as a registered investment adviser; we take the following steps, among others to address
this conflict:
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• we disclose to clients the existence of all material conflicts of interest, including the potential for the Firm,
investment advisors, and our employees to earn compensation from advisory clients in addition to the
Firm's advisory fees.
• we disclose to clients that they have the right to decide to purchase recommended investment products
from our employees.
• we collect, maintain and document accurate, complete and relevant client background information,
•
including the client’s financial goals, objectives, and liquidity needs.
the Firm conducts regular reviews of each client advisory account to verify that all recommendations made
to a client are in the best interest of the client’s needs and circumstances.
• we require that our investment advisors and employees seek prior approval of any outside employment
activity so that we may ensure that any conflicts of interests in such activities are properly addressed.
• we periodically review these outside employment activities of the investment advisor to verify that any
conflicts of interest continue to be properly disclosed by the investment advisor ; and
• we educate our investment advisors regarding the responsibilities of a fiduciary, including the need for
having a reasonable and independent basis for the investment advice provided to clients.
CODE OF ETHICS
POM has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we
require of our investment advisors and employees, including compliance with applicable federal securities
laws. POM and its investment advisors owe a duty of loyalty, fairness and good faith towards our clients, and
have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general
principles that guide the Code. Our Code of Ethics includes policies and procedures for the reporting and review
of personal securities transactions reports by our firm’s investment advisors and employees. In addition, our Code
of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private
placement) or an initial public offering. Our code also provides for oversight, enforcement and recordkeeping
provisions.
POM’s Code of Ethics further includes the Firm 's policy prohibiting the use of material non-public
information. While we do not believe that we have any particular access to non-public information, all
investment advisors are reminded that such information may not be used in a personal or professional
capacity. POM and its investment advisors are prohibited from engaging in principal transactions and agency
cross transactions.
Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our
investment advisors will not interfere with (i) making decisions in the best interest of advisory clients and (ii)
implementing such decisions while, at the same time, allowing investment advisors to invest for their own
accounts. Our Firm and/or investment advisors or employees may buy or sell for their personal accounts
securities that are identical to or different from those recommended to our clients. In addition, any related
person(s) may have an interest or position in a certain security(ies) which may also be recommended to a
client. It is the expressed policy of our Firm that no investment advisor may purchase or sell any security
prior to a transaction(s) being implemented for an advisory account, thereby preventing such investment
advisor(s) from benefiting from transactions placed on behalf of advisory accounts.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. Clients may request a
copy by calling us at 919-787-8866.
REVIEW OF ACCOUNTS
Our Investment Adviser Representatives will monitor investment management client accounts on a regular basis
and perform annual reviews with each client. All accounts are reviewed for consistency with client investment
strategy, asset allocation, risk tolerance, and performance relative to the appropriate benchmark. More frequent
reviews may be triggered by changes in an account holder’s personal, tax, or financial status. Geopolitical and
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macroeconomic specific events may also trigger reviews. Clients are urged to notify us of any changes in your
personal circumstances.
CLIENT REFERRALS AND OTHER COMPENSATION
Our firm can receive on-going compensation via advisory fees on commission free variable annuities through
Nationwide. Nationwide receives service fees from the insurers that offer their commission free products through
the platform. These service fees are based on the insurance premiums received by the insurers from Nationwide
members’ clients. Our firm receives advisory fees either; debited from the policy itself or directly from the client.
Our firm will only recommend the use of these insurance products if they are in the client’s best interest.
Advisors Excel provides our Firm bonus compensation based on the amount of annuity sales which is a conflict of
interest. They also provide indirect compensation by providing marketing assistance and business development
tools to acquire new clients, technology with the goal of improving the client experience and our firm’s efficiency,
back office and operations support to assist in the processing of our insurance (through Advisors Excel) services
for clients, business succession planning, business conferences and incentive trips for our firm. Although some of
these services can benefit a client, other services obtained by us from Advisors Excel such as marketing assistance,
business development and incentive trips will not benefit an existing client and is a conflict of interest. The Firm
can receive bonus payments from an insurance company for selling a targeted number of annuities during a
specified period of time which creates a conflict of interest.
At times, we will receive expense reimbursement for travel and/or marketing expenses from distributors of
investment and/or insurance products. Travel expense reimbursements are a result of attendance at due diligence
and/or investment training events hosted by product sponsors. Marketing expense reimbursements are the result
of informal expense sharing arrangements in which product sponsors will underwrite costs incurred for marketing
such as client appreciation events, advertising, publishing, and seminar expenses. Receipt of these travel and
marketing expense reimbursements are dependent upon specific sales quotas, the product sponsor
reimbursements are made by those sponsors for which sales have been made or for which it is anticipated sales
will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and
investments based on the receipt of this compensation instead of what is in the best interest of our clients. We
attempt to control for this conflict by always basing investment decisions on the individual needs of our clients.
Our Firm and our supervised persons do not accept or receive compensation based on the sale of securities.
Supervised persons can be compensated for obtaining prospective clients through marketing initiatives.
POM may be asked to recommend a financial professional, such as an attorney, accountant or mortgage broker. In
such cases, our Firm does not receive any direct compensation in return for any referrals made to individuals or
firms in our professional network. Clients must independently evaluate these firms or individuals before engaging
in business with them and clients have the right to choose any financial professional to conduct business.
Individuals and firms in our financial professional network may refer clients to our Firm. Again, our Firm does not
pay any direct compensation in return for any referrals made to our firm. Our Firm does recognize the fiduciary
responsibility to place your interests first and have established policies in this regard to mitigate any conflicts of
interest.
It is POM's policy not to accept or allow our related persons to accept any form of compensation, including cash,
sales awards, or other prizes, from a non-client in conjunction with the advisory services we provide to our clients.
FINANCIAL INFORMATION
As an advisory Firm that maintains discretionary authority for client accounts, POM is also required to disclose
any financial condition that is reasonably likely to impair our ability to meet our contractual obligations. POM has
no such financial circumstances to report. Under no circumstances do we require or solicit payment of fees in
excess of $1,200 per client more than six (6) months in advance of services rendered. Therefore, we are not
required to include a financial statement. POM has not been the subject of a bankruptcy petition at any time during
the past ten (10) years.
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P R I V A C Y P O L I C Y
Our Firm collects nonpublic personal information about Clients from information provided on applications or other
forms, as well as from information regarding Client transactions with our Firm, our affiliates, or others. In
accordance with Regulation S-P, our Firm does not disclose any nonpublic personal information about current or
former Clients to third parties, except as permitted or required by law, or as necessary to service Client accounts.
Access to Client information is restricted to Firm personnel who require such information to provide investment
advisory services. Our Firm maintains physical, electronic, and procedural safeguards designed to protect Client
information in compliance with federal standards and Regulation S-P. Our Firm provides a copy of its Privacy
Policy to Clients at the time of account opening, upon request, and annually if the Policy is amended.
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