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ADV PART 2A
Bouchey Financial Group Ltd. (CRD 111824), brochure dated September 4, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Item 1
Cover Page
Bouchey Financial Group, Ltd.
SEC File Number: 801 – 51979
ADV Part 2A, Firm Brochure
Dated: September 4, 2026
Contact: David W. Clarke, Chief Compliance Officer
1819 Fifth Avenue
Troy, New York 12180-3302
www.bouchey.com
This Brochure provides information about the qualifications and business practices Bouchey
Financial Group, Ltd. (“Bouchey Financial”). If you have any questions about the contents of this
Brochure, please contact us at (518) 720-3333 or dclarke@bouchey.com. The information in this
Brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority.
Additional information about Bouchey Financial Group, Ltd. also is available on the SEC’s website
at www.adviserinfo.sec.gov.
References herein to Bouchey Financial Group, Ltd. as a “registered investment adviser” or any
reference to being “registered” does not imply a certain level of skill or training.
Material Changes
Item 2
The following material changes have been made to this disclosure brochure since the last annual amendment
filing on 3/27/2026.
• The Advisor has amended its minimum relationship size to $1,000,000. Please see Item 7 for
additional information.
Item 3
Table of Contents
Item 1 Cover Page .................................................................................................................................... 1
Item 2 Material Changes .......................................................................................................................... 2
Item 3
Table of Contents .......................................................................................................................... 2
Item 4 Advisory Business ........................................................................................................................ 3
Fees and Compensation ................................................................................................................ 6
Item 5
Performance-Based Fees and Side-by-Side Management ............................................................ 8
Item 6
Item 7
Types of Clients ............................................................................................................................ 8
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 8
Item 9 Disciplinary Information ............................................................................................................. 14
Item 10 Other Financial Industry Activities and Affiliations .................................................................. 14
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............. 14
Item 12 Brokerage Practices .................................................................................................................... 15
Item 13 Review of Accounts .................................................................................................................... 16
Item 14 Client Referrals and Other Compensation .................................................................................. 17
Item 15 Custody ....................................................................................................................................... 18
Investment Discretion ................................................................................................................. 18
Item 16
Item 17 Voting Client Securities .............................................................................................................. 18
Item 18 Financial Information .................................................................................................................. 19
2
Item 4
Advisory Business
A. Bouchey Financial Group, LTD. (“Bouchey Financial” or the “Advisor”) is a Delaware
corporation formed on August 30, 1995 and located in the State of New York. Bouchey
Financial became a registered investment advisor in May 1996. Bouchey Financial is
majority owned by Steven B. Bouchey (President).
Bouchey Financial’s Chief Compliance Officer, David W. Clarke, remains available
to address any questions that a client or prospective client may have regarding any
aspect of this ADV Part 2A, Firm Brochure.
B. As discussed below, Bouchey Financial offers to its clients (individuals, high net worth
individuals, pension and profit-sharing plans, business entities, trusts, estates and charitable
organizations) investment advisory services, and, to the extent specifically requested by a
client, financial planning and related consulting services.
Bouchey Financial serves as a fiduciary to clients, as defined under the applicable laws and
regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith
towards each client and seeks to mitigate conflicts of interest. Bouchey Financial’s
fiduciary commitment is further described in the Code of Ethics. For more information
regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest
in Client Transactions and Personal Trading.
WEALTH MANAGEMENT SERVICES
Bouchey Financial may provide Clients with wealth management services, which generally
includes a broad range of comprehensive financial planning and consulting services as well
as discretionary management of investment portfolios. Financial planning and consulting
may also be offered as a stand-alone service.
Investment Management Services – Bouchey Financial provides customized investment
advisory solutions for its Clients either as a component of wealth management or on a
stand-alone basis. This is achieved through continuous personal Client contact and
interaction while providing discretionary and/or non-discretionary
investment
management and related advisory services. Bouchey Financial works with each Client to
identify their investment goals and objectives as well as risk tolerance and financial
situation.
Bouchey Financial primarily allocates Client assets among various mutual funds,
individual equity securities, fixed income securities and exchange traded funds, and
unaffiliated investment managers or investment platforms (collectively “Independent
Managers”) in accordance with their stated investment objectives. The Advisor may retain
other types of investments from the Client’s legacy portfolio due to fit with the overall
portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor
and the Client.
Bouchey Financial’s investment approach is primarily long-term focused, but the Advisor
may buy, sell or re-allocate positions that have been held for less than one year to meet the
objectives of the Client or due to market conditions. Bouchey Financial will construct,
implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances,
and risk tolerance agreed to by the Client. Each Client will have the opportunity to place
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reasonable restrictions on the types of investments to be held in their respective portfolio,
subject to acceptance by the Advisor.
Bouchey Financial evaluates and selects investments for inclusion in Client portfolios only
after applying its internal due diligence process. Bouchey Financial may recommend
specific positions to increase sector or asset class weightings. The Advisor may recommend
employing cash positions as a possible hedge against market movement. Bouchey
Financial may recommend selling positions for reasons that include, but are not limited to,
harvesting capital gains or losses, business or sector risk exposure to a specific security or
class of securities, overvaluation or overweighting of the position[s] in the portfolio,
change in risk tolerance of the Client, generating cash to meet Client needs, or any risk
deemed unacceptable for the Client’s risk tolerance.
At no time will Bouchey Financial accept or maintain custody of a Client’s funds or
securities, except for the limited authority as outlined in Item 15 – Custody. All Client
assets will be managed within their designated account[s] at the Custodian, pursuant to the
terms of the advisory agreement, please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding
ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a
fiduciary within the meaning of Title I of the Employee Retirement Income Security Act
(“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor
will provide investment advice to a Client regarding a distribution from an ERISA
retirement account or to roll over the assets to an IRA, or recommend a similar transaction
including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA,
or from one type of account to another account (e.g. commission-based account to fee-
based account). Such a recommendation creates a conflict of interest if the Advisor will
earn a new (or increase its current) advisory fee as a result of the transaction. No client is
under any obligation to roll over a retirement account to an account managed by the
Advisor.
Use of Independent Managers – In certain instances, Bouchey Financial will recommend
that Clients utilize one or more Independent Managers for all or a portfolio of a Client’s
investment portfolio. Bouchey Financial may also assist in the development of the initial
policy recommendations and managing the ongoing Client relationship. The Advisor will
perform initial and ongoing oversight and due diligence over each Independent Manager
to ensure the strategy remains aligned with Client investment objectives and overall best
interests. The Advisor will also assist the Client in the development of the initial policy
recommendations and managing the ongoing Client relationship. The Client will be
provided with the Independent Manager's Form ADV 2A (or a brochure that makes the
appropriate disclosures).
Financial Planning and Consulting – Bouchey Financial will typically provide a variety
of financial planning services to individuals and families as a component of wealth
management services. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan or
rendering a financial consultation based on the Client’s financial goals and objectives. This
planning or consulting may encompass one or more areas of need, including, but not
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limited to business planning, investment planning, retirement planning, insurance
planning, personal savings, education savings, cash flow forecasting, large purchase
planning, charitable giving, tax planning, trust/estate planning and other areas of a Client’s
financial situation.
A financial plan developed for the Client will usually include general recommendations for
a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs,
commence or alter retirement savings, establish education savings and/or charitable giving
programs. Bouchey Financial may also refer Clients to an accountant, attorney or other
specialist, as appropriate for their unique situation. For certain financial planning
engagements, the Advisor will provide a written summary of Client’s financial situation,
observations, and recommendations. For consulting or ad-hoc engagements, the Advisor
may not provide a written summary. Plans or consultations are typically completed within
six months of contract date, assuming all information and documents requested are
provided promptly.
Financial planning recommendations pose a conflict between the interests of the Advisor
and the interests of the Client. For example, the Advisor has an incentive to recommend
that Clients engage the Advisor for investment management services or to increase the
level of investment assets, as it would increase the amount of advisory fees paid to the
Advisor. Clients are not obligated to implement any recommendations made by the Advisor
or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of
the recommendations made by the Advisor, the Client is under no obligation to implement
the transaction through the Advisor.
RETIREMENT PLAN ADVISORY SERVICES
Bouchey Financial provides retirement plan advisory services on behalf of the retirement
plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement
plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary
obligations to the Plan and its Plan Participants. Each engagement is customized to the
needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
Investment Management (ERISA 3(21) and ERISA 3(38))
•
• Performance Reporting
• Benchmarking Services
These services are provided by Bouchey Financial serving in the capacity as a fiduciary
under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In
accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written
description of Bouchey Financial’s fiduciary status, the specific services to be rendered
and all direct and indirect compensation the Advisor reasonably expects under the
engagement.
to providing
investment advisory services, an
C. Bouchey Financial shall provide investment advisory services specific to the needs of each
investment adviser
client. Prior
representative will ascertain each client’s investment objective(s). Thereafter, Bouchey
Financial shall allocate and/or recommend that the client allocate investment assets
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consistent with the designated investment objective(s). The client may, at any time, impose
reasonable restrictions, in writing, on Bouchey Financial’s services.
D. Bouchey Financial does not participate in a wrap fee program.
E. As of December 31, 2025, Bouchey Financial manages $1,606,520,371 in client assets,
$1,573,838,174 of which are managed on a discretionary basis and $32,682,197 on a non-
discretionary basis.
Item 5
Fees and Compensation
A.
WEALTH MANAGEMENT AND INVESTMENT MANAGEMENT SERVICES
Wealth management or investment management fees (herein “investment advisory fees”)
are paid quarterly, at the end of each quarter, pursuant to the terms of the agreement.
Investment advisory fees are based on the market value of assets under management at the
end of the prior calendar quarter. Investment advisory fees range up to 1.00% annually
based on several factors, including: the complexity of the services to be provided, the level
of assets to be managed, and the overall relationship with the Advisor. Relationships with
multiple objectives, specific reporting requirements, portfolio restrictions and other
complexities may be charged a higher fee.
The investment advisory fee in the first quarter of service is prorated from the inception
date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole
discretion of the Advisor. The client’s fees will take into consideration the aggregate assets
under management with the Advisor. All securities held in accounts managed by Bouchey
Financial will be independently valued by the Custodian. Bouchey Financial will conduct
periodic reviews of the Custodian’s valuations to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to, brokerage fees, transaction fees, and
other related costs and expenses, which may be incurred by the client. However, the
Advisor shall not receive any portion of these commissions, fees, and costs.
Use of Independent Managers - As noted in Item 4, the Advisor will implement all or a
portion of a client’s investment portfolio utilizing one or more Independent Managers. To
eliminate any conflict of interest, the Advisor does not earn any compensation from an
Independent Manager. The Advisor will only earn its investment advisory fee as described
above. Independent Managers typically do not offer any fee discounts but may have a
breakpoint schedule which will reduce the fee with an increased level of assets placed under
management with an Independent Manager. The terms of such fee arrangements are
included in the Independent Manager’s disclosure brochure and applicable contract[s] with
the Independent Manager. The total blended fee, including the Advisor’s fee and the
Independent Manager’s fee, will not exceed 2.00% annually.
RETIREMENT PLAN ADVISORY SERVICES
Fees for retirement plan advisory services are charged an annual asset-based fee ranging
from 0.25% to 1.00% and are billed on a quarterly basis, at the end of each quarter, pursuant
to the terms of the retirement plan advisory agreement. Retirement plan advisor fees are
based on the market value of assets under management at the end of the prior calendar
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quarter. Fees may be negotiable depending on the size and complexity of the services to be
provided to the Plan.
B.
WEALTH MANAGEMENT AND INVESTMENT MANAGEMENT SERVICES
Investment advisory fees are calculated by the Advisor or its delegate and deducted from
the client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian
indicating the amount of the fees to be deducted from the client’s account[s] at the
respective quarter end date. The amount due is calculated by applying the quarterly rate
(annual rate divided by 4) to the total assets under management with Bouchey Financial at
the end of each quarter. Clients will be provided with a statement, at least quarterly, from
the Custodian reflecting deduction of the investment advisory fee. It is the responsibility
of the client to verify the accuracy of these fees as listed on the Custodian’s brokerage
statement as the Custodian does not assume this responsibility. Clients provide written
authorization permitting advisory fees to be deducted by Bouchey Financial to be paid
directly from their account[s] held by the Custodian as part of the investment advisory
agreement and separate account forms provided by the Custodian. In limited instances,
Bouchey Financial will bill client directly, to which payment is due upon receipt of the
invoice.
Use of Independent Managers - For client accounts implemented through an Independent
Manager, the Advisor and the Independent Manager will each assume the responsibility
for calculating and deducting their respective fees from the client’s account[s].
RETIREMENT PLAN ADVISORY SERVICES
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted
from the assets of the Plan, depending on the terms of the retirement plan advisory
agreement.
C. Clients may incur certain fees or charges imposed by third parties, other than Bouchey
Financial, in connection with investments made on behalf of the client’s account[s]. The
client is responsible for all securities execution and custody fees charged by the Custodian,
if applicable. The Advisor's recommended Custodian does not charge securities transaction
fees for ETF and equity trades in a client's account, provided that the account meets the
terms and conditions of the Custodian's brokerage requirements. However, the Custodian
typically charges for mutual funds and other types of investments. The fees charged by
Bouchey Financial are separate and distinct from these custody and execution fees.
In addition, all fees paid to Bouchey Financial for investment advisory services are separate
and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if
applicable. These fees and expenses are described in each fund’s prospectus. These fees
and expenses will generally be used to pay management fees for the funds, other fund
expenses, account administration (e.g., custody, brokerage and account reporting), and a
possible distribution fee. A client may be able to invest in these products directly, without
the services of Bouchey Financial, but would not receive the services provided by Bouchey
Financial which are designed, among other things, to assist the client in determining which
products or services are most appropriate for each client’s financial situation and
objectives. Accordingly, the client should review both the fees charged by the fund[s] and
7
the fees charged by Bouchey Financial to fully understand the total fees to be paid. Please
refer to Item 12 – Brokerage Practices for additional information.
D.
WEALTH MANAGEMENT AND INVESTMENT MANAGEMENT SERVICES
Bouchey Financial is compensated for its services at the end of the quarter after investment
advisory services are rendered. Either party may terminate the investment advisory
agreement, at any time, by providing advance written notice to the other party. The client
may also terminate the investment advisory agreement within five (5) business days of
signing the Advisor’s agreement at no cost to the client. After the five-day period, the client
will incur charges for bona fide advisory services rendered to the point of termination and
such fees will be due and payable by the client. The client’s investment advisory agreement
with the Advisor is non-transferable without the client’s prior consent.
Use of Independent Managers - In the event that a client should wish to terminate their relationship
with the Independent Manager, the terms for the termination will be set forth in the respective
agreements between the client and that Independent Manager. Bouchey Financial will assist the
client with the termination and transition as appropriate.
RETIREMENT PLAN ADVISORY SERVICES
Bouchey Financial is compensated for its services at the end of the quarter after retirement
plan advisory services are rendered. Either party may terminate the retirement plan
advisory agreement, at any time, by providing advance written notice to the other party.
Upon termination, the Plan shall be responsible for retirement plan advisory fees up to and
including the effective date of termination. The Plan’s retirement plan advisory agreement
with the Advisor is non-transferable without the client’s prior consent.
E. Neither Bouchey Financial, nor its representatives, accepts compensation from the sale of
securities or other investment products.
Item 6
Performance-Based Fees and Side-by-Side Management
Neither Bouchey Financial, nor any supervised person of Bouchey Financial, accepts
performance-based fees.
Item 7
Types of Clients
Bouchey Financial’s clients shall generally include individuals, high net worth individuals,
pension and profit-sharing plans, business entities, trusts, estates and charitable
organizations. The amount of each type of client is available on Bouchey Financial’s Form
ADV Part 1A. These amounts may change over time and are updated at least annually by
Bouchey Financial. Bouchey Financial generally requires a minimum relationship size of
$1,000,000 which may be waived at the sole discretion of the Advisor.
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
A. Bouchey Financial may utilize the following methods of security analysis:
8
• Fundamental - (analysis performed on historical and present data, with the goal of
making financial forecasts)
• Technical – (analysis performed on historical and present data, focusing on price
and trade volume, to forecast the direction of prices)
Bouchey Financial may utilize, or otherwise assist clients in implementing, the following
investment strategies:
• Long Term Purchases (securities held at least a year)
• Short Term Purchases (securities sold within a year)
• Trading (securities sold within thirty (30) days)
• Short Sales (contracted sale of borrowed securities with an obligation to make the
lender whole)
• Margin Transactions (use of borrowed assets to purchase financial instruments)
• Private Equity Subscriptions (legal commitment by an investor to contribute
capital to a private equity fund)
Please Note: Investment Risk. Investing in securities involves risk of loss that clients
should be prepared to bear. Different types of investments involve varying degrees of risk,
and it should not be assumed that future performance of any specific investment or
investment strategy (including the investments and/or investment strategies recommended
or undertaken by Bouchey Financial) will be profitable or equal any specific performance
level(s).
ETF Characteristics
Investors buying or selling Exchange-Traded Fund (ETF) shares on the secondary market
may incur customary brokerage commissions. Market prices may differ to some degree
from the net asset value of the shares. Investors who sell fund shares may receive less than
the share's net asset value. Shares may be sold throughout the day on the exchange through
any brokerage account. However, unlike mutual funds, shares may only be redeemed
directly from the fund by authorized participants, in very large creation/redemption units.
If the fund's authorized participants are unable to proceed with creation/redemption orders
and no other authorized participant is able to step forward to create or redeem, fund shares
may trade at a discount to the fund's net asset value and possibly face delisting.
Risk Considerations
The ETF’s shares will change in value, and you could lose money by investing in the fund.
One of the principal risks of investing in the fund is market risk. Market risk is the risk that
a particular stock owned by the fund, fund shares or stocks in general may fall in value.
There can be no assurance that the fund's investment objective will be achieved.
ETF’s may invest in securities issued by companies concentrated in a particular industry.
ETF’s may invest in small capitalization and mid-capitalization companies. Such
companies may experience greater price volatility than larger, more established companies.
An investment in a fund containing securities of non-U.S. issuers is subject to additional
risks, including currency fluctuations, political risks, withholding, the lack of adequate
financial information, and exchange control restrictions impacting non-U.S. issuers. The
fund may invest in depositary receipts which may be less liquid than the underlying shares
in their primary trading market.
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Certain ETFs may be classified as “non-diversified” and may invest a relatively high
percentage of its assets in a limited number of issuers. As a result, the fund may be more
susceptible to a single adverse economic or regulatory occurrence affecting one or more of
these issuers, experience increased volatility and be highly concentrated in certain issuers.
B. Bouchey Financial’s methods of analysis and investment strategies do not present any
significant or unusual risks.
However, every method of analysis has its own inherent risks. To perform an accurate
market analysis Bouchey Financial must have access to current/new market information.
Bouchey Financial has no control over the dissemination rate of market information;
therefore, unbeknownst to Bouchey Financial, certain analyses may be compiled with
outdated market information, severely limiting the value of Bouchey Financial’s analysis.
Furthermore, an accurate market analysis can only produce a forecast of the direction of
market values. There can be no assurances that a forecasted change in market value will
materialize into actionable and/or profitable investment opportunities.
Bouchey Financial’s primary investment strategies - Long Term Purchases, Short Term
Purchases, and Trading - are fundamental investment strategies. However, every
investment strategy has its own inherent risks and limitations. For example, longer term
investment strategies require a longer investment time period to allow for the strategy to
potentially develop. Shorter term investment strategies require a shorter investment time
period to potentially develop but, as a result of more frequent trading, may incur higher
transactional costs when compared to a longer-term investment strategy. Trading, an
investment strategy that requires the purchase and sale of securities within a thirty (30) day
investment time period, involves a very short investment time period but will incur higher
transaction costs when compared to a short-term investment strategy and substantially
higher transaction costs than a longer-term investment strategy.
In addition to the fundamental investment strategies discussed above, Bouchey Financial
may also, at the direction of the client, implement short selling, use of margin, and/or
options transactions. Each of these strategies has a high level of inherent risk. (See
discussion below) and, as a result, Bouchey Financial will open implement these strategies
at the direction of the client.
Short Selling. Bouchey Financial does not recommend the use of short selling. Short
selling, involves the selling of assets that the investor does not own. The investor borrows
the assets from a third-party lender (i.e., Broker-Dealer) with the obligation of buying
identical assets at a later date to return to the third party lender. Individuals who engage in
this activity shall only profit from a decline in the price of the assets between the original
date of sale and the date of repurchase. Conversely, the short seller will incur a loss if the
price of the assets rises. Other costs of shorting may include a fee for borrowing the assets
and payment of any dividends paid on the borrowed assets.
Access to Margin. Bouchey Financial does not recommend the use of margin. A margin
transaction occurs when an investor uses borrowed assets to purchase financial instruments
and/or to access liquidity. The investor generally obtains the borrowed assets by using other
securities as collateral for the borrowed sum. The effect of purchasing a security using
margin is to magnify any gains or losses sustained by the purchase of the financial
instruments on margin. Although clients may retain the ability to use margin, Bouchey
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Financial does not use margin for investment purposes and does not recommend its use by
clients. The use of margin by a client will not impact a client’s fees.
Risks Specific to the Program. ETFs in which the Program may invest involve certain
inherent risks generally associated with investments in a portfolio of securities, including
the risk that the general level of security prices may decline, thereby adversely affecting
the value of each unit of the ETF. Moreover, an ETF may not fully replicate the
performance of its benchmark index because of the temporary unavailability of certain
index securities in the secondary market or discrepancies between the ETF and the index
with respect to the weighting of securities or the number of securities held. ETFs in which
the strategies invest have their own fees and expenses as set forth in the ETF prospectuses.
ETFs may have exposure to derivative instruments, such as futures contracts, forward
contracts, options, and swaps. There is a risk that a derivative may not perform as expected.
The main risk with derivatives is that some types can amplify a gain or loss, potentially
earning or losing substantially more money than the actual cost of the derivative, or that
the counterparty may fail to honor its contract terms, causing a loss for the ETF. Use of
these instruments may also involve certain costs and risks such as liquidity risk, interest
rate risk, market risk, credit risk, management risk, and the risk that an ETF could not close
out a position when it would be most advantageous to do so. Some ETFs available,
including Schwab ETFs™, are less than 10 years old. Accordingly, there is limited data
available to use when assessing the investment risk of some of these ETFs. As a result, one
or more of the following may occur: (i) poor liquidity in or limited availability of the ETFs,
or (ii) lack of market depth causing the ETFs to trade at excessive premiums or discounts
C. Currently, Bouchey Financial primarily allocates client investment assets among mutual
funds, individual equity securities, fixed income securities, ETFs, and Independent
Manager(s) on a discretionary and/or non-discretionary basis in accordance with the
client’s designated investment objective(s). (See Independent Managers disclosure at Item
4.B. above).
Risks associated with these asset types include:
1. Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
2. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk may be caused by
external factors independent of the fund’s specific investments as well as due to the
fund’s specific investments. Additionally, each security’s price will fluctuate based on
market movement and emotion, which may, or may not be due to the security’s
operations or changes in its true value. For example, political, economic and social
conditions may trigger market events which are temporarily negative, or temporarily
positive.
3. Inflation Risk: When any type of inflation is present, a dollar today will not buy as
much as a dollar next year, because purchasing power is eroding at the rate of inflation.
4. Reinvestment Risk: This is the risk that future proceeds from investments may have to
be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily
relates to fixed income securities.
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5. Financial Risk: Excessive borrowing to finance a business’ operations increases the
risk of profitability, because the company must meet the terms of its obligations in
good times and bad. During periods of financial stress, the inability to meet loan
obligations may result in bankruptcy and/or a declining market value.
6. Market Risk (Systematic 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 your portfolio will fluctuate, there is
a risk that you will lose money.
7. Unsystematic Risk: Unsystematic risk is the company-specific or industry-specific risk
in a portfolio. The combination of systematic (market risk) and unsystematic risk is
defined as the portfolio risk that the investor bears. While the investor can do little to
reduce systematic risk, he or she can affect unsystematic risk. Unsystematic risk may
be significantly reduced through diversification. However, even a portfolio of well-
diversified assets cannot escape all risk.
8. 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 performance. Credit risk is greater for fixed income securities
with ratings below investment grade (BB or below by Standard & Poor’s Rating Group
or Ba or below by Moody’s Investors Service, Inc.). Fixed income securities that are
below investment grade involve higher credit risk and are considered speculative.
9. Call Risk: Call risk is the risk that during periods of falling interest rates, a bond issuer
will call or repay a higher-yielding bond before its maturity date, forcing the
investment to reinvest in bonds with lower interest rates than the original obligations.
10. Income Risk: Income risk is the risk that falling interest rates will cause the
investment’s income to decline.
11. Purchasing Power Risk: Purchasing power risk is the risk that your investment’s value
will decline as the price of goods rises (inflation). The investment’s value itself does
not decline, but its relative value does, which is the same thing. Inflation can happen
for a variety of complex reasons, including a growing economy and a rising money
supply. Rising inflation means that if you have $1,000 and inflation rises 5 percent in
a year, your $1,000 has lost 5 percent of its value, as it cannot buy what it could buy a
year previous.
12. Political Risks: Most investments have a global component, even domestic stocks.
Political events anywhere in the world may have unforeseen consequences to markets
around the world.
13. Regulatory Risk: Changes in laws and regulations from any government can change
the market value of companies subject to such regulations. Certain industries are more
susceptible to government regulation. Changes in zoning, tax structure or laws impact
the return on these investments.
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14. Risks Related to Investment Term: Securities do not follow a straight line up in value.
All securities will have periods of time when the current price of the security is not
what we believe it is truly worth. If you require us to liquidate your portfolio during
one of these periods, you will not realize as much value as you would have had the
investment had the opportunity to regain its value.
An investment in a mutual fund or ETF involves risk, including the loss of principal.
Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the
individual issuers of the fund’s underlying portfolio securities. Such shareholders are also
liable for taxes on any fund-level capital gains, as ETFs and mutual funds are required by
law to distribute capital gains in the event they sell securities for a profit that cannot be
offset by a corresponding loss. As such, a mutual fund or ETF client or investor may incur
substantial tax liabilities even when the fund underperforms.
Shares of mutual funds are distributed and redeemed on an ongoing basis by the fund itself
or a broker acting on its behalf. The trading price at which a share is transacted is equal to
a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g.,
sales loads, purchase fees, redemption fees). The per-share NAV of a mutual fund is
calculated at the end of each business day, although the actual NAV fluctuates with
intraday changes in the market value of the fund’s holdings. The trading prices of a mutual
fund’s shares can differ significantly from the NAV during periods of market volatility,
which may, among other factors, lead to the mutual fund’s shares trading at a premium or
discount to NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the
secondary market. Generally, ETF shares trade at or near their most recent NAV, which is
generally calculated at least once daily for indexed-based ETFs and more frequently for
actively managed ETFs. However, certain inefficiencies can cause the shares to trade at a
premium or discount to their pro-rata NAV. There is also no guarantee that an active
secondary market for such shares will develop or continue to exist. While clients and
investors may be able to sell their ETF shares on an exchange, ETFs generally only redeems
shares directly from shareholders when aggregated as creation units (usually 50,000 shares
or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular
ETF, a shareholder may have no way to dispose of such shares.
Alternative Investment Vehicles. The Advisor may periodically allocate a portion of a
Client’s portfolio to alternative investments at its discretion, considering the Client’s
objectives and risk tolerance. These investments are influenced by the performance of their
respective Managers, whose strategies and decisions impact returns. If a Manager’s
approach falls out of favor or investment decisions are poor, losses may occur. If several
Managers underperform simultaneously, a Client’s account may experience significant
declines.
Cryptocurrency ETF Risks. Cryptocurrency ETFs are investment vehicles designed to
provide exposure to the price movements of cryptocurrencies or cryptocurrency-related
assets through exchange-listed securities. Cryptocurrencies and cryptocurrency-related
markets are highly volatile. Prices may fluctuate dramatically over short periods of time
due to factors including, but not limited to, market sentiment, technological developments,
macroeconomic events, regulatory actions, and changes in liquidity. As a result,
Cryptocurrency ETFs may experience rapid and substantial losses. A Cryptocurrency
ETF’s performance may differ materially from the crypto market exposure it seeks to
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provide due to fees and expenses, portfolio construction and rebalancing, and the use of
derivatives, and during periods of market stress liquidity may decline, bid-ask spreads may
widen, shares may trade above or below the value of underlying holdings, and trading may
be halted or limited, which may prevent buying or selling at desired times or prices.
Item 9
Disciplinary Information
Bouchey Financial has not been the subject of any disciplinary actions.
Item 10
Other Financial Industry Activities and Affiliations
Licensed Insurance Agency. Bouchey Financial is affiliated through common control and
ownership with Bouchey, Millet, and Schafer, LLC, a corporation licensed with the New
York State Department of Insurance. Bouchey Financial’s representatives will not
recommend that clients of Bouchey Financial purchase insurance products through
Bouchey, Millet, and Schafer, LLC.
Tax Services
Bouchey Financial is also affiliated through common control and ownership with B, M &
Co. Tax Service, LLC. Bouchey Financial’s representatives recommend that certain
Clients of Bouchey Financial engage in tax preparation and accounting services through B,
M & Co. Tax Service, LLC.
The recommendation that a client utilize the services of one the Affiliated Entities presents
a conflict of interest, as the additional compensation may provide an incentive to
recommend certain investment products, rather than on a particular client’s need. No client
is under any obligation to purchase any investment products from the Affiliated Entities.
Clients are reminded that they may engage in tax preparation and accounting services
recommended by Bouchey Financial through other, non-affiliated tax agencies.
Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. Bouchey Financial maintains an investment policy relative to personal securities
transactions. This investment policy is part of Bouchey Financial’s overall Code of Ethics,
which serves to establish a standard of business conduct for all of Bouchey Financial’s
representatives that is based upon fundamental principles of openness, integrity, honesty
and trust, a copy of which is available upon request.
In accordance with Section 204A of the Investment Advisers Act of 1940, Bouchey
Financial also maintains and enforces written policies reasonably designed to prevent the
misuse of material non-public information by Bouchey Financial or any person associated
with Bouchey Financial.
B. Neither Bouchey Financial nor any related person of Bouchey Financial recommends,
buys, or sells for client accounts, securities in which Bouchey Financial or any related
person of Bouchey Financial has a material financial interest.
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C. Bouchey Financial and/or representatives of Bouchey Financial may buy or sell securities
that are also recommended to clients. This practice may create a situation where Bouchey
Financial and/or representatives of Bouchey Financial are in a position to materially benefit
from the sale or purchase of those securities. Therefore, this situation creates a potential
conflict of interest. Practices such as “scalping” (i.e., a practice whereby the owner of
shares of a security recommends that security for investment and then immediately sells it
at a profit upon the rise in the market price which follows the recommendation) could take
place if Bouchey Financial did not have adequate policies in place to detect such activities.
In addition, this requirement can help detect insider trading, “front-running” (i.e., personal
trades executed prior to those of Bouchey Financial’s clients) and other potentially abusive
practices.
Bouchey Financial has a personal securities transaction policy in place to monitor the
personal securities transactions and securities holdings of each of Bouchey Financial’s
“Access Persons”. Bouchey Financial’s securities transaction policy requires that an
Access Person of Bouchey Financial must provide the Chief Compliance Officer or his/her
designee with a written report of their current securities holdings within ten (10) days after
becoming an Access Person. Additionally, each Access Person must provide the Chief
Compliance Officer or his/her designee with a written report of the Access Person’s current
securities holdings at least once each twelve (12) month period thereafter on a date
Bouchey Financial selects.
D. Bouchey Financial and/or representatives of Bouchey Financial may buy or sell securities,
at or around the same time as those securities are recommended to clients. This practice
creates a situation where Bouchey Financial and/or representatives of Bouchey Financial
are in a position to materially benefit from the sale or purchase of those securities.
Therefore, this situation creates a potential conflict of interest. As indicated above in Item
11.C, Bouchey Financial has a personal securities transaction policy in place to monitor
the personal securities transaction and securities holdings of each of Bouchey Financial’s
Access Persons.
Item 12
Brokerage Practices
A. Bouchey Financial does not have discretionary authority to select the broker-
dealer/custodian for custody and execution services. The client will engage the broker-
dealer/custodian (herein the "Custodian") to safeguard client assets and authorize Bouchey
Financial to direct trades to the Custodian as agreed upon in the investment advisory
agreement. Further, Bouchey Financial does not have the discretionary authority to
negotiate commissions on behalf of clients on a trade-by-trade basis.
Where Bouchey Financial does not exercise discretion over the selection of the Custodian,
it may recommend the Custodian[s] to clients for custody and execution services. Clients
are not obligated to use the recommended Custodian and will not incur any extra fee or
cost from the Advisor associated with using a custodian not recommended by Bouchey
Financial. However, the Advisor may be limited in the services it can provide if the
recommended Custodian is not engaged. Bouchey Financial may recommend the
Custodian based on criteria such as, but not limited to, reasonableness of commissions
charged to the client, services made available to the client, its reputation and/or the location
of the Custodian’s offices.
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Bouchey Financial will generally recommend that clients establish their account[s] at
Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member
SIPC. Schwab and Fidelity will serve as the client’s “qualified custodian”. Bouchey
Financial maintains an institutional relationship with Schwab, whereby the Advisor
receives economic benefits from Schwab. Please see Item 14 below.
The following are additional details regarding the brokerage practices of the Advisor:
Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians
whereby an advisor enters into an agreement to place security trades with a broker-
dealer/custodian in exchange for research and other services. Bouchey Financial does
not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Advisor does receive certain economic benefits from
Schwab. Please see Item 14.
Brokerage Referrals – Bouchey Financial does not receive any compensation from any
third party in connection with the recommendation for establishing an account.
Directed Brokerage – All clients are serviced on a “directed brokerage basis”, where
Bouchey Financial will place trades within the established account[s] at the Custodian
designated by the client. Further, all client accounts are traded within their respective
account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any
security from or to the Advisor’s own account) or cross transactions with other client
accounts (i.e., purchase of a security into one client account from another client’s
account[s]). Bouchey Financial will not be obligated to select competitive bids on
securities transactions and does not have an obligation to seek the lowest available
transaction costs. These costs are determined by the Custodian.
A. To the extent that Bouchey Financial provides investment management services to its
clients, the transactions for each client account may be affected independently, unless
Bouchey Financial decides to purchase or sell the same securities for several clients at
approximately the same time. Bouchey Financial may combine or “bunch” such orders to
obtain best execution, to negotiate more favorable commission rates or to allocate equitably
among Bouchey Financial’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. Bouchey Financial shall not receive any additional compensation or
remuneration as a result of such aggregation.
Item 13
Review of Accounts
A. For those clients to whom Bouchey Financial provides investment supervisory services,
account reviews are conducted on an ongoing basis by Bouchey Financial's Principals
and/or representatives. All investment supervisory clients are advised that it remains their
responsibility to advise Bouchey Financial 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 Bouchey Financial on an annual basis.
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B. Bouchey Financial may conduct account reviews on an other-than-periodic basis upon the
occurrence of a triggering event, such as a change in client investment objectives and/or
financial situation, market corrections and client request.
C. Clients are provided, at least quarterly, with written transaction confirmation notices and
regular written summary account statements directly from the broker-dealer/custodian
and/or program sponsor for the client accounts. Bouchey Financial may also provide a
written periodic report summarizing account activity and performance.
Item 14
Client Referrals and Other Compensation
A. Bouchey Financial may refer clients to various third parties to provide certain financial
services necessary to meet the goals of its clients. Likewise, Bouchey Financial may
receive non-compensated referrals of new clients from a third party.
Participation in Institutional Advisor Platform
Bouchey Financial has established an institutional relationship with Schwab through its
“Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent
advisory firms like Bouchey Financial. As a registered investment advisor participating on
the Schwab Advisor Services platform, Bouchey Financial receives access to software and
related support without cost because the Advisor renders investment management services
to clients that maintain assets at Schwab. Services provided by Schwab Advisor Services
benefit the Advisor and many, but not all services provided by Schwab will benefit clients.
In fulfilling its duties to its clients, the Advisor endeavors at all times to put the interests
of its clients first. Clients should be aware, however, that the receipt of economic benefits
from a custodian creates a conflict of interest since these benefits may influence the
Advisor's recommendation of this custodian over one that does not furnish similar
software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access
to a broad range of investment products, execution of securities transactions, and custody
of client’s funds and securities. Through Schwab, the Advisor may be able to access certain
investments and asset classes that the client would not be able to obtain directly or through
other sources. Further, the Advisor may be able to invest in certain mutual funds and other
investments without having to adhere to investment minimums that might be required if
the client were to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors
with access to technology, research, discounts and other services. In addition, the Advisor
receives duplicate statements for client accounts, the ability to deduct advisory fees, trading
tools, and back-office support services as part of its relationship with Schwab. These
services are intended to assist the Advisor in effectively managing accounts for its clients,
but may not directly benefit all clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to Bouchey
Financial that may not benefit the client, including: educational conferences and events,
consulting services and discounts for various service providers. Access to these services
creates a financial incentive for the Advisor to recommend Schwab, which results in a
conflict of interest. Bouchey Financial believes, however, that the selection of Schwab as
Custodian is in the best interests of its clients.
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B. Bouchey Financial does not compensate, either directly or indirectly, any persons who are
not supervised persons, for Client referrals.
Item 15
Custody
Bouchey Financial shall have the ability to have its advisory fee for each client debited by
the custodian on a quarterly basis. Clients are provided, at least quarterly, with written
transaction confirmation notices and regular written summary account statements directly
from the broker-dealer/custodian and/or program sponsor for the client accounts. Bouchey
Financial may also provide a written periodic report summarizing account activity and
performance.
Please Note: To the extent that Bouchey Financial provides clients with periodic account
statements or reports, the client is urged to compare any statement or report provided by
Bouchey Financial with the account statements received from the account custodian. Please
Also Note: The account custodian does not verify the accuracy of Bouchey Financial’s
advisory fee calculation.
In addition, certain clients have established asset transfer authorizations which permit the
qualified custodian to rely upon instructions from Bouchey Financial to transfer client
funds or securities to third parties. These arrangements are also disclosed at ADV Part 1,
Item 9, but in accordance with the guidance provided in the SEC’s February 21, 2017
Investment Adviser Association No-Action Letter, the affected accounts are not subject to
an annual surprise CPA examination.
Item 16
Investment Discretion
The client can determine to engage Bouchey Financial to provide investment advisory
services on a discretionary basis. Prior to Bouchey Financial assuming discretionary
authority over a client’s account, the client shall be required to execute an Investment
Advisory Agreement, naming Bouchey Financial as the client’s attorney and agent in fact,
granting Bouchey Financial full authority to buy, sell, or otherwise effect investment
transactions involving the assets in the client’s name found in the discretionary account.
Clients who engage Bouchey Financial on a discretionary basis may, at any time, impose
restrictions, in writing, on Bouchey Financial’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 Bouchey
Financial’s use of margin, etc.).
Item 17
Voting Client Securities
A. Bouchey Financial does not vote client proxies. Clients maintain exclusive responsibility
for: (1) directing the manner in which proxies solicited by issuers of securities beneficially
owned by the client shall be voted, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the
client’s investment assets.
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B. Clients will receive their proxies or other solicitations directly from their custodian. Clients
may contact Bouchey Financial to discuss any questions they may have with a particular
solicitation.
Item 18
Financial Information
A. Bouchey Financial does not solicit fees of more than $1,200, per client, six months or more
in advance.
B. Bouchey Financial is unaware of any financial condition that is reasonably likely to impair
its ability to meet its contractual commitments relating to its discretionary authority over
certain client accounts.
C. Bouchey Financial has not been the subject of a bankruptcy petition.
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