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APPENDIX 1 WRAP BROCHURE
Longview Wealth Management (CRD 136214), brochure dated February 25, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
LongView Wealth Management
Item 1 – Cover Page
FORM ADV PART 2A
“APPENDIX 1”
LongView Wealth Management
5605 Glenridge Drive Suite 300
Atlanta, GA 30342
P: 404-843-3100
www.LongViewWealthManagement.com
www.LongViewAtlanta.com
February 25, 2026
This wrap fee program Appendix 1 provides information about the qualifications and business practices of
LongView Wealth Management. If you have any questions about the contents of this Appendix 1, please
contact us at 404-843-3100 and/or jhayes@lvwm.com. The information in this Appendix 1 has not been
approved or verified by the United States Securities and Exchange Commission or by any state securities
authority.
Additional information about LongView Wealth Management also is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for LongView Wealth Management is
136214.
Any references to LongView Wealth Management as a registered investment adviser or its related persons
as registered investment advisory representatives does not imply a certain level of skill or training.
1
LongView Wealth Management
Item 2 - MATERIAL CHANGES
We have not made any material changes to the brochure; however, we encourage you to read the Appendix
1 in its entirety.
The date of the last annual update of the Appendix 1 was March 2025.
In the past, we have offered or delivered information about our qualifications and business practices to clients
on at least an annual basis. Pursuant to new SEC Rules, we will ensure that you receive a summary of any
material changes to this and subsequent Appendix 1 within 120 days of the close of our fiscal year, which is
December 31st. We may further provide other ongoing disclosure information about material changes as
necessary.
LongView will further provide you with a new Appendix 1 as necessary based on changes or new
information, at any time, without charge. Currently, LongView’s Appendix 1 may be requested by
contacting Mr. John Hayes, Chief Compliance Officer at (404) 843-3100 or jhayes@lvwm.com.
Additional information about LongView is also available via the SEC’s web site www.adviserinfo.sec.gov.
The searchable IARD/CRD number for LongView is 136214. The SEC’s web site also provides information
about any persons affiliated with LongView who are registered, or are required to be registered, as
investment adviser representatives of LongView.
2
LongView Wealth Management
Item 3 - TABLE OF CONTENTS
Item 1 – COVER PAGE ............................................................................................. Cover Page
Item 2 - MATERIAL CHANGES .................................................................................................... 2
Item 3 - TABLE OF CONTENTS .................................................................................................... 3
Item 4 – SERVICES, FEES AND COMPENSATION ....................................................................... 4
LongView Wealth Management Program ............................................................................................ 4
Fees and Compensation .................................................................................................................... 4
General Information ......................................................................................................................... 7
IRA Rollover Considerations ............................................................................................................. 8
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 ........................... 11
Item 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS .................................................. 11
Item 9 – ADDITIONAL INFORMATION ..................................................................................... 11
Item 10 - REQUIREMENTS FOR STATE REGISTERED ADVISERS ........................................... 14
LongView Wealth Management
Item 4 – SERVICES, FEES AND COMPENSATION
A. Wrap Programs
Wrap accounts are managed by LongView on a discretionary or non-discretionary basis as agreed to
between the client and the Advisory Representative. Accounts managed on a discretionary basis will
give LongView the authority to determine the securities to be purchased and sold in the account and
alter the securities holdings from time to time, without prior consultation with you. Discretionary
authority will be granted by you to LongView by execution of the Client Agreement. If you elect to
have your accounts managed on a nondiscretionary basis, no changes will be made to the allocation
of your account without prior consultation with you and your expressed agreement.
The LongView Wealth Management Program (Wrap) is offered as a wrap program. A wrap program
is where the client will pay one fee and the fee will cover LongView’s advisory fee and any transaction
charges. Typically, a wrap program is more suitable for clients who will have more frequent trading
and in securities for which the custodian charges transaction fees. In a wrap program Longview has a
conflict of interest to use securities for which the account custodian waives transaction fees.
Transactions in the account, account reallocations and rebalancing may trigger a taxable event for the
client, with the exception of qualified retirement accounts.
LongView Wealth Management Program (Wrap)
LongView provides asset management services on a continuous and ongoing basis based on the
individual needs of the client.
Custodial services are made available through Schwab Advisor Services division of Charles Schwab
& Co., Inc. (“Schwab”), and Fidelity Brokerage Services LLC (“Fidelity”) both are registered
broker/dealers, member SIPC. LongView is independently owned and operated and not affiliated with
Fidelity or Schwab. Schwab and Fidelity generally do not charge you separately for custody services
but are compensated by charging LongView a ticket charge or a fee for executing orders in your
account. In addition, they may charge you other fees which will be disclosed to you in their fee
agreement. We encourage to review your fee agreements with the custodian and if you have any
questions consult with your Investment Advisor Representative. We have determined that having your
custodian execute most trades is consistent with our duty to seek “best execution” of your trades. Best
execution means the most favorable terms for a transaction based on all relevant factors, including
those listed above.
Fees and Compensation
Fees are negotiable and are not based on a share of capital gains upon or capital appreciation of the
funds or any portion of the funds. Fees vary from client-to-client and are detailed on the Client
Agreement provided to the client. Fees vary based on the complexity of the services, number of
meetings, and the Advisory Representative.
You may make additions to the Account or withdrawals from the Account, provided the Account
continues to meet minimum account size requirements. No fee adjustments will be made for Account
appreciation or depreciation. No fee adjustments will be made for additional deposits to or partial
withdrawals from the client’s portfolio during a period. Portfolio is defined as all accounts of a client
LongView Wealth Management
under management. Therefore, if a client opens a new account under management or closes an account
under management, there will be no fee adjustment during the quarter.
Advisory Representatives can choose to aggregate all of a client’s managed accounts together to
determine the fee breakpoint based on the schedule. Thus, all accounts will pay the same fee.
Alternatively, Advisory Representatives can choose to charge a fee based on the value of each account
under management. Therefore, clients may pay a different fee on each account based on the account
value.
LongView may change the fee schedule upon 30-days prior written notice to you.
Wrap Program Fees*
FROM TO MAXIMUM CLIENT FEE
$0 $100,000
$100,000.01 $250,000
$250,000.01 $500,000
$500,000.01 $1,000,000
$1,000,000.01 and higher
1.75%
1.50%
1.25%
1.20%
1.00%
*Fees may be a flat fee based on the value of the client’s managed portfolio or per account size or may
be tiered. Clients on a tiered fee schedule will pay a fee based on each level outlined above (e.g. a
$1,000,000 account will pay up to 1.75% on the first $100,000, 1.50% on the next $150,000, 1.25%
on the next $250,000 and 1.20% on the remaining $500,000).
Advisory fees will generally be collected directly from your account, provided you have given
LongView written authorization. You will be provided with an account statement reflecting the
deduction of the advisory fee direct from the account custodian. If the Account does not contain
sufficient funds to pay advisory fees, LongView has limited authority to sell or redeem securities in
sufficient amounts to pay advisory fees. You may reimburse the account for advisory fees paid to
LongView, except for ERISA and IRA accounts.
Advisory fees are charged on a quarterly basis in advance or in arrears, depending on the Advisory
Representative and as negotiated with the client. Quarterly periods may be on a calendar year basis or
every three months starting on cycle as agreed between client and advisory representative. Fees for
partial quarters (i.e. accounts established or closed during a quarter period) will be charged a prorated
portion of the fee for the quarterly period. In cases where fees are charged in advance, the initial fee
will be based on the value of the account upon establishment and will be prorated based on the number
of days remaining in the quarterly period. In cases where the fee is charged in arrears, the initial fee
will be a prorated fee based on the number of days the account was under management and based on
the value of the account as of the last business day of the quarterly period. Thereafter the fees will be
calculated based on the value of the account on the last business day of the just completed quarterly
period.
A set-up fee not to exceed one percent (1%) of the initial account value may be charged. The set-up
fee will be billed in full along with the first quarter fee. The set-up fee is negotiable.
LongView Wealth Management
Some Advisory Representatives of LongView are dually registered representatives of M.S. Howells
& Co., a registered broker/dealer, member of the Financial Regulatory Association (FINRA) and
SIPC. As Registered Representatives our Advisory Representatives will earn a commission on
products sold through M.S. Howells & Co. so there is a conflict of interest to recommend products
that pay a commission.
You can purchase the securities recommended by LongView directly or through other brokers or
agents not affiliated with LongView.
Termination Provisions
Client may terminate LongView’s engagement within five business days of execution of the advisory
agreement and receive a full refund of all prepaid fees paid to LongView. Thereafter, client may
terminate upon LongView’s receipt of client’s written notice to terminate and receive a pro rata portion
of the prepaid advisory fee based upon the time remaining under the Client Agreement from the date
of receipt of client’s written notice to terminate to the end of the calendar quarter. Clients who are
paying in arrears will be charged a prorated fee for the quarter up to the date of receipt of client’s
written notice to terminate.
B. Wrap programs can cost the client more or less than if the client purchased advisory and
execution services separately. If services are purchased separately, it is possible the advisory fee would
be less and transaction charges could be controlled or managed based on the frequency of trading and
the types of securities purchased (i.e. use of no transaction fee funds). Actively traded accounts are
more suitable for a wrap program, depending on the number of no transaction fee funds utilized.
Clients are advised that typically a wrap program is more expensive since LongView will charge a
higher fee to cover any transaction expenses.
Further, there is an incentive for LongView to limit transactions to no transaction fee funds in an effort
to reduce LongView’s costs. This is considered a conflict of interest for LongView to cause a client
to participate in a wrap program if trading will be infrequent or if a number of no transaction fee funds
will be utilized since LongView will be able to retain a larger portion of the management fee since no
fees will need to be allocated to trading costs by LongView. Therefore, there is an incentive for
LongView to limit transactions to no-transaction fee funds in an effort to reduce LongView’s costs.
Clients are advised LongView has several Advisory Representatives who are independent contractors.
The Advisory Representatives may not charge an advisory fee in excess of the fee schedule disclosed
above. However, each Advisory Representative determines the fee to the client. Therefore, depending
on the Advisory Representative selected by the client, the client can pay more or less than another
client serviced by another Advisory Representative.
C.
In addition to the advisory fees set forth above, client can be assessed account maintenance
fees, custodial fees, and retirement fees for maintaining their portfolio. LongView does not share in
any portion of these fees. Further, there is an incentive for LongView to limit transactions to no
transaction fee funds in an effort to reduce LongView’s costs.
Wrap accounts will be charged transaction fees for any unsolicited transaction (i.e. transactions
requested by the client). Additionally, for trades executed away from the custodian, the client will be
charged and responsible for any fees associated with trading the securities away and/or delivering the
securities into the client’s account.
LongView Wealth Management
You will pay your proportionate share of the fund’s management and administrative fees and sales
charges as well as the mutual fund adviser’s fee of any mutual fund they purchase. Such advisory fees
are not shared with LongView and are compensation to the fund-manager. Fees not included in the
advisory fee are charges imposed directly by a mutual fund, index fund, or exchange traded fund which
are disclosed in the prospectus (i.e., fund management fees and other fund expenses), mark-ups and
mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire
transfer fees and other fees and taxes on brokerage accounts and securities transactions.
D.
Your Advisory Representative has an incentive in the advisory fee paid by the client since the
Advisory Representative will receive a portion of the advisory fee collected by LongView. The
amount of compensation paid to the Advisory Representative is not more or less than if your Advisory
Representative selected another investment option.
General Information
You are advised the investment recommendations and advice offered by LongView are not legal,
tax or accounting advice. You should coordinate and discuss the impact of financial advice with your
attorney and/or accountant. You are advised that it is necessary to inform LongView promptly with
respect to any changes in your financial situation and investment goals and objectives. Failure to
notify LongView of any such changes could result in investment recommendations not meeting
your needs.
Advisory Representatives recommend to clients the use of various share classes of mutual funds
including no transaction fee funds. This will create conflicts of interest as the IAR will be
incentivized to recommends funds which will not charge them a ticket charge for wrap accounts and
is not necessarily in your best interest. Generally, clients should select the lowest cost available
share class for wrap accounts. For Non-Wrap accounts a client should weigh the benefit of not
paying a ticket charge with the increased cost for the share class.
Class I shares generally have lower internal expenses and no upfront fees. There may be
Clients are advised of the following:
1.
minimums to utilize this share class.
2. No Transaction fee funds typically have higher internal expenses that can outweigh the
benefits of not paying a ticket charge.
Disclosure of the costs and expenses of various share classes is contained in the prospectus. Clients
should read the prospectus prior to investing.
The cost to the client will vary depending on the type of share class of mutual funds purchased,
amount of trading, and amount of service requested by the client. Clients are advised that clients
will continue to pay internal expenses of the mutual fund even after the termination of the advisory
agreement. It is important to consider and evaluate the internal costs. Though internal costs are not
evident on statements and confirmations, such costs and expenses should be considered along with
the advisory fee you pay LongView, when determining your total cost of investing.
There is no assurance that the level of experience and service each individual IAR provides is
uniform. LongView clients can pay more or less for the same service due to the experience, amount
LongView Wealth Management
of work done and sophistication of its Financial Planner.
IRA Rollover Considerations
As part of our consulting and advisory services, we may provide you recommendations and advice
concerning your employer retirement plan or other qualified retirement account. Our
recommendations may include you consider withdrawing the assets from your employer's retirement
plan or other qualified retirement account and roll the assets over to an individual retirement account
("IRA"). Further, we offer our management services be applied to those funds and securities rolled
into an IRA or other account for which we will receive compensation. If you elect to roll the assets to
an IRA that is subject to our management, we will charge you an asset based fee as described above
under Item 5 of our ADV 2A . This practice presents a conflict of interest because persons providing
investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of
generating fee based compensation rather than solely based on your needs. You are under no
obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the
rollover, you are under no obligation to have the assets in an IRA managed by us.
It is important for you to understand many employers permit former employees to keep their retirement
assets in their company plan. Also, current employees can sometimes move assets out of their company
plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and
to the extent the following options are available, you should consider the costs and benefits of each.
Leave the funds in your employer's (former employer's) plan.
An employee will typically have four options:
1.
2. Move the funds to a new employer's retirement plan.
3.
4.
Cash out and taking a taxable distribution from the plan.
Roll the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage
you to speak with your CPA and/or tax attorney.
Determine whether the investment options in your employer's retirement plan address your
Employer retirement plans generally have a more limited investment menu than IRAs.
Employer retirement plans may have unique investment options not available to the public
You should understand the various products and services you might take advantage of at an
If you are considering rolling over your retirement funds to an IRA for us to manage it is important
you understand the following:
1.
needs or whether you might want to consider other types of investments.
a.
b.
such as employer securities, or previously closed funds.
2.
Your current plan may have lower fees than our fees.
If you are interested in investing only in mutual funds, you should understand the cost structure
a.
of the share classes available in your employer's retirement plan and how the costs of those share
classes compare with those available in an IRA.
b.
IRA provider and the potential costs of those products and services.
c.
It is likely you will not be charged a management fee and will not receive ongoing asset
management services unless you elect to have such services. In the event your plan offers asset
management or model management, there may be a fee associated with the services that is more or
less than our asset management fee.
3.
Our strategy may have higher risk than the option(s) provided to you in your plan.
LongView Wealth Management
Your current plan may offer financial advice, guidance, and/or model management or portfolio
If you keep your assets titled in a 401k or retirement account, you could potentially delay your
If you own company stock in your plan, you may be able to liquidate those shares at a lower
4.
options at no additional cost.
5.
required minimum distribution beyond age 70.5 (70 ½).
Your 401k may offer more liability protection than a rollover IRA; each state may vary.
6.
a.
Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets
have been generally protected from creditors in bankruptcies. However, there can be some exceptions
to the general rules so you should consult an attorney if you are concerned about protecting your
retirement plan assets from creditors.
You may be able to take out a loan on your 401k, but not from an IRA.
7.
8.
IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
and may also be subject to a 10% early distribution penalty unless they qualify for an exception such
as disability, higher education expenses or the purchase of a home.
9.
capital gains tax rate.
10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important that you understand the differences between these types of accounts and to decide
whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment
adviser representative, or call our main number as listed on the cover page of this Appendix 1.
Item 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
LongView generally requires a minimum amount of assets be deposited to an account for the purpose
of obtaining asset management services through LongView. LongView may waive the minimum
account size requirement and accept accounts less than the stated minimums. Such circumstances
include but not be limited to additional assets will soon be deposited or you have other accounts under
management with LongView. You are advised performance can suffer due to difficulties with
diversifying smaller accounts and due to risk controls potentially being compromised. Performance of
smaller accounts may vary from the performance of accounts with more dollars invested due to
fluctuations in the market may affect smaller accounts more and the effects of compounding may be
greater in larger accounts.
LongView’s services are geared toward individuals both high net worth (i.e. clients with a net worth
of $2,000,000) and other than high net worth, pension and profit-sharing plans, and corporations or
other businesses. There is no minimum requirement for clients.
Item 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION
LongView requires education and experience in investments, insurance, taxation, or other related
fields as the minimum standard for their Advisory Representatives. LongView requires that all staff
obtain appropriate licenses, including securities licenses to buy and sell securities and insurance
products. In addition, LongView encourages professional staff to participate in industry education
programs and in courses of study for Certified Financial Planner or Chartered Financial Consultant
professional designations
Your Advisory Representative is the sole manager on your account. Accounts are not assigned by
LongView to any Advisory Representative. You retain the authority to select who you want to manage
LongView Wealth Management
your account. LongView’s Advisory Representatives have different education and experience levels
and have different management styles and philosophies.
Neither LongView nor a third-party reviews Advisory Representatives’ performance.
LongView offers the following advisory services. Each of the services is more fully described in
LongView’s Disclosure Appendix 1.
• Asset Management
• Financial Planning
• Analysis, Recommendation and Monitoring of Third Party Managed Programs
LongView tailors the advisory services it offers to your individual needs. You may impose restrictions
and/or limitations on investing in certain securities or types of securities. LongView will ask you to
complete a fact finder or data gathering questionnaire to assist LongView with obtaining information
about your financial situation and history. Additionally, LongView will meet with you and conduct an
interview and data gathering session to continue the due diligence process. The information gathered
by LongView will assist LongView to provide you with the requested services and customize the
services to your financial situation. Depending on the services you have requested, LongView will
gather various financial information and history from you including, but not limited to:
Investment objectives
Investment horizon
• Retirement and financial goals
•
•
• Financial needs
• Cash flow analysis
• Cost of living needs
• Education needs
• Savings tendencies
• Other applicable financial information required by LongView in order to provide the
investment advisory services requested.
As stated above, LongView offers the LongView Wealth Management Wrap Program. The program
is offered as a wrap fee program and LongView’s Advisory Representatives are the portfolio
managers. The wrap fee will be allocated to LongView and deducted from your Advisory
Representative’s fee.
LongView does not charge performance-based fees.
LongView conducts economic analysis and attempts to analyze and determine the trends.
Additionally, LongView conducts fundamental analysis. Fundamental analysis generally involves
assessing a company’s or security’s value based on factors such as sales, assets, markets, management,
products and services, earnings, and financial structure.
LongView will conduct technical market analysis and technical trend following. Technical analysis
generally involves studying trends and movements in a security’s price, trading volume, and other
market-related factors in an attempt to discern patterns.
LongView does not vote your securities. Unless you suppress proxies, securities proxies will be sent
directly to you by the account custodian or transfer agent. You may contact LongView about questions
LongView Wealth Management
you may have an opinion on how to vote the proxies. However, the voting and how you vote the
proxies is solely your decision.
As of December 31, 2025, we managed approximately $1,153,392350 of client assets under
management on a discretionary basis and $188,490 on a non-discretionary basis.
Item 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS
Your Advisory Representative will gather various information about you including, but not limited to,
investment objectives and goals, personal information such as social security number, address, birth
date and other information to verify your identity, financial information such as net worth, income,
liquid net worth, prior investment experience, employer information, etc. During annual reviews your
Advisory Representative will ask questions and may request you to complete updated account
documents or verify the information you have provided remains current.
Item 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS
You may contact your Advisory Representative or any Advisory Representative of LongView at any
time.
Item 9 – ADDITIONAL INFORMATION
Some of the Advisor’s investment advisor representatives are registered representatives of M.S.
Howells & Co., a registered broker/dealer, member FINRA and SIPC. Clients are not obligated to
purchase or sell securities through the investment advisor representatives in these separate capacities.
However, if clients choose to implement the advice provided by Advisor through its investment
advisor representatives in their separate capacities as registered representatives, M.S. Howells & Co.
will be used, and commissions will be earned in addition to any fees paid for advisory services.
LongView is not and does not have a related person who is a: futures commission merchant,
commodity pool operator, commodity trading advisor, or an associated person of the foregoing
entities. Further, LongView is not and does not have a related person who is: broker/dealer or other
similar type of broker or dealer; investment company or other pooled investment vehicle, futures
commission merchant or commodity pool operator; banking or thrift institution; accountant or
accounting firm; lawyer or law firm; insurance company or agency; pension consultant; real estate
broker or dealer; or sponsor or syndicator of a limited partnership.
LongView attempts to mitigate conflicts of interest with the receipt of commissions if
recommendations are implemented by providing you with these disclosures. Further, you are
encouraged to consult other professionals and may implement recommendations through other
financial professionals. Furthermore, as a registered representative with M.S. Howells & Co.,
Advisory Representatives are subject to a supervisory structure at M.S. Howells & Co. for their
securities business.
LongView and its management persons are not actively engaged in any other business. Further,
LongView does not have a related person who is a: broker/dealer or other similar type of broker or
dealer; investment company or other pooled investment vehicle; futures commission merchant or
commodity pool operator; banking or thrift institution; accountant or accounting firm; lawyer or law
firm; insurance company or agency; pension consultant; real estate broker or dealer; or sponsor or
syndicator of a limited partnership.
LongView Wealth Management
LongView recommends other investment advisers (i.e. third-party managers) and will receive a
portion of the fee charged to you by the investment adviser or will charge a fee in addition to the third-
party managers. Since LongView has an interest in the compensation this is considered a material
conflict of interest. LongView selects third party managers based on several criteria including cost,
type of management, past history, ability to meet a need and provide a unique service. Since the fee
charged to you is based on the value of your portfolio, all parties have an incentive to work toward
performance goals and objectives. Consequently, if the third-party manager does not adequately
manage your account and the value of your portfolio goes down, so does the third-party manager’s
and LongView’s compensation.
Code of Ethics
B.
LongView has a fiduciary duty to you to act in your best interest and always place your interests first
and foremost. LongView takes seriously its compliance and regulatory obligations and requires all
staff to comply with such rules and regulations as well as LongView’s policies and procedures.
Further, LongView strives to handle your non-public information in such a way to protect information
from falling into hands that have no business reason to know such information and provides you with
LongView’s Privacy Policy. As such, LongView maintains a code of ethics for its Advisory
Representatives, supervised persons and staff. The Code of Ethics contains provisions for standards
of business conduct in order to comply with federal securities laws, personal securities reporting
requirements, pre-approval procedures for certain
transactions, code violations reporting
requirements, and safeguarding of material non-public information about your transactions. Further,
LongView’s Code of Ethics establishes LongView’s expectation for business conduct. A copy of our
Code of Ethics will be provided to you upon request.
Neither LongView nor its associated persons recommends to clients or buys or sells for client
accounts any securities in which we have a material financial interest.
LongView and its associated persons buy or sell securities identical to those securities recommended
to you. Therefore, LongView and/or its associated persons have an interest or position in certain
securities that are also recommended and bought or sold to you. LongView and its associated persons
will not put their interests before your interest. LongView and its associated persons may not trade
ahead of you or trade in such a way to obtain a better price for themselves than for you or other clients.
LongView is required to maintain a list of all securities holdings for its associated persons and
develop procedures to supervise the trading activities of associated persons who have knowledge of
your transactions and their related family accounts at least quarterly. Further, associated persons are
prohibited from trading on non-public information or sharing such information.
You have the right to decline any investment recommendation. LongView and its associated persons
are required to conduct their securities and investment advisory business in accordance with all
applicable Federal and State securities regulations.
Prohibition on Use of Insider Information
LongView has adopted policies and procedures to prevent the misuse of “insider” information (i.e.
material n, non-public information). A copy of such policies and procedures is available to any person
upon request.
LongView Wealth Management
Review of Accounts
C.
You will be invited to participate in a review not less than at least annually or as agreed by you and
your Advisory Representative. You may request more frequent reviews and may set thresholds for
triggering events that would cause a review to take place. Your Advisory Representative will monitor
for changes or shifts in the economy, changes to the management and structure of a mutual fund or
company in which your assets are invested, and market shifts and corrections.
You are advised that you must notify your Advisory Representative promptly of any changes to your
financial goals, objectives or financial situation as such changes may require him review the potfolio
allocation and make recommendations for changes.
Clients participating in managed account programs will be provided statements at least quarterly direct
from the account custodian. Additionally, you will receive confirmations of all transactions occuring
direct from the account custodian. You may request additional account summary reports from
LongView at any time. You should compare any report produced by LongView with statements
received direct from the account custodian. Should there be any discrepancy the account custodian’s
report will prevail.
Client Referrals and Other Compensation
D.
Investment product vendors recommended by LongView can provide monetary and non-monetary
assistance with client events, provide educational tools and resources. LongView does not select
products as a result of any monetary or non-monetary assistance. LongView’s due diligence of a
product does not take into consideration any assistance it may receive. However, the receipt of any form
of compensation, either directly or indirectly, is considered a conflict of interest.
We also receive an economic benefit from Schwab in the form of the support products and services it
makes available to us and other independent investment advisors whose clients maintain their accounts
at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we
would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a
certain size. You do not pay more for assets maintained at Schwab as a result of these arrangements.
However, we benefit from the arrangement because the cost of these services would otherwise be
borne directly by us. You should consider these conflicts of interest when selecting a custodian. The
products and services provided by Schwab, how they benefit us, and the related conflicts of interest
are described above.
LongView mitigates this conflict of interest by supervising the activities of the Advisory
Representatives, reviewing the investment recommendations provided to the clients, implementing
policies and procedures, including the Code of Ethics. We also encourage you to discuss any
recommendations provided by your Advisory Representative with another financial professional if
you have any concerns about the appropriateness of the recommendation based on your financial
situation.
Our firm may engage in promoter arrangements for client referrals. These individual promoters offer
our services to the public. The Firm pays a referral fee to the promoter based on a portion of the
management fees charged by the Firm and memorialized in a written agreement (“Promoter
Agreement”). In all cases, the Firm will comply with the cash solicitation rules established by the SEC,
state regulators and the client disclosure requirements. If a referred prospective client enters into an
investment advisory agreement with the Firm, a referral fee is paid to the referring party. The referral
LongView Wealth Management
relationship will not result in clients being charged any fees over and above the normal advisory fees
charged for the advisory services provided. The Firm will pay the promoter their share of the total
fee. The Promoter Agreement requires that the promoter be appropriately registered under federal and
state securities laws where applicable. Clients receive all related agreements and disclosures prior to
or at the time of entering into an Investment Advisory Agreement with the Firm.
CUSTODY
E.
All client accounts are held at qualified custodians. LongView does not take physical custody of your
funds or securities. LongView may be deemed to have constructive custody if a client has a standing
letter of authorization (SLOA) to transfer funds or securities to a third party and LongView has the
ability to direct transfers, change the amount, and/or the timing of the transfer.
Under the applicable regulations, we are deemed to have custody of your assets if, for example, you
authorize us to instruct your account custodian to deduct our advisory fees directly from your account
or if you grant us authority to move your money to another person’s account. Your custodian maintains
physical custody of your assets. You will receive account statements directly from your account
custodian at least quarterly. They will be sent to the email or postal mailing address you provided.
You should carefully review those statements promptly when you receive them.
Standing Letters of Authorization
Some clients may execute limited powers of attorney or other standing letters of authorization that
permit the firm to transfer money from their account with the client’s independent qualified Custodian
to third parties.$ This authorization to direct the Custodian may be deemed to cause our firm to
exercise limited custody over your funds or securities and for regulatory reporting purposes, we are
required to keep track of the number of clients and accounts for which we may have this ability. We
do not have physical custody of any of your funds and/or securities. Your funds and securities will be
held with a bank, broker-dealer, or other independent, qualified custodian. You will receive account
statements from the independent, qualified custodian(s) holding your funds and securities at least
quarterly. The account statements from your custodian(s) will indicate any transfers that may have
taken place within your account(s) each billing period. You should carefully review account
statements for accuracy.
Item 10 - REQUIREMENTS FOR STATE REGISTERED ADVISERS
This section is not applicable to LongView. LongView is not state registered. LongView is registered
with the Securities and Exchange Commission.