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Part 2A of Form ADV: Firm Brochure
Form ADV, Part 2A, Item 1
Cover Page
Canopy 360 Wealth, LLC
104 SE 1ST AVENUE, SUITE B
Ocala, Florida 34471
Tel: (352) 369-1120
Fax: (352) 351-9393
January 23, 2026
FORM ADV PART 2
FIRM BROCHURE
This brochure provides information about the qualifications and business practices of Canopy 360
Wealth, LLC. If you have any questions about the contents of this brochure, please contact us at
(352) 369-1120. 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 Canopy 360 Wealth, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Canopy 360 Wealth, LLC is 296771.
Canopy 360 Wealth, LLC is a Registered Investment Adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain
level of skill or training.
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Form ADV, Part 2A, Item 2
Material Changes
Canopy 360 Wealth, LLC was established as a new Registered Investment Advisor in June 2018
under the Securities and Exchange Commission rules and regulations.
Each year we will deliver to you, by no later than April 30th, a free updated brochure that includes
or is accompanied by a summary of material changes; or a summary of material changes and an
offer to provide a copy of the updated brochure and how to obtain it. This disclosure brochure
provides prospective clients with information about Canopy 360 Wealth, LLC that should be
considered before, or at the time of, obtaining our advisory services. This brochure is required to
be updated at least annually, or sooner when material changes to our business take place. Please
retain a copy of this Disclosure Brochure for your records.
There have been the following material changes made since the last annual update was filed on
February 7, 2025:
• None
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Form ADV, Part 2A, Item 3
Table of Contents
Advisory Business…………………………………………………………… ................ 4
Fees and Compensation…………………………………………………….. ............... 5
Performance-Based Fees and Side-By-Side Management……………. ............... 8
Types of Clients………………………………………………………………. ................ 8
Methods of Analysis, Investment Strategies, and Risk of Loss……… ............... 8
Disciplinary Information…………………………………………………….. .............. 10
Other Financial Industry Activities and Affiliations……………………. .............. 10
Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading………………………………………………………………………… ............... 11
Brokerage Practices………………………………………………………….. ............. 12
Review of Accounts………………………………………………………….. ............. 13
Client Referrals and Other Compensation……………………………….. ............. 14
Custody………………………………………………………………………… .............. 14
Investment Discretion……………………………………………………….. .............. 15
Voting Client Securities……………………………………………………… ............. 15
Financial Information………………………………………………………… ............. 15
Requirements for State-Registered Advisers…………………………… .............. 16
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Form ADV Part 2A, Item 4
Advisory Business
including, but not
limited
Canopy 360 Wealth, LLC (hereinafter called “Canopy 360”) is a Registered Investment Adviser
based in Ocala, Florida, and incorporated under the laws of the State of Florida. Canopy 360 is
owned by Lindsay Financial Services, LLC and Powers Wealth Management, LLC, and those
entities are owned by Russell Lindsay, Lance Powers and Jamie Losito. Canopy 360 is
registered with the Securities and Exchange Commission and is subject to its rules and
regulations. Founded in June 2018, Canopy 360 provides investment advisory services, which
may include, but are not limited to, the review of client investment objectives and goals,
recommending asset allocation strategies of managed assets among investment products such as
cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment strategies.
Our investment advice is tailored to meet our clients’ needs and investment objectives. Clients
may impose restrictions on investing in certain securities or types of securities (such as a product
type, specific companies, specific sectors, etc.) by providing a signed and dated written
notification, of which an e-mail is also an acceptable form of notification. Canopy 360 also
provides financial planning consulting services
to, risk
assessment/management, investment planning, estate planning, financial organization, or
financial decision making/negotiation.
Canopy 360 provides investment advisory and other financial services through its Investment
Advisory Representatives ("IAR") to accounts opened with Canopy 360. Managed Accounts
are available to individuals and small businesses.
Canopy 360 provides discretionary and non-discretionary investment advisory services to some
of its clients through various managed accounts. Canopy 360 will assist clients in determining
the suitability of the investments within the managed account(s) for the client. The IAR is
compensated through a comprehensive single fee and the account may be assessed other charges
associated with conducting a brokerage business. Canopy 360 and its IAR, as appropriate, will
be responsible for the following:
• Performing due diligence
• Recommending strategic asset and style allocations
• Providing research on investment product options, as needed
• Providing client risk profile questionnaire
• Obtaining investment advisory contract from client with required financial, risk
tolerance, suitability and investment vehicle selection information for each new account
• Performing client suitability check on account documentation, review the investment
objectives and evaluate the investment vehicle selections
• Providing Firm Brochure (this document)
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Canopy 360, in providing the services agreed upon with the Client, may refer the Client to an
unaffiliated Securities and Exchange Commission registered investment adviser (“referred
advisor”) to manage all or a portion of the managed assets. The Client will be required to sign
an Investment Advisory Agreement of the advisor for which Canopy 360 referred, and this
authorizes the referred adviser discretionary trading authority. If this occurs, Canopy 360 will
be responsible for the continuing supervision of the Client's account. Client understands that the
advisory fees paid to Canopy 360 are included in the advisory fees paid to the referred adviser.
Client will also be required to sign a disclosure document stating the portion of the advisory fees
paid to the referred advisor and the portion paid to Canopy 360.
Canopy 360 may recommend a Wrap Fee Program for the client’s account(s). A “Wrap Fee
Program” for purposes of the SEC is a program under which investment advisory and brokerage
execution services are provided for a single “wrapped” fee that is not based on the transactions
in a client account. Canopy 360 provides discretionary investment advisory services to some of
its clients through a Wrap Fee Program. Canopy 360 will assist clients in determining the
suitability of the Wrap Fee Program for the client. Wrap Fee Program accounts recommended
by Canopy 360 are not managed differently from non-Wrap Fee Program accounts. Because
brokerage execution costs are included in the client’s overall advisory fee, the client’s fee may
be greater than those that have accounts in non-Wrap Fee Program accounts, however fees will
not exceed the fee schedule stated in Canopy 360’s Wrap Fee Brochure. All clients with Wrap
Fee Program accounts will be provided with Canopy 360’s Wrap Fee Brochure. This Brochure
is focused on non-Wrap Fee Program accounts.
As of January 5, 2026, the firm has total client assets under management in the amount of
$382,820,511; that includes $323,748,226 in discretionary assets and $59,072,285 in non-
discretionary assets.
Form ADV, Part 2A, Item 5
Fees and Compensation
The following types of fees will be assessed:
Asset Management – Fees are charged monthly in advance and are based primarily on asset size
and the level of complexity of the services provided. In individual cases, Canopy 360 has the
sole discretion to negotiate fees that are lower than the standard fee shown or to waive fees. Fees
are not based on the share of capital gains or capital appreciation of the funds or any portion of
the funds. Comparable services for lower fees may be available from other sources. Fees for the
initial month or quarter will be prorated based upon the number of calendar days in the calendar
month or quarter that the advisory agreement is in effect. Fees are based on the market value of
the assets on the last business day of the previous month or quarter. Annual fees range from
.75% - 3.00% depending on the amount of assets under management (“AUM”) – See chart
below. Consulting services are included in these fees for asset management services with the
exception of unique circumstances that may require a separate agreement for financial planning
services (description and fees are discussed below). If the situation warrants separate financial
planning fees, it will be discussed upfront and a separate agreement will be negotiated.
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Fee Schedule for Asset Management:
Total Account Value
Maximum Annual Advisory Fee
First $250,000 3.00%
Next $250,000 2.50%
Next $500,000 2.00%
Next $1,500,000 1.50%
Next $2,500,000
1.00%
Additional Assets 0.75%
As authorized in the client agreement, the account custodian withdraws Canopy 360 Wealth,
LLC’s advisory fees directly from the clients’ accounts according to the custodian’s policies,
practices, and procedures. The custodial statement includes the amount of any fees paid to Canopy
360 for advisory services. You should carefully review the statement from your custodian/broker-
dealer’s statement and verify the calculation of fees. Your custodian/broker-dealer does not verify
the accuracy of fee calculations.
Fees are charged in advance on a monthly basis, meaning that advisory fees for a month are
charged on the first day of the month. Clients may terminate investment advisory services obtained
from Canopy 360, without penalty, upon written notice within five (5) business days after entering
into the advisory agreement with Canopy 360. The client is responsible for any fees and charges
incurred by the client from third parties as a result of maintaining the account such as transaction
fees for any securities transactions executed and account maintenance or custodial fees.
Thereafter, the client may terminate advisory services upon written notice delivered to and
received by Canopy 360. Clients who terminate investment advisory services during a month are
charged a prorated advisory fee based on the date of Canopy 360’s receipt of client’s written notice
to terminate. The client may obtain a pro-rated refund of a pre-paid fee if the advisory contract is
terminated before the end of the billing period by contacting Russell Lindsay at (352) 369-1120.
For clients that are referred to another SEC registered investment adviser, Canopy 360 will receive
a flat fee of 0.50%, collected by the referred entity and paid to Canopy 360.
Financial Planning – Financial planning services are charged in advance through a fixed fee or
hourly arrangement as agreed upon between the client and Canopy 360 Wealth, LLC. There will
never be an instance where $1,200 or more in fees is charged six or more months in advance.
Hourly fees are generally charged when the scope of services cannot be determined or if the
services are limited to one meeting. Fixed fees are generally quoted to the client for longer-term
consulting projects. Fees are negotiable and vary depending upon the complexity of the client
situation and services to be provided. Hourly fees range from $200 - $750 per hour, depending on
what is negotiated between Canopy 360 and the client. Similar financial planning services may
be available elsewhere for a lower cost to the client. Fixed fees for longer-term consulting projects
range from $750 to $50,000 per project. An estimate for total hours and charges is determined at
the start of the advisory relationship.
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Typically, clients will be invoiced monthly for all time spent by Canopy 360 as agreed upon by
client or upon completion of the services if less than a month. Clients who wish to terminate the
planning process prior to completion may do so with written notice. Upon receipt of written
notification, any earned fee will immediately become due and payable, and any unearned, pre-paid
fee will be promptly refunded. A client may terminate an advisory agreement without being
assessed any fees or expenses within five (5) days of its signing.
Additional Fees and Expenses
In addition to advisory fees paid to Canopy 360 as explained above, clients may pay custodial
service, account maintenance, transaction, and other fees associated with maintaining the account.
Some of these fees may be included in Wrap Fee Program accounts as described above in Item 4
– Advisory Services. These fees vary by broker and/or custodian. Clients should ask Canopy 360
for details on transaction fees or other custodial fees specific to their account, as these fees are not
included in the annual advisory fee. Canopy 360 does not share any portion of such fees.
Additionally, for any mutual funds purchased, the client may pay their proportionate share of the
funds’ distribution, internal management, investment advisory and administrative fees. Such fees
are not shared with Canopy 360 and are compensation to the fund manager. Clients are urged to
read the mutual fund prospectus prior to investing.
Mutual fund companies impose internal fees and expenses on clients. These fees are in addition
to the costs associated with the investment advisory services as described above. Complete details
of such internal expenses are specified and disclosed in each mutual fund company’s prospectus.
Clients are strongly advised to review the prospectus(es) prior to investing in such securities.
Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that would
not exist if the purchase or sale were made directly with the mutual fund company. Mutual funds
held in broker-dealer accounts also charge management fees. These mutual fund management fees
may be more or less than the mutual fund management fees charged if the client held the mutual
fund directly with the mutual fund company.
Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal
underwriter, or a distributor without purchasing the services of Canopy 360 or paying the advisory
fee on such shares (but subject to any applicable sales charges). Certain mutual funds are offered
to the public without a sales charge. In the case of mutual funds offered with a sales charge, the
prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the
applicable advisory fee. However, clients would not receive Canopy 360’s assistance in
developing an investment strategy, selecting securities, monitoring performance of the account,
and making changes as necessary.
Please refer to Item 12 “Brokerage Practices” of this brochure for additional information.
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Form ADV, Part 2A, Item 6
Performance-Based Fees and Side-By-Side Management
Canopy 360 Wealth, LLC does not charge performance-based fees or participate in side-by-side
management. Side-by-side management refers to the practice of managing accounts that are
charged performance-based fees while at the same time managing accounts that are not charged
performance-based fees. Performance-based fees are fees that are based on a share of capital gains
or appreciation of the assets of a client. Our fees are calculated as described in Fees and
Compensation section above and are not charged on the basis of performance of your advisory
account.
Form ADV, Part 2A, Item 7
Types of Clients
Canopy 360 offers investment advisory services to individuals and small businesses. There is no
minimum account size to open and maintain an advisory account.
Form ADV, Part 2A, Item 8
Methods of Analysis, Investment Strategies, and Risk of Loss
Canopy 360’s methods of analysis and investment strategies incorporate the client’s needs and
investment objectives, time horizon, and risk tolerance. Canopy 360 is not bound to a specific
investment strategy for the management of investment portfolios, but rather consider the risk
tolerance levels pre-determined gathered at the account opening, as well as on an on-going basis.
Examples of methodologies that our investment strategies may incorporate include:
Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix
of asset classes and the efficient allocation of capital to those assets by matching rates of return to
a specified and quantifiable tolerance for risk.
Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount
of securities at regularly scheduled intervals, regardless of the price per share. This will gradually,
over time, decrease the average share price of the security. Dollar-cost averaging lessens the risk
of investing a large amount in a single investment at the wrong time.
Technical Analysis – involves studying past price patterns and trends in the financial markets to
predict the direction of both the overall market and specific stocks.
Long-Term Purchases – securities purchased with the expectation that the value of those securities
will grow over a relatively long period of time, generally greater than one year.
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Short-Term Purchases – securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities’
short-term price fluctuations.
Our strategies and investments may have unique and significant tax implications. Regardless of
your account size or other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.
Investing in securities involves risk of loss that clients should be prepared to bear. Although we
manage your portfolio with strategies and in a manner consistent with your risk tolerances, there
can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of
loss.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of future
earnings. These risks include market risk, interest rate risk, issuer risk, and general economic risk.
Regardless of the methods of analysis or strategies suggested for your particular investment goals,
you should carefully consider these risks, as they all bear risks.
Below are some more specific risks of investing:
Market Risk. The prices of securities in which clients invest may decline in response to certain
events taking place around the world, including those directly involving the companies whose
securities are owned by the client or an underlying fund; conditions affecting the general economy;
overall market changes; local, regional or global political, social or economic instability; and
currency, interest rate and commodity price fluctuations. Investors should have a long-term
perspective and be able to tolerate potentially sharp declines in market value.
Management Risk. Canopy 360’s investment approach may fail to produce the intended results.
If our perception of the performance of a specific asset class or underlying fund is not realized in
the expected time frame, the overall performance of client’s portfolio may suffer.
Equity Risk. Equity securities tend to be more volatile than other investment choices. The value
of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility
affects the value of the client’s overall portfolio. Small- and mid-cap companies are subject to
additional risks. Smaller companies may experience greater volatility, higher failure rates, more
limited markets, product lines, financial resources, and less management experience than larger
companies. Smaller companies may also have a lower trading volume, which may
disproportionately affect their market price, tending to make them fall more in response to selling
pressure than is the case with larger companies.
Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and
principal payments when due. Generally, the lower the credit rating of a security, the greater the
risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower
rating, the value of the debt security will decline because investors will demand a higher rate of
return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.
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Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may
be affected by adverse political, legislative and tax changes, as well as by financial developments
that affect the municipal issuers. Because many municipal obligations are issued to finance similar
projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.), conditions in
the sector related to the project can affect the overall municipal market. Payment of municipal
obligations may depend on an issuer’s general unrestricted revenues, revenue generated by a
specific project, the operator of the project, or government appropriation or aid. There is a greater
risk if investors can look only to the revenue generated by the project. In addition, municipal bonds
generally are traded in the “over-the-counter” market among dealers and other large institutional
investors. From time to time, liquidity in the municipal bond market (the ability to buy and sell
bonds readily) may be reduced in response to overall economic conditions and credit tightening.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client
indirectly bears its proportionate share of any fees and expenses payable directly by those funds.
Therefore, the client will incur higher expenses, many of which may be duplicative. In addition,
the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk
arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs
are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above
or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high
leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials
deem such action appropriate, the shares are de-listed from the exchange, or the activation of
market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock
trading generally. Canopy 360 has no control over the risks taken by the underlying funds.
Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by the
Firm to service client accounts have artificial intelligence components. The use of artificial
intelligence and machine learning includes increased risk of data inaccuracies and security
vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks
related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our
clients, the Firm performs periodic due diligence of our service providers for assurance that the
service providers have appropriate controls in place to protect our clients’ information and to limit
data inaccuracies when artificial intelligence is used by the service provider.
Form ADV, Part 2A, Item 9
Disciplinary Information
Canopy 360 Wealth, LLC or its Principal Executive Officers have not had any reportable
disclosable events in the past ten years.
Form ADV, Part 2A, Item 10
Other Financial Industry Activities and Affiliations
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Canopy 360 Wealth, LLC or its IARs are not currently registered with any broker dealer.
Neither Canopy 360 nor its representatives are registered as a Futures Commission Merchant,
Commodity Pool Operator, or a Commodity Trading Advisor.
Certain persons associated with Canopy 360 are also associated with Lindsay, Crabb & Associates,
LLC, an accounting and consulting firm providing audit, compliance, tax consulting and financial
planning services to clients. Canopy 360 is an affiliate, and Russell Lindsay is an indirect owner
of Canopy 360, as well as a partner of Lindsay, Crabb & Associates, LLC. If you require
accounting and/or tax services, Canopy 360 may recommend Lindsay, Crabb & Associates, LLC.
Our advisory services and compensation are separate and distinct from the services provided by
Lindsay, Crabb & Associates, LLC. Our recommendation for you to use the services of Lindsay,
Crabb & Associates, LLC may appear to present a conflict of interest because we have a financial
incentive to recommend our affiliate’s services. While we strongly believe that integrating tax and
accounting services provides a value added to our investment advisory clients, you may choose to
have another firm to provide these services. You are under no obligation to use our affiliate’s
services and may obtain comparable services through other firms.
IARs of Canopy 360 may also be licensed insurance agents. From time to time, they may offer
clients advice or products from those activities. Clients should be aware that these services pay a
commission and involve a possible conflict of interest, as commissionable products can conflict
with the fiduciary duties of a registered investment adviser. Canopy 360 always acts in the best
interest of the client, including the sale of commissionable products to advisory clients. Clients
are in no way required to implement the plan through any representative of Canopy 360 in their
capacity as an insurance agent.
Form ADV, Part 2A, Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Canopy 360’s Code of Ethics includes guidelines for professional standards of conduct for our
Associated Persons. Our goal is to protect client interests at all times and to demonstrate our
commitment to fiduciary duties of honesty, good faith, and fair dealing. All of Canopy 360’s
Associated Persons are expected to strictly adhere to these guidelines. Persons associated with
Canopy 360 Wealth, LLC are also required to report any violations to the Code of Ethics.
Additionally, the firm maintains and enforces written policies reasonably designed to prevent the
misuse or dissemination of material, non-public information about our clients or client accounts
by persons associated with our firm.
Canopy 360 and its employees may buy or sell securities that are also held by clients. It is the
expressed policy of the advisor that no person employed by our firm purchase or sell any security
prior to the transaction being implemented for an advisory account; therefore, preventing such
employees from benefiting from transactions placed on behalf of the advisory clients.
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The advisor may have an interest or position in a certain security, which may also be recommended
to the client. As these situations may present a conflict of interest, the advisor has established the
following restrictions in order to ensure its fiduciary responsibilities:
1. A director, officer or employee of the advisor shall not buy or sell a security for their
personal portfolio(s) where their decision is substantially derived, in whole or part, by
reason of his or her employment, unless the information is also available to the investing
public. No owner/employee of Canopy 360 shall prefer their own interest to that of the
client.
2. The advisor maintains a list of all securities held by the company and all directors, officers,
and employees. These holdings are reviewed on a quarterly basis by the principal of the
firm.
3. The advisor requires that all employees must act in accordance with all applicable Federal
and State regulations governing registered investment advisors.
4. The advisor may block personal trades with those of clients but will ensure that
clients are not at a disadvantage.
Canopy 360’s Code of Ethics is available to you upon request. You may obtain a copy of our
Code of Ethics by contacting Russell Lindsay at (352) 369-1120.
Form ADV, Part 2A, Item 12
Brokerage Practices
In order for Canopy 360 to provide asset management services, we request you utilize the
brokerage and custodial services of Charles Schwab & Co., Inc. or Raymond James Financial,
Inc., for which we have an existing relationship. In considering which independent qualified
custodian will be the best fit for Canopy 360’s business model, we evaluate the following factors,
which is not an all-inclusive list:
Financial strength
Reputation
Reporting capabilities
Execution capabilities
Pricing, and
Types and quality of research
While you are free to choose any broker-dealer or other service provider, we recommend that you
establish an account with a brokerage firm with which we have an existing relationship. Such
relationships may include benefits provided to our firm, including, but not limited to research,
market information, and administrative services that help our firm manage your account(s). We
believe that recommended broker-dealers provide quality execution services for our clients at
competitive prices. Price is not the sole factor we consider in evaluating best execution. We also
consider the quality of the brokerage services provided by the recommended broker-dealers,
including the value of research provided, the firm’s reputation, execution capabilities, commission
rates, and responsiveness to our clients and our firm.
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You may direct us in writing to use a particular broker-dealer to execute some or all of the
transactions for your account. If you do so, you are responsible for negotiating the terms and
arrangements for the account with that broker-dealer. We may not be able to negotiate
commissions, obtain volume discounts, or best execution. In addition, under these circumstances
a difference in commission charges may exist between the commissions charged to clients who
direct us to use a particular broker or dealer and other clients who do not direct us to use a particular
broker or dealer.
Canopy 360 does not have any soft dollar arrangements.
Canopy 360 does not receive client referrals from broker-dealers in exchange for cash or other
compensation, such as brokerage services or research.
When Canopy 360 buys or sells the same security for two or more clients (including our personal
accounts), we may place concurrent orders to be executed together as a single “block” in order to
facilitate orderly and efficient execution. Each client account will be charged or credited with the
average price per unit. We receive no additional compensation or remuneration of any kind
because we aggregate client transactions. No client is favored over any other client. If an order is
not completely filled, it is allocated pro-rata based on an allocation statement prepared by Canopy
360 prior to placing the order. Because of an order’s aggregation, some clients may pay higher
transaction costs, or greater spreads, or receive less favorable net prices on transactions than would
otherwise be the case if the order had not been aggregated. Canopy 360 may choose to aggregate
orders for its proprietary or personnel’s accounts with those of its clients. Canopy 360 will receive
no additional compensation or remuneration resulting from the aggregation of client transactions.
Form ADV, Part 2A, Item 13
Review of Accounts
Client accounts are reviewed at least quarterly by Russell Lindsay, Lance Powers or Jamie Losito,
Executive Officers of the firm. Accounts are reviewed with regard to their investment policies and
risk tolerance levels. All accounts at Canopy 360 are assigned to these reviewers.
All financial planning accounts are reviewed upon financial plan creation and plan delivery by one
or more of the Executive Officers of the firm. There is only one level of review and that is the total
review conducted to create the financial plan.
Reviews may be triggered by material market, economic or political events, or by changes in
client's financial situations (such as retirement, termination of employment, physical move, or
inheritance).
Each client will receive at least quarterly a written report that details the clients’ account which
may come from the custodian.
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Form ADV, Part 2A, Item 14
Client Referrals and Other Compensation
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 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.
Form ADV, Part 2A, Item 15
Custody
Canopy 360 does not have physical custody of any client funds and/or securities and does not take
custody of client accounts at any time. Client funds and securities will be held with a bank, broker
dealer, or other independent qualified custodian. However, by granting Canopy 360 written
authorization to automatically deduct fees from client accounts, Canopy 360 is deemed to have
limited custody. You will receive account statements from the independent, qualified custodian
holding your funds at least quarterly. The account statement from your custodian will indicate the
amount of advisory fees deducted from your account(s) each billing cycle. Clients should carefully
review statements received from the custodian.
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.
We use a third-party platform to facilitate management of held away assets such as defined
contribution plan participant accounts, with discretion. The platform allows us to avoid being
considered to have custody of Client funds since we do not have direct access to Client log-in
credentials to affect trades. We are not affiliated with the platform in any way and receive no
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compensation from them for using their platform. A link will be provided to the Client allowing
them to connect an account(s) to the platform. Once Client account(s) is connected to the platform,
Adviser will review the current account allocations. When deemed necessary, Adviser will
rebalance the account considering client investment goals and risk tolerance, and any change in
allocations will consider current economic and market trends. The goal is to improve account
performance over time, minimize loss during difficult markets, and manage internal fees that harm
account performance. Client account(s) will be reviewed at least quarterly and allocation changes
will be made as deemed necessary.
Form ADV, Part 2A, Item 16
Investment Discretion
Before Canopy 360 can buy or sell securities on your behalf, you must first sign our discretionary
management agreement, a limited power of attorney, and/or trading authorization forms. By
choosing to do so, you may grant the firm discretion over the selection and amount of securities to
be purchased or sold for your account(s) without obtaining your consent or approval prior to each
transaction. Clients may impose limitations on discretionary authority for investing in certain
securities or types of securities (such as a product type, specific companies, specific sectors, etc.),
as well as other limitations as expressed by the client. Limitations on discretionary authority are
required to be provided to the IAR in writing. Please refer to the “Advisory Business” section of
this Brochure for more information on our discretionary management services.
Form ADV, Part 2A, Item 17
Voting Client Securities
Canopy 360 does not vote proxies on behalf of Client advisory accounts. At the Client’s request,
Canopy 360 may offer you advice regarding corporate actions and the exercise of the proxy voting
rights. If the Client owns shares of common stock or mutual funds, the Client is responsible for
exercising your right to vote as a shareholder.
In most cases, the Client will receive proxy materials directly from the account custodian.
However, in the event we were to receive any written or electronic proxy materials, we would
forward them directly to you by mail, unless you have authorized our firm to contact you by
electronic mail, in which case, we would forward any electronic solicitation to vote proxies.
Form ADV, Part 2A, Item 18
Financial Information
Canopy 360 is not required to provide financial information to our clients because we do not
require or solicit the prepayment of more than $1,200 six or more months in advance.
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Form ADV, Part 2A, Item 19
Requirements for State-Registered Advisers
This section is not applicable because the firm is registered with the Securities and Exchange
Commission.
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