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Disclosure Brochure
ADV Part 2A
CFO4Life Group, LLC
735 Plaza Blvd., Suite 100
Coppell, TX 75019
Ph. (214) 637-9500 / Fax (214) 637-9595
www.mycfo4life.com
March 25, 2026
This Brochure provides important information about the qualifications and business
practices of CFO4Life Group, LLC. If you have any questions about the contents of this Brochure,
please contact us at 214-637-9500. The information in this Brochure has not been approved or
verified by the United States Securities and Exchange Commission (SEC) or by any state securities
authority. CFO4Life’s registration as an investment adviser does not imply a certain level of skill
or training.
Additional information about CFO4Life Group, LLC is also available on the SEC’s website
at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a
CRD number. The CRD number for CFO4Life Group, LLC is 287600.
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Item 2 – Material Changes
Our clients are strongly encouraged to read this Brochure in its entirety prior to engaging CFO4Life
for investment advisory or financial planning services. We will provide, or offer to provide, a copy of this
Brochure annually to each of our clients. We may also provide updates between annual offers if there are
material changes to the information in this Brochure. Our Brochure may be requested by contacting us at
214-637-9500.
CFO4Life has the following material change to report as of last annual filing on March 25, 2025.
CFO4Life has appointed Roseann Higgins as Chief Compliance Officer as of the date of this filing.
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Item 3 – Table of Contents
Item 1 – Cover Page………………………………………………………………………………1
Item 2 – Material Changes………………………………………………………………………..2
Item 3 – Table of Contents………………………………………………………………………..3
Item 4 – Advisory Business………………………………………………………………………4
Item 5 – Fees and Compensation…………………………………………………………………8
Item 6 – Performance-Based Fees and Side-by-Side Management……………………………..11
Item 7 – Types of Clients………………………………………………………………………..11
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss………………………...11
Item 9 – Disciplinary Information……………………………………………………………….16
Item 10 – Other Financial Industry Activities and Affiliations………………………………….16
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading…………………………………………………………………………………………...19
Item 12 – Brokerage Practices…………………………………………………………………...20
Item 13 – Review of Accounts…………………………………………………………………...22
Item 14 – Client Referrals and Other Compensation…………………………………………….23
Item 15 – Custody………………………………………………………………………………..26
Item 16 – Investment Discretion…………………………………………………………………26
Item 17 – Voting Client Securities……………………………………………………………….26
Item 18 – Financial Information…………………………………………………………………27
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Item 4 – Advisory Business
A. Introduction
CFO4Life Group, LLC (“CFO4Life” or “the Firm”) is an SEC registered investment adviser.
CFO4Life’s registration as an investment adviser does not imply a certain level of skill or training.
The oral and written communications we provide to you, including this Brochure, is information
that you should use in your decision to hire us or continue a professional relationship with us. This Brochure
provides information about our qualifications and business practices.
B. Ownership
CFO4Life is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically,
CFO4Life is a wholly-owned indirect subsidiary of Focus LLC. Focus Financial Partners Inc. is the sole
managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of
directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and
collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment
vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because
CFO4Life is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment
vehicles are indirect owners of CFO4Life.
Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants,
insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth
management, benefit consulting and investment consulting services to individuals, families, employers, and
institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment
companies as disclosed on their respective Form ADVs.
CFO4Life is managed by Levi McMellian and Brian Chastain (“CFO4Life Principals”), pursuant to
a management agreement between MGMT4Life LLC and CFO4Life. The CFO4Life Principals serve as
leaders and officers of CFO4Life and are responsible for the management, supervision and oversight of
CFO4Life.
While this Brochure generally describes the business of CFO4Life, certain sections also discuss the
activities of its personnel, including its officers, partners, directors, employees (or other persons occupying
a similar status or performing similar functions) or any other person who provides investment advice on
behalf of CFO4Life and is subject to the Firm’s supervision or control (each, a “Supervised Person”).
C. Financial Planning and Advisory Services
CFO4Life offers the following services:
Comprehensive Financial Planning and Investment Management Services to affluent
1.
individuals and business executives;
Advisory Services to Retirement Plans;
2.
Corporate Services – Investment Education and Financial Wellness: and
3.
Cash Management Solutions.
4.
A description of each service is provided below.
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Comprehensive Financial Planning Services
CFO4Life offers personal comprehensive financial planning services to set forth goals, objectives
and implementation strategies for the client over the long-term. Depending upon individual client
requirements, the comprehensive financial plan will include recommendations for retirement planning,
educational planning, estate planning, cash flow planning, tax planning and insurance needs and analysis.
CFO4Life prepares and provides the financial planning client with a written comprehensive financial plan
and performs quarterly, semi-annual or annual reviews of the plan with the client, dependent on the client’s
needs in accordance with the financial planning agreement. Clients should notify us promptly anytime there
is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the financial
information initially provided to us.
Clients are under no obligation to implement any of the recommendations provided in their written
financial plan. However, should a client decide to proceed with the implementation of the investment
recommendations then the client can either have CFO4Life implement those recommendations or utilize the
services of any investment adviser or broker-dealer of their choice.
CFO4Life cannot provide any guarantees or promises that a client’s financial goals and objectives
will be met.
Investment Management Services
CFO4Life offers investment management services on a discretionary basis. All investment advice
provided is customized to each client’s investment objectives and financial needs. The information provided
by the client, together with any other information relating to the client’s overall financial circumstances, will
be used by CFO4Life to determine the appropriate portfolio asset allocation and investment strategy for the
client. Financial planning services also are provided, depending on the needs of the client.
The securities utilized by CFO4Life for investment in client accounts mainly consist of registered
mutual funds and exchange traded funds (ETFs), but we will also invest in equity securities, corporate
bonds, REITS and variable annuities, among others, if we determine such investments fit within a client’s
objectives and are in the best interest of our clients. Please refer to Item 8 for detailed information on our
method of analysis and the risks involved with these types of securities.
Wrap Programs Offered by Third Party Managers
When appropriate, CFO4Life will allocate certain client assets to third-party separate account
managers. For example, Fidelity Managed Account Xchange may be used for actively managed separate
accounts. When engaging Fidelity Managed Account Exchange, clients will be assessed an all-in-one “wrap
fee” for custody, brokerage, investment management and performance reporting services for the third-party
separate account, rather than individual trading and other costs. CFO4Life will provide clients a copy of
program brochures prior to or concurrently with any asset allocations through these platforms.
Advisory Services to Retirement Plans
CFO4Life offers discretionary and non-discretionary advisory services to 401k Plans, which
include, depending on the needs of the 401k Plan client, recommending, or for discretionary clients
selecting, investment options for plans to offer to participants, ongoing monitoring of a plan’s investment
options, assisting plan fiduciaries in creating and/or updating the plan’s written investment policy statements,
working with plan service providers, and providing general investment education to plan participants.
Education for plan participants covers information regarding: financial planning; risk management;
types of investments; estate planning; and taxes. These education services are provided in the form of
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written materials and seminars.
Corporate Services – Investment Education and Financial Wellness
CFO4Life offers services to corporations that include investment education for corporate
executives, economic updates for corporate investment committees and/or benefits coordinators, and
financial wellness for corporate executives. Education for executives covers topics such as: financial
planning; risk management; types of investments; estate planning; and taxes. These education services are
provided in the form of written materials and seminars.
Economic updates are generally provided during face-to-face meetings covering items such as the
state of the economy, forecasts for growth, inflation, interest rates and other key economic factors, and
analysis of current levels of the stock market, recent news and other current hot topics.
Financial Wellness is a benefit that corporations can provide to their employees through CFO4Life
wherein CFO4Life will meet with the employees to discuss overall objectives, needs and goals, and provide
a written analysis and financial planning recommendations to the employees. Employees are under no
obligation to implement any recommendations provided. However, should an employee decide to proceed
with the implementation of the recommendations, then the employee has the option of entering into a
separate engagement with CFO4Life and can either have CFO4Life implement the recommendations, or
the employee can utilize the services of another investment adviser or broker-dealer of their choice.
Cash Management Solutions
We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus
Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners,
LLC. Please see Items 5 and 10 for a fuller discussion of this service and other important information.
We offer clients the option of obtaining certain financial solutions from unaffiliated third -party
financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its
affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Please see Items 5 and 10 for a fuller
discussion of these services and other important information.
D. Important Information Relating to CFO4Life’s Services
Information Received From Clients
CFO4Life will not assume any responsibility for the accuracy of the information provided by the
client. We are not obligated to verify any information received from the client or other professionals (e.g.,
attorney, accountant, etc.) designated by client, and CFO4Life is expressly authorized by the client to rely
on such information provided. Under all circumstances, clients are responsible for promptly notifying
CFO4Life in writing of any material changes to the client’s financial situation, investment objectives, time
horizon, or risk tolerance. In the event that a client notifies CFO4Life of changes in the client’s financial
circumstances or investment objectives, we will review such changes and recommend any necessary
revisions to the client’s portfolio.
Client Agreements and Disclosures
Prior to engaging CFO4Life to provide services, the client will be required to enter into one or more
written agreements with us setting forth the terms and conditions under which the Firm shall render its
services (collectively, the “Agreement”). In accordance with Rule 204-3 under the Investment Advisers Act
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of 1940, as amended (“Advisers Act”), CFO4Life will provide this Brochure and one or more brochure
supplements (Form ADV Part 2B) to each client prior to or contemporaneously with the execution of the
Agreement.
As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed
on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or
limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations
under the federal and state securities laws or as a waiver of any unwaivable rights you possess.
Neither CFO4Life nor the client may assign the written agreement without the consent of the other
party. Transactions that do not result in a change of actual control or management of CFO4Life shall not
be considered an assignment.
Fiduciary Status for Retirement Plan Accounts
CFO4Life is a fiduciary under the Employment Retirement Income Security Act of 1974, as
amended (“ERISA”) with respect to investment management services and investment advice provided to
ERISA plan clients, including ERISA plan participants. CFO4Life is also a fiduciary under the Internal
Revenue Code (the “IRC”) with respect to investment management services and investment advice
provided to ERISA plans, ERISA plan participants, individual retirement accounts and individual
retirement account owners (collectively “Retirement Account Clients”). As such, CFO4Life is subject to
specific duties and obligations under ERISA and the IRC, that include, among other things, prohibited
transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a
fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the
conflict or rely upon a prohibited transaction exemption (a “PTE”).
E. Assets Under Management
As of December 31, 2025 the following represents the amount of client assets under management
by CFO4Life on a discretionary and non-discretionary basis.
Type of Account
Assets Under Management (AUM)
Discretionary
$1,902,285,860
Non-Discretionary
$33,227,352
Total
$1,935,513,212
As outlined in Item 10 below, certain IARs of CFO4Life are also registered representatives
(RRs) with Ausdal Financial Partners (“Ausdal”), a registered broker-dealer and member of
FINRA. Ausdal and CFO4Life are not affiliated companies. These RRs have client brokerage
accounts that total $254,601,442 in assets as of December 31, 2025. The brokerage assets are not
managed by CFO4Life and are not included in the AUM amount listed above. Total advisory and
brokerage assets as of December 31, 2025 are $2,190,114,654.
Item 5 – Fees and Compensation
Financial Planning and Advisory Fees
A.
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CFO4Life charges fees based on a percentage of assets under management as well as fixed fees,
depending on the particular types of services to be provided. CFO4Life includes the value of accrued
interest and accrued dividends for billing purposes. The specific fees charged by CFO4Life for services
provided will be set forth in each client’s Agreement.
Fees for Comprehensive Financial Planning Services
Clients that are receiving financial planning services only are charged an annual fixed fee ranging
from $10,000 to $15,000, depending on the complexity of a client’s plan and services provided. Initially,
25% of the annual fee is due upon entering into the agreement with the Firm and the remainder of the annual
fee is charged quarterly thereafter based on a calendar quarter. Actual fees charged are clearly outlined in
the financial planning agreement and clients receive invoices reflecting the amount of the fee due and
payable. Please refer to “Additional Information Regarding Fees” below for more detailed information
regarding fees paid by CFO4Life clients.
Fees for Investment Management Services
Advisory clients are charged a quarterly fee based on the account’s assets under management
(AUM) as of the close of business on the last business day of the preceding calendar quarter without
adjustments for deposits, additions or withdrawals during the billing period. Asset management fees are
calculated and paid quarterly in advance and the management fee ranges from 1.00% to 1.50% (per annum).
See below in Section B. Additional Information Regarding Fees for information regarding clients paying
fees for investment management services which are less than the listed fee range. For the purposes of fee
calculation, assets under management include cash and cash equivalents, as well as margined securities.
CFO4Life does not reduce management fees for margin borrowing, regardless of whether the assets are in
cash or other securities. CFO4Life has a financial incentive to recommend that clients borrow money for
the purchase of additional securities for the client’s account managed by CFO4Life or otherwise not
liquidate some or all the assets CFO4Life manages. CFO4Life addresses this conflict of interest by this
disclosure and working to ensure that any recommendation to a client regarding the use of margin is suitable
for the client.
In 2018 CFO4Life completed the acquisition of Vogel Financial Advisors, LLC. Clients of Vogel
Financial Advisors who became clients of CFO4Life through that acquisition maintained the fee schedule
that was applicable to that client while a client of Vogel Financial Advisors. The Vogel Financial Advisors
fee schedule maintained for these clients contain advisory fee breakpoints that are effective as a client’s
account reaches certain asset levels. In addition, a limited number of CFO4Life client accounts are subject
to a breakpoint fee schedule. For these grandfathered Vogel Financial Advisors accounts and the limited
number of other CFO4Life accounts, CFO4Life works to ensure that all related client accounts, specifically
the accounts of direct family members sharing the same residence address, are included in determining a
client’s applicable fee rate. Other than the Vogel Financial Advisors grandfathered accounts and limited
number of other CFO4Life accounts, CFO4Life accounts are not subject to a breakpoint fee schedule and,
therefore, the “householding” of related client accounts is not applicable.
Lower fees for comparable services may be available from other sources. These fees may be
negotiated by CFO4Life under certain circumstances, and at the sole discretion of CFO4Life. Unless
otherwise arranged by the client, our advisory fees are automatically deducted from a client’s account by
the custodian of the account as soon as reasonably practicable after the end of each calendar quarter. For
accounts opened or closed after the beginning of a new calendar quarter, our fees will be prorated. For new
accounts CFO4Life generally will make the initial fee deduction shortly after the finalization of the client
relationship.
Fees for Wrap Programs
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Advisory clients that participate in a third -party separate account manager’s wrap fee programs are
charged a separate fee on those assets. The wrap fee includes CFO4Life’s advisory fee, fees to the Fidelity
Managed Account Xchange as the program provider, and fees to the third-party manager for investment
management services. The wrap fee paid by clients in the wrap program differs from CFO4Life’s typical
investment management fee in that the wrap fee is inclusive of trade execution costs, while in a non -wrap
program account, the client pays trade execution costs directly to the broker, and such costs are in addition
to the investment management fee charged by CFO4Life. The fee schedules for the third-party manager
wrap fee programs are provided in the respective adviser wrap fee program brochure and advisory client
agreements. Clients are encouraged to carefully review the contents of these brochures with their advisor,
including descriptions of the various programs and services offered, as well as fees and charges.
CFO4Life’s advisory fee component within the wrap program will be determined by the client’s
total relationship size and be reflected on the client’s investment management agreement. The third -party
managers will have a tiered fee schedule commensurate with the level of assets at the individual client or
CFO4Life firm level. Aperio Group pricing is currently 15 bps and Quantinno is at 2.2bps in addition to
CFO4Life’s advisory fee component. Fidelity Managed Account Xchange fees vary depending on the
separate account manager. In addition, the third-party managers calculate the fees payable by clients. The
third-party manager may calculate fees in a different fashion than CFO4Life. As an example, the third-
party managers may value client assets for fee billing purposes by the average daily balance, rather than the
end of the preceding period valuation as per CFO4Life’s procedures. In addition, third-party managers may
make adjustments for account deposits, additions or withdrawals. As detailed above, CFO4Life does not
make valuation adjustments for client deposits, additions or withdrawals. For fee billing purposes
CFO4Life values the account as of the close of business on the last business day of the preceding calendar
quarter with no adjustments for deposits, additions or withdrawals during the billing period.
Fees for Advisory Services to Retirement Plans
Retirement plan advisory clients will be charged an annual fixed fee or an asset based fee. The
annual fixed fees range from $30,000 to $200,000, depending on the complexity of the services provided.
Initially, 25% of the annual fee is due upon entering into the agreement with the Firm and the remainder of
the annual fee is charged quarterly thereafter at the end of each calendar quarter. For retirement plan
advisory clients subject to an asset based fee, the percentage fee amounts range from .10% to .75% (per
annum).
Actual fees charged are clearly outlined in the client agreement and clients receive invoices
reflecting the amount of the fee due and payable. Please refer to “Additional Information Regarding Fees”
below for more detailed information regarding fees paid by CFO4 Life clients.
Fees for Corporate Services
Corporate clients are charged an annual fixed fee ranging from $50,000 to $250,000, depending on
the actual services provided. Initially, 25% of the annual fee is due upon entering into the agreement with
the Firm and the remainder of the annual fee is charged quarterly thereafter at the end of each calendar
quarter. Actual fees charged are clearly outlined in the client agreement and clients receive invoices
reflecting the amount of the fee due and payable. Please refer to “Additional Information Regarding Fees”
below for more detailed information regarding fees paid by CFO4Life clients.
Cash Management Solutions
CFO4Life Group, LLC | ADV Part 2A Brochure
We offer clients the option of obtaining certain financial solutions from unaffiliated third -party
financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its
affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). . Focus Financial Partners, LLC (“Focus”)
is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such
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third-party financial institutions for serving our clients. Although the revenue paid to UPTIQ benefits
UPTIQ, Inc.’s investors, including Focus, our parent company, no Focus affiliate will receive any
compensation from UPTIQ or Flourish that is attributable to our clients’ transactions. Further information
on this conflict of interest is available in Item 10 of this Brochure.
Additional Information Regarding Fees
B.
CFO4Life fees are negotiable and arrangements with any particular client may differ from those
described above. CFO4Life may, in its sole discretion, waive its fees in their entirety for friends and family
of the Firm and/or reduce its fees for certain clients, and could change the above listed fee amounts at any
time. Fee reductions for certain clients can represent fee rates significantly lower than the above listed fee
range.
Although CFO4Life believes that its fees are competitive, clients should understand that lower fees
for comparable services may be available from other sources and firms. The fees charged by CFO4Life do
not include charges imposed by third parties such as custodian fees, ETFs, private investment funds, and
mutual fund fees and expenses. Client assets will also be subject to transaction costs, retirement plan
administration fees (if applicable), deferred sales charges on mutual funds initially deposited in the account,
12b-1 fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and
taxes on brokerage accounts and securities transactions.
Client assets invested in ETFs, private investment funds, and mutual funds will be subject to certain
fees and expenses imposed directly by funds to their shareholders, which are described in each fund’s
prospectus. These fees will generally include a management fee, other fund expenses, and a possible
distribution fee. If the sponsor also imposes sales charges, a client will pay initial or deferred sales or
surrender charges. These fees and expenses are separate from and in addition to the fees charged by
CFO4Life. Accordingly, the client should review the fees charged by any mutual funds in which the client’s
assets are invested, together with the fees charged by CFO4Life, to fully understand the total amount of fees
to be paid by the client and to thereby evaluate the advisory services being provided.
Additionally, clients will incur brokerage commissions and other execution costs charged by the
custodian or executing broker-dealer in connection with transactions for a client’s account. Clients should
further understand that all custodial fees and any other charges, fees and commissions incurred in
connection with transactions for a client’s account will be paid out of the assets in the account and are
exclusive of and in addition to the fees charged by CFO4Life. We do not share in any of these fees but we
may elect at our option, to bear the cost of certain transactions under certain circumstances. Please refer to
Item 12 of this Brochure entitled “Brokerage Practices” for additional important information about the
brokerage and transactional practices of CFO4Life.
The Agreement between CFO4Life and the client will continue in effect until terminated by either
party pursuant to the terms of the Agreement. As noted above, CFO4Life’s advisory fees are generally paid
in advance. CFO4Life will issue a refund equal to any unearned advisory fee for the remainder of the billing
period prorated through the date of termination. The client may specify how he/she would like such refund
issued (i.e. a check sent directly to the client or a check sent to the client’s custodian for deposit into his/her
account).
Important Considerations
C.
Compensation for Sales of Securities or Other Investment Products
CFO4Life Group, LLC | ADV Part 2A Brochure
As described in Item 4, certain representatives of CFO4Life, in their individual capacities, also
areregistered representatives of Ausdal. In this capacity, these individuals will transact in various types of
securities or investment products and will receive separate and typical compensation for doing so. Clients
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have the option to purchase investment products that CFO4Life recommends through other brokers or
agents that are not affiliated with CFO4Life.
Certain IARs of CFO4Life also are licensed insurance agents and are appointed with various life,
health and disability insurance companies. In such a capacity they will offer insurance products as a
recommendation to a client’s financial plan and receive a normal and customary commission and other
indirect benefits as a result of such a purchase.
Please refer to Item 10 below for detailed information regarding these arrangements, along with
the conflicts surrounding such and the steps CFO4Life has in place to help mitigate the conflicts.
We offer clients the option of obtaining certain financial solutions from unaffiliated third -party
financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its
affiliates, “UPTIQ”). Focus Financial Partners, LLC (“Focus”) is a minority investor in UPTIQ, Inc.
UPTIQ is compensated by sharing in the revenue earned by such third -party financial institutions for
serving our clients. Although the revenue paid to UPTIQ benefits UPTIQ, Inc.’s investors, including Focus,
our parent company, no Focus affiliate will receive any compensation from UPTIQ that is attributable to
our clients’ transactions. Further information on this conflict of interest is available in Item 10 of this
Brochure.
We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus
Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners,
LLC. FRS assists our clients with regulated insurance sales activity by advising our clients on insurance
matters and placing insurance products for them and/or referring our clients to certain third-party insurance
brokers (the “Brokers”), with whom FRS has agreements, which either separately or togethe r with FRS
place insurance products for them. FRS does not receive any compensation from the Brokers or any other
third parties for serving our clients. Additionally, in exchange for allowing certain of the Brokers to offer
their services to clients of other Focus firms, FRS receives periodic fees (the “Platform Fees”) from such
Brokers. The Platform Fees are expected to change over time. Such Platform Fees are revenue for FRS and,
ultimately, for our common parent company, Focus, but we do not share in such revenue and no portion of
the Platform Fees is attributable to our clients’ use of the Brokers’ services. Further information on this
service is available in Item 10 of this Brochure.
Item 6 – Performance-Based Fees and Side-by-Side Management
CFO4Life does not charge performance-based fees (i.e., fees assessed based on a share of capital
gains on or capital appreciation of a client’s assets). Consequently, CFO4Life does not engage in side-by-
side management of accounts that are charged a performance-based fee with accounts that are charged
another type of fee (such as assets under management). As described above, CFO4Life provides investment
management services for a fee based upon a percentage of assets under management. Notably, accounts
that are managed in the same investment style (e.g., moderately aggressive) may not be managed the same
way due to the client's overall investment objective, asset size and account restrictions.
Item 7 – Types of Clients
CFO4Life provides services to affluent individuals and business executives, trusts, estates,
charitable organizations, retirement plans, corporations and other businesses. CFO4Life imposes a
minimum portfolio size or a minimum initial investment of $2 million and a net worth of $5 million
to open an account, but does reserve the right to waive these minimums or accept or decline a potential
client for any reason in its sole discretion.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
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Methods of Analysis and Investment Strategies
A.
When providing investment advice, we base our analysis on creating a diversified portfolio (Asset
Allocation Model) that is compatible with a client’s goals, objectives, risk tolerance and time horizon for
investment. CFO4Life evaluates the client’s investment holdings using software such as Morningstar,
BlackRock’s Aladdin, Orion Risk Intelligence, and other tools. CFO4Life also utilizes a variety of financial
publications such as the Wall Street Journal, Value Line and Dow Theory to make investment
recommendations.
Our recommendations and investments are based on the asset allocation model which considers
each client’s risk tolerance and time horizon for holding such investments. The Firm utilizes primarily
mutual funds and ETFs. We focus on allocating among three main asset classes: equities; fixed income;
and alternative investments, which can include commodities, real estate, private equity, private debt, and
hedge funds. CFO4Life monitors clients’ allocations and may reallocate investments in an effort to reduce
risk and increase performance. Additionally, for certain clients CFO4Life will utilize private funds, i.e.
funds subject to a registration exemption under the federal securities laws. CFO4Life may sell certain
investments for reasons that include, but are not limited to, overvaluation or overweighting of a position,
change in the client’s investment objectives and risk tolerance, and indications of severe and prolonged
market downturns.
Risk of Loss
B.
Investing in securities involves a significant risk of loss which clients should be prepared to bear.
CFO4Life’s investment recommendations are subject to various market, currency, economic, political and
business risks, and such investment decisions will not always be profitable. Clients should be aware that
there may be a loss or depreciation to the value of the client’s account. There can be no assurance that the
client’s investment objectives will be obtained and no inference to the contrary should be made.
Generally, the market value of equity stocks will fluctuate with market conditions, and small- stock
prices generally will fluctuate more than large-stock prices. The market value of fixed income securities
will generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed
income securities are obligations of the issuer to make payments of principal and/or interest on future dates,
and include, among other securities: bonds, notes and debentures issued by corporations; debt securities
issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, or by a non -U.S.
government or one of its agencies or instrumentalities; municipal securities; and mortgage-backed and asset-
backed securities. These securities may pay fixed, variable, or floating rates of interest, and may include
zero coupon obligations and inflation-linked fixed income securities. The value of longer duration fixed
income securities will generally fluctuate more than shorter duration fixed income securities. Investments in
overseas markets also pose special risks, including currency fluctuation and political risks, and it may be
more volatile than that of a U.S. only investment. Such risks are generally intensified for investments in
emerging markets. In addition, there is no assurance that a mutual fund or ETF will achieve its investment
objective. Past performance of investments is no guarantee of future results.
Additional risks involved in the securities recommended by CFO4Life include, among others:
•
Stock market risk, which is the chance that stock prices overall will decline. The market
value of equity securities will generally fluctuate with market conditions. Stock markets tend to move in
cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend to fluctuate
over the short term as a result of factors affecting the individual companies, industries or the securities
market as a whole. Equity securities generally have greater price volatility than fixed income securities.
•
Sector risk, which is the chance that significant problems will affect a particular sector, or
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that returns from that sector will trail returns from the overall stock market. Daily fluctuations in specific
market sectors are often more extreme than fluctuations in the overall market.
•
Issuer risk, which is the risk that the value of a security will decline for reasons directly
related to the issuer, such as management performance, financial leverage, and reduced demand for the
issuer's goods or services.
•
Non-diversification risk, which is the risk of focusing investments in a small number of
issuers, industries or foreign currencies, including being more susceptible to risks associated with a single
economic, political or regulatory occurrence than a more diversified portfolio might be.
•
Value investing risk, which is the risk that value stocks not increase in price, not issue
the anticipated stock dividends, or decline in price, either because the market fails to recognize the stock’s
intrinsic value, or because the expected value was misgauged. If the market does not recognize that the
securities are undervalued, the prices of those securities might not appreciate as anticipated. They also may
decline in price even though in theory they are already undervalued. Value stocks are typically less volatile
than growth stocks, but may lag behind growth stocks in an up market.
•
Smaller company risk, which is the risk that the value of securities issued by a smaller
company will go up or down, sometimes rapidly and unpredictably as compared to more widely held
securities. Investments in smaller companies are subject to greater levels of credit, market and issuer risk.
•
Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities
result in the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests
exclusively in securities of U.S. companies. Risks associated with investing in foreign securities include
fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value of a security,
the possibility of substantial price volatility as a result of political and economic instability in the foreign
country, less public information about issuers of securities, different securities regulation, different
accounting, auditing and financial reporting standards and less liquidity than in the U.S. markets.
•
Interest rate risk, which is the chance that prices of fixed income securities decline
because of rising interest rates. Similarly, the income from fixed income securities may decline because of
falling interest rates.
•
Credit risk, which is the chance that an issuer of a fixed income security will fail to pay
interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such
payments will cause the price of that fixed income security to decline.
•
Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF,
including the possible loss of principal. ETFs typically trade on a securities exchange and the prices of their
shares fluctuate throughout the day based on supply and demand, which may not correlate to their net asset
values. Although ETF shares will be listed on an exchange, there can be no guarantee that an active trading
market will develop or continue. Owning an ETF generally reflects the risks of owning the underlying
securities it is designed to track. ETFs are also subject to secondary market trading risks. In addition, an
ETF may not replicate exactly the performance of the index it seeks to track for a number of reasons,
including transaction costs incurred by the ETF, the temporary unavailability of certain securities in the
secondary market, or discrepancies between the ETF and the index with respect to weighting of securities
or number of securities held.
•
Management risk, which is the risk that the investment techniques and risk analyses
applied by CFO4Life may not produce the desired results and that legislative, regulatory, or tax
developments, affect the investment techniques available to CFO4Life. There is no guarantee that a client’s
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investment objectives will be achieved.
•
Real Estate risk, which is the risk that an investor’s investments in Real Estate Investment
Trusts (“REITs”) or real estate-linked derivative instruments will subject the investor to risks similar to
those associated with direct ownership of real estate, including losses from casualty or condemnation, and
changes in local and general economic conditions, supply and demand, interest rates, zoning laws,
regulatory limitations on rents, property taxes and operating expenses. An investment in REITs or real
estate-linked derivative instruments subject the investor to management and tax risks.
•
Investment Companies (“Mutual Funds”) risk, when an investor invests in mutual
funds, the investor will bear additional expenses based on his/her pro rata share of the mutual fund’s
operating expenses, including the management fees. The risk of owning a mutual fund generally reflects
the risks of owning the underlying investments the mutual fund holds.
•
Commodity risk, generally commodity prices fluctuate for many reasons, including
changes in market and economic conditions or political circumstances (especially of key energy -producing
and consuming countries), the impact of weather on demand, levels of domestic production and imported
commodities, energy conservation, domestic and foreign governmental regulation (agricultural, trade,
fiscal, monetary and exchange control), international politics, policies of OPEC, taxation and the
availability of local, intrastate and interstate transportation systems and the emotions of the marketplace. The
risk of loss in trading commodities can be substantial.
•
Cybersecurity risk, which is the risk related to unauthorized access to the systems and
networks of CFO4Life and its service providers. The computer systems, networks and devices used by
CFO4Life and service providers to us and our clients to carry out routine business operations employ a
variety of protections designed to prevent damage or interruption from computer viruses, network failures,
computer and telecommunication failures, infiltration by unauthorized persons and security breaches.
Despite the various protections utilized, systems, networks or devices potentially can be breached. A client
could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include
unauthorized access to systems, networks or devices; infection from computer viruses or other malicious
software code; and attacks that shut down, disable, slow or otherwise disrupt operations, business processes
or website access or functionality. Cybersecurity breaches may cause disruptions and impact business
operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and
other service providers to transact business; violations of applicable privacy and other laws; regulatory
fines, penalties, reputational damage, reimbursement or other compensation costs, or other compliance
costs; as well as the inadvertent release of confidential information. Similar adverse consequences could
result from cybersecurity breaches affecting issues of securities in which a client invests; governmental and
other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers and
other financial institutions; and other parties. In addition, substantial costs may be incurred by those entities
in order to prevent any cybersecurity breaches in the future.
•
Cryptocurrency risk, Cryptocurrency is a digital representation of value that functions
as a medium of exchange, a unit of account, or a store of value, but it does not have legal tender status.
Cryptocurrencies are sometimes exchanged for U.S. dollars or other world currencies, but they are not
generally backed or supported by any government or central bank. They are more volatile than traditional
currencies. Their value is speculative, given that they are not currently, widely accepted as a medium or
exchange, is derived by market forces of supply and demand, and may be impacted by the continued
willingness of market participants to exchange fiat currency for cryptocurrency. Cryptocurrencies are not
covered by either FDIC or SIPC insurance. Bitcoin, Ethereum and other cryptocurrencies are very
speculative investments and involve a high degree of risk. An investment in cryptocurrency is not suitable
for all investors, and may not generally be appropriate, particularly with funds drawn from retirement
savings, student loans, mortgages, emergency funds, or funds set aside for other purposes. Investors must
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have the financial ability, sophistication/experience and willingness to bear the risks of an investment, and
a potential total loss of their investment. An investment in cryptocurrency should be made with capital
allocated to speculative purposes. Fees and expenses associated with a cryptocurrency investment may be
substantial. Cryptocurrency exchanges and other trading venues on which cryptocurrencies trade are
relatively new and, in most cases, largely unregulated and may therefore be more exposed to fraud and
failure than established, regulated exchanges for securities, derivatives and other currencies. Investments
that are related to cryptocurrencies could be subject to volatility experienced by the cryptocurrency
exchanges and other cryptocurrency trading venues. Cryptocurrency exchanges may stop operating or
permanently shut down due to fraud, technical glitches, hackers or malware, which may also affect the price
of bitcoin and other cryptocurrencies and indirect investments in cryptocurrencies. In addition to the risks
above, clients should consider the following risks:
•
History of volatility, The exchange rate of cryptocurrency historically has been very
volatile and the exchange rate of a cryptocurrency could drastically decline. For
example, the exchange rate of Bitcoin has dropped more than 50% in a single day.
Cryptocurrency-related investments may be affected by such volatility.
•
Government regulation, Cryptocurrencies largely lack regulatory protections.
Federal, state or foreign governments may restrict the use and exchange of
cryptocurrency. Legislative and regulatory changes or actions at the federal, state or
international level may adversely affect the use, transfer, exchange, and value of
cryptocurrency.
•
Security concerns, Cryptocurrency exchanges may stop operating or permanently shut
down due to fraud, technical glitches, hackers or malware. Cryptocurrency also may
be stolen by hackers.
•
New and developing, As a relatively recent invention, cryptocurrency and related
investments do not have an established track record of operating history, performance,
credibility and/or trust. Bitcoin and other cryptocurrencies are evolving.
Cryptocurrencies use blockchain technology, which lacks standardization
•
Alternative Investments / Private Funds risk, CFO4Life recommends that certain
clients who are interested and financially qualified invest in alternative investments. Alternative
investments generally involve various risk factors, including, but not limited to, high fees, the potential
for complete loss of principal, and risks associated with the use of leverage, liquidity constraints, tax
complexity, and lack of transparency. Unlike other, more liquid, investments that a client may maintain,
certain alternative investments do not provide daily liquidity or pricing. Alternative investment vehicles
are varied, and each requires a careful evaluation of the specific structure of the fund, management team’s
experience, and operational risks. CFO4Life urges clients to review carefully the complete discussion of
risk factors set forth in the offering documents (including the private offering memorandum) which are
provided to each prospective investor for review and consideration for the relevant alternative investment
that we recommend. For alternative investments other than liquid alternatives, each prospective client
investor will be required to complete a Subscription Agreement or similar offering document, pursuant to
which the client shall establish that he/she is qualified for investment in the alternative investment and
acknowledges and accepts the various risk factors that are associated with such an investment. Investing
in alternative investments is speculative, not suitable for all clients, and intended for experienced and
sophisticated investors who are willing to bear the high economic risks of the investment, which can
include:
•
loss of all or a substantial portion of the investment due to leveraging, short-selling or
other speculative investment practices;
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•
lack of liquidity in that there may be no secondary market for the investment and none
expected to develop;
•
volatility of returns;
•
restrictions on transferring interests in the investment;
•
potential lack of diversification and resulting higher risk due to concentration of trading
authority when a single adviser is utilized;
•
absence of information regarding valuations and pricing;
•
delays in tax reporting;
•
less regulation and higher fees than mutual funds;
•
risks associated with the operations, personnel, and processes of the manager of the
funds investing in alternative investments.
There also are risks surrounding various insurance products that are recommended to CFO4Life
clients from time to time. Such risks include, but are not limited to loss of premiums. Prior to purchasing
any insurance product, clients should carefully read the policy and applicable disclosure documents.
Clients are advised that they should only commit assets for management that can be invested for
the long term, that volatility from investing can occur, and that all investing is subject to risk. CFO4Life
does not guarantee the future performance of a client’s portfolio, as investing in securities involves the risk
of loss that clients should be prepared to bear.
Item 9 – Disciplinary Information
Registered investment advisers, such as CFO4Life are required to disclose all material facts
regarding any legal or disciplinary events that would be material to a client’s or prospective client’s
evaluation of CFO4Life or the integrity of CFO4Life management. CFO4Life has no disciplinary
information to disclose.
Item 10 – Other Financial Industry Activities and Affiliations
As mentioned above in Items 4 and 5, certain IARs of CFO4Life also are RRs with the broker-
dealer Ausdal. In this capacity, such RRs offer securities or alternative investments and receive normal and
customary fees or commissions as a result of these transactions. In addition, these individuals receive
additional ongoing 12b-1 fees for mutual fund purchases from the mutual fund company during the period
that the client maintains the mutual fund investment. As a result of this relationship, Ausdal has access to
certain confidential information (e.g., financial information, investment objectives, transactions and
holdings) about clients, even if a client does not establish an account through Ausdal. If you would like a
copy of the Ausdal privacy policy, please contact CFO4Life as described on the cover page of this Brochure.
Clients should be aware that the receipt of additional compensation itself creates an inherent
conflict of interest, and may affect the judgment of these individuals when making recommendations.
CFO4Life and Ausdal are separate, nonaffiliated entities. Nevertheless, to the extent that a CFO4Life
representative recommends the purchase of securities or other investment products where the representative
receives commissions for doing so, a conflict of interest exists because the representative is incentivized to
make recommendations based on the compensation received rather than on a client’s needs.
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Certain IARs of CFO4Life also are licensed insurance agents and are appointed with various life,
health and disability insurance companies. Messrs. McMellian and Chastain are the principal owners of
LMBC II, LLC and receive insurance commissions for the previous sales of life insurance products by and through
LMBC II, LLC. In addition, there are times when CFO4Life IARs, including Mr. McMellian, recommend the
purchase of certain insurance products to CFO4Life clients as part of their financial plan. Upon purchase,
Mr. McMellian in his capacity as an insurance agent will receive normal and customary commissions.
Mr. McMellian, by and through LMBC II or in his individual capacity as an insurance agent, as
applicable, has arrangements with Sewell Uselton Insurance Agency and PH Robb BGA, both unaffiliated
insurance agencies, wherein Mr. McMellian, as applicable, offers certain types of insurance products as a
recommendation to certain CFO4Life clients. Under these arrangements, he will receive a portion of the
normal and customary commissions paid as a result of such purchases. Furthermore, LMBC II, LLC
has an arrangement with Hub International and Grayhawk Insurance Group, LLC, unaffiliated property
and casualty insurance agencies, wherein LMBC II, LLC and those IARs of CFO4Life who are licensed
insurance agents under LMBC II, LLC offer certain types of insurance products as a recommendation to
CFO4Life clients. Similar to the Sewell Uselton Insurance Agency and PH Robb BGA arrangements, LMBC
II, LLC, Mr. McMellian in his individual capacity as an insurance agent and/or those IARs licensed as
insurance agents will receive a portion of the normal and customary commissions paid as a result of such
purchases.Again, these arrangements present conflicts of interest to the extent that the insurance agent/IAR
is incentivized to make recommendations based on the commissions being paid to them and/or any indirect
benefit received.
CFO4Life has also adopted certain procedures designed to mitigate the effects of these conflicts.
As part of our fiduciary duty to clients, the Firm and our representatives endeavor at all times to put the
interests of the clients first, and recommendations will only be made to the extent that they are reasonably
believed to be in the best interests of the client. Additionally, the conflicts presented by these practices are
disclosed to clients through this Brochure, client agreement and/or verbally prior to or at the time of entering
into an Agreement. Clients are not obligated to implement recommended transactions through any
CFO4Life representative or any particular broker-dealer or insurance carrier. Clients have the option to
purchase any recommended investment and insurance products or services through brokers, carriers, or
agents other than Ausdal, LMBC II, LLC, Hub International TX, Inc., Sewell Uselton Insurance Agency,
or any recommended third party managers.
CFO4Life clients should understand that lower fees and/or commissions for comparable services
may be available from other broker-dealers, insurance carriers and investment advisers.
Messrs. McMellian and Chastain also have ownership interests in the following companies:
• LMBC II, LLC – a licensed insurance agency and also provides tax and business consulting
services to corporations and certain retirement educational services to a corporation’s 401K
Plan participants and other employees as requested (each own 47.5% - Rusty Boaz of the
Firm owns 5%); and
• MGMT4Life LLC – the Management Company as described above in Item 4 (each own 50%).
Among other services, LMBC II, LLC offers retirement educational services to 401K Plan
participants under the name of “Financial Wellness 4 Life.” These services are provided via access to a
dedicated website and also through telephonic and email communications with certain professionals, such
as CPAs, CFPs, MBAs, AIFs, and insurance specialists. Some of these professionals are IARs of CFO4Life,
including Mr. McMellian and Mr. Chastain. Additionally, there are times when an IAR or other
representative of CFO4Life refers a CFO4Life 401K Plan client to LMBC II, LLC for consideration of
obtaining some or all of the non-investment related services provided by such firm, including the retirement
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educational services offered to 401K Plan participants. The IARs of CFO4Life do not receive any type of
compensation for such referrals or for the educational services they provide through Financial Wellness 4
Life. However, Messrs. McMellian and Chastain as owners of LMBC II, LLC receive an indirect benefit
since they share in that firm’s profits and losses, which include fees received from LMBC II, LLC clients
under the Financial Wellness 4 Life program.
LMBC II, LLC has entered into a loan servicing agreement with Pennsylvania-based Tristate
Capital Bank (“Tristate”), whereby Tristate will offer certain types of collateralized loans to LMBC II, LLC
clients that have been referred to Tristate by LMBC II, LLC. For each loan obtained by such clients, Tristate
will pay a referral fee to LMBC II, LLC in the form of revenue share payments. There are times when a
LMBC II, LLC client referred to Tristate is also a client of CFO4Life. CFO4Life has an additional conflict
of interest when personnel recommend that clients obtain a loan through Tristate, because CFO4Life’s
interest in continuing to receive investment advisory fees from client accounts gives CFO4Life a financial
incentive to recommend that clients borrow money rather than liquidating some or all of the assets
CFO4Life manages.
In addition, LMBC II, LLC has, and intends to continue to, enter into referral agreements with
certain non-affiliated third party companies, such as insurance brokers and service agencies, whereby
LMBC II, LLC will refer potential clients to such companies and receive a fee. There will be times when
LMBC II, LLC refers an LMBC II, LLC client to one or more of the companies that also is a client of
CFO4Life.
For complete details regarding the time spent, compensation received and potential conflicts with
each of the above listed affiliated companies, please refer to ADV Part 2B – Supplemental Brochures for
Messrs. McMellian and Chastain. For detailed information regarding the outside business activities of all
our IARs, including the compensation received and related conflicts of interest, please refer to their
respective Form ADV Part 2B.
As noted above in response to Item 4, certain investment vehicles affiliated with CD&R collectively
are indirect majority owners of Focus LLC, and certain investment vehicles affiliated with Stone Point are
indirect owners of Focus LLC. Because CFO4Life is an indirect, wholly- owned subsidiary of Focus LLC,
CD&R and Stone Point investment vehicles are indirect owners of CFO4Life.
Focus Risk Solutions
We help our clients obtain certain insurance solutions by introducing clients to our affiliate,
Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus
Financial Partners, LLC (“Focus”). FRS assists our clients with regulated insurance sales activity
by advising our clients on insurance matters and placing insurance products for them and/or
referring our clients to certain third-party insurance brokers (the “Brokers”), with whom FRS has
agreements, which either separately or together with FRS place insurance products for them.
Neither we nor FRS receives any compensation from the Brokers or any other third parties
for providing insurance solutions to our clients. For services provided by FRS to clients of other
Focus firms, FRS receives a percentage of the upfront commission or a percentage of the ongoing
premiums for policies successfully placed with insurance carriers on behalf of referred clients.
Additionally, in exchange for allowing certain of the Brokers to offer their services to clients of
other Focus firms, FRS receives periodic fees (the “Platform Fees”) from such Brokers. The
Platform Fees are expected to change over time. Such Platform Fees are revenue for FRS and,
ultimately, for our common parent company, Focus, but we do not share in such revenue and no
portion of the Platform Fees is attributable to our clients’ use of the Brokers’ services. Such
compensation to FRS, including the Platform Fees, is also revenue for our common parent
company, Focus. However, this compensation to FRS does not come from insurance so lutions
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provided to any of our clients. The volume generated by our clients’ transactions does benefit FRS
and Focus in attracting, retaining, and negotiating with the Brokers and insurance carriers. We
mitigate this conflict by: (1) fully and fairly disclosing the material facts concerning the above
arrangements to our clients, including in this Brochure; (2) offering FRS solutions to clients on a
strictly nondiscretionary and fully disclosed basis, and not as part of any discretionary investment
services; and (3) not sharing in any portion of the Platform Fees. Additionally, we note that clients
who use FRS’s services will receive product-specific disclosure from the Brokers and insurance
carriers and other unaffiliated third-party intermediaries that provide services to our clients.
The insurance premium is ultimately dictated by the insurance carrier, although in some
circumstances the Brokers or FRS may have the ability to influence an insurance carrier to lower
the premium of the policy. The final rate may be higher or lower than the prevailing market rate.
We can offer no assurances that the rates offered to you by the insurance carrier are the lowest
possible rates available in the marketplace.
Credit and Cash Management Solutions
We offer clients the option of obtaining certain financial solutions from unaffiliated third-
party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with
UPTIQ, Inc. and its affiliates, “UPTIQ”). and Flourish Financial LLC (“Flourish”). These third-
party financial institutions are banks and non-banks that offer credit and cash management solutions
to our clients, as well as certain other unaffiliated third parties that provide administrative and
settlement services to facilitate UPTIQ’s cash management solutions. UPTIQ acts as an
intermediary to facilitate our clients’ access to these credit and cash management solutions.
Flourish acts as an intermediary to facilitate our clients’ access to cash management solutions.
We are a wholly owned subsidiary of Focus Financial Partners, LLC (“Focus”). Focus is
a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by
such third-party financial institutions for serving our clients. Although the revenue paid to UPTIQ
benefits UPTIQ, Inc.’s investors, including Focus, no Focus affiliate will receive any compensation
from UPTIQ that is attributable to our clients’ transactions. Additionally, no Focus affiliate will
receive any compensation from Flourish that is attributable to our clients’ transactions.
For services provided by UPTIQ and Flourish to clients of other Focus firms and when
legally permissible, UPTIQ and Flourish each shares a portion of this earned revenue with our
affiliate, Focus Solutions Holdings, LLC (“FSH”). Such compensation to FSH is also revenue for
FSH’s and our common parent company, Focus. This compensation to FSH does not come from
credit or cash management solutions provided to any of our clients. However, the volume generated
by our clients’ transactions allows Focus to negotiate better terms with UPTIQ, and Flourish, which
benefits Focus. We mitigate this conflict by: (1) fully and fairly disclosing the material facts
concerning the above arrangements to our clients, including in this Brochure; and (2) offering
UPTIQ’s and Flourish’s solutions to clients on a strictly nondiscretionary and fully disclosed basis,
and not as part of any discretionary investment services. Additionally, we note that clients who use
UPTIQ’s and Flourish’s services will receive product-specific disclosures from the third-party
financial institutions and other unaffiliated third-party intermediaries that provide services to our
clients.
We have an additional conflict of interest when we recommend credit solutions to our
clients because our interest in continuing to receive investment advisory fees from client accounts
gives us a financial incentive to recommend that clients borrow money rather than liquidate some
or all of the assets we manage.
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Credit Solutions
Clients retain the right to pledge assets in accounts generally, subject to any restrictions
imposed by clients’ custodians. While credit solution programs that we offer facilitate secured
loans through third-party financial institutions, clients are free instead to work directly with
institutions outside such programs. Because of the limited number of participating third -party
financial institutions, clients may be limited in their ability to obtain as favorable loan terms as if
the client were to work directly with other banks to negotiate loan terms or obtain other financial
arrangements.
Clients should also understand that pledging assets in an account to secure a loan involves
additional risk and restrictions. A third-party financial institution has the authority to liquidate all
or part of the pledged securities at any time, without prior notice to clients and without their consent,
to maintain required collateral levels. The third-party financial institution also has the right to call
client loans and require repayment within a short period of time; if the client cannot repay the loan
within the specified time period, the third-party financial institution will have the right to force the
sale of pledged assets to repay those loans. Selling assets to maintain collateral levels or calling
loans may result in asset sales and realized losses in a declining market, leading to the permanent
loss of capital. These sales also may have adverse tax consequences. Interest payments and any
other loan-related fees are borne by clients and are in addition to the advisory fees that clients pay
us for managing assets, including assets that are pledged as collateral. The returns on pledged
assets may be less than the account fees and interest paid by the account. Clients should consider
carefully and skeptically any recommendation to pursue a more aggressive investment strategy in
order to support the cost of borrowing, particularly the risks and costs of any such strategy. More
generally, before borrowing funds, a client should carefully review the loan agreement, loan
application, and other forms and determine that the loan is consistent with the client’s long-term
financial goals and presents risks consistent with the client’s financial circumstances and risk
tolerance.
We use UPTIQ to facilitate credit solutions for our clients.
Cash Management Solutions
For cash management programs, certain third-party intermediaries provide administrative
and settlement services to our clients. Engaging the third-party financial institutions and other
intermediaries to provide cash management solutions does not alter the manner in which we treat
cash for billing purposes. Clients should understand that in rare circumstances, depending on
interest rates and other economic and market factors, the yields on cash management solutions
could be lower than the aggregate fees and expenses charged by the third-party financial
institutions, the intermediaries referenced above, and us. Consequently, in these rare
circumstances, a client could experience a negative overall investment return with respect to those
cash investments. Nonetheless, it might still be reasonable for a client to participate in a cash
management program if the client prefers to hold cash at the third-party financial institutions rather
than at other financial institutions (e.g., to take advantage of FDIC insurance).
We use UPTIQ and Flourish to facilitate cash management solutions for our clients.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Code of Ethics Summary
A.
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CFO4Life has adopted a Code of Ethics (“Code”) which establishes standards of conduct for our
supervised persons and includes general requirements that such supervised persons comply with their
fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among
other things, personal trading, insider trading, conflicts of interest and confidentiality of client information.
It contains written policies reasonably designed to prevent the unlawful use of material non-public
information by the Firm or any of our associated persons. The Code also requires that certain of CFO4Life
personnel (called “Access Persons”) report their personal securities holdings and transactions and obtain
pre- approval of certain investments such as initial public offerings and limited offerings.
The Code also requires supervised persons to report any violations of the Code promptly to
CFO4Life’s Chief Compliance Officer (“CCO”). Each supervised person receives a copy of the Code and
any amendments to it and must acknowledge in writing having received the materials. Annually, each
supervised person must certify that he or she complied with the Code during that year. CFO4Life will
provide a copy of its Code of Ethics to any client or prospective client upon request by contacting us at (214)
637-9500.
Participation or Interest in Client Transactions
B.
It is CFO4Life’s general policy not to enter into any principal transactions or agency cross
transactions on behalf of client accounts. Notwithstanding the foregoing, in limited instances principals of
CFO4Life may purchase ownership interests of business entities in which clients of CFO4Life also
purchase ownership interests and which constitute a principal transaction. Any purchase by a client of such
interest in such a situation is done solely at the discretion of the client and no personnel of CFO4Life
recommend the purchase of such interest to the client. In addition, in such instances as required by applicable
provisions of the Investment Advisers Act of 1940 such clients are provided disclosure regarding the
purchase and status of CFO4Life and any participating personnel of CFO4Life. Principal transactions occur
where an adviser, acting as principal for its own account, buys securities from or sells securities to any
advisory client. Agency cross transactions occur where a person acts as an investment adviser in relation to
a transaction in which the adviser, or an affiliate of the adviser, acts as broker for both the advisory client
and for another person on the other side of the transaction.
CFO4Life or individuals associated with CFO4Life may buy or sell for their personal account(s)
securities or investment products identical to those recommended to or already owned by clients.
Alternatively, CFO4Life may cause clients to buy a security in which CFO4Life or such individuals have an
ownership position. Such recommendations will only be made to the extent that they are reasonably believed
to be in the best interests of the client. Nevertheless, such practices present potential conflicts of interest.
To mitigate these conflicts, the Code outlines the procedures regarding personal trading that must be
followed (see details below). Additionally, as part of CFO4Life’s fiduciary duty to clients, the Firm and its
associated persons will endeavor at all times to put the interests of the clients first and at all times are
required to adhere to the Code.
Personal Trading
C.
The Firm and its Access Persons may invest personally in securities of the same classes as are
purchased for clients and may own securities of the issuers whose securities are subsequently purchased for
clients. CFO4Life understands that this could create a conflict of interest, where the Access Person’s interest
may be at odds with the interest of our clients. To help mitigate these conflicts of interest, the Code sets
forth certain standards of business and professional conduct regarding the personal trading activities of
Access Persons. The following summarizes our procedures for the purchase and/or sales of securities held
within personal accounts.
•
CFO4Life Group, LLC | ADV Part 2A Brochure
CFO4Life requires quarterly reporting of all personal securities transactions with the
exception of certain exempt transactions and securities (such as government securities, open end mutual
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funds and money market funds). Access Persons, or those persons with a beneficial interest such as
immediate family members, may not buy or sell securities for their personal portfolio(s) where their
decision is derived in whole, or in part, by material nonpublic information.
Security holdings and financial circumstances of clients must be kept confidential.
•
•
CFO4Life and its Access Persons may not participate in private placements, initial public
offerings (IPOs) or certain securities subject to restriction by CFO4Life without pre-clearance from the
CCO.
Records will be maintained of reportable securities bought or sold by Access Persons and
•
will be reviewed periodically by designated Firm personnel.
Any individual not in observance of the above may be subject to termination.
•
Item 12 – Brokerage Practices
For discretionary investment management accounts, CFO4Life generally recommends that its
investment management clients utilize the custody and brokerage services of certain unaffiliated
broker/dealer custodians. When CFO4Life places orders for the execution of portfolio transactions for
discretionary client accounts, transactions are allocated to broker- dealers for execution in various markets
at prices and commission rates that CFO4Life believes, based upon good faith judgment, will be in the best
interest of the client. The following discussion summarizes the material aspects of CFO4Life’s practices for
the selection of broker- dealers to execute client transactions.
Selection Criteria
CFO4Life participates in the Charles Schwab & Co., Inc. (“Schwab”), an unaffiliated SEC-
registered broker-dealer, custodial platform for clients. Furthermore, CFO4Life has an arrangement with
National Financial Services, LLC and Fidelity Brokerage Services LLC (together with all affiliates
“Fidelity”), also an unaffiliated SEC-registered broker-dealer. CFO4Life recommends that its investment
management clients custody their assets with Schwab and/or Fidelity.
Schwab provides CFO4Life with access to its institutional trading and custody services, which are
typically not available to Schwab retail investors. These services generally are available to independent
investment advisors on an unsolicited basis, at no charge to advisors. Schwab’s services include brokerage
services that are related to the execution of securities transactions, custody, research, including that in the
form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise
generally available only to institutional investors or would require a significantly higher minimum initial
investment.
The services provided by Fidelity to CFO4Life include, among others, brokerage, custodial,
administrative support, record keeping and related services. In addition, Fidelity makes available to
CFO4Life, at no additional charge to CFO4Life, certain research and brokerage services, including research
services obtained by Fidelity directly from independent research companies, as selected by CFO4Life
(within specified parameters). Fidelity charges brokerage commissions and transaction fees for effecting
certain securities transactions (i.e., transactions fees are charged for certain no-load mutual funds,
commissions are charged for individual equity and debt securities transactions). Fidelity enables CFO4Life
to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal
transaction charges. Fidelity’s commission rates are generally considered discounted from customary retail
commission rates. However, the commissions and transaction fees charged by Fidelity may be higher or
lower than those charged by other custodians and broker-dealers. In addition, see Item 14 for information
regarding certain additional benefits provided by Fidelity to CFO4Life.
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Factors considered by us in recommending Schwab and Fidelity as custodian for client accounts
are based on, but not limited to, the reasonableness of transaction fees charged by Schwab and Fidelity,
product availability, quality of executions, research and other services available to both the client and us.
While there is no direct link between the investment advice given to clients and our
recommendation to use the custodial services of Schwab and Fidelity, certain benefits are received by
CFO4Life due to these arrangements that typically are not available to Schwab and Fidelity retail investors.
Please refer to Item 14A below for additional descriptions of the services and benefits received by us from
Schwab and Fidelity.
There may be times, however, when we evaluate and use an alternative broker-dealer for certain
individual transactions, if in our discretion we believe that best execution for such individual transactions
could be achieved outside of the client’s broker custodian.
Best Execution
A.
It is the policy and practice of CFO4Life to strive for the best price and execution that are
competitive in relation to the value of the transaction (“best execution”). In order to achieve best execution,
CFO4Life will use its best judgment to choose the broker-dealer most capable of providing the brokerage
services necessary to obtain the best overall qualitative execution. Although CFO4Life will strive to achieve
the best execution possible for client securities transactions, this does not require it to solicit competitive
bids and CFO4Life does not have an obligation to seek the lowest available commission cost. In seeking
best execution, the determinative factor is not the lowest possible cost, but whether the transaction
represents the overall best qualitative execution, taking into consideration the full range of a broker-dealer’s
services, including among other things, the value of research provided, execution capability, commission
rates, and responsiveness. Consistent with the foregoing, while CFO4Life will seek competitive rates, it
will not necessarily obtain the lowest possible commission rates for client transactions.
To verify that brokerage/custodian firms recommended by CFO4Life are conducting overall
acceptable qualitative execution, CFO4Life will periodically (and no less often than annually) evaluate the
trading process and broker-dealer(s) utilized. Clients have no obligation to open accounts with any custodial
broker-dealers that CFO4Life recommends.
Trade Aggregation and Allocation
B.
Transactions for each client will be effected independently, unless CFO4Life decides to purchase
or sell the same securities for several clients at approximately the same time. CFO4Life performs investment
management services for various clients, some of which may have similar investment objectives. CFO4Life
may aggregate sale and purchase orders with other client accounts and proprietary (employee) accounts that
have similar orders being made at the same time, if in our judgment such aggregation is reasonably likely
to result in an overall economic benefit to the affected accounts. Such benefits may include better
transaction prices and lower trade execution costs. CFO4Life may (but is not obligated to) combine or
“batch” such orders to obtain best execution, to negotiate more favorable commission rates, or to allocate
equitably among CFO4Life clients differences in prices and commissions or other transaction costs that
might have been obtained had such orders been placed independently. If all aggregate orders do not fill at the
same price, transactions will generally be averaged as to price and allocated among participating accounts
pro rata to the purchase and sale orders placed for each participating account on any given day. If such
orders cannot be fully executed under prevailing market conditions, CFO4Life may allocate the securities
traded among participating accounts and each similar order in a manner which it considers equitable, taking
into consideration, among other things, the size of the orders placed, the relative cash positions of each
account, the investment objectives of the accounts, and liquidity of the security.
Item 13 – Review of Accounts
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Periodic Reviews
A.
Financial Planning Account Reviews
Upon completion of the initial financial plan, ongoing annual review services are established.
Generally, we meet with our clients on an annual basis; however, more frequent reviews are not uncommon.
The nature of the annual review is to evaluate the client’s progress from the previous year based on their
goals and objectives. CFO4Life will collaborate with the client to update their financial information (i.e.
insurance, investments, assets, income and expenses) and craft their yearly financial planning reports.
Financial planning reports are written and may consist of a net worth statement, cash flow statement,
estimated tax projections, education analysis, retirement analysis, insurance needs analysis, estate tax
calculation, and an investment analysis. Reviews are conducted by an advisor of CFO4Life who is
appropriately licensed to provide financial planning services.
Investment Management Account Reviews
While investment management accounts are monitored on an ongoing basis, CFO4Life’s IARs
undertake reviews of client accounts not less than annually. Accounts are reviewed for consistency with the
investment strategy and other parameters set forth for the account and to determine if any adjustments need
to be made.
Other Reviews and Triggering Factors
B.
In addition to the periodic reviews described above, reviews may be triggered by changes in an
account holder’s personal, tax or financial status. Other events that may trigger a review of an account are
material changes in market conditions as well as macroeconomic and company- specific events. Clients are
encouraged to notify CFO4Life of any changes in his/her personal financial situation that might affect
his/her investment needs, objectives, or time horizon.
Regular Reports
C.
Written brokerage statements are generated no less than quarterly and are sent directly from the
account custodian. These reports list the account positions, activity in the account over the covered period,
and other related information. Clients are also sent confirmations following each brokerage account
transaction unless confirmations have been waived.
CFO4Life provides account statements to investment management clients on a quarterly basis.
These statements include holdings, transactions and the overall performance of a client’s
account(s). CFO4Life also provides account performance reports during client meetings.
Clients are urged to carefully review all custodial account statements and compare them to the
statements and reports provided by CFO4Life. Our statements may vary from custodial statements based
on accounting procedures, reporting dates, or valuation meth odologies of certain securities.
Item 14 – Client Referrals and Other Compensation
Economic Benefits Received
A.
As noted in Item 12, CFO4Life participates in the Schwab custodial platform for clients. Schwab
also makes available to CFO4Life other products and services that benefit CFO4Life but may not benefit
its clients’ accounts. These benefits include national, regional or CFO4Life specific educational events
organized and/or sponsored by Schwab. Other potential benefits include occasional business entertainment
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of personnel of CFO4Life by Schwab personnel, including meals, invitations to sporting events, including
golf tournaments, and other forms of entertainment, some of which accompany educational opportunities.
Other of these products and services assist CFO4Life in managing and administering clients’ accounts. These
include software and other technology (and related technological training) that provide access to client
account data (such as trade confirmations and account statements), facilitate trade execution (and allocation
of aggregated trade orders for multiple client accounts), provide research, pricing information and other
market data, facilitate payment of CFO4Life’s fees from its clients’ accounts, and assist with back-office
training and support functions, recordkeeping and client reporting. Many of these services may be used to
service all or some substantial number of CFO4Life’s accounts, including accounts not maintained at
Schwab. Schwab also makes available to CFO4Life other services intended to help CFO4Life manage and
further develop its business enterprise. These services include professional compliance, legal and business
consulting, publications and conferences on practice management, information technology, business
succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and
marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services
rendered to CFO4Life by independent third parties. Schwab may discount or waive fees it would otherwise
charge for some of these services or pay all or a part of the fees of a third-party providing these services to
CFO4Life.
Also, as noted in Item 12, CFO4Life recommends that clients utilize the custodial services of
Fidelity. Fidelity makes available to CFO4Life other products and services without cost or at a discount
that may benefit CFO4Life but may not benefit its clients’ accounts. These additional benefits and services
include pricing information and market data, software and other technology that provide access to client
account data, compliance and/or practice management-related publications, discounted or gratis consulting
services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social
events, marketing support, computer hardware and/or software and/or other products used by CFO4Life
while it is performing its investment advisory business operations.
The benefits received by CFO4Life through its participation in the Schwab custodial platform and
the Fidelity custodial platform do not depend on the amount of brokerage transactions directed to Schwab or
Fidelity. In addition, there is no corresponding commitment made by CFO4Life to Schwab and Fidelity to
invest any specific amount or percentage of client assets in any specific mutual funds, securities or other
investment products as a result of participation in the program. While as a fiduciary, we endeavor to act in
our clients’ best interests, our recommendation that clients maintain their assets in accounts at Schwab and
Fidelity will be based in part on the benefit to CFO4Life of the availability of some of the foregoing products
and services and not solely on the nature, cost or quality of custody and brokerage services provided by
Schwab and Fidelity. The receipt of these benefits creates a potential conflict of interest and may indirectly
influence CFO4Life’s choice of Schwab and Fidelity for custody and brokerage services.
Compensation for Client Referrals
B.
While no arrangements were in place as of the date of this Brochure, CFO4Life seeks to enter into
arrangements with third party solicitors whereby CFO4Life will compensate them for referring clients to
CFO4Life. Referral arrangements inherently give rise to potential conflicts of interest, particularly when
the person recommending the adviser receives an economic benefit for doing so. The Advisers Act addresses
this conflict of interest by requiring disclosures related to the referral, including a description of the material
terms of the compensation arrangement with the solicitor.
CFO4Life Group, LLC | ADV Part 2A Brochure
At such time that an arrangement is in place, it is anticipated that CFO4Life will pay third -party
solicitors a percentage of the advisory fees CFO4Life receives from referred clients. CFO4Life will require
third party solicitors who introduce potential clients to CFO4Life to provide the potential client, at the time
of the solicitation, with a copy of this Brochure and a copy of a written disclosure statement which indicates
whether the solicitor is a client or non-client; explains that the solicitor will be compensated for the referral
; includes the material conflicts of interest arising from the relationship and/or compensation arrangement;
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and contains the terms and conditions of the solicitation arrangement, including the percentage of the advisory
fees or other compensation the solicitor is to receive.
Sponsorships and Other Benefits Received
C.
CFO4Life holds various client events during each year, as well as organizes and executes a golf
outing the proceeds of which benefit charitable purposes. In staging these events, CFO4Life, or its affiliates,
solicit and receive various sponsorships and other donations from mutual fund advisers, insurance
underwriters and other service providers (the “Service Providers”). The Service Providers have business
and service relationships with CFO4Life and/or its affiliates. The contributions range in amounts from $500
to $20,000. Contributors for the 2025 events were as follows: AMG/Pantheon; Cais Group; Cliffwater
Research; Eaton Vance; Fidelity; First Eagle; Hartford Funds; MDS Energy; New York Life Insurance;
Partners Group; Performance Trust Asset Management; Prudential; Reszi; RPM Lakeview; Transamerica;
and Vanguard. The receipt of these sponsorships creates a potential conflict of interest and may indirectly
influence investment and other related choices made by CFO4Life. Through the execution of its policies and
procedures, including such things as execution of its fiduciary duty to clients, account reviews and other
policies and processes, CFO4Life works so that investment or other client related decisions are in no way
affected, directly or indirectly, by any such received sponsorship dollars.
Other Compensation
D.
CFO4Life’s parent company is Focus Financial Partners, LLC (“Focus”). From time to time, Focus
holds partnership meetings and other industry and best-practices conferences, which typically include
CFO4Life, other Focus firms and external attendees. These meetings are first and foremost intended to
provide training or education to personnel of Focus firms, including CFO4Life. However, the meetings do
provide sponsorship opportunities for asset managers, asset custodians, vendors and other third party service
providers. Sponsorship fees allow these companies to advertise their products and services to Focus firms,
including CFO4Life. Although the participation of Focus firm personnel in these meetings is not
preconditioned on the achievement of a sales target for any conference sponsor, this practice could
nonetheless be deemed a conflict as the marketing and education activities conducted, and the access
granted, at such meetings and conferences could cause CFO4Life to focus on those conference sponsors in
the course of its duties. Focus attempts to mitigate any such conflict by allocating the sponsorship fees only
to defraying the cost of the meeting or future meetings and not as revenue for itself or any affiliate, including
CFO4Life. Conference sponsorship fees are not dependent on assets placed with any specific provider or
revenue generated by such asset placement.
The following entities have provided conference sponsorship to Focus from January 1, 202 5 to February
1, 2026:
• Addepar Inc.
• AQR Capital Management, LLC
• Bigelow LLC
• BlackRock Inc.
• BOWS Administrator (Brookfield Oaktree Wealth Solutions)
• Capital Integration Systems LLC (CAIS)
• Charles Schwab & Co., Inc.
• Cliffwater LLC
• Dimensional Fund Advisors LP
• Dinsmore Compliance Services, LLC (DCS)
• Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates)
• Edgewood Partners Insurance Center (EPIC) (includes Vanbridge)
• Fidelity Brokerage Services LLC (includes FIAM and Wealthscape)
• Flourish Financial LLC
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• Franklin Templeton Distributors, LLC
(includes O’Shaughnessy Asset
Management, L.L.C. (OSAM) and CANVAS)
Jackson National Life Distributors LLC
•
• K&L Gates LLP
• Lord, Abbett & Co. LLC
• Nuveen Securities, LLC
• Orion Advisor Solutions, Inc.
• Pacific Investment Management Company LLC (PIMCO)
• Pinnacle Insurance & Financial Services, LLC
• Practifi, Inc.
• Quantinno Capital Management LP (includes TaxEdge and DEALS (Direct Equity
Active Long Short))
• RedblackSoftware, LLC (includes Intelliflo)
• SmartAsset Advisors LLC
• Stone Ridge Asset Management LLC
• The Vanguard Marketing Corporation, Inc.
• TriState Capital Bank
• VRGL Inc.
You can access updates to the list of conference sponsors on Focus’ website through the following link:
https://www.focusfinancialpartners.com/conference-sponsors.
Certain CFO4Life IARs have outside business activities that provide additional compensation.
Please refer to Item 10 above for detailed information regarding the business activities, the compensation
received, the related conflicts and how CFO4Life mitigates such conflicts.
Item 15 – Custody
Pursuant to Rule 206(4)-2 of the Advisers Act, CFO4Life is deemed to have custody of certain
client funds because the Firm has the authority and ability to debit its fees directly from clients’ accounts.
To mitigate any potential conflicts of interests, all CFO4Life client account assets will be maintained with
an independent qualified custodian. CFO4Life currently recommends that its investment management
clients use Schwab and Fidelity for custodial services. In addition, pursuant to that Rule, CFO4Life is
deemed to have custody of certain client funds in those situations where a client provides CFO4Life with
authority pursuant to a third party standing letter of authorization (“SLOA”). Any SLOA is implemented
pursuant to the instruction of the client, the procedures of the independent qualified custodian and
applicable regulatory requirements.
CFO4Life will only implement its investment management recommendations after the client has
arranged for and furnished CFO4Life with all information and authorization regarding its accounts held at
Schwab, Fidelity or other acceptable qualified custodian.
Clients will receive statements on at least a quarterly basis (generally monthly) directly from
Schwab, Fidelity or other acceptable qualified custodian. Clients are urged to carefully review all custodial
account statements and compare them to the statements provided by CFO4Life. Our statements may vary
from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of
certain securities.
Item 16 – Investment Discretion
CFO4Life Group, LLC | ADV Part 2A Brochure
Clients can determine to engage CFO4Life to provide investment advisory services on a
discretionary basis. Prior to CFO4Life assuming discretionary authority over a client’s account, the client
is required to execute a CFO4Life approved investment advisory agreement granting CFO4Life full
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authority to buy, sell, or otherwise effect investment transactions involving the assets in the client’s
name found in the discretionary account.
While we generally allow clients to impose, in writing, reasonable restrictions on the types of
securities and/or industries they do not want to be included in their portfolio, each client assumes
responsibility for informing CFO4Life in writing of any changes to these restrictions or to their overall
investment objectives.
Item 17 – Voting Client Securities
CFO4Life’s policy and practice is to not vote proxies on behalf of its clients and therefore, shall
have no obligation or authority to take any action or render any advice with respect to the voting of proxies
solicited by or with respect to issuers of securities held in a client’s account. Any such proxies will
be received by the client directly from their custodian. Should a client have questions regarding a particular
proxy solicitation, they may contact their advisor at 214-637-9500.
Consequently, the client retains the responsibility for receiving and voting all proxies for securities
held within the client's account. CFO4Life shall not be deemed to have proxy voting authority solely as a
result of providing advice or information about a particular proxy vote to a client.
CFO4Life typically does not advise or act for clients with respect to any legal matters,
includingbankruptcies and class actions, for the securities held in clients’ accounts.
Item 18 – Financial Information
CFO4Life does not have any financial impairment that will preclude it from meeting contractual
commitments to clients. A balance sheet is not required to be provided as CFO4Life does not both (i) serve as
custodian for client funds or securities and (ii) require prepayment of fees six months or more in advance.
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