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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, 2025
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
Following is a summary of material changes to CFO4Life Group, LLC’s (“CFO4Life”) Form
ADV Part 2A (the “Brochure”) since the annual update filing of March 27, 2024.
We offer clients the option of obtaining cash management solutions from unaffiliated
third-party financial institutions through Flourish Financial LLC (“Flourish”). Further
information on this conflict of interest is available in Items 4, 5, and 10 of this Brochure.
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.We help our clients obtain certain
insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”). FRS
does not receive any compensation from serving our clients. Further information on this service
is available in Items 4, 5 and 10 of this 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”). Further
information on this conflict of interest is available in Items 4, 5, and 10 of this Brochure.
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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:
1.
Comprehensive Financial Planning and Investment Management Services to
affluent individuals and business executives;
2.
Advisory Services to Retirement Plans;
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3.
Corporate Services – Investment Education and Financial Wellness: and
4.
Cash Management Solutions.
A description of each service is provided below.
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
When appropriate, CFO4Life will allocate certain client assets to third-party separate
account managers. For example, Aperio Group may be used as a direct indexing solution or the
Fidelity Managed Account Xchange may be used for actively managed separate accounts. Under
these circumstances, clients will be assessed an all-in-one “wrap fee” for custody, brokerage,
investment management and performance reporting services, 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.
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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 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 offer clients the option of obtaining cash management solutions from unaffiliated
third-party financial institutions through Flourish Financial LLC (“Flourish”). Please see Items 5
and 10 for a fuller discussion of these services and other important information.
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.
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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 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, 2024 the following represents the amount of client assets under
management by CFO4Life on a discretionary and non-discretionary basis.
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Type of Account
Assets Under Management (AUM)
Discretionary
$1,704,809,735
Non-Discretionary
$30,699,455
Total
$1,735,509,190
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 $223,187,560 in assets as of December 31,
2o24. 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, 2023 are
$1,958,696,750.
Item 5 – Fees and Compensation
A.
Financial Planning and Advisory Fees
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. 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.
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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
Advisory clients that participate in 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 25 bps 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, inclusive of the CFO4Life advisory fee. 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
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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
We offer clients the option of obtaining cash management solutions from unaffiliated
third-party financial institutions through Flourish Financial LLC (“Flourish”). No Focus affiliate
will receive any compensation from Flourish that is attributable to our clients’ transactions.
Further information on this conflict of interest is available in Item 10 of this Brochure.UPTIQ
Treasury and Credit 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”). . 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 or Flourish that is
attributable to our clients’ transactions. Further information on this conflict of interest is available
in Item 10 of this Brochure.
B.
Additional Information Regarding Fees
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,
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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).
C.
Important Considerations
Compensation for Sales of Securities or Other Investment Products
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.
Certain IARs of CFO4Life also are licensed insurance agents that are licensed with LBMC
II, LLC, an insurance agency owned by Levi McMellian and Brian Chastain and 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-
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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 together 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 $500,000 and a net worth of
$1,500,000 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
A.
Methods of Analysis and Investment Strategies
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, FactSet, 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:
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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.
B.
Risk of Loss
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 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.
CFO4Life Group, LLC | ADV Part 2A Brochure
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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 investment objectives will be achieved.
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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.
CFO4Life Group, LLC | ADV Part 2A Brochure
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
15
generally be appropriate, particularly with funds drawn from retirement savings, student loans,
mortgages, emergency funds, or funds set aside for other purposes. Investors must 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.
regulation, Cryptocurrencies
largely
lack
Government
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, 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;
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
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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.
Certain IARs of CFO4Life also are licensed insurance agents with LMBC II, LLC, an
insurance agency, and 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
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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, Grayhawk
Insurance Group, 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, CFAs, 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 educational services offered to 401K Plan
participants. The IARs of CFO4Life do not receive any type of compensation for such referrals or
CFO4Life Group, LLC | ADV Part 2A Brochure
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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.
Flourish Cash Management Solutions
We offer clients the option of obtaining cash management solutions from unaffiliated
third-party financial institutions through Flourish Financial LLC (“Flourish”). Flourish has
established deposit accounts at FDIC-member banks to offer a deposit account sweep
arrangement to wealth management firms’ clients, including our clients. Flourish acts as an
intermediary to facilitate our clients’ access to these cash management solutions.
For services provided by Flourish to clients of other Focus firms and when legally
permissible, Flourish 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 cash management
solutions provided to any of our clients. However, the volume generated by our clients’
transactions allows Focus to negotiate better terms with 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 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 Flourish’s services will receive
product-specific disclosure from the third-party financial institutions and other unaffiliated third-
party intermediaries that provide services to our clients.
CFO4Life Group, LLC | ADV Part 2A Brochure
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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 Flourish to facilitate cash management solutions for our clients.
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 solutions 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.
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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.
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
CFO4Life Group, LLC | ADV Part 2A Brochure
21
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
A.
Code of Ethics Summary
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
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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.
B.
Participation or Interest in Client Transactions
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.
C.
Personal Trading
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 requires quarterly reporting of all personal securities transactions
with the exception of certain exempt transactions and securities (such as government securities,
open end mutual 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.
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•
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.
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
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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.
A.
Best Execution
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.
B.
Trade Aggregation and Allocation
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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A.
Periodic Reviews
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.
B.
Other Reviews and Triggering Factors
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.
C.
Regular Reports
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 methodologies of
certain securities.
Item 14 – Client Referrals and Other Compensation
A.
Economic Benefits Received
As noted in Item 12, CFO4Life participates in the Schwab custodial platform for clients.
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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 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.
B.
Compensation for Client Referrals
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
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solicitor.
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
disclosure statement which explains that the solicitor will be compensated for the referral 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.
C.
Sponsorships and Other Benefits Received
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 2023 events were as
follows: AIG; AMG/Pantheon; BlackRock; Cliffwater Research; Deutsche Bank; Fidelity; First
Eagle; First Trust; Goldman Sachs; Hub; InWest; JP Morgan; MDS Securities; Mutual of Omaha;
Nationwide; Natixis; New York Life Insurance; Partners Group; Prudential; TD Ameritrade;
Transamerica; and Tristate Capital Bank. 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.
D.
Other Compensation
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, 2024 to
February 1, 2025:
• Advent Software, Inc. (includes SS&C)
• BlackRock, Inc.
• Blackstone Administrative Services Partnership L.P.
• Capital Integration Systems LLC (CAIS)
• Charles Schwab & Co., Inc.
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• Confluence Technologies Inc.
• Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates)
• Fidelity Brokerage Services LLC and Fidelity Distributors Company LLC
(includes Fidelity Institutional Asset Management and FIAM)
• Flourish Financial LLC
• Franklin Distributors, LLC (includes O’Shaughnessy Asset Management,
L.L.C. (OSAM) and CANVAS)
• K&L Gates LLP
• Nuveen Securities, LLC
• Orion Advisor Technology, LLC
• Pinegrove Capital Partners LLC (includes Brookfield Oaktree Wealth
Solutions)
• Practifi, Inc.
• Salus GRC, LLC
• Stone Ridge Asset Management LLC
• The Vanguard Group, Inc.
• TriState Capital Bank
• UPTIQ, 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
Clients can determine to engage CFO4Life to provide investment advisory services on a
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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 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.
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,
including
bankruptcies 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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