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963 Highland Avenue
Dunedin, FL 34698
(727) 450-2301
www.c1ag.com
August 5, 2025
This Brochure provides information about the qualifications and business practices of Client 1st Advisory
Group LLC (“Client 1st”). If you have any questions about the contents of this Brochure, please contact us
at 727-450-2301 or by email at: info@ c1ag.com. 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. Additional information about us is also available on the SEC’s website www.advisorinfo.sec.gov.
References to Client 1st as a “registered investment advisor” or any reference to being “registered” does
not imply a certain level of skill or training.
Item 2 — Summary of Material Changes
This section discusses only specific material changes that are made to this Form ADV Part 2A (the
“Brochure”) and provides you with a summary of such changes. Since March 31, 2025, when we
filed our last annual update to our Brochure, we have the following material changes to report:
•
In July 2025, Client 1st Advisory Group moved its Main Office location to 963 Highland
Avenue, Dunedin, FL 34698.
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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 – Investment Advisory Business ......................................................................................... 4
Item 5 – Fees and Compensation. ................................................................................................... 7
Item 6 - Performance-Based Fees and Side-By-Side Management ................................................ 9
Item 7 – Types of Clients ................................................................................................................ 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 9
Item 9 – Disciplinary Information. ............................................................................................... 12
Item 10 – Other Financial Industry Activities and Affiliations .................................................... 12
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading. ............... 13
Item 12 – Brokerage Practices ...................................................................................................... 14
Item 13 – Review of Accounts ..................................................................................................... 15
Item 14 – Client Referrals and Other Compensation. ................................................................. 15
Item 15 – Custody. ...................................................................................................................... 16
Item 16 – Investment Discretion. ................................................................................................ 17
Item 17 – Voting Client Securities ............................................................................................... 17
Item 18 – Financial Information. ................................................................................................. 17
ADV Part 2B: Brochure Supplement .......................................................................................... 18
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Item 4 — Investment Advisory Business
In this brochure, references to “we”, “us”, “our”, “our firm”, “the firm” “the Company” and “Client
1st” refers to Client 1st Advisory Group, LLC. Individuals who serve as our directors, officers, and
representatives are referred to as our “advisors” “investment advisory representatives” or “IARs”.
Our firm’s clients are referred to as “you” “your” or “our clients”.
Client 1st Advisory Group, LLC was formed under the laws of the State of Florida in March 2013
as the successor to Client 1st Advisors, Inc. and Wealth Management Consultants, Inc. The firm is
registered with the United States Securities and Exchange Commission as an investment advisor.
Our Managing Members are Michelle Mabry, Chief Executive Officer, Dave Stieh, Chief
Operations & Chief Compliance Officer, and Morgan Mabry, Chief Investment Officer.
Client 1st offers personalized investment advisory services to individuals, pension and profit-
sharing plans, trusts, estates, charitable organizations and corporations. Our services and fee
arrangements are described in the following pages.
OUR ADVISORY SERVICES
We provide personalized financial planning and portfolio management services. Most of our clients
are individuals and revocable grantor trusts. However, we also work with family limited
partnerships, pension and profit-sharing plans, estates, charitable organizations and small
businesses. We also provide financial consulting services to employer sponsored retirement plans.
We provide advice to our clients through our “Consultative Client Management Program”. This
process involves a series of meetings to (1) determine your financial goals and objectives, (2)
present you with an investment plan, (3) form a mutual commitment to the plan and (4) schedule
progress meetings on a quarterly basis.
We work with other professionals (e.g. lawyers or accountants) who are directly engaged by our
clients to assist on an as-needed basis.
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Investment Management
Client 1st provides customized asset management services by gathering relevant information about
your current financial needs, objectives, existing financial assets, investment experience and risk
tolerance. All aspects of your financial affairs are reviewed. We use this information to create an
investment management strategy (or “Investment Plan”) that forms the basis of the asset allocation
model that we will use to manage your investments. The Investment Plan changes with adjustments
to your goals and objectives and the financial markets that we invest in on your behalf.
A key element of our regular progress meetings in our Consultative Client Management Program is
to revisit this process on a quarterly basis. The Investment Plan can also be revisited on demand when
a material change in your financial situation occurs.
Based on the Investment Plan that we prepare for you, the Client 1st Portfolio Management Team
(“Portfolio Team”) creates a portfolio consisting of investments that meet the goals and objectives
identified in your Investment Plan. We select a combination of investment vehicles that may consist
of ETFs (exchange traded funds), mutual funds, stocks, bonds, alternative investments and
commodities. Our selection of these investments is based on extensive research of the performance
and risk associated with each investment vehicle.
Our Firm minimum account size for investment management is $1,000,000 of assets under
management. Client 1st reserves the right to waive the account minimum.
Client 1st Wrap Fee Program
We sponsor a wrap fee program (the “Client 1st Wrap Fee Program” or “Wrap Program”) and we
are the portfolio manager of our Wrap Fee Program. In a wrap fee program you typically pay the
sponsoring financial services firm a single fee, generally payable on a quarterly basis, to cover all
costs in connection with securities transactions in your account and the investment management
services.
Your IAR will manage your investments in the Wrap Program according to your Investment Plan
on a discretionary basis, deliver ongoing investment advice and monitor your security holdings.
Our Wrap Program allows you the ability to pay an asset-based advisory fee that covers all
transaction costs within the advisory fee.
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For further information please refer to the Client 1st Form ADV Part 2A Appendix I Wrap Fee
Program Brochure
Retirement Plan Consulting
Through its qualified advisors Client 1st offers a fee-for-service consulting program whereby our
advisors may offer one-time or ongoing advisory services to qualified retirement plans. Through
the Retirement Plan Consulting program, our advisors may assist plan sponsors with their fiduciary
duties and provide individualized advice based upon the particular needs of the plan and/or plan
participants regarding investment management matters including:
Investment Policy Statement support
Investment selection and monitoring
•
•
• Overall portfolio composition
• Participant advice programs
Financial Planning and Consulting
We offer financial planning services to you on matters involving securities and non-securities topics.
The areas addressed may include retirement income planning, estate planning, budgeting and cash
flow analysis, business succession planning, education planning and other areas where you may
require assistance. Your IAR may prepare special reports on these matters at your request.
As is the case with our investment management program, our financial plans are based on the
financial information that you disclose to us at the time the plan is presented to you. Client 1st does
not offer any guarantees or promises that your financial goals and objectives will be met. Further,
you must continue to review any plan and update the plan based upon changes in your financial
situation, goals, or objectives or changes in the economy. As your financial situation, goals,
objectives, or needs change, you will need to promptly notify Client 1st and your investment advisory
representative so that we can make adjustments to your plan.
You are under no obligation to act on our financial planning recommendations. Moreover, if the
financial plan that we prepare requires investment management you are under no obligation to
implement the financial plan through Client 1st.
ASSETS UNDER MANAGEMENT
We manage your assets on either a discretionary or non-discretionary basis. As of December 31,
2024, we had total assets under management of $403,969,413 of which $397,894,899 in client
assets were managed on a discretionary basis and $6,074,514 were managed on a non-
discretionary basis.
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Item 5 — Fees and Compensation
INVESTMENT MANAGEMENT FEES
Advisor Fees
Our fee is billed quarterly in advance. The quarterly fee is the annual fee percentage adjusted for
the number of days in the calendar quarter and is based on the market value of the account on the
last business day of the preceding calendar quarter. The market values are also separately provided to
you by the custodian. We urge our clients to compare both statements. If errors are discovered in
the firm’s favor, we credit or refund such amount, with no time limit.
The first billing cycle begins on the account inception date and is based on the account value on the
inception date as determined by your broker-dealer or other qualified custodian. We prorate the fee
for new accounts based on the number of days remaining in the calendar quarter. The quarterly
billing value is equal to the closing market value of the account on the last business day of the
quarter.
Additions of funds or investments exceeding $50,000 deposited to your accounts during a quarter
will be subject to a pro-rated annual management fee. Liquidations and distributions occurring
during the quarter will not receive pro-rated refunds of fees.
Our advisory fee ranges up to 1.50% and is based on the aggregate value of related accounts, the
complexity of the account and the investment strategies employed. We will specify the amount and
the manner in which we charge fees in our written agreement with you.
Upon your authorization, the custodian of your assets will deduct our advisory fee from your
account.
Other Fees and Expenses
In certain circumstances where our clients will benefit from broader diversification or lower overall
expenses we will purchase investments and you will incur nominal transaction fees with executing
broker/dealers. These transaction fees and the fees charged by the custodian for maintaining your
assets are separate and in addition to the advisory fee.
We charge an additional management fee ranging from .50% to 1.50% for direct management of
held away assets such as 401(k) plans.
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Moreover, if our Portfolio Team is investing your assets in funds, you will also incur expenses at
the fund level. “Investment company shares” or “funds” of which the most common types are
mutual funds, index funds, exchange traded funds (“ETFs”) and unit investment trusts (“UITs”)
charge their shareholders various advisory fees and expenses associated with the establishment and
operation of the funds. These fees and expenses generally include a management fee, shareholder
servicing, portfolio transaction costs, other fund expenses, and sometimes a distribution fee. These
separate fees are disclosed in each fund’s current prospectus, which is available from the sponsor
and, upon request, from us.
FINANCIAL PLANNING AND CONSULTING FEES
The Client 1st Financial Planning and Consulting Program provides clients with the option of paying
an annual fee for ongoing services, a flat fee, or an hourly rate not to exceed $350 per hour. The fee
amount a client will pay is negotiable between the Client and his or her advisor and may either be
paid at the time of service, in advance of service, or in arrears. Annual fees may be paid in monthly,
quarterly, semiannual, or annual installments as agreed to between the client and the advisor.
In some circumstances, implementing the recommendations in financial plans may involve
investment or insurance products that result in a commission or other fee being paid to a registered
representative of a broker / dealer. Client 1st IARs are not registered representatives of a
broker/dealer and do not receive commissions or 12(b)-1 fees. However, some of our advisors are
registered insurance agents and may receive commissions for fixed insurance products. In instances
where a client pays a fee for financial planning advice, the client is notified in advance of any such
transactions resulting in a commission being paid to an associated person of Client 1st.
TERMINATION OF AGREEMENTS
You may terminate any Investment Advisory Agreement or Financial Planning Agreement by
notifying Client 1st in writing.
For Investment Management Agreements you may terminate the Agreement for any reason within
five (5) days of the initial contract date and receive a total refund of your fees. After the initial five
days the Agreement may be terminated by either party upon written notice to the other party and
will become effective on the date received by the other party (“termination date”). In the event an
account is terminated in the middle of a quarter, fee’s will be refunded on a prorated basis.
For Financial Plan Consulting Agreements and Retirement Plan Consulting Agreements, you may
terminate the agreement at any time and a refund of unearned fees will be provided to you. The
unearned fee will be calculated by Client 1st and your advisor and is based on the amount of time
the advisor has spent working for you before you terminated the agreement. A full refund will be
made if you terminate your agreement within 5 business days of signing the agreement.
Client 1st may also terminate the above-referenced agreements by written notification if pertinent
information to the planning process has not been provided. In this instance, any unused portion of
advanced fees will be refunded within 15 days.
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Item 6 — Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees (fees based on a share of capital gains or on capital
appreciation of your assets).
Item 7 — Types of Clients
Our investment management and financial planning services are available to individuals, revocable
grantor trusts, irrevocable trusts, pension and profit sharing plans, estates, charitable organizations
and small businesses.
For investment management services our Firm’s minimum account size is $1,000,000 of assets
under management. We may require you to add to the amount in order to maintain the minimum or
request that the account be terminated. These conditions are negotiable in light of your specific
circumstances and relationships with our firm, our principals and representatives. Client 1st reserves
the right to waive the account minimum. There is no minimum asset size for our fee-based financial
planning services.
Item 8 — Methods of Analysis, Investment Strategies and Risk of Loss
Our goal at Client 1st is to help you achieve your stated investment objectives by selecting a mix of
investment products and asset managers that provide the highest returns at an acceptable level of
risk within your stated time frame.
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METHODS OF ANALYSIS
Our Portfolio Team determines the appropriate asset mix and asset allocation through analysis of
potential asset classes for the period of your given time horizon. In the course of determining the
appropriate investment assets and allocations, we also attempt to incorporate your existing
investment assets into the mix.
In performing our analysis we utilize research software created by third parties that incorporate
performance and statistical probability for the existing investment asset classes. We also utilize
other information sources both public and purchased including financial publications, prospectuses
and annual reports.
INVESTMENT STRATEGIES
Your portfolio of investment assets is a customized allocation strategy based on your means, goals,
objectives and risk tolerance and may include but not be limited to various combinations of stocks,
bonds, mutual funds, exchange traded funds (“ETFs”) and to a limited extent “alternative
investments” including Real Estate Investment Trusts (“REIT’s), high yield and structured notes,
limited partnerships, master limited partnerships (“MLP’s) commodities and managed futures.
We use a passive asset allocation process based on the following core strategies that we
periodically rebalance back to their original allocations:
Conservative
An income-oriented strategy that seeks current income with minimal risk to principal with only
modest long-term growth of principal and has a short- to mid-range investment time horizon
Balanced
A balanced-oriented strategy that seeks to reduce potential volatility by including income-
generating investments in the portfolio with moderate growth of principal, short-term price
fluctuations, and has a mid- to long-range investment time horizon
Growth
A growth-oriented strategy that seeks to maximize the long-term potential for growth of principal
with potentially moderate short-term price fluctuations, a long-term investment time horizon and
generating current income is not a primary goal.
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Aggressive Growth
A growth-oriented strategy that seeks to maximize the long-term potential for growth of principal
with potentially large short-term price fluctuations, a long-term investment time horizon and
generating current income is not a primary goal.
We track and monitor the performance of your portfolio on a regular basis to ensure that the
performance is on track to meet the financial objectives that we established for you. You will also
be provided with quarterly reports of your portfolio’s performance (either electronically or by mail).
RISK OF LOSS
We offer advice about a wide variety of investment types, including mutual funds, index funds,
ETFs, etc., each having different types and levels of risk. We discuss these risks with you in
determining the investment objectives that will guide our investment advice for your account. We
explain and answer any questions you have about these kinds of investments, which present special
considerations.
Investing in securities involves risk of loss that you should be prepared to bear. Obtaining higher
rates of return on investments typically entails accepting higher levels of risk. We work with you to
attempt to identify the balance of risks and rewards that is appropriate and comfortable for you.
However, it is still your responsibility to ask questions if you do not fully understand the risks
associated with any investment or investment strategy.
Also, while we strive to render our best judgment on your behalf, many economic and market
variables beyond our control can affect the performance of your investments and we cannot assure
you that your investments will be profitable or assure you that no losses will occur in your
investment portfolio. Past performance is one relatively important consideration with respect to any
investment or investment advisor, but it is not a predictor of future performance.
Please be advised that all investment programs have certain risks that are borne by you, the investor.
Our investment approach constantly keeps the risk of loss in mind. Investors face the following
investment risks:
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing their
market values to decline.
Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and
intangible events and conditions. This type of risk is caused by external factors independent of a
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security’s underlying circumstances. For example, political, economic and social conditions may
trigger market events.
Inflation Risk: When any type of inflation is present a dollar today will not buy as much as a dollar
next year because purchasing power is eroding at the rate of inflation.
Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against
the currency of the investment’s originating. This is also referred to as exchange rate risk.
Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested
at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income
securities.
Business Risk: These risks are associated with a particular industry or a particular company within
an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy
process, before they can generate a profit. They carry a higher risk of profitability than an electric
company, which generates its income from a steady stream of customers who buy electricity no
matter what the economic environment is like.
Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets
are more liquid if many traders are interested in a standardized product. For example, Treasury Bills
are highly liquid, while individual real estate properties are not.
Financial Risk: Excessive borrowing (leverage) to finance a business’ operations increases the risk
of profitability, because the company must meet the terms of its obligations in good times and bad.
During periods of financial stress, the inability to meet loan obligations may result in bankruptcy
and/or a declining market value.
Item 9 — Disciplinary Information
Registered Investment advisors are required to disclose all matters regarding any legal or
disciplinary events involving our firm or any of our representatives. We have no items to report.
Item 10 — Other Financial Industry Activities and Affiliations
Pontera (formerly FeeX) – Participant Account Management
We use a third party platform, Pontera (f..k.a FeeX) to facilitate management of held away assets such as
defined contribution plan participant accounts, with discretion. The platform allows us to avoid being
considered to have custody of Client funds since we do not have direct access to Client log-in credentials to
affect trades. We are not affiliated with the platform in any way and receive no compensation from them for
using their platform. A link is provided to our Client allowing he or she to connect an account(s) to the
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platform. Once Client’s account(s) is connected to the platform, we manage the account on a discretionary
basis. We review the current account allocations. When deemed necessary, we will rebalance the account
considering client investment goals and risk tolerance. Any change in allocations considers current economic
and market trends. Client account(s) are reviewed at least quarterly and allocation changes are made as
deemed necessary.
Insurance Agents
Some of our IARs are registered insurance agents and occasionally may receive commissions on
fixed insurance products. You will be notified in advance of any such transactions resulting in a
commission being paid to an associated person of Client 1st . The additional compensation creates
conflicts of interest that you should consider before engaging our services.
Item 11 — Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
CODE OF ETHICS
We have adopted a Code of Ethics (the “Code”) describing the standards of business conduct we
expect all officers, directors, employees, and advisory representatives to follow. It expresses our
core fundamental values to be honest, fair, and forthright in our dealings with clients and others in
the conduct of our business.
Our Code also guides our practices in giving investment advice to our clients and personal trading of
securities for our employees and their related accounts. The Code also describes certain reporting
requirements with which particular individuals, associated with or employed by us, must comply.
You may request a copy of our Code of Ethics by contacting our Main Office at 727- 450-2301 or
by email at: info@ c1ag.com.
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
Client 1st employees and representatives may benefit from their purchases or sales of investments
that we recommend to you and we may buy or sell securities that are also held by our clients.
However, employees may not trade their own securities ahead of our clients’ trades.
PERSONAL TRADING
Our Chief Investment Officer reviews all employee statements each quarter. The personal trading
reviews ensure that personal trading by our employees does not affect the market and If any
irregularities are noted, the Firm’s Chief Compliance Officer is advised.
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Item 12 — Brokerage Practices
SELECTING BROKERAGE AND CUSTODIAL SERVICES
Client 1st selects brokerage service relationships that include custody of securities, trade execution,
clearance and settlement of transactions. The factors that we consider in selecting our brokerage
and custodial services include:
In-house research capabilities
• Range of securities offered: stocks, bonds, mutual funds, ETFs, alt investments
• Low transaction costs
• Access to client data
• Monthly/ quarterly reports to clients
• Capability of supporting 3rd party money managers
•
• Overlay functions for customizing asset allocations
• Back-office support facilitating management of multiple Client accounts
We have established primary custodial and brokerage service relationships with Charles Schwab.
Schwab in not affiliated with Client 1st.
BEST EXECUTION AND TRADING FEES
In placing orders to purchase and sell securities, our Firm considers a number of factors, not solely
the ability to receive the best price, in selecting appropriate broker-dealers. We consider, among
other factors, financial condition, reputation, level of trading expertise and capability, infrastructure,
alternative trading options resulting from technology developments, market changes and
commission rates charged. We typically rely on the brokerage services of our custodian.
Occasionally, for fixed income security transactions, we employ third party firms to assist us in
seeking best execution. On a periodic basis we review reports on execution quality that are available
from our selected broker/dealers. We do not receive any portion of the trading fees charged by the
broker-dealers.
AGGREGATION OF ORDERS
We will aggregate trades where possible and when advantageous to clients. This aggregation of
trades permits the trading of blocks of securities composed of assets from multiple clients’
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accounts so long as transaction costs are shared equally and on a pro-rated basis between all
accounts included in any such block. Block trading allows us to execute equity trades in a more
timely and equitable manner, and may result in better pricing to clients. Trades for associated
persons of Firm may be included in client block trades.
SOFT DOLLAR ARRANGEMENTS
We do not participate in any “soft dollar” arrangements where client commissions are partially
rebated in the form of research credits or other benefits. Nor does any brokerage firm or custodian
refer clients to our firm either as a matter of course or in consideration for using their brokerage
services.
Item 13 — Review of Accounts
If we provide you with asset management services, we conduct review meetings with you at your
request, at the time of significant new deposits or withdrawals, during substantial changes in market
conditions and at least on an annual basis.
You must contact us when a significant change in your financial condition occurs so that we can
review your portfolio along with your new information to insure the investment strategies continue to
are volatile market conditions
be appropriate. Other conditions that may trigger a review
and changes in the tax laws.
We review your accounts on a quarterly basis. Account reviewers are members of our Investment
Committee. They consider your current security positions, asset allocations and the likelihood that
the performance of each security or investment strategy will contribute or continue to contribute to
your investment objectives. In some cases we prepare reports of portfolio performance when
requested by our clients for periodic reviews.
Item 14 — Client Referrals and Other Compensation
Solicitor Arrangements
Occasionally we enter into solicitor agreements with accounting firms, and other professional
firms or individuals who have referred friends and associates to our Firm. Under these
agreements the solicitor may be compensated for their referral by sharing the annual management
fee earned by Client 1st. If you become our client as a result of the solicitor’s efforts, the solicitor
will provide you with the terms of the solicitor’s arrangement with our Firm you will also receive
a copy of this Brochure. Generally, the Firm’s agreement with the solicitor will provide for an
ongoing payment to the solicitor as a percentage of the advisory fees we collect from you. We do
not charge clients introduced by such solicitors a higher advisory fee as
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a result of our obligation to pay for the solicitation services. Outside solicitor arrangements create
a potential conflict of interest. Solicitors may have an incentive to recommend clients to us based
on the referral fee.
Schwab Advisor Network
Client 1st receives client referrals from Charles Schwab & Co., Inc. (“Schwab”) through our participation in
the Schwab Advisor Network® (“the Service” or SAN Program”). Schwab designed the Service to help
investors find an independent investment advisor. Schwab is a broker-dealer independent of, and unaffiliated
with Client 1st. Schwab does not supervise us and has no responsibility for our management of clients
’portfolios or other advice or services we provide. Client 1st pays Schwab fees to receive client referrals
through the Service. Our participation in the Service raises conflicts of interest, as described below.
Client 1st pays Schwab a Participation Fee on all referred clients ’accounts custodied at Schwab and a Non-
Schwab Custody Fee on all accounts maintained at, or transferred to, another custodian. The Participation
Fee we pay is a percentage of the fees the client pays to us, or a percentage of the value of the assets in the
client’s account subject to a minimum Participation Fee. Client 1st pays Schwab the Participation Fee as long
as the referred client’s account remains in custody at Schwab. Schwab bills us the Participation Fee quarterly
and Schwab may increase, decrease, or waive the fee from time to time. Client 1st pays the Participation Fee
and not the client. We have agreed not to charge clients referred through the Service fees or costs greater than
the fees or costs we normally charge to clients with similar portfolios who were not referred through the
Service.
Schwab bases the Participation Fee and Non-Schwab Custody Fee on assets in accounts of our clients referred
by Schwab and those referred clients ’family members living in the same household. This means that we
have an incentive to encourage household members of clients referred through the Service to maintain
custody of their accounts and execute transactions at Schwab and to instruct Schwab to debit our fees directly
from their accounts.
Compensation or future benefits that we or other network participants receive from referrals creates
conflicts of interests and you should carefully consider proceeding with such referrals. You are never
obligated to accept a referral and will not be charged any additional fee for it.
Item 15 — Custody
Assets are held at our qualified custodian, Charles Schwab. The custodian provides account
statements directly to you at your address of record at least quarterly. Client 1st does not take
custody of Clients’ securities (See “Item 12—Brokerage Practices” above)
In very limited circumstances we act as a trustee for clients. Or we may also provide bill paying
services where we directly debit your account to pay your service providers. In these service
relationships we are deemed to have constructive custody of your funds under federal and state
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regulations. We establish these relationships with Compliance Department approval and we
undergo an annual surprise audit by an accountant designated by the Public Company Accounting
Oversight Board (PCAOB).
We urge you to compare the account statements received directly by mail or electronically from
your custodian with any performance report statements or services provided to you by Client 1st in
the course of our relationship.
Item 16 — Investment Discretion
You designate Client 1st as your agent and attorney-in-fact to determine appropriate Account
investments based on your financial circumstances and investment objectives. Our advisor can
accordingly purchase and sell investment assets for your account. . This “trading discretion”
granted to Client 1st does not authorize us to withdraw funds or assets from the Account.
Discretionary trading authority facilitates placing trades in your accounts on your behalf so that
we may promptly implement the investment plan that you have approved in writing and allows us
to periodically rebalance your accounts to maintain the asset allocation strategy for meeting your
goals and objectives.
Item 17 — Voting Client Securities
Client 1st does not vote securities (proxies) on behalf of our clients. We will not accept
authorization to vote proxies. Nor will we take any action to render any advice with respect to
voting proxies. We have instructed our custodian to forward all proxies and shareholder
communications relating to the investment assets of our clients directly to our clients.
Item 18 — Financial Information
As a registered investment adviser, we are required to provide you with certain financial
information or disclosures about our financial condition or if we have financial commitments that
impair our ability to meet contractual and fiduciary commitments to you. We have not been the
subject of a bankruptcy and do not have any financial commitments that would impair our ability
to meet any contractual or fiduciary commitments to you.
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