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Collective Family Office, LLC
235 St. Charles Way, Suite 200
York, PA 17402
Phone: (717) 893-5055
Email: info@collectivefo.com
March 3, 2025
Form ADV Part 2A Brochure
Collective Family Office, LLC is a registered investment adviser. An "investment adviser" means any person
who, for compensation, engages in the business of advising others, either directly or through publications
or writings, as to the value of securities or as to the advisability of investing in, purchasing, or selling
securities, or who, for compensation and as part of a regular business, issues or promulgates analyses or
reports concerning securities. Registration with the SEC or any state securities authority does not imply a
certain level of skill or training.
This brochure provides information about the qualifications and business practices of Collective Family
Office, LLC. If you have any questions about the contents of this brochure, please contact us at (717) 893-
5055. The information in this brochure has not been approved or verified by the United States Securities
and Exchange Commission or by any state securities authority.
Additional information about Collective Family Office, LLC is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Form ADV Part 2A Brochure
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Material Changes - Item 2
The purpose of this page is to inform you of any material changes since the previous version of this brochure.
On March 3, 2025, we submitted our annual updating amendment filing for fiscal year 2024 and made the
following material changes to our Form ADV Part 2A Brochure:
• We updated Item 4 to disclose discretionary assets under management of approximately $446,381,340,
and non-discretionary assets under management of approximately $5,355,154.
• We amended Item 8 to provide additional risk disclosures related to government policies, such as tariffs.
• We amended Item 17 to disclose that we now use Chicago Clearing Corp to assist our clients with the
preparation, filing, acceptance and processing of class action claims, the distributions of settlement
payments, government filings, and other support services.
If you would like to receive a complete copy of our current brochure free of charge at any time, please contact us
at (717) 893-5055 or at info@collectivefo.com.
Collective Family Office, LLC
Form ADV Part 2A Brochure
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Table of Contents - Item 3
Contents
Advisory Business - Item 4 ........................................................................................................................ 4
Fees and Compensation - Item 5 .............................................................................................................. 6
Performance-Based Fees and Side-By-Side Management - Item 6 .......................................................... 9
Types of Clients - Item 7............................................................................................................................ 9
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 ................................................... 10
Disciplinary Information - Item 9 ............................................................................................................ 18
Other Financial Industry Activities or Affiliations - Item 10 .................................................................... 18
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ........... 18
Brokerage Practices - Item 12 ................................................................................................................. 19
Review of Accounts - Item 13 ................................................................................................................. 21
Client Referrals and Other Compensation - Item 14 .............................................................................. 21
Custody - Item 15 .................................................................................................................................... 21
Investment Discretion - Item 16 ............................................................................................................. 22
Voting Client Securities - Item 17 ........................................................................................................... 22
Financial Information - Item 18 .............................................................................................................. 23
Requirements of State-Registered Advisers - Item 19 ............................................................................ 23
Additional Information ........................................................................................................................... 23
Collective Family Office, LLC
Form ADV Part 2A Brochure
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Advisory Business - Item 4
Description of Services and Fees
Collective Family Office, LLC (hereinafter “CFO”) is a registered investment adviser based in York, Pennsylvania.
We are a limited liability company, formed under the laws of the State of Pennsylvania. We have been providing
investment advisory services since 2019. David S Sivel, CEO, Trevor Hoffman, COO/CCO and Brian Luster, CIO, are
the Managing Members and principal owners of CFO.
You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to
anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of
our firm, including Mr. Sivel, Mr. Hoffman and Mr. Luster. Such persons are properly registered as investment
adviser representatives in applicable jurisdictions where required.
Portfolio Management Services
Our firm offers discretionary portfolio management services to our clients. Discretionary portfolio management
means we will make investment decisions and place buy or sell orders in your account without contacting you.
These decisions would be made based upon your stated investment objectives. If you wish, you may limit our
discretionary authority by, for example, setting a limit on the type of securities that can be purchased for your
account. Simply provide us with your restrictions or guidelines in writing.
Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our
firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals,
and help you decide how much risk you should take in your investments. The information we gather will help us
implement an asset allocation strategy that will be specific to your goals, whether we are actively investing for
you or simply providing you with advice.
CFO does not recommend one particular type of security over other types of securities, but we do provide advice
on various types of securities, such as exchange listed equities, over the counter equities, foreign issues, American
depository receipts, corporate debt securities, commercial paper, certificates of deposit, municipal securities,
investment company securities (including mutual funds and exchange traded funds), US Government securities,
options contracts on securities and/or commodities, private equity instruments, return enhanced notes, and
interests in partnership investing in real estate. Additionally, will provide advice on existing investments you may
hold at the inception of the advisory relationship or on other types of investments for which you ask advice.
If you engage us for portfolio management services, we will monitor your portfolio’s performance on a continuous
basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions and/or your
financial circumstances.
Recommendation of Sub Advisors
As part of our overall portfolio management strategy, we may use one or more sub-advisors to manage all or a
portion of your account. All sub-advisors recommended by our firm must either be registered as investment
advisors or exempt from registration requirements. These sub-advisors may specialize in private equity
investments, private credit markets, hedge funds or other types of alternative investments. Factors that we take
into consideration when making our recommendations include, but are not limited to, the following: the sub-
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advisor’s performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and
investment objectives. We will periodically monitor the sub-advisor’s performance to ensure its management and
investment style remains aligned with your investment goals and objectives. We retain the right to hire and fire
sub-advisors and the right to reallocate client assets to other model portfolios at the same sub-advisor.
Management of Held Away Assets
As part of our overall portfolio management services, we may provide asset allocation review, rebalancing and
management services for accounts that are not held in custody of the qualified custodian(s) recommended by our
firm. These services are provided through an account aggregation service called Pontera Solutions Inc.
("Pontera"). This service primarily applies to ERISA and non-ERISA plan assets such as 401(k)s and 403(b)s, and
other assets that must be held in custody of the plan custodian(s). We regularly review the available investment
options in these accounts, monitor them, and periodically rebalance and implement our strategies using different
tools as necessary. If you elect to allow our firm to manage your assets through Pontera, you will be notified via
email when CFO places trades through Pontera.
Pension Consulting Services
CFO provides several pension consulting related services. While the primary clients for these services will be
pension, profit sharing and 401(k) plans, CFO will also offer these services, where appropriate, to individuals and
trusts, estates, corporate entities and charitable organizations. Pension Consulting Services are comprised of the
following components. Clients may choose to use any or all of the following services:
• Assistance with the development and/or review and revision of an Investment Policy Statement (“IPS”)
•
as requested.
Provision of recommendations on appropriate investments that have a level of risk commensurate with
the anticipated return, seeing to it that risk is minimized through diversification, and ensuring that the
Plan has sufficient liquidity to meet its cash flow requirements.
• Assistance with the selection of a qualified default investment alternative (“QDIA”) and determination
of the continuing suitability of a QDIA.
• Assistance with on-going monitoring and make recommendations regarding the replacement of the
Plan’s investments and investment providers.
• Assistance with the monitoring of investment options by preparing quarterly reports that document
investment performance, consistency of fund management, and conformance to any guidelines set forth
in the IPS and will notify you with any recommendations.
• Analysis of the fees and expenses associated with the investments and the service providers and
recommend changes when warranted.
• Ongoing and continuous discretionary investment management with respect to the asset classes and
investments for the Plan in accordance with the Plan’s investment policies and objectives. This service is
described in more detail in the Portfolio Management Services section above.
• Monitor investments by preparing periodic investment reports that document investment performance,
consistency of fund management and conformance to the guidelines set forth in the IPS and determine
whether to maintain or remove and replace investment options.
• Meetings with Clients on a periodic basis to discuss the reports and investment decisions.
These services are designed to assist plan sponsors in meeting their management and fiduciary obligations to
Participants under ERISA. Pursuant to adopted regulations of the U.S. Department of Labor, we are required to
provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment
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Form ADV Part 2A Brochure
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adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive
for providing those services, and our status (which is described below).
Other pension consulting services are available on request. All of our pension consulting services, whether general
or customized, will be outlined in an Agreement that shows the services that will be provided and the fees that
will be charged for those services.
CFO is registered as an investment advisor and represents that it is not subject to any disqualification as set forth
in Section 411 under the Employee Retirement Income Security Act (“ERISA”). To the extent CFO performs
Fiduciary Services, CFO is acting as a fiduciary of the Plan as defined in Section 3(21) or Section 3(38) under ERISA.
CFO may also perform the following Non-Fiduciary services:
• Assistance with the education of the participants in the Plan about general investment principles. Client
understands that CFO’s assistance in participant investment education shall be consistent with and
within the scope of the definition of investment education of Department of Labor Interpretive Bulletin
96-1. As such, CFO is not providing fiduciary advice (as defined in ERISA) to the participants. CFO will not
provide individualized investment advice concerning the prudence of any investment or combination of
investment for a particular participant or beneficiary under the Plan.
• Assistance with group enrollment meetings designed to increase retirement plan participation among
employees and investment and financial understanding by the employees.
CFO may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these
services, as agreed upon between CFO and Client.
Wrap Fee Programs
We do not sponsor, manage, or participate in any wrap fee programs.
Assets Under Management
As of December 31, 2024, we had approximately $446,381,340 in discretionary assets under management and
approximately $5,355,154 in non-discretionary assets under management.
Fees and Compensation - Item 5
Portfolio Management Services
For portfolio management services, CFO charges an annual fee of up to 1.00% of assets under management. Fees
are payable quarterly in advance and are based on the value of assets on the last day of the previous calendar
quarter. Fees will be pro-rated for the first partial quarter and adjusted for any deposits or withdrawals during
the quarter. In limited cases, clients may have non-managed assets that are included in portfolio management
reviews and performance reports provided to clients. Such assets will be subject to an annual fee of up to 0.15%.
Portfolio management fees and payment arrangements are negotiable depending on factors such as the amount
of assets under management, range of investments, and complexity of the client’s financial circumstances, among
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Form ADV Part 2A Brochure
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others. The agreed upon fee to be paid by the client will be clearly stated in the Agreement signed by the client
and the firm.
Generally, the custodian holding the client’s account will deduct CFO’s fees and any other custodial fees directly
from a designated account to facilitate billing provided the client has given written authorization. The qualified
custodian will send an account statement at least quarterly. This statement will detail all account activity. Fees
may be deducted from a single designated client account to facilitate billing. In limited circumstances, at the sole
discretion of CFO, we may agree to invoice you directly for our advisory fee or we may negotiate other fee
payment arrangements.
For held away assets managed through Pontera, Pontera does not offer us the ability to deduct fees from the
account. As such, fees for the management of held away assets will either be paid directly by the client or
deducted from another account that we manage for the client at the qualified custodian(s) recommended by our
firm.
Our annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other related costs
and expenses which will be incurred by the client. However, we will not receive any portion of the commissions,
fees, and costs. Please see Item 12 – Brokerage Practices for further information on brokerage and transaction
costs.
You may terminate the portfolio management services agreement upon 30-days’ written notice to our firm. You
will incur a pro rata charge for services rendered prior to the termination of the portfolio management agreement,
which means you will incur advisory fees only in proportion to the number of days in the quarter for which you
are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of
those fees.
Pension Consulting Services Fees
The fees and compensation charged by CFO is negotiated independently with each Plan Sponsor in order to
consider the varying, unique characteristics or requirements of each plan. Primary determinants of the
negotiated fee may include but are not limited to the:
• Amount of plan assets,
• Number of employees / participants,
• Number of plan sponsor locations, and
•
Special plan sponsor considerations or requirements.
Delivery of compensation or fees to CFO is dependent on the invoicing or fee assessment frequency (monthly,
quarterly) and policies (“arrears” or “in advance”) of the Plan Provider/Platform utilized by the Plan Sponsor. The
exact fee and fee payment method will be clearly listed in the pension consulting agreement signed by the client
and CFO.
Either party to the pension consulting agreement may terminate the agreement in accordance to the terms of
the agreement. The fees will be prorated for the quarter in which the termination notice is given, and any
unearned fees will be refunded to the client.
IRA Rollover Considerations
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As a normal extension of financial advice, we provide education or recommendations related to the rollover of an
employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice
offers advantages and disadvantages, depending on desired investment options and services, fees and expenses,
withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and
retirement plans. The complexity of these choices may lead an investor to seek assistance from us.
An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account
(“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we
have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and
expenses will increase to the investor as a result because the above-described fees will apply to assets rolled over
to an IRA and outlined ongoing services will be extended to these assets.
We are fiduciaries under the Investment Advisers Act of 1940 and we must act in your best interests and not put
our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual funds
and exchange traded funds. The fees that you pay to our firm for investment advisory services are separate and
distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund’s
prospectus) to their shareholders. These fees will generally include an advisory fee and other fund expenses.
You will also incur custodial fees, transaction charges and/or brokerage fees when purchasing or selling securities.
These charges and fees are typically imposed by the broker-dealer or custodian through which your account
transactions are executed. We do not share in any portion of the fees or charges imposed by the broker-dealer
or custodian. Where suitable, we will recommend no-load mutual funds. To fully understand the total cost you
will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others.
For information on our brokerage practices, please refer to the “Brokerage Practices” section of this Disclosure
Brochure.
Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact investment
management fees within the range disclosed in our Form ADV Part 2A Brochure. As a result, the Associated Person
servicing your account may charge more or less for the same service than another Associated Person of our firm.
Further, our annual investment management fee may be higher than that charged by other investment advisors
offering similar services/programs.
Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless
otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included
as part of assets under management for purposes of calculating the firm’s advisory fee. At any specific point in
time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such
anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts
could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could
exceed the interest paid by the client’s cash or cash equivalent positions.
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Billing on Margin: Unless otherwise agreed in writing, the gross amount of assets in the client’s account, including
margin balances, are included as part of assets under management for purposes of calculating the firm’s advisory
fee. Clients should note that this practice will increase total assets under management used to calculate advisory
fees which will in turn increase the amount of fees collected by our firm. This practice creates a conflict of interest
in that our firm has an incentive to use margin in order to increase the amount of billable assets. At all times, the
firm and its Associated Persons strive to uphold their fiduciary duty of fair dealing with clients. Clients are free to
restrict the use of margin by our firm. However, clients should note that any restriction on the use of margin may
negatively impact an account’s performance in a rising market.
Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including but not limited to investment
performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial
circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may
be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary
nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will
continue to apply during these periods, and there can be no assurance that investment decisions made by the
firm will be profitable or equal any specific performance level(s).
Any material conflicts of interest between you and our firm, or our employees are disclosed in this Disclosure
Brochure. If at any time, additional material conflicts of interest develop, we will provide you with written
notification of the material conflicts of interest or an updated Disclosure Brochure.
Note: Information related to tax or legal consequences that is provided as part of overall portfolio management
service is for informative purposes only. Clients are instructed to contact their tax professionals or attorneys for
tax or legal advice.
Performance-Based Fees and Side-By-Side Management - Item 6
Performance-based fees are fees that are based on a share of capital gains or capital appreciation of a client’s
account. Side-by-side management refers to the practice of managing accounts that are charged performance-
based fees while at the same time managing accounts that are not charged performance-based fees. We do not
accept performance-based fees or participate in side-by-side management. Our fees are calculated as described
in the Fees and Compensation section above, and are not charged on the basis of a share of capital gains upon, or
capital appreciation of, the funds in your advisory account.
Types of Clients - Item 7
We offer investment advisory services to individuals, high net worth individuals, Pension and profit sharing plans,
trusts, estates, charitable organizations, and corporations, or other business entities.
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Generally, we require a minimum of $1,000,000 to establish an advisory relationship. At our sole discretion, we
may waive this requirement. This requirement can be met by combining two or more accounts owned by you or
related family members.
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8
We may use one or more of the following methods of analysis and/or investment strategies when providing
investment advice to you:
• Fundamental Analysis – involves analyzing individual companies and their industry groups, such as a
company’s financial statements, details regarding the company’s product line, the experience and
expertise of the company’s management, and the outlook for the company’s industry. The resulting data
is used to measure the true value of the company’s stock compared to the current market value. The
primary risk of fundamental analysis is that information obtained may be incorrect and the analysis may
not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities
prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable
performance.
• Technical Analysis – technical analysis is a technique that relies on the assumption that current market
data (such as charts of price, volume, and open interest) can help predict future market trends, at least
in the short term. It assumes that market psychology influences trading and can predict when stocks will
rise or fall. Technical trading models are mathematically driven based upon historical data and trends of
domestic and foreign market trading activity, including various industry and sector trading statistics
within such markets. Technical trading models, through mathematical algorithms, attempt to identify
when markets are likely to increase or decrease and identify appropriate entry and exit points. The
primary risk of technical trading models is that historical trends and past performance cannot predict
future trends, and there is no assurance that the mathematical algorithms employed are designed
properly, updated with new data, and can accurately predict future market, industry, and sector
performance.
• Cyclical Analysis – Cyclical analysis is similar to technical analysis in that it involves the analysis of market
conditions at a macro (entire market/economy) or micro (company specific) level, rather than the overall
fundamental analysis of the health of the particular company. The primary risks with cyclical analysis are
similar to those of technical analysis.
We may use one or more of the following investment strategies when advising you on investments:
• Long Term Purchases – securities purchased with the expectation that the value of those securities will
grow over a relatively long period of time, generally greater than one year. Using a long-term purchase
strategy generally assumes the financial markets will go up in the long-term which may not be the case.
There is also the risk that the segment of the market that you are invested in or perhaps just your
particular investment will go down over time even if the overall financial markets advance. Purchasing
investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized
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in the short-term in other investments.
• Short Term Purchases – securities purchased with the expectation that they will be sold within a relatively
short period of time, generally less than one year, to take advantage of the securities' short-term price
fluctuations. Using a short-term purchase strategy generally assumes that we can predict how financial
markets will perform in the short-term which may be very difficult and will incur a disproportionately
higher amount of transaction costs compared to long-term trading. There are many factors that can
affect financial market performance in the short-term (such as short-term interest rate changes, cyclical
earnings announcements, etc.) but may have a smaller impact over longer periods of times.
• Option Writing – an option is the right either to buy or sell a specified amount or value of a particular
underlying investment instrument at a fixed price (i.e. the “exercise price”) by exercising the option
before its specified expiration date. Options giving you the right to buy are called “call” options. Options
giving you the right to sell are called “put” options. When trading options on behalf of a client, we
generally use covered options. Covered options involve options trading when you own the underlying
instrument on which the option is based. Investments in options contracts have the risk of losing value
in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of
a single contract to control many shares of an underlying stock. This leverage can compound gains or
losses.
Investing in securities involves risk of loss that Clients should be prepared to bear.
The investment advice provided along with the strategies suggested by CFO will vary depending on each client’s
specific financial situation and goals. This brief statement does not disclose all of the risks and other significant
aspects of investing in financial markets. In light of the risks, you should fully understand the nature of the
contractual relationship(s) into which you are entering and the extent of your exposure to risk. Certain investing
strategies may not be suitable for many members of the public. You should carefully consider whether the
strategies employed would be appropriate for you in light of your experience, objectives, financial resources and
other relevant circumstances.
Recommendation of Particular Types of Securities
As disclosed under the “Advisory Business” section in this Brochure, we provide advice on various types of
securities and we do not necessarily recommend one particular type of security over another since each client
has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated
with it and it would not be possible to list here all of the specific risks of every type of investment. Even within
the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated
return of an investment, the higher the risk of loss associated with it.
General Investment Risk: All investments come with the risk of losing money. Investing involves substantial risks,
including complete possible loss of principal plus other losses and may not be suitable for many members of the
public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect
against market losses. Different market instruments carry different types and degrees of risk and you should
familiarize yourself with the risks involved in the particular market instruments in which you intend to invest.
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Loss of Value: There can be no assurance that a specific investment will achieve its investment objectives and
past performance should not be seen as a guide to future returns. The value of investments and the income
derived may fall as well as rise and investors may not recoup the original amount invested. Investments may also
be affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and
economic developments, and governmental economic or monetary policies.
Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income securities may
fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their
prices fall when interest rates rise. Longer-term debt securities are usually more sensitive to interest rate changes.
Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may
not make required interest payments. An issuer suffering an adverse change in its financial condition could lower
the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of
a security may also offset the security's liquidity, making it more difficult to sell. Funds investing in lower quality
debt securities are more susceptible to these problems and their value may be more volatile.
Foreign Exchange Risk: Foreign investments may be affected favorably or unfavorably by exchange control
regulations or changes in the exchange rates. Changes in currency exchange rates may influence the share value,
the dividends or interest earned and the gains and losses realized. Exchange rates between currencies are
determined by supply and demand in the currency exchange markets, the international balance of payments,
governmental intervention, speculation, and other economic and political conditions. If the currency in which a
security is denominated appreciates against the US Dollar, the value of the security will increase. Conversely, a
decline in the exchange rate of the currency would adversely affect the value of the security.
Environmental, Social, and Governance Investment Criteria Risk: If a portfolio is subject to certain
environmental, social and governance (ESG) investment criteria it may avoid purchasing certain securities for ESG
reasons when it is otherwise economically advantageous to purchase those securities, or may sell certain
securities for ESG reasons when it is otherwise economically advantageous to hold those securities. In general,
the application of the portfolio’s ESG investment criteria may affect the portfolio’s exposure to certain issuers,
industries, sectors and geographic areas, which may affect the financial performance of the portfolio, positively
or negatively, depending on whether these issuers, industries, sectors or geographic areas are in or out of favor.
An adviser can vary materially from other advisers with respect to its methodology for constructing ESG portfolios
or screens, including with respect to the factors and data that it collects and evaluates as part of its process. As a
result, an adviser’s ESG portfolio or screen may materially differ from or contradict the conclusions reached by
other ESG advisers concerning the same issuers. Further, ESG criteria are dependent on data and are subject to
the risk that such data reported by issuers or received from third-party sources may be subjective, or it may be
objective in principle but not verified or reliable.
Risks Associated with Investing in Equities: Investments in equities generally refers to buying shares of stocks by
an individual or firms in return for receiving a future payment of dividends and capital gains if the value of the
stock increases. There is an innate risk involved when purchasing a stock that it may decrease in value and the
investment may incur a loss.
Risks Associated with Investing in Mutual Funds: Mutual funds are professionally managed collective investment
systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments,
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other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the
fund's investments in accordance with the fund's investment objective. While mutual funds generally provide
diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market,
primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant
degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different
types of securities. The returns on mutual funds can be reduced by the costs to manage the funds. In addition,
while some mutual funds are “no load” and charge no fee to buy into, or sell out of, other types of mutual funds
do charge such fees which can also reduce returns.
Risks Associated with Investing in Exchange Traded Funds (ETF): Investing in stocks & ETF's carries the risk of
capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investments in these
securities are not guaranteed or insured by the FDIC or any other government agency.
Risks Associated with Investing in Private Funds: Private investment funds are not registered with the Securities
and Exchange Commission and may not be registered with any other regulatory authority. Accordingly, they are
not subject to certain regulatory restrictions and oversight to which other issuers are subject. There may be little
public information available about their investments and performance. Moreover, as sales of shares of private
investment companies are generally restricted to certain qualified purchasers, it could be difficult for a client to
sell its shares of a private investment company at an advantageous price and time. Since shares of private
investment companies are not publicly traded, from time to time it may be difficult to establish a fair value for
the client’s investment in these companies.
Risks Associated with Investing in Options: Transactions in options carry a high degree of risk. A relatively small
market movement will have a proportionately larger impact, which may work for or against the investor. The
placing of certain orders, which are intended to limit losses to certain amounts, may not be effective because
market conditions may make it impossible to execute such orders. Selling ("writing" or "granting") an option
generally entails considerably greater risk than purchasing options. Although the premium received by the seller
is fixed, the seller may sustain a loss well in excess of that amount. The seller will also be exposed to the risk of
the purchaser exercising the option and the seller will be obliged either to settle the option in cash or to acquire
or deliver the underlying investment. If the option is "covered" by the seller holding a corresponding position in
the underlying investment or a future on another option, the risk may be reduced.
Risks Associated with Investing in Inverse and Leveraged Funds: Leveraged mutual funds and ETFs generally seek
to deliver multiples of the daily performance of the index or benchmark that they track. Inverse mutual funds and
ETFs generally seek to deliver the opposite of the daily performance of the index or benchmark that they track.
Inverse funds often are marketed as a way for investors to profit from, or at least hedge their exposure to,
downward-moving markets. Some Inverse funds are both inverse and leveraged, meaning that they seek a return
that is a multiple of the inverse performance of the underlying index. To accomplish their objectives, leveraged
and inverse funds use a range of investment strategies, including swaps, futures contracts, and other derivative
instruments. Leveraged, inverse, and leveraged inverse funds are more volatile and riskier than traditional funds
due to their exposure to leverage and derivatives, particularly total return swaps and futures. At times, we will
recommend leveraged and/or inversed funds, which may amplify gains and losses.
Most leveraged funds are typically designed to achieve their desired exposure on a daily (in a few cases, monthly)
basis, and reset their leverage daily. A "single day" is measured from the time the leveraged fund calculates its
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net asset value ("NAV") to the time of the leveraged fund's next NAV calculation. The return of the leveraged fund
for periods longer than a single day will be the result of each day's returns compounded over the period. Due to
the effect of this mathematical compounding, their performance over longer periods of time can differ
significantly from the performance (or inverse performance) of their underlying index or benchmark during the
same period of time. For periods longer than a single day, the leveraged fund will lose money when the level of
the Index is flat, and the leveraged fund may lose money even if the level of the Index rises. Longer holding
periods, higher index volatility, and greater leverage all exacerbate the impact of compounding on an investor's
returns. During periods of higher Index volatility, the volatility of the Index may affect the leveraged fund's return
as much as or more than the return of the Index itself. Therefore, holding leveraged, inverse, and leveraged
inverse funds for longer periods of time increases their risk due to the effects of compounding and the inherent
difficulty in market timing. Leveraged funds are riskier than similarly benchmarked funds that do not use leverage.
Non-traditional funds are highly volatile and not suitable for all investors. They provide the potential for significant
losses.
Risks Associated with Investing in Buffer ETFs: Buffer ETFs are also known as defined-outcome ETFs since the ETF
is designed to offer downside protection for a specified period of time. These ETFs are modeled after options-
based structured notes, but are generally cheaper, and offer more liquidity. Buffer ETFs are designed to safeguard
against market downturns by employing complex options strategies. Buffer ETFs typically charge higher
management fees that are considerably more than the index funds whose performance they attempt to track.
Additionally, because buffer funds own options, they do not receive dividends from their equity holdings. Both
factors result in the underperformance of the Buffer ETF compared to the index they attempt to track. Clients
should carefully read the prospectus for a buffer ETF to fully understand the cost structures, risks, and features
of these complex products.
Structured Notes: Below are some specific risks related to the structured notes recommended by our firm:
•
Complexity: Structured notes are complex financial instruments. Clients should understand the reference
asset(s) or index(es) and determine how the note’s payoff structure incorporates such reference asset(s)
or index(es) in calculating the note’s performance. This payoff calculation may include leverage
multiplied by the performance of the reference asset or index, protection from losses should the
reference asset or index produce negative returns, and/or fees. Structured notes may have complicated
payoff structures that can make it difficult for clients to accurately assess their value, risk and potential
for growth through the term of the structured note. Determining the performance of each note can be
complex and this calculation can vary significantly from note to note depending on the structure. Notes
can be structured in a wide variety of ways. Payoff structures can be leveraged, inverse, or inverse-
leveraged, which may result in larger returns or losses. Clients should carefully read the prospectus for a
structured note to fully understand how the payoff on a note will be calculated and discuss these issues
with our firm.
• Market risk. Some structured notes provide for the repayment of principal at maturity, which is often
referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing
financial institution. Many structured notes do not offer this feature. For structured notes that do not
offer principal protection, the performance of the linked asset or index may cause clients to lose some,
or all, of their principal. Depending on the nature of the linked asset or index, the market risk of the
structured note may include changes in equity or commodity prices, changes in interest rates or foreign
exchange rates, and/or market volatility.
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•
•
•
Issuance price and note value: The price of a structured note at issuance will likely be higher than the fair
value of the structured note on the date of issuance. Issuers now generally disclose an estimated value
of the structured note on the cover page of the offering prospectus, allowing investors to gauge the
difference between the issuer’s estimated value of the note and the issuance price. The estimated value
of the notes is likely lower than the issuance price of the note to investors because issuers include the
costs for selling, structuring, and/or hedging the exposure on the note in the initial price of their notes.
After issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value
given their complexity.
Liquidity: The ability to trade or sell structured notes in a secondary market is often very limited, as
structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on
securities exchanges. As a result, the only potential buyer for a structured note may be the issuing
financial institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In
addition, issuers often specifically disclaim their intention to repurchase or make markets in the notes
they issue. Clients should, therefore, be prepared to hold a structured note to its maturity date or risk
selling the note at a discount to its value at the time of sale.
Credit risk: Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is
obligated to make payments on the notes as promised. These promises, including any principal
protection, are only as good as the financial health of the structured note issuer. If the structured note
issuer defaults on these obligations, investors may lose some, or all, of the principal amount they
invested in the structured notes as well as any other payments that may be due on the structured notes.
Concentrated Position Risk: Certain accounts may, or may be advised to, hold concentrated positions in specific
securities. Therefore, at times, an account may, or may be advised to, hold a relatively small number of securities
positions, each representing a relatively large portion of assets in the account. As a result, the account will be
subject to greater volatility than a more sector diversified portfolio. Investments in issuers within an industry or
economic sector that experiences adverse economic, business, political conditions or other concerns will impact
the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the
value of a single investment within the portfolio will affect the overall value of the portfolio and will cause greater
losses than it would in a portfolio that holds more diversified investments.
Preferred Securities Risk: Preferred Securities have similar characteristics to bonds in that preferred securities
are designed to make fixed payments based on a percentage of their par value and are senior to common stock.
Like bonds, the market value of preferred securities is sensitive to changes in interest rates as well as changes in
issuer credit quality. Preferred securities, however, are junior to bonds with regard to the distribution of corporate
earnings and liquidation in the event of bankruptcy. Preferred securities that are in the form of preferred stock
also differ from bonds in that dividends on preferred stock must be declared by the issuer’s board of directors,
whereas interest payments on bonds generally do not require action by the issuer’s board of directors, and
bondholders generally have protections that preferred stockholders do not have, such as indentures that are
designed to guarantee payments – subject to the credit quality of the issuer – with terms and conditions for the
benefit of bondholders. In contrast preferred stocks generally pay dividends, not interest payments, which can
be deferred or stopped in the event of credit stress without triggering bankruptcy or default. Another difference
is that preferred dividends are paid from the issue’s after-tax profits, while bond interest is paid before taxes.
Cybersecurity Risks: Our firm and our service providers are subject to risks associated with a breach in
cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices designed
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to protect networks, systems, computers, programs, and data from cyber-attacks and hacking by other computer
users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of
data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate; however,
unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the
processing of transactions, affecting the ability to calculate net asset value or impeding or sabotaging trading.
Clients may also incur substantial costs as the result of a cybersecurity breach, including those associated with
forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft,
unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary
information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or action. In
addition, clients could be exposed to additional losses as a result of unauthorized use of their personal
information. While our firm has established a business continuity plan and systems designed to prevent cyber-
attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have
not been identified. Similar types of cyber security risks are also present for issuers of securities, investment
companies and other investment advisers in which we invest, which could result in material adverse
consequences for such entities and may cause a client's investment in such entities to lose value.
Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a
wide geographic area, crossing international boundaries, and causing significant economic, social, and political
disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety
of factors including the global response of regulators and governments to address and mitigate the worldwide
effects of such events. Workforce reductions, travel restrictions, governmental responses and policies and
macroeconomic factors will negatively impact investment returns.
Recommendation of Other Advisers: In the event we recommend a third-party investment adviser to manage all
or a portion of your assets, we will advise you on how to allocate your assets among various classes of securities
or third-party investment managers, programs, or managed model portfolios. As such, we will primarily rely on
investment model portfolios and strategies developed by the third-party investment advisers and their portfolio
managers. If there is a significant deviation in characteristics or performance from the stated strategy and/or
benchmark, we may recommend changing models or replacing a third-party investment adviser. The primary risks
associated with investing with a third party is that while a particular third party may have demonstrated a certain
level of success in the past; it may not be able to replicate that success in future markets. In addition, as we do
not control the underlying investments in third party model portfolios, there is also a risk that a third party may
deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for
our clients. To mitigate this risk, we seek third parties with proven track records that have demonstrated a
consistent level of performance and success over time. A third party’s past performance is not a guarantee of
future results and certain market and economic risks exist that may adversely affect an account’s performance
that could result in capital losses in your account. Please refer to the third-party investment adviser’s advisory
agreements, Form ADV Brochure, and associated disclosure documents for details on their specific investment
strategies, methods of analysis, and associated risks.
Cryptocurrency Risk: Cryptocurrency (e.g., bitcoin and ether), often referred to as “virtual currency”, “digital
currency,” or “digital assets,” is designed to act as a medium of exchange. Cryptocurrency is an emerging asset
class. There are thousands of cryptocurrencies, the most well-known of which is bitcoin. Certain of the firm’s
clients may have exposure to bitcoin or another cryptocurrency, directly or indirectly through an investment such
as an ETF or other investment vehicles. Cryptocurrency operates without central authority or banks and is not
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backed by any government. Cryptocurrencies may experience very high volatility and related investment vehicles
may be affected by such volatility. As a result of holding cryptocurrency, certain of the firm’s clients may also
trade at a significant premium or discount to NAV. Cryptocurrency is also not legal tender. Federal, state or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still developing.
The market price of many cryptocurrencies, including bitcoin, has been subject to extreme fluctuations. If
cryptocurrency markets continue to be subject to sharp fluctuations, investors may experience losses if the value
of the client’s investments decline. Similar to fiat currencies (i.e., a currency that is backed by a central bank or a
national, supra-national or quasi-national organization), cryptocurrencies are susceptible to theft, loss and
destruction. 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. The SEC has issued a public
report stating U.S. federal securities laws require treating some digital assets as securities.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical glitches, hackers
or malware. Due to relatively recent launches, most cryptocurrencies have a limited trading history, making it
difficult for investors to evaluate investments. Generally, cryptocurrency transactions are irreversible such that
an improper transfer can only be undone by the receiver of the cryptocurrency agreeing to return the
cryptocurrency to the original sender. Digital assets are highly dependent on their developers and there is no
guarantee that development will continue or that developers will not abandon a project with little or no notice.
Third parties may assert intellectual property claims relating to the holding and transfer of digital assets, including
cryptocurrencies, and their source code. Any threatened action that reduces confidence in a network’s long-term
ability to hold and transfer cryptocurrency may affect investments in cryptocurrencies.
Many significant aspects of the U.S. federal income tax treatment of investments in cryptocurrency are uncertain
and an investment in cryptocurrency may produce income that is not treated as qualifying income for purposes
of the income test applicable to regulated investment companies. Certain cryptocurrency investments may be
treated as a grantor trust for U.S. federal income tax purposes, and an investment by the firm’s clients in such a
vehicle will generally be treated as a direct investment in cryptocurrency for tax purposes and “flow-through” to
the underlying investors.
Government Policy Risk: Each administration presents its own set of unique policy risks. For example, the use of
tariffs, or the threats thereof, as a material policy tool could impact investors, especially if the scope,
implementation, and duration of tariffs are extensive. Industries that rely on imported raw material or that have
heavily integrated cross-border manufacturing practices may be most impacted. However, it is challenging to
predict the impact of actual and/or threatened tariffs and impossible to predict the administration’s future policy
decisions. When tariffs are imposed, there is also a higher probability that retaliatory tariffs could be imposed,
which could negatively impact domestic industries and products. Tariffs in general can also permanently alter
global supply chains and have far-reaching indirect impacts. Historically, tariffs tend to hurt growth in the long
term and add to inflation, which can also lead to pressure on interest rates, impacting the fixed income
market. Many publicly traded companies are global in nature, generating significant portions of their income
abroad and subject to the risk of protectionist policies.
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Disciplinary Information - Item 9
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of CFO’s advisory business or of the integrity of its management
personnel. We have no material history of legal or disciplinary events to report under this item. However,
information regarding management persons of our firm and CFO can be found at www.adviserinfo.sec.gov.
Other Financial Industry Activities or Affiliations - Item 10
Neither CFO nor any of our Associated Persons, including Mr. Sivel, Mr. Hoffman and Mr. Luster, are registered
as, or have pending applications to register as, a broker/dealer, Futures Commission Merchant, Commodity Pool
Operator, or Commodity Trading Advisor or are currently an associated person of any the foregoing types of
entities.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11
Description of Our Code of Ethics
CFO has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The Code focuses
primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The
Code includes CFO’s policies and procedures developed to protect client’s interests in relation to the following
topics:
▪
▪
▪
▪
▪
The duty at all times to place the interests of clients first;
The requirement that all personal securities transactions be conducted in such a manner as to be
consistent with the code of ethics.
The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s
position of trust and responsibility;
The fiduciary principle that information concerning the identity of security holdings and financial
circumstances of clients is confidential; and
The principle that independence in the investment decision-making process is paramount.
A copy of CFO’s Code of Ethics is available upon request to Trevor Hoffman, CCO, at (717) 893-5055 or at
info@collectivefo.com.
Personal Trading Practices
At times, CFO and/or its Advisory Representatives may take positions in the same securities as clients. This is
considered a conflict of interest with clients. CFO and its Advisory Representatives will generally be “last in” and
“last out” for the trading day when trading occurs in close proximity to client trades, however, we will uphold our
fiduciary responsibilities to our clients. Front running (trading shortly ahead of clients) is prohibited. Should a
conflict occur because of materiality (e.g., a thinly traded stock), disclosure will be made to the client(s) at the
time of trading.
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Brokerage Practices - Item 12
CFO has an institutional custodial relationship with Charles Schwab & Co., Inc. (Schwab), a FINRA-registered
broker-dealer, member SIPC. Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business
serving independent investment advisory firms like us. We are independently owned and operated and not
affiliated with Schwab. Schwab will hold your assets in a brokerage account and will buy and sell securities in your
account(s) upon our instructions. While we recommend that you use Schwab as custodian/broker, you will decide
whether to do so and you will open your account with Schwab by entering into an account agreement directly
with them. We do not open the account for you.
Your Custody and Brokerage Costs
Schwab generally does not charge you separately for custody services, but is compensated by charging
commissions or other fees on trades that it executes or that settle into your Schwab account. In addition to
commissions, Schwab charges a flat dollar amount as a “prime broker” or “trade away” fee for each trade that
we have executed by a different broker-dealer but where the securities bought or the funds from the securities
sold are deposited (settled) into your Schwab account.
Research and Other Soft Dollar Benefits
Although not considered “soft dollar” compensation, CFO may receive some economic benefits from Schwab
Advisor Services in the form of access to its institutional brokerage, trading, custody, reporting and related
services, many of which are not typically available to Schwab retail customers. Schwab also makes available
various support services. Some of those services help us manage or administer our clients’ accounts while others
help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis
(we don’t have to request them) and at no charge to us as long as we keep a total of at least $10 million of our
clients’ assets in accounts at Schwab. If we have less than $10 million in client assets at Schwab, Schwab may
charge us quarterly service fees. Below is a detailed description of Schwab’s support services.
Services that Benefit You: Schwab’s institutional brokerage services include access to a broad range of investment
products, execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access or that would require a significantly
higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit
you and your account.
Services that May Not Directly Benefit You: Schwab also makes available to us other products and services that
benefit us but may not directly benefit you or your account. These products and services assist us in managing
and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third
parties. We may use this research to service all or some substantial number of our clients’ accounts, including
accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
•
•
provide access to client account data (such as duplicate trade confirmations and account statements);
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
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•
•
•
provide pricing and other market data;
facilitate payment of our fees from our clients’ accounts; and
assist with back-office functions, recordkeeping, and client reporting.
•
•
•
•
Services that Generally Benefit Only Us: Schwab also offers other services intended to help us manage and further
develop our business enterprise. These services include:
educational conferences and events;
technology, compliance, legal, and business consulting;
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants, and insurance providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide
the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a
third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of
our personnel.
Additionally, we have received certain hard dollar benefits from Schwab to help us pay for certain start-up costs,
software purchases, and compliance assistance services. Clients should be aware of this conflict and take it into
consideration in making a decision whether to custody their assets with firms recommended by our firm.
However, CFO understands its duty for best execution and considers all factors in making recommendations to
clients. These additional services may be useful in servicing all CFO clients, and may not be used in connection
with any particular account that may have paid compensation to the firm providing such services. While CFO may
not always obtain the lowest commission rate, CFO believes the rate is reasonable in relation to the value of the
brokerage and research services provided.
Brokerage for client Referrals
We do not receive client referrals from broker-dealers and custodians with which we have an institutional
advisory arrangement. Also, we do not receive other benefits from a broker-dealer in exchange for client referrals.
Directed Brokerage
In very limited circumstances, and at our sole discretion, some clients may instruct our firm to use one or more
particular brokers for the transactions in their accounts. In the event that a client directs CFO to use a particular
broker/dealer, the firm may not be authorized to negotiate commissions and may not be able to obtain volume
discounts or best execution. In addition, under these circumstances a disparity in commission charges may exist
between the commissions charged to clients who direct the firm to use a particular broker/dealer and those that
don’t.
Trade Aggregation/Block Trading
We combine multiple orders for shares of the same securities purchased for advisory accounts we manage on a
discretionary basis whenever possible and where in the clients’ best interests (this practice is commonly referred
to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and
equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account,
but it is not based on account performance or the amount or structure of management fees. In rare instances,
such as partial fills or limited shares of thinly traded or illiquid stocks, it may be necessary to place block trades
for only small groups of clients over a period of time. Subject to our discretion regarding factual and market
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conditions, when we combine orders, each participating account pays an average price per share for all
transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or persons
associated with our firm may participate in block trading with your accounts; however, they will not be given
preferential treatment.
Review of Accounts - Item 13
Managed Account Reviews
CFO monitors client’s managed accounts on a continuous basis and recommends a formal review with the client
at least annually. Accounts are reviewed by Mr. Sivel, Mr. Hoffman and Mr. Luster, or the Associated Person
assigned to the account.
Additional reviews may be offered in certain circumstances. Triggering factors that may stimulate additional
reviews include, but are not limited to, changes in economic conditions, changes in the client’s financial situation
or investment objectives, or a client’s request. Clients are encouraged to notify our firm if changes occur in their
personal financial situation.
Clients will receive statements directly from their account custodian(s) on at least a quarterly basis. Additionally,
CFO will provide performance reports on an as needed basis.
Client Referrals and Other Compensation - Item 14
Custodial Benefits
As described in Item 12 above, we receive economic benefits from our custodial broker dealer in the form of
support products and services they make available to us and other independent investment advisors whose
clients maintain their accounts at these custodial broker dealers. The availability of custodial products and
services is not dependent upon or based on the specific investment advice we provide our clients, such as buying
or selling specific securities or specific types of securities for our clients. The products and services provided by
the custodial broker dealer, how they benefit us, and the related conflicts of interest are described above (see
Item 12 – Brokerage Practices).
Custody - Item 15
We do not have physical custody of any of your funds and/or securities. However, we are deemed to have custody
over your funds or securities because of the fee deduction authority granted by the client and in certain situations
where we accept standing letters of authorization from clients to transfer assets to third parties.
Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You
will receive account statements from the independent, qualified custodian(s) holding your funds and securities at
least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees
deducted from your account. You should carefully review account statements for accuracy. If you have questions
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regarding your account or if you did not receive a statement from your custodian, please contact Trevor Hoffman,
CCO, at (717) 893-5055.
Investment Discretion - Item 16
CFO offers management services on a discretionary basis. Clients must grant discretionary authority in the
advisory agreement. Discretionary authority extends to the types and amounts of securities to be bought and sold
in client accounts. Apart from the ability to instruct the custodian to withdraw advisory fees from client accounts,
CFO does not have the ability to withdraw funds or securities from client accounts.
If you wish, you may limit our discretionary authority by, for example, setting a limit on the type of securities that
can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. Please refer
to the “Advisory Business” section in this Brochure for more information on our discretionary management
services.
Voting Client Securities - Item 17
Generally, CFO does not vote proxies. It is the client's responsibility to vote proxies. Clients will receive proxy
materials directly from the custodian.
However, in limited circumstances, where CFO is required by a corporate trustee and has written authorization
to vote proxies, and in accordance with Rule 206(4)-6 under Rules of the Advisers Act, CFO will vote all proxies in
respect of securities in client accounts (Client Securities) over which the Company has voting discretion in a
manner consistent with the best interests of the Company’s clients. Trevor Hoffman, CCO is responsible for
ensuring adherence to the Company’s Proxy Voting Policy.
The Company generally will monitor proposed corporate actions and proxy issues regarding Client Securities, and
will take one or more of the following actions based on the best interests of the clients: (i) determine how to vote
the proxies; (ii) abstain; or (iii) follow the recommendations of an independent proxy voting service in voting the
proxies. In general, the Company will determine how to vote proxies based on its reasonable judgment of the
vote most likely to produce favorable financial results for its clients. Proxy votes generally will be cast in favor of
proposals that maintain or strengthen the shared interests of shareholders and management, increase
shareholder value, maintain or increase shareholder influence over the issuer's board of directors and
management and maintain or increase the rights of shareholders. Proxy votes generally will be cast against
proposals having the opposite effect. However, the Company will consider both sides of each proxy issue.
If the CCO determines that a material conflict of interest exists, the Company will:
•
•
•
disclose the existence and nature of the conflict to the client(s) owning the Client Securities, and seek
directions from the client or client’s designated representative on how to vote the proxies; or,
abstain from voting, particularly if there are conflicting client interests (for example, where client
accounts hold different Client Securities in a competitive merger situation); or,
follow the recommendations of an independent proxy voting service in voting the proxies.
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The full text of CFO’s Proxy Voting Policy is available upon client request. If you have questions regarding our
Proxy Voting Policies, please contact Trevor Hoffman, CCO, at (717) 893-5055.
Class Action Claims
CFO has engaged Chicago Clearing Corp (CCC) to assist its clients with the preparation, filing, acceptance and
processing of class action claims, the distributions of settlement payments, government filings, and other support
services. CCC will automatically file on all class action settlement claims for which our clients are eligible. If the
client is eligible, a settlement claim will be filed and the client can expect to receive a pro rata portion of any
proceeds once the court approves distribution of the settlement funds. For these services, CCC will receive a
contingency fee of 15% of the total reimbursement of assets it collects in consideration for its services. CFO will
not receive a share of client settlement claims and will not share in the fee received by CCC. Clients will be bound
by the releases included in any settlement for which CCC obtains settlement payments on their behalf. However,
clients will have the discretion to opt out of individual claims and can opt out of using CCC’s services altogether.
If you would like to opt out of CCC’s service, you should notify us in writing. Clients who opt out should note that
they have the sole responsibility to file class action settlement claims in the event of a class action lawsuit or
settlement.
Financial Information - Item 18
Our firm does not have any financial conditions or impairments that would prevent us from meeting our
contractual commitments to you. We do not take physical custody of client funds or securities, or serve as trustee
or signatory for client accounts, and, we do not require the prepayment of more than $1,200 in fees six or more
months in advance. Therefore, we are not required to include a financial statement with this brochure.
Requirements of State-Registered Advisers - Item 19
This section is not applicable because our firm is SEC registered.
Additional Information
Class Action Lawsuits
From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. CFO has
no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit.
It also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities
class action settlement or verdict. Furthermore, the firm has no obligation or responsibility to initiate litigation to
recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence
by corporate management of issuers whose securities are held by clients.
Collective Family Office, LLC
Form ADV Part 2A Brochure
Page 24
Where the firm receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting
securities owned by a client, it will forward all notices, proof of claim forms, and other materials, to the client.
Electronic mail is acceptable where appropriate, and the client has authorized contact in this manner.
Confidentiality
CFO views protecting its customers’ private information as a top priority and, pursuant to the requirements of
the Gramm-Leach-Bliley Act, the firm has instituted policies and procedures to ensure that customer information
is kept private and secure. CFO does not disclose any non-public personal information about its customers or
former customers to any non-affiliated third parties, except as permitted by law. In the course of servicing a client
account, CFO may share some information with its service providers, such as transfer agents, custodians, broker-
dealers, accountants, and lawyers.
CFO restricts internal access to nonpublic personal information about its clients to those employees who need to
know that information in order to provide products or services to the client. CFO maintains physical and
procedural safeguards that comply with state and federal standards to guard a client’s nonpublic personal
information and ensure its integrity and confidentiality. It is the firm’s policy never to sell information about
current or former customers or their accounts to anyone. It is also the firm’s policy not to share information unless
required to process a transaction, at the request of the client, or as required by law.
A copy of the firm’s privacy policy notice will be provided to each client prior to, or contemporaneously with, the
execution of the agreement for advisory services. Thereafter, the firm will deliver a copy of the current privacy
policy notice to its clients on an annual basis. If you have any questions on this policy, please contact Trevor
Hoffman, CCO, at (717) 893-5055 or at info@collectivefo.com.