Overview
- Headquarters
- Tampa, FL
- Average Client Assets
- $3.9 million
- SEC CRD Number
- 323135
Fee Structure
Primary Fee Schedule (CONCURRENT DISCLOSURE BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 2.00% |
| $1,000,001 | $2,000,000 | 1.70% |
| $2,000,001 | $3,000,000 | 1.60% |
| $3,000,001 | $5,000,000 | 1.50% |
| $5,000,001 | $7,500,000 | 1.40% |
| $7,500,001 | $10,000,000 | 1.30% |
| $10,000,001 | and above | 1.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $20,000 | 2.00% |
| $5 million | $83,000 | 1.66% |
| $10 million | $150,500 | 1.50% |
| $50 million | $550,500 | 1.10% |
| $100 million | $1,050,500 | 1.05% |
Clients
- HNW Share of Firm Assets
- 74.17%
- Total Client Accounts
- 41,105
- Discretionary Accounts
- 32,222
- Non-Discretionary Accounts
- 8,883
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection
Regulatory Filings
Additional Brochure: CONCURRENT DISCLOSURE BROCHURE (2026-03-24)
View Document Text
Concurrent Investment Advisors, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: March 24, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Concurrent Investment Advisors, LLC (“Concurrent” or the “Advisor”). If you have any questions
about the content of this Disclosure Brochure, please contact the Advisor at (813) 709-8800.
Concurrent is a registered investment advisor with U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information about Concurrent to assist you in determining whether to retain the
Advisor.
Additional information about Concurrent and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 323135.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of Concurrent.
Concurrent believes that communication and transparency are the foundation of its relationship with clients and
will continually strive to provide you with complete and accurate information at all times. Concurrent encourages
all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with
the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual updating
amendment on March 10, 2025.
• The Advisor has updated its phone number. (Cover page)
• The Advisor receives reimbursements from third party product providers and their affiliates (“Product
Sponsors”) in connection with financial services and platform services offered by Concurrent to our brokerage
and advisory customers, including mutual funds and exchange-traded funds. (Item 14)
• Concurrent has identified “Flourish Cash” as a potential alternative to money market and sweep accounts for
some Clients. Concurrent receives an annual fee of 0.10% of the value of the Client’s Flourish Cash account if
a Client participates in the cash management program from Flourish. (Items 4, 5 and 10)
• Concurrent makes available a mortgage‑broker platform called Flourish Lending. Flourish Lending is a broker,
not a lender, and provides access to unaffiliated third‑party lenders. Concurrent’s role is limited to informing
clients that Flourish Lending is available and, at a client’s request, assisting with administrative access. (Items
4, 5 and 10)
• Leveraged and inverse ETFs are subject to additional risks beyond those associated with traditional ETFs,
including compounding risk, volatility risk, and the potential for accelerated losses, particularly in volatile or
sideways markets. (Item 8)
•
• The Advisor utilizes a third-party data aggregation and reporting platform to assist in the collection and
organization of information related to certain alternative investments Alternative Investments. (Item 8)
Investment adviser representatives of Concurrent may receive an equity interest in Concurrent Asset
Management, LLC (“CAM”) based on their use of CAM as a sub-advisor for client accounts they service.
Because Concurrent and CAM are affiliated entities, this arrangement creates a conflict of interest. Concurrent
addresses this conflict by using CAM only when it determines that doing so is in the client’s best interest.
(Items 5 and 10)
• Concurrent may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants,
estate planners) to provide certain financial services necessary to meet the goals of its Clients. In some cases,
Concurrent is compensated by the non-advisory professional for the referrals. This presents a conflict of
interest. (Item 14)
• The Advisor has access to a variety of economic benefits, services, and products in connection with its use of
SEI and Goldman Sach’s investment adviser platforms. (Item 14)
• From time to time, the Advisor and/or its Advisory Persons enter into arrangements with third parties for lead
generation. Referral arrangements give rise to material conflicts of interest because the referring party has a
financial incentive to introduce new clients to the Advisor and its Advisory Persons. (Item 14)
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material
change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 323135. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (813) 709-8800.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ................................................................................................................................................. 1
Item 2 – Material Changes ....................................................................................................................................... 2
Item 3 – Table of Contents ....................................................................................................................................... 3
Item 4 – Advisory Services ...................................................................................................................................... 4
Item 5 – Fees and Compensation ........................................................................................................................... 8
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................... 14
Item 7 – Types of Clients ....................................................................................................................................... 14
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................ 14
Item 9 – Disciplinary Information .......................................................................................................................... 18
Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 18
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................... 19
Item 12 – Brokerage Practices .............................................................................................................................. 19
Item 13 – Review of Accounts ............................................................................................................................... 21
Item 14 – Client Referrals and Other Compensation ........................................................................................... 21
Item 15 – Custody .................................................................................................................................................. 25
Item 16 – Investment Discretion ............................................................................................................................ 25
Item 17 – Voting Client Securities ......................................................................................................................... 25
Item 18 – Financial Information ............................................................................................................................. 26
Privacy Policy ......................................................................................................................................................... 27
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 3
Item 4 – Advisory Services
A. Firm Information
Concurrent Investment Advisors, LLC (“Concurrent” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company
(“LLC”) under the laws of the State of Delaware. Concurrent was founded in November 2022. Concurrent is a
wholly owned subsidiary of Concurrent Partnership Holdings, LLC, a Delaware entity. The Founder of
Concurrent is Nathan M. Lenz.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by Concurrent. For information regarding this Disclosure Brochure, please contact Courtney T.
Haddad at (813) 709-8800.
Advisory Persons of Concurrent may have their trade names (aka “doing business as name” or “DBA name”) and
logos are used for marketing purposes and may appear on marketing materials and/or Client statements. The
Form ADV 2B – Brochure Supplements for our Advisory Persons identify any DBA name utilized.
B. Advisory Services Offered
Concurrent offers advisory services to different types of clients (each referred to as a “Client”), including
individuals, high net worth individuals, families, trusts, estates, businesses, and retirement plans.
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate conflicts
of interest. Concurrent’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Wealth Management Services
Concurrent may provide Clients with wealth management services, which generally includes a broad range of
comprehensive financial planning and consulting services in connection with discretionary management of
investment portfolios. These services may also be offered on a stand-alone basis and are described below.
Investment Management Services – Concurrent provides customized investment management solutions for its
Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary
or non-discretionary investment management and related advisory services. Concurrent works closely with each
Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to
design a portfolio strategy. Concurrent will then construct an investment portfolio, consisting of exchange-traded
funds (“ETFs”) and/or mutual funds to achieve the Client’s investment goals. The Advisor may also utilize
individual stocks, individual bonds, and other types of investments, as appropriate, to meet the needs of the
Client. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
Concurrent will select, recommend and/or retain mutual funds on a fund-by-fund basis. Due to specific custodial
and/or mutual fund company constraints, material tax consideration, and/or systematic investment plans,
Concurrent will select, recommend and/or retain a mutual fund share classes that do not have trading costs when
possible. These will in most cases be institutional share classes but, in some cases, may be share classes with
higher internal expense ratios than institutional share classes. Concurrent will seek to select the lowest cost
share class available that is in the best interest of each Client weighing the expected investment pattern,
expense ratios and potential ticket charges, and will ensure the selection aligns with the Client’s financial
objectives and stated investment guidelines.
Concurrent’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Concurrent will construct, implement, and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 4
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
Concurrent evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Concurrent may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Concurrent may recommend specific positions to increase sector or asset class weightings. The
Advisor may recommend employing cash positions as a possible hedge against the market movement.
Concurrent may recommend selling positions for reasons that include, but are not limited to, harvesting capital
gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or
overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet
Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
Held-Away Accounts – The Advisor provides an additional service for accounts not directly held at the Advisor's
custodian as outlined in Item 12 – Brokerage Practices, but where the Advisor does have discretion, and may
leverage an Order Management System, such as Pontera, to implement tax-efficient asset location and
opportunistic rebalancing strategies on behalf of the Client. These are primarily 401(k) accounts, HSA’s, and
other assets. The Advisor reviews the available investment options in these accounts, monitors them, and
rebalances and implements strategies in the same way we do other accounts, though using different tools as
necessary.
To provide management services through Pontera, Clients must grant Pontera electronic access to held‑away
accounts. Sharing or enabling access to account credentials with any third party, including Pontera, entails
cybersecurity and privacy risks. These may include, but are not limited to, the risk of unauthorized access to the
account if credentials are compromised, misused, or intercepted. The Advisor conducts due diligence of
Pontera as a service provider and seeks to understand its security controls. However, clients should carefully
consider these risks before authorizing us to manage accounts through Pontera. Clients should follow the plan
provider’s security guidelines for passwords and multifactor authentication, review all account statements and
activity confirmations regularly, and notify the plan provider, Pontera, and the Advisor immediately if they
suspect any unauthorized activity.
Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client
take a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts
(“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one
IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-
based account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under
The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as
applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if
the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under
any obligation to roll over a retirement account to an account managed by the Advisor.
Use of Independent Managers – Concurrent may utilize or recommend that Clients utilize one or more
unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a
portion of a Client’s investment portfolio, based on the Client’s needs and objectives. Under most circumstances,
Concurrent has the authority to hire Independent Managers or terminate an Independent Manager’s relationship
without specific Client consent. In certain instances, the Client may be required to enter into an investment
advisory agreement or an authorized addendum with the Independent Manager[s] that defines the terms in
which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight
and due diligence over each Independent Manager to ensure the strategy remains aligned with the Client’s
investment objectives and overall best interests. The Advisor will also assist the Client in the development of the
initial policy recommendations and managing the ongoing Client relationship. Upon request, the Client will be
provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes
the appropriate disclosures).
Use of CAM – Concurrent may utilize or recommend that Clients utilize Concurrent Asset Management, LLC
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 5
(“CAM”), an investment adviser registered with the SEC that is under common control with Concurrent, for all or
a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. CAM offers advisory
services to other investment advisers and their IARs, including stand-alone investment management services,
access to a CAM-configured turnkey asset management program (“TAMP”), and outsourced chief investment
officer (“OCIO”) services. CAM may invest all or a portion of a Client’s investment portfolio in one or more
private funds for which it serves as investment adviser.
Flourish Cash – Concurrent has identified “Flourish Cash” as a potential alternative to money market and
sweep accounts for some Clients. In many cases Flourish Cash offers higher yields and greater FDIC
insurance then the average cash account. Flourish Cash is an online cash management solution that seeks to
provide Clients with competitive annual percentage yield (“APY”) and elevated FDIC coverage for their deposits
placed at program banks. Flourish Cash is offered by Flourish Financial LLC, a registered broker-dealer and
FINRA member. Concurrent is not affiliated with Flourish or any of the program’s banks. Concurrent is not
acting in a discretionary manner when inviting Clients to use Flourish and only do so with Client consent.
Flourish Lending – Concurrent makes available a mortgage‑broker platform called Flourish Lending, a
technology‑enabled residential mortgage broker offered by SoraFinance, Inc. (NMLS #2355841), an affiliate of
Flourish. Flourish Lending is a broker, not a lender, and provides access to unaffiliated third‑party lenders
offering residential purchase mortgages, rate‑and‑term refinances, and cash‑out refinances through a digital
platform supported by licensed mortgage loan officers. Concurrent’s role is limited to informing clients that
Flourish Lending is available and, at a client’s request, assisting with administrative access (such as sending an
invitation or helping navigate the platform). We do not act as mortgage brokers, do not underwrite or approve
loans, do not select or recommend any particular lender on the platform, and are not parties to any mortgage
transaction. Clients interact directly with Flourish Lending and the selected lender and remain free to obtain
mortgage financing from any provider of their choosing.
Financial Planning Services
Concurrent will typically provide a variety of financial planning and consulting services to Clients either as a
component of wealth management services or pursuant to a written financial planning agreement. Services are
offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such
financial planning services involve preparing a formal financial plan or rendering a specific financial consultation
based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more
areas of need, including but not limited to, investment planning, retirement planning, education savings, cash
flow planning, charitable giving, estate planning, insurance needs, and other areas of a Client’s financial
situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence, or alter
retirement savings, establish education savings and/or charitable giving programs. Concurrent may also refer
Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. For certain
financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation,
observations, and recommendations. For project-based or ad-hoc engagements, the Advisor may not provide a
written summary. Project-based financial plans or consultations are typically completed within six (6) months of
contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for wealth management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 6
Retirement Plan & Participant Advisory Services
Concurrent provides both discretionary and non-discretionary retirement plan advisory services on behalf of the
retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory
services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan
Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally
include:
Investment Policy Statement (“IPS”) Design and Monitoring
Investment Monitoring and Oversight
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
•
•
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
Concurrent will assist the Plan’s fiduciaries by providing ongoing oversight of the Advisor Managed Account
(“AMA”) program and the evaluation of the designated investment manager (“DIM”). This includes reviewing the
DIM’s investment methodology, governance framework, and use of capital market assumptions to ensure
consistency with the stated objectives of the AMA service.
Additionally, Concurrent will select the underlying AMA Investment Lineup, and on a periodic basis will monitor
and evaluate the lineup. If an investment fails to meet the criteria standards, as determined by it’s score, it may
be placed on a “watchlist” or replaced by Concurrent. Concurrent will remain informed of any updates to the
DIM’s capital market assumptions, portfolio construction approach, or planned changes to model allocations
from quarter to quarter.
Concurrent will periodically sample participant-level allocations to confirm they are applied in a manner
consistent with the AMA's methodology and the participant's risk profile. This oversight process is intended to
help verify the implementation is consistent with the AMA’s participant-level design and does not represent a
guarantee of performance or investment outcomes. Findings from these reviews may be used to determine
whether continued use of the DIM remains appropriate under the Plan’s fiduciary framework.
Use of CAM – Concurrent may utilize or recommend that Clients utilize Concurrent Asset Management, LLC
(“CAM”), an investment adviser registered with the SEC that is under common control with Concurrent, for all or
a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. CAM offers advisory
services to other investment advisers and their IARs, including stand-alone investment management services,
access to a CAM-configured turnkey asset management program (“TAMP”), and outsourced chief investment
officer (“OCIO”) services.
In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of
Concurrent’s status as a fiduciary under ERISA when it provides “investment advice” (as that term is defined by
Department of Labor (“DOL”) regulations) or exercises discretion of Plan investments, the specific services to
be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
The Advisor and its investment adviser representatives (“IARs”), in the course of providing Plan advisory
services or otherwise, may establish a client relationship with one or more Plan participants or beneficiaries.
Such client relationships develop in various ways, including, without limitation:
• as a result of a decision by the Plan participant or beneficiary to purchase services from the Advisor not
involving the use of Plan assets;
• as part of an individual or family financial plan for which any specific recommendations concerning the
allocation of assets or investment recommendations relate to assets held outside of a Plan; or
through a rollover of an Individual Retirement Account ("IRA Rollover").
•
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 7
In providing these optional services, the Advisor may offer employers and employees information on other
financial and retirement products or services offered by the Advisor. If the Advisor is providing services to a
Plan, IARs may, when requested by a participant or beneficiary, arrange to provide services to that participant or
beneficiary through a separate agreement.
When a participant requests assistance with an IRA Rollover from his/her Plan to an account advised or
managed by us, we will have a conflict of interest if our fees are reasonably expected to be higher than those we
would otherwise receive in connection with the Plan advisory services. For participants invested in Plans which
we do not advise, we also have a conflict of interest given that we may not earn any compensation if they remain
invested in their current Plan. We will disclose relevant information about the applicable fees charged by us
prior to opening an IRA account. Any decision to affect the rollover or about what to do with the rollover assets
remain that of the Plan participant or beneficiary alone.
C. Client Account Management
Prior to engaging Concurrent to provide advisory services, each Client is required to enter into a written advisory
agreement with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – Concurrent, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Concurrent will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation, and tolerance for risk for each Client or unique
client goal.
• Portfolio Construction – Concurrent will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Wealth Management and Supervision – Concurrent will provide wealth management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Concurrent acts as portfolio manager for and sponsor of a wrap fee program, which is an investment program
where the client pays one stated fee that includes management fees, transaction costs, and certain other
administrative fees.
E. Assets Under Management
Effective December 31, 2025, the Advisor manages $12,803,029,449in Client assets on a discretionary basis
and $2,924,961,395on a non-discretionary basis. Clients may request more current information at any time by
contacting the Advisor.
In addition, as of February 28, 2026, the Advisor also has $14,397,375,088 in assets under advisement (“AUA”).
Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
advisory agreement with the Advisor.
A. Fees for Advisory Services
Wealth Management Services / Investment Management Services
Advisory fees for wealth or investment management services are paid quarterly, in advance of each calendar
quarter, pursuant to the terms of the advisory agreement. Investment advisory fees are based on the market value
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 8
of assets under management at the end of the prior quarter. Investment advisory fees generally range from 1.00%
to 2.00% annually based on several factors, including: the scope and complexity of the services to be provided;
the level of assets to be managed; and the overall relationship with the Advisor. Relationships with multiple
objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher
fee.
When providing fees based on a tiered fee schedule, the following schedule will be used.
Total Assets Under Management
$0 - $1,000,000
$1,000,001 - $2,000,000
$2,000,001 - $3,000,000
$3,000,001 – $5,000,000
$5,000,001 - $7,500,000
$7,500,001 - $10,000,000
$10,000,001 - Above
Maximum Annual Fee
2.00%
1.70%
1.60%
1.50%
1.40%
1.30%
1.00%
Fees are incremental. The schedule breakpoints and rates may be modified and are negotiable. When
Concurrent utilizes tiered billing, different rates are charged on different tranches of assets under Concurrent’s
management in accordance with the fee schedule above.
The advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the
first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Advisor typically offers a fixed
annual rate fee schedule (as detailed above). In certain circumstances, the Advisor may charge a fixed annual fixed
quarterly fee for its services. The Client’s fees will take into consideration the aggregate assets under management
with the Advisor across all accounts, unless otherwise agreed in writing. All securities held in accounts managed by
Concurrent will be independently valued by the Custodian. Concurrent will not have the authority or responsibility to
value portfolio securities.
Clients may make additions to and withdrawals from their account[s] at any time, subject to Concurrent’s right to
terminate an account. Additions may be in cash or securities provided that Concurrent reserves the right to liquidate
any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may withdraw
account assets on notice to Concurrent, subject to the usual and customary securities settlement procedures.
However, Concurrent designs its portfolios as long-term investments, and the withdrawal of assets may impair the
achievement of a Client’s investment objectives. Concurrent may consult with its Clients about the options and
ramifications of transferring securities. However, Clients are advised that when transferred securities are liquidated,
they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales
charge) and/or tax ramifications.
Custody, Platform and Admin (“CPA”) Fee – In addition to the advisory fee described above, Concurrent imposes a
Custody, Platform and Admin fee that is separate and distinct from the Client’s advisory fee. The CPA fee covers
certain platform-related expenses relating to Client accounts, including portfolio accounting, billing, and technology
services. The CPA fee is typically accessed at 0.05% annually and billed quarterly, in advance of each calendar
quarter. The CPA fee in the first quarter of service is prorated from the inception date of the account[s] to the end of
the first quarter. The CPA fee may be reduced or waived at Concurrent’s or investment advisor representative’s
discretion. Should the investment advisor representative assigned to the Client’s account[s] reduce or waive the
Client’s CPA fee, the representative will receive a lower payout percentage from the Client’s account[s]. This creates
a conflict of interest in that the representative has an incentive to not reduce or waive the Client’s CPA fee.
Held Away Accounts – The fee on held-away accounts will be assessed and billed quarterly. The exact amount
charged is determined by the daily average over the course of the quarter. The current exception for this is directly-
managed held-away accounts, which are determined by the account value at the end of the quarter. In either case, if
the Advisor only manages your assets for part of a quarter, the charge will be prorated. The advisory fee is a
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 9
blended fee and is calculated by assessing the advisory fee as outlined above and applying the fee to the daily
average of the account value or the account value as of the last day of the previous quarter (per the paragraph
above), resulting in a combined weighted fee.
Use of Independent Managers – As noted in Item 4, the Advisor may implement all or a portion of a Client’s
investment portfolio utilizing one or more Independent Managers. Pursuant to some arrangements, Concurrent will
be compensated via a fee share from the advisors to which it directs those clients. This creates a conflict of interest
in that Concurrent has an incentive to direct clients to the Independent Managers that provide Concurrent with a
larger fee split. Pursuant to other arrangements, the fees of the Independent Manager(s) are in addition to
Concurrent’s standard fees. The relationship between Concurrent and each Independent Manager will be disclosed
in each contract between the parties. The total fees charged to a client will not exceed any limit imposed by any
regulatory agency.
Concurrent will always act in the best interests of the client, including when determining which Independent
Manager to recommend to clients. Independent Managers typically do not offer any fee discounts but may have a
breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an
Independent Manager. If the Client is required to authorize and enter into an investment advisory agreement with an
Independent Manager, then the terms of such fee arrangements are included in the Independent Manager’s
disclosure brochure and applicable contract[s] with the Independent Manager. If not, the fees of any Independent
Manager that are in addition to Concurrent’s fees will be disclosed to the Client separately.
Use of CAM – As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio
utilizing its affiliate, CAM. When CAM acts as a sub-adviser or otherwise provides services to the Advisor, CAM
receives compensation for its investment management services. In addition, IARs of the Advisor may receive an
equity interest in Concurrent Asset Management, LLC (“CAM”) based on their use of CAM as a sub-advisor for client
accounts they service. There is a conflict of interest due to the affiliation between the Advisor and CAM, because the
Advisor is incentivized to utilize CAM as a sub-adviser with respect to its Clients rather than utilizing one or more
Independent Managers in order to generate additional revenue for its owners through CAM as well as to generate an
equity interest for Advisor IARs. CAM will earn the investment advisor fees as described in its Form ADV. CAM may
invest all or a portion of a Client’s investment portfolio in one or more private funds for which it serves as investment
adviser. In such a case, the Client will pay advisory fees to CAM at the private fund level as well as for CAM’s sub-
advisory services, in addition to the advisory fees paid to the Advisor otherwise described herein. The Advisor will
only utilize CAM when it is in the best interest of the Client to do so.
Flourish Cash – Concurrent receives an annual fee of 0.10% of the value of the Client’s Flourish Cash account if a
Client participates in the cash management program from Flourish. This fee is deducted from the Client’s account in
advance. This fee is not negotiable. This fee is separate from Concurrent’s wealth management fee.
Flourish Lending – Neither Concurrent nor its Advisory Persons receive referral fees, revenue sharing,
volume‑based payments, or any other compensation from Flourish Lending or from lenders in connection with
clients’ use of the platform. Flourish Lending receives customary mortgage‑broker compensation from participating
lenders, but this is paid to Flourish Lending and not to Concurrent. Flourish Lending is separate from other Flourish
services (such as Flourish Cash), and clients are not required to use any Flourish service to access another.
Financial Planning Services
Financial planning fees are offered as both ongoing and project-based engagements. Project-based
engagements are billed at an hourly rate of up to $500 per hour or as a fixed engagement fee ranging up to
$25,000. An estimate for total hours and/or costs will be determined prior to engaging for project-based financial
planning services. Ongoing financial planning engagements are charged a fixed annual fee of up to $200,000 per
year.
Fees may be negotiable based on the nature and complexity of the services to be provided and the overall
relationship with the Advisor.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 10
Retirement Plan & Participant Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee ranging from 0.25% to 1.75%
based on the size of the Plan and scope of services to be provided. Fees for these services may be billed in
advance or arrears and at varying frequencies. The billing methodology will be agreed upon within the retirement
plan advisory agreement. Fees may be negotiable depending on the size and complexity of the Plan.
Depending upon the capabilities and requirements of the Plan’s recordkeeper or custodian, the Advisor may
collect its Fees in arrears or in advance. Typically, Sponsors instruct the Plan’s recordkeeper or custodian to
automatically deduct the Fees from the Plan account; however, in some cases a Sponsor may request that the
Advisor send invoices directly to the Sponsor or recordkeeper/custodian.
In some cases, Plan Sponsors may elect to engage the Advisor to manage asset allocation model portfolios for Plan
participants (“Managed Models”) and the Managed Model Fees will be separately charged to Plan participants who
elect to invest in one or more Managed Models. The additional Managed Model Fees present a conflict of interest
when our IARs meet with Plan participants as the representative and our firm will earn more compensation if a Plan
participant elects to invest in any Managed Models. To mitigate the potential for a conflict of interest, Plan participants
are provided information concerning the additional Managed Model Fees in accordance with DOL Reg. 404a-5, and
our policies and procedures require representatives to provide only “investment education” (as that term is defined
under DOL’s Interpretative Bulleting 1996-1) and refrain from recommending Plan participants invest in a Managed
Model.
Sponsors receiving retirement plan advisory services may pay more than or less than a client might otherwise pay if
purchasing the retirement plan advisory services separately or through another service provider. There are several
factors that determine whether the costs would be more or less, including, but not limited to, the size of the Plan, the
specific investments made by the Plan, the number of or locations of Plan participants, services offered by another
service provider, and the actual costs of retirement plan advisory services purchased elsewhere. In light of the
specific retirement plan advisory services offered by the Advisor, the Fees charged may be more or less than those of
other similar service providers.
In determining the value of the Account for purposes of calculating any asset-based Fees, the Advisor will rely
upon the valuation of assets provided by Sponsor or the Plan’s custodian or recordkeeper without independent
verification.
Unless agreed otherwise, no adjustments or refunds will be made in respect of any period for (i) appreciation or
depreciation in the value of the Plan account during that period or (ii) any partial withdrawal of assets from the
account during that period. If the Agreement is terminated by the Advisor or by Sponsor, the Advisor will refund
certain Fees to Sponsor to the extent provided in Section 8 of the Agreement. Unless agreed otherwise, all
Fees shall be based on the total value of the assets in the account without regard to any debit balance.
All Fees paid to the Advisor for retirement plan advisory services are separate and distinct from the fees and
expenses charged by mutual funds, variable annuities and exchange-traded funds to their shareholders. These
fees and expenses are described in each investment's prospectus. These fees will generally include a
management fee, other expenses, and possible distribution fees. If the investment also imposes sales charges,
a client may pay an initial or deferred sales charge. The retirement plan advisory services we provide may,
among other things, assist the client in determining which investments are most appropriate to each client's
financial condition and objectives and to provide other administrative assistance as selected by the client.
Accordingly, the client should review both the fees charged by the funds, the fund manager, the Plan's other
service providers and the fees charged by us to fully understand the total amount of fees to be paid by the client
and to evaluate the Retirement Plan Services being provided.
In the event the Advisor receives any third-party payments or subsidies in connection with the retirement plan
advisory services, the Advisor will disclose such fees to Sponsors in accordance with ERISA and Department of
Labor regulations.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 11
Fees for individualized advisory services provided to Plan participants or beneficiaries are charged in accordance
with the description of wealth or investment management services, as applicable, above.
B. Fee Billing
Wealth Management Services / Investment Management Services
Advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the
Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] in advance of each quarter. The amount due is calculated by applying the quarterly rate
(annual rate divided by 4) to the market value of assets under management as of the end of the prior quarter.
Clients will be provided with a statement, generally quarterly, from the Custodian reflecting the deduction of the
advisory fee. Clients provide written authorization permitting advisory fees to be deducted by Concurrent to be paid
directly from their account[s] held by the Custodian as part of the advisory agreement and separate account forms
provided by the Custodian.
Use of Independent Managers – For Client accounts implemented through an Independent Manager, the Client’s
overall fees may include Concurrent’s investment advisory fee (as noted above) plus investment advisory fees
and/or platform fees charged by the Independent Manager[s], as applicable. In certain instances, the
Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all
fees from the Client’s account[s]. In other instances, the Advisor and the Independent Manager will each assume
the responsibility for calculating and deducting their respective fees from the Client’s account[s].
Financial Planning Services
Fees for project-based financial planning engagements may be invoiced up to fifty percent (50%) of the expected
total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the
agreed upon deliverable[s].
Fees for ongoing financial planning engagements may be invoiced on a monthly, quarterly or annual basis pursuant
to the terms of the financial planning agreement.
Retirement Plan & Participant Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the
Plan, depending on the terms of the retirement plan advisory agreement.
Fees for Managed Models, if applicable, will be deducted from Plan participants individual Plan accounts or, in
some cases, deducted directly from the returns of the Managed Models.
Fees for all other individualized advisory services provided to Plan participants or beneficiaries are deducted or
invoiced in accordance with the description of wealth or investment management services, as applicable,
above.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Concurrent, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian, as applicable. The Advisor’s recommended Custodian does not
charge securities transaction fees for ETF and equity trades in a Client’s account, provided that the account
meets the terms and conditions of the Custodian’s brokerage requirements. However, the Custodian typically
charges for mutual funds and other types of investments. The fees charged by Concurrent are separate and
distinct from these custody and execution fees.
In addition, all fees paid to Concurrent for investment advisory services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees
for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and
a possible distribution fee. A Client may be able to invest in these products directly, without the services of
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 12
Concurrent, but would not receive the services provided by Concurrent which are designed, among other things,
to assist the Client in determining which products or services are most appropriate for each Client’s financial
situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees
charged by Concurrent to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage
Practices for additional information.
This brochure describes Concurrent’s non-wrap fee advisory services; clients utilizing Concurrent’s wrap fee
portfolio management should see the separate Wrap Fee Program Brochure for additional details regarding third
party fees. Client accounts not participating in the wrap fee program are responsible for the payment of all third-
party fees (i.e., custodian fees, commissions, brokerage fees, mutual fund fees, transaction fees, etc.). Those
fees are separate and distinct from the fees and expenses charged by Concurrent. Please see Item 12 of this
brochure regarding broker/custodian.
D. Advance Payment of Fees and Termination
Wealth Management Services / Investment Management Services
Concurrent is compensated for its advisory services in advance of the quarter in which services are rendered.
Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to
the other party. The Client may also terminate the advisory agreement within five (5) business days of signing the
Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide
advisory services rendered to the point of termination, and such fees will be due and payable by the Client. Upon
termination, the Advisor will refund any unearned, prepaid fees from the effective date of termination through the
end of the quarter. The Client’s advisory agreement with the Advisor is non-transferable without the Client’s prior
consent.
Held-Away Accounts – Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee
based on the amount of time remaining in the billing period. An account may be terminated with written notice at
least fifteen (15) calendar days in advance. Since fees are paid in arrears, no rebate will be needed upon
termination of the account.
Use of Independent Managers – In the event that the Advisor has determined that an Independent Manager is no
longer in the Client’s best interest or a Client should wish to terminate their relationship with the Independent
Manager, the terms for the termination will be set forth in the respective agreements between the Client or the
Advisor and the Independent Manager. Concurrent will assist the Client with the termination and transition as
appropriate.
Financial Planning Services
Concurrent may be partially compensated for its financial planning services in advance. Either party may terminate
the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may
also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at
no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered
to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be
billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee
engagement, the percentage of the engagement scope completed by the Advisor. The Advisor will refund any
unearned, prepaid planning fees from the effective date of termination to the end of the quarter. The Client’s
financial planning agreement with the Advisor is non-transferable without the Client’s prior consent.
Retirement Plan & Participant Advisory Services
Concurrent is compensated for its services at the beginning of the quarter before advisory services are
rendered. Either party may request to terminate a retirement plan advisory agreement, at any time, by
providing advance written notice to the other party. The Client shall be responsible for advisory fees up to and
including the effective date of termination. Upon termination, the Advisor will refund any unearned, prepaid
advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan
advisory agreement with the Advisor is non-transferable without the Client’s prior consent.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 13
Fees for individualized advisory services provided to Plan participants or beneficiaries are paid in accordance
with the description of wealth or investment management services, as applicable, above.
E. Compensation for Sales of Securities
Concurrent does not buy or sell securities to earn commissions and does not receive any compensation for
securities transactions in any Client account, other than the investment advisory fees noted above.
Certain Advisory Persons are also a Registered Representatives of Purshe Kaplan Sterling Investments, Inc.
(“PKS”). PKS is a registered broker-dealer (CRD# 35747), member FINRA, SIPC. In an Advisory Person’s
separate capacity as a Registered Representative of PKS, the Advisory Person will implement securities
transactions under PKS and not through Concurrent. In such instances, the Advisory Person will receive
commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for
the sale of investment company products. Compensation earned by the Advisory Person in one’s capacity as a
Registered Representative is separate and in addition to the Advisor’s fees. This practice presents a conflict of
interest because the Advisory Person who is a Registered Representative has an incentive to effect securities
transactions for the purpose of generating commissions rather than solely based on the Client. Clients are not
obligated to implement any recommendation provided by the Advisor nor Advisory Persons. Neither the Advisor
nor Advisory Persons will earn ongoing investment advisory fees in connection with any products or services
implemented in the Advisory Person’s separate capacity as a Registered Representative. Please see Item 10
below.
Advisory Persons are also licensed as independent insurance professionals. As an independent insurance
professional, an Advisory Person may earn commission-based compensation for selling insurance products,
including insurance products sold to Clients. Insurance commissions earned by Advisory Persons are separate
and in addition to our advisory fees. This practice presents a conflict of interest as the Advisory Person may have
an incentive to recommend insurance products to a Client for the purpose of generating commissions rather
than solely based on the Client’s needs. Clients are under no obligation, contractually or otherwise, to purchase
insurance products through any Advisory Person affiliated with the Advisor.
Item 6 – Performance-Based Fees and Side-By-Side Management
Concurrent does not charge performance-based fees for its wealth management services. The fees charged by
Concurrent are as described in Item 5 above and are not based upon the capital appreciation of the funds or
securities held by any Client.
Item 7 – Types of Clients
Concurrent offers advisory services to individuals, high net worth individuals, families, trusts, estates,
businesses, and retirement plans. Concurrent generally does not impose a minimum relationship size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Concurrent employs various analysis methods in developing investment strategies for its Clients. Research and
analysis from Concurrent are derived from numerous sources, including financial media companies, third-party
research materials, professional data subscriptions, Internet sources, and review of company activities, including
annual reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
generally consists of ratios and trends that may indicate the overall strength and financial viability of the entity
being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong
investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 14
potential investment, it does not guarantee that the investment will increase in value. Assets meeting the
investment criteria utilized in the fundamental analysis may lose value and may have negative investment
performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations
are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of
Accounts.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns
and trends, which may be based on investor sentiment rather than the fundamentals of the company. The
primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the
future. Even if the trend will eventually reoccur, there is no guarantee that Concurrent will be able to predict such
a reoccurrence accurately.
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 that is being recommended. The risks with cyclical analysis are similar to those of
technical analysis.
Charting analysis utilizes various market indicators as investment selection criteria. These criteria are generally
pricing trends that may indicate movement in the markets. Assets are deemed suitable if they meet certain criteria to
indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps
the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value.
Assets meeting the investment criteria utilized in the technical and charting analysis may lose value and may have
negative investment performance. The Advisor monitors these market indicators to determine if adjustments to
strategic allocations are appropriate.
B. Investment Strategies
As noted above, Concurrent generally employs a long-term investment strategy for its Clients, as consistent with
their financial goals. Concurrent will typically hold all or a portion of a security for more than a year but may hold
for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times,
Concurrent may also buy and sell positions that are more short-term in nature, depending on the goals of the
Client and/or the fundamentals of the security, sector, or asset class.
C. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Concurrent will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals. Please see this Item 8.C. for risks associated with the Advisor’s
investment strategies as well as general risks of investing.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis
may lose value and may have negative investment performance. The Advisor monitors these economic
indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk, and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the
Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals,
or other factors that may affect this analysis.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 15
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Following are some of the risks associated with the Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading
risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large
bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and
may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF
purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a
short time later.
Leveraged and Inverse ETFs
Certain ETFs seek to provide investment results that are a multiple (e.g., 2x or 3x) or the inverse (or inverse
multiple) of the performance of an underlying index or benchmark. These products are typically designed to
achieve their stated objectives on a daily basis and, as a result, their performance over longer periods of time
may differ significantly from the performance (or inverse performance) of the underlying index for the same
period. Leveraged and inverse ETFs are subject to additional risks beyond those associated with traditional
ETFs, including compounding risk, volatility risk, and the potential for accelerated losses, particularly in volatile
or sideways markets. Due to the effects of daily rebalancing, these ETFs may experience increased tracking
error and may lose value even when the underlying index’s long-term performance is favorable.
Leveraged and inverse ETFs may be more volatile, have higher expense ratios, and may be less tax-efficient
than non-leveraged ETFs. They may not be appropriate for all investors and are generally intended for short-
term trading or tactical purposes, rather than long-term investment strategies. Clients should be aware that
losses may exceed those of traditional ETFs tracking the same underlying index.
Bond Risks
Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond
prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bonds time to maturity, and
the coupon rate of the bond. (2) reinvestment risk, i.e., the risk that any profit gained must be reinvested at a
lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation
increase at a rate that exceeds the income investment thereby decreasing the investors rate of return, (4) credit
default risk, i.e., the risk associated with purchasing a debt instrument which includes the possibility of the
company defaulting on its repayment obligation, (5) rating downgrades, i.e., the risk associated with a rating
agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to
repay its debt and (6) Liquidity Risks, i.e., the risk that a bond may not be sold as quickly as there is no readily
available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily; therefore, a mutual fund purchased at one point in the day will typically have the
same price as a mutual fund purchased later that same day.
Options Contracts
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.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 16
This leverage can compound gains or losses.
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities
pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin
call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory
liquidation of the pledged securities to compensate for the decline in value.
Structured Notes
Structured notes are securities issued by financial institutions whose returns are based on, among other things,
equity indexes, a single equity security, a basket of equity securities, interest rates, commodities, and/or foreign
currencies. Thus, returns are “linked” to the performance of a reference asset or index. Structured notes have
specific risks that include market risk, an issuance price that is likely higher than the fair value of the note on the
date of the issuance, liquidity risk, credit risk, call risk, and a complicated payoff structure.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An
investor could lose all or a portion of their investment. Such investments often have concentrated positions and
investments that may carry higher risks. The success of each alternative investment will depend heavily upon the
efforts of its manager. When the investment objectives and strategies of a manager are out of favor in the market or a
manager makes unsuccessful investment decisions, the alternative investments managed by the manager may lose
money. A client account may lose a substantial percentage of its value if the investment objectives and strategies of
many or most of the alternative investments in which it is invested are out of favor at the same time, or many or most
of the managers make unsuccessful investment decisions at the same time.
Alternative Investments (Third-Party Data Platform)
The Advisor utilizes a third-party data aggregation and reporting platform to assist in the collection and organization of
information related to certain alternative investments. These investments may include private funds, private equity,
private credit, hedge funds, real estate investments, or other illiquid or non-publicly traded assets. Information
provided through this platform is obtained from third-party sources, including investment sponsors, managers,
custodians, or client-provided documentation. Valuations for alternative investments are generally provided by the
investment sponsor or manager and may be based on estimates, unaudited financial statements, or methodologies
that differ from those used for publicly traded securities. As a result, valuations may be subject to revision, may not
reflect current market conditions, and may not be readily realizable. The Advisor does not independently verify the
accuracy, completeness, or timeliness of such information and relies on data as reported by these third parties.
While the Advisor may use this platform to facilitate reporting or monitoring consistent with the scope of services
agreed upon with the client, the use of this platform does not eliminate the inherent risks associated with alternative
investments, including valuation uncertainty, limited liquidity, and delayed or incomplete reporting.
Securities-Backed Loans and Lines of Credit
Securities-backed loans and lines of credit carry a number of risks, including but not limited to the risk of a market
downturn, tax implications if collateralized securities are liquidated, and an increase in interest rates. A decline in
the market value of collateralized securities held in the account[s] at the Custodian, may result in a reduction in the
draw amount of the Client’s line of credit, a demand from the Lending Program that the Client deposit additional
funds or securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s collateral
account[s].
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 17
Item 9 – Disciplinary Information
There are no legal, regulatory, or disciplinary events involving Concurrent or its management persons.
Concurrent values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite
due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its
Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov
by searching with the Advisor’s firm name or CRD# 323135.
Item 10 – Other Financial Industry Activities and Affiliations
Concurrent Asset Management, LLC
The Advisor is under common control with Concurrent Asset Management, LLC, an investment adviser
registered with the SEC that offers advisory services to other investment advisers and their IARs, including
stand-alone investment management services, access to a CAM-configured TAMP, and OCIO services. CAM
will serve as a sub-advisor for the Advisor with respect to certain of its Clients pursuant to a Sub-Advisory
Agreement. When CAM acts as a sub-adviser or otherwise provides services to the Advisor, CAM receives
compensation for its investment management services. In addition, IARs of the Advisor may receive an equity
interest when CAM is used as a sub-advisor with respect to Advisor clients they service. There is a conflict of
interest due to the affiliation between the Advisor and CAM, because the Advisor is incentivized to utilize CAM
as a sub-adviser with respect to its Clients rather than utilizing one or more unaffiliated investment advisers in
order to generate additional revenue for its owners through CAM as well as to generate an equity interest for
Advisor IARs. CAM will earn the investment advisor fees as described in its Form ADV. The Advisor will only
utilize CAM when it is in the best interest of the Client to do so.
Broker-Dealer Affiliation
As noted in Item 5, certain Advisory Persons are also Registered Representatives of PKS. In one’s separate
capacity as a Registered Representative, an Advisory Person will receive commissions for the implementation of
recommendations for commissionable transactions. Clients are not obligated to implement any recommendation
provided by the Advisory Person. Neither the Advisor nor its Advisory Persons will earn ongoing investment
advisory fees in connection with any services implemented in an Advisory Person’s separate capacity as a
Registered Representative.
Insurance Agency Affiliations
As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. The Advisor is affiliated
with Concurrent Insurance Solutions (“CIS”), a licensed insurance agency, through common control and
ownership. Therefore, associates providing investment advice on behalf of our firm may be licensed as insurance
agents. These associates will earn a commission-based compensation for selling insurance products, including
insurance products they sell to you. Insurance commissions earned by these associates are separate from our
advisory fees. Please see the “Item 5 Fees and Compensation” section in this brochure for more information on
the compensation received by insurance agents who are affiliated with our firm.”
Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more
Independent Managers. Concurrent will be compensated via a fee share from the advisors to which it directs those
clients. This relationship will be disclosed in each contract between Concurrent and each Independent Manager. The
fees shared will not exceed any limit imposed by any regulatory agency. This creates a conflict of interest in that
Concurrent has an incentive to direct clients to the Independent Managers that provide Concurrent with a larger fee
split. Concurrent will always act in the best interests of the client, including when determining which Independent
Manager to recommend to clients. Concurrent will ensure that all recommended advisors or managers are licensed or
notice filed in the states in which Concurrent is recommending them to clients.
Flourish
As stated above, Concurrent has made available Flourish Cash and Flourish Lending. Concurrent is not
affiliated with Flourish or any of the program’s banks or lenders. Concurrent is not acting in a discretionary
manner when inviting Clients to use Flourish and only do so with Client consent. Clients are under no obligation
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 18
to use Flourish Cash or Flourish Lending.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Concurrent has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to
each Client. This Code applies to all persons associated with Concurrent (“Supervised Persons”). The Code was
developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the
Client. Concurrent and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client.
It is the obligation of Concurrent’s Supervised Persons to adhere not only to the specific provisions of the Code,
but also to the general principles that guide the Code. The Code covers a range of topics that address employee
ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (813) 709-8800.
B. Personal Trading with Material Interest
Concurrent allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Concurrent does not act as a principal in any transactions. In addition, the
Advisor does not act as the general partner of a fund or advise an investment company. Concurrent does not
have a material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Concurrent allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities.
The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by Concurrent requiring reporting of personal securities trades by its Supervised Persons for review by
the Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect
the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Concurrent allows Supervised Persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded
afterward. At no time will Concurrent, or any Supervised Person of Concurrent, transact in any security to
the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
In most cases, Concurrent does not have discretionary authority to select the broker-dealer/custodian for
custody and execution services. The Client will engage the custodian (herein the "Custodian") to safeguard
Client assets and typically authorizes Concurrent to direct trades to the Custodian as agreed upon in the
investment advisory agreement. Further, Concurrent does not have the discretionary authority to negotiate
commissions on behalf of Clients on a trade-by-trade basis. In some limited cases, the Client authorizes
Concurrent to execute certain fixed income trades with a broker-dealer other than the Custodian (i.e., trade-
away) in its discretion.
Where Concurrent does not exercise discretion over the selection of the Custodian, it may recommend the
Custodian[s] to Clients for custody and execution services. Clients are not obligated to use the Custodian
recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 19
recommended by Concurrent. However, the Advisor may be limited in the services it can provide if the
recommended Custodian is not engaged. Concurrent may recommend the Custodian based on criteria such as,
but not limited to, the reasonableness of commissions charged to the Client, services made available to the
Client, and its reputation and/or the location of the Custodian’s offices. As Advisory Persons are also Registered
Representatives of PKS, the Advisor may be limited in using other broker-dealers/custodians as PKS must
approve the use of any outside broker-dealer/custodian.
Concurrent will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody
Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial Services
LLC, and Fidelity Brokerage Services LLC (collectively “Fidelity”). Concurrent may also recommend Charles
Schwab & Co., Inc. (“Schwab”), Inspire Financial Trust, LLC (“Inspire”), Goldman Sachs Custody Solutions
(“Goldman Sachs”), SEI Investments Management Corp (“SEI”) and TIAA (for employer-sponsored retirement
plans). All are collectively referred to herein as the “Custodians”. The Custodians will serve as the Client’s
“qualified custodian”. Concurrent may also recommend Falcon Square to act as the Client’s broker-dealer only.
Concurrent maintains institutional relationships with the Custodians, whereby the Advisor receives certain
economic benefits.
Concurrent has established the institutional relationships with the Custodians to assist the Advisor in managing
Client accounts. Access to the respective Custodian platforms are provided at no charge to the Advisor. The
Custodian platforms include brokerage, custody, administrative support, recordkeeping, technology, and related
services designed to support registered investment advisors like Concurrent. These services are intended to serve
the best interests of the Advisor’s Clients.
The Custodians may charge brokerage commissions (securities transaction fees) for effecting certain securities
transactions. The Custodians enable the Advisor to obtain certain no-load mutual funds without securities
transaction fees and other no-load funds at nominal transaction charges. The Custodians’ commission rates are
generally considered discounted from customary retail commission rates. However, the commissions and
transaction fees charged by the Custodians may be higher or lower than those charged by other custodians and
broker-dealers. Please see Item 14 below for additional information.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. Concurrent does not participate in soft dollar programs sponsored or offered by any
broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodians.
Please see Item 14 below.
2. Brokerage Referrals - Concurrent does not receive any compensation from any third party in connection with
the recommendation for establishing an account.
3. Directed Brokerage – Most Clients are serviced on a “directed brokerage basis,” where Concurrent will
place trades within the established account[s] at the Custodian designated by the Client. Further, all Client
accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions
(i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts
(i.e., purchase of a security into one Client account from another Client’s account[s]). Concurrent will not be
obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest
available transaction costs. These costs are determined by the Custodian.
A Client may pay a commission that is higher than another qualified custodian might charge to effect the same
transaction. The Advisor has determined in good faith that the commissions charged by the Custodian are
reasonable in relation to the value of the brokerage and research services received.
As noted above, in some limited cases, the Client authorizes Concurrent to execute certain fixed income trades
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 20
with a broker-dealer other than the Custodian (i.e., trade-away) in its discretion. When given discretion to select
the brokerage firm that will execute orders in client accounts, the Advisor seeks “best execution” for client
trades.
In seeking best execution, the determinative factor is not necessarily the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of the Custodian’s
services, including the value of research provided, execution capability, commission rates, and responsiveness.
Accordingly, although the Advisor will seek competitive rates, to the benefit of all Clients, it may not necessarily
obtain the lowest possible commission rates for specific Client account transactions. Although the investment
research products and services that may be obtained by the Advisor will generally be used to service all of the
Advisor’s Clients, they may not equally benefit all Clients. Please also see Item 14.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian. Concurrent will execute its transactions
through the Custodian as authorized by the Client. Concurrent may aggregate orders in a block trade or trades
when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same
trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased
or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-
allocation or other written statement. This must be done in a way that does not consistently advantage or
disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of Concurrent
and periodically by the CCO. Formal reviews are generally conducted at least annually or more frequently
depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a
result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large
deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Concurrent if changes occur
in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional
reviews may be triggered by material market, economic, or political events.
C. Review Reports
The Client will receive brokerage statements at least quarterly from the Custodian. These brokerage statements
are sent directly from the Custodian to the Client. The Client may also establish electronic access to the
Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions, and fees relating to the Client’s account[s]. The Advisor may
also provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Concurrent
Concurrent may receive compensated or non-compensated referrals of new Clients from various third-parties.
Likewise, Concurrent may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys,
accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. In
some cases, Concurrent is compensated by the non-advisory professional for the referrals. This presents a
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
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conflict of interest, as it provides an incentive to recommend professionals based on the compensation to be
received, rather than the Client’s particular need. Concurrent always acts in the best interest of Clients,
including when recommending non-advisory professionals. No client is under any obligation to engage a non-
advisory professional recommended by Concurrent. Clients may receive similar services from other
professionals on more favorable terms.
As described in Item 12 above, Concurrent maintains institutional relationships with the Custodians, whereby
the Advisor receives certain economic benefits. Access to the respective Custodian platforms are provided at no
charge to the Advisor. All Custodian platforms include brokerage, custody, administrative support,
recordkeeping, technology, and related services designed to support registered investment advisors like
Concurrent. The terms and availability of these benefits vary by Custodian and may include investment-related
research, pricing information and market data, software and other technology that provide access to client
account data, compliance and/or practice management-related publications, discounted or gratis consulting
services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social
events, marketing support, computer hardware and/or software and/or other products used by Concurrent in its
investment advisory business operations. These services generally help Concurrent conduct its advisory
business, but each specific benefit does not necessarily benefit each client. Some custodians may be more
expensive than other custodial options available. Clients are encouraged to review and compare custodial fees,
transaction costs, and service offerings and to ask questions regarding any differences prior to selecting or
approving a custodian.
In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first.
Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of
interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does
not furnish similar software, systems support, or services
Participation in Institutional Advisor Platform (Fidelity)
Concurrent has established an institutional relationship with Fidelity to assist the Advisor in managing Client
account[s]. As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the
Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from
independent research companies. The Advisor may also receive additional services and support from Fidelity. As a
result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or
expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter
into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s
Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above.
The Advisor receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Fidelity. The software and related systems support may
benefit the Advisor, but not its Clients directly. In addition, Fidelity has provided the Advisor with financial support
in the launch of the Advisor and reimbursements for various third-party service providers.
Participation in Institutional Advisor Platform (Schwab)
Concurrent has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit,
a division of Schwab dedicated to serving independent advisory firms like Concurrent. As a registered investment
advisor participating on the Schwab Advisor Services platform, Concurrent receives access to software and
related support without cost because the Advisor renders investment management services to Clients that
maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but
not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors
at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic
benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's
recommendation of this custodian over one that does not furnish similar software, systems support, or services.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
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Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be
able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds
and other investments without having to adhere to investment minimums that might be required if the Client were
to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for
Client accounts, the ability to deduct advisory fees, trading tools, and back-office support services as part of its
relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for
its Clients but may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to
Concurrent that may not benefit the Client, including: educational conferences and events, financial start-up
support, consulting services and discounts for various service providers. Access to these services creates a
financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest.
Concurrent believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients.
Participation in Institutional Advisor Platform (SEI)
The Advisor has access to a variety of economic benefits, services, and products in connection with its use of
SEI’s investment adviser platform. The terms and availability of these benefits vary among advisors on the SEI
platform (including Concurrent) depending on the business conducted with SEI and other factors. These services
generally help Concurrent conduct its advisory business, but each specific benefit does not necessarily benefit
each client.
Beyond access to SEI investment products, these include conferences, seminars and other educational and
networking activities, business entertainment, reimbursement of travel and attendance expenses, research and
other investment support services (such as client proposal and other financial planning support), technical and
operational solutions (including the SEI Wealth Platform), marketing assistance (including joint marketing designed
to promote SEI’ investment products), compliance services, human resources consulting, risk
management/insurance assistance, front office, middle office, back office and other administrative support
(including providing clerical staff to assist in the completion of required paperwork), SEI attendance at client
meetings, information technology services, continuity and succession planning, access to financing and banking
options, trust services, portfolio reporting, automatic rebalancing, tax loss harvesting, waiver or payment of certain
fees (including paying account transfer fees or other charges that Concurrent or its clients would incur when
changing service providers), vendor discounts, discount pricing on SEI services, and broader practice
management consulting. These benefits may be provided via SEI, its affiliates, or third parties and may be made
available to Concurrent at no fee, at a discounted fee, or via financial compensation provided by SEI. Some of
these offerings depend on Concurrent conducting a minimum amount or type of current or expected future
business with SEI or having a minimum account size or amount of assets under management with SEI or invested
in SEI investment products. Certain of these services or products, including those provided by or paid for by SEI,
may be used by Concurrent in connection with its general business activities, in addition to supporting Concurrent’s
interaction with SEI systems. The benefits, services, products, or payments discussed herein may be significant to
Concurrent and create an incentive for the Concurrent to utilize SEI services or investment products for its
customers rather than other service providers or investment products. However, Concurrent strives at all times to
put the interests of its clients first, including when selecting custodians or investment products for clients.
Concurrent is independently owned and operated; it is not affiliated with SEI.
Participation in Institutional Advisor Platform (Goldman Sachs)
Concurrent has established an institutional relationship with Goldman Sachs to assist the Advisor in managing
Client account[s]. As part of the arrangement, Goldman Sachs also makes available to the Advisor, at no
additional charge to the Goldman Sachs, certain research and brokerage services, including research services
obtained by Goldman Sachs directly from independent research companies. The Advisor may also receive
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 23
additional services and support from Goldman Sachs. As a result of receiving such services for no additional cost,
the Advisor may have an incentive to continue to use or expand the use of Goldman Sachs’s services. The
Advisor examined this potential conflict of interest when it chose to enter into the relationship with Goldman Sachs
and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client
obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to
software and related support without cost because the Advisor renders investment management services to
Clients that maintain assets at Goldman Sachs. The software and related systems support may benefit the
Advisor, but not its Clients directly.
Reimbursements from Third-Parties to Concurrent
Concurrent receives reimbursements from third party product providers and their affiliates (“Product Sponsors”) in
connection with financial services and platform services offered by Concurrent to our brokerage and advisory
customers, including mutual funds and exchange-traded funds.
Concurrent generally seeks to be reimbursed for the associated operational and/or technology costs of adding
and/or maintaining mutual funds and money market funds on our platform. The flat fees are paid by the fund sponsor
or affiliates and not the funds. Financial advisors do not receive additional compensation from these companies for
recommending funds that have reimbursed Concurrent for our costs.
In general, Product Sponsors pay third party compensation in addition to other product-related fees paid by the
investor, which include sale charges, deferred sale charges, distribution and service fees, redemption fees, and
other fees and expenses disclosed in a product’s offering documents.
Product Sponsors pay Concurrent third party compensation for platform services, marketing support, data analytics,
and administrative services, among other reasons. Concurrent provides fund families with opportunities to sponsor
meetings and conferences and grants them access to our branch offices and financial advisors for education,
marketing and other promotional efforts. Some fund representatives also work closely with our branch offices and
financial advisors to develop business strategies and plan promotional events for clients, prospective clients, and
educational activities. The amount and form of third-party compensation paid by a Product Sponsor can vary
depending on many factors, including the services provided by Concurrent and the Product Sponsor’s investment
products.
Some fund families or their affiliates reimburse Concurrent for certain expenses incurred in connection with these
platform services, promotional efforts and/or training programs. Fund families independently decide if and what they
will spend on these activities, with some fund families agreeing to make annual dollar amount expense
reimbursement commitments of up to $300,000, although actual reimbursements may be higher. Some fund families
also invite our financial advisors to attend fund family-sponsored events. Expense payments may include meeting
or conference facility rental fees and hotel, meal, and travel charges.
Concurrent also provides fund families with the opportunity to purchase sales data analytics. The amount of the
fees depends on the level of data and ranges up to $200,000. For an additional fee, fund families may purchase
supplemental data analytics on other financial product sales at Concurrent.
These reimbursements present potential conflicts of interest for Concurrent and our financial advisors to the extent
they lead us to focus on funds from those fund families that commit significant financial and staffing resources to
promotional and educational activities and or purchase data analytics instead of funds from fund families that do
not. In order to mitigate this conflict, financial advisors do not receive additional compensation for recommending
funds sponsored by fund families that purchase data analytics.
Fund family representatives are allowed to provide funding for client/ prospect seminars, employee education, and
training event, occasional meals and entertainment, and gifts. Concurrent’s non-cash compensation policies set
conditions for these types of payments.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 24
B. Client Referrals from Promoters
If a Client is introduced to the Advisor by either an unaffiliated or affiliated party (herein a “Promoter”), the Advisor
compensates that Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state
securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by
the Advisor and shall not result in any additional charge to the Client.
From time to time, the Advisor and/or its Advisory Persons enter into arrangements with third parties for lead
generation. These third parties typically operate as referral networks. Referral networks may present potential
clients with a list of possible investment advisory firms and investment adviser representatives, or may direct
potential clients specifically only to Concurrent and its Advisory Persons. Some referral networks receive a flat fee
per referral and/or an ongoing fee, while others share a portion of the ongoing advisory fees. Clients and
prospective clients are not charged any additional fee by the Advisor as a result of its participation in these
arrangements.
Referral arrangements give rise to material conflicts of interest because the referring party has a financial incentive
to introduce new clients to the Advisor and its Advisory Persons. Clients who are introduced to the Advisor and its
Advisory Persons through a referral arrangement receive specific disclosures at the time of the introduction. Clients
should review those disclosures carefully to understand the details of the arrangements. The Advisor’s participation
in these referral arrangements does not diminish its fiduciary obligations to its clients.
Item 15 – Custody
Concurrent does not accept or maintain custody of any Client accounts, except for the authorized deduction of
the Advisor’s fees. All Clients must place their assets with a “qualified custodian.” Clients are required to engage
the Custodian to retain their funds and securities and direct Concurrent to utilize that Custodian for the Client’s
security transactions. Clients should review statements provided by the Custodian and compare to any reports
provided by Concurrent to ensure accuracy, as the Custodian does not perform this review. For more information
about custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may
have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor
have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s
instructions.
Item 16 – Investment Discretion
Concurrent offers its services on either a discretionary or non-discretionary basis.
Discretionary engagements – For discretionary accounts, Concurrent will have authority over the selection and
amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the
Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or
limitations previously set forth by the Client and agreed to by Concurrent. The discretionary authority will only be
authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's
execution of an investment advisory agreement containing all applicable limitations to such authority. All
discretionary trades made by Concurrent will be in accordance with each Client's investment objectives and
goals.
Non-discretionary engagements – For non-discretionary accounts, Concurrent Advisory Persons must obtain prior
approval from the Client (verbally or in writing) prior to executing a trade or allocating investment assets.
Item 17 – Voting Client Securities
Concurrent does not accept proxy-voting responsibility for Clients. Clients will receive proxy statements directly
from the Custodian. Should a Client direct the Custodian to send proxy statements to the Advisor, such action
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 25
will not authorize the Advisor to vote proxies. The Advisor will assist in answering questions relating to proxies.
However, the Client retains the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither Concurrent, nor its management, have any adverse financial situations that would reasonably impair the
ability of Concurrent to meet all obligations to its Clients. Concurrent has not been subject to a bankruptcy or
financial compromise. Concurrent is not required to deliver a balance sheet along with this Disclosure Brochure
as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more
in the future.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 26
Privacy Policy
Effective: March 19, 2026
Our Commitment to You
Concurrent Investment Advisors, LLC (“Concurrent” or the “Advisor”) is committed to safeguarding the use of
personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment
Advisor, as described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. Concurrent (also referred to as "we",
"our" and "us”) protects the security and confidentiality of the personal information we have and implements
controls to ensure that such information is used for proper business purposes in connection with the
management or servicing of our relationship with you.
Concurrent does not sell your non-public personal information to anyone. Nor do we provide such information to
others except for discrete and reasonable business purposes in connection with the servicing and management
of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number
Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Account applications and forms
Investment questionnaires and suitability
documents
Transactional information with us or others
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical, procedural,
and electronic security measures. These include such safeguards as secure passwords, encrypted file storage,
and a secure office environment. Our technology vendors provide security and access control over personal
information and have policies over the transmission of data. Our associates are trained on their responsibilities to
protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they
receive from us.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 27
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information. If you are a new client, we may begin sharing your information on
the day you sign our agreement. When you are no longer our client, we continue to share your information as
described in this notice.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
Yes
No
No
Not Shared
Yes
Yes
Servicing our Clients
We share non-public personal information with non-affiliated third parties
(such as administrators, brokers, custodians, regulators, credit agencies,
other financial institutions) as necessary for us to provide agreed upon
services to you, consistent with applicable law, including but not limited
to: processing transactions; general account maintenance; responding to
regulators or legal investigations; and credit reporting.
We share client information with Purshe Kaplan Sterling Investments, Inc.
(“PKS”) due to the oversight PKS has over certain Supervised Persons of
the Advisor. You may contact us at any time for a copy of the PKS Privacy
Policy.
Affiliates
We share non-public personal information for our affiliates everyday
business purposes, including information about your transactions and
experiences.
Marketing Purposes
Concurrent does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where Concurrent or
the client has a formal agreement with the financial institution. Text
messaging originator opt-in data will not be shared with third-parties for
marketing purposes. We will only share information for purposes of
servicing your accounts, not for marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent(s) or
representative(s).
Artificial Intelligence (“AI”)
We may utilize AI tools internally to assist with certain business and operational functions such as notetaking,
data analysis, investment research support, client communications, or administrative processes. These AI tools
do not replace human oversight, and are reviewed for accuracy and compliance with regulatory standards. We
conduct thorough due diligence upfront and ongoing assessments of our AI tools' privacy and cybersecurity
protocols to ensure they meet standards of security and confidentiality. If you have any questions or concerns
about our use of AI, please contact us.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by
contacting us at (813) 709-8800.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
Page 28
Additional Brochure: CONCURRENT WRAP BROCHURE (2026-03-24)
View Document Text
Concurrent Investment Advisors, LLC
Wrap Fee Program Brochure
Effective: March 24, 2026
This Wrap Fee Brochure (“Wrap Brochure”) provides information about the qualifications and
business practices of Concurrent Investment Advisors, LLC (“Concurrent” or the “Advisor”). If you
have any questions about the content of this Wrap Brochure, please contact the Advisor at (813)
709-8800.
Concurrent is a registered investment advisor with U.S. Securities and Exchange Commission
(“SEC”). The information in this Wrap Brochure has not been approved or verified by the SEC or
by any state securities authority. Registration of an investment advisor does not imply any specific
level of skill or training. This Wrap Brochure provides information about Concurrent to assist you
in determining whether to retain the Advisor.
Additional information about Concurrent and its Advisory Persons is available on the SEC’s
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 323135.
Concurrent Investment Advisors, LLC
100 S. Ashley Drive, Suite 830, Tampa, FL 33602
Phone: (813) 709-8800
1
Item 2 – Material Changes
•
Concurrent Investment Advisors, LLC has the following material changes to report since the
annual updating amendment on March 10, 2025. Material changes relate to Concurrent
Investment Advisors, LLC’s policies, practices or conflicts of interests.
• The Advisor has updated its phone number. (Cover page)
• The Advisor receives reimbursements from third party product providers and their affiliates
(“Product Sponsors”) in connection with financial services and platform services offered by
Concurrent to our brokerage and advisory customers, including mutual funds and exchange-traded
funds. (Item 9)
Investment adviser representatives of Concurrent may receive an equity interest in Concurrent
Asset Management, LLC (“CAM”) based on their use of CAM as a sub-advisor for client accounts
they service. Because Concurrent and CAM are affiliated entities, this arrangement creates a
conflict of interest. Concurrent addresses this conflict by using CAM only when it determines that
doing so is in the client’s best interest. (Item 9)Concurrent may refer Clients to various unaffiliated,
non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain
financial services necessary to meet the goals of its Clients. In some cases, Concurrent is
compensated by the non-advisory professional for the referrals. This presents a conflict of interest.
(Item 9)
• The Advisor has access to a variety of economic benefits, services, and products in connection
with its use of SEI and Goldman Sachs investment adviser platforms. (Item 9)
• From time to time, the Advisor and/or its Advisory Persons enter into arrangements with third
parties for lead generation. Referral arrangements give rise to material conflicts of interest because
the referring party has a financial incentive to introduce new clients to the Advisor and its Advisory
Persons. (Item 9)
2
Item 3 – Table of Contents
Item 1: Cover Page
Item 2 – Material Changes ......................................................................................................................... 2
Item 3 – Table of Contents ......................................................................................................................... 3
Item 4 – Services, Fees and Compensation ............................................................................................... 4
Item 5 – Account Requirements and Types of Clients................................................................................. 6
Item 6 – Portfolio Manager Selection and Evaluation .................................................................................. 7
Item 7 – Client Information Provided to Portfolio Managers .......................................................................10
Item 8 – Client Contact with Portfolio Managers ........................................................................................10
Item 9 – Additional Information ..................................................................................................................10
3
Item 4 – Services, Fees and Compensation
Concurrent Investment Advisors LLC (hereinafter “Concurrent” or the “Advisor”) provides
portfolio management to clients under this wrap fee program as sponsor and portfolio manager.
A. Description of Services
Concurrent participates in and sponsors wrap fee programs, which means Concurrent will
wrap third party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction
fees, etc.) for wrap fee portfolio management accounts. Concurrent will charge clients one
fee and pay all transaction fees using the fee collected from the client. Accounts
participating in the wrap fee program are not charged higher advisory fees based on
trading activity, but clients should be aware that Concurrent has an incentive to limit trading
activities for those accounts since the firm absorbs those transaction costs.
Certain other fees are not included in the wrap fee and are paid for separately by the client.
These include, but are not limited to, margin costs, charges imposed directly by a mutual
fund or exchange traded fund, fees associated with “step out” transactions if the account
uses different custodians or broker-dealers, deferred sales charges, odd-lot differentials,
transfer taxes, wire transfer and electronic fund fees, account transfer/closure fees, and
other fees and taxes on brokerage accounts and securities transactions.
Advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the
terms of the advisory agreement. Investment advisory fees are based on the market value
of assets under management at the end of the prior quarter. Investment advisory fees
generally range from 1.00% to 2.00% annually based on several factors, including: the
scope and complexity of the services to be provided; the level of assets to be managed;
and the overall relationship with the Advisor. Relationships with multiple objectives,
specific reporting requirements, portfolio restrictions and other complexities may be
charged a higher fee.
When providing fees based on a tiered fee schedule, the following schedule will be used.
Total Assets Under Management
Maximum Annual Fee
$0 - $1,000,000
$1,000,001 - $2,000,000
$2,000,001 - $3,000,000
$3,000,001 – $5,000,000
$5,000,001 - $7,500,000
$7,500,001 - $10,000,000
$10,000,001 - Above
2.00%
1.70%
1.60%
1.50%
1.40%
1.30%
1.00%
Fees are incremental. The schedule breakpoints and rates may be modified and are
negotiable. When Concurrent utilizes tiered billing, different rates are charged on different
tranches of assets under Concurrent’s management in accordance with the fee schedule
above.
4
In addition to the advisory fee described above, Concurrent imposes a Custody, Platform
and Admin (“CPA”) fee that is separate and distinct from the client’s advisory fee. The
CPA fee is typically accessed at 0.05% annually and billed quarterly, in advance of each
calendar quarter. The CPA fee in the first quarter of service is prorated from the inception
date of the account[s] to the end of the first quarter. The CPA fee may be reduced or
waived at Concurrent’s or investment advisor representative’s discretion. Should the
investment advisor representative assigned to the client’s account[s] reduce or waive the
client’s CPA fee, the representative will receive a lower payout percentage from the client’s
account[s]. This creates a conflict of interest in that the representative has an incentive to
not reduce or waive the client’s CPA fee.
The advisory fee in the first quarter of service is prorated from the inception date of the
account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of
the Advisor. The Advisor typically offers a fixed annual rate fee schedule (as detailed
above). In certain circumstances, the Advisor may charge a fixed annual fixed quarterly
fee for its services. The client’s fees will take into consideration the aggregate assets under
management with the Advisor across all accounts, unless otherwise agreed in writing. All
securities held in accounts managed by Concurrent will be independently valued by the
Custodian. Concurrent will not have the authority or responsibility to value portfolio
securities.
Either party may terminate the investment advisory agreement, at any time, by providing
advance written notice to the other party. The client may also terminate the advisory
agreement within five (5) business days of signing the Advisor’s agreement at no cost to
the client. After the five-day period, the client will incur charges for bona fide advisory
services rendered to the point of termination, and such fees will be due and payable by
the client. Upon termination, the Advisor will refund any unearned, prepaid fees from the
effective date of termination through the end of the quarter. The client’s advisory
agreement with the Advisor is non-transferable without the client’s prior consent.
Use of Independent Managers – The Advisor may implement all or a portion of a Client’s
investment portfolio utilizing one or more Independent Managers. Concurrent will be
compensated via a fee share from the advisors to which it directs those clients. This
relationship will be disclosed in each contract between Concurrent and each Independent
Manager. The fees shared will not exceed any limit imposed by any regulatory agency.
This creates a conflict of interest in that Concurrent has an incentive to direct clients to the
Independent Managers that provide Concurrent with a larger fee split. Concurrent will
always act in the best interests of the client, including when determining which
Independent Manager to recommend to clients. Independent Managers typically do not
offer any fee discounts but may have a breakpoint schedule which will reduce the fee with
an increased level of assets placed under management with an Independent Manager.
The Advisor will allocate a portion of the advisory fee collected to the Independent
Manager pursuant to the terms of the executed agreement between the Advisor and the
Independent Manager. If the Client is required to authorize and enter into an investment
advisory agreement with an Independent Manager, then the terms of such fee
arrangements are included in the Independent Manager’s disclosure brochure and
applicable contract[s] with the Independent Manager. Concurrent may utilize or
recommend that Clients utilize Concurrent Asset Management, LLC (“CAM”), an
investment adviser registered with the SEC that is under common control with Concurrent,
for all or a portion of a Client’s investment portfolio, based on the Client’s needs and
objectives.
5
For Client accounts implemented through an Independent Manager, the Client’s overall
fees may include Concurrent’s investment advisory fee (as noted above) plus investment
advisory fees and/or platform fees charged by the Independent Manager[s], as applicable.
In certain instances, the Independent Manager or the Advisor may assume responsibility
for calculating the Client’s fees and deduct all fees from the Client’s account[s]. In other
instances, the Advisor and the Independent Manager will each assume the responsibility
for calculating and deducting their respective fees from the Client’s account[s].
B. Contribution Cost Factors
The program may cost the client more or less than purchasing such services separately.
There are several factors that bear upon the relative cost of the program, including the
trading activity in the client’s account, the adviser’s ability to aggregate trades, and the
cost of the services if provided separately (which in turn depends on the prices and specific
services offered by different providers).
C. Additional Fees
Concurrent will wrap third party fees (i.e., brokerage fees, mutual fund fees, transaction
fees, etc.) for wrap fee portfolio management accounts. Concurrent will charge clients one
fee and pay all transaction fees using the fee collected from the client. Accounts
participating in the wrap fee program are not charged higher advisory fees based on
trading activity, but clients should be aware that Concurrent has an incentive to limit trading
activities for those accounts since the firm absorbs those transaction costs.
Certain other fees are not included in the wrap fee and are paid for separately by the client.
These include, but are not limited to, margin costs, charges imposed directly by a mutual
fund or exchange traded fund, fees associated with “step out” transactions if the account
uses different custodians or broker-dealers, deferred sales charges, odd-lot differentials,
transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on
brokerage accounts and securities transactions.
D. Compensation of Client Participation
Neither Concurrent, nor any representatives of Concurrent receive any additional
compensation beyond advisory fees for the participation of client’s in the wrap fee
program. However, compensation received may be more than what would have been
received if client paid separately for investment advice, brokerage, and other services.
Therefore, Concurrent may have a financial incentive to recommend the wrap fee program
to clients.
Item 5 – Account Requirements and Types of Clients
Concurrent offers advisory services to individuals, high net worth individuals, families, trusts,
estates, businesses, and retirement plans. Concurrent generally does not impose a minimum
relationship size.
6
Item 6 – Portfolio Manager Selection and Evaluation
A. Selecting/Reviewing Portfolio Managers
Concurrent will select outside portfolio managers for management of some accounts
under this wrap fee program.
Concurrent will use industry standards to calculate portfolio manager performance.
A third party reviews the performance information to determine and verify its accuracy and
compliance with presentation standards. The performance information is reviewed by the
third-party advisor.
B. Related Persons
Concurrent and its personnel serve as the portfolio managers for some wrap fee
program accounts. For others, Concurrent may utilize its affiliate, Concurrent Asset
Management, LLC (“CAM”), as sub-advisor. There is a conflict of interest due to the
affiliation between the Advisor and CAM, because the Advisor is incentivized to utilize
CAM as a sub-adviser with respect to its Clients rather than utilizing one or more
unaffiliated investment advisers in order to generate additional revenue for its owners
through CAM. CAM is subject to the same selection and review as any other portfolio
managers that participate in the wrap fee program. Please see item 9.A. below for more
information related to CAM.
C. Advisory Business
Concurrent offers portfolio management services to its wrap fee program participants as
discussed in Section 4 above.
Wrap Fee Portfolio Management
Concurrent provides customized investment management solutions for its Clients. This is
achieved through continuous personal Client contact and interaction while providing
discretionary or non-discretionary investment management and related advisory services.
Concurrent works closely with each Client to identify their investment goals and objectives
as well as risk tolerance and financial situation in order to design a portfolio strategy.
Concurrent will then construct an investment portfolio, consisting of exchange-traded
funds (“ETFs”) and/or mutual funds to achieve the Client’s investment goals. The Advisor
may also utilize individual stocks, individual bonds, and other types of investments, as
appropriate, to meet the needs of the Client. The Advisor may retain certain legacy
investments based on portfolio fit and/or tax considerations.
Concurrent will select, recommend and/or retain mutual funds on a fund-by-fund basis.
Due to specific custodial and/or mutual fund company constraints, material tax
consideration, and/or systematic investment plans, Concurrent will select, recommend
and/or retain a mutual fund share classes that do not have trading costs when possible.
These will in most cases be institutional share classes but, in some cases, may be share
classes with higher internal expense ratios than institutional share classes. Concurrent will
seek to select the lowest cost share class available that is in the best interest of each
Client weighing the expected investment pattern, expense ratios and potential ticket
charges, and will ensure the selection aligns with the Client’s financial objectives and
7
stated investment guidelines.
Concurrent’s investment approach is primarily long-term focused, but the Advisor may
buy, sell or re-allocate positions that have been held for less than one year to meet the
objectives of the Client or due to market conditions. Concurrent will construct, implement,
and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable
restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
Concurrent evaluates and selects investments for inclusion in Client portfolios only after
applying its internal due diligence process. Concurrent may recommend, on occasion,
redistributing investment allocations to diversify the portfolio. Concurrent may recommend
specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against the market movement.
Concurrent may recommend selling positions for reasons that include, but are not limited
to, harvesting capital gains or losses, business or sector risk exposure to a specific
security or class of securities, overvaluation or overweighting of the position[s] in the
portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or
any risk deemed unacceptable for the Client’s risk tolerance.
Prior to engaging Concurrent to provide advisory services, each Client is required to enter
into a written advisory agreement with the Advisor that define the terms, conditions,
authority, and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Concurrent, in connection with the
Client, will develop a strategy that seeks to achieve the Client’s goals and
objectives.
• Asset Allocation – Concurrent will develop a strategic asset allocation that is
targeted to meet the investment objectives, time horizon, financial situation,
and tolerance for risk for each Client or unique client goal.
• Portfolio Construction – Concurrent will develop a portfolio for the Client that
is intended to meet the stated goals and objectives of the Client.
• Wealth Management and Supervision – Concurrent will provide wealth
management and ongoing oversight of the Client’s investment portfolio
Concurrent sponsors and acts as portfolio manager for this wrap fee program. Concurrent
manages the investments in the wrap fee program but does not manage those wrap fee
accounts any differently than non-wrap fee accounts. The fees paid to the wrap account
program will be given to Concurrent as a management fee.
Effective December 31, 2025, the Advisor manages $12,803,029,449 in Client assets on
a discretionary basis and $2,924,961,395 on a non-discretionary basis. Clients may
request more current information at any time by contacting the Advisor.
In addition, as of February 28, 2026, the Advisor also has $14,397,375,088 in assets
under advisement (“AUA”). Clients may request more current information at any time by
contacting the Advisor.
Performance-Based Fees and Side-By-Side Management
8
Concurrent does not charge performance-based fees for its wealth management services.
The fees charged by Concurrent are as described above and are not based upon the
capital appreciation of the funds or securities held by any Client.
Methods of Analysis and Investment Strategies
Concurrent employs various analysis methods in developing investment strategies for its
Clients. Research and analysis from Concurrent are derived from numerous sources,
including financial media companies, third-party research materials, professional data
subscriptions, Internet sources, and review of company activities, including annual reports,
prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection
criteria. This criteria generally consists of ratios and trends that may indicate the overall
strength and financial viability of the entity being analyzed. Assets are deemed suitable if
they meet certain criteria to indicate that they are a strong investment with a value
discounted by the market. While this type of analysis helps the Advisor in evaluating a
potential investment, it does not guarantee that the investment will increase in value.
Assets meeting the investment criteria utilized in the fundamental analysis may lose value
and may have negative investment performance. The Advisor monitors these economic
indicators to determine if adjustments to strategic allocations are appropriate.
Technical analysis involves the analysis of past market data rather than specific company
data in determining the recommendations made to clients. Technical analysis may involve
the use of charts to identify market patterns and trends, which may be based on investor
sentiment rather than the fundamentals of the company. The primary risk in using technical
analysis is that spotting historical trends may not help to predict such trends in the future.
Even if the trend will eventually reoccur, there is no guarantee that Concurrent will be able
to predict such a reoccurrence accurately.
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 that is being
recommended. The risks with cyclical analysis are similar to those of technical analysis.
Charting analysis utilizes various market indicators as investment selection criteria. These
criteria are generally pricing trends that may indicate movement in the markets. Assets
are deemed suitable if they meet certain criteria to indicate that they are a strong
investment with a value discounted by the market. While this type of analysis helps the
Advisor in evaluating a potential investment, it does not guarantee that the investment will
increase in value. Assets meeting the investment criteria utilized in the technical and
charting analysis may lose value and may have negative investment performance. The
Advisor monitors these market indicators to determine if adjustments to strategic
allocations are appropriate.
As noted above, Concurrent generally employs a long-term investment strategy for its
Clients as consistent with their financial goals. Concurrent will typically hold all or a portion
of a security for more than a year but may hold for shorter periods for the purpose of
rebalancing a portfolio or meeting the cash needs of Clients. At times, Concurrent may
also buy and sell positions that are more short-term in nature, depending on the goals of
the Client and/or the fundamentals of the security, sector, or asset class.
Investing in securities involves certain investment risks. Securities may fluctuate in value
9
or lose value. Clients should be prepared to bear the potential risk of loss. Concurrent will
assist Clients in determining an appropriate strategy based on their tolerance for risk and
other factors noted above. However, there is no guarantee that a Client will meet their
investment goals.
Voting Client Proxies
Concurrent does not accept proxy-voting responsibility for any Client. Clients will receive
proxy statements directly from the Custodian. Should a Client direct the Custodian to send
proxy statements to the Advisor, such action will not authorize the Advisor to vote proxies.
The Advisor will assist in answering questions relating to proxies. However, the Client
retains the sole responsibility for proxy decisions and voting.
Item 7 – Client Information Provided to Portfolio Managers
All client information material to managing the portfolio (including basic information, risk tolerance,
sophistication level, and income level) is provided to the portfolio manager. The portfolio manager
will also have access to that information as it changes and is updated.
Item 8 – Client Contact with Portfolio Managers
Concurrent does not restrict clients
from contacting portfolio managers. Concurrent’s
representatives can be contacted during regular business hours using the information on the Form
ADV Part 2B cover page.
Item 9 – Additional Information
A. Disciplinary Action and Other Financial Industry Activities
Disciplinary Information
There are no legal, regulatory, or disciplinary events involving Concurrent or its
management persons. Concurrent values the trust Clients place in the Advisor. The
Advisor encourages Clients to perform the requisite due diligence on any advisor or
service provider that the Client engages. The backgrounds of the Advisor and its Advisory
Persons are available on the Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 323135.
Other Financial Industry Activities and Affiliations
Concurrent Asset Management, LLC
The Advisor is under common control with Concurrent Asset Management, LLC (“CAM”),
an investment adviser registered with the SEC that offers advisory services to other
investment advisers and their IARs, including stand-alone investment management
services, access to a CAM-configured turnkey asset management program (“TAMP”), and
outsourced chief investment officer (“OCIO”) services. CAM will serve as a sub-advisor for
the Advisor with respect to certain of its Clients pursuant to a Sub-Advisory Agreement.
When CAM acts as a sub-adviser or otherwise provides services to the Advisor, CAM
receives compensation for its investment management services. In addition, IARs of the
Advisor may receive an equity interest when CAM is used as a sub-advisor with respect
10
to Advisor clients they service. There is a conflict of interest due to the affiliation between
the Advisor and CAM, because the Advisor is incentivized to utilize CAM as a sub-adviser
with respect to its Clients rather than utilizing one or more unaffiliated investment advisers
in order to generate additional revenue for its owners through CAM as well as to generate
an equity interest for Advisor IARs. CAM will earn the investment advisor fees as described
in its Form ADV. The Advisor will only utilize CAM when it is in the best interest of the
client to do so.
Broker-Dealer Affiliation
Certain Advisory Persons are also Registered Representatives of PKS. In one’s separate
capacity as a Registered Representative, an Advisory Person will receive commissions
for the implementation of recommendations for commissionable transactions. Clients are
not obligated to implement any recommendation provided by the Advisory Person. Neither
the Advisor nor its Advisory Persons will earn ongoing investment advisory fees in
connection with any services implemented in an Advisory Person’s separate capacity as
a Registered Representative.
Insurance Agency Affiliations
Certain Advisory Persons are also licensed insurance professionals. The Advisor is
affiliated with Concurrent Insurance Solutions (“CIS”), a licensed insurance agency,
through common control and ownership. Therefore, associates providing investment
advice on behalf of our firm may be licensed as insurance agents. These associates will
earn a commission-based compensation for selling insurance products, including
insurance products they sell to you. Insurance commissions earned by these associates
are separate from our advisory fees.
Use of Independent Managers
The Advisor may implement all or a portion of a Client’s investment portfolio with one or
more Independent Managers. Concurrent will be compensated via a fee share from the
advisors to which it directs those clients. This relationship will be disclosed in each contract
between Concurrent and each Independent Manager. The fees shared will not exceed
any limit imposed by any regulatory agency. This creates a conflict of interest in that
Concurrent has an incentive to direct clients to the Independent Managers that provide
Concurrent with a larger fee split. Concurrent will always act in the best interests of the
client, including when determining which Independent Manager to recommend to clients.
Concurrent will ensure that all recommended advisors or managers are licensed, or notice
filed in the states in which Concurrent is recommending them to clients.
B. Code of Ethics, Client Referrals, and Financial Information
Code of Ethics
Concurrent has implemented a Code of Ethics (the “Code”) that defines the Advisor’s
fiduciary commitment to each Client. This Code applies to all persons associated with
Concurrent (“Supervised Persons”). The Code was developed to provide general ethical
guidelines and specific instructions regarding the Advisor’s duties to the Client. Concurrent
and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each
Client. It is the obligation of Concurrent’s Supervised Persons to adhere not only to the
specific provisions of the Code, but also to the general principles that guide the Code. The
Code covers a range of topics that address employee ethics and conflicts of interest. To
request a copy of the Code, please contact the Advisor at (813) 709-8800.
11
Personal Trading with Material Interest
Concurrent allows Supervised Persons to purchase or sell the same securities that may
be recommended to and purchased on behalf of Clients. Concurrent does not act as a
principal in any transactions. In addition, the Advisor does not act as the general partner
of a fund or advise an investment company. Concurrent does not have a material interest
in any securities traded in Client accounts.
Personal Trading in the Same Securities as Clients
Concurrent allows Supervised Persons to purchase or sell the same securities that may
be recommended to and purchased on behalf of Clients. Owning the same securities that
are recommended (purchase or sell) to Clients presents a conflict of interest that, as
fiduciaries, must be disclosed to Clients and mitigated through policies and procedures.
As noted above, the Advisor has adopted the Code to address insider trading (material
non-public information controls); gifts and entertainment; outside business activities and
personal securities reporting. When trading for personal accounts, Supervised Persons
have a conflict of interest if trading in the same securities.
The fiduciary duty to act in the best interest of its Clients can be violated if personal trades
are made with more advantageous terms than Client trades, or by trading based on
material non-public information. This risk is mitigated by Concurrent requiring reporting of
personal securities trades by its Supervised Persons for review by the Chief Compliance
Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect
the misuse of material, non-public information.
Personal Trading at Same Time as Client
While Concurrent allows Supervised Persons to purchase or sell the same securities that
may be recommended to and purchased on behalf of Clients, such trades are typically
aggregated with Client orders or traded afterward. At no time will Concurrent, or any
Supervised Person of Concurrent, transact in any security to the detriment of any Client.
Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Advisory
Persons of Concurrent and periodically by the CCO. Formal reviews are generally
conducted at least annually or more frequently depending on the needs of the Client.
Causes for Reviews
In addition to the investment monitoring noted above, each Client account shall be
reviewed at least annually. Reviews may be conducted more frequently at the Client’s
request. Accounts may be reviewed as a result of major changes in economic conditions,
known changes in the Client’s financial situation, and/or large deposits or withdrawals in
the Client’s account[s]. The Client is encouraged to notify Concurrent if changes occur in
the Client’s personal financial situation that might adversely affect the Client’s investment
plan. Additional reviews may be triggered by material market, economic, or political events.
Review Reports
The Client will receive brokerage statements at least quarterly from the Custodian. These
brokerage statements are sent directly from the Custodian to the Client. The Client may
also establish electronic access to the Custodian’s website so that the Client may view
these reports and their account activity. Client brokerage statements will include all
positions, transactions, and fees relating to the Client’s account[s]. The Advisor may also
their holdings, allocations, and
provide Clients with periodic reports regarding
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performance.
Compensation Received by Concurrent
Concurrent may receive compensated or non-compensated referrals of new Clients from
various third-parties. Likewise, Concurrent may refer Clients to various unaffiliated, non-
advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain
financial services necessary to meet the goals of its Clients. In some cases, Concurrent is
compensated by the non-advisory professional for the referrals. This presents a conflict of
interest, as it provides an incentive to recommend professionals based on the
compensation to be received, rather than the Client’s particular need. Concurrent always
acts in the best interest of Clients, including when recommending non-advisory
professionals. No client is under any obligation to engage a non-advisory professional
from other
recommended by Concurrent. Clients may receive similar services
professionals on more favorable terms.
Concurrent maintains institutional relationships with the Custodians, whereby the Advisor
receives certain economic benefits. Access to the respective Custodian platforms are
provided at no charge to the Advisor. All Custodian platforms include brokerage, custody,
administrative support, recordkeeping, technology, and related services designed to support
registered investment advisors like Concurrent. The terms and availability of these benefits
vary by Custodian and may include investment-related research, pricing information and
market data, software and other technology that provide access to client account data,
compliance and/or practice management-related publications, discounted or gratis
consulting services, discounted and/or gratis attendance at conferences, meetings, and
other educational and/or social events, marketing support, computer hardware and/or
software and/or other products used by Concurrent in its investment advisory business
operations. These services generally help Concurrent conduct its advisory business, but
each specific benefit does not necessarily benefit each client. Some custodians may be
more expensive than other custodial options available. Clients are encouraged to review
and compare custodial fees, transaction costs, and service offerings and to ask questions
regarding any differences prior to selecting or approving a custodian.
In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of
its Clients first. Clients should be aware, however, that the receipt of economic benefits from
a Custodian creates a conflict of interest since these benefits may influence the Advisor's
recommendation of this Custodian over one that does not furnish similar software, systems
support, or services.
Participation in Institutional Advisor Platform (Fidelity)
Concurrent has established an institutional relationship with Fidelity to assist the Advisor
in managing Client account[s]. As part of the arrangement, Fidelity also makes available
to the Advisor, at no additional charge to the Advisor, certain research and brokerage
services, including research services obtained by Fidelity directly from independent
research companies. The Advisor may also receive additional services and support from
Fidelity. As a result of receiving such services for no additional cost, the Advisor may have
an incentive to continue to use or expand the use of Fidelity's services. The Advisor
examined this potential conflict of interest when it chose to enter into the relationship with
Fidelity and has determined that the relationship is in the best interests of the Advisor’s
Clients and satisfies its Client obligations, including its duty to seek best execution.
The Advisor receives access to software and related support without cost because the
Advisor renders investment management services to Clients that maintain assets at
Fidelity The software and related systems support may benefit the Advisor, but not its
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Clients directly. In addition, Fidelity has provided the Advisor with financial support in the
launch of the Advisor and reimbursements for various third-party service providers.
Participation in Institutional Advisor Platform (Schwab)
Concurrent has established an institutional relationship with Schwab through its “Schwab
Advisor Services” unit, a division of Schwab dedicated to serving independent advisory
firms like Concurrent. As a registered investment advisor participating on the Schwab
Advisor Services platform, Concurrent receives access to software and related support
without cost because the Advisor renders investment management services to Clients that
maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the
Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling
its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients
first. Clients should be aware, however, that the receipt of economic benefits from a
custodian creates a potential conflict of interest since these benefits may influence the
Advisor's recommendation of this custodian over one that does not furnish similar
software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access
to a broad range of investment products, execution of securities transactions, and custody
of Client’s funds and securities. Through Schwab, the Advisor may be able to access
certain investments and asset classes that the Client would not be able to obtain directly
or through other sources. Further, the Advisor may be able to invest in certain mutual
funds and other investments without having to adhere to investment minimums that might
be required if the Client were to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors
with access to technology, research, discounts and other services. In addition, the Advisor
receives duplicate statements for Client accounts, the ability to deduct advisory fees,
trading tools, and back-office support services as part of its relationship with Schwab.
These services are intended to assist the Advisor in effectively managing accounts for its
Clients but may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services and
financial support to Concurrent that may not benefit the Client, including: educational
conferences and events, financial start-up support, consulting services and discounts for
various service providers. Access to these services creates a financial incentive for the
Advisor to recommend Schwab, which results in a potential conflict of interest. Concurrent
believes, however, that the selection of Schwab as Custodian is in the best interests of its
Clients.
Participation in Institutional Advisor Platform (SEI)
The Advisor has access to a variety of economic benefits, services, and products in
connection with its use of SEI’s investment adviser platform. The terms and availability of
these benefits vary among advisors on the SEI platform (including Concurrent) depending
on the business conducted with SEI and other factors. These services generally help
Concurrent conduct its advisory business, but each specific benefit does not necessarily
benefit each client.
Beyond access to SEI investment products, these include conferences, seminars and
other educational and networking activities, business entertainment, reimbursement of
travel and attendance expenses, research and other investment support services (such
as client proposal and other financial planning support), technical and operational
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solutions (including the SEI Wealth Platform), marketing assistance (including joint
marketing designed to promote SEI’ investment products), compliance services, human
resources consulting, risk management/insurance assistance, front office, middle office,
back office and other administrative support (including providing clerical staff to assist in
the completion of required paperwork), SEI attendance at client meetings, information
technology services, continuity and succession planning, access to financing and banking
options, trust services, portfolio reporting, automatic rebalancing, tax loss harvesting,
waiver or payment of certain fees (including paying account transfer fees or other charges
that Concurrent or its clients would incur when changing service providers), vendor
discounts, discount pricing on SEI services, and broader practice management consulting.
These benefits may be provided via SEI, its affiliates, or third parties and may be made
available to Concurrent at no fee, at a discounted fee, or via financial compensation
provided by SEI. Some of these offerings depend on Concurrent conducting a minimum
amount or type of current or expected future business with SEI, or having a minimum
account size or amount of assets under management with SEI or invested in SEI
investment products. Certain of these services or products, including those provided by or
paid for by SEI, may be used by Concurrent in connection with its general business
activities, in addition to supporting Concurrent’s interaction with SEI systems. The
benefits, services, products, or payments discussed herein may be significant to
Concurrent and create an incentive for the Concurrent to utilize SEI services or investment
products for its customers rather than other service providers or investment products.
However, Concurrent strives at all times to put the interests of its clients first, including
when selecting custodians or investment products for clients. Concurrent is independently
owned and operated; it is not affiliated with SEI.
Participation in Institutional Advisor Platform (Goldman Sachs)
Concurrent has established an institutional relationship with Goldman Sachs to assist the
Advisor in managing Client account[s]. As part of the arrangement, Goldman Sachs also
makes available to the Advisor, at no additional charge to the Goldman Sachs, certain
research and brokerage services, including research services obtained by Goldman
Sachs directly from independent research companies. The Advisor may also receive
additional services and support from Goldman Sachs. As a result of receiving such
services for no additional cost, the Advisor may have an incentive to continue to use or
expand the use of Goldman Sachs’s services. The Advisor examined this potential conflict
of interest when it chose to enter into the relationship with Goldman Sachs and has
determined that the relationship is in the best interests of the Advisor’s Clients and satisfies
its Client obligations, including its duty to seek best execution. Please see Item 12 above.
The Advisor receives access to software and related support without cost because the
Advisor renders investment management services to Clients that maintain assets at
Goldman Sachs. The software and related systems support may benefit the Advisor, but
not its Clients directly.
Reimbursements from Third-Parties to Concurrent
Concurrent receives reimbursements from third party product providers and their affiliates
(“Product Sponsors”) in connection with financial services and platform services offered
by Concurrent to our brokerage and advisory customers, including mutual funds and
exchange-traded funds.
Concurrent generally seeks to be reimbursed for the associated operational and/or
technology costs of adding and/or maintaining mutual funds and money market funds on
our platform. The flat fees are paid by the fund sponsor or affiliates and not the funds.
Financial advisors do not receive additional compensation from these companies for
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recommending funds that have reimbursed Concurrent for our costs.
In general, Product Sponsors pay third party compensation in addition to other product-
related fees paid by the investor, which include sale charges, deferred sale charges,
distribution and service fees, redemption fees, and other fees and expenses disclosed in
a product’s offering documents.
Product Sponsors pay Concurrent third party compensation for platform services,
marketing support, data analytics, and administrative services, among other reasons.
Concurrent provides fund families with opportunities to sponsor meetings and conferences
and grants them access to our branch offices and financial advisors for education,
marketing and other promotional efforts. Some fund representatives also work closely with
our branch offices and financial advisors to develop business strategies and plan
promotional events for clients, prospective clients, and educational activities. The amount
and form of third-party compensation paid by a Product Sponsor can vary depending on
many factors, including the services provided by Concurrent and the Product Sponsor’s
investment products.
Some fund families or their affiliates reimburse Concurrent for certain expenses incurred
in connection with these platform services, promotional efforts and/or training programs.
Fund families independently decide if and what they will spend on these activities, with
some fund families agreeing to make annual dollar amount expense reimbursement
commitments of up to $300,000, although actual reimbursements may be higher. Some
fund families also invite our financial advisors to attend fund family-sponsored events.
Expense payments may include meeting or conference facility rental fees and hotel, meal,
and travel charges.
Concurrent also provides fund families with the opportunity to purchase sales data
analytics. The amount of the fees depends on the level of data and ranges up to $200,000.
For an additional fee, fund families may purchase supplemental data analytics on other
financial product sales at Concurrent.
These reimbursements present potential conflicts of interest for Concurrent and our
financial advisors to the extent they lead us to focus on funds from those fund families that
commit significant financial and staffing resources to promotional and educational
activities and or purchase data analytics instead of funds from fund families that do not. In
order to mitigate this conflict, financial advisors do not receive additional compensation for
recommending funds sponsored by fund families that purchase data analytics.
Fund family representatives are allowed to provide funding for client/ prospect seminars,
employee education, and training event, occasional meals and entertainment, and gifts.
Concurrent’s non-cash compensation policies set conditions for these types of payments.
Client Referrals from Promoters
If a Client is introduced to the Advisor by either an unaffiliated or affiliated party (herein a
“Promoter”), the Advisor compensates that Promoter a fee in accordance with Rule 206(4)-
1 of the Advisers Act and any corresponding state securities requirements. Any such
compensation shall be paid solely from the investment advisory fees earned by the Advisor
and shall not result in any additional charge to the Client.
From time to time, the Advisor and/or its Advisory Persons enter into arrangements with
third parties for lead generation. These third parties typically operate as referral networks.
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Referral networks may present potential clients with a list of possible investment advisory
firms and investment adviser representatives, or may direct potential clients specifically
only to Concurrent and its Advisory Persons. Some referral networks receive a flat fee per
referral and/or an ongoing fee, while others share a portion of the ongoing advisory fees.
Clients and prospective clients are not charged any additional fee by the Advisor as a
result of its participation in these arrangements.
Referral arrangements give rise to material conflicts of interest because the referring party
has a financial incentive to introduce new clients to the Advisor and its Advisory Persons.
Clients who are introduced to the Advisor and its Advisory Persons through a referral
arrangement receive specific disclosures at the time of the introduction. Clients should
review those disclosures carefully to understand the details of the arrangements. The
Advisor’s participation in these referral arrangements does not diminish its fiduciary
obligations to its clients.
Financial Information
Neither Concurrent, nor its management, have any adverse financial situations that would
reasonably impair the ability of Concurrent to meet all obligations to its Clients. Neither
Concurrent, nor any of its Advisory Persons, have been subject to a bankruptcy or financial
compromise. Concurrent is not required to deliver a balance sheet along with this
Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for
services to be performed six months or more in the future.
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