Overview

Assets Under Management: $265 million
Headquarters: DULUTH, GA
High-Net-Worth Clients: 69
Average Client Assets: $3.6 million

Frequently Asked Questions

C.W. O'CONNER WEALTH ADVISORS, INC. charges 0.90% on the first $1 million, 0.70% on the next $2 million, 0.60% on the next $3 million, 0.50% on the next $10 million according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #125646), C.W. O'CONNER WEALTH ADVISORS, INC. is subject to fiduciary duty under federal law.

C.W. O'CONNER WEALTH ADVISORS, INC. is headquartered in DULUTH, GA.

C.W. O'CONNER WEALTH ADVISORS, INC. serves 69 high-net-worth clients according to their SEC filing dated February 18, 2026. View client details ↓

According to their SEC Form ADV, C.W. O'CONNER WEALTH ADVISORS, INC. offers financial planning, portfolio management for individuals, pension consulting services, and selection of other advisors. View all service details ↓

C.W. O'CONNER WEALTH ADVISORS, INC. manages $265 million in client assets according to their SEC filing dated February 18, 2026.

According to their SEC Form ADV, C.W. O'CONNER WEALTH ADVISORS, INC. serves high-net-worth individuals and pension and profit-sharing plans. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (ADV2A 12.2025)

MinMaxMarginal Fee Rate
$0 $1,000,000 0.90%
$1,000,001 $2,000,000 0.70%
$2,000,001 $3,000,000 0.60%
$3,000,001 $10,000,000 0.50%
$10,000,001 and above 0.40%

Minimum Annual Fee: $10,000

Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $32,000 0.64%
$10 million $57,000 0.57%
$50 million $217,000 0.43%
$100 million $417,000 0.42%

Clients

Number of High-Net-Worth Clients: 69
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 94.34%
Average Client Assets: $3.6 million
Total Client Accounts: 464
Discretionary Accounts: 460
Non-Discretionary Accounts: 4
Minimum Account Size: None

Regulatory Filings

CRD Number: 125646
Filing ID: 2050042
Last Filing Date: 2026-02-18 15:24:46

Form ADV Documents

Primary Brochure: ADV2A 12.2025 (2026-02-18)

View Document Text
C. W. O'Conner Wealth Advisors, Inc. 3175 Satellite Boulevard Suite 110 Duluth, GA 30096 Telephone: 770-368-9919 Facsimile: 770-368-9906 www.cwoconner.com February 15, 2026 FORM ADV PART 2A BROCHURE This brochure provides information about the qualifications and business practices of C. W. O'Conner Wealth Advisors, Inc. If you have any questions about the contents of this brochure, contact us at 770-368-9919. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about C. W. O'Conner Wealth Advisors, Inc. is available on the SEC's website at www.adviserinfo.sec.gov. C. W. O'Conner Wealth Advisors, Inc. is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1 Item 2 Summary of Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since the filing of our last annual updating amendment dated March 17, 2025, we have no material change to report. 2 Item 3 Table Of Contents Table of Contents Item 2 Summary of Material Changes ................................................................................................ 2 Item 3 Table Of Contents ................................................................................................................. 3 Item 4 Advisory Business ................................................................................................................ 4 Item 4 Advisory Fees ...................................................................................................................... 4 Item 5 Fees and Compensation ......................................................................................................... 6 Item 6 Performance-Based Fees and Side-By-Side Management ........................................................... 6 Item 7 Types of Clients .................................................................................................................... 6 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 7 Item 9 Disciplinary Information ........................................................................................................ 7 Item 10 Other Financial Industry Activities and Affiliation ................................................................... 7 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................. 8 Item 12 Brokerage Practices ............................................................................................................. 8 Item 13 Review of Accounts ............................................................................................................ 9 Item 14 Client Referrals and Other Compensation ............................................................................... 9 Item 15 Custody ............................................................................................................................. 9 Item 16 Investment Discretion ........................................................................................................ 10 Item 17 Voting Client Securities ..................................................................................................... 11 Item 18 Financial Information......................................................................................................... 11 Item 19 Requirements for State-Registered Advisers ......................................................................... 11 Item 20 Additional Information ...................................................................................................... 11 3 Item 4 Advisory Business C. W. O'Conner Wealth Advisors, Inc. is a registered investment adviser based in Duluth, Georgia. This firm is organized as a Sub S Corporation under the laws of the State of Georgia. We have been providing investment advisory services since 1995. Clifford W. O' Conner is our firm's principal owner. We are a fee-only independent financial adviser that provides wealth management services by incorporating financial planning, investment wealth management, and other aggregated financial services. The following describes our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to C. W. O'Conner Wealth Advisors, Inc. and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. You may see the term Associated Person in this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. Our wealth management service is tailored to meet our clients' needs and investment objectives. If you retain our firm for wealth management services, we meet to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We use the suitability information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our wealth management services, we may provide consulting services to you regarding real estate planning, income taxes, and other financial planning- related matters. Once we construct an investment portfolio for you, we monitor your portfolio's performance and rebalance the portfolio as required by changes in market conditions and in your financial circumstances when communicated to us by you. In lieu of our wealth management service, you may retain our firm's investment management service only. Our investment management service includes constructing an investment portfolio for you and monitoring and rebalancing your portfolio as required; however, it does not include any financial planning services. We may manage your portfolio on either a discretionary or non-discretionary basis. If you participate in our discretionary wealth management services, you grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the number of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing your restrictions and guidelines in writing. If you enter into a non-discretionary arrangement with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. As part of our investment advisory services, we may recommend you use the services of a third-party investment adviser ("TPA") to manage your entire, or a portion of your investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPA or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPA's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPA(s)' performance to ensure its management and investment style remain aligned with your investment goals and objectives. Our recommendations to use third party investment advisers are included in our portfolio management fee. We do not charge you a separate fee for the selection of other advisers nor will we share in the advisory fee you pay directly to the TPA. Item 4 Advisory Fees Advisory fees that you pay to the TPA are established and payable in accordance with the Form ADV Part 2 or other equivalent disclosure document provided by each TPA to whom you are referred. These fees may or may 4 not be negotiable. You should review the recommended TPA's brochure for information on its fees and services. Our fee for wealth management services is charged either as a fixed fee or a fee based on a percentage of your assets we manage. Our asset-based fees are set forth in the following fee schedule: Assets Under Management Annual Fee First $1,000,000 0.90% Next $1,000,000 0.70% Next $1,000,000 0.60% Next $7,000,000 0.50% Over $10,000,000 0 .40% The fee is negotiable depending on the scope and complexity of your situation, size of your portfolio, and frequency with which services are provided. Effective 01/01/2026 our minimum annual fee for new clients is $10,000. Existing clients will retain the fee schedule agreed upon at the original date of service. Prospective clients referred to us by existing clients may use the same fee schedule as the referring client. This may be relevant for existing clients who wish to refer their family members to our firm. Our annual wealth management fee is billed and payable quarterly in advance based on the value of your account on the last day of the previous quarter. We will send you an invoice for the payment of our advisory fee, or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. We will also receive a duplicate copy of your account statements. You may terminate the Investment and Wealth Management Agreement upon 30-days' written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the wealth management agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. If we recommend you use the services of a TPA, you may be required to sign an agreement directly with that TPA. You may terminate your advisory relationship with the TPA according to the terms of your agreement with the TPA. You should review each TPA's brochure for specific information on how you may terminate your advisory relationship with the TPA and how you may receive a refund, if applicable. Advisory Services to Retirement Plans and Plan Participants We offer various levels of advisory and consulting services to employee benefit plans ("Plan") and participants of such plans (“Participants”). The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Securities Act (“ERISA”). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below). The services we provide to your Plan and the compensation we receive for these services is described in the service 5 agreement previously signed. We do not reasonably expect to receive other compensation, direct or indirect, for services we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our fee from the plan or directs the plan record-keeper to issue payment for our fee out of the plan. If we receive other compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the amount of such compensation, services rendered for such compensation and the payer of such compensation. Status In providing services to the Plan and Participants, our status is that of an investment adviser registered under the Investment Advisers Act of 1940, and we are not subject to any disqualifications under Section 411 of ERISA. In performing fiduciary services, we are acting either as a non-discretionary fiduciary of the Plan as defined in Section 3(21) under ERISA, or as a discretionary fiduciary of the plan as defined in Section 3(38) under ERISA. Types of Investments We generally offer advice on equity securities, corporate debt securities (other than commercial paper), certificates of deposit, municipal securities, mutual fund shares, United States government securities, money market funds, REITs, ETFs and private placements. You may request we refrain from investing in certain types of securities. You must provide these restrictions to our firm in writing. Assets Under Management and Advisement As of December 2025, we managed a total of $264,615,105 in client assets of which $251,300,687 we provided continuous management services on a discretionary basis, and $13,314,418 on a non-discretionary basis. We also had $30,735,328 of assets under advisement. Item 5 Fees and Compensation Please refer to the "Advisory Business" section in this brochure for information on our advisory fees, fee deduction arrangements, and refund policy. Additional Fees and Expenses As part of our investment advisory services, we may invest, or recommend that you invest, in mutual funds and exchange traded funds. The fees you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You could also incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through whom your account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, please refer to the "Brokerage Practices" section of this brochure. Item 6 Performance-Based Fees and Side-By-Side Management We do not accept performance-based fees or participate in side-by-side management. Side-by-side management refers to the practice of managing accounts that charge performance-based fees while at the same time managing accounts that are not charged performance-based fees. Performance-based fees are fees that are based on a share of capital gains or capital appreciation of a client's account. Item 7 Types of Clients We offer investment advisory services to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. We generally do not require a minimum dollar amount to open and maintain an advisory account; however, we have the right to terminate your Account if it falls below a minimum size which, in our opinion, is too small to effectively manage. 6 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Our Methods of Analysis and Investment Strategies Our investment strategies and advice may vary depending upon each client's specific financial situation. We determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is important you notify us immediately with respect to any material changes to your financial circumstances, including for example, a change in your current or expected income level, tax circumstances, or employment status. Our strategies and investments may have unique and significant tax implications. Unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or other factors, we strongly recommend you continuously consult with a tax professional prior to and throughout the investing of your assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis of your investments. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, please provide written notice to our firm immediately and we will alert your account custodian of your individually selected accounting method. Decisions about cost basis accounting methods need to be made before trades settle, as the cost basis method cannot be changed after settlement. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Recommendation of Particular Types of Securities As disclosed under the "Advisory Business" section in this brochure, we recommend all types of securities, and we do not necessarily recommend one particular type of security over another since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. Item 9 Disciplinary Information Neither our firm nor any of our Associated Persons has any reportable disciplinary information. Item 10 Other Financial Industry Activities and Affiliation We have not provided information on other financial industry activities and affiliations because we do not have any affiliation, through control or ownership, with any of the types of entities listed below. 1. broker-dealer, municipal securities dealer, or government securities dealer or broker 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund) 3. other investment adviser or financial planner 4. futures commission merchant, commodity pool operator, or commodity trading advisor 5. banking or thrift institution 7 6. accountant or accounting firm 7. lawyer or law firm 8. insurance company or agency 9. pension consultant 10. real estate broker or dealer 11. sponsor or syndicator of limited partnerships Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Our Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect your interests and demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing. Associated Persons are expected to adhere to these guidelines. Our Code of Ethics requires that certain persons associated with our firm submit reports of their personal account holdings and transactions to a qualified representative of our firm who will review these reports on a periodic basis. Persons associated with our firm are also required to report violations of our Code of Ethics. We maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this brochure. Participation or Interest in Client Transactions Neither our firm nor our Associated Persons have material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities we recommend to you or securities in which you are invested. A conflict of interest exists in such cases because we could trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is our policy that our Associated Persons shall not have priority over your account in the purchase or sale of securities. Item 12 Brokerage Practices We recommend the brokerage and custodial services of Fidelity Brokerage Services LLC ("Fidelity"). We believe that the recommended broker-dealer/custodian provides quality execution services at competitive prices. Price is not the sole factor we consider in evaluating best execution. We consider the quality of the brokerage services provided by recommended broker-dealer/custodian, including the value of research provided, the firm's reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. In recognition of the value of research services and additional brokerage products and services the recommended broker-dealer/custodian provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere. Research and Other Services Fidelity provides our firm with access to its institutional trading and operations services, which are typically not available to Fidelity retail investors. Fidelity services may include research, brokerage, custody, access to mutual funds and other investments that are otherwise available only to institutional investors or would require significantly higher minimum initial investments. Fidelity also makes available to our firm other products and services that benefit our firm but may not benefit its clients' accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution, provide research, pricing information and other market data, facilitate payment of our firm's fees from 8 its clients' accounts, and assist with back-office support, recordkeeping and client reporting. The availability to our firm of the foregoing products and services is not contingent upon our firm committing to Fidelity any specific amount of business (assets in custody or trading). Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Directed Brokerage Some clients may instruct our firm to use one or more brokers for the transactions in their accounts. If you choose to direct our firm to use a particular broker, you should understand that this might prevent our firm from aggregating trades with other client accounts. This practice may also prevent our firm from obtaining favorable net price and execution. Thus, when directing brokerage business, you should consider whether the commission expenses, execution, clearance, and settlement capabilities that you will obtain through your broker are adequately favorable in comparison to those that we would otherwise obtain for you. Block Trades We combine multiple orders for shares of the same securities purchased for non-discretionary and discretionary advisory accounts we manage (this practice is commonly referred to as "block trading"). We distribute a portion of the shares to participating accounts in a fair and equitable manner. Subject to our discretion regarding factual and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. In the event an order is partially filled, the shares will be allocated to participating accounts in a fair and equitable manner, typically in proportion to the size of each client’s order. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. Item 13 Review of Accounts Clifford W. O’Conner, Chief Compliance Officer and Kevin O’Conner, monitor your accounts on an ongoing basis. Investment guidelines are agreed upon between you and our firm at the outset of the agreement and are changed when you communicate there are material changes in your circumstances. All accounts are reviewed at least quarterly to maintain the agreed upon investment allocations. Factors such as portfolio size, transaction activity, maturities, contributions, withdrawals and market activity may affect the frequency of reviews. We maintain client records on Tamarac Software. Performance reports are provided to clients daily via the portal provided by Tamarac. Since portfolios are maintained electronically, reports are available upon request. Additional reporting capabilities are available. You may receive reports from TPAs in accordance with your agreement with the TPA. You will receive trade confirmations and monthly or quarterly statements from your account custodian(s). Item 14 Client Referrals and Other Compensation We do not receive any compensation from any third party in connection with providing investment advice to you nor do we compensate any individual or firm for client referrals. Item 15 Custody As paying agent for our firm, your independent custodian will directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees 9 deducted from your account(s) each billing period. You should carefully review account statements for accuracy. If you have a question regarding your account statement or if you did not receive a statement from your custodian, please contact us directly at the telephone number on the cover page of this brochure. Trustee Services Persons associated with our firm may serve as trustees to certain accounts for which we also provide investment advisory services. In all cases, the people associated with our firm have been appointed trustee as a result of a family or personal relationship with the trust grantor and/or beneficiary and not as a result of employment with our firm. Therefore, we are not deemed to have custody over the advisory accounts for which persons associated with our firm serve as trustee. Use of Client Log-in Credentials Our firm or associated persons may be in possession of client log-on information to the client's investment accounts. In general, where our account access gives us the ability to control client funds and securities, we are deemed to have custody. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer or other independent, qualified custodian. Wire Transfer and/or Standing Letter of Authorization Our firm may affect wire transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, as long as the client has provided us with written authorization to do so. Such written authorization is known as a Standing Letter of Authorization. An adviser with authority to conduct such third-party wire transfers has access to the client's assets and therefore has custody of the client's assets in any related accounts. We do not have to obtain a surprise annual audit, as we otherwise would be required to by reason of having custody, if we meet the following criteria: 1. You provide written, signed instruction to the qualified custodian that includes the third party’s name and address or account number at a custodian; 2. You authorize us in writing to direct transfers to the third party either on a specified schedule or from time to time; 3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a transfer of funds notice to you promptly after each transfer; 4. You can terminate or change the instruction; 5. We have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party; 6. We maintain records showing that the third party is not a related party to us nor located at the same address as us; and 7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. We hereby confirm that we meet the above criteria. Item 16 Investment Discretion Before we can buy or sell securities on your behalf, you must first sign our discretionary management agreement, a power of attorney, and/or trading authorization forms. You may grant our firm discretion over the selection and number of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. You may specify investment objectives, guidelines, and/or impose certain conditions or investment parameters for your account(s). For example, you may specify that the investment in any stock or industry should not exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions in the securities of a specific industry or security. Please refer to the "Advisory Business" section in this brochure for more information on our 10 discretionary management services. If you enter non-discretionary arrangements with our firm, we will obtain your approval prior to the execution of any transactions for your account(s). You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Item 17 Voting Client Securities We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. If we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitation to vote proxies. Item 18 Financial Information We are not required to provide financial information to our clients because we do not: • require the prepayment of more than $1,200 in fees and six or more months in advance, or • take custody of client funds or securities, or • have a financial condition likely to impair our ability to meet our commitments to you. Item 19 Requirements for State-Registered Advisers We are a federally registered investment adviser; therefore, we are not required to respond to this item. Item 20 Additional Information Your Privacy We view protecting your private information as a top priority. Pursuant to applicable privacy requirements, we have instituted policies and procedures to ensure that we keep your personal information private and secure. We do not disclose any nonpublic personal information about you to nonaffiliated third parties, except as permitted by law. While servicing your account, we may share information with our service providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and attorneys. We restrict internal access to nonpublic personal information about you to employees who need that information to provide products or services to you. We maintain physical and procedural safeguards that comply with regulatory standards to guard your nonpublic personal information and to ensure our integrity and confidentiality. We will not sell information about you or your accounts to anyone. We do not share your information unless it is required to process a transaction, at your request, or required by law. You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our firm. Thereafter, we deliver a copy of the current privacy policy notice to you on an annual basis. Please contact our main office (number on first page of this brochure) if you have any questions regarding this policy. Trade Errors In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. If a trade error results in a profit, the profit is donated to a charitable organization selected by the custodian. 11 Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation. We do not initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. IRA Rollover Considerations As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of: 1. Leaving the funds in your employer's (former employer's) plan. 2. Moving the funds to a new employer’s retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider before you do so: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs of those products and services. 3. Our strategy may have higher risk than the option(s) provided to you in your plan. 4. Your current plan may also offer financial advice. 5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA. 12 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important you understand the differences between these types of accounts and decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. 13