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Form ADV Part 2A – Disclosure Brochure
Item 1: Cover Page
Cypress Wealth Services, LLC
Effective: February 2025
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
Phone: (760) 834-7250
http://CypressWS.com
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of
Cypress Wealth Services, LLC (“Cypress” or the “Advisor”). If you have any questions about the contents of this
Disclosure Brochure, please contact us at (760) 834-7250.
Cypress is a registered investment advisor with the 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 through Cypress to assist you in determining whether to retain the Advisor.
Additional information about Cypress and its advisory persons are available on the SEC’s website at
www.adviserinfo.sec.gov by searching with our firm name or our CRD# 288992.
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 advisory
personnel of Cypress.
Cypress believes that communication and transparency are the foundation of its relationship with Clients and will
continually strive to provide its Clients with complete and accurate information at all times. Cypress encourages all
current and prospective Clients to read this Disclosure Brochure and discuss any questions you may have with us.
And of course, we always welcome your feedback.
Material Change
Since our last annual amendment filed on 02/07/2024, we have the following material change(s) to report.
• We have started subscribing to a proxy monitor and voting agent service offered by Broadridge Investor
Communication Solutions, Inc. (“Broadridge”), which includes access to proxy analyses with research
and vote recommendations. Please see Item 17 for additional information.
• We have also arranged for Broadridge to provide class action litigation monitoring and securities claim
filing administration services if you choose to participate in this service. For this service, Broadridge
charges a contingency fee of 20% of the amount of each claim settlement award, which is deducted from
your award at the time of payment. There are no minimum fees or other fees deducted from an account
related to this service. Regardless of whether you choose to utilize the services of Broadridge, we do not
monitor or file claims on your behalf. Please see Item 17 for additional information.
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Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents ..................................................................................................................................... 3
Item 4 – Advisory Services .................................................................................................................................... 4
A. Firm Information ............................................................................................................................................................ 4
B. Advisory Services Offered ............................................................................................................................................ 4
C. Client Account Management ......................................................................................................................................... 6
D. Wrap Fee Programs ..................................................................................................................................................... 6
E. Assets Under Management .......................................................................................................................................... 6
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services ........................................................................................................................................... 6
B. Fee Billing ..................................................................................................................................................................... 7
C. Other Fees and Expenses ............................................................................................................................................ 8
D. Advance Payment of Fees and Termination ................................................................................................................. 8
E. Compensation for Sales of Securities ........................................................................................................................... 8
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9
Item 7 – Types of Clients ....................................................................................................................................... 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 9
A. Methods of Analysis ...................................................................................................................................................... 9
B. Risk of Loss .................................................................................................................................................................. 9
Item 9 – Disciplinary Information ........................................................................................................................ 13
Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 13
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 13
A. Code of Ethics............................................................................................................................................................. 13
B. Personal Trading with Material Interest ....................................................................................................................... 13
C. Personal Trading in Same Securities as Clients ......................................................................................................... 13
D. Personal Trading at Same Time as Client .................................................................................................................. 13
Item 12 – Brokerage Practices ............................................................................................................................ 14
A. Recommendation of Custodian[s] ............................................................................................................................... 14
B. Aggregating and Allocating Trades ............................................................................................................................. 14
Item 13 – Review of Accounts ............................................................................................................................. 15
A. Frequency of Reviews ................................................................................................................................................ 15
B. Causes for Reviews .................................................................................................................................................... 15
C. Review Reports ........................................................................................................................................................... 15
Item 14 - Client Referrals and Other Compensation ......................................................................................... 15
A. Compensation Received by Cypress .......................................................................................................................... 15
B. Client Referrals from Solicitors.................................................................................................................................... 16
Item 15 – Custody ................................................................................................................................................. 16
Item 16 – Investment Discretion ......................................................................................................................... 16
Item 17 – Voting Client Securities ...................................................................................................................... 17
Item 18 – Financial Information .......................................................................................................................... 18
Form ADV Part 2B – Brochure Supplements .................................................................................................... 19
Privacy Policy ....................................................................................................................................................... 38
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Item 4 – Advisory Services
A. Firm Information
Cypress Wealth Services, LLC (“Cypress” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”), which is organized as a limited liability company under the laws of
the State of California. Cypress was founded in June 2017 and is owned by Christian B. Risenmay, David R.
Thatcher, and Stephen (Ross) Biesinger indirectly through their personal holding companies. This Disclosure
Brochure provides information regarding the qualifications, business practices, and the advisory services provided
by Cypress.
For questions regarding this Disclosure Brochure, please contact Marc Koven, Chief Compliance Officer at (760)
834-7250.
B. Advisory Services Offered
Cypress offers investment advisory services to high net worth individuals, families, trusts, estates, and businesses
(each referred to as a “Client”). Cypress provides comprehensive investment management, planning and
consulting services tailored to the individual needs of each Client.
Investment Advisory Services
Cypress provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management, planning and related
advisory services. Cypress typically offers these as a bundled advisory engagement, but may, in certain
circumstances, offer as individual services. Cypress works closely with each Client to develop an investment
strategy that seeks to achieve the goals of the Client.
Internal Investment Management - Cypress customizes its investment management services for its Clients.
Portfolios are primarily constructed using mutual funds, exchange-traded funds (“ETFs”), individual stocks and
fixed income securities. For certain Clients, the Advisor may also utilize alternative investments and other types of
investments, as appropriate, to meet the needs of particular Clients. The Advisor generally constructs portfolios in
alignment with its internal strategies, but may retain legacy securities due to portfolio fit and tax considerations.
Cypress evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Cypress’s investment strategy is primarily long-term focused, but the Advisor may buy, sell or
re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market
conditions. If it is consistent with the Client’s goals, the Advisor may also engage in an investment strategy that
utilizes frequent trading in securities, please see Item 8 for more information. Cypress will construct, implement
and monitor the Client’s 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.
Cypress, in its discretion, may redistribute investment allocations to diversify the portfolio. Cypress may
recommend specific positions to increase sector or asset class weightings. The Advisor may recommend
employing cash positions as a possible hedge against market movement. Cypress 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 Client, generating cash to meet Client needs, or any risk deemed unacceptable
for the Client’s risk tolerance.
Cypress will provide investment management and related advisory services. At no time will Cypress accept or
maintain custody of a Client’s funds or securities, except for authorized deduction of the Advisor’s fees and
dispersing client funds to a third party under a standing letter of instruction. All Client assets will be managed within
their designated account[s] at the Custodian, pursuant to the investment advisory agreement.
Use of Independent Managers - Cypress may recommend to Clients that all or a portion of their investment portfolio
be implemented by utilizing one or more unaffiliated money managers or investment platforms (collectively
“Independent Managers”). Independent Managers may be sourced directly or accessed through an investment
management platform or directly engaged by the Advisor. The Client will be required to enter into a separate
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agreement with the Independent Manager[s] or an agreement with Cypress that outlines the Independent
Manager[s]’ fees. Please see Item 10 for additional information.
Cypress serves as the Client’s primary advisor and relationship manager. However, the Independent Manager[s]
will assume discretionary authority for the day-to-day investment management of those assets placed in their
control. Cypress will assist and advise the Client in establishing investment objectives for their account[s], the
selection of the Independent Manager[s], and defining any restrictions on the account[s]. Cypress will continue to
provide oversight of the Client’s account[s] and ongoing monitoring of the activities of these unaffiliated parties.
The Independent Manager[s] will implement the selected investment strategies based on their investment
mandates. The Client may be able to impose reasonable investment restrictions on these accounts, subject to the
acceptance of these third parties. Cypress does not receive any compensation from these Independent Managers
or Investment Platforms, other than its investment advisory fee (described in Item 5).
Financial Planning and Consulting Services
Cypress will typically provide a variety of financial planning services to Clients as part of the investment advisory
engagement or as a separate engagement. Services are offered in several areas of a Client’s financial situation,
depending on their goals, objectives and financial situation.
Generally, such financial planning services will involve preparing a financial plan or rendering a 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, estate planning,
personal savings, education savings 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. Cypress may also refer Clients
to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning
engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and
recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans
or consultations are typically completed within six months of contract date, assuming all information and documents
requested are provided promptly.
Financial planning and consulting recommendations may pose a potential conflict between the interests of the
Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor would pose a conflict, as it
would increase the 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.
Retirement Plan Consulting Services
Cypress provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally,
such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing
their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising
could include: investment options, plan structure and participant education. Retirement Plan Consulting services
typically include:
•
• Establishing an Investment Policy Statement – Cypress will assist in the development of a statement that
summarizes the investment goals and objectives along with the broad strategies to be employed to meet
the objectives.
Investment Options – Cypress will work with the Plan Sponsor to evaluate existing investment options and
make recommendations for appropriate changes.
•
• Asset Allocation and Portfolio Construction – Cypress will develop strategic asset allocation models to aid
Participants in developing strategies to meet their investment objectives, time horizon, financial situation
and tolerance for risk.
Investment Monitoring – Cypress will monitor the performance of the investments and notify the client in
the event of over/underperformance and in times of market volatility.
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In providing services for retirement plan consulting, Cypress does not provide any advisory services with respect
to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded
REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window
programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the
applicable state laws regulating retirement consulting services. This applies to Client accounts that are retirement
or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”). If the Client accounts are part of a Plan, and Cypress accepts appointment to provide services
to such accounts, Cypress acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of
ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services
described therein.
C. Client Account Management
Prior to engaging Cypress to provide investment advisory services, each Client is required to enter into one or
more advisory agreements 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 – Cypress, in connection with the Client, will develop an investment
strategy targeted to achieve the Client’s investment goals and objectives.
• Asset Allocation – Cypress 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.
• Portfolio Construction – Cypress will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
•
Investment Management and Supervision – Cypress will provide investment management and ongoing
oversight of the Client’s portfolio.
• Financial Planning and Consulting – For Clients engaging for investment advisory services, the Advisor
provides ongoing financial planning and related services regarding the Client’s overall financial situation.
D. Wrap Fee Programs
Cypress does not manage or place Client assets into a wrap fee program.
E. Assets Under Management
Cypress managed $965,541,741 on a discretionary basis as of December 31st, 2024.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client shall sign one or more agreements that detail the responsibilities of Cypress and the Client.
A. Fees for Advisory Services
Investment Advisory Services
Investment advisory fees are paid quarterly, at the end of each calendar quarter, pursuant to the terms of the
investment advisory agreement. Investment advisory fees are typically based on the average daily ending market
value of assets under management during the calendar quarter and will not exceed 1.50%. The investment advisory
fee charged will depend on the size of the Client relationship, the scope/complexity of services to be provided, and
other factors. Certain illiquid securities that do not have daily valuations will be billed based upon the most recently
available valuation.
The investment 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. Certain Clients may have a fixed
annual fee or fixed rate fee or a fee schedule that differs from above. The Client’s fees will take into consideration the
aggregate assets under management with Advisor. Investment advisory fees include financial planning and
consulting services, unless separately engaged for those services. All securities held in accounts managed by
Cypress will be independently valued by the Custodian. Cypress will not have the authority or responsibility to value
portfolio securities.
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The Client may make additions or withdrawals from the account[s] at any time, subject to the Advisor’s right to
terminate an account or the overall relationship. Additions may be in cash or securities provided that the Advisor
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 Cypress, subject to the usual and customary securities
settlement procedures. However, the Advisor typically designs its investment portfolios as long-term investments and
the withdrawal of assets may impair the achievement of a Client’s investment objectives. Cypress may consult the
Client about the implications of such transactions. Clients are advised that when such securities are liquidated, they
may be subject to securities transaction fees, short-term redemption fees, and/or tax ramifications. Cypress bills on
cash unless indicated otherwise in writing.
Use of Independent Managers
For Client account[s] implemented through an Independent Manager, the Client’s overall fees will include Cypress’s
investment advisory fee (as noted above) plus advisory fees and/or platform fees charged by the Independent
Manager[s], as applicable. The selected Independent Manager[s]’ advisory fees and/or platform fees shall not exceed
1.00%. The Independent Manager may assume responsibility for calculating the Client’s fees and deduct their fees
from the Client’s account[s].
Financial Planning and Consulting Services
Financial planning and consulting services may be included as part of an overall wealth management engagement
or provided as a stand-alone engagement. For spearate engagements, financial planning and consulting services
are offered at an hourly rate or for a fixed engagement. Fees are based on the experience of the person performing
the services, the complexity of the services to be provided and the duration of the engagement. Hourly engagements
are billed at a rate of up to $350 per hour or a fixed engagement fee. Fixed fee engagements are based on the
estimated number of hours to complete the service as the Advisor’s hourly rate. An estimate for total hours and/or
costs will be determined prior to engaging for these services. The Advisor’s fee is exclusive of, and in addition to,
brokerage fees, transaction fees, and other related costs and expenses, which may be incurred by the Client.
However, the Advisor shall not receive any portion of these commissions, fees, and costs.
Retirement Plan Consulting Services
Retirement plan consulting services are provided as a stand-alone engagement. The Advisor’s fee is exclusive of,
and in addition to, brokerage fees, transaction fees, and other related costs and expenses, which may be incurred by
the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs.
B. Fee Billing
Investment Advisory Services
Investment advisory fees will be 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] at the respective quarter-end date. The amount due is calculated by applying the quarterly
rate (annual rate divided by 4) to the average daily ending market value of assets under management during the
previous calendar quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting
deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as
listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide
written authorization permitting Cypress to be paid directly from their accounts held by the Custodian as part of the
investment advisory agreement and separate account forms provided by the Custodian.
Use of Independent Managers
Client account[s] implemented through Independent Manager[s] will be billed in accordance to the separate
agreement[s] with Cypress or the Independent Manager[s]. These parties’ fees are separate from and in addition
to the fee Cypress charges and discloses in our firm management agreement.
Financial Planning and Consulting Services
Financial planning and consulting fees are invoiced up to 50% upon the execution of the financial planning or
consulting agreement with the balance due upon completion of the engagement deliverable[s]. Flat fees range from
$500 to $10,000. The ultimate fee charged is based on the scope and complexity of our engagement with the client.
Our firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6 months.
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Retirement Plan Consulting Services
Retirement Plan Consulting fees are based on the percentage of Plan assets under management and will not exceed
1.50%.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Cypress, 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 including fees for trading away from the primary Custodian. The investment advisory fee
charged by Cypress is separate and distinct from these custody and execution fees. Charles Schwab & Co., Inc.
(“Schwab”) does not charge transaction fees for U.S. listed equities and exchange traded funds.
In addition, all fees paid to Cypress 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. The Client should review both the fees charged by the fund[s] and the fees charged by Cypress to
fully understand the total fees to be paid.
D. Payment of Fees and Termination
Investment Advisory Services
Cypress is compensated for its investment advisory services at the end of the quarter, after services are rendered.
Either party may request to terminate the investment advisory agreement with Cypress, at any time, by providing
advance written notice to the other party. The Client shall be responsible for investment advisory fees up to and
including the effective date of termination. Upon notice of termination, pro-rata advisory fees for services rendered to
the point of termination will be charged. If advisory fees cannot be deducted, the Advisor will send an invoice for due
advisory fees to the Client.
Use of Independent Managers
In the event that a Client should wish to terminate their relationship with an Independent Manager, the terms for
termination will be set forth in the respective agreements between the Client and Cypress or the Independent
Manager. Cypress will assist the Client with the termination and transition as appropriate.
Financial Planning and Consulting Services
The Advisor is partially compensated for its financial planning and consulting services upon execution of the
engagement agreement. Either party may terminate a planning agreement, at any time, by providing written notice to
the other party. Upon termination, the Client shall be responsible for fees based on the hours worked by the Advisor
or the percentage of the engagement completed. Upon termination, any unearned prepaid fees will be promptly
refunded to the Client. The Client’s financial planning agreement with the Advisor is non-transferable without the
Client’s prior consent.
Retirement Plan Consulting Services
The fee-paying arrangements will be determined on a case-by-case basis by the third party recordkeeper or
administrator and will be detailed in the signed consulting agreement.
E. Compensation for Sales of Securities
Advisory Persons of Cypress may also be registered representatives of M.S. Howells & Co. In one’s separate capacity
as registered representative, an Advisory Person may implement securities transactions on a commission basis
through M.S. Howells & Co. In such instances, an 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 an Advisory Person in their capacity as a registered representative is separate and in
addition to Cypress’s advisory fees. This practice presents a conflict of interest as an Advisory Person may have an
incentive to effect securities transactions for the purpose of generating commissions rather than solely based on
Client needs. To mitigate this conflict, Clients are under no obligation, contractually or otherwise, to purchase
securities products through one of our Advisory Persons. Further, Cypress will not charge an ongoing investment
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advisory fee on any assets implemented in the separate capacity of one of our Advisory Persons. Please see Item
10.
Advisory Persons may also be licensed as independent insurance professionals. Advisory persons will earn
commission-based compensation for selling insurance products, including insurance products they sell to you.
Insurance commissions earned by an Advisory Person is separate and in addition to Cypress’s advisory fees. This
practice presents a conflict of interest as an Advisory Person may have an incentive to recommend insurance
products for the purpose of generating commissions rather than solely based on Client needs. Clients are under no
obligation, contractually or otherwise, to purchase insurance products through any person affiliated with the Advisor.
Item 6 – Performance-Based Fees and Side-By-Side Management
Cypress does not charge performance-based fees for its investment advisory services. The fees charged by
Cypress are as described in “Item 5 – Fees and Compensation” above and are not based upon the capital
appreciation of the funds or securities held by any Client.
Cypress does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or
a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
Cypress offers investment advisory services to high net worth individuals, families, trusts, estates, and businesses.
The relative percentage of each type of Client is available in Cypress’s Form ADV Part 1. These percentages will
change over time. Cypress does not impose a size for establishing a relationship, but does tailor its services to
high net worth Clients.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Cypress primarily employs fundamental analysis methods in developing investment strategies for its Clients.
Research and analysis from Cypress is derived from numerous sources, including financial media companies,
third-party research materials, Internet sources, and review of company activities, including annual reports,
prospectuses, press releases and research prepared by others.
As noted above, Cypress generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. Cypress 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, Cypress 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.
B. Risks
Investment Risk
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. Cypress 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.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria
are generally 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. 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
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analysis of a Client's account. 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.
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.
Credit Risk
Credit risk can be a factor in situations where an investment’s performance relies on a borrower’s repayment of
borrowed funds. With credit risk, an investor can experience a loss or unfavorable performance if a borrower does
not repay the borrowed funds as expected or required. Investment holdings that involve forms of indebtedness (i.e.
borrowed funds) are subject to credit risk.
Interest Rate Risk
Certain investments involve the payment of a fixed or variable rate of interest to the investment holder. Once an
investor has acquired or has acquired the rights to an investment that pays a particular rate (fixed or variable) of
interest, changes in overall interest rates in the market will affect the value of the interest-paying investment(s)
they hold. In general, changes in prevailing interest rates in the market will have an inverse relationship to the
value of existing, interest paying investments. In other words, as interest rates move up, the value of an instrument
paying a particular rate (fixed or variable) of interest will go down. The reverse is generally true as well.
Liquidity Risk:
Certain assets may not be readily converted into cash or may have a very limited market in which they trade. This
can create a substantial delay in the receipt of proceeds from an investment. Liquidity risk can also result in
unfavorable pricing when exiting (i.e. not being able to quickly get out of an investment before the price drops
significantly) a particular investment and therefore, can have a negative impact on investment returns.
Margin Transactions: Cypress may purchase securities for your portfolio with money borrowed from a Client’s
brokerage account. This allows the Client to purchase more stock than the Client would be able to with their
available cash and allows Cypress to purchase securities without selling other holdings. Margin accounts and
transactions are risky and not necessarily appropriate for every Client. It should be noted that Cypress bills advisory
fees on securities purchased on margin which creates a financial incentive for Cypress to utilize margin in client
accounts.
The potential risks associated with these transactions are (1) Clients can lose more funds than are deposited into
the margin account; (2) the forced sale of securities or other assets in the Client’s account; (3) the sale of securities
or other assets without contacting the Client; (4) Client may not be entitled to choose which securities or other
assets in their account(s) are liquidated or sold to meet a margin call; and (5) custodians charge interest on margin
balances which will reduce their returns over time.
Options: An option is a financial derivative that represents a contract sold by one party (the option writer) to another
party (the option holder, or option buyer). The contract offers the buyer the right, but not the obligation, to buy or
sell a security or other financial asset at an agreed-upon price (the strike price) during a certain period of time or
on a specific date (exercise date). Options are extremely versatile securities. Traders use options to speculate,
which is a relatively risky practice, while hedgers use options to reduce the risk of holding an asset. In terms of
speculation, option buyers and writers have conflicting views regarding the outlook on the performance of a:
• Call Option: Call options give the option to buy at certain price, so the buyer would want the stock to go
up. Conversely, the option writer needs to provide the underlying shares in the event that the stock's market
price exceeds the strike due to the contractual obligation. An option writer who sells a call option believes
that the underlying stock's price will drop relative to the option's strike price during the life of the option, as
that is how he will reap maximum profit. This is exactly the opposite outlook of the option buyer. The buyer
believes that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock for a
lower price and then sell it for a profit. However, if the underlying stock does not close above the strike
price on the expiration date, the option buyer would lose the premium paid for the call option.
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• Put Option: Put options give the option to sell at a certain price, so the buyer would want the stock to go
down. The opposite is true for put option writers. For example, a put option buyer is bearish on the
underlying stock and believes its market price will fall below the specified strike price on or before a
specified date. On the other hand, an option writer who sells a put option believes the underlying stock's
price will increase about a specified price on or before the expiration date. If the underlying stock's price
closes above the specified strike price on the expiration date, the put option writer's maximum profit is
achieved. Conversely, a put option holder would only benefit from a fall in the underlying stock's price
below the strike price. If the underlying stock's price falls below the strike price, the put option writer is
obligated to purchase shares of the underlying stock at the strike price.
The potential risks associated with these transactions are that (1) all options expire. The closer the option gets to
expiration, the quicker the premium in the option deteriorates; and (2) Prices can move very quickly. Depending
on factors such as time until expiration and the relationship of the stock price to the option’s strike price, small
movements in a stock can translate into big movements in the underlying options.
Alternative Investments
Hedge funds, commodity pools, Real Estate Investment Trusts (“REITs”), Business Development Companies
(“BDCs”), and other alternative investments involve a high degree of risk and can be illiquid due to restrictions on
transfer and lack of a secondary trading market. They can be highly leveraged, speculative and volatile, and an
investor could lose all or a substantial amount of an investment. Alternative investments may lack transparency as
to share price, valuation and portfolio holdings. Complex tax structures often result in delayed tax reporting.
Compared to mutual funds, hedge funds and commodity pools are subject to less regulation and often charge
higher fees and may require “capital calls” which would require additional investment. Alternative investment
managers typically exercise broad investment discretion and may apply similar strategies across multiple
investment vehicles, resulting in less diversification.
Cryptocurrency Products
We may recommend investment in digital (crypto) currency products. These products may be an illiquid private
placement or structured as a trust or exchange traded fund which pool capital together to purchase holdings of
digital currencies or derivatives based on their value. Such products are extremely volatile and are suitable only
as a means of diversification for investors with high risk tolerances. Furthermore, these securities carry very high
internal expense ratios, and may use derivatives to achieve leverage or exposure in lieu of direct cryptocurrency
holdings. This can result in tracking error and may sell at a premium or discount to the market value of their
underlying holdings. Security is also a concern for digital currency investments which make them subject to the
additional risk of theft.
Private Funds
A private fund is an investment vehicle that pools capital from a number of investors and invests in securities and
other instruments. In almost all cases, a private fund is a private investment vehicle that is typically not registered
under federal or state securities laws. So that private funds do not have to register under these laws, issuers make
the funds available only to certain sophisticated or accredited investors and cannot be offered or sold to the general
public. Private funds are generally smaller than mutual funds because they are often limited to a small number of
investors and have a more limited number of eligible investors. Many but not all private funds use leverage as part
of their investment strategies. Private funds management fees typically include a base management fee along with
a performance component. In many cases, the fund’s managers may become “partners” with their clients by making
personal investments of their own assets in the fund. Most private funds offer their securities by providing an
offering memorandum or private placement memorandum, known as “PPM” for short.
The PPM covers important information for investors and investors should review this document carefully and should
consider conducting additional due diligence before investing in the private fund. The primary risks of private funds
include the following: (a) Private funds do not sell publicly and are therefore illiquid. An investor may not be able to
exit a private fund or sell its interests in the fund before the fund closes.; and (b) Private funds are subject to various
other risks, including risks associated with the types of securities that the private fund invests in or the type of
business issuing the private placement.
Municipal Bonds
Municipal bonds are debt obligations generally issued to obtain funds for various public purposes, including the
construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. Because
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of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax
return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same
general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk,
market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Investing in municipal bonds carries
risk unique to these types of bonds, which may include: (a) Legislative risk includes the risk that a change in the
tax code could affect the value of taxable or tax-exempt interest income.; (b) Municipal bonds generate tax-free
income, and therefore pay lower interest rates than taxable bonds. Investors who anticipate a significant drop in
their marginal income-tax rate may benefit from the higher yield available from taxable bonds.; (c) The risk that
investors may have difficulty finding a buyer when they want to sell and may be forced to sell at a significant
discount to market value. Liquidity risk is greater for thinly traded securities such as lower-rated bonds, bonds that
were part of a small issue, bonds that have recently had their credit rating downgraded or bonds sold by an
infrequent issuer. Municipal bonds may be less liquid than other bonds.; (d) Credit risk includes the risk that a
borrower will be unable to make interest or principal payments when they are due and therefore default. To reduce
investor concern, insurance policies that guarantee repayment in the event of default back many municipal bonds.
Debt Securities (Bonds):
Issuers use debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the
amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can
purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but rather are priced
at a discount from their face values and their values accrete over time to face value at maturity. The market prices
of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general,
market prices of debt securities decline when interest rates rise and increase when interest rates fall. Bonds with
longer rates of maturity tend to have greater interest rate risks.
Certain additional risk factors relating to debt securities include: (a) When interest rates are declining, investors
have to reinvest their interest income and any return of principal, whether scheduled or unscheduled, at lower
prevailing rates.; (b) Inflation causes tomorrow’s dollar to be worth less than today’s; in other words, it reduces the
purchasing power of a bond investor’s future interest payments and principal, collectively known as “cash flows.”
Inflation also leads to higher interest rates, which in turn leads to lower bond prices.; (c) Debt securities may be
sensitive to economic changes, political and corporate developments, and interest rate changes. Investors can
also expect periods of economic change and uncertainty, which can result in increased volatility of market prices
and yields of certain debt securities. For example, prices of these securities can be affected by financial contracts
held by the issuer or third parties (such as derivatives) relating to the security or other assets or indices. (d) Debt
securities may contain redemption or call provisions entitling their issuers to redeem them at a specified price on
a date prior to maturity. If an issuer exercises these provisions in a lower interest rate market, the account would
have to replace the security with a lower yielding security, resulting in decreased income to investors. Usually, a
bond is called at or close to par value. This subjects investors that paid a premium for their bond risk of lost
principal. In reality, prices of callable bonds are unlikely to move much above the call price if lower interest rates
make the bond likely to be called.; (e) If the issuer of a debt security defaults on its obligations to pay interest or
principal or is the subject of bankruptcy proceedings, the account may incur losses or expenses in seeking recovery
of amounts owed to it.; (f) There may be little trading in the secondary market for particular debt securities, which
may affect adversely the account's ability to value accurately or dispose of such debt securities. Adverse publicity
and investor perceptions, whether or not based on fundamental analysis, may decrease the value and/or liquidity
of debt securities.
Our firm attempts to reduce the risks described above through diversification of the client’s portfolio and by credit
analysis of each issuer, as well as by monitoring broad economic trends and corporate and legislative
developments, but there can be no assurance that our firm will be successful in doing so. Credit ratings for debt
securities provided by rating agencies reflect an evaluation of the safety of principal and interest payments, not
market value risk. The rating of an issuer is a rating agency's view of past and future potential developments related
to the issuer and may not necessarily reflect actual outcomes. There can be a lag between the time of
developments relating to an issuer and the time a rating is assigned and updated.
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.
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Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Cypress. Our backgrounds are on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD#
288992.
Item 10 – Other Financial Industry Activities and Affiliations
Broker-Dealer Affiliation
As noted in Item 5.E., Advisory Persons of Cypress are also registered representatives of M.S. Howells & Co. In
one’s separate capacity as a registered representative, an Advisory Person will typically receive commissions for
the implementation of recommendations for commissionable transactions. Clients are not obligated to implement
any recommendation provided by an Advisory Person. Neither the Advisor nor its Advisory Person will earn ongoing
investment advisory fees in connection with any products or services implemented in one’s separate capacity as
a registered representative.
Insurance Agency Affiliations
Advisory persons are also licensed insurance professionals. Implementations of insurance recommendations are
separate and apart an Advisory Person’s role with Cypress. As an insurance professional, one may receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by the Advisor or any of its Advisory Persons.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Cypress has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of
Ethics applies to all persons associated with Cypress (our “Supervised Persons”). The Code of Ethics was
developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client.
Cypress and its personnel owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of
Cypress 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 of Ethics covers a range of topics that address employee ethics and
conflicts of interest. To request a copy of our Code of Ethics, please contact us at (760) 834-7250.
B. Personal Trading with Material Interest
Cypress allows the purchase or sale of the same securities that may be recommended to and purchased on behalf
of Clients. Cypress does not act as principal in any transactions. In addition, the Advisor does not act as the
general partner of a fund, or advise an investment company. Cypress does not have a material interest in any
securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Cypress allows the purchase or sale of the same securities that may be recommended to and purchased on behalf
of Clients. Owning the same securities we recommend (purchase or sell) to you presents a potential conflict of
interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above,
we have adopted a Code of Ethics, which addresses insider trading (material non-public information controls) and
personal securities reporting procedures. When trading for personal accounts, Supervised Persons of Cypress
may have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its
Clients can potentially 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 Cypress requiring reporting of
personal securities trades by its employees for review by the Chief Compliance Officer (“CCO”). We have also
adopted written policies and procedures to detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Cypress allows the purchase or sale of the same securities that may be recommended to and purchased on
behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Cypress
transact in any security to the detriment of any Client.
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Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Cypress does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will select the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and
authorize Cypress to direct trades to this Custodian as agreed in the investment advisory agreement. Further,
Cypress does not have the discretionary authority to negotiate commissions on behalf of our Clients on a trade-
by-trade basis.
Where Cypress does not exercise discretion over the selection of the Custodian, it may recommend the Custodian
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 recommended by Cypress.
Cypress may recommend the Custodian based on criteria such as, but not limited to, reasonableness of
commissions charged to the Client, services made available to the Client, and its overall reputation. Cypress does
not receive research services, other products, or compensation as a result of recommending a particular broker-
dealer/custodian that may result in the Client paying higher commissions than those obtainable through other
broker-dealer/custodians. Cypress will generally recommend that Clients establish their account[s] at Charles
Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the
Client’s “qualified custodian”. Cypress maintains an institutional relationship with Schwab, whereby the Advisor
receives economic benefits from Schwab.
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 such parties in exchange for research and other services.
Schwab makes certain research and brokerage services available at no additional cost to our firm. Research
products and services provided by Schwab may include: research reports on recommendations or other
information about particular companies or industries; economic surveys, data and analyses; financial publications;
portfolio evaluation services; financial database software and services; computerized news and pricing services;
quotation equipment for use in running software used in investment decision-making; and other products or
services that provide lawful and appropriate assistance by Schwab to our firm in the performance of our investment
decision-making responsibilities. The aforementioned research and brokerage services qualify for the safe harbor
exemption defined in Section 28(e) of the Securities Exchange Act of 1934. However, the Advisor does receive
certain economic benefit from the Custodian as described in Item 14 below.
2. Brokerage Referrals - Cypress does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Cypress will place trades
within the established account[s] at the Custodian designated by the Client. In certain situations, the Client may
separately direct the Advisor to trade-away from the Custodian. Further, all Client accounts are traded within their
respective brokerage account[s], unless instructed otherwise by the Client. 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]). In
selecting the Custodian, Cypress 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.
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 order, 3) difficulty of execution, 4)
confidentiality and 5) skill required of the Custodian. Cypress will execute its transactions through the Custodian
as designated by the Client, unless otherwise instructed. Cypress may aggregate orders in a block trade or trades
when securities are purchased or sold through the same Custodian for multiple (discretionary) accounts. 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 particular Client
accounts.
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Item 13 – Review of Accounts
A. Frequency of Reviews
Investments in Client accounts are monitored on a regular and continuous basis by Principals of Cypress and
periodicially by the CCO. Formal reviews are generally conducted at least annually or more or less 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 or less 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 Cypress 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 no less than 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 Cypress
Participation in Schwab’s Institutional Advisor Platform
Cypress has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like Cypress. As a registered investment
advisor participating on the Schwab Advisor Services platform, Cypress 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. In addition, Schwab has agreed to provide transition assistance by covering
ACT fees for Clients who custody with Schwab.
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Cypress
that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting
services and discounts for various service providers. In addition, Schwab has offered Cypress up to $60,000 in
marketing, technology, consulting, and research expenses based on the amount of assets custodied at Schwab.
Schwab also covers ACAT fees for Clients who join Schwab’s platform. Access to these services creates a financial
Page 15
incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. Cypress believes,
however, that the selection of Schwab as Custodian is in the best interests of its Clients.
Product Sponsors and Other Service Providers
Representatives of our firm will occasionally accept speaking arrangements provided by product sponsors and
other service providers for no cost. Such arrangements are not directly dependent upon the recommendation of
any specific product. Although we may be incentivized to recommend products from product sponsors that provide
speaking arrangements, our representatives will always adhere to their fiduciary duty in recommending appropriate
investments for our clients.
B. Client Referrals from Solicitors
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide cash or non-
cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include
client referrals).
Item 15 – Custody
All of our clients receive account statements directly from their qualified custodians at least quarterly upon opening
of an account. If our firm decides to also send account statements to clients, such notice and account statements
include a legend that recommends that the client compare the account statements received from the qualified
custodian with those received from our firm.
The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under the Investment
Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that
an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”)
is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our
custodian, Schwab:
• The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature,
the third party’s name, and either the third party’s address or the third party’s account number at a
custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or
separately, to direct transfers to the third party either on a specified schedule or from time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as a signature
review or other method to verify the client’s authorization, and provides a transfer of funds notice to the
client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified custodian.
• The investment adviser has no authority or ability to designate or change the identity of the third party, the
address, or any other information about the third party contained in the client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party of the
investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and
an annual notice reconfirming the instruction.
Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our
custodial recommendations.
Item 16 – Investment Discretion
Cypress generally has discretion 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 Cypress.
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 Cypress will be in accordance with each Client's investment objectives
and goals.
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Item 17 – Voting Client Securities
SEC Rule 206(4)-6 requires investment advisers who have voting authority with respect to securities held in their
clients’ accounts to monitor corporate actions and vote proxies in their clients’ interests. Cypress is required by the
SEC to adopt written policies and procedures, make those policies and procedures available to clients, and retain
certain records with respect to proxy votes cast.
Cypress considers proxy voting an important right of Clients as shareholders and believe that reasonable care and
diligence must be taken to ensure that such rights are properly and timely exercised. Clients have the option of
providing Cypress with the authority to vote proxies. When Cypress has discretion to vote the proxies of Clients,
our firm will vote those proxies in the Client’s best interests and in accordance with these policies and procedures.
Clients may request a copy of our written policies and procedures regarding proxy voting and/or information on
how particular proxies were voted by contacting our Chief Compliance Officer, Marc Koven, by phone at
760.834.7219 or email at Marc@cypressWS.com.
Policy for Voting Proxies
All proxies received by our firm will be given to our Chief Compliance Officer or designated person for processing.
Our Chief Compliance Officer will determine which accounts managed by our firm hold the security to which the
proxy relates. These accounts and their share holdings will be matched to the proxies received for each security.
Missing proxies or significant variances in shares held will be investigated.
A grid of securities being voted will be updated with each proxy being voted. The grid will also contain a list of
clients with the security voted upon. Our Chief Compliance Officer will review each item for voting on each proxy.
Based on our proxy voting guidelines outlined below, a determination of how our firm votes will be made. Proxies
will generally be voted online unless custodian requires mailed forms. In the absence of standing voting guidelines
from the client, our firm will vote proxies in accordance with Board recommendation.
Our firm seeks to ensure compliance with the new Exchange Act Rule 14a-11. In accordance with the
aforementioned rule, our firm provides shareholders with the opportunity to nominate directors at a shareholder
meeting under the applicable state or foreign law. Clients also have the ability to have their nominees included in
the company proxy materials sent to all of our shareholders. Furthermore, the clients as shareholders also have
the ability to use the shareholder proposal process to establish procedures for the inclusion of shareholder director
nominations in company proxy materials.
Proxies Voting Guidelines
Our firm subscribes to a proxy monitor and voting agent service offered by Broadridge Investor Communication
Solutions, Inc. (“Broadridge”), which includes access to proxy analyses with research and vote recommendations.
Where voting authority exists, proxies are voted by our firm according to Board recommendations in categories
listed below among others unless not deemed to be in the best interests of the client:
•
•
for directors and for management on routine matters;
for a limit on or reduction of the number of directors, and for an increase in the number of directors on a
case by case basis;
• against the creation of a tiered board;
•
•
•
•
•
•
•
for the elimination of cumulative voting;
for independence of auditors;
for deferred compensation;
for profit sharing plans;
for stock option plans unless the plan could result in material dilution to shares outstanding or is excessive;
for stock repurchases;
for an increase in authorized shares unless the authorization effectively results in a blind investment pool
for shareholders;
for reductions in the par value of stock;
for company name changes;
for routine appointments of auditors.
•
•
•
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Our firm abstains on motions to limit directors' liability. Material issues not addressed above (e.g., mergers, poison
pills, social investing and miscellaneous shareholder proposals) are dealt with on a case-by-case basis.
Our firm will defer to instruction from clients in all voting matters. Records of all issues and votes are maintained
and reported to clients as requested.
Our firm recognizes that under certain circumstances our firm may have a conflict of interest between us and our
clients. Such circumstances may include, but are not limited to, situations where our firm or one or more of our
affiliates, including officers, directors and employees, has or is seeking a client relationship with the issuer of the
security that is the subject of the proxy vote. Our firm shall periodically inform our employees that they are under
an obligation to be aware of the potential for conflicts of interest on the part of our firm with respect to voting proxies
on behalf of funds, both as a result of our employee’s personal relationships and due to circumstances that may
arise during the conduct of our business, and to bring conflicts of interest of which they become aware to the
attention of the proxy manager. Our firm shall not vote proxies relating to such issuers on behalf of client accounts
until our firm has determined that the conflict of interest is not material or a method of resolving such conflict of
interest has been agreed upon by our management team. A conflict of interest will be considered material to the
extent that it is determined that such conflict has the potential to influence our decision-making in voting a proxy.
Materiality determinations will be based upon an assessment of the particular facts and circumstances. If our firm
determines that a conflict of interest is not material, our firm may vote proxies notwithstanding the existence of a
conflict. If the conflict of interest is determined to be material, the conflict shall be disclosed to our management
team and our firm shall follow the instructions of the management team.
Our Chief Compliance Officer will maintain files relating to our proxy voting procedures. Records will be maintained
and preserved for 5 years from the end of the fiscal year during which the last entry was made on a record, with
records for the last two years kept on our premises. Records of the following will be included in the files:
• a copy of each proxy statement that our firm receives, provided however that our firm may rely on obtaining
a copy of proxy statements from the SEC’s EDGAR system for those proxy statements that are available;
• a record of each vote that our firm casts;
• a copy of any document our firm created that was material to making a decision how to vote proxies, or
that memorializes that decision;
• a copy of each written client request for information on how our firm voted such client’s proxies, and a copy
of any written response to any client request for information on how our firm voted their proxies.
Our written policies and procedures regarding proxy voting are disclosed here. Information on how particular
proxies were voted may contact our Chief Compliance Officer.
Our firm does not pay for proxy voting services with soft dollars. Also, our firm does not charge an additional fee
to vote proxies.
Class Action Litigation
We have arranged for Broadridge to provide class action litigation monitoring and securities claim filing
administration services if you choose to participate in this service. For this service, Broadridge charges a
contingency fee of 20% of the amount of each claim settlement award, which is deducted from your award at the
time of payment. There are no minimum fees or other fees deducted from an account related to this service.
Regardless of whether you choose to utilize the services of Broadridge, we do not monitor or file claims on your
behalf.
Item 18 – Financial Information
Neither Cypress, nor its management, have any adverse financial situations that would reasonably impair the ability
of Cypress to meet all obligations to its Clients. Neither Cypress, nor any of its advisory persons, has been subject
to a bankruptcy or financial compromise. Cypress is not required to deliver a balance sheet along with this
Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months
or more in advance.
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Form ADV Part 2B – Brochure Supplement
for
Stephen (Ross) Biesinger
Partner & Senior Financial Advisor
Effective: April 2021
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Stephen R. Biesinger (CRD# 4689955) in addition to the information contained in the Cypress Wealth Services,
LLC (“Cypress” or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Cypress Disclosure Brochure or this
Brochure Supplement, please contact us at (760) 834-7250.
Additional information about Mr. Biesinger is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4689955.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
Phone: (760) 834-7250
http://CypressWS.com
Page 19
Item 2 – Educational Background and Business Experience
Stephen (Ross) Biesinger, born in 1978, is dedicated to advising clients as a Partner & Senior Financial Advisor
with Cypress Wealth Services. Mr. Biesinger earned a Bachelor of Science degree in Business Finance with a
minor in Economics from Brigham Young University in 2003. Additional information regarding Mr. Biesinger’s
employment history is included below.
Employment History:
07/2017 to Present
04/2021 to Present
04/2014 to 04/2021
04/2014 to 07/2017
Partner & Senior Financial Advisor, Cypress Wealth Services, LLC
Registered Representative, M.S. Howells & Co.
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Vice President & Senior Financial Advisor, Integrated Wealth Management,
Inc.
Financial Advisor, Morgan Stanley & Co. Incorporated
Financial Advisor, Merrill Lynch, Pierce, Fenner & Smith Incorporated
09/2008 to 04/2014
05/2004 to 09/2008
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures regarding
this Item. However, we do encourage you to independently view the background of Mr. Biesinger on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his
Individual CRD# 4689955.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Biesinger is also a registered representative of M.S. Howells & Co. M.S. Howells & Co. is a registered broker-
dealer, member FINRA, SIPC. In Mr. Biesinger’s separate capacity as a registered representative, Mr. Biesinger
will typically receive commissions for the implementation of recommendations for commissionable transactions.
Clients are not obligated to implement any recommendation provided by Mr. Biesinger. Neither the Advisor nor Mr.
Biesinger will earn ongoing investment advisory fees in connection with any products or services implemented in
Mr. Biesinger’s separate capacity as a registered representative.
Insurance Agency Affiliations
Mr. Biesinger is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart Mr. Biesinger’s role with Cypress. As an insurance professional, Mr. Biesinger may receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. Biesinger is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Biesinger or the Advisor.
Item 5 – Additional Compensation
Mr. Biesinger has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Biesinger serves as a Partner and Senior Financial Advisor of Cypress and is supervised by Marc Koven, the
Chief Compliance Officer. Mr. Koven can be reached at (760) 834-7250.
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 20
Form ADV Part 2B – Brochure Supplement
for
Clark S. Penney
Partner & Senior Financial Advisor
Effective: March 2024
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Clark
S. Penney (CRD# 5539813) in addition to the information contained in the Cypress Wealth Services, LLC
(“Cypress” or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the Cypress Disclosure Brochure or this Brochure
Supplement, please contact us at (760) 834-7250.
Additional information about Mr. Penney is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5539813.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
3620 Penland Parkway, Anchorage, AK 99508
Phone: (760) 834-7250
http://CypressWS.com
Page 21
Item 2 – Educational Background and Business Experience
Clark S. Penney, born in 1985, is dedicated to advising clients as a Partner & Senior Financial Advisor with Cypress
Wealth Services. Mr. Penney earned a Bachelor of Science degree in Business Management with a Minor in
Economics from Southern Oregon University in 2007. Additional information regarding Mr. Penney’s employment
history is included below.
Employment History:
07/2017 to Present
05/2021 to 12/2022
01/2019 to Present
04/2021 to Present
04/2014 to 04/2021
04/2014 to 07/2017
Partner & Senior Financial Advisor, Cypress Wealth Services, LLC
President, Penney Energy
President, Penney Capital, Inc.
Registered Representative, M.S. Howells & Co.
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Vice President & Senior Financial Advisor,
Integrated Wealth Management, Inc.
Financial Advisor, Morgan Stanley & Co. Incorporated
Financial Advisor, Merrill Lynch, Pierce, Fenner & Smith Incorporated
09/2008 to 04/2014
06/2008 to 09/2008
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures regarding
this Item. However, we do encourage you to independently view the background of Mr. Penney on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 5539813.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Penney is also a registered representative of M.S. Howells & Co. M.S. Howells & Co. is a registered broker-
dealer, member FINRA, SIPC. In Mr. Penney’s separate capacity as a registered representative, Mr. Penney will
typically receive commissions for the implementation of recommendations for commissionable transactions. Clients
are not obligated to implement any recommendation provided by Mr. Penney. Neither the Advisor nor Mr. Penney
will earn ongoing investment advisory fees in connection with any products or services implemented in Mr.
Penney’s separate capacity as a registered representative.
Insurance Agency Affiliations
Mr. Penney is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart Mr. Penney’s role with Cypress. As an insurance professional, Mr. Penney may receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. Penney is not required to offer the products of any particular insurance company. Commissions generated
by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Penney or the Advisor.
Business Development Consulting
Mr. Penney is President of Penney Capital, Inc., which provides business/economic development consulting
services. A conflict of interest may arise as a result because Mr. Penney may have an incentive to recommend
Penney Capital, Inc.’s services to Cypress’s clients for additional compensation. To mitigate this conflict, Mr.
Penney will act in the client’s best interest. Furthermore, any services that may be offered through Penney Capital,
Inc. will remain separate from our firm’s advisory services and governed under a separate agreement. Penney
Capital, Inc. will not actively solicit our clients.
Item 5 – Additional Compensation
Mr. Penney has additional business activities that are detailed in Item 4 above.
Page 22
Item 6 – Supervision
Mr. Penney serves as a Partner & Senior Financial Advisor with Cypress and is supervised by Marc Koven, the
Chief Compliance Officer. Mr. Koven can be reached at (760) 834-7250.
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 23
Form ADV Part 2B – Brochure Supplement
for
Christian B. Risenmay, CFP®
Partner & Senior Financial Advisor
Effective: February 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Christian B. Risenmay (CRD# 4534437) in addition to the information contained in the Cypress Wealth Services,
LLC (“Cypress” or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Cypress Disclosure Brochure or this
Brochure Supplement, please contact us at (760) 834-7250.
Additional information about Mr. Risenmay is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4534437.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
Phone: (760) 834-7250
http://CypressWS.com
Page 24
Item 2 – Educational Background and Business Experience
Christian B. Risenmay, CFP®, born in 1977, is dedicated to advising clients as a Partner and Senior Financial
Advisor with Cypress Wealth Services. Mr. Risenmay earned a Bachelor of Science degree in Finance from
Brigham Young University in 2002. Additional information regarding Mr. Risenmay’s employment history is included
below.
Employment History:
07/2017 to Present
04/2021 to 07/2024
04/2014 to 04/2021
04/2014 to 07/2017
Partner & Senior Financial Advisor, Cypress Wealth Services, LLC
Registered Representative, M.S. Howells & Co.
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Senior Vice President & Financial Advisor,
Integrated Wealth Management, Inc.
Financial Advisor, Morgan Stanley & Co. Incorporated
Financial Advisor, Merrilly Lynch, Pierce, Fenner & Smith Incorporated
09/2008 to 04/2014
07/2002 to 09/2008
Certified Financial Planner ("CFP®")
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have
States.
obtained
CFP® certification
in
the
United
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP Board’s studies have determined as necessary for the competent and professional delivery
of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject
areas include insurance planning and risk management, employee benefits planning, investment planning,
income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered
in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability
to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real
world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
CFP® professionals.
practice
outlining
the
ethical
and
standards
for
Individuals who become certified must complete the following ongoing education and ethics requirements in order
to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
– Renew
an
agreement
to
be
bound
by
the Standards
• Ethics
of Professional
Conduct. The Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in
the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP® certification.
Page 25
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures regarding
this Item. However, we do encourage you to independently view the background of Mr. Risenmay on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his
Individual CRD# 4534437.
Item 4 – Other Business Activities
Mr. Risenmay does not have any other business activities to disclose.
Item 5 – Additional Compensation
Mr. Risenmay does not have any additional compensation to disclose.
Item 6 – Supervision
Mr. Risenmay serves as a Partner & Senior Financial Advisor of Cypress and is supervised by Marc Koven, the
Chief Compliance Officer. Mr. Koven can be reached at (760) 834-7250.
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 26
Form ADV Part 2B – Brochure Supplement
for
David R. Thatcher, CFP®
Partner & Senior Financial Advisor
Effective: April 2021
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of David
R. Thatcher (CRD# 5518858) in addition to the information contained in the Cypress Wealth Services, LLC
(“Cypress” or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the Cypress Disclosure Brochure or this Brochure
Supplement, please contact us at (760) 834-7250.
Additional information about Mr. Thatcher is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5518858.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
Phone: (760) 834-7250
http://CypressWS.com
Page 27
Item 2 – Educational Background and Business Experience
David R. Thatcher, CFP®, born in 1972, is dedicated to advising clients as a Partner & Senior Financial Advisor
with Cypress Wealth Services. Mr. Thatcher earned a Bachelor of Science degree from Utah State University in
1997. Additional information regarding Mr. Thatcher’s employment history is included below.
Employment History:
07/2017 to Present
04/2021 to Present
04/2014 to 04/2021
04/2014 to 07/2017
Partner & Senior Financial Advisor, Cypress Wealth Services, LLC
Registered Representative, M.S. Howells & Co.
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Vice President & Senior Financial Advisor,
Integrated Wealth Management, Inc.
Financial Advisor, Morgan Stanley & Co. Incorporated
Financial Advisor, Merrill Lynch, Pierce, Fenner & Smith Incorporated
09/2008 to 04/2014
04/2008 to 09/2008
Certified Financial Planner ("CFP®")
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have
States.
obtained
CFP® certification
in
the
United
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP Board’s studies have determined as necessary for the competent and professional delivery
of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject
areas include insurance planning and risk management, employee benefits planning, investment planning,
income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered
in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability
to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real
world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
CFP® professionals.
practice
outlining
the
ethical
and
standards
for
Individuals who become certified must complete the following ongoing education and ethics requirements in order
to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
– Renew
an
agreement
to
be
bound
by
the Standards
• Ethics
of Professional
Conduct. The Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in
the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP® certification.
Page 28
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures regarding
this Item. However, we do encourage you to independently view the background of Mr. Thatcher on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 5518858.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Thatcher is also a registered representative of M.S. Howells & Co. M.S. Howells & Co. is a registered broker-
dealer, member FINRA, SIPC. In Mr. Thatcher’s separate capacity as a registered representative, Mr. Thatcher
will typically receive commissions for the implementation of recommendations for commissionable transactions.
Clients are not obligated to implement any recommendation provided by Mr. Thatcher. Neither the Advisor nor Mr.
Thatcher will earn ongoing investment advisory fees in connection with any products or services implemented in
Mr. Thatcher’s separate capacity as a registered representative.
Insurance Agency Affiliations
Mr. Thatcher is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart Mr. Thatcher’s role with Cypress. As an insurance professional, Mr. Thatcher may receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. Thatcher is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Thatcher or the Advisor.
Item 5 – Additional Compensation
Mr. Thatcher has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Thatcher serves as a Partner & Senior Financial Advisor of Cypress and is supervised by Marc Koven, the
Chief Compliance Officer. Mr. Koven can be reached at (760) 834-7250.
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 29
Form ADV Part 2B – Brochure Supplement
for
Marc E. Koven
Chief Compliance Officer
Senior Financial Advisor
Effective: April 2021
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Marc
E. Koven (CRD# 4916658) in addition to the information contained in the Cypress Wealth Services, LLC (“Cypress”
or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure
or if you have any questions about the contents of the Cypress Disclosure Brochure or this Brochure Supplement,
please contact us at (760) 834-7250.
Additional information about Mr. Koven is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4916658.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
Phone: (760) 834-7250
http://CypressWS.com
Page 30
Item 2 – Educational Background and Business Experience
Marc E. Koven, born in 1977, is dedicated to advising clients as the Chief Compliance Officer and Senior Financial
Advisor of Cypress Wealth Services. Mr. Koven earned a Bachelor of Arts degree in Business Administration with
a Minor in Finance from California State University, San Bernardino in 2004. Additional information regarding Mr.
Koven’s employment history is included below.
Employment History:
07/2017 to Present
Chief Compliance Officer & Senior Financial Advisor,
Cypress Wealth Services, LLC
04/2021 to Present
Registered Representative, M.S. Howells & Co.
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
04/2014 to 04/2021
Vice President & Senior Financial Advisor, Integrated Wealth Management, Inc. 04/2014 to 07/2017
05/2005 to 04/2014
Financial Advisor, Morgan Stanley & Co. Incorporated
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures regarding
this Item. However, we do encourage you to independently view the background of Mr. Koven on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 4916658.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Koven is also a registered representative of M.S. Howells & Co. M.S. Howells & Co. is a registered broker-
dealer, member FINRA, SIPC. In Mr. Koven’s separate capacity as a registered representative, Mr. Koven will
typically receive commissions for the implementation of recommendations for commissionable transactions. Clients
are not obligated to implement any recommendation provided by Mr. Koven. Neither the Advisor nor Mr. Koven
will earn ongoing investment advisory fees in connection with any products or services implemented in Mr. Koven’s
separate capacity as a registered representative.
Insurance Agency Affiliations
Mr. Koven is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart Mr. Koven’s role with Cypress. As an insurance professional, Mr. Koven may receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr.
Koven is not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending certain
products of the insurance companies. Clients are under no obligation to implement any recommendations made
by Mr. Koven or the Advisor.
Item 5 – Additional Compensation
Mr. Koven has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Koven serves as the Chief Compliance Officer and a Senior Financial Advisor of Cypress. Mr. Koven can be
reached at (760) 834-7250. Cypress has implemented a Code of Ethics and internal compliance that guide each
Supervised Person in meeting their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to
regulatory oversight by various agencies. These agencies require registration by Cypress and its Supervised
Persons. As a registered entity, Cypress is subject to examinations by regulators, which may be announced or
unannounced. Cypress is required to periodically update the information provided to these agencies and to provide
various reports regarding the business activities and assets of the Advisor.
Page 31
Form ADV Part 2B – Brochure Supplement
for
Jason M. Nettleton
Senior Vice President
Financial Advisor
Effective: April 2021
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Jason
M. Nettleton (CRD# 4084405) in addition to the information contained in the Cypress Wealth Services, LLC
(“Cypress” or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the Cypress Disclosure Brochure or this Brochure
Supplement, please contact us at (760) 834-7250.
Additional information about Mr. Nettleton is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4084405.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
Phone: (760) 834-7250
http://CypressWS.com
Page 32
Item 2 – Educational Background and Business Experience
Jason M. Nettleton, born in 1975, is dedicated to advising clients as a Senior Vice President and Financial Advisor
with Cypress Wealth Services. Mr. Nettleton earned a Bachelor of Arts degree in Business Administration from
University of San Diego in 2004. Additional information regarding Mr. Nettleton’s employment history is included
below.
Employment History:
Senior Vice President and Financial Advisor, Cypress Wealth Services, LLC
Registered Representative, M.S. Howells & Co.
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Senior VP Financial Advisor, Integrated Wealth Management, Inc.
Financial Consultant, Fidelity Investments
07/2017 to Present
04/2021 to Present
10/2016 to 04/2021
06/2016 to 07/2017
11/2005 to 06/2016
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Nettleton. Mr. Nettleton has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Nettleton.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Nettleton.
However, we do encourage you to independently view the background of Mr. Nettleton on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
4084405.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Nettleton is also a registered representative of M.S. Howells & Co. M.S. Howells & Co. is a registered broker-
dealer, member FINRA, SIPC. In Mr. Nettleton’s separate capacity as a registered representative, Mr. Nettleton
will typically receive commissions for the implementation of recommendations for commissionable transactions.
Clients are not obligated to implement any recommendation provided by Mr. Nettleton. Neither the Advisor nor Mr.
Nettleton will earn ongoing investment advisory fees in connection with any products or services implemented in
Mr. Nettleton’s separate capacity as a registered representative.
Insurance Agency Affiliations
Mr. Nettleton is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart Mr. Nettleton’s role with Cypress. As an insurance professional, Mr. Nettleton may receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. Nettleton is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Nettleton or the Advisor.
Item 5 – Additional Compensation
Mr. Nettleton has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Nettleton serves as a Senior Vice President and Financial Advisor of Cypress and is supervised by Marc Koven,
the Chief Compliance Officer. Mr. Koven can be reached at (760) 834-7250.
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
Page 33
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 34
Form ADV Part 2B – Brochure Supplement
for
Penny E. Salamida
Senior Vice President
Financial Advisor
Effective: April 2021
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Penny E. Salamida (CRD# 2475366) in addition to the information contained in the Cypress Wealth Services, LLC
(“Cypress” or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the Cypress Disclosure Brochure or this Brochure
Supplement, please contact us at (760) 834-7250.
Additional information about Ms. Salamida is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 2475366.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
Phone: (760) 834-7250
http://CypressWS.com
Page 35
Item 2 – Educational Background and Business Experience
Penny E. Salamida, born in 1967, is dedicated to advising clients as a Senior Vice President & Financial Advisor
with Cypress Wealth Services. Additional information regarding Ms. Salamida’s employment history is included
below.
Employment History:
Senior Vice President & Financial Advisor, Cypress Wealth Services, LLC
Registered Representative, M.S. Howells & Co.
Registered Representatiave, Purshe Kaplan Sterling Investments, Inc.
Client Service Coordinator, Integrated Wealth Management
Registered Representatiave, Morgan Stanley
08/2017 to Present
04/2021 to Present
12/2013 to 04/2021
11/2013 to 08/2017
06/2009 to 10/2013
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Salamida. Ms. Salamida has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Ms. Salamida.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Ms. Salamida.
However, we do encourage you to independently view the background of Ms. Salamida on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
2475366.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Ms. Salamida is also a registered representative of M.S. Howells & Co. M.S. Howells & Co. is a registered broker-
dealer, member FINRA, SIPC. In Ms. Salamida’s separate capacity as a registered representative, Ms. Salamida
will typically receive commissions for the implementation of recommendations for commissionable transactions.
Clients are not obligated to implement any recommendation provided by Ms. Salamida. Neither the Advisor nor
Ms. Salamida will earn ongoing investment advisory fees in connection with any products or services implemented
in Ms. Salamida’s separate capacity as a registered representative.
Insurance Agency Affiliations
Ms. Salamida is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart Ms. Salamida’s role with Cypress. As an insurance professional, Ms. Salamida may receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Ms. Salamida is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Ms. Salamida or the Advisor.
Item 5 – Additional Compensation
Ms. Salamida has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Ms. Salamida serves as a Senior Vice President & Financial Advisor of Cypress and is supervised by Marc Koven,
the Chief Compliance Officer. Mr. Koven can be reached at (760) 834-7250.
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Page 36
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 37
Form ADV Part 2B – Brochure Supplement
for
Gregory Frech, CRPC®
Managing Director
Effective: April 2021
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Gregory Frech, CRPC® (CRD# 2945802) in addition to the information contained in the Cypress Wealth Services,
LLC (“Cypress” or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Cypress Disclosure Brochure or this
Brochure Supplement, please contact us at (760) 834-7250.
Additional information about Mr. Frech is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2945802.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
Phone: (760) 834-7250
http://CypressWS.com
Page 38
Item 2 – Educational Background and Business Experience
Gregory Frech, CRPC®, born in 1976, is dedicated to advising clients as a Managing Director with Cypress Wealth
Services. Mr. Frech earned a Bachelor of Science degree in Organizational Leadership from Biola in 2005.
Additional information regarding Mr. Frech’s employment history is included below.
Employment History:
Managing Director, Cypress Wealth Services, LLC
Registered Representative, M.S. Howells & Co.
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Financial Advisor, Morgan Stanley
01/2019 to Present
04/2021 to Present
01/2019 to 04/2021
01/2009 to 01/2019
Chartered Retirement Planning Counselor (CRPC®)
The CRPC® is offered by The College for Financial Planning®. The CRPC® Program focuses on the pre- and post-
retirement needs of individuals. Enrollment in the program guides you through the retirement process, addressing
issues such as estate planning and asset management. The College for Financial Planning® awards the Chartered
Retirement Planning CounselorSM and CRPC® designation to students who: successfully complete the program;
pass the final examination; and comply with the Code of Ethics, which includes agreeing to abide by the Standards
of Professional Conduct promulgated by The College for Financial Planning®. Applicants must also disclose of any
criminal, civil, self-regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to
their professional or business conduct. Conferment of the designation is contingent upon the College for Financial
Planning’s review of matters either self-disclosed or which are discovered by the College that are required to be
disclosed. Successful students receive a certificate and are granted the right to use the designation on
correspondence and business cards for a two-year period. Continued use of the CRPC® designation is subject to
ongoing renewal requirements. Every two years individuals must renew their right to continue using the CRPC®
designation by: completing 16 hours of continuing education and reaffirming to abide by the Standards of
Professional Conduct, Terms and Conditions, and self-disclose any criminal, civil, self-regulatory organization, or
governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct.
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures regarding
this Item. However, we do encourage you to independently view the background of Mr. Frech on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 2945802.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Frech is also a registered representative of M.S. Howells & Co. M.S. Howells & Co. is a registered broker-
dealer, member FINRA, SIPC. In Mr. Frech’s separate capacity as a registered representative, Mr. Frech will
typically receive commissions for the implementation of recommendations for commissionable transactions. Clients
are not obligated to implement any recommendation provided by Mr. Frech. Neither the Advisor nor Mr. Frech will
earn ongoing investment advisory fees in connection with any products or services implemented in Mr. Frech’s
separate capacity as a registered representative.
Insurance Agency Affiliations
Mr. Frech is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart Mr. Frech’s role with Cypress. As an insurance professional, Mr. Frech may receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr.
Frech is not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending certain
products of the insurance companies. Clients are under no obligation to implement any recommendations made
by Mr. Frech or the Advisor.
Page 39
Item 5 – Additional Compensation
Mr. Frech has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Frech serves as a Managing Director of Cypress and is supervised by Marc Koven, the Chief Compliance
Officer. Mr. Koven can be reached at (760) 834-7250.
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 40
Form ADV Part 2B – Brochure Supplement
for
Bradley Arave, CFP®
Senior Vice President
Financial Advisor
Effective: April 2021
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Bradley Arave, CFP® (CRD# 5482571) in addition to the information contained in the Cypress Wealth Services,
LLC (“Cypress” or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Cypress Disclosure Brochure or this
Brochure Supplement, please contact us at (760) 834-7250.
Additional information about Mr. Arave is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5482571.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
17581 Irvine Boulevard, Suite 208, Tustin, CA 92780
Phone: (760) 834-7250
http://CypressWS.com
Page 41
Item 2 – Educational Background and Business Experience
Bradley Arave, CFP®, born in 1982, is dedicated to advising clients as a Senior Vice President & Financial Advisor
with Cypress Wealth Services. Mr. Arave earned a Bachelor of Arts degree in Business Administration from
Brigham Young University in 2007. Additional information regarding Mr. Arave’s employment history is included
below.
Employment History:
Financial Advisor, Cypress Wealth Services, LLC
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Vice President, JP Morgan
Financial Advisor, Merrill Lynch
01/2019 to Present
01/2019 to 04/2021
05/2011 to 01/2019
01/2008 to 05/2011
Certified Financial Planner ("CFP®")
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have
States.
obtained
CFP® certification
in
the
United
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP Board’s studies have determined as necessary for the competent and professional delivery
of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject
areas include insurance planning and risk management, employee benefits planning, investment planning,
income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered
in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability
to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real
world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
CFP® professionals.
practice
outlining
the
ethical
and
standards
for
Individuals who become certified must complete the following ongoing education and ethics requirements in order
to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
– Renew
an
agreement
to
be
bound
by
the Standards
• Ethics
of Professional
Conduct. The Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in
the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP® certification
Page 42
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures regarding
this Item. However, we do encourage you to independently view the background of Mr. Arave on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 5482571.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Arave is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart Mr. Arave’s role with Cypress. As an insurance professional, Mr. Arave may receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr.
Arave is not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending certain
products of the insurance companies. Clients are under no obligation to implement any recommendations made
by Mr. Arave or the Advisor.
Item 5 – Additional Compensation
Mr. Arave has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Arave serves as a Senior Vice President & Financial Advisor of Cypress and is supervised by Marc Koven, the
Chief Compliance Officer. Mr. Koven can be reached at (760) 834-7250.
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 43
Form ADV Part 2B – Brochure Supplement
for
Carey McCrady
Financial Advisor
Effective: May 2023
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Carey
McCrady (CRD# 5192241) in addition to the information contained in the Cypress Wealth Services, LLC (“Cypress”
or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure
or if you have any questions about the contents of the Cypress Disclosure Brochure or this Brochure Supplement,
please contact us at (760) 834-7250.
Additional information about Mr. McCrady is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or her Individual CRD# 5192241.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
Phone: (760) 834-7250
http://CypressWS.com
Page 44
Item 2 – Educational Background and Business Experience
Carey McCrady, born in 1969, is dedicated to advising clients as a Financial Advisor with Cypress Wealth Services.
Mr. McCrady graduated from Changler Gilbert Community College and Western International University. We may
list any professional designations held by Mr. McCrady. We must provide you with a sufficient explanation of the
minimum qualifications required for each designation to allow you to understand the value of the designation.
Additional information regarding Mr. McCrady’s employment history is included below.
Employment History:
Financial Advisor, Cypress Wealth Services, LLC
Advisor, Watts Gwilliam and Associates
Investment Advisor Representative, CSM Financial Planning
05/2023 to Present
12/2019 to 04/2023
07/2016 to 12/2019
Certified Financial Planner ("CFP®")
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have
States.
obtained
CFP® certification
in
the
United
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP Board’s studies have determined as necessary for the competent and professional delivery
of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject
areas include insurance planning and risk management, employee benefits planning, investment planning,
income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered
in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability
to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real
world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
CFP® professionals.
practice
outlining
the
ethical
and
standards
for
Individuals who become certified must complete the following ongoing education and ethics requirements in order
to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
– Renew
an
agreement
to
be
bound
by
the Standards
• Ethics
of Professional
Conduct. The Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in
the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP® certification.
Page 45
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures regarding
this Item. However, we do encourage you to independently view the background of Mr. McCrady on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual
CRD# 7493992.
Item 4 – Other Business Activities
Mr. McCrady does not have any other business activities to disclose.
Item 5 – Additional Compensation
Mr. McCrady has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. McCrady serves as a Financial Advisor of Cypress and is supervised by Marc Koven, the Chief Compliance
Officer. Mr. Koven can be reached at (760) 834-7250.
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 46
Form ADV Part 2B – Brochure Supplement
for
James Watson
Financial Advisor
Effective: September 2024
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
James Watson (CRD# 5962288) in addition to the information contained in the Cypress Wealth Services, LLC
(“Cypress” or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the Cypress Disclosure Brochure or this Brochure
Supplement, please contact us at (760) 834-7250.
Additional information about Mr. Watson is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5962288.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
17581 Irvine Boulevard, Suite 208, Tustin, CA 92780
Phone: (760) 834-7250
http://CypressWS.com
Page 47
Item 2 – Educational Background and Business Experience
James Watson, born in 1973, is dedicated to advising clients as a Financial Advisor with Cypress Wealth Services.
Mr. Watson earned a Bachelor of Science degree in Business Administration from Califonria State University,
Chico in 2000. Additional information regarding Mr. Watson’s employment history is included below.
Employment History:
Financial Advisor, Cypress Wealth Services, LLC
Registered Representative, LPL Financial
Unemployed
Sales Director, Wells Fargo Asset Management
09/2024 to Present
06/2019 to 09/2024
01/2019 to 05/2019
06/2006 to 12/2018
Certified Exit Planning Advisor (CEPA)
The CEPA designation is made available through the Exit Planning Institute (“EPI”). Candidates must have or be:
(1) 5 years of full-time or equivalent experience working directly with business owners as a financial advisor,
attorney, CPA, business broker, investment banker, commercial lender, estate planner, insurance professional,
business consultant or in a related capacity; (2) Undergraduate degree from a qualifying institution; if no qualifying
degree must submit additional professional work experience (2 years of relevant professional experience may be
substituted for each year of required undergraduate studies); and (3) Exit Planning Institute member in good
standing. The CEPA Program offers professionals an innovative learning experience, performance-enhancing
resources, and the strategic tools to help advance their exit planning practice.
Renewing certificants must have completed a minimum of 40 hours of exit planning related professional
development, or a minimum of 30 hours of exit planning related professional development plus 10 hours of
qualifying leadership, authorship, and teaching activities contributing to the exit planning profession. Qualifying
leadership activities include volunteer service as a chairman, Chair-Elect, or officer for committee service to a
qualifying organization other than the applicant's employer. Renewal applicants must again agree in writing that
they will adhere to the EPI Professional Standards and Code of Ethics, and must re-attest that they have not been
convicted of a felony related to the practice of exit planning.
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures regarding
this Item. However, we do encourage you to independently view the background of Mr. Watson on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 5962288.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Watson is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from Mr. Watson’s role with Cypress. As an insurance professional, Mr. Watson may receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. Watson is not required to offer the products of any particular insurance company. Commissions generated
by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Watson or the Advisor.
Item 5 – Additional Compensation
Mr. Watson has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Watson serves as a Financial Advisor of Cypress and is supervised by Marc Koven, the Chief Compliance
Officer. Mr. Koven can be reached at (760) 834-7250.
Page 48
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 49
Form ADV Part 2B – Brochure Supplement
for
Dermott Larkin
Financial Advisor
Effective: April 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Dermott Larkin (CRD# 2440976) in addition to the information contained in the Cypress Wealth Services, LLC
(“Cypress” or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the Cypress Disclosure Brochure or this Brochure
Supplement, please contact us at (760) 834-7250.
Additional information about Mr. Larkin is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or her Individual CRD# 5192241.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
Phone: (760) 834-7250
http://CypressWS.com
Page 50
Item 2 – Educational Background and Business Experience
Dermott Larkin, born in 1967, is dedicated to advising clients as a Financial Advisor with Cypress Wealth Services.
Mr. Larkin graduated from Santa Monica Community College and California State at Northridge. We may list any
professional designations held by Mr. Larkin. We must provide you with a sufficient explanation of the minimum
qualifications required for each designation to allow you to understand the value of the designation.
Additional information regarding Mr. Larkin’s employment history is included below.
Employment History:
Financial Advisor, Cypress Wealth Services, LLC
Financial Advisor, Perigon Wealth Management
No Title, Stealth
Business Consultant, TriNet, Inc.
04/2025 to Present
08/2018 – 04/2025
10/2017 – 07/2018
01/2015 – 10/2017
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures regarding
this Item. However, we do encourage you to independently view the background of Mr. Larkin on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual
CRD# 2440976.
Item 4 – Other Business Activities
Mr. Larkin does not have any other business activities to disclose.
Item 5 – Additional Compensation
Mr. Larkin has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Larkin serves as a Financial Advisor of Cypress and is supervised by Marc Koven, the Chief Compliance
Officer. Mr. Koven can be reached at (760) 834-7250.
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 51
Form ADV Part 2B – Brochure Supplement
for
William Gordon
Senior Wealth Advisor
Effective: April 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
William Gordon (CRD# 7184825) in addition to the information contained in the Cypress Wealth Services, LLC
(“Cypress” or the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the Cypress Disclosure Brochure or this Brochure
Supplement, please contact us at (760) 834-7250.
Additional information about Mr. Gordon is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or her Individual CRD# 5192241.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
Phone: (760) 834-7250
http://CypressWS.com
Page 52
Item 2 – Educational Background and Business Experience
William Gordon, born in 1964, is dedicated to advising clients as a Senior Wealth Advisor with Cypress Wealth
Services. Mr. Gordon graduated from University of California Bekeley. We may list any professional designations
held by Mr. Gordon. We must provide you with a sufficient explanation of the minimum qualifications required for
each designation to allow you to understand the value of the designation.
Additional information regarding Mr. Gordon’s employment history is included below.
Employment History:
Senior Wealth Advisor, Cypress Wealth Services, LLC
Wealth Advisor, Perigon Wealth Management
VP Business Development, The Business Advantage Group Ltd.
VP Business Development, KineMatik
04/2025 to Present
10/2019 – 04/2025
05/2015 to Present
01/2011 – 05/2015
Certified Divorce Financial Analyst (CDFA®)
The CDFA® designation is made available through the Institute of Divorce Financial Analysts. Individuals with a
minimum of 3 years of professional experience in finance or divorce are eligible to enroll in the CDFA® course. This
includes experience as a financial professional, accountant, or matrimonial lawyer. Candidates should also have
working knowledge of financial calculators. After completing the CDFA® course, the designation is valid for 1 year,
after which designees must pay an annual re-instatement fee. To retain the CDFA® designation, designees must
also obtain 15 divorce-related hours of continuing education every 2 years.
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures regarding
this Item. However, we do encourage you to independently view the background of Mr. Gordon on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual
CRD# 7184825.
Item 4 – Other Business Activities
Mr. Gordon does not have any other business activities to disclose.
Item 5 – Additional Compensation
Mr. Gordon has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Gordon serves as a Senior Wealth Advisor of Cypress and is supervised by Marc Koven, the Chief Compliance
Officer. Mr. Koven can be reached at (760) 834-7250.
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 53
Form ADV Part 2B – Brochure Supplement
for
Jim Bray
Managing Director & Senior Financial Advisor
Effective: September 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Jim
Bray (CRD# 4786682) in addition to the information contained in the Cypress Wealth Services, LLC (“Cypress” or
the “Advisor”, CRD# 288992) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or
if you have any questions about the contents of the Cypress Disclosure Brochure or this Brochure Supplement,
please contact us at (760) 834-7250.
Additional information about Mr. Bray is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or her Individual CRD# 4786682.
Cypress Wealth Services, LLC
74150 Country Club Drive, Palm Desert, CA 92260
Phone: (760) 834-7250
http://CypressWS.com
Page 54
Item 2 – Educational Background and Business Experience
James “Jim” Michael Bray, born in 1976, is dedicated to advising clients as a Managing Director & Senior Financial
Advisor with Cypress Wealth Services. Mr. Bray graduated from University of California Santa Barbara. We may
list any professional designations held by Mr. Bray. We must provide you with a sufficient explanation of the
minimum qualifications required for each designation to allow you to understand the value of the designation.
Additional information regarding Mr. Bray’s employment history is included below.
Employment History:
Managing Director & Senior Financial Advisor, Cypress Wealth Services, LLC
Financial Advisor, Steelpeak Wealth, LLC
Financial Advisor, SEIA
Financial Advisor, Integrated Wealth Management
09/2025 to Present
05/2023 – 09/2025
07/2017 – 05/2023
02/2015 – 07/2017
Certified Financial Planner ("CFP®")
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have
States.
obtained
CFP® certification
in
the
United
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP Board’s studies have determined as necessary for the competent and professional delivery
of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject
areas include insurance planning and risk management, employee benefits planning, investment planning,
income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered
in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability
to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real
world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
CFP® professionals.
practice
outlining
the
ethical
and
standards
for
Individuals who become certified must complete the following ongoing education and ethics requirements in order
to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
– Renew
an
agreement
to
be
bound
by
the Standards
• Ethics
of Professional
Conduct. The Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in
the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP® certification.
Page 55
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There are no disclosures regarding
this Item. However, we do encourage you to independently view the background of Mr. Bray on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual
CRD# 4786682.
Item 4 – Other Business Activities
Mr. Bray does not have any other business activities to disclose.
Item 5 – Additional Compensation
Mr. Bray does not have any additional compensation to disclose.
Item 6 – Supervision
Mr. Bray serves as a Managing Director & Senior Financial Advisor of Cypress and is supervised by Marc Koven,
the Chief Compliance Officer. Mr. Koven can be reached at (760) 834-7250.
Cypress has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting
their fiduciary obligations to Clients of Cypress. Further, Cypress is subject to regulatory oversight by various
agencies. These agencies require registration by Cypress and its Supervised Persons. As a registered entity,
Cypress is subject to examinations by regulators, which may be announced or unannounced. Cypress is required
to periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Page 56
Privacy Policy
Effective Date: August 2019
Our Commitment to You
Cypress Wealth Services, LLC (“Cypress” 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. Cypress (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.
Cypress 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?
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number(s)
E-mail address(es)
Account information (including other institutions)
Income and expenses
Investment activity
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
questionnaires
and
suitability
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment
documents
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.
How do we share your information?
An RIA shares Client personal information to effectlively implement its services. In the section below, we list some
reasons we may share your personal information.
Page 57
Do we share?
Can you limit?
Yes
No
No
Not Shared
Yes
Yes
Basis For Sharing
Servicing our Clients
We may 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.
Marketing Purposes
Cypress does not disclose, and does not intend to disclose, personal
information with non-afffiliated 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 Cypress or the
client has a formal agreement with the financial institution. 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).
No
Not Shared
Information About Former Clients
Cypress does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
State-specific Regulations
California
In response to a California law, to be conservative, we assume accounts with California addresses do not want us to
disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit
the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws.
Your Right to Opt Out
Federal privacy laws give you the right to restrict some sharing of your personal financial information. These laws
balance your right to privacy with CWS’s need to provide information for normal business purposes. You have the
right to opt out of some information sharing with companies that are (1) Part of the same corporate group as your
financial company (or affiliates); or (2) Not part of the same corporate group as your financial company (or non-
affiliates). Choosing to restrict the sharing of our personal financial information will not apply to (1) Information
about you to firms that help promote and market the company's own products or products offered under a joint
agreement between two financial companies; (2) Records of your transactions--such as your loan payments, credit
card or debit card purchases, and checking and savings account statements--to firms that provide data processing
and mailing services for your company; (3) Information about you in response to a court order; and (4) Your
payment history on loans and credit cards to credit bureaus. If you opt out, you limit the extent to which CWS can
provide your personal financial information to non-affiliates. You may request to opt out by calling us at (760) 834-
7250.
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. We will not, however, revise our Privacy Policy to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
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 (760) 834-7250.
Page 58