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Item 1
Cover Page
Dixon Financial Services, Inc.
875 Las Trampas Road
Lafayette, CA 94549
925.283.3104
www.dfsinc.com
February 10, 2026
This brochure describes the qualifications and business practices of Dixon
Financial Services, Inc. If you have any questions about the contents of this
brochure, please contact us at 925.283.3104 or invest@dfsinc.com. The
information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities
authority.
Dixon Financial Services, Inc. is a Registered Investment Advisory firm.
Being a Registered Investment Adviser does not imply any particular level of
skill or training.
Additional information about Dixon Financial Services is also available on the
SEC’s website at www.adviserinfo.sec.gov.
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Item 2
Material Changes
Our last ADV Update was dated February 5, 2025. Since that time there have been no material
changes.
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Item 3
Table of Contents
Item 1 Cover Page ....................................................................................................................... 1
Item 2 Material Changes.............................................................................................................. 2
Item 4 Advisory Services ............................................................................................................ 5
Item 5 Fees and Compensation .................................................................................................... 6
Item 6 Performance-Based Fees and Side-By-Side Management ............................................... 7
Item 7 Types of Clients ............................................................................................................... 7
Account Requirements ............................................................................................................ 7
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss .................................... 7
Item 9 Disciplinary Information .................................................................................................. 9
Item 10 Other Financial Industry Activities and Affiliations .................................................... 9
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
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Code of Ethics ........................................................................................................................... 10
Participation or Interest in Client Transactions ....................................................................... 10
Personal Trading....................................................................................................................... 10
Item 12 Brokerage Practices .................................................................................................... 10
How We Select Brokers/Custodians .......................................................................................... 11
Brokerage and Custody Costs ................................................................................................... 11
Products and Services Available to Us from Institutional Service Programs .......................... 12
Trade Aggregation .................................................................................................................... 13
Item 13 Review of Accounts.................................................................................................... 13
Account Reviews ........................................................................................................................ 13
Reports ...................................................................................................................................... 13
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Item 14 Client Referrals and Other Compensation .................................................................. 14
Item 15 Custody ....................................................................................................................... 14
Item 16
Investment Discretion ................................................................................................. 14
Item 17 Voting Client Securities.............................................................................................. 14
Item 18
Financial Information ................................................................................................. 15
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Item 4
Advisory Services
Dixon Financial Services, Inc. (DFS) is a Registered Investment Advisory firm that has provided
Investment Advisory services since 1989. The owner of and principal investment adviser
representative for DFS is Michael Dixon. DFS has approximately $1.086 billion in regulatory
assets under management as of December 31, 2025.
Our goal is to help our clients manage their financial assets to support their lifestyle objectives.
Every client has different values, resources and lifestyle objectives, and we use these three
factors as raw materials to work with each client to design a financial lifestyle plan. We begin
by developing a document called an Investment Policy Statement (IPS) with each client. This
document covers a client’s investing goals, future financial desires and risk tolerance. In
addition, each IPS contains a policy framework for investing a client’s assets through our Asset
Allocation Advisory Service. Asset Allocation is a process of creating a portfolio based on the
three primary asset classes - stocks, bonds and cash. Using these, we create a diversified
portfolio by purchasing mutual funds and occasionally Exchange Traded Funds (ETFs) that
represent a wide range of sub-classes of these assets. For example, the stock portion of the
portfolio may in part consist of a small cap US fund, a large cap international fund, and a large
cap US fund. Our management of these accounts and each client’s underlying objectives is an
ongoing process. We work to keep the portfolios on track with their associated Investment
Policy Statements, and with our clients to incorporate changes in their goals, resources and
values into their IPS. Clients may impose restrictions on investing in certain securities or types of
securities so long as such restrictions may reasonably be implemented by DFS.
Dixon Financial Services provides a number of other services, usually in conjunction with our
advisory services discussed above. We often coordinate with attorneys, insurance
representatives and accountants to help our clients with various aspects of financial and estate
planning. We have no attorneys or accountants on staff, so we do not provide either legal or tax
services, but we are happy to work with our clients’ attorneys and accountants, and we do so
periodically. Finally, we provide cash flow management services and general financial advisory
services to small businesses when requested by our clients.
We do not participate in any wrap fee programs.
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Item 5
Fees and Compensation
Our current fee schedule is below.
Client Assets
Up to $250,000
Next $250,000 to $500,000
Next $500,000 to $1,000,000
Next $1,000,000 to $2,000,000
Amounts above $2,000,000
Per Annum
1.50%
1.00%
0.75%
0.55%
0.40%
Per Quarter
0.38%
0.25%
0.19%
0.14%
0.10%
Upon execution of the “Dixon Financial Services Investment Adviser Agreement” and the initial
allocation of funds invested, prorated fees for the current quarter are due and payable. We
deduct subsequent fees quarterly, in advance, from each client’s account based upon the market
value of the account as of the last day of the previous calendar quarter. The Asset Allocation
Advisory Service may be terminated by either party thirty (30) days after written notice. Any
prepaid fees will be prorated from the date of termination and DFS will refund the difference.
In the event a client deposits $50,000 or 1% (whichever is greater) of AUM more during a
particular quarter, such client will be billed a pro-rata advisory fee based on the remaining
number of the days in such quarter. Conversely, in the event a client withdraws $50,000 or 1%
(whichever is greater) of AUM more during a particular quarter, such client will be refunded a
pro-rata advisory fee based on the remaining number of days in such quarter.
Accounts managed by DFS but serviced by another independent registered investment adviser or
an asset management company will be separately billed by such independent investment adviser.
The independent investment adviser may also bill accounts for our fees as well. The total
amount of our fees and the independent investment adviser’s fees, on a percentage basis, is
always approved in advance by each client and may be .1% to .5% higher than the fee schedule
above, depending on the third party and the size of the account.
DFS does not negotiate fees. There may be certain exceptions in unusual situations, such as
when we review and report on a client’s assets that we do not directly manage. In these
instances, which we review on a case-by-case basis, we charge an administrative fee on either an
hourly or a fixed-fee basis as quoted.
Our clients are responsible for additional fees and expenses not included in the above schedule.
In general, all of our clients will incur transaction fees (commissions) from their custodian, as
well as mutual fund fees. Unless specifically requested by a client, we do not purchase funds
with sales fees, including front-end loads and surrender fees. This helps keep our clients’ costs
down. A few clients incur custodian fees, including holding and maintenance fees for a small
number of specific assets that we do not include in most accounts. Please refer to Item 12 of this
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brochure for more details about brokerage (custodian) fees. Although we don’t generally
recommend annuities to our clients, some of our clients do have them and they are often subject
to custodian fees.
Neither DFS nor any of its supervised persons accepts compensation for the sale of securities or
other investment products.
Item 6
Performance-Based Fees and Side-By-Side Management
Dixon Financial Services does not charge performance-based fees.
Item 7
Types of Clients
Dixon Financial Services has the following types of clients:
Individuals who have personal investment or retirement accounts such as IRAs.
Business owners who maintain investment accounts for the company or act as plan
administrators for their company retirement and pension plans.
Trustees who administer personal trusts for themselves, for their families, for an estate or
for a charitable trust.
Charitable Organizations that maintain endowment accounts or charitable accounts.
Corporations that maintain accounts for non-profit organizations or associations.
Account Requirements
The minimum account size for a client of Dixon Financial Services is typically $500,000. We
may make, at our discretion, exceptions to this based on a variety of factors. These factors
include, but are not limited to, considerations such as growth potential, relationship of a potential
client to us or to a current client, and the type of client.
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
At DFS, we do not analyze or select individual securities. Instead, we focus on allocating our
clients’ investment dollars among three major asset classes: stocks, bonds, and cash. We then try
to identify mutual funds that focus on providing broad exposure to major sub-classes in both
domestic and international markets. This strategy is called Asset Allocation, and is derived from
a Nobel Prize winning financial theory called Modern Portfolio Theory. This theory provides a
framework for creating portfolios with expected returns based on a given level of risk by
diversifying the portfolio’s investments over a wide range of securities. Rather than directly
holding large numbers of individual securities in our clients’ accounts, we invest our clients’
funds in a mix of mutual funds that hold a large number of securities in that fund’s area of focus.
For instance, a fund we use that focuses on large cap international stocks has holdings in over
500 companies. The allocation is determined by an asset mix we develop for each client by
working with them to discover their financial needs, their goals and their overall feelings about
risk. A client’s asset mix typically includes Fixed Income Funds, Large Cap US funds, Small
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Cap US funds, International Large Cap funds, and others. Each client’s mix is part of their
Investment Policy Statement. By holding a few carefully selected mutual funds, our clients can
indirectly hold thousands of different stocks while keeping trading costs and trading frequency
low.
We use mutual funds and occasionally ETFs from several different companies, but our focus is
on mutual funds from Dimensional Fund Advisors (DFA). DFA’s funds are largely developed
using Modern Portfolio Theory, a core principle of our general investment philosophy. We use
historical data from those funds or similar indices as part of our process to develop the asset mix
for each client’s Investment Policy Statement. The types of historical data used include returns,
the standard deviation (a measure of risk) around those historical returns and correlation between
asset classes. Correlation is a measure of how closely the price of a security moves in relation to
the prices of other securities.
Dixon Financial Services also uses financial simulation programs to calculate the effect of
various rates of return from different asset classes. These calculations help us develop
investment plans for our clients.
Our strategy does not incur frequent trading. The strategy we use focuses on long term holdings
and keeping a balance of asset classes. However, asset classes and the funds representing them
usually have different returns over time, so our clients’ accounts can get out of balance. To bring
these accounts back in line with our clients’ Investment Policy Statements, we review accounts
for trading at least once per quarter, and trade only on those accounts that are significantly out of
balance. Trades will also occur when a client deposits or withdraws money from an account, or
if a client requests a trade. One of our goals at DFS is to minimize trading as much as possible.
Frequent trading increases our clients’ costs and may create a greater tax liability for them.
Our Asset Allocation Strategy is specifically designed to minimize risk by diversifying over a
wide range of asset classes and sub-classes. While this strategy has the potential to reduce risk
compared to a portfolio with only a few stocks, it does not eliminate risk entirely. Market risk,
the risk of markets falling in response to economic downturns, political changes, new laws and
other events, remains the biggest risk for this strategy. Market risk can include just a country or
regional market, or can involve global markets. This is a risk common to all investments and
investment strategies.
Investing in mutual funds does not guarantee a return on investment, and shareholders of a
mutual fund may lose the principal that they’ve invested into a particular mutual fund. Mutual
funds invest into underlying securities that comprise the mutual fund, and as such clients are
exposed to the risks arising from such underlying securities. Mutual funds charge internal
expenses to their shareholders (which can include management fees, administration fees,
shareholder servicing fees, sales loads, redemption fees, and other fund fees and expenses, e.g.),
and such internal expenses subtract from its potential for market appreciation. Shares of mutual
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funds may only be traded at their stated Net Asset Value (“NAV”), calculated at the end of each
day upon the market’s close. Clients are encouraged to carefully read the prospectus of any
mutual fund to be purchased for investment to obtain a full understanding if its respective risks
and costs.
Please be aware that investing in securities, including investment in our Asset Allocation
Strategy, involves risk of loss, including loss of principal, which our clients should be prepared
to bear.
Item 9
Disciplinary Information
This item requires us to discuss any legal or disciplinary events that are material to a client’s or a
prospective client’s evaluation of our advisory business or the integrity of our business.
Neither Dixon Financial Services nor its employees have any such events to discuss in this
section.
Item 10 Other Financial Industry Activities and Affiliations
The owner and certain employees of DFS are licensed insurance agents and from time to time
sell life, health and disability insurance. Those individuals typically maintain license
arrangements with several insurance companies as necessary to meet the needs of clients. They
operate as independent agents without any special arrangement with any particular insurance
company. The sale of insurance products accounts for less than 1% of the representative’s time
of DFS.
DFS has entered into an agreement with Buckingham Strategic Partners, LLC. to make their
Asset Allocation Advisory Service and other investment administrative services available to us.
DFS does not receive any compensation directly from Buckingham Strategic Partners, but
Buckingham Strategic Partners does offer services that are intended to directly benefit DFS,
clients, or both. Such services include (a) an online platform through which DFS can monitor
and review client accounts, create model portfolios, and perform other client account
maintenance matters, (b) access to technology that allows for client account aggregation, (c)
quarterly client statements, (d) invitations to Buckingham Strategic Partners’ educational
conferences at a discount, (e) practice management consulting, (f) sponsorship of DFS seminars
or client appreciation events, and (f) occasional business meals and entertainment. DFS attempts
to mitigate this conflict by disclosing it to clients in this Form ADV and by requiring all
representatives to follow DFS’s policies and procedures, which specifically note the fiduciary
obligation to place client interests ahead of the individual representative’s or DFS’s. Fees for
such programs may be higher or lower than if client directly obtained services of the third party
manager or if client obtained advisory services separately.
Neither DFS nor any of its management persons are registered, or have an application pending to
register, as a broker-dealer or a registered representative of a broker-dealer.
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Neither DFS nor any of its management persons are registered, or have an application pending to
register, as a futures commission merchant, commodity pool operator, a commodity trading
advisor, or an associated person of the foregoing entities.
Code of Ethics, Participation or Interest in Client
Item 11
Transactions and Personal Trading
Code of Ethics
An employee or adviser of DFS will place the needs and best interests of our clients above the
needs and interests of themselves or business associates in all cases, and will not allow the
pursuit of financial gain or other personal benefit to interfere with the exercise of sound
professional judgment and skills. A complete copy of our code of ethics is available upon
request.
Participation or Interest in Client Transactions
At times the interest of the accounts belonging to the owner and employees of DFS may
correspond with client interests. At no time do any of these corresponding interests represent a
material interest in the security involved.
DFS obtains information from a wide variety of public sources and has no direct sources of
inside or private information. In the event that a conflict of interest arises that has significant
financial implications to our clients, we will fully disclose it. All rules and regulations of the
Investment Advisers Act of 1940 will be strictly enforced. Dixon Financial Services will
maintain personal transaction records and will not permit insider trading.
Personal Trading
From time to time, the owners and employees of DFS invest in the same securities that DFS
recommends to our clients and that clients hold in their accounts. This can be considered a
conflict of interest in that we may have an incentive (our own investment) to encourage our
clients to invest in a particular security; however, the securities we recommend to our clients are
almost always mutual funds and are always large enough and liquid enough that neither our nor
our clients’ transactions can materially affect the price of the security. It is also possible that
DFS or an employee of DFS could be buying or selling securities for our own accounts about the
same time as the same securities are bought and sold for our clients. To avoid conflicts of
interest here, neither DFS nor its employees may trade in advance of our clients’ trades. In
addition, neither DFS nor its employees will take an opposite position to one recommended to a
client.
Item 12
Brokerage Practices
DFS does not maintain custody of our client’s assets that we manage, although we may be
deemed to have custody of these assets if we are given authority by our clients to withdraw
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assets from their accounts (see Item 15 – Custody). Our clients’ assets must be maintained in an
account at a “qualified custodian,” generally a broker-dealer or bank. The qualified custodian we
recommend is Charles Schwab & Co., Inc. (Schwab). DFS is independently owned and operated
and not affiliated with any qualified custodian, including the one we recommend. A qualified
custodian holds our clients’ assets in their brokerage accounts and will buy and sell securities
when instructed by our clients or by DFS using limited power of attorney if a client has
approved.
While DFS recommends that our clients use Schwab, we do not require our clients to use a
particular custodian. We do, however, have some restrictions. There are some custodians that
do not integrate well with our computer systems and software. Because of this, we are not able
to manage accounts held with those custodians. Regardless of the custodian chosen, our clients
open their accounts directly with the custodian. We will assist in this process as required. Not
all advisers require their clients to use a particular broker-dealer or other custodian recommended
by the adviser.
How We Select Brokers/Custodians
We seek to recommend a custodian who will hold our clients’ assets and execute transactions on
terms that we feel offer the best value when compared to other available providers and their
services. We consider a wide range of factors, including, among others:
Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
Breadth of available investment products (stocks, bonds, mutual funds, ETFs, etc.)
Availability of investment research and tools that assist us in making investment
decisions
Quality of services
Competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate the prices
Reputation, financial strength, and stability
Prior service to us and our clients
Availability of other products and services that benefit us and our clients, as discussed
below (see “Products and Services Available to Us From Custodians”)
Brokerage and Custody Costs
The custodians that maintain accounts for our clients generally do not charge separately for
custody services but are compensated by charging commissions or other fees on trades they
execute or settle into each client’s account. Our clients are responsible for these fees. In very
rare cases, and only at the request of a client, we may need to have a trade executed on an
account by a broker that is different from the broker that is actually holding the account. In
addition to commissions, this may result in a flat dollar amount called a “trade away” fee. These
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fees are in addition to the commissions or other compensation our client pays the executing
broker-dealer.
We have determined that having the recommended custodians execute trades is consistent with
our duty to seek “best execution” of our clients’ trades. Best execution means the most favorable
terms for a transaction based on all relevant factors, including those listed above (see “How We
Select Brokers/Custodians.”)
Products and Services Available to Us from Institutional Service Programs
The custodians that we work with provide a variety of support services that are generally
available on an unsolicited basis (we don’t have to request them) and at no charge to us as long
as our clients collectively maintain a total of at least $10 million of their assets in accounts with
the custodian. If our clients collectively have less than $10 million in assets, these custodians
may charge us quarterly service fees of up to $1,200. These services are not contingent upon us
committing any specific amount of business to the custodian in trading commissions or assets in
custody. Services that directly benefit our clients generally include software and support
services that:
Provide access to client account data (such as duplicate trade confirmations and account
statements)
Facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
Facilitate payment of our fees from our clients’ accounts
Assist with back-office functions, recordkeeping, and client reporting
Provide investment research and publications from the brokerage and from third party
sources
In addition, there are also services custodians provide to us that do not help our clients directly
but are intended to help us manage and further develop our business enterprise. These services
include:
Educational conferences and events
Consulting on technology, compliance, legal, and business needs
Publications and conferences on practice management and business succession
Access to employee benefit providers, human capital consultants, and insurance providers
From time to time, they also provide us with other benefits, such as occasional business
entertainment of our personnel.
The availability of these Institutional Services free of charge from custodians benefits us, but
creates a conflict of interest in that we have an incentive to direct our clients towards the
particular brokerages that we receive these benefits from rather than a brokerage that might
provide the most favorable execution. We believe that the execution methods and pricing
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obtained from our recommended brokerages is very competitive and that the benefits our clients
receive from the provided services outweigh the benefits of getting the least expensive trade.
DFS does not consider, in selecting or recommending a custodian and/or brokerage, whether
DFS or a related person receives client referrals from such custodian and/or brokerage, or any
other third-party.
Trade Aggregation
Dixon Financial Services generally is not able to combine trades of the same security for
multiple clients (trade aggregation) because we evaluate each account on an individual basis
according to the needs and requirements of each client. This means it is possible we could buy
or sell the same securities for different clients at the same or slightly different times. This may
result in higher trading costs for our clients. In the rare cases where we are purchasing securities
other than mutual funds, this also may result in pricing differences between clients. When we
do aggregate trades, trading costs will be split proportionally between all client accounts
involved in the trade.
Item 13
Review of Accounts
Account Reviews
We review accounts on a quarterly basis to evaluate changes that may occur in the allocation of a
client’s portfolio due to the performance of individual asset classes relative to the allocation
outlined in the client’s Investment Policy Statement to determine if rebalancing should occur.
Client needs or requests may result in a temporary deviation from the allocation in the
Investment Policy Statement. In these cases, portfolios will not be rebalanced until we are
otherwise instructed by the client. We review Investment Policy Statements as needed. DFS
strongly encourages our clients to talk to us about any changes to their financial lifestyle needs or
goals, or about significant life events such as a marriage or retirement. Changes like these will
normally trigger a review of the client’s Investment Policy Statement and the associated
investment model. All reviews are done by either Michael Dixon or one of DFS’ Investment
Advisers. Finally, all daily transactions are reviewed and acknowledged by at least two
employees.
Reports
DFS provides computer generated performance reports no less than on a quarterly basis for
clients utilizing our Asset Allocation Advisory Service. This report includes both details and
summaries of account performance and holdings.
Some accounts with DFS are managed by a third party advisory service (see Item 10 for more
information). The third party service delivers quarterly statements to clients with such accounts.
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All clients will also receive quarterly and annual statements from the custodian holding their
accounts.
Item 14
Client Referrals and Other Compensation
DFS does not pay cash or provide an economic benefit to anyone or any organization who
introduces us to a client. Likewise, DFS does not receive any cash or other economic benefit for
making referrals to other advisers or third party service providers.
Item 15
Custody
For clients that do not have their fees deducted directly from their account(s) and have not
provided Dixon Financial Services with any standing letters of authorization to distribute funds
from their account(s), Dixon Financial Services will not have any custody of client funds or
securities. For clients that have their fees deducted directly from their account(s) or that have
provided Dixon Financial Services with discretion as to amount and timing of disbursements
pursuant to a standing letter of authorization to disburse funds from their account(s), Dixon
Financial Services will typically be deemed to have limited custody over such clients’ funds or
securities pursuant to the SEC’s custody rule and subsequent guidance thereto. At no time will
Dixon Financial Services accept full custody of client funds or securities in the capacity of a
custodial broker-dealer, and at all times client accounts will be held by a third-party qualified
custodian as described in Item 12, above.
Clients of Dixon Financial Services will receive statements at least quarterly from the qualified
custodians that maintain our clients’ assets. We strongly encourage our clients to carefully
review those statements. Clients should also take the time to compare these statements against
the statements provided by DFS or one of our third party advisory services. Comparing these two
sets of statements allows our clients to ensure that all transactions, including the deductions for
the advisory fees, are proper and correct.
Item 16
Investment Discretion
The Investment Policy Statement that each client signs to establish an Advisory Service
relationship with Dixon Financial Services defines the discretion we have to buy and sell
securities for our clients without their prior consent. This “discretionary authority” is limited to
the purchase and sale of securities within specific asset classes approved by the client in the
Investment Policy Statement, and must be done in accordance with the investment model
outlined in each client’s Investment Policy Statement or as otherwise approved by the client.
Item 17
Voting Client Securities
Dixon Financial Services does not vote proxies for clients. Most clients do not have individual
stock holdings in their accounts, but for those who do, the proxy statements will be mailed by the
account custodian directly to the client at the address the custodian has on file.
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Item 18
Financial Information
This section requires us to report any financial issues that DFS has that might make it difficult to
meet our contractual obligations to our clients. We are also required to report any past
bankruptcies here.
Dixon Financial Services is financially sound, does not have any past bankruptcies, and therefore
does not have any items to report under this section.
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