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(DYNAMIC ADVISOR SOLUTIONS, LLC)
CRD #151367
Firm Brochure
Effective: June 2025
Dynamic Wealth Advisors
2415 E. Camelback Road, Suite 700
Phoenix, AZ 85016
(877) 257-3840
Dynamic Advisors Solution LLC is the legal name of the Firm and the name we use to market our services
to Financial Advisors. Dynamic Wealth Advisors (“Dynamic”) is the primary name under which we
conduct our advisory business with Clients. Dynamic is an investment adviser registered with the U.S.
Securities and Exchange Commission (“SEC”). The information in this Brochure has not been approved
or verified by the SEC or by any state securities authority. While Dynamic may refer to itself as a
“registered investment adviser” or “RIA” client should be aware that registration itself does not imply any
level of skill or training. Additional information about Dynamic and its investment advisor representatives
(“Financial Advisors”) is available on the SEC’s website at www.adviserinfo.sec.gov.
The Firm Brochure (“Brochure”) provides information about the qualifications and business practices of
Dynamic Wealth Advisors (“Dynamic”) and the nature of the advisory services that should be considered
before becoming an advisory client of Dynamic. If you have any questions about the contents of this
Brochure, please contact us at: Compliance@DynamicWealthAdvisors.com.
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Item 2: Material Changes
The Material Changes section of this brochure is updated to report any “material” changes to the previous
version of Form ADV, Part 2A (the Firm Brochure). The section below provides a summary of material
changes since the last update.
•
Item 4: Advisory Services
The Assets Under Management section was updated. As of December 31, 2024, total assets
under management: Discretionary $5,319,603,646, Non-discretionary $21,730,040 with a
Total $5,341,333,686
•
Item 5: Fees and Compensation
This was updated to disclose Dynamic’s cash management process.
•
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
This section was updated to include some of the risks associated with holding cash.
•
Item 10: Other Financial Activities and Affiliations
This section was updated to disclose an outside business activity regarding a Technology Vendor
Relationship of certain principals and Financial Advisors of the Firm.
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Item 3: Table of Contents
Item 2: Material Changes ................................................................................................................................2
Item 3: Table of Contents ................................................................................................................................3
Item 4: Advisory Services ...............................................................................................................................4
Item 5: Fees and Compensation ................................................................................................................. 10
Item 6: Performance-Based Fees ............................................................................................................... 14
Item 7: Types of Clients ................................................................................................................................ 14
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ............................................ 16
Item 9: Disciplinary Information ................................................................................................................. 23
Item 10: Other Financial Activities and Affiliations ............................................................................... 24
Item 11: Code of Ethics, Participation in Client Transactions, and Personal Trading ................... 25
Item 12: Brokerage Practices...................................................................................................................... 26
Item 13: Review of Accounts ....................................................................................................................... 27
Item 14: Client Referrals and Other Compensation .............................................................................. 28
Item 15: Custody ............................................................................................................................................ 29
Item 16: Investment Discretion ................................................................................................................... 29
Item 17: Voting Client Securities ................................................................................................................ 29
Item 18: Financial Information .................................................................................................................... 29
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Item 4: Advisory Services
Dynamic is an investment adviser registered with the SEC. Dynamic was founded in 2008 as a Delaware
limited liability company. Dynamic Management LLC, an Arizona limited liability company, owns 100% of
Dynamic.
Investment Advisory Services
Dynamic offers investment advisory services to individuals, high net worth individuals, trusts, estates,
charitable organizations, pension plans, profit sharing plans and businesses (each referred to as a
“Client” or “You”) through affiliated investment advisor representatives (“Financial Advisors”). Many of the
Financial Advisors have their own legal business entities whose trade names and logos are used for
marketing purposes that will appear on marketing materials and/or client statements. Clients should
understand that the businesses are legal entities of the Financial Advisor and not of Dynamic. The
Financial Advisors are under the supervision of Dynamic and all advisory services offered by the Financial
Advisor are provided through Dynamic. Additional information regarding these "trade names" is available
on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov.
Dynamic’s investment strategies are primarily long-term focused, but Financial Advisors may, in certain
circumstances, buy, sell, re-allocate or rebalance positions that have been held less than one year to
meet a Client’s objectives or due to market conditions. Prior to rendering investment recommendations,
Financial Advisors ascertain your financial situation, risk tolerance, and investment objectives.
Financial Advisors may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Financial Advisors may recommend specific positions to increase sector or asset class
weightings. Financial Advisors may recommend employing cash, options, or inverse ETF positions as
possible hedges against general market declines, which could adversely affect the portfolio. Financial
Advisors 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 positions in the portfolio, change in a Client’s risk tolerance or
investment objectives, generating cash to meet a Client’s needs, or any risk deemed unacceptable for a
Client’s risk tolerance.
You should immediately advise your Financial Advisor if your investment objectives or risk
tolerance changes, or other factors change that may affect the proper positioning of your
portfolio.
Your participation in this process, including full and accurate disclosure of requested information, is
essential for the analysis of your portfolio. Your Financial Advisor and Dynamic shall rely on the financial
and other information provided by you or your designees without the duty or obligation to validate the
accuracy and completeness of the provided information. It is your responsibility to inform your Financial
Advisor or Dynamic of any changes in financial condition, goals or other factors that may affect this
analysis. The Financial Advisor will work with you to determine your tolerance for risk as part of the asset
allocation and portfolio construction process.
Dynamic Discretionary Investment Management Accounts
Dynamic and Clients enter into an Investment Management Agreement (“IMA”) to provide Dynamic with
discretion to manage one or more Client accounts. Your Financial Advisor works with you to identify your
investment goals and objectives as well as your risk tolerance and financial situation. Investment
strategies consider your specific needs and are implemented using the investment options most
appropriate for you. Your Financial Advisor may develop an asset allocation or a targeted investment
strategy for you, as appropriate.
Your Financial Advisor will construct your portfolios utilizing various types of securities based upon your
investment objectives, risk tolerance and other factors. Dynamic and your Financial Advisor may use
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individual equity and fixed income securities, mutual funds, exchange-traded funds (“ETFs”), structured
notes and options as necessary to achieve your investment goals. Individual equity securities may include
domestic and international securities covering all market capitalizations. Fixed income securities may
include corporate debt securities, U.S. government securities, municipal securities, foreign debt, and
short-term instruments. Investments in tradable or non-tradable real estate investment trusts (“REITs”),
private equity, private debt investments, limited partnerships and non-security investments may be
recommended, if appropriate, for certain Client portfolios. Financial Advisors may recommend Sub-
advisors to manage a portion of your portfolio. Sub-advisors act in accordance with Dynamic’s instruction
and charge Dynamic for investment management.
Dynamic may, in accordance with Client’s investment objectives, determine to allocate all or a portion of
the Assets among various individual debt and/or equity securities and/or mutual funds, or other securities
or investment contracts. A portion of the Assets may remain in cash. In some cases, a substantial portion
of the Assets may be held in cash for a period of time, rather than being invested in money market funds
or other cash equivalents, to improve liquidity and flexibility to invest the cash in other securities and
ensure that cash is available for Fees, distributions, etc. To monitor cash balances, we perform periodic
cash reviews. Cash balances may be outside of tolerance to due to upcoming Fees, distributions,
deposits, or other money movements, or to reduce trades and trading costs. If a significant portion of the
Assets is held in cash or cash-like instruments, investment performance may be affected. The custodian
cash sweep accounts typically used for cash positions are generally low-to-no interest-bearing accounts.
Advised assets may serve as collateral for loans, derivatives, or other securities. Some of Dynamic’s
Financial Advisors may recommend the use of prepaid variable forward contracts. A variable prepaid
forward contract is a strategy used by stockholders to cash in some or all of their shares of an individual
stock while deferring the taxes owed on the capital gains. The investor receives a portion of the current
value of the stock in the form of a loan. The stock position is held as collateral for the loan that is given
to the stockholder. The loan proceeds are generally deposited into to another managed account to be
invested. Dynamic will charge the client a fee for the collateralized portion of the stock in addition to the
investments that the collateralized loan is used to purchase.
Financial Advisors construct, implement and monitor your portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance that you have agreed to. You have the ability to place
reasonable restrictions on the types of investments to be held in your respective portfolio, subject to the
acceptance by the Financial Advisor and Dynamic.
Dynamic Investment Advisory Accounts (Non-Discretionary)
Dynamic and Clients may enter into an Investment Advisory Agreement (“IAA”) to provide Dynamic on a
non-discretionary basis to perform services as described in the IAA to one or more Client accounts.
Financial Advisor shall be responsible for reviewing, analyzing and providing recommendations
regarding your investments and accounts you designate as subject to the IAA. Your Financial Advisor
works with you to identify your investment goals and objectives as well as your risk tolerance and financial
situation. Investment strategies consider your specific needs and the recommendations made are using
the investment options most appropriate for you. Your Financial Advisor may develop and recommend
an asset allocation or a targeted investment strategy for you, as appropriate.
The IAA is a non-discretionary advisory agreement. If your Financial advisor does not have access or
authority to execute trades in your account(s), you are responsible for the implementation, trading and
execution of any recommendations provided by your Financial Advisor. In some instances, your
Financial Advisor will have trading authorization on your account(s), however the Financial Advisor must
confirm all trades with you prior to executing the trade(s).
Sub-advisors
Some of our Financial Advisors utilize third-party managers to sub-advise your accounts if you need or
are seeking a specific type of investment management or strategy. Sub-advisors provide investment
allocation and securities selection and may execute securities transactions in your accounts pursuant to
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an agreement with Dynamic and your IMA. Certain sub-advisors use ETFs and/or mutual funds in Client
portfolios to which they are manager or sub-advisor. In such cases, the selection of these investments
creates a conflict of interest for the sub-advisor. These sub-advisors disclose conflicts of interests,
including their selection of such investments, in their Form ADV Part 2. Financial Advisors advise you in
establishing investment objectives, and work with the sub-advisors to ensure an appropriate investment
strategy for you. You are provided with the sub-advisor’s Form ADV Part 2 (or a brochure such as this).
Third-party Account Managers
Some of our Financial Advisors may recommend to you that all or a portion of your portfolio be
implemented by utilizing one or more unaffiliated money managers. This involves entering into an IMA
with Dynamic and a separate agreement with a third-party manager. Financial Advisors advise you in
establishing investment objectives for the account, the selection of the third-party manager, and defining
any restrictions on the account. Financial Advisors continue to provide management oversight of your
account and ongoing monitoring of the activities of the third-party manager. Certain third-party managers
use ETFs and/or mutual funds in Client portfolios to which they are manager or sub-advisor. In such
cases, the selection of these investments creates a conflict of interest for the third-party manager. These
third-party managers disclose conflicts of interests, including their selection of such investments, in their
Form ADV Part 2. You are provided with the third-party manager’s Form ADV Part 2 (or a brochure such
as this one).
Outside Accounts
Some Financial Advisors also manage and recommend allocations as well as provide consolidated
reporting for Outside Accounts such as sub accounts of variable annuities, fixed annuities, 529 Plans,
401ks, REITs and other similar accounts. Generally, these accounts are not held by a custodian that is
holding other accounts managed by Dynamic and Financial Advisors. If the Outside Accounts are
managed, we periodically review the current holdings and available investment options in these accounts,
monitor the accounts, rebalance and implement our strategies as necessary. In some cases, we may
recommend the use of a third-party Order Management System to implement asset allocation or
rebalancing strategies on behalf of the client. In other cases, we do not have the ability to execute the
recommended asset allocation or strategies and therefore you are responsible for implementing any such
recommendations. Outside Accounts may be included in the accounts on the IMA and subject to an
Investment Advisory Fee, if applicable (See “Fees and Compensation” section herein below and your
IMA).
To service the management of certain variable insurance products or contracts, Dynamic has an
agreement with third party vendors under which Financial Advisors provide investment advice to the
vendor that serves as agent on certain variable insurance products or contracts owned by Clients.
Financial Advisors may recommend that Clients transfer their variable insurance contract to one of these
third-party vendors to serve as agent and to facilitate the management of the sub accounts in the variable
products or contracts owned by Clients in an effort to integrate asset allocation, risk tolerance and
investment objectives across all or a broader portion of Client Assets. The third-party vendor is not
required to follow the advice of Financial Advisors. The third-party vendor may receive compensation
from the insurance carriers of these products. Dynamic receives a service fee from the third-party vendor
for providing investment advice to the vendor. Although the receipt of the service fee creates a conflict of
interest for Dynamic, we believe many Clients can benefit from this arrangement by receiving a more
comprehensive and integrated service of their Assets. We will adhere to our fiduciary duty and make a
recommendation when we deem it to be in your best interest.
Outsourced Trading
Dynamic has entered into a partnership with Advisor Logistics, LLC to provide non-discretionary
outsourced trading to some of our client accounts. Dynamic has sole discretion on these accounts and
there are no material differences between how the clients’ accounts are managed from a portfolio
management perspective. There are no additional costs to clients. Additional information about Advisor
Logistics LLC (CRD #292784) is available on the SEC’s website at www.adviserinfo.sec.gov.
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Dynamic RIA Professional Services
Dynamic provides professional services to unaffiliated registered investment advisors, including an
integrated technology platform to efficiently operate their advisory practices, a range of investment
management solutions, operational and compliance support and related services, client account
aggregation and consolidated reporting through an online portal, and the ability to service Clients utilizing
various asset custodians. Dynamic charges fees to unaffiliated registered investment advisors for these
services as described in the “Fees and Compensation” section herein below.
Dynamic Sub-Advisory Services
Dynamic provides sub-advisory services to unaffiliated registered investment advisors. Such services
include the design and implementation of investment models for their client accounts, and periodic
rebalancing, re-allocating, trading and reporting. Under these arrangements, unaffiliated registered
investment advisors select the investment model based upon their clients’ financial situation, objectives,
risk tolerance and other factors. Unaffiliated registered investment advisors are responsible for
maintaining current client information to ensure appropriate investment models are selected for their
clients. Dynamic charges fees to unaffiliated registered investment advisors for these services as
described in the “Fees and Compensation” section herein below.
Through a contract directly between Dynamic and Raymond James Financial Services Advisors, Inc.
(“RJ”) Financial Advisors have access to various investment strategies and products for clients. One of
these products is a wrap fee program sponsored by RJ(“wrap sponsor”). Under this program, Financial
Advisors recommend and assist clients in selecting an appropriate investment strategy, taking into
account the client’s financial situation and investment objectives. Dynamic’s role is to oversee the
client’s wrap fee account to ensure it is being managed according to the strategy selected. The wrap
program includes all fees for investment management, trading and execution. Wrap fees are charged
to the client account by RJ. Dynamic charges the client a separate Advisory Fee for overseeing the
management of the client account.
RJ has prepared a brochure which contains detailed information about its wrap fee program, including
the wrap fee charged. Copies of the brochure are available from RJ upon request.
Financial Planning, Retainer Financial Planning and Consulting Services
Financial Advisors provide a variety of financial planning and consulting services to individuals, families
and businesses, depending upon their circumstances. In certain cases, your Financial Advisor will
request that you enter into a separate Financial Planning or Retainer Financial Planning Agreement with
Dynamic for the performance of these planning services. Generally, such financial planning services
involve preparing a financial plan or rendering a financial consultation for you based upon your 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, personal savings, education savings and
other areas of your financial situation. A financial plan developed for you or financial consultation
rendered to you usually includes general recommendations for a course of activity or specific actions to
be taken by you. For example, recommendations may be made that you initiate or revise your investment
programs, commence or alter retirement savings, establish education savings and/or charitable giving
programs. The financial planning agreement may be for a specific project, a specified period or on-going,
depending upon your situation, goals, objectives and other factors.
Financial Advisors may also refer you to an accountant, attorney, or another specialist, as appropriate
for your unique situation. For certain financial planning engagements, Financial Advisors generally
provide a written summary of your financial situation, observations, and recommendations. For retainer,
consulting or ad-hoc engagements, your Financial Advisor may not provide you with a final written
summary, depending on the arrangement. Your Financial Advisor will communicate the work performed
and any recommendations as defined in the Agreement throughout the engagement.
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Certain Financial Advisors provide Tax Preparation services in conjunction with Financial Planning
services through separate, unaffiliated entities or as an outside business activity. Dynamic does not
provide Tax Preparation nor does it supervise the Tax Preparation provided by Financial Advisors or
unaffiliated entities. You are not obligated to engage with your Financial Advisor for Tax Preparation
services. For convenience, the Financial Planning Fees or Retainer Financial Planning Fees can include
the cost of Tax Preparation. If the cost of Tax Preparation is included in your Financial Planning Fees or
Retainer Financial Planning Fees, your Financial Advisor uses a portion of the total Fees you pay to
compensate the entity that performs Tax Preparation services. Dynamic maintains a portion of the Tax
Preparation fees to cover the administration of the billing services.
You are not obligated to implement any recommendations made by your Financial Advisor and your
Financial Advisor is in no way responsible for ensuring you do so.
Dynamic has an agreement with Wealth.com which provides our Financial Advisors with access to their
Wealth platform. Financial Advisors can then invite or refer an unlimited number of clients to the platform
for estate planning. Clients are under no obligation to engage the services of Wealth.com or any other
recommended professional. If the Client engages a recommended professional, and a dispute arises
thereafter relative to such engagement, the Client agrees to seek recourse exclusively from and against
the engaged professional/firm.
Wealth.com provides a holistic estate planning solution that allows users to create, manage and
administrate estate plans through a technology platform. Clients are provided access to Wealth.com
where they can start the process digitally but still consult live with a T&E attorney partners for a fee.
Financial Advisors do not provide legal advice. To the extent that the material concerns legal matters, it
is not intended to be used as legal advice.
Once referred to Wealth, Clients enter the Wealth platform and are guided through the document creation
process by Wealth, not by the Financial Advisor. Though our Financial Advisors can refer clients to the
platform, Dynamic Financial Advisors are not involved with the drafting of the legal documents and do
not have the ability to make selections for the client. A Financial Advisor is granted read-only visibility of
the client account to help ensure they complete the process of creating and continue to monitor for
optimization opportunities.
Financial Advisors that utilize this service through their Financial Planning role can charge an additional
fee for this service. Please note that a conflict exists between Dynamic and the client in offering estate
planning. Dynamic's clients are under no obligation to act upon any recommendations received. Further,
if they elect to act on any recommendations received, they are under no obligation to implement the
estate plan through Wealth.com or any suggested third party. The client retains absolute discretion over
all such implementation decisions and is free to accept or reject Dynamic and/or Wealth.com’s
recommendations. Dynamic does not represent that these products or services are offered at the lowest
available cost - clients may be able to obtain the same products or services at a lower price from other
providers. Clients should consult their Agreement for complete details.
Employee Retirement Income Security Act (“ERISA”)
Dynamic may authorize certain of its Financial Advisors to provide fiduciary or non-fiduciary services to
ERISA plans. ERISA plan documents typically designate one of more persons, such as the plan trustee,
to undertake fiduciary responsibility for the operation of, and take actions on behalf of, the plan. Such
persons are known as Responsible Plan Fiduciaries (“RPFs”). Financial Advisors may provide the
following services to ERISA plans:
Investment Policy Statement Review
• Assessment and Selection of Investments
•
Investment Policy Statement Development
• Non-ERISA Fiduciary Services
•
• Performance Monitoring
8 | D y n a m i c A D V P a r t 2 A – 6 . 2 0 2 5
• Employee Enrollment and/or assistance
• Employee Education
• Vendor Review and Conversion
When we provide investment advice to you regarding your retirement plan or individual retirement plan
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The
way we make money creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours.
Dynamic Retirement Plan Services
Dynamic makes available a qualified retirement plan program to Financial Advisors and other third-party
advisors for sponsors of qualified retirement plans. Retirement Plan services include the coordination
and management of ERISA plan services and consist of a fiduciary-based investment management
process, and the selection and on-going monitoring of an investment line-up and asset allocation models
that include passive and active mutual funds and exchange traded funds. Dynamic and certain sub-
advisors serve as ERISA Section 3(38) Investment Manager. Plan sponsors have the option to offer self-
directed brokerage accounts. The program emphasizes the desired outcomes of retirement plan
participants.
investments are maintained
third-party
in accounts held by unrelated custodians. Dynamic
The
record keepers and administrators of plan assets,
facilitates arrangements with
professional fiduciaries, and other retirement plan service providers. Dynamic and such plan sponsors
enter into an agreement for services which details the services, and obligations of Dynamic, Financial
Advisor and the plan sponsors.
Research and Investment Models Services
Certain Financial Advisors provide investment research and investment models to other investment
advisors and individual investors (“Research Subscribers”). Research Subscribers receive periodic
updates to a list of stocks and/or investment models. Research Subscribers are responsible for the
implementation and use of the research, including making their own investment purchase and sale
decisions, trade execution and management of their accounts. Research Subscribers do not enter into
Investment Management Agreement with Dynamic nor do they receive personal investment advice from
Dynamic or Financial Advisors.
Assets Under Management
As of December 31, 2024, total assets under management were: Discretionary $5,319,603,646,
Non-discretionary $21,730,040 for a Total $5,341,333,686.
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Item 5: Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for investment
management. You are required to sign an IMA with Dynamic which details the fees payable to each.
Dynamic Investment Management and Advisory Account Fees
Investment Advisory Fees (“Fees”) are paid monthly or quarterly, in advance or in arrears, pursuant to
the terms of the IMA or IAA, unless otherwise agreed to in writing by you and Dynamic. Fees are generally
determined by the Financial Advisors and are based upon the market value of all the assets subject to
an IMA or IAA (“Assets”). If billing is in arrears, the Fee will be based on the average daily balance of
the Assets held for the period in which the fee is charged.
Fees may range up to 2.25% annually depending on the type and complexity of the investment
management strategy employed as well as the size of your account(s). Generally, larger accounts, or
accounts with less complexity may be offered a lower Fee relative to fees generally assessed by a
Financial Advisor. Certain accounts may be charged higher Fees based on complex situations, including,
but not limited to, accounts with multiple investment objectives, multiple underlying registrations, or
aggressive growth strategies and/or accounts which require active trading to achieve your objectives.
Fees may be negotiable at the discretion of Financial Advisors. Fees vary among Financial Advisors.
Some Financial Advisors establish minimum Fees. In these cases, the total Fee can be in excess of
2.25% annually, depending upon the market value of the Assets and the amount of the minimum annual
Fee. Please refer to your IMA or IAA and Fee Schedule for details about your Fees.
Clients with margin accounts are subject to Fees on the additional amount of assets resulting from the use
of margin, if any. For example, an account with a value of $100,000 before margin that later uses margin of
$20,000, would be subject to a Fee on $120,000. The use of margin creates a conflict of interest since we
receive a Fee on the entire balance.
In addition, unless specifically excluded from Fees by you or your Advisor Representative, all Assets are
included in the Fee charged, for accounts with or without margin, including cash and cash equivalents.
All securities held in accounts managed by Dynamic and Financial Advisors are independently valued by
the custodian or other third-party pricing services. Dynamic does not have the authority or responsibility
to value portfolio securities. Dynamic relies upon third-party sources for account data to determine the
calculation of fees to be charged. While Dynamic reviews and periodically samples the data to ensure it
is accurate, there may be cases where the account data does not match the source of the data. In these
cases, the Fees charged may be different than expected. If Dynamic discovers, is made aware of, or is
advised by clients of differences, then any bills generated and Fees collected will be updated, if
necessary.
Fees are deducted from your account(s) by the custodian as requested by Dynamic. You provide written
authorization permitting Dynamic to bill your accounts directly from the custodian when you execute an
IMA or IAA and separate account forms required by the custodian. If billed quarterly, the Fee due is
calculated by applying the quarterly rate (annual rate divided by 4) to the total market value of your Assets
as of the end of preceding quarter. If billing is in arrears, the Fee will be based on the average daily
balance of your Assets held during the billing period.
Fees can be primarily structured in one of the following ways:
1. Blended Management Fee: Total Fee is calculated based upon sum of Asset value multiplied by
the fee percentage in all asset ranges;
2. Breakpoint Management Fee: Total Fee is calculated based upon total Asset value multiplied by
the fee percentage of highest total asset value range applicable for Assets in the account(s); or
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3. Flat Management Fee: Total Fee is calculated based upon sum of Asset value multiplied by the fee
percentage.
If your Assets are billed in advance, Fees in the initial quarter of service are prorated to include the
number of days in the previous quarter your account(s) was managed. Additional contributions to
accounts may be charged a prorated fee pursuant to your IMA. If your Assets are billed in arrears, the
Fee is based on the average daily balance of the Assets held during the billing period. You may request
a Fee Statement showing the Fees charged by account and the annual Fee used to calculate your Fees.
You should also receive, at least quarterly, a statement from the custodian reflecting the deduction of the
Fees (please note: usually this is coded as a “management fee” by the custodian). It is your responsibility
to verify the accuracy of any fees listed on the custodian’s brokerage statement as neither the custodian
nor Dynamic assume this responsibility You should immediately notify your Financial Advisor or Dynamic
if you are not receiving statements from custodians, or if you have questions about Fees.
Termination of Investment Management or Advisory Agreement
You may request to terminate your IMA or IAA with Dynamic, in whole or in part, by providing advance
written notice. You are responsible for Fees up to and including the effective date of termination. Dynamic
will refund any unearned, prepaid Fees based on the number of days remaining in the quarter from the
day following the effective date of termination to the end of the quarter. If billing is in arrears, the Fee will
be calculated up to the termination date and charged to the account based on the average daily balance
of the Assets held as of the end of the final billing period. Your IMA is non-transferable and cannot be
assigned to another registered investment advisor without your consent.
Dynamic RIA Professional Services Fees
Unaffiliated registered investment advisor that contract with Dynamic to provide support services to their
firm pay Dynamic based upon the amount of assets on Dynamic’s platform and the type of services
provided. The fees generally range up to .50% of assets annually. In most cases, advisors also pay
technology license fees ranging from $400 to $500 per month per user. Clients of unaffiliated registered
investment advisors should consult with their advisor and read their advisor’s Form ADV Part 2.
Dynamic Sub-Advisory Services Fees
Dynamic charges some unaffiliated registered investment advisors fees for performing certain Sub-
Advisory Services for their client accounts. Fees are generally based upon a percentage of the total
assets under sub-advisory arrangements with Dynamic, and generally range up to .50% annually. Fees
for Dynamic Sub-Advisory Services may be passed onto clients in certain situations. Clients of unaffiliated
registered investment advisors should consult with their advisor and read their advisor’s Form ADV Part
2.
Dynamic Financial Planning, Retainer Financial Planning and Consulting Services Fees
Dynamic offers financial planning on a fixed rate or hourly basis. The hourly rate generally ranges from
$150 to $500 per hour and fixed fees may range from $1,000 to $50,000 per project, depending on the
nature and complexity of the specific services involved in each certain engagement. Fixed fee
engagements are based on the estimated hours to complete the deliverable for the engagement. You
may also be charged for any out-of-pocket expenses, such as, postage, copying, etc. involved with the
engagement. Fixed fees are due upon receipt, unless you and your Financial Advisor specifically agree
otherwise. If you are billed on a quarterly basis and/or upon completion of work performed, you may be
required to provide an advance payment of up to 50% of the expected cost of the financial plan. These
fees may be negotiated by the Financial Advisor at his or her sole discretion. In addition, some of our
advisors include financial planning services without charging a separate fee. Financial Advisors cannot
charge pre-planning fees of $1,200 more than 6 months in advance. Consequently, services to the Client
must be performed on an ongoing basis once the initial fee is received.
For example, Financial Advisors may charge Clients a Retainer where the annual fee is $5,000 to be
paid monthly or quarterly (e.g., $416.66 per month or $1,250 per quarter). The Retainer Agreement
renews automatically every year unless terminated in writing by the Client or the Financial Advisor or if
payment is not received by the Client as agreed upon.
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A Retainer Agreement includes financial planning, consulting and related services, and in certain cases
discretionary or non-discretionary investment management is included. Retainer fees are generally billed
monthly or quarterly in advance, unless you and your Financial Advisor specifically agree otherwise.
Retainer fee arrangements generally range from $1,000 to $20,000 per year, depending upon several
factors including, but not limited to the scope of work in the Agreement, the type or amount of Client
assets and/or net worth, and on the nature and complexity of the specific services involved in each
engagement.
Whether you implement any investment recommendations resulting from the financial planning services
provided by your Financial Advisor is entirely your decision. If you implement recommendations, you may
do so through the financial professional of your choice. If you implement recommendations through your
Financial Advisor, Dynamic and your Financial Advisor will receive compensation for the services
provided in conjunction with that implementation. Certain Financial Advisors are also licensed to sell
insurance products and are compensated with commissions for recommending insurance solutions to
you as part of your financial plan. See your Financial Advisor’s ADV 2B for information about additional
compensation.
You may terminate a planning or fixed retainer fee agreement at any time by providing written notice to
Dynamic. In the event you wish to cancel the agreement under which any plan or service is being
provided, any unearned fees will be returned to you.
Dynamic Retirement Plan Services Fees
Dynamic’s Fees for Retirement Plan services generally range from .10% to 1.20% of the plan assets,
depending upon the total plan assets. All Dynamic's fees are detailed in the IMAA. All plan fees are
detailed in a separate disclosure provided to plan sponsors.
ERISA Fees
Fees charged for ERISA fiduciary or non-fiduciary services are agreed upon between the plan sponsor,
Dynamic and Financial Advisor. Fees may be based on a percentage of plan assets per year, hourly
charges, or a fixed fee. All fees are detailed in an Investment Management Adoption Agreement ("IMAA")
between the plan fiduciaries, and Dynamic.
When Complete 401k is selected by a Plan Sponsor, Dynamic is paid a 5-basis point annual 3(38)
investment fiduciary fee from the Plan assets in Complete 401k. In addition, Dynamic receives a Fee for
3(21) plan services as stated in the IMAA. When other retirement plan solutions are selected, Dynamic’s
3(21) and 3(38) investment fiduciary fees are combined and listed as a single fee in the IMAA.
Fees for Sub-advisors
The fees for sub-advisors used by Dynamic to sub-advise Client portfolios are paid from Investment
Advisory Fees Dynamic charges as outlined above. In certain instances, you may pay higher Investment
Advisory Fees to Dynamic if a sub-advisor is used. Total Investment Advisory Fees shall not exceed
2.25% per year, including the sub-advisor.
Fees for Third-party Account Managers
If you are using a third-party manager under a separate agreement, the third-party manager will bill you
or your account directly for their services. In some circumstances when a third-party manager is used,
Dynamic will charge you or your account an amount equal to Dynamic’s Investment Advisory Fee plus
the third-party manager’s fee. The third-party manager’s fee is usually calculated in the same manner
as Dynamic’s Fee and charged quarterly. The amount of the third-party manager’s fee is disclosed in the
separate agreement between you and the third-party manager and in the third-party manager’s Form
ADV 2 (or similar disclosure as this). Investment Advisory Fees plus the third-party manager’s fee shall
not exceed 2.25% annually.
In the event that you decide to terminate your relationship with a third-party manager, the provisions for
termination are set forth in the respective agreements between you and such certain third parties.
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Dynamic and your Financial Advisor will assist you with the termination and transition process, as
appropriate.
Fees for Outside Accounts
Financial Advisors may also manage and recommend allocations, as well as provide consolidated
reporting for Outside Accounts as such sub-accounts of variable annuities, fixed annuities, 529 Plans,
401ks, REITs, private equity, private debt, and other similar accounts generally not held by a custodian
of other Client securities managed by Dynamic and Financial Advisors. If included as managed accounts
in an IMA, Outside Accounts are subject to an Investment Management Fee as described above.
Investment Advisory Fees for Outside Accounts may range up to 2.25% annually, depending upon
several factors, including the size of accounts managed and type of assets held within the accounts.
Outside Accounts Holding Non-Tradeable Assets
Financial Advisors may recommend that a portion of your account be invested in illiquid securities or
securities that are not regularly valued or immediately redeemable (“Non-tradeable Assets”). Non-
tradeable Assets may not be held by a custodian that is holding other accounts managed by Dynamic
and Financial Advisors. Non-tradeable Assets may be included in the accounts on the IMA and subject
to a Fee. Some Non-tradeable Assets do not provide regular valuation updates or accurate and current
valuations. Consequently, Fees could be over or understated on Non-tradeable Assets. Dynamic relies
upon third-party sources for account data to determine the calculation of Fees, including Fees for Non-
tradeable Assets. Dynamic attempts to obtain statements for Non-tradeable Assets in order to properly
value these positions for Fees. Clients should immediately notify Dynamic or their Financial Advisor if
they believe their Fees are incorrect.
Dynamic receives a service fee from third party vendors that act as agent for certain Clients with variable
insurance products or contracts who were referred to one of these vendors by a Financial Advisor. The
receipt of service fees creates a conflict of interest that incentivizes Financial Advisors to recommend
that Clients transfer their insurance product or contract to one of these vendors. Although the receipt of
the service fee creates a conflict of interest for Dynamic, we believe many Clients can benefit from this
arrangement by receiving a more comprehensive and integrated service of their Assets.
We will adhere to our fiduciary duty and make a recommendation when we deem it to be in your best
interest.
Research and Investment Models Services
Fees for research and investment models offered by certain Financial Advisors range from $50 to $2,500
per month, based upon the amount of research and number of investment models purchased. Fees for
Research Subscribers are billed and payable monthly.
Clearing, Trading, and Settlement Costs
The investment management fee charged by the Firm does not include commission charges, mark-up or
mark-down charges resulting from securities transactions affected with or through broker-dealers on the
client’s behalf. The interest charged on margin or other lending accounts is directly charged to your
custodian account. The costs of clearing, settlement, and trading of Dynamic Investment Management
Accounts are billed separately by the custodian holding your accounts (See “Brokerage Practices” section
herein below).
Other Fees and Expenses
You may incur certain fees or charges imposed by third parties, other than Dynamic, in connection with
investments made on behalf of your account. You are responsible for all custodial and securities
execution fees charged by the custodian and executing broker-dealer. The Investment Advisory Fee
charged by Dynamic is separate and distinct from these custodian and execution fees. In addition, all
fees paid to Dynamic are separate and distinct from the expenses charged by mutual funds and
exchange-traded funds to their shareholders, if applicable. These fees and expenses are described in
each fund’s prospectus. You may be able to invest in some of these products directly, without the services
of Dynamic, but would not receive the services provided by Dynamic. These services are designed,
13 | D y n a m i c A D V P a r t 2 A – 6 . 2 0 2 5
among other things, to assist you in determining which products or services are most appropriate to your
risk tolerance, financial condition, and objectives.
Compensation for Sales of Insurance Products
Certain Financial Advisors are engaged in professions other than providing financial planning and
investment advice for which they receive additional compensation. They may be licensed to sell
insurance products through various insurance companies that are unaffiliated with Dynamic. Any such
transactions result in the receipt of commissions and other compensation to the Financial Advisor.
Dynamic does not receive any commissions or other compensation for the sale of insurance products.
The insurance product sales create a conflict of interest since there is an incentive to recommend such
products based upon the commissions and other compensation paid by insurance companies to Financial
Advisor rather than based upon a client’s needs. Dynamic has policies and procedures in place to
address the conflicts of interest with disclosure, including the information contained herein and on
Financial Advisors’ Form ADV2B.
As a Dynamic Client, you are under no obligation to utilize the services of your Financial Advisor
in the purchase or sales of other products, including insurance. Commissions and other
compensation received by your Financial Advisor for insurance product sales do not reduce Fees paid to
Dynamic. It is your responsibility to determine whether insurance products being offered are appropriate
for your circumstances.
Item 6: Performance-Based Fees
Dynamic does not charge performance-based fees for its investment advisory services. The fees charged
by Dynamic are as described above and are not based upon the capital appreciation of the funds or
securities you hold.
Dynamic does not manage any proprietary investment funds or limited partnerships (for example, a
mutual fund or a hedge fund).
Item 7: Types of Clients
Investment Advisory Services
Dynamic, through Financial Advisors, offers investment advisory services to individuals, high net worth
individuals, trusts, estates, charitable organizations, pension plans, profit sharing plans, businesses and
other investment advisors who sponsor investment management programs. Dynamic generally does not
impose a minimum account size for establishing a relationship, however, some Financial Advisors may
require minimum total client assets to establish a relationship.
RIA Professional Services
Dynamic offers a range of professional services, including back-office support, technology solutions,
investment management and administrative services to other independent financial advisors and
registered investment advisors for a fee.
ERISA Clients
If a Client’s account is a pension or other employee benefit plan governed by the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”), Dynamic is a fiduciary to the plan. In providing our
investment management services, the sole standard of care imposed upon us is to act with the care, skill,
prudence and diligence under the circumstances then prevailing that a prudent man acting in a like capacity
and familiar with such matters would use in the conduct of an enterprise of a like character and with like
aims.
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When we provide investment advice to you regarding your retirement plan or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The
way we make money creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours.
Dynamic will provide certain required disclosures to the “responsible plan fiduciary” (as such term is defined
in ERISA) in accordance with Section 408(b)(2), regarding the services we provide and the direct and
indirect compensation we receive by such clients.
Generally, these disclosures are contained in this Form ADV Part 2A, the client agreement and/or in
separate ERISA disclosure documents and are designed to enable the ERISA plan’s fiduciary to: (1)
determine the reasonableness of all compensation received by Dynamic; (2) identify any potential conflicts
of interests; and (3) satisfy reporting and disclosure requirements to plan participants.
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Item 8: Methods of Analysis, Investment Strategies, and Risk of
Loss
Methods of Analysis
Dynamic and its Financial Advisors primarily employ fundamental and technical analysis methods in
developing investment strategies for you.
Fundamental analysis is a method of evaluating a company that has issued securities by attempting to
measure the value of its underlying assets. This involves researching overall economic and industry
conditions as well as the financial condition and the quality of the company’s management. Earning,
expenses, assets, and liabilities are all important in determining the value of a company. The value is
then compared to the current price of the company’s securities to determine whether to purchase, sell or
hold those securities.
Technical analysis is a method of evaluating securities by analyzing statistics associated with market
activity, such as past prices and trading volume. Technical analysis involves using charts and other tools
to identify patterns that can suggest future performance. Research and analysis are 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.
Dynamic Financial Advisors generally employ a long-term investment strategy for their Clients, consistent
with their financial goals. Financial Advisors may 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 your cash
needs. At times, Financial Advisors may also buy and sell positions that are more short-term in nature,
depending on your goals and/or the fundamentals of the security, sector or asset class.
Dynamic Financial Advisors may recommend portfolios with non-traded securities, private placements,
private equity, and private debt investments based upon factors that include, but are not limited to
accreditation status, the level of interest Clients express, the level of risk a Client is willing to assume,
and diversification considerations. We consider these types of investments to have a higher degree of
risk. Generally, there is no ready market for these types of investments and therefore they are less liquid
than marketable, exchange traded securities. Consequently, these investments are limited to persons
who meet certain income and/or net worth requirements.
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value.
You should be prepared to bear the potential risk of loss. Financial Advisors will assist you in determining
an appropriate strategy based on your tolerance for risk and other factors noted above. However, there
is no guarantee that you will meet your investment goals. Your engagement will entail a review of your
investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an
appropriate strategy for managing your account.
All investments have certain risks. Investing in securities involves the risk of loss, including the principal
amount invested, and clients should be prepared to bear this loss. Below is a more complete discussion
of the types of risks inherent in the securities and investment techniques referenced above. The value of
the securities held in portfolios may fluctuate because of these risks. Dynamic’s investment strategies
may be subject to the following principal investment risks:
•
Alternative Investment Risk: Alternative investments may be subject to risks including,
but not limited to, derivatives risk, liquidity risk, credit risk and commodities risk. Certain alternative
strategies involve the risk that a counterparty to a transaction will not perform as promised, which
would result in losses. Alternative strategies may employ leverage, involve extensive short
positions and/or focus on narrow segments of the market, which may magnify the overall risks
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and volatility associated with such investments. Certain alternatives such as private placements,
private equity, private credit, and non-traded REITs are not liquid and Clients are subject to long
periods in which they may not be able to liquidate any or all of their investment.
Bond Market Risk: The risk that the bond market as a whole would decline, bringing the
•
value of individual securities down with it regardless of their fundamental characteristics.
•
Call Risk: Bonds that are callable carry an additional risk because they may be called
prior to maturity depending on current interest rates thereby increasing the likelihood that
reinvestment risk may be realized.
Cash Risk: If a significant portion of the Assets is held in cash or cash-like instruments,
•
investment performance might be affected.
Credit Risk: A bond issuer’s credit rating may change, which can cause price volatility,
•
and in the case of a credit rating downgrade, lower prices.
•
Cryptocurrency Risk: Cryptocurrency is a digital representation of value that functions
as a medium of exchange, a unit of account, or a store of value, but it does not have legal tender
status. Cryptocurrencies are sometimes exchanged for U.S. dollars or other currencies around
the world, but they are not currently backed nor supported by any government or central bank.
Their value is completely derived by market forces of supply and demand, and they are more
volatile than traditional currencies, stocks, bonds or other “traditional asset classes.”
Trading (buying/ selling) in cryptocurrencies comes with significant risks, including volatile market
price swings or flash crashes, market manipulation, and cybersecurity risks and risk of losing
principal or all of your investment. In addition, cryptocurrency markets and exchanges are not
regulated with the same controls or customer protections available in equity, option, futures, or
foreign exchange investing. Cryptocurrency trading requires knowledge of cryptocurrency
markets. In attempting to profit through cryptocurrency trading, you must compete with traders
worldwide. You should have appropriate knowledge and experience before engaging in
substantial cryptocurrency trading.
Cryptocurrency trading may not generally be appropriate, particularly with funds drawn from
retirement savings, student loans, mortgages, emergency funds, or funds set aside for other
purposes. Cryptocurrency trading can lead to large and immediate financial losses. Under certain
market conditions, you may find it difficult or impossible to liquidate a position quickly at a
reasonable price. This can occur, for example, when the market for a particular cryptocurrency
suddenly drops, or if trading is halted due to recent news events, unusual trading activity, or
changes in the underlying cryptocurrency system.
•
Cybersecurity risk: Intentional cybersecurity breaches include unauthorized access to
systems, networks, or devices (such as through "hacking" activity); infection from computer
viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise
disrupt operations, business processes, or website access or functionality. In addition,
unintentional incidents can occur, such as the inadvertent release of confidential information
(possibly resulting in the violation of applicable privacy laws). A cybersecurity breach could result
in the loss or theft of customer data or funds, the inability to access electronic systems ("denial of
services"), loss or theft of proprietary information or corporate data, physical damage to a
computer or network system, or costs associated with system repairs. Such incidents could cause
an investment fund, the advisor, a manager, or other service providers to incur regulatory
penalties, reputational damage, additional compliance costs, or financial loss.
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•
Default Risk: The possibility that a bond issuer will be unable to make interest or principal
payments when they are due. If these payments are not made according to the agreements in
the bond documentation, the issuer can default.
•
Foreign Risk: Investing in foreign stocks can be riskier than U.S. stock investments.
Foreign stocks tend to be more volatile and less liquid than U.S. stocks. The prices of foreign
stocks and the prices of U.S. stocks may move in opposite directions. There is also a chance that
world events—such as political upheaval, financial troubles, or natural disasters—will adversely
affect the value of securities issued by companies in foreign countries or regions.
•
General Risks of Owning Securities: The prices of securities held in client accounts
and the income they generate may decline in response to certain events taking place around the
world. These include events directly involving the issuers of securities held as underlying assets
of mutual funds in a client’s account, conditions affecting the general economy, and overall market
changes. Other contributing factors include local, regional, or global political, social, or economic
instability and governmental or governmental agency responses to economic conditions. Finally,
currency, interest rate, and commodity price fluctuations may also affect security prices and
income.
•
Hedging Risk: The risk associated with utilizing hedging strategies. Hedging instruments
such as options and certain ETFs are typically intended to limit or reduce investment risk, but can
also be expected to limit or reduce the potential for profit or result in losses. No assurance can be
given that any particular hedging strategy will be successful and achieve its desired objective, or
will make any profit, or will be able to avoid incurring losses. Certain hedging transactions may
involve the use of leverage, which could result in losses exceeding the amount committed in the
transaction.
•
Inflation Risk: 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 payments and principal,
collectively known as “cash flows.” Inflation also leads to higher interest rates, which in turn leads
to lower bond prices. Inflation-indexed securities such as Treasury Protection Securities (TIPS)
are structured to limit inflation risks.
•
Interest Rate Risk: Security price and total return will vary in response to changes in
interest rates. If rates increase, the market value of bonds generally will decline, as will the value
of your investment. Securities with longer maturities tend to produce higher yields, but are more
sensitive to changes in interest rates and are subject to greater fluctuations in value.
•
Inverse Exchange Traded Funds: An ETF traded on a public stock market, which is
designed to perform as the inverse of whatever index or benchmark it is designed to track. These
funds work by using short selling, trading derivatives such as futures contracts, and other
leveraged investment techniques. Investing in inversion ETFs is similar to holding various short
positions, or using a combination of advanced investment strategies to profit from falling prices.
Also known as a "Short ETF," or "Bear ETF." Inverse ETFs along with other ETFs that use
derivatives, typically are not used as long-term investments. Many inverse ETFs utilize daily
futures contracts to produce their returns, and this frequent trading often increases fund
expenses. Inverse and leveraged inverse ETFs tend to have higher expense ratios than standard
index ETFs, since the funds are by their nature actively managed; these costs can eat away at
performance. An inverse ETF needs to buy when the market rises and sell when it falls in order
to maintain a fixed leverage ratio. This results in a volatility loss proportional to the market
variance. Compared to a short position with identical initial exposure, the inverse ETF will
therefore usually deliver inferior returns. The exception is if the market declines significantly on
low volatility so that the capital gain outweighs the volatility loss. Such large declines benefit the
inverse ETF because the relative exposure of the short position drops as the market falls. Since
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the risk of the inverse ETF and a fixed short position will differ significantly as the index drifts away
from its initial value, differences in realized payoff have no clear interpretation. It may therefore
be better to evaluate the performance assuming the index returns to the initial level. In that case
an inverse ETF will always incur a volatility loss relative to the short position. As with synthetic
options, leveraged ETFs need to be frequently rebalanced. These strategies are generally
designed for intra-day trading, however may be held for longer durations in cases we deem it
prudent to do so.
o Compounding Risk: Compounding risk is one of the main types of risks affecting inverse
ETFs. Inverse ETFs held for periods longer than one day are affected by compounding
returns. Since an inverse ETF has a single-day investment objective of providing
investment results that are one times the inverse of its underlying index, the fund's
performance likely differs from its investment objective for periods greater than one day.
Investors who wish to hold inverse ETFs for periods exceeding one day must actively
manage and rebalance their positions to mitigate compounding risk. The effect of
compounding returns becomes more conspicuous during periods of high market
turbulence. During periods of high volatility, the effects of compounding returns cause an
inverse ETF's investment results for periods longer than one single day to substantially
vary from one times the inverse of the underlying index's return.
o Derivative Securities Risk: Many inverse ETFs provide exposure by employing
derivatives. Derivative securities are considered aggressive investments and expose
inverse ETFs to more risks, such as correlation risk, credit risk and liquidity risk. Swaps
are contracts in which one party exchanges cash flows of a predetermined financial
instrument for cash flows of a counterparty's financial instrument for a specified period.
Swaps on indexes and ETFs are designed to track the performances of their underlying
indexes or securities. The performance of an ETF may not perfectly track the inverse
performance of the index due to expense ratios and other factors, such as negative effects
of rolling futures contracts. Therefore, inverse ETFs that use swaps on ETFs usually carry
greater correlation risk and may not achieve high degrees of correlation with their
underlying indexes compared to funds that only employ index swaps. Additionally, inverse
ETFs using swap agreements are subject to credit risk. A counterparty may be unwilling
or unable to meet its obligations and, therefore, the value of swap agreements with the
counterparty may decline by a substantial amount. Derivative securities tend to carry
liquidity risk, and inverse funds holding derivative securities may not be able to buy or sell
their holdings in a timely manner, or they may not be able to sell their holdings at a
reasonable price.
o Correlation Risk: Inverse ETFs are also subject to correlation risk, which may be caused
by many factors, such as high fees, transaction costs, expenses, illiquidity and investing
methodologies. Although inverse ETFs seek to provide a high degree of negative
correlation to their underlying indexes, these ETFs usually rebalance their portfolios daily,
which leads to higher expenses and transaction costs incurred when adjusting the
portfolio. Moreover, reconstitution and index rebalancing events may cause inverse funds
to be underexposed or overexposed to their benchmarks. These factors may decrease
the inverse correlation between an inverse ETF and its underlying index on or around the
day of these events.
Futures contracts are exchange-traded derivatives that have a predetermined delivery
date of a specified quantity of a certain underlying security, or they may settle for cash on
a predetermined date. With respect to inverse ETFs using futures contracts, during times
of backwardation, funds roll their positions into less-expensive, further-dated futures
contracts. Conversely, in contango markets, funds roll their positions into more-expensive,
further-dated futures. Due to the effects of negative and positive roll yields, it is unlikely
for inverse ETFs invested in futures contracts to maintain perfectly negative correlations
to their underlying indexes on a daily basis.
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o Short Sale Exposure Risk: Inverse ETFs may seek short exposure through the use of
derivative securities, such as swaps and futures contracts, which may cause these funds
to be exposed to risks associated with short selling securities. An increase in the overall
level of volatility and a decrease in the level of liquidity of the underlying securities of short
positions are the two major risks of short selling derivative securities. These risks may
lower short-selling funds' returns, resulting in a loss.
•
Leveraged Exchange Traded Funds: Leverage is the investment strategy of using
borrowed money: specifically, the use of various financial instruments or borrowed capital to
increase the potential return of an investment. Leverage can also refer to the amount of debt used
to finance assets. When one refers to something (a company, a property or an investment) as
"highly leveraged," it means that item has more debt than equity. Like other ETFs, leveraged
ETFs are individual securities that trade on an exchange and can be bought and sold in intraday
trading. But leveraged ETFs differ from their traditional cousins in that they typically invest in one
or more derivatives, which will cause their prices to rise or fall exponentially farther than the
underlying benchmark against which they trade. For example, an ETF that is double leveraged
against the S&P 500 Index would rise and fall twice as much in price as the index itself. If the
index rises 2% in a day, then this fund would rise by 4% in value. These funds can be leveraged
at different rates, with some moving twice as much as the underlying market or index and others
rising or falling three, four or more times as much as the benchmark. There are also leveraged
ETFs that move inversely to their benchmarks, where the fund will fall in price by a given
exponential rate when the benchmark rises and vice-versa. Those that move with the markets are
referred to as long or bullish funds and those that move inversely are short or bearish. It is
important to note that many leveraged ETFs are rebalanced daily. This characteristic renders
many of them inappropriate for use as long-term holdings in an investment portfolio. They are
more appropriately used by short-term traders who buy and sell them within a matter of minutes
or hours with protective stop-loss orders. These strategies are generally designed for intra-day
trading, however may be held for longer durations in cases we deem it prudent to do so.
•
Liquidity Risk: Liquidity risk exists when particular investments would be difficult to
purchase or sell, possibly preventing clients from selling such securities at an advantageous time
or price.
•
Margin or Other Borrowings: The use of margin or other borrowings may result in
certain additional risks to you. For example, if securities pledged to brokers to secure your margin
accounts decline in value, you could be subject to a "margin call", pursuant to which you must
either deposit additional funds with the broker or be the subject of mandatory liquidation of the
pledged securities to compensate for the decline in value.
•
Market Risk: The price of any security, including ETFs, equities, bonds or mutual funds
may drop in reaction to tangible and intangible events and conditions. This type of risk is caused
by external factors independent of a security’s particular underlying circumstances. For example,
political, economic and social conditions may trigger market events.
•
Options Contracts: Investments in options contracts have the risk of losing value in a
relatively short period of time. Option contracts are leveraged instruments that allow the holder of
a single contract to control many shares of an underlying stock. This leverage can compound
gains or losses.
•
Variable Prepaid Forward Contracts: A variable prepaid forward contract is a forward
equity transaction that enables stockholders to sell shares for future delivery at an agreed
discount for cash today. Stock ownership only transfers to the other side of the VPFC at the end
of the contract term. The number of shares delivered will vary depending on the share price at
contract expiry. Contracts will typically have cap and floor strike prices that will determine how
much value is repaid by the equity seller. If at expiry the shares are trading below the floor, the
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seller transfers the number of shares as stated in the original sale. If the shares are trading within
the cap/floor range, the number of shares delivered will be a function of size of the collateralized
loan divided by the actual share price. If the share price at expiry is above the VPFC cap, the
seller will repay the principal plus additional value (the difference between the cap and the share
price multiplied by the number of shares sold). Because of the future delivery nature of the
transaction, the seller will not build up a tax liability until contract expiry. In many respects, a VPFC
is a collateralized loan, with nominal interest coming in the form of the discounted equity sale
price.
Certain transactions - including those involving futures, options, equity swaps, and other
derivatives as well as non-investment-grade securities - give rise to substantial risk and are not
available to nor suitable for all investors. You should not enter into these types of transactions
unless you understand the terms of the transaction you are entering into as well as the nature
and extent of your risk exposure. Risks involved while trading in these types of securities include,
liquidity risk, credit risk, default risk, margin risk, settlement, regulatory risk and lack of flexibility.
•
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.
•
Socially Conscious and Environmental, Social and Governance Investing: A
portfolio invested according to socially conscious principles can experience reduced asset class
diversification since the number of publicly traded companies that meet stated investment
parameters can or will be limited. Therefore, there is the potential of similarity or overlap of
holdings, especially among socially conscious mutual funds or ETFs, and a pronounced positive
or negative impact can occur with a socially conscious portfolio, which could be more volatile than
an unscreened portfolio.
•
Short Sales: A short sale involves the sale of a security that you do not own in the hope
of purchasing the same security at a later date at a lower price. To make delivery to the buyer,
you must borrow the security and are obligated to return the security to the lender, which is
accomplished by a later purchase of the security. You realize a profit or a loss as a result of a
short sale if the price of the security decreases or increases respectively between the date of the
short sale and the date on which you recover its short position, (i.e., purchases the security to
replace the borrowed security). A short sale involves the theoretically unlimited risk of an increase
in the market price of the security that would result in a theoretically unlimited loss.
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•
Structured Notes: Structured notes are complex financial instruments. Clients should
understand the reference asset(s) or index(es) and determine how the note’s payoff structure
incorporates such reference asset(s) or index(es) in calculating the note’s performance. This
payoff calculation may include leverage multiplied on the performance of the reference asset or
index, protection from losses should the reference asset or index produce negative returns, and
fees. Structured notes may have complicated payoff structures that can make it difficult for clients
to accurately assess their value, risk and potential for growth through the term of the structured
note. Determining the performance of each note can be complex and this calculation can vary
significantly from note to note depending on the structure. Notes can be structured in a wide
variety of ways. Payoff structures can be leveraged, inverse, or inverse- leveraged, which may
result in larger returns or losses. Clients should carefully read the prospectus for a structured note
to fully understand how the payoff on a note will be calculated and discuss these issues with us.
Some structured notes provide for the repayment of principal at maturity, which is often referred
to as “principal protection.” This principal protection is subject to the credit risk of the issuing
financial institution. Many structured notes do not offer this feature. For structured notes that do
not offer principal protection, the performance of the linked asset or index may cause clients to
lose some, or all, of their principal. Depending on the nature of the linked asset or index, the
market risk of the structured note may include changes in equity or commodity prices, changes in
interest rates or foreign exchange rates, or market volatility.
The price of a structured note at issuance will likely be higher than the fair value of the structured
note on the date of issuance. Issuers now disclose an estimated value of the structured note on
the cover page of the offering prospectus, allowing investors to gauge the difference between the
issuer’s estimated value of the note and the issuance price. The estimated value of the notes is
likely lower than the issuance price of the note to investors because issuers include the costs for
selling, structuring or hedging the exposure on the note in the initial price of their notes. After
issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value
given their complexity.
The ability to trade or sell structured notes in a secondary market is often very limited as structured
notes (other than exchange-traded notes known as ETNs) are not listed for trading on security
exchanges. As a result, the only potential buyer for a structured note may be the issuing financial
institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In
addition, issuers often specifically disclaim their intention to repurchase or make markets in the
notes they issue. Clients should, therefore, be prepared to hold a structured note to its maturity
date, or risk selling the note at a discount to its value at the time of sale.
Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is obligated
to make payments on the notes as promised. These promises, including any principal protection,
are only as good as the financial health of the structured note issuer. If the structured note issuer
defaults on these obligations, investors may lose some, or all, of the principal amount they
invested in the structured notes as well as any other payments that may be due on the structured
notes.
Some structured notes have “call provisions” that allow the issuer, at its sole discretion, to redeem
the note before it matures at a price that may be above, below or equal to the face value of the
structured note. If the issuer “calls” the structured note, clients may not be able to reinvest their
money at the same rate of return provided by the structured note that the issuer redeemed.
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The tax treatment of structured notes is complicated and, in some cases uncertain. Before
purchasing any structured note, clients may wish to consult with a tax advisor. Clients also should
read the applicable tax risk disclosures in the prospectuses and other offering documents of any
structured note they are considering purchasing.
Financial Planning - Risks
The tools Dynamic uses for incidental financial planning rely on various assumptions, such as estimates of
inflation, risk, economic conditions, and rates of return on security asset classes. All return assumptions
use estimates of future returns of asset classes, not returns of actual investments, and do not include fees
or expenses that clients would pay if they invested in specific products.
Financial planning software is only a tool used to help guide Financial Advisors and the client in developing
an appropriate plan. Dynamic cannot guarantee that clients will achieve the results shown in the plan.
Results will vary based on the information provided by the client regarding the client’s assets, risk tolerance,
and personal information. Changes to the program’s underlying assumptions or differences in actual
personal, economic, or market outcomes may result in materially different results for the client. Clients
should carefully consider the assumptions and limitations of the financial planning software as disclosed on
the financial planning reports and should discuss the results of the plan with a qualified investment
professional before making any changes in their investment or financial planning program.
There are conflicts of interest when we provide financial planning recommendations and offer investment
advisory services. In addition, some Financial Advisors provide insurance services as well as financial
planning recommendations, which also creates conflicts of interest. These conflicts of interest are
disclosed in Dynamic’s ADV Part 2A – Firm Brochure, and the Financial Advisor’s ADV 2B. You are not
obligated to implement any recommendations made by your Financial Advisor and your Financial Advisor
is in no way responsible for ensuring you do so.
Third Party Managers and Sub-advisors - Risks
As stated above, Dynamic may select certain third-party managers or sub-advisors to manage a portion of
its Client assets. In these situations, Dynamic continues to conduct ongoing due diligence of such
managers, but such recommendations rely to a great extent on the mangers’ ability to successfully
implement their investment strategies. In addition, Dynamic generally may not have the ability to supervise
the managers on a day-to-day basis.
Past performance is not a guarantee of future returns. Investing in securities and other
investments involve a risk of loss that you should understand and be willing to bear. You are
reminded to discuss these risks with your Financial Advisor.
Item 9: Disciplinary Information
Neither Dynamic nor its employees have been involved in any legal or disciplinary events in the past ten
years that would-be material to a client’s evaluation of the Firm or its personnel.
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Item 10: Other Financial Activities and Affiliations
RIA Professional Services
In addition to providing advisory and related services to you, Dynamic provides unaffiliated registered
investment advisors with practice support, including technology platforms, back-office support,
compliance support and other business services. These services represent approximately 20% of the
business time of Dynamic.
Dynamic has entered into a Service Agreement with a nonaffiliated RIA whereby we share various back
office, technology, accounting, payroll, human resources, marketing, administrative and investment
management related resources. Other than sharing these services, both firms are organized, managed,
and operate independently of each other. When Client assets are managed by Dynamic, the other RIA
pays a sub-advisory fee to Dynamic.
Outside Business Activities of Financial Advisors
Insurance. Certain Financial Advisors are engaged in other professions in addition to providing financial
planning and investment advice for which they receive additional compensation. They may be licensed
to sell insurance products through various insurance companies that are unaffiliated with Dynamic. As a
Dynamic Client, these products are offered separate and apart from your Financial Advisor’s relationship
with Dynamic. You are under no obligation to utilize the services of your Financial Advisor in the purchase
or sales of other products including securities, insurance, annuities, commodities, or futures products.
Any such transactions you effect through a Financial Advisor will result in the receipt of commissions and
other compensation in addition to any Investment Advisory Fees as discussed above. The commissions
and other compensation from the sale of other products do not offset the regular advisory fees charged
to client accounts managed by Dynamic. It is the client’s ultimate responsibility to determine whether
other products being offered to them are appropriate investment products.
Technology Vendor Relationship. Certain of the Firm’s principals and Financial Advisors are involved
with and have an economic interest in a third-party technology vendor that is developing an application
that will use artificial intelligence and other technology to create operational and service efficiencies for
wealth management firms like Dynamic. Dynamic has entered into a corporate sponsorship agreement
with the vendor to support the development efforts in exchange for preferred pricing on licenses to utilize
the application in its operations, if a commercially viable product is developed. During the development
phase, Dynamic will engage in collaboration with the vendor, providing firm data solely for system
integration and workflow efficiency exploration and development. Dynamic will not share Client data
containing personal information (PII) during the development of the application. If a commercially viable
product meeting Dynamic’s cybersecurity and other operational and business requirements is developed
by the vendor, Dynamic intends to enter into a vendor agreement to license the technology application.
Dynamic could benefit from this application if it is fully developed for use in its operations. If successfully
developed, the technology vendor intends to license the application to firms in the wealth management
industry. The Firm’s principals and Financial Advisors involved could benefit from these efforts.
Advisors to Qualified Retirement Plans
In the course of serving as advisor to qualified retirement plans, Dynamic or Financial Advisors may
introduce other service providers to retirement plan sponsors if they believe they may benefit from such
services. Such providers include record keepers, third-party administrators and other fiduciaries.
Dynamic does not receive a fee or other compensation for making such introductions.
Dynamic and its Financial Advisors are committed to acting in your best interests at all times. Financial
Advisors will aim to explain to you the specific costs associated with any investments recommended and
you have no obligation to purchase investments or insurance products or to implement any financial plan
recommendations through a Financial Advisor.
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Personal and Business Relationship
In Item 4, we explained that Financial Advisors may recommend specific positions to increase sector or
asset class weightings and otherwise develop an asset allocation or a targeted investment strategy for
you. Because Dynamic and its Financial Advisors have relationships with other investment professionals,
we may allocate a portion of your account to a security advised by individuals with a personal (including
familial) or business relationship with Dynamic or one of its Financial Advisors. One example of such a
relationship is that Dynamic may recommend that some Clients invest in Fundamental Income Net Lease
Real Estate ETF (NETL), which is managed by a relative of one of our Financial Advisors. No
compensation is received by Dynamic or any of our Financial Advisors in connection with such a
recommendation or allocation, other than the Investment Advisory Fee normally charged by Dynamic.
Financial Advisors affiliation with outside broker/dealers
Neither Dynamic nor its Financial Advisors are registered with a broker/dealer.
Commodity Pool Operator, Commodity Trading Advisor, Futures Commission Merchant
Registration
Dynamic is neither registered nor has an application pending to register with the Commodity Futures Trading
Commission (“CFTC”) as a futures commission merchant (“FCM”), a commodity pool operator (“CPO”)
or a commodity trading advisor (“CTA”) or have any application pending to be registered with respect to
any of the foregoing.
Item 11: Code of Ethics, Participation in Client Transactions, and
Personal Trading
Code of Ethics
Dynamic has implemented a Code of Ethics to define our fiduciary commitment to you. This Code of
Ethics applies to all persons associated with Dynamic. The Code of Ethics was developed to provide
general ethical guidelines and specific instructions regarding our duties to you, our Client. Dynamic and
its personnel owe a duty of loyalty, fairness, and good faith to you. It is the obligation of Dynamic
associates to adhere not only to the specific provisions of the Code, but also to the general principles
that guide the Code of Ethics.
The Code of Ethics covers a range of topics that may include; general ethical principles, reporting
personal securities trading, exceptions to reporting securities trading, reportable securities, initial public
offerings, and private placements, reporting ethical violations, distribution of the Code of Ethics, review
and enforcement processes, amendments to Form ADV, managing conflicts of interest, and supervisory
procedures. Dynamic has established its Code of Ethics to meet and exceed regulatory standards. We
will provide a copy of our Code of Ethics to any client or prospective client upon request.
Personal Trading and Conflicts of Interest
Dynamic allows Financial Advisors and our personnel to purchase or sell the same securities that may
be recommended to and purchased on your behalf. Owning the same securities, we recommend 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, consistent with Section 204A of the Investment Advisers Act of 1940,
a Code of Ethics, which addresses insider trading (material non-public information controls) and personal
securities reporting procedures. We have also adopted written policies and procedures to detect the
misuse of material, non-public information. We may have an interest or position in certain securities,
which may also be recommended to you. At no time, will Dynamic or any associated person of Dynamic,
transact in any security to your detriment.
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Item 12: Brokerage Practices
Recommendation of Custodians
Dynamic and its Financial Advisors generally recommend Clients use either Fidelity Brokerage Services,
LLC (“Fidelity”), Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”), or
Raymond James & Associates, Inc. member of the New York Stock Exchange/SIPC (“Raymond James”)
(“custodians”) as custodians for your accounts. Dynamic does not have discretionary authority to select
the broker-dealer/custodian for custodial and execution services or to select the administrator for defined
contribution accounts. You, in consultation with your Financial Advisor, determine the broker-dealer or
custodian to safeguard your assets and authorize Dynamic to direct trades to this custodian as agreed
in the Investment Management Agreement and custodian documents.
Further, Dynamic does not have the discretionary authority to negotiate commissions on your behalf on
a trade-by-trade basis. You are not obligated to use the recommended custodian and will not incur any
extra fee or cost from Dynamic by using a custodian not recommended by Dynamic. Dynamic may
recommend a custodian based on criteria such as, but not limited to, reasonableness of commissions
charged to you, services made available to you and Financial Advisors, and location of the custodian’s
offices.
Directed Brokerage
You are serviced on a “directed brokerage basis”, where Dynamic will place trades within the established
account at the custodian designated by you. Further, your accounts are traded within their respective
brokerage account. Because you are selecting the custodian for your accounts, Dynamic 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 your designated custodian. Please
note that not all advisers require their clients to direct brokerage.
Dynamic may not engage in any principal transactions (i.e., trade of any security from or to Dynamic’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).
Aggregating and Allocating Trades
Dynamic does not generally aggregate trades. The primary objective in placing orders for the purchase
and sale of securities for your 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 broker. Dynamic executes its transactions through unaffiliated custodians. Dynamic may - but is
not required to 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.
Trade Errors
From time-to-time Dynamic may make an error in submitting a trade order on your behalf. An overriding
principle in dealing with a trading error made by Dynamic or a Financial Advisor (or any other party to the
trade other than the client) is that the client never pays for losses resulting from such errors. In general,
when the error and responsible party are identified, the trade is broken immediately, if possible, and the
error is corrected the same day.
Research and Other Soft-Dollar Benefits
Dynamic currently has no written soft dollar agreements.
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Item 13: Review of Accounts
During periodic reviews, Dynamic seeks to analyze a variety of factors, including risk tolerance, suitability
and fiduciary standards. Dynamic requires that the Financial Advisors have a reasonable basis to believe
that recommended investment strategies are in the best interest of its clients based on information
obtained from clients through reasonable diligence. In addition, account reviews will take into
consideration the current economic environment, the outlook for the securities markets, and the merits of
the securities in which the accounts are invested.
Clients are strongly encouraged to immediately notify their Financial Advisor of the following: (a) a change
in the client’s investment objectives, guidelines and/or financial situation; (b) change in strategy or
diversification; (c) change in tax considerations; (d) plans to add or withdrawn from the account; and (e)
any other changes or concerns their Financial Advisory may need to know to properly manage their
accounts. For discretionary accounts, the allocation of each portfolio is adjusted, and securities selected,
at the Financial Advisor’s discretion, in accordance with the client's investment objectives, risk tolerance,
and financial needs. Accounts are reviewed by Financial Advisors on a periodic basis.
Third Party Manager
Financial Advisors will review third party money manager reports provided to the client in order to review
client’s investment and financial profile. Dynamic will assist client to understand and evaluate services
provided by the third-party manager. The client is expected to notify Dynamic of any changes in his/her
financial situation, investment objectives, or account restrictions that could affect their account. Upon client
request, Dynamic will contact directly the third-party money manager managing to account to facilitate any
request from the client.
Advisory & Consultation Services for Retirement Plan Sponsors
Retirement Plan Sponsor clients’ advisory accounts will be reviewed based on the terms outlined in the
Investment Policy Statement and advisory agreement. For clients that have entered into a consultation
agreement, the frequency and scope of periodic review will be stipulated in the Investment Policy
Statement and in the agreement for services.
Reports
You will receive brokerage statements no less than quarterly from the trustee or custodian of your
account. These brokerage statements are sent directly from the custodian to you either electronically or
by physical mail, at your election. You may also establish electronic access to the custodian’s website so
that you may view these reports and your account activity. Your brokerage statements will include all
positions, transactions and fees relating to your account.
Dynamic also provides you with periodic reports regarding your holdings, allocations, and performance
via an on-line portal which you may access with a unique user ID and password. You may request that
your Financial Advisor provide physical copies of these Dynamic reports to you. You are encouraged to
compare any reports from Dynamic or your Financial Advisor with statements from custodians.
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Item 14: Client Referrals and Other Compensation
Certain Financial Advisors are engaged in other professions in addition to providing financial planning
and investment advice for which they receive additional commissions and compensation. They may be
licensed to sell insurance products through various insurance companies that are unaffiliated with
Dynamic. Any such transactions you may affect through a Financial Advisor result in the receipt of
commissions and other compensation in addition to any Investment Advisory Fees as discussed above.
The insurance product sales create a conflict of interest since there is an incentive to recommend such
products based upon the commissions and other compensation paid by insurance companies rather than
based upon a client’s needs.
Dynamic has procedures in place to address the conflicts of interest with disclosure, including the
information contained herein and on Financial Advisors’ Form ADV2Bs. As a Dynamic Client, you are
under no obligation to utilize the services of your Financial Advisor in the purchase or sales of other
products including insurance. Commissions and other compensation received by your Financial Advisor
for insurance product sales do not reduce Fees paid to Dynamic and Financial Advisors.
Referrals
Dynamic has Agreements with certain unaffiliated investment advisors, other outside RIA Firms,
custodians, and other professionals to compensate them for referring Clients to Dynamic. As disclosed
in an Agreement between such Parties and Dynamic, Dynamic pays a portion of the Investment Advisory
Fee to the Party who refers a Client to Dynamic. Any such referral fee is paid solely from Dynamic’s
Investment Advisory Fee and does not result in any additional charge to the Client.
Dynamic is required to disclose this arrangement with the referred Client. This disclosure contains the
terms and conditions of the arrangement.
for prospect
referrals
that may
result
in
the
Lead Generators and Other Compensation
Dynamic and many of our advisers have entered into arrangements with one or more third-party
intermediaries pursuant to which it agrees to compensate the third-party intermediaries or “Lead
Generators”
referred clients establishing
an investment advisory relationship with Dynamic. Such compensation will be paid on a flat fee per
referral(s) and is not dependent upon whether the referred prospect becomes a client or not, and no
portion of any fees paid are not passed on to referred clients.
Other Consideration and Benefits
Dynamic and Financial Advisors, in certain cases, receive benefits and other support from product
sponsors and custodians used and recommended by Financial Advisors. In certain cases, these
companies provide for technology, training, education, industry meetings, client events and marketing.
The benefits are generally paid in the form of reimbursement or direct payment of expenses. The receipt
of such benefits is a conflict of interest as Dynamic and/or Financial Advisors may recommend products
or custodians based upon these arrangements. Dynamic and Financial Advisors are obligated to act in
the client's best interest at all times.
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Item 15: Custody
Dynamic does not accept or maintain custody of your accounts. You must place your assets with a
qualified third-party custodian. You select your own custodian, in consultation with your Financial Advisor,
to hold your funds and securities and direct Dynamic to utilize that custodian for your securities
transactions. You will receive statements from your custodian at least quarterly. We urge you to review
these statements and ensure the transactions are consistent with your objectives. For more information
about custodians and brokerage practices, see “Brokerage Practices” herein above.
Item 16: Investment Discretion
Dynamic generally has discretion over the selection and the amount of securities to be bought or sold in
your accounts without obtaining prior consent or approval from you. However, these purchases or sales
are subject to specified investment objectives, guidelines, or limitations previously set forth by you and
agreed to by Dynamic. Discretionary authority will only be authorized upon full disclosure to you. The
granting of such authority will be evidenced by your execution of an Investment Management Agreement
containing all applicable limitations to such authority and necessary custodian agreements and required
custodian forms. All discretionary trades made by Dynamic are designed to be in accordance with your
investment objectives and goals.
Dynamic is authorized to make the following determinations in accordance with client objectives and
restrictions without obtaining prior consent from the client:
(1) which securities or instruments, including mutual funds, to buy or sell;
(2) the total amount of securities or instruments to buy or sell;
(3) the executing broker or dealer for any transaction;
(4) the commission rates or commission equivalents charged for transactions;
(5) whether to hire or fire a third-party manager.
Item 17: Voting Client Securities
Dynamic does not accept proxy-voting responsibility for you. Clients may contact Dynamic or their
Financial Advisor to obtain information about proxy voting. Clients will receive their proxies or other
solicitations directly from their custodian(s) or transfer agent(s).
Item 18: Financial Information
Neither Dynamic nor its management has any adverse financial situations that would reasonably impair
our ability to meet all our obligations to you. Dynamic has not been subject to a bankruptcy or financial
compromise.
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