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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
February 2026
Dynamic Financial Group, LLC
4615 Chadwick Road, Suite 1
Cedar Falls, Iowa 50613
www.DynamicFinancial.net
Firm Contact:
Darren Yoder
Chief Compliance Officer
firm
is also available on
This brochure provides information about the qualifications and business practices of Dynamic
Financial Group, LLC. If clients have any questions about the contents of this brochure, please
contact us at 319-277-2727. The information in this brochure has not been approved or verified by
the United States Securities and Exchange Commission or by any State Securities Authority.
Additional
the SEC’s website at
information about our
www.adviserinfo.sec.gov by searching CRD #288763.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who
advise clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Dynamic Financial Group, LLC, is required to make clients aware of information that has changed
since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them.
Clients can then determine whether to review the brochure in its entirety or to contact us with
questions about the changes.
Since our last annual amendment filed on 1/23/2025, we do not have any material changes to
report for our firm.
ADV Part 2A – Firm Brochure
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Dynamic Financial Group, LLC,
Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................................. 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Advisory Business.................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................. 5
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 6
Item 7: Types of Clients & Account Requirements .................................................................................................... 6
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 6
Item 9: Disciplinary Information..................................................................................................................................... 14
Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 14
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............. 14
Item 12: Brokerage Practices ........................................................................................................................................... 15
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 19
Item 14: Client Referrals & Other Compensation ..................................................................................................... 19
Item 15: Custody .................................................................................................................................................................... 20
Item 16: Investment Discretion ....................................................................................................................................... 20
Item 17: Voting Client Securities ..................................................................................................................................... 21
Item 18: Financial Information ........................................................................................................................................ 21
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Item 4: Advisory Business
Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company
formed under the laws of the
State of Iowa in 2017 and has been in business as an investment adviser since that time. Our firm is
owned by Darren Yoder (70%) and Caleb Schmidt (30%).
Our firm provides asset management and financial planning for many different types of clients to
help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As a
fiduciary it is our duty to always act in the client’s best interest. This is accomplished in part by
knowing the client. Our firm has established a service-oriented advisory practice with open lines of
communication. Working with clients to understand their investment objectives while educating
them about our process, facilitates the kind of working relationship we value.
Types of Advisory Services Offered
Comprehensive Portfolio Management:
As part of our Comprehensive Portfolio Management service, clients will be provided asset
management and financial planning or consulting services. This service is designed to assist clients
in meeting their financial goals through the use of a financial plan or consultation. Our firm
conducts client meetings to understand their current financial situation, existing resources,
financial goals, and tolerance for risk. Based on what is learned, an investment approach is
presented to the client, consisting of individual stocks, bonds, ETFs, options, mutual funds and
other public and private securities or investments. Once the appropriate portfolio has been
determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced
based upon the client’s individual needs, stated goals and objectives. Upon client request, our firm
provides a summary of observations and recommendations for the planning or consulting aspects
of this service.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Comprehensive Portfolio Management
clients. Each Comprehensive Portfolio Management client has the opportunity to place reasonable
restrictions on the types of investments to be held in the portfolio. Restrictions on investments in
certain securities or types of securities may not be possible due to the level of difficulty this would
entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of 12/31/2025, our firm managed $539,558,246 on a discretionary basis.
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Dynamic Financial Group, LLC,
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Comprehensive Portfolio Management:
The maximum annual fee charged for this service will not exceed 2.00%. Fees to be assessed will be
outlined in the advisory agreement to be signed by the client. Annualized fees are billed on a pro-
rata basis quarterly in advance based on the value of the account(s) on the last day of the previous
quarter. In rare cases, our firm will agree to directly invoice. Fees are negotiable and will be
deducted from client account(s). As part of the advisory fee deduction process, Clients understand
the following:
a)
b)
c)
The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
Clients will provide authorization permitting our firm to be directly paid by these terms.
Our firm will send an invoice directly to the custodian; and
If our firm sends a copy of our invoice to the client, the invoice will include a disclosure
urging the client to compare the information provided in our statement with those from the
qualified custodian.
Other Types of Fees & Expenses
Clients will incur transaction charges for trades executed by their chosen custodian. These
transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen
custodian. Our recommended custodian, Fidelity Brokerage Services (“Fidelity”), eliminated
transaction fees for U.S. listed equities and exchange traded funds for clients who opt into
electronic delivery of statements or maintain at least $1 million in assets at Fidelity. Clients who do
not meet either criteria will be subject to transaction fees charged by Fidelity for U.S. listed equities
and exchange traded funds.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), initial or
deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity
fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads paid to market
makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes
on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees.
Termination & Refunds
Either party may terminate the advisory agreement for our Comprehensive Portfolio Management
service by providing notice in writing to the other party at any time. Upon notice of termination,
our firm will process a pro-rata refund of any unearned portion of the advisory fees charged in
advance at the beginning of the quarter.
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Dynamic Financial Group, LLC,
Commissionable Securities Sales
Representative(s) of our firm are registered representatives of Mutual Securities, Inc. (“Mutual
Securities”), member FINRA/SIPC. As such they are able to accept compensation for the sale of
securities or other investment products, including distribution or service (“trail”) fees from the sale
of mutual funds. Clients should be aware that the practice of accepting commissions for the sale of
securities presents a conflict of interest and gives our firm and/or our representatives an incentive
to recommend investment products based on the compensation received. Our firm generally
addresses commissionable sales conflicts that arise when explaining to clients these sales create an
incentive to recommend based on the compensation to be earned and/or when recommending
commissionable mutual funds, explaining that “no-load” funds are also available. Our firm does not
prohibit clients from purchasing recommended investment products through other unaffiliated
brokers or agents.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
•
•
•
Individuals and High Net Worth Individuals;
Trusts, Estates or Charitable Organizations; and
Corporations, Limited Liability Companies and/or Other Business Types
Our firm does not impose requirements for opening and maintaining accounts or otherwise
engaging us.
Clients who opt into electronic delivery of statements or maintain at least $1 million in assets at
Fidelity will not be charged transaction fees for U.S. listed equities and exchange traded funds.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Charting:
In this type of technical analysis, our firm reviews charts of market and security activity
in an attempt to identify when the market is moving up or down and to predict when how long the
trend may last and when that trend might reverse.
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Cyclical Analysis:
Statistical analysis of specific events occurring at a sufficient number of
relatively predictable intervals that they can be forecasted into the future. Cyclical analysis asserts
that cyclical forces drive price movements in the financial markets. Risks include that cycles may
invert or disappear and there is no expectation that this type of analysis will pinpoint turning
points, instead be used in conjunction with other methods of analysis.
Fundamental Analysis:
The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches
one can use: bottom-up analysis and top-down analysis. The terms are used to distinguish such
analysis from other types of investment analysis, such as quantitative and technical. Fundamental
analysis is performed on historical and present data, but with the goal of making financial forecasts.
There are several possible objectives: (a) to conduct a company stock valuation and predict its
probable price evolution; (b) to make a projection on its business performance; (c) to evaluate its
management and make internal business decisions; (d) and/or to calculate its credit risk.; and (e)
to find out the intrinsic value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are
two basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets
may misprice a security in the short run but that the "correct" price will eventually be reached.
Profits can be made by purchasing the mispriced security and then waiting for the market to
recognize its "mistake" and reprice the security.; and (b) Technical analysis maintains that all
information is reflected already in the price of a security. Technical analysts analyze trends and
believe that sentiment changes predate and predict trend changes. Investors' emotional responses
to price movements lead to recognizable price chart patterns. Technical analysts also analyze
historical trends to predict future price movement. Investors can use one or both of these different
but complementary methods for stock picking. This presents a potential risk, as the price of a
security can move up or down along with the overall market regardless of the economic and
financial factors considered in evaluating the stock.
Technical Analysis:
A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the
history of a security's trading pattern rather than external drivers such as economic, fundamental
and news events. Therefore, price action tends to repeat itself due to investors collectively tending
toward patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are
mathematical transformations of price, often including up and down volume, advance/decline data
and other inputs. These indicators are used to help assess whether an asset is trending, and if it is,
the probability of its direction and of continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among
traders and financial professionals and is very often used by active day traders, market makers and
pit traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
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Dynamic Financial Group, LLC,
Investment Strategies
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Alternative Investments:
Hedge funds, commodity pools, Real Estate Investment Trusts (“REITs”),
Business Development Companies (“BDCs”), and other alternative investments involve a high
degree of risk and can be illiquid due to restrictions on transfer and lack of a secondary trading
market. They can be highly leveraged, speculative and volatile, and an investor could lose all or a
substantial amount of an investment. Alternative investments may lack transparency as to share
price, valuation and portfolio holdings. Complex tax structures often result in delayed tax reporting.
Compared to mutual funds, hedge funds and commodity pools are subject to less regulation and
often charge higher fees. Alternative investment managers typically exercise broad investment
discretion and may apply similar strategies across multiple investment vehicles, resulting in less
diversification.
Asset Allocation:
The implementation of an investment strategy that attempts to balance risk
versus reward by adjusting the percentage of each asset in an investment portfolio according to the
investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle
that different assets perform differently in different market and economic conditions. A
fundamental justification for asset allocation is the notion that different asset classes offer returns
that are not perfectly correlated, hence diversification reduces the overall risk in terms of the
variability of returns for a given level of expected return. Although risk is reduced as long as
correlations are not perfect, it is typically forecast (wholly or in part) based on statistical
relationships (like correlation and variance) that existed over some past period. Expectations for
return are often derived in the same way.
investment-grade or
An asset class is a group of economic resources sharing similar characteristics, such as riskiness
and return. There are many types of assets that may or may not be included in an asset allocation
strategy. The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a
"blend" of any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap;
domestic, foreign [developed], emerging or frontier markets), bonds (fixed income securities more
junk [high-yield]; government or corporate; short-term,
generally:
intermediate, long-term; domestic, foreign, emerging markets), and cash or cash equivalents.
Allocation among these three provides a starting point. Usually included are hybrid instruments
such as convertible bonds and preferred stocks, counting as a mixture of bonds and stocks. Other
alternative assets that may be considered include: commodities: precious metals, nonferrous
metals, agriculture, energy, others.; Commercial or residential real estate (also REITs); Collectibles
such as art, coins, or stamps; insurance products (annuity, life settlements, catastrophe bonds,
personal life insurance products, etc.); derivatives such as long-short or market neutral strategies,
options, collateralized debt, and futures; foreign currency; venture capital; private equity; and/or
distressed securities.
•
There are several types of asset allocation strategies based on investment goals, risk tolerance, time
frames and diversification. The most common forms of asset allocation are: strategic, dynamic,
tactical, and core-satellite.
Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an
asset mix that seeks to provide the optimal balance between expected risk and return for a
long-term investment horizon. Generally speaking, strategic asset allocation strategies are
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Dynamic Financial Group, LLC,
•
[3]
•
•
agnostic to economic environments, i.e., they do not change their allocation postures
relative to changing market or economic conditions.
Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in
that portfolios are built by allocating to an asset mix that seeks to provide the optimal
balance between expected risk and return for a long-term investment horizon.
Like
strategic allocation strategies, dynamic strategies largely retain exposure to their original
asset classes; however, unlike strategic strategies, dynamic asset allocation portfolios will
adjust their postures over time relative to changes in the economic environment.
Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a
more active approach that tries to position a portfolio into those assets, sectors, or
individual stocks that show the most potential for perceived gains. While an original asset
mix is formulated much like strategic and dynamic portfolio, tactical strategies are often
traded more actively and are free to move entirely in and out of their core asset classes
Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core'
strategic element making up the most significant portion of the portfolio, while applying a
dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this
way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical
allocation strategies mentioned above.
Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis:
Analysis of the experience and
track record of the manager of the mutual fund or ETF in an attempt to determine if that manager
has demonstrated an ability to invest over a period of time and in different economic conditions.
The underlying assets in a mutual fund or ETF are also reviewed in an attempt to determine if there
is significant overlap in the underlying investments held in another fund(s) in the Client’s portfolio.
The funds or ETFs are monitored in an attempt to determine if they are continuing to follow their
stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities
investments, past performance does not guarantee future results. A manager who has been
successful may not be able to replicate that success in the future. In addition, as our firm does not
control the underlying investments in a fund or ETF, managers of different funds held by the Client
may purchase the same security, increasing the risk to the Client if that security were to fall in
value. There is also a risk that a manager may deviate from the stated investment mandate or
strategy of the fund or ETF, which could make the holding(s) less suitable for the Client’s portfolio.
Fixed Income:
Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed-income investments because of
the reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid
income face the risk of inflation eroding their spending power.
Some examples of fixed-income investments include treasuries, money market instruments,
corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary
risk associated with fixed-income investments is the borrower defaulting on his payment. Other
considerations include exchange rate risk for international bonds and interest rate risk for longer-
dated securities. The most common type of fixed-income security is a bond. Bonds are issued by
federal governments, local municipalities and major corporations. Fixed-income securities are
recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio
dedicated to fixed income depends on your own personal investment style. There is also an
opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products,
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Dynamic Financial Group, LLC,
such as junk bonds and longer-dated products, should comprise a lower percentage of your overall
portfolio.
The interest payment on fixed-income securities is considered regular income and is determined
based on the creditworthiness of the borrower and current market rates. In general, bonds and
fixed-income securities with longer-dated maturities pay a higher rate, also referred to as the
coupon rate, because they are considered riskier. The longer the security is on the market, the more
time it has to lose its value and/or default. At the end of the bond term, or at bond maturity, the
borrower returns the amount borrowed, also referred to as the principal or par value.
Individual Stocks
: A common stock is a security that represents ownership in a corporation.
Holders of common stock exercise control by electing a board of directors and voting on corporate
policy. Investing in individual common stocks provides us with more control of what you are
invested in and when that investment is made. Having the ability to decide when to buy or sell helps
us time the taking of gains or losses. Common stocks, however, bear a greater amount of risk when
compared to certificate of deposits, preferred stock and bonds. It is typically more difficult to
achieve diversification when investing in individual common stocks. Additionally, common
stockholders are on the bottom of the priority ladder for ownership structure; if a company goes
bankrupt, the common stockholders do not receive their money until the creditors and preferred
shareholders have received their respective share of the leftover assets.
Long-Term Purchases:
Our firm may buy securities for your account and hold them for a relatively
long time (more than a year) in anticipation that the security’s value will appreciate over a long
horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that
could have been profitable to your account, or it’s possible that the security’s value may decline
sharply before our firm make a decision to sell.
Short Sales:
A short sale is a transaction in which an investor sells borrowed securities in
anticipation of a price decline and is required to return an equal number of shares at some point in
the future. These transactions have a number of risks that make it highly unsuitable for the notice
investor. This strategy has a slanted payoff ratio in that the maximum gain (which would occur if
the shorted stock was to plunge to zero) is limited, but the maximum loss is theoretically infinite
(since stocks can in theory go up infinitely in price). The following risks should be considered: (1)
In addition to trading commissions, other costs with short selling include that of borrowing the
security to short it, as well as interest payable on the margin account that holds the shorted
security. (2) The short seller is responsible for making dividend payments on the shorted stock to
the entity from whom the stock has been borrowed. (3) Stocks with very high short interest may
occasionally surge in price. This usually happens when there is a positive development in the stock,
which forces short sellers to buy the shares back to close their short positions. Heavily shorted
stocks are also susceptible to “buy-ins,” which occur when a broker closes out short positions in a
difficult-to-borrow stock whose lenders are demanding it back. (4) Regulators may impose bans on
short sales in a specific sector or even in the broad market to avoid panic and unwarranted selling
pressure. Such actions can cause a spike in stock prices, forcing the short seller to cover short
positions at huge losses. (5) Unlike the “buy-and-hold” investor who can afford to wait for an
investment to work out, the short seller does not have the luxury of time because of the many costs
and risks associated with short selling. Timing is everything when it comes to shorting. (5) Short
selling should only be undertaken by experienced traders who have the discipline to cut a losing
short position, rather than add to it hoping that it will eventually work out.
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Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease, and the account(s) could suffer a loss. It is important that clients understand the
risks associated with investing in the stock market, are appropriately diversified in investments,
and ask any questions.
Capital Risk:
Capital risk is one of the most basic, fundamental risks of investing; it is the risk that
you may lose 100% of your money. All investments carry some form of risk, and the loss of capital
is generally a risk for any investment instrument.
Company Risk:
When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as unsystematic
risk and can be reduced through appropriate diversification. There is the risk that the company
will perform poorly or have its value reduced based on factors specific to the company or its
industry. For example, if a company’s employees go on strike or the company receives unfavorable
media attention for its actions, the value of the company may be reduced.
Credit Risk:
Credit risk can be a factor in situations where an investment’s performance relies on a
borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or
unfavorable performance if a borrower does not repay the borrowed funds as expected or required.
Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit
risk.
Currency Risk:
Fluctuations in the value of the currency in which your investment is denominated
may affect the value of your investment and thus, your investment may be worth more or less in the
future. All currency is subject to swings in valuation and thus, regardless of the currency
denomination of any particular investment you own, currency risk is a realistic risk measure. That
said, currency risk is generally a much larger factor for investment instruments denominated in
currencies other than the most widely used currencies (U.S. dollar, British pound, German mark,
Euro, Japanese yen, French franc, etc.).
Economic Risk:
The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country
that experiences wide swings from an economic standpoint or in situations where certain elements
of an investment instrument are hinged on dealings in such countries, the investment instrument
will generally be subject to a higher level of economic risk.
Equity (Stock) Market Risk:
Common stocks are susceptible to general stock market fluctuations
and to volatile increases and decreases in value as market confidence in and perceptions of their
issuers change. If you held common stock, or common stock equivalents, of any given issuer, you
would generally be exposed to greater risk than if you held preferred stocks and debt obligations of
the issuer.
ETF & Mutual Fund Risk
: When investing in an ETF or mutual fund, you will bear additional
expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including
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Dynamic Financial Group, LLC,
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients will also
incur brokerage costs when purchasing ETFs.
Financial Risk:
Financial risk is represented by internal disruptions within an investment or the
issuer of an investment that can lead to unfavorable performance of the investment. Examples of
financial risk can be found in cases like Enron or many of the dot com companies that were caught
up in a period of extraordinary market valuations that were not based on solid financial footings of
the companies.
Growth Securities Risk:
Securities of companies perceived to be “growth” companies may be more
volatile than other stocks and may involve special risks. The price of a “growth” security may be
impacted if the company does not realize its anticipated potential or if there is a shift in the market
to favor other types of securities.
Inflation Risk
: Inflation risk involves the concern that in the future, your investment or proceeds
from your investment will not be worth what they are today. Throughout time, the prices of
resources and end-user products generally increase and thus, the same general goods and products
today will likely be more expensive in the future. The longer an investment is held, the greater the
chance that the proceeds from that investment will be worth less in the future than what they are
today. Said another way, a dollar tomorrow will likely get you less than what it can today.
Interest Rate Risk:
Certain investments involve the payment of a fixed or variable rate of interest
to the investment holder. Once an investor has acquired or has acquired the rights to an investment
that pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the
market will affect the value of the interest-paying investment(s) they hold. In general, changes in
prevailing interest rates in the market will have an inverse relationship to the value of existing,
interest paying investments. In other words, as interest rates move up, the value of an instrument
paying a particular rate (fixed or variable) of interest will go down. The reverse is generally true as
well.
Legal/Regulatory Risk:
Certain investments or the issuers of investments may be affected by
changes in state or federal laws or in the prevailing regulatory framework under which the
investment instrument or its issuer is regulated. Changes in the regulatory environment or tax laws
can affect the performance of certain investments or issuers of those investments and thus, can
have a negative impact on the overall performance of such investments.
Liquidity Risk:
Certain assets may not be readily converted into cash or may have a very limited
market in which they trade. Thus, you may experience the risk that your investment or assets
within your investment may not be able to be liquidated quickly, thus, extending the period of time
by which you may receive the proceeds from your investment. Liquidity risk can also result in
unfavorable pricing when exiting (i.e. not being able to quickly get out of an investment before the
price drops significantly) a particular investment and therefore, can have a negative impact on
investment returns.
Market Risk:
The value of your portfolio may decrease if the value of an individual company or
multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is
incorrect. Further, regardless of how well individual companies perform, the value of your portfolio
could also decrease if there are deteriorating economic or market conditions. It is important to
understand that the value of your investment may fall, sometimes sharply, in response to changes
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in the market, and you could lose money. Investment risks include price risk as may be observed by
a drop in a security’s price due to company specific events (e.g. earnings disappointment or
downgrade in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock
values fall in general). For fixed-income securities, a period of rising interest rates could erode the
value of a bond since bond values generally fall as bond yields go up. Past performance is not a
guarantee of future returns.
Market Timing Risk:
Market timing can include high risk of loss since it looks at an aggregate
market versus a specific security. Timing risk explains the potential for missing out on beneficial
movements in price due to an error in timing. This could cause harm to the value of an investor's
portfolio because of purchasing too high or selling too low.
Mid-Sized Companies Risk:
Investments in securities issued by mid-sized companies may involve
greater risks than are customarily associated with larger, more established companies. Securities
issued by mid-sized companies tend to be more volatile than securities issued by larger or more
established companies and may underperform as compared to the securities of larger companies.
Money Market Risk:
An investment in a money market fund is not a bank deposit and is not
insured or guaranteed by the Federal Deposit Insurance Corporation or any other government
agency. Although a money market fund seeks to preserve the value of your investment at $1.00 per
share, it is possible to lose money by investing in a money market fund.
Operational Risk:
Operational risk can be experienced when an issuer of an investment product is
unable to carry out the business it has planned to execute. Operational risk can be experienced as a
result of human failure, operational inefficiencies, system failures, or the failure of other processes
critical to the business operations of the issuer or counter party to the investment.
Past Performance:
Charting and technical analysis are often used interchangeably. Technical
analysis generally attempts to forecast an investment’s future potential by analyzing its past
performance and other related statistics. In particular, technical analysis often times involves an
evaluation of historical pricing and volume of a particular security for the purpose of forecasting
where future price and volume figures may go. As with any investment analysis method, technical
analysis runs the risk of not knowing the future and thus, investors should realize that even the
most diligent and thorough technical analysis cannot predict or guarantee the future performance
of any particular investment instrument or issuer thereof.
Small-Sized Companies Risk:
Investments in securities issued by small-sized companies, which
tend to be smaller, start-up companies offering emerging products or services, may involve greater
risks than are customarily associated with larger, more established companies. Securities issued by
small-sized companies tend to be more volatile and somewhat more speculative than securities
issued by larger or more established companies and may underperform as compared to the
securities of larger companies.
Strategy Risk:
There is no guarantee that the investment strategies discussed herein will work
under all market conditions and each investor should evaluate his/her ability to maintain any
investment he/she is considering in light of his/her own investment time horizon. Investments are
subject to risk, including possible loss of principal.
ADV Part 2A – Firm Brochure
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Dynamic Financial Group, LLC,
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately,
our firm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a
money market account so that our firm may debit advisory fees for our services related to our
Comprehensive Portfolio Management service, as applicable.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representative(s) of our firm are registered representatives of Mutual Securities, member
FINRA/SIPC, and licensed insurance agents. As a result of these transactions, they receive normal
and customary commissions. A conflict of interest exists as these commissionable securities sales
create an incentive to recommend products based on the compensation earned. To mitigate this
potential conflict, our firm will act in the client’s best interest.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all
material facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty
is the underlying principle for our firm’s Code of Ethics, which includes procedures for personal
securities transaction and insider trading. Our firm requires all representatives to conduct business
with the highest level of ethical standards and to comply with all federal and state securities laws at all
times. Upon employment with our firm, and at least annually thereafter, all representatives of our firm
will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all
circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients.
This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential
client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon
request.
Our firm recognizes that the personal investment transactions of our representatives demand the
application of a Code of Ethics with high standards and requires that all such transactions be carried
out in a way that does not endanger the interest of any client. At the same time, our firm also believes
that if investment goals are similar for clients and for our representatives, it is logical, and even
desirable, that there be common ownership of some securities.
ADV Part 2A – Firm Brochure
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Dynamic Financial Group, LLC,
To prevent conflicts of interest, our firm has established procedures for transactions effected by our
1
representatives for their personal accounts
. In order to monitor compliance with our personal trading
policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. To minimize this conflict of interest, our related persons will place client
interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is
available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time
they buy or sell the same securities for client accounts. To minimize this conflict of interest, our related
persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics,
a copy of which is available upon request. Further, our related persons will refrain from buying or
selling the same securities prior to buying or selling for our clients in the same day unless included in a
block trade.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
Our firm does not maintain custody of client assets. Client assets must be maintained by a qualified
custodian. Our firm seeks to recommend a custodian who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. The factors considered, among others, are these:
•
•
•
•
•
•
•
•
•
•
•
•
•
Timeliness of execution
Timeliness and accuracy of trade confirmations
Research services provided
Ability to provide investment ideas
Execution facilitation services provided
Record keeping services provided
Custody services provided
Frequency and correction of trading errors
Ability to access a variety of market venues
Expertise as it relates to specific securities
Financial condition
Business reputation
Quality of services
1
For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which
our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or
indirect beneficial interest in.
ADV Part 2A – Firm Brochure
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Dynamic Financial Group, LLC,
Our firm has an arrangement with National Financial Services LLC and Fidelity Brokerage Services LLC
(collectively, and together with all affiliates, "Fidelity") through which Fidelity provides our firm with
"institutional platform services." Our firm is independently operated and owned and is not affiliated
with Fidelity. The institutional platform services include, among others, brokerage, custody, and other
related services. Fidelity's institutional platform services that assist us in managing and administering
clients' accounts include software and other technology that (i) provide access to client account data
(such as trade confirmations and account statements); (ii) facilitate trade execution and allocate
aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market
data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions,
recordkeeping and client reporting.
Fidelity may make certain research and brokerage services available at no additional cost to our
firm. Research products and services provided by Fidelity may include: research reports on
recommendations or other information about particular companies or industries; economic surveys,
data and analyses; financial publications; portfolio evaluation services; financial database software and
services; computerized news and pricing services; quotation equipment for use in running software
used in investment decision-making; and other products or services that provide lawful and
appropriate assistance by Fidelity to our firm in the performance of our investment decision-making
responsibilities. The aforementioned research and brokerage services qualify for the safe harbor
exemption defined in Section 28(e) of the Securities Exchange Act of 1934.
Fidelity does not make client brokerage commissions generated by client transactions available for
our firm’s use. The aforementioned research and brokerage services are used by our firm to
manage accounts for which our firm has investment discretion. Without this arrangement, our firm
might be compelled to purchase the same or similar services at our own expense.
As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of
our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm
or our related persons creates a potential conflict of interest and may indirectly influence our firm’s
choice of Fidelity as a custodial recommendation. Our firm examined this potential conflict of interest
when our firm chose to recommend Fidelity and have determined that the recommendation is in the
best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best
execution.
Our clients may pay a transaction fee or commission to Fidelity that is higher than another qualified
broker dealer might charge to effect the same transaction where our firm determines in good faith
that the commission is reasonable in relation to the value of the brokerage and research services
provided to the client as a whole.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Client Brokerage Commissions
In addition to the benefits described above, Fidelity also makes available to our firm other products
and services that benefit our firm. These benefits may include national, regional or investment
ADV Part 2A – Firm Brochure
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Dynamic Financial Group, LLC,
adviser specific educational events organized and/or sponsored by Fidelity. Other potential
benefits may include occasional business entertainment of personnel of our firm by Fidelity
personnel, including meals, invitations to sporting events, including golf tournaments, and other
forms of entertainment, some of which may accompany educational opportunities. Some of these
products and services assist our firm in managing and administering clients’ accounts. These
include software and other technology (and related technological training) that provide access to
client account data (such as trade confirmations and account statements), facilitate trade execution
(and allocation of aggregated trade orders for multiple client accounts), provide research, pricing
information and other market data, facilitate payment of our fees from clients’ accounts, and assist
with back-office training and support functions, recordkeeping and client reporting. Many of these
services may be used to service all or some substantial number of our accounts, including accounts
not maintained at Fidelity. While, as a fiduciary, our firm endeavors to act in our clients’ best
interests, our recommendation/requirement that clients maintain their assets in accounts at
Fidelity may be based in part on the benefit to our firm of the availability of some of the foregoing
products and services and other arrangements and not solely on the nature, cost, or quality of
custody and brokerage services provided by Fidelity, which creates a potential conflict of interest.
As a result of receiving such products and services for no cost, our firm may have an incentive to
continue to place client trades through broker-dealers that offer soft dollar arrangements/the
aforementioned services and products. This interest conflicts with the clients' interest of obtaining
the lowest commission rate available. Therefore, our firm must determine in good faith, based on
the best execution policy stated above that such commissions are reasonable in relation to the value
of the services provided by such executing broker-dealers.
Client Transactions in Return for Soft Dollars
All soft dollars arrangements must be approved in writing by our Chief Compliance Officer. When
deciding whether to approve or disapprove of a soft dollar relationship, the following criteria is
reviewed: the broker-dealer's business reputation and financial position and our ability to
consistently execute orders professionally and on a cost effective basis, provide prompt and
accurate execution reports, prepare timely and accurate confirms, deliver securities or cash
proceeds promptly and provide meaningful research services that are useful to us in investment
decision-making or other desired and appropriate services. Our Chief Compliance Officer also
annually reviews all our soft dollar relationships for appropriateness, benefits to our clients, etc.
At times, a product or service our firm would like to purchase with soft dollars may have a "mixed
use", meaning that a portion of the product is used to provide bona fide research as part of the
investment decision-making process and part of it may be used for a non-research purpose. In these
situations, our Chief Compliance Officer will make a pro-rata allocation of the cost of such service
based on our evaluation of the research and non-research uses of the product. The cost of the
product must be paid using both hard and soft dollars, the hard dollars being paid by our firm for
the non-research portion and soft dollars for the research portion. For services that have a "mixed
use", our Chief Compliance Officer will make a fair and reasonable determination as to how much of
the cost may be paid with soft dollars. The basis for such determination shall be documented and
will include an explanation as to how the computation of such percentage was reached. Our Chief
Compliance Officer’s computation shall be retained in our firm’s files along with any records used to
determine the “mixed use” percentages. Whenever there is a substantial change in the use of “mixed
use” services, our Chief Compliance Officer will reevaluate such services. Providers of services that
have a "mixed use" will be directed to either bill the paying broker for such service and the broker
ADV Part 2A – Firm Brochure
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Dynamic Financial Group, LLC,
will be directed to bill us for the non-research portion, or to send separate bills to us and the paying
broker for the appropriate amounts.
As a fiduciary, our firm has an obligation to obtain "best execution" of clients' transactions under
the circumstances of the particular transaction. Consequently, notwithstanding the safe harbor
provided under Section 28(e) of the Securities Exchange Act of 1934, no allocation for soft dollar
payments shall be made unless best execution of the transaction is reasonably expected to be
obtained.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
Neither our firm nor any of our firm’s representatives have discretionary authority in making the
determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale
of securities are placed for execution, and the commission rates at which such securities
transactions are effected. Our firm routinely recommends that clients direct us to execute through a
specified broker-dealer. Our firm recommends the use of Fidelity. Each client will be required to
establish their account(s) with Fidelity if not already done. Please note that not all advisers have this
requirement.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer to obtain goods or services on behalf of the plan. Such direction
is permitted provided that the goods and services provided are reasonable expenses of the plan
incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement
will be for the exclusive benefit of the plan.
Client-Directed Brokerage
Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to
achieve the most favorable execution of client transactions. Client directed brokerage may cost
clients more money. For example, in a directed brokerage account, clients may pay higher
brokerage commissions because our firm may not be able to aggregate orders to reduce transaction
costs, or clients may receive less favorable prices.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the
same security for numerous accounts served by our firm, which involve accounts with similar
investment objectives. Although such concurrent authorizations potentially could be either
advantageous or disadvantageous to any one or more particular accounts, they are affected only when
our firm believes that to do so will be in the best interest of the effected accounts. When such
ADV Part 2A – Firm Brochure
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Dynamic Financial Group, LLC,
concurrent authorizations occur, the objective is to allocate the executions in a manner which is
deemed equitable to the accounts involved. In any given situation, our firm attempts to allocate trade
executions in the most equitable manner possible, taking into consideration client objectives, current
asset allocation and availability of funds using price averaging, proration and consistently non-
arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
Our management personnel or financial advisors review accounts on at least an annual basis for
our Comprehensive Portfolio Management clients. The nature of these reviews is to learn whether
client accounts are in line with their investment objectives, appropriately positioned based on
market conditions, and investment policies, if applicable. Our firm does not provide written reports
to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis
when our Comprehensive Portfolio Management clients are contacted. Our firm may review client
accounts more frequently than described above. Among the factors which may trigger an off-cycle
review are major market or economic events, the client’s life events, requests by the client, etc.
Item 14: Client Referrals & Other Compensation
Fidelity Brokerage Services, LLC
Except for the arrangements outlined in Item 12 of our Firm Brochure, our firm has no additional
arrangements to disclose.
Product Sponsors
Our firm occasionally sponsors events in conjunction with our product providers in an effort to
keep our clients informed as to the services we offer and the various financial products we utilize.
These events are educational in nature and are not dependent upon the use of any specific product.
While a conflict of interest may exist because these events are at least partially funded by product
sponsors, all funds received from product sponsors are used for the education of our clients. We
will always adhere to our fiduciary duty in recommending appropriate investments for our clients.
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not
provide cash or non-cash compensation directly or indirectly to unaffiliated persons for
testimonials or endorsements (which include client referrals).
ADV Part 2A – Firm Brochure
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Dynamic Financial Group, LLC,
Item 15: Custody
Deduction of Advisory Fees
All of our clients receive account statements directly from their qualified custodians at least
quarterly upon opening of an account. If our firm decides to also send account statements to clients,
such notice and account statements include a legend that recommends that the client compare the
account statements received from the qualified custodian with those received from our firm.
Standing Letters of Authorization
•
The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”)
under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the
Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a
third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our
firm has adopted the following safeguards. As such, our firm has adopted the following
safeguarding procedures in conjunction with our custodian, Fidelity:
•
•
•
•
•
•
Fidelity’s forms, used to establish a standing letter of authorization, include the name and
account number on the receiving account and must be signed by the client.
Fidelity’s SLOA forms currently require client’s signature.
Fidelity performs verification on all SLOA forms and sends a transfer of notice to the client
promptly following the transaction.
Clients always have the ability to terminate (or amend) an SLOA in writing.
Our firm has no authority, or ability, to amend the third party designated on a standing
instruction.
Our firm maintains records showing the third party is not a related party of our firm or
located at our firm.
Fidelity notifies the client in writing when a new standing instruction is set up. Clients also
receive an annual mailing reconfirming the existence of the standing instruction.
Clients are encouraged to raise any questions with us about the custody, safety or security of their
assets and our custodial recommendations.
Item 16: Investment Discretion
Our firm manages accounts on a discretionary basis. After you sign an agreement with our firm,
we’re authorized to execute securities transactions, determine which securities are bought and
sold, and the total amount to be bought and sold without prior consultation with you. Limitations
may be imposed by the client in the form of specific constraints on any of these areas of discretion
with our firm’s written acknowledgement. We will have discretion until the advisory agreement is
terminated by you or our firm.
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Dynamic Financial Group, LLC,
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are
sent to our firm, our firm will forward them to the appropriate client and ask the party who sent
them to mail them directly to the client in the future. Clients may call, write or email us to discuss
questions they may have about particular proxy votes or other solicitations.
Item 18: Financial Information
•
Our firm is not required to provide financial information in this Brochure because:
•
•
Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
Our firm does not take custody of client funds or securities.
Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
Our firm has never been the subject of a bankruptcy proceeding.
ADV Part 2A – Firm Brochure
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Dynamic Financial Group, LLC,