Overview
- Headquarters
- Huntington, NY
- Total Firm Assets
- $65 million
- Average High-Net-Worth Client Portfolio Size
- $2.8 million
- Minimum Account Size
- $500,000
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A ECA)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $3,000,000 | 1.00% |
| $3,000,001 | $5,000,000 | 0.80% |
| $5,000,001 | $7,500,000 | 0.60% |
| $7,500,001 | $10,000,000 | 0.40% |
| $10,000,001 | and above | 0.30% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $46,000 | 0.92% |
| $10 million | $71,000 | 0.71% |
| $50 million | $191,000 | 0.38% |
| $100 million | $341,000 | 0.34% |
Clients
- High-Net-Worth Share of Firm Assets
- 90.62%
- Number of High-Net-Worth Clients
- 21
- Total Client Accounts
- 204
- Discretionary Accounts
- 204
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 335252
Primary Brochure: FORM ADV PART 2A ECA (2026-06-30)
View Document Text
Item 1:
Cover Sheet
INFORMATIONAL BROCHURE
FORM ADV Part 2A
75 PROSPECT STREET, SUITE 402C
HUNTINGTON, NY 11743
646-627-6030
Abel Oonnoonny
June 16, 2026
This brochure provides information about the qualifications and business practices of Eagle’s Crest
Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at 646-627-
6030. 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. Eagle’s Crest Advisors, LLC is a registered
investment adviser. Registration does not imply any certain level of skill or training.
Additional information about Eagle’s Crest Advisors, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2:
Statement of Material Changes
Eagle’s Crest Advisors, LLC is required to report any material changes here in Item 2. Please note that the
address on the cover page of this brochure has been updated. Additionally, edits have been made in Item
5, below to reflect an updated standard advisory fee schedule.
2
Item 3:
Table of Contents
TABLE OF CONTENTS
Item 1:
Cover Sheet
1
Item 2:
Statement of Material Changes
2
Item 3:
Table of Contents
3
Item 4
Advisory Business
4
Item 5:
Fees and Compensation
5
Item 6:
Performance Based Fees
7
Item 7:
Types of Clients
7
Item 8:
Methods of Analysis, Investment Strategies and Risk of Loss
7
Item 9:
Disciplinary Information
10
Item 10:
Other Financial Industry Activities and Affiliations
10
Item 11:
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
11
Item 12:
Brokerage Practices
11
Item 13:
Review of Accounts
12
Item 14:
Client Referrals and Other Compensation
12
Item 15:
Custody
12
Item 16:
Investment Discretion
13
Item 17:
Voting Client Securities
13
Item 18:
Financial Information
13
3
INFORMATIONAL BROCHURE
EAGLE’S CREST ADVISORS, LLC
Item 4
Advisory Business
Eagle’s Crest Advisors, LLC (“Eagle’s Crest”) has been in business as a registered investment advisor since
April, 2025. Abel Oonnoonny is, the firm’s principal and managing member. Eagle’s Crest provides
personalized wealth management and financial planning services. The firm services to individuals, trusts,
foundations, retirement plans, and corporations.
Financial Planning
Financial planning is a process by which a client’s current circumstances are reviewed, goals stated, and a
plan is made to guide the client to those goals. In the information-gathering stage, the client will supply to
Eagle’s Crest information including income, investments, savings, insurance, age, and many other items that
are helpful to the firm in assessing your financial goals. The information is typically provided during personal
interviews and supplemented with written information. Once the information is received, we will discuss
their financial needs and goals and compare their current financial situation with the goals they stated. Once
these are compared, we will create a financial and/or investment plan to help them meet their goals.
The plan is intended to be a suggested blueprint of how to meet our client’s goals. Not every plan will be the
same for every client. Each one is specific to the client who requested it. Because the plan is based on
information supplied by the client, it is very important that they accurately and completely communicate to
us the information we need. We determine these objectives by interviewing the client for relevant financial
information and any additional background information so we can understand a more complete picture of a
client’s needs. It is very important that our clients continually provide us with any updates so that, if
necessary, we are able to update their plan. Otherwise, their plan may no longer be accurate. Financial
planning services are generally included with investment advisory services, but in some circumstances can
be provided on a standalone basis.
Investment Advisory Services
Investment advisory services are designed to meet the desires, objectives and needs of a particular client or
entity. This process includes determining risk tolerance and an in-depth understanding of the client’s
investment objectives. The financial plan is also intended to be a suggested blueprint of how to meet client’s
investment related goals. From this process an appropriate investment advisory strategy will be determined.
Depending on the client’s desires, objectives and needs, we will determine which stocks, bonds, exchange-
traded funds, and/or mutual funds to be utilized.
When we perform asset management services, we will generally do so on a discretionary basis. This means
that while we will continue an ongoing relationship with each client, being involved in various stages of their
lives and decisions to be made, we will not seek specific approval of changes to the securities in client
accounts. Clients can make deposits or withdrawals in their accounts at any time. Because we take discretion
when managing accounts, clients engaging us will be asked to execute a Limited Power of Attorney (granting
4
us discretionary authority over the client accounts) through an Investment Management Agreement that
outlines the responsibilities of both the client and Eagle’s Crest. This Limited Power of Attorney does not
grant Eagle’s Crest the authority to make any withdrawals or transfers in or out of a client account beyond
the deduction of fees. Such other transfers will only be made at the specific direction of the client. Advisory
services are tailored to the specific needs of an individual client. Clients may place reasonable restrictions on
the management of assets, including specific securities or types of securities. However, clients should
understand that significant restrictions may decrease the ability of Eagle’s Crest to meet the client’s goals.
In some circumstances, Eagle’s Crest may provide investment management services on a non-discretionary
basis, which means we will manage the clients’ accounts as we do for our discretionary clients, except we
will receive approval from the client prior to implementing any investment recommendation. Clients should
be aware that some recommendations may be time-sensitive, and, as such, their performance may be affected
if Eagle’s Crest is unable to reach them on a timely basis.
Retirement Plan Consulting
Eagle’s Crest offers retirement plan solutions for plan sponsors. These services are tailored based on the
individual needs of the plan, but may include investment insight and oversight, plan benchmarking, improved
participant outcomes, ongoing fiduciary monitoring, fee and expense analysis, participant communication,
plan design consulting, and vendor search support. Eagle’s Crest will also assist plan sponsors with the
selection of a 401(K) provider or qualified plan providers for their respective plans. This process may include
a review of administrative, recordkeeping, compliance, and employee communication services. Eagle’s Crest
may also review fees associated with investments.
Assets Under Management
As of the date of February 28, 2026, Eagle’s Crest provided discretionary investment management services
to $65,336,093 of client assets.
Item 5:
Fees and Compensation
A. Fees Charged
Investment Advisory Services
All investment management clients will be required to execute an Investment Advisory Agreement that will
describe the type of management services to be provided and the fees, among other items.
Investment Management Account Fee Schedule
Advisory Fee
Total Assets Under Management
$0–$3,000,000
$3,000,001–$5,000,000
1.00%
0.80%
5
$5,000,001–$7,500,000
$7,500,001–$10,000,000
$10,000,001+
0.60%
0.40%
0.30%
Fixed Income/Cash Management Account Fee Schedule
Total Assets Under Management
$0–$2,000,000
$2,000,001–$5,000,000
$5,000,001–$10,000,000
$10,000,001+
Advisory Fee
0.55%
0.45%
0.35%
0.25%
The fee range stated is a guide. Fees are negotiable, and may be higher or lower than this range, based on the
nature of the account. Factors affecting fee percentages include the size of the account, complexity of asset
structures, and other factors. Please note that same or similar services may be available for a lower cost from
other investment advisers. Accounts holding only alternative investments will be charged a fixed rate of
1.00%.
Financial Planning Services
Financial Planning services on a standalone basis are billed on an hourly basis ranging between $150 and $500
per hour. The total fee is calculated by the number of hours times the hourly rate of the team member providing
the service. Planning services may also be provided on a flat fee basis negotiated prior to providing the service.
Full payment is due upon presentation of the plan.
Retirement Plan Consulting
Fees shall be 1.0% per annum of the market value of the plan’s assets managed or advised on by Eagle’s Crest.
The fee range stated is a guide. Fees are negotiable, and may be higher or lower than this range, based on the
nature of the account. Factors affecting fee percentages include the size of the plan, complexity of asset
structures, and other factors.
B. Fee Payment
Investment Advisory Services
Investment Advisory fees will generally be debited directly from each client’s account. As of the date of this
brochure, the advisory fees may be paid monthly, in arrears, and the fees shall be calculated monthly using
an average of the daily balance in the client's account throughout the billing period, after taking into account
deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory
fee is based.
Clients whose fees are directly debited will provide written authorization to debit advisory fees from their
6
accounts held by a qualified custodian chosen by the client. The client will also receive a statement from their
account custodian showing all transactions in their account, including the fee.
Retirement plan fees also may be paid monthly, in arrears, and the fees shall be calculated monthly using an
average of the daily balance of the plan’s assets throughout the billing period for purposes of determining the
market value of the plan assets upon which the fee is based. The plan sponsor will receive an invoice from
Eagle’s Crest showing all transactions, including the fee.
C. Other Fees
There are a number of other fees that can be associated with holding and investing in securities. You will be
responsible for fees including transaction fees for the purchase or sale of a mutual fund or Exchange Traded
Fund, or commissions for the purchase or sale of a stock. Expenses of a fund will not be included in
management fees, as they are deducted from the value of the shares by the mutual fund manager. For
complete discussion of expenses related to each mutual fund, you should read a copy of the prospectus issued
by that fund. Eagle’s Crest can provide or direct you to a copy of the prospectus for any fund that we
recommend to you. Eagle’s Crest may utilize external money managers, exchange traded funds, mutual funds
and other investment options. These investment options have related expenses which are not included in the
advisory fee.
Please make sure to read Item 12 of this informational brochure, where we discuss broker-dealer and custodial
issues.
D. Pro-rata Fees
If you become a client during a billing cycle you will pay a management fee for the number of days left in that
cycle. You may terminate the Investment Management Agreement by providing written notice to Eagle’s
Crest Once your notice of termination is received, we will charge the fee through the date of transfer of your
assets. Eagle’s Crest will cease to perform services, including processing trades and distributions, upon
termination. Assets not transferred from terminated accounts within 30 (thirty) days of termination may be
“de-linked”, meaning they will no longer be visible to Eagle’s Crest and will become a retail account with
the custodian.
E. Compensation for the Sale of Securities
This item is not applicable. Eagle’s Crest does not receive any commissions or fees from investment product
providers or custodians. Its sole source of income is from fees paid by clients.
Item 6:
Performance Based Fees
Fees will not be based upon a share of capital gains or capital appreciation of your accounts (otherwise known
as “performance-based fees”).
Item 7:
Types of Clients
7
Clients advised may include individuals, families, retirement accounts, trusts, foundations, and corporations.
Eagle’s Crest requires each client seeking investment management services to place at least $500,000 with
us. We may waive this account minimum under certain circumstances, in our discretion.
Item 8:
Methods of Analysis, Investment Strategies and Risk of Loss
It is important for you to know and remember that all investments carry risks. Investing in securities
involves risk of loss that clients should be prepared to bear.
The specific securities we recommend for your account will depend on market conditions and our research
at the time. Generally, we recommend a mix of mutual funds, index funds, exchange traded funds, stocks,
and bonds. Specific funds are chosen based on where its investment objective fits into the asset allocation
recommended by Eagle’s Crest, its risk parameters, past performance, peer rankings, fees, expenses, and any
other aspects of the fund Eagle’s Crest deems relevant to that particular fund. We base our conclusions on
predominantly publicly available research, such as regulatory filings, press releases, competitor analyses, and
in some cases research we receive from our custodian or other market analyses. We will primarily use
fundamental analysis which involves analyzing individual companies and their industry groups, such as a
company’s financial statements, details regarding the company’s product line, the experience, and expertise
of the company’s management, and the outlook for the company’s industry. The resulting data is used to
measure the true value of the company’s stock compared to the current market value. The risk of fundamental
analysis is that the information obtained may be incorrect and the analysis may not provide an accurate
estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new
information, utilizing fundamental analysis may not result in favorable performance
Each client’s portfolio will be invested according to that client’s investment objectives. We determine these
objectives by interviewing the client and/or asking the client to put these objectives in writing. Once we
ascertain your objectives for each account, we will develop a set of asset allocation guidelines. Because we
develop an investment strategy based on your personal situation and financial goals, your guidelines may be
similar to or different from another client’s. We will periodically recommend securities transactions in your
portfolio to meet the guidelines of the asset allocation strategy. It is important to remember that because
market conditions can vary greatly, your guidelines are not necessarily strict rules. Rather, we review
accounts individually, and may deviate from the guidelines as we believe necessary.
There are always risks to investing. Clients should be aware that all investments carry various types of risk
including the potential loss of principal that clients should be prepared to bear. It is impossible to name all
possible types of risks. Among the risks are the following:
• Political Risks. Most investments have a global component, even domestic stocks. Political events
anywhere in the world may have unforeseen consequences to markets around the world.
• General Market Risks. Markets can, as a whole, go up or down on various news releases or for no
understandable reason at all. This sometimes means that the price of specific securities could go up or down
without real reason, and may take some time to recover any lost value. Adding additional securities does not
help to minimize this risk since all securities may be affected by market fluctuations.
• Currency Risk. When investing in another country using another currency, the changes in the value of
8
the currency can change the value of your security value in your portfolio.
• Regulatory Risk. Changes in laws and regulations from any government can change the value of a
given company and its accompanying securities. Certain industries are more susceptible to government
regulation. Changes in zoning, tax structure or laws impact the return on these investments.
• Tax Risks Related to Short Term Trading: Clients should note that Eagle’s Crest may engage in short-
term trading transactions. These transactions may result in short term gains or losses for federal and state tax
purposes, which may be taxed at a higher rate than long term strategies. Eagle’s Crest endeavors to invest
client assets in a tax efficient manner, but all clients are advised to consult with their tax professionals
regarding the transactions in client accounts.
• Risks Related to Investment Term. Securities do not follow a straight line up in value. All securities
will have periods of time when the current price of the security is not an accurate measure of its value. If you
require us to liquidate your portfolio during one of these periods, you will not realize as much value as you
would have had the investment had the opportunity to regain its value.
• Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will decline as
the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does,
which is the same thing. Inflation can happen for a variety of complex reasons, including a growing economy
and a rising money supply.
• Business Risk. This can be thought of as certainty or uncertainty of income. Management comes under
business risk. Cyclical companies (like automobile companies) have more business risk because of the less
steady income stream. On the other hand, fast food chains tend to have steadier income streams and therefore,
less business risk.
• Financial Risk. The amount of debt or leverage determines the financial risk of a company.
• Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by
several rating services help to identify those companies with more risk. Obligations of the U.S. government
are said to be free of default risk.
• REITs: A REIT is an entity, typically a trust or corporation that accepts investments from a number of
investors, pools the money, and then uses that money to invest in real estate through either actual property
purchases or mortgage loans. While there are some benefits to owning REITs, which include potential tax
benefits, income, and the relatively low barrier to invest in real estate as compared to directly investing in
real estate, REITs also have some increased risks as compared to more traditional investments such as stocks,
bonds, and mutual funds. First, real estate investing can be highly volatile. Second, the specific REIT chosen
may have a focus such as commercial real estate or real estate in a given location.
• MLPs: An MLP is a publicly traded entity that is designed to provide tax benefits for the investor. In
order to preserve these benefits, the MLP must derive most, if not all, of its income from real estate, natural
resources, and commodities. While MLPs may add diversification and tax favored treatment to a client’s
portfolio, they also carry significant risks beyond more traditional investments such as stocks, bonds, and
mutual funds. One such risk is management risk-the success of the MLP is dependent upon the manager’s
experience and judgment in selecting investments for the MLP. Another risk is the governance structure,
which means the rules under which the entity is run.
•
International Investing: Investing outside of the United States, especially in emerging markets, can
have special or enhanced risks. The most obvious are political risk (changes in local politics can have a vast
impact on the markets in that country as well as regulations affecting given issuers) and currency risk
(changes in exchange rates between the dollar and the local denominations can materially affect the value of
9
the security even if the underlying fundamentals and market price are stagnant). There are other risks,
including enhanced liquidity risk, meaning that while domestic equities and mutual funds are generally easily
liquidated (though there may be a risk of loss due to the timing of the sale), equities in other jurisdictions
may be subject to the circumstances of lower overall market volume and fewer companies on an emerging
exchange. In addition, there may be less information and less transparency in a foreign market or from a
foreign company. Foreign markets impose different rules than domestic markets, which may not be to an
investor's advantage. Also, companies in foreign jurisdictions are generally able to avail themselves of local
laws and venues, meaning that legal remedies for U.S. investors may not be as easily obtained as in the U.S.
• Annuities: Annuities can have many complex features and clauses. In particular, annuity values and
income may be impacted by the financial condition of the issuer.
• Restriction Risk. Clients may at all times place reasonable restrictions on the management of their
accounts. However, placing these restrictions limit our ability to implement recommendations, thus lowering
the potential for returns.
• Risks Related to Investment Term & Liquidity: Securities do not follow a straight line up in value.
All securities will have periods of time in which the current price of the security is not an accurate measure
of its value. If you require us to liquidate your portfolio during one of these periods, you may not realize as
much value. Further, some investments are made with the intention of the investment appreciating over an
extended period of time. Liquidating these investments prior to their intended time horizon may result in
losses.
•
Interest Rate Risks: The prices of, and the income generated by, most debt and equity securities may
be affected by changing interest rates and by changes in the effective maturities and credit ratings of these
securities. For example, the prices of debt securities generally will decline when interest rates rise and will
increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, “call,” or
refinance a security before its stated maturity date, which may result in having to reinvest the proceeds in
lower-yielding securities.
Item 9:
Disciplinary Information
There are no disciplinary items to report.
Item 10:
Other Financial Industry Activities and Affiliations
A. Broker-dealer
Neither the principal of Eagle’s Crest nor any related persons are registered, or have an application pending
to register, as a broker dealer.
B. Futures Commission Merchant/Commodity Trading Advisor
Neither the principal of Eagle’s Crest nor any related persons are registered, or have an application pending
to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an
associated person of the foregoing entities.
C. Relationship with Related Persons
10
Certain professionals of Eagle’s Crest are separately licensed as independent insurance agents. As such, these
professionals may conduct insurance product transactions for Eagle’s Crest clients, in their capacity as
licensed insurance agents, and will receive customary commissions for these transactions in addition to any
compensation received in their capacity as employees of Eagle’s Crest. Commissions from the sale of
insurance products will not be used to offset or as a credit against advisory fees. These professionals therefore
have incentive to recommend insurance products based on the compensation to be received, rather than on a
client’s needs. The receipt of additional fees for insurance commissions is therefore a conflict of interest,
and clients should be aware of this conflict when considering whether to engage Eagle’s Crest or utilize these
professionals to implement any insurance recommendations. Eagle’s Crest attempts to mitigate this conflict
of interest by disclosing the conflict to clients, and informing the clients that they are always free to purchase
insurance products through other agents that are not affiliated with Eagle’s Crest, or to determine not to
purchase the insurance product at all. Eagle’s Crest also attempts to mitigate the conflict of interest by
requiring employees to acknowledge in the firm’s Code of Ethics, their individual fiduciary duty to the clients
of Eagle’s Crest, which requires that employees put the interests of clients ahead of their own.
D. Recommendations of Other Advisers
We may recommend that you use a third party adviser or money manager based on your needs and suitability.
We do not, however, receive compensation from the money manager for recommending that you use their
services.
Item 11:
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A copy of our Code of Ethics is available upon request. Our Code of Ethics includes discussions of
A.
our fiduciary duty to clients, political contributions, gifts, entertainment, and trading guidelines.
Eagle’s Crest does not recommend to clients that they invest in any security in which Eagle’s Crest,
B.
or any principal thereof has any financial interest.
C.
On occasion, an employee of Eagle’s Crest may purchase for his or her own account securities which
are also recommended for clients. Our Code of Ethics details rules for employees regarding personal trading
and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a
client (in the case of a purchase) or after a client (in the case of a sale), all employee trades must be reviewed
by the Compliance Officer. All employee trades must either take place in the same block as a client trade or
sufficiently apart in time from the client trade so the employee receives no added benefit. Employee
statements are reviewed to confirm compliance with the trading procedures.
D.
On occasion, an employee of Eagle’s Crest may purchase for his or her own account securities which
are also recommended for clients at the same time the clients purchase the securities. Our Code of Ethics
details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in
one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the
case of a sale), all employee trades must be reviewed by the Compliance Officer. All employee trades must
either take place in the same block as a client trade or sufficiently apart in time from the client trade so the
employee receives no added benefit. Employee statements are reviewed to confirm compliance with the
11
trading procedures.
Item 12:
Brokerage Practices
A. Recommendation of Broker-Dealer
Eagle’s Crest utilizes SEI Private Trust Company ("SEI") as its primary custodian and generally recommend
this custodian to clients. SEI offers to independent investment advisors services which include custody of
securities, trade execution, clearance, and settlement of transactions. We receive some benefits through
participation in these programs.
Benefits provided to our firm may include, but are not limited to, market information and administrative
services that help our firm manage your account(s). We believe that the recommended custodians and broker-
dealers provide quality execution services for our clients at competitive prices. Price is not the sole factor we
consider in evaluating best execution. We also consider the quality of the services provided by recommended
custodians, including the value of the firm's reputation, execution capabilities, custodial fees, and
responsiveness to our clients and our firm. In recognition of the value of the services recommended
custodians provide, you may pay higher custodial fees than those that may be available elsewhere.
In selecting or recommending a custodian and broker-dealer, we will consider the value of research and
additional brokerage products and services a broker-dealer has provided or will provide to our clients and our
firm. Receipt of these additional brokerage products and services are not considered to have been paid for
with "soft dollars."
Aggregating Trades
Commission costs per client may be lower on a particular trade if all clients in whose accounts the trade is to
be made are executed at the same time. This is called aggregating trades. Instead of placing a number of
trades for the same security for each account, we will, when appropriate, executed one trade for all accounts
and then allocate the trades to each account after execution. If an aggregate trade is not fully executed, the
securities will be allocated to client accounts on a pro rata basis, except where doing so would create an
unintended adverse consequence (For example, ¼ of a share, or a position in the account or less than 1%.)
Directed Brokerage
Eagle’s Crest allows clients to direct brokerage in most circumstances. Eagle’s Crest may be unable to
achieve most favorable execution of client transactions if clients choose to direct brokerage. This may cost
clients money because without the ability to direct brokerage, Eagle’s Crest may not be able to aggregate
orders to reduce transactions costs resulting in higher brokerage commissions and less favorable prices. Not
all investment advisers allow their clients to direct brokerage.
Item 13:
Review of Accounts
12
All accounts will be reviewed by a senior professional on at least an annual basis. However, it is expected
that market conditions, changes in a particular client’s account, or changes to a client’s circumstances will
trigger a review of accounts.
All clients will receive statements and confirmations of trades directly from SEI, please refer to Item 15
regarding custody.
Item 14:
Client Referrals and Other Compensation
A. Economic Benefit Provided by Third Parties for Advice Rendered to Client.
Please refer to Item 12, where we discuss recommendation of Broker-Dealers.
B. Compensation to Non-Advisory Personnel for Client Referrals.
Eagle’s Crest does not receive compensation from third parties and does not compensate third parties for
client referrals. We do not receive nor provide compensation for client referrals.
Item 15:
Custody
There are two avenues through which Eagle’s Crest may have custody of client funds; by directly debiting
its fees from client accounts pursuant to applicable agreements granting such right, and potentially by
permitting clients to sign standing letters of authorization (“SLOAs”). SLOAs permit a client to sign one
document that directs Eagle’s Crest to make distributions out of the client’s account(s).
Clients whose fees are directly debited will provide written authorization to debit advisory fees from their
accounts held by a qualified custodian chosen by the client. Each month or quarter, clients will receive a bill
itemizing the fees to be debited, including the formula used to calculate the fee, the amount of assets the fee
is based, and the time period covered by the fee. The invoice will also state that the fee was not independently
calculated by the custodian. The client will also receive a statement from their account custodian showing
all transactions in their account, including the fee
We encourage clients to carefully review the statements and confirmations sent to them by their custodian,
and to compare the information on your quarterly report prepared by Eagle’s Crest against the information in
the statements provided directly from SEI. Please alert us of any discrepancies.
Item 16:
Investment Discretion
Asset management services will generally be provided on a “discretionary” basis. When Eagle’s Crest is
engaged to provide asset management services on a discretionary basis, we will monitor your accounts to
ensure that they are meeting your asset allocation requirements. If any changes are needed to your
investments, we will make the changes. These changes may involve selling a security or group of investments
and buying others or keeping the proceeds in cash. You may at any time place restrictions on the types of
investments we may use on your behalf, or on the allocations to each security type. You will receive written
13
or electronic confirmations from your account custodian after any changes are made to your account. You will
also receive statements at least quarterly from your account custodian. Clients engaging us on a discretionary
basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the
client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the
client and Eagle’s Crest.
Item 17:
Voting Client Securities
From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities may be
permitted to vote on various types of corporate actions. Examples of these actions include mergers, tender
offers, or board elections. Clients are required to vote proxies related to their investments, or to choose not
to vote their proxies. Eagle’s Crest will not accept authority to vote client securities. Clients will receive
their proxies directly from the custodian for the client account. Eagle’s Crest will not give clients advice on
how to vote proxies.
Item 18:
Financial Information
A. Eagle’s Crest does not require the prepayment of fees more than six (6) months or more in
advance and therefore has not provided a balance sheet with this brochure.
B. There are no material financial circumstances or conditions that would reasonably be expected to impair
our ability to meet our contractual obligations to our clients.
C. Eagle’s Crest has not been the subject of a bankruptcy petition at any time during the past ten years.
14