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ITEM 1 - COVER PAGE
1440 North Harbor Blvd.
Suite 220
Fullerton, CA 92835
(714) 738-0220
www.eclecticassociates.com
Form ADV, Part 2A Brochure
February 3, 2026
This brochure provides information about the qualifications and business practices of
Eclectic Associates, Inc. If you have any questions about the contents of this brochure,
please contact us at (714) 738-0220 or info@eclecticassociates.com. The information in
this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Inc.
is available on
Any reference to or use of the terms “registered investment adviser” or “registered,” does
not imply that Eclectic Associates, Inc., or any person associated with Eclectic
Associates, Inc. has achieved a certain level of skill or training. Additional information
about Eclectic Associates,
the SEC’s website at
www.adviserinfo.sec.gov.
ITEM 2 - MATERIAL CHANGES
The purpose of this page is to inform you of any material changes to our brochure. If
you are receiving this brochure for the first time, this section may not be relevant to you.
Eclectic Associates, Inc. (“Eclectic”) reviews and updates our brochure at least annually
to make sure that it remains current. We have not made any material changes to our
brochure since the previous annual update, dated February 3, 2026.
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ITEM 3 - TABLE OF CONTENTS
ITEM 1 - COVER PAGE ..................................................................................................................1
ITEM 2 - MATERIAL CHANGES ....................................................................................................2
ITEM 3 - TABLE OF CONTENTS ...................................................................................................3
ITEM 4 - ADVISORY BUSINESS....................................................................................................6
Description of Advisory Firm ................................................................................................................ 6
Fiduciary Duty .................................................................................................................................... 6
Advisory Services Offered .................................................................................................................... 7
Investment Management Services ................................................................................................. 7
Financial Planning Services ............................................................................................................. 8
Consulting Services........................................................................................................................... 9
Limitations on Investments ............................................................................................................... 9
Non-Managed Assets ..................................................................................................................... 10
Tailored Services and Client Imposed Restrictions ........................................................................ 10
Wrap Fee Programs ............................................................................................................................ 11
Assets Under Management ................................................................................................................ 11
ITEM 5 - FEES AND COMPENSATION ....................................................................................... 11
Fee Schedule ....................................................................................................................................... 11
Investment Management Services ............................................................................................... 11
Billing Method ....................................................................................................................................... 12
Investment Management Services ............................................................................................... 12
Consulting Services......................................................................................................................... 13
Other Fees and Expenses .................................................................................................................. 13
Termination ........................................................................................................................................... 13
Investment Management Services ............................................................................................... 13
Other Compensation ........................................................................................................................... 14
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ..................... 14
ITEM 7 - TYPES OF CLIENTS ...................................................................................................... 14
Account Requirements ........................................................................................................................ 14
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ...... 15
Methods of Analysis and Investment Strategies ............................................................................. 15
General Investment Strategies ...................................................................................................... 15
Methods of Analysis for Selecting Securities .............................................................................. 15
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Specific Investment Strategies for Managing Portfolios ............................................................ 16
Additional Strategies ....................................................................................................................... 17
Deeds of Trust .................................................................................................................................. 17
Private Placements ......................................................................................................................... 17
Investing Involves Risk ........................................................................................................................ 18
Specific Security Risks ........................................................................................................................ 18
General Risks of Owning Securities ............................................................................................. 18
Mutual Funds (Open-end Investment Company) ....................................................................... 18
Different Types of Funds ................................................................................................................ 20
Exchange-Traded Funds (ETFs) ................................................................................................... 23
Deeds of Trust .................................................................................................................................. 23
Private Placements ......................................................................................................................... 24
Investing Outside the U.S. ............................................................................................................. 24
Cash and Cash Equivalents ........................................................................................................... 25
Other Risks ........................................................................................................................................... 25
Cybersecurity ................................................................................................................................... 25
Pandemics and Other Public Health Crises ................................................................................ 25
Financial Planning................................................................................................................................ 25
ITEM 9 - DISCIPLINARY INFORMATION .................................................................................... 26
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ......................... 26
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING ........................................................................................................ 26
Code of Ethics ...................................................................................................................................... 26
Personal Trading Practices ............................................................................................................ 27
Participation or Interest in Client Transactions ................................................................................ 27
ITEM 12 - BROKERAGE PRACTICES ........................................................................................ 27
The Custodian and Brokers We Use ................................................................................................ 27
How We Select Brokers/Custodians ............................................................................................. 28
Client Brokerage and Custody Costs ........................................................................................... 28
Products and Services Available to Us from Schwab ................................................................ 29
Directed Brokerage Transactions ................................................................................................. 30
Aggregation and Allocation of Transactions .................................................................................... 30
ITEM 13 - REVIEW OF ACCOUNTS ............................................................................................ 31
Managed Account Reviews ................................................................................................................ 31
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Consulting Reviews ............................................................................................................................. 31
Account Reporting ............................................................................................................................... 31
Valuation of illiquid investments .................................................................................................... 32
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ............................................ 32
Schwab Support Products and Services .......................................................................................... 32
Outside Referrals ................................................................................................................................. 32
ITEM 15 - CUSTODY .................................................................................................................... 33
ITEM 16 - INVESTMENT DISCRETION ....................................................................................... 33
Discretionary Management ............................................................................................................ 33
Non-Discretionary Management ................................................................................................... 34
ITEM 17 - VOTING CLIENT SECURITIES ................................................................................... 34
Proxy Voting ..................................................................................................................................... 34
Class Actions .................................................................................................................................... 35
ITEM 18 - FINANCIAL INFORMATION ........................................................................................ 35
Form ADV, Part 2B Brochure Supplement ................................................................................. i
Description of Professional Designations Used in this Brochure Supplement* ........................... ii
David K. Little, CFP®, CFA® .......................................................................................................... iv
Carl W. R. Lachman, CFP® ............................................................................................................ v
Russell W. Hall, CFP®, CPWA® .................................................................................................... vi
David K. MacLeod, CFP®, CFA ................................................................................................... vii
Travis J. McShane, CFP®, CFA .................................................................................................. viii
Aimee E. Calderon, CFP® ............................................................................................................. ix
James I. Moore, CFP® .................................................................................................................... x
Amber M. Shrosbree, CFP® .......................................................................................................... xi
Clarissa L. Hartono, CFP® ........................................................................................................... xii
Russell E. Murdock, CFA ........................................................................................................... xiii
Privacy Information ...................................................................................................................... A
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ITEM 4 - ADVISORY BUSINESS
Description of Advisory Firm
Eclectic Associates, Inc. (“Eclectic,” “we,” “our,” or “us”) is a privately owned corporation
headquartered in Fullerton, CA. Eclectic is registered as an investment adviser with the
U.S. Securities and Exchange Commission. The firm’s principal owner is David Little,
Chairman & President.
Fiduciary Duty
Registered investment advisers are considered fiduciaries under federal law. Our
fiduciary duty carries with it an obligation to act in the best interest of our clients
pursuant to a relationship of trust and confidence. It encompasses a duty of care and a
duty of loyalty.
Duty of Care
The duty of care includes, among other things,
1. the duty to provide advice that is in the best interest of the client;
2. the duty to seek best execution of a client’s transactions where the adviser has
the
responsibility to select broker-dealers to execute client trades; and
3. the duty to provide advice and monitoring over the course of the relationship.
The duty to provide advice suitable to each client based on a reasonable understanding
of the client’s objectives is a critical component of the duty of care. Providing suitable
advice includes making a reasonable inquiry into the client’s financial situation,
investment experience, and financial goals and then updating this information as
necessary throughout the course of the relationship to reflect the client’s changing
objectives over time and adjusting the advice we provide to reflect any changed
circumstances.
When Eclectic has the responsibility to select broker-dealers to execute client trades in
discretionary accounts, we seek to trade such that the client’s total cost or proceeds in
each transaction are the most favorable under the circumstances. In doing so, we
consider the full range and quality of a broker’s services and so the determinative factor
is not necessarily the lowest possible commission cost but whether the transaction
represents the best qualitative execution. Moreover, we periodically and systematically
evaluate the execution we receive on behalf of our clients.
Our duty of care includes an obligation to provide advice and monitoring at a frequency
that is in the best interest of the client, taking into account the scope of the agreed
relationship. This scope is indicated by the duration and nature of the services as
outlined in each client’s advisory arrangement and extends to all personalized advice
provided to clients.
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Duty of Loyalty
Eclectic adheres to a duty of loyalty where we seek to serve the best interests of our
clients and never subordinate the interests of our clients to our own. Simply put, Eclectic
cannot place its own interests ahead of the interests of our clients. In observance of this
duty, we must make full and fair disclosure to clients of all material facts relating to the
advisory relationship. Further, we also seek to eliminate or at least expose through full
and fair disclosure all conflicts of interest which might incline Eclectic, consciously or
unconsciously, to render advice that is not disinterested. We believe that in order for
disclosure to be full and fair, it should be sufficiently specific so that each client is able
to understand the material fact or conflict of interest and make an informed decision
whether to provide consent. Consequently, we provide this ADV 2A brochure to all
prospective clients at or before entering into a contract so that they can use the
information within to decide whether or not to enter into an advisory relationship.
Advisory Services Offered
Eclectic offers the following services to advisory clients:
Investment Management Services
We invite prospective clients to an initial appointment without cost or obligation to
enable both parties to determine the benefits of a continuing relationship.
We provide advice to clients regarding asset allocation and the selection of investments.
Our investment management services include designing, implementing, and continued
monitoring of client accounts. Eclectic will invest the account on a fully discretionary
basis, limited only by the client’s individual needs and any restrictions imposed on the
account. Eclectic also manages some accounts on a non-discretionary basis but
generally does not offer new non-discretionary accounts.
Using a questionnaire, along with in person and telephonic meetings, Eclectic develops
a written Investment Plan prior to investing client assets. The plan takes into
consideration the client’s unique and individual goals, current financial situation
including diversification, financial needs, timing of when money is needed, risk
tolerance, and taxes.
The plan sets forth analysis and recommendations for overall diversification among
investment classes, further diversification within classes, then specific investment
recommendations selected for each client. Once we finalize the plan, we assist in
implementing the plan.
Eclectic primarily utilizes a diversified portfolio of mutual funds and exchange-traded
funds (ETFs) when making investment recommendations/purchases in client accounts.
Eclectic may also occasionally utilize additional types of investments if they are
appropriate to address the individual needs, goals, and objectives of the client or in
response to client inquiry or direction. Eclectic may offer investment advice on any
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investment held by the client at the start of the advisory relationship. We describe the
material investment risks for many of the securities that we use in Item 8 below.
We discuss our discretionary authority below under Item 16 - Investment Discretion.
For more information about the restrictions clients can put on their accounts, see
Tailored Services and Client Imposed Restrictions in this item below. We describe
the fees charged for investment management services below under Item 5 - Fees and
Compensation.
Our Fiduciary Duties to Clients with Retirement Plans
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Financial Planning Services
Eclectic provides financial planning services as part of our investment management
services. These services generally involve providing advice to clients regarding the
investment/management of financial resources based upon an analysis of their
individual needs. These services are generally comprehensive and typically include a
written plan.
Financial Planning Services may include but are not limited to:
1. Retirement planning
2. Education funding
3. Insurance issues
4. Estate planning
5. Investment diversification
Our financial planning services do not include preparation of any income tax, gift, or
estate tax returns, or preparation of any legal documents. We do not receive separate
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compensation for the inclusion of financial planning services beyond our standard
advisory and setup fee. Further, we do not discount advisory fees based on a client’s
request to exclude financial planning from the services we provide to them.
Consulting Services
Eclectic offers other financial consulting as requested by the client for special projects
and analysis. This service is “client initiated” and only available on a selected basis and
may be discontinued at any time.
We describe the fees charged for consulting services below under Item 5 - Fees and
Compensation.
Limitations on Investments
In some circumstances, Eclectic’s advice may be limited to certain types of securities.
Limitation by Plan Sponsor/Employer
In the event Eclectic is managing assets within a retirement plan such as 401(k), 403(b),
or other employer plan, Eclectic is limited to those investment providers and investment
options chosen by the plan administrator. Similarly, when we provide services to
participants in an employer-sponsored plan, the participant may be limited to investing
in securities included in the plan’s investment options. Therefore, Eclectic can only
make recommendations to the client from among the available options and will not
recommend or invest the client’s account in other securities, even if there may be more
suitable options elsewhere.
Limitation by Issuer
In the event Eclectic is managing assets within an annuity, we are limited to those
investment options made available by the insurance company.
Limitation by Type of Security
Limitation on Fixed Income
Eclectic generally utilizes debt-related mutual funds for the fixed income allocation of a
portfolio. With the exception of accounts that do not meet our standard minimum
account requirements, we may also hold individual fixed-income securities contained in
new accounts or purchase new individual fixed incomes securities, including CD’s and
individual bonds. The holding period may be temporary or until maturity based on the
individual needs of the client.
Mutual Fund Limitations
No Load Mutual Funds
Eclectic generally limits recommendations/selections of mutual funds to no load funds or
load-waived equivalents.
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Limitation by Custodian
There may also be limitations on the securities Eclectic may recommend/utilize in a
client’s account based on which broker-dealer holds the account. Most clients establish
brokerage accounts with Schwab Advisor Services™, a division of Charles Schwab &
Co., Inc. (“Schwab”), registered broker-dealer/member SIPC. Schwab offers a broad
range of investment products, but we may occasionally recommend a security for the
client that they do not have available. Generally, we can purchase the securities from
another firm and have them transferred to the client’s account, but the broker-dealer
may charge the client additional fees. Eclectic considers these fees when we
recommend outside securities.
Limitation by Client
Eclectic may also limit advice based on certain client-imposed restrictions. For more
information about the restrictions clients can put on their accounts, see Tailored
Services and Client Imposed Restrictions in this Item below.
Non-Managed Assets
Eclectic occasionally offers securities trading activities for non-managed positions in a
client’s managed account, acting as an intermediary between the client and the
custodian. We do not provide investment advice regarding that portion of the client’s
managed account designated as non-managed assets nor do we provide opinions as to
the merits of any non-managed asset held in the account. We also do not make any
judgments as to the appropriateness of assumed risk or suitability of any non-managed
investment given the client’s situation. Eclectic offers this service at no charge and at
our discretion, in consideration of other accounts that we manage for the client.
For client-directed trades, it is the client’s responsibility to notify Eclectic of their
instructions, to ensure that we receive the instructions, and to review custodial
statements to confirm that trades were placed according to the client’s instructions.
Eclectic will not be liable for failure to place client-directed trades if we do not receive
the client’s instructions or if the client fails to notify us within 30 days of providing
instructions that the transaction was not executed.
Tailored Services and Client Imposed Restrictions
Eclectic manages client accounts based on the investment strategy discussed below
under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss.
Eclectic applies the strategy for each client, based on the client’s individual
circumstances and financial situation. We make investment decisions for clients based
on information the client supplies about their financial situation, goals, and risk
tolerance. Our recommendations/investment selections may not be suitable if the client
does not provide us with accurate and complete information. It is the client’s
responsibility to keep Eclectic informed of any changes to their investment objectives or
restrictions.
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Clients may also request other restrictions on the account, such as when a client needs
to keep a minimum level of cash in the account or does not want Eclectic to buy or sell
certain specific securities or security types in the account. However, with mutual fund
investments, Eclectic cannot influence the underlying assets chosen and held by the
funds we recommend and therefore we are very limited in accommodating client
restrictions on certain holdings. Eclectic reserves the right to not accept and/or
terminate management of a client’s account if we feel that the client-imposed
restrictions would limit or prevent us from meeting or maintaining the client’s investment
strategy.
Wrap Fee Programs
We do not provide portfolio management services to a wrap fee program.
Assets Under Management
Eclectic manages client assets in both discretionary and non-discretionary accounts on
a continuous and regular basis. As of December 31, 2025, the total amount of assets
under our management was:
Discretionary Assets
Non-Discretionary Assets
Total Assets
$ 1,332,348,401
$ 141,149,984
$ 1,473,498,385
ITEM 5 - FEES AND COMPENSATION
Fee Schedule
Investment Management Services
Eclectic charges advisory fees for investment management services. Eclectic‘s advisory
fees are charged based on a percentage of the client’s total assets under management,
per the following schedule:
Annual
Fee
1.00%
0.75%
0.50%
Assets Under
Management
First $1,000,000
Next $2,000,000
Next $2,000,000
Amounts after and above
the first $5,000,000
0.35%
For individual fixed income investments, such as individual bonds and certificates of
deposit, and illiquid investments such as private placements, which are generally held to
maturity, the first year’s fee is as shown above. Subsequent years’ fees are 0.35% of
the value of those types of investments. This does not apply to mutual funds since they
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do not have an expected maturity date. We charge the balance of clients’ investments
according to the table above.
Some accounts are under different fee schedules honoring prior agreements. At our
sole discretion, our standard fee schedule can be negotiated based on a number of
factors, which include but are not limited to “grandfathered” accounts, related accounts,
and other structures that we may consider in special situations. At our discretion,
services are provided without charge to employees and their family members and in
other limited circumstances, which sometimes include charities. Eclectic aggregates
client accounts within the same household for purposes of calculating the advisory fee
rate applicable to each client. We generally make pro-rations for additions or
withdrawals greater than $9,975 made during the client’s billing period. The client’s fee
calculation will reflect any pro-rated additions and/or reductions.
See also Item 13 - Review of Accounts for additional billing methodology relating to
illiquid investments held in client accounts.
Setup Charges (One-Time Charge)
We charge a one-time setup charge of up to $2,000 at the start of a new investment
management services relationship. It partially covers the initial analysis, allocation,
selection of appropriate investments and setting up the client’s account(s) in our
recordkeeping system. We assess the setup charge when the client’s account(s) is/are
opened with Eclectic. At our discretion, we sometimes negotiate or waive the setup
charge.
Consulting Services
At a client’s request, Eclectic will provide financial planning/consulting services on an
hourly or fixed rate basis. We base fixed fee consulting on an estimate of the time it will
take to complete a project using our hourly rate of $350. The fixed fee may be
negotiable depending on the nature and complexity of each client’s circumstances. Our
fixed rate generally ranges between $350 and $7,000 but could be higher depending on
the scope of the project.
At our discretion, Eclectic provides any of the above services to accounts belonging to
our current and former employees and family members (“Proprietary Accounts”), certain
legacy clients, and to charities and/or foundations and their associated persons at a
reduced rate or free of charge.
Billing Method
Investment Management Services
Eclectic’s advisory fees are payable in advance at the beginning of each four-month
billing period. We generally charge one third of the annual fee each four months based
on the market value of the client’s portfolio as of the last business day of the prior billing
period. The formula used for the calculation is as follows: (Annual Rate) x (Total Assets
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Under Management at Period-End) / 3. Fees billed on assets held in client accounts that
receive valuations less than every four months will be calculated using the most recent
pricing data available through the product sponsor and/or the client’s custodian.
For new client accounts, the first payment is calculated based on the value of the
portfolio on the last business day of the month that the client’s assets are
deposited/transferred into accounts under our management and will be payable the
following month.
With client authorization, Eclectic will instruct the custodian to automatically withdraw
our advisory fee from the client’s account. Typically, we authorize the custodian to
withdraw our advisory fee from the client’s account during the first month of each billing
period. All clients will receive brokerage statements from the custodian no less
frequently than quarterly. The custodian statement will show the deduction of the
advisory fee for those clients who authorize the advisory fees to be withdrawn directly
from their custodian account. In addition, Eclectic sends a receipt to the client after fees
are deducted.
Consulting Services
Eclectic’s hourly rate is $350. For fixed fee arrangements, we will provide a quote at the
start of the relationship and charge the client after the work is completed.
Other Fees and Expenses
Eclectic’s fees do not include custodian fees. Clients pay all brokerage commissions,
stock transfer fees, margin charges, foreign exchange, and settlement fees, and/or
other charges incurred in connection with transactions in accounts, from the assets in
the account. These charges are in addition to the fees a client pays to Eclectic. See
Item 12 - Brokerage Practices below for more information. Eclectic does not receive
any of these fees.
In addition, any fund shares held in a client’s account are subject to fund-related
expenses and, if applicable, mutual fund 12b-1 fees and/or early redemption fees. The
fund’s prospectus fully describes the fees and expenses. All fees paid to Eclectic for
investment advisory services are separate and distinct from the fees and expenses
charged by funds. Funds pay advisory fees to their managers, which are indirectly
charged to all holders of the fund shares.
Termination
Investment Management Services
Either party may terminate the agreement upon thirty (30) days written notice to the
other party. The client may terminate the agreement by writing to Eclectic at our office.
Eclectic will refund any prepaid, unearned advisory fees based on the effective date of
termination. If either party terminates the agreement during the first four-month period in
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the first year of the relationship, the entire amount of advisory fees and setup charges
paid to Eclectic will be returned to client. After the first four-month period, the initial
setup charges are non-refundable.
Terminations will not affect liabilities or obligations from transactions initiated in client
accounts prior to termination. In the event the client terminates the investment advisory
agreement, Eclectic will not liquidate any securities in the account unless instructed by
the client to do so. In the event of client’s death or disability, Eclectic will continue
management of the account until we are notified of client’s death or disability and given
alternative instructions by an authorized party.
Consulting Services
Eclectic considers the consulting phase of our services to be complete, and the
consulting agreement terminated upon delivery of the project. In the event that either
the client or Eclectic wishes to terminate the consulting agreement before completion of
the project, either party may terminate the agreement at any time by providing written
notice to the other party. The client may terminate the agreement at any time by writing
Eclectic at our office. Upon notice of termination, Eclectic will provide the client with an
invoice for services provided through the date of termination.
Other Compensation
Eclectic is a fee-only investment advisory and financial planning firm. We do not have
any products for sale, or accept commissions or bonuses, directly or indirectly.
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE
MANAGEMENT
Eclectic does not charge performance-based fees or other fees based on a share of
capital gains or capital appreciation of the assets of a client.
ITEM 7 - TYPES OF CLIENTS
Eclectic provides discretionary and non-discretionary investment advisory and financial
planning services to individuals, high net worth individuals, trusts and estates, and
individual participants of retirement plans. In addition, we provide advisory services to
pension and profit sharing plans, charitable organizations, and businesses.
Account Requirements
Generally, Eclectic requires clients to maintain a minimum portfolio size of $400,000.
On rare occasions and at Eclectic’s discretion, significant fund withdrawal may result in
a request for additional deposits to continue with management of accounts. We also
may choose to combine family accounts to meet the account size minimum. Eclectic
may reduce or waive the account minimum requirements at our discretion.
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ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND
RISK OF LOSS
Methods of Analysis and Investment Strategies
General Investment Strategies
Eclectic generally uses diversification in an effort to minimize risk and optimize the
potential return of a portfolio. More specifically, we utilize multiple investment styles,
market capitalizations, sectors, and regions to provide diversification among our mutual
fund portfolios. Each portfolio composition is determined in accordance with the clients’
investment objectives, risk tolerance, and time horizon.
Eclectic’s general investment strategy is to seek real capital growth proportionate with
the level of risk the client is willing to take. We treat each client account uniquely.
Eclectic assists our clients to develop a Financial and Investment Plan designed in an
effort to help clients attain their financial goals (See Advisory Services Offered in Item
4, above). Eclectic will then recommend/utilize investments that we feel are consistent
with the client’s Financial and Investment Plan.
Since Eclectic treats each client account uniquely, client portfolios with a similar
investment objectives and asset allocation goals often own different securities. Timing
and tax factors also influence Eclectic’s investment decisions. Clients who buy or sell
exchange-listed securities on the same day may receive different prices.
For discretionary clients, Eclectic will implement changes whenever it appears changes
are needed in order to better meet the client’s investment objectives. Stocks and mutual
funds owned by clients are reviewed at least monthly; other investments are reviewed
less frequently. Each portfolio maintains a target asset allocation. Generally, Eclectic
reviews each portfolio semi-annually to evaluate the extent to which the actual
allocation matches the target allocation. Where we consider the variance excessive,
Eclectic takes appropriate actions (buys and sells) in order to bring the actual allocation
within acceptable range of the target allocation. We refer to this process as "re-
balancing." Since we believe that all investments are subject to cycles, this process of
re-balancing offers a systematic process to help us sell when investment categories
have been in favor and to buy when they have been out of favor.
Recommendations are given to non-discretionary clients whenever it appears changes
should be made to better meet the client’s investment objectives.
Methods of Analysis for Selecting Securities
Eclectic primarily uses fundamental analysis in the selection of individual mutual funds,
including the analysis of fund managers, annual reports, and any competitive
advantages. Additionally, in analyzing and selecting mutual funds, we use public and
private research sources (e.g., Morningstar), fund reporting, and fund conference calls.
We review key characteristics including historical performance, consistency of returns,
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risk level, and size of fund. Expense ratio and other costs are also significant factors in
fund selection. We also access additional information from other sources that inform our
general macro-economic view. Eclectic may also consider cyclical conditions, which is
an analysis of business cycles to find favorable conditions for buying and/or selling a
security.
Specific Investment Strategies for Managing Portfolios
Eclectic may use Modern Portfolio Theory, cash as a strategic asset, long-term holding,
and dollar-cost-averaging strategies in the construction and management of client
portfolios. There is no guarantee that any of the following strategies will be successful,
and we make no promises or warranties as to the accuracy of our market analysis.
Modern Portfolio Theory (MPT)
Eclectic uses the Modern Portfolio Theory, which has a basic concept of using
diversification in an effort to help minimize risk and optimize the potential return of a
portfolio.
Cash as a Strategic Asset
Eclectic may use cash as a strategic asset and may at times move or keep client’s
assets in cash or cash equivalents including but not limited to money market funds and
cash sweeps. While high cash levels can help protect a client’s assets during periods of
market decline, there is a risk that our timing in moving to cash is less than optimal upon
either exit or reentry into the market, potentially resulting in missed opportunities during
positive market moves. Eclectic does not attempt to time the market by using cash
strategies.
Long-term Holding
Eclectic’s strategy consists of purchasing, holding, and rebalancing a diversified
portfolio of securities. Eclectic typically intends to hold these investments for the long
term except when sales are necessary to rebalance the portfolio or to fund replacement
acquisitions. When selecting equity securities, Eclectic may focus on the potential for
income and/or growth, depending on the client’s investment objectives.
Eclectic does not attempt to time short-term market swings. Short-term buying and
selling of securities are typically limited to those cases where a purchase has resulted in
an unanticipated gain or loss in which we believe that a subsequent sale is in the best
interest of the client.
Dollar-Cost-Averaging
Dollar cost averaging involves investing money in multiple installments over time to take
advantage of price fluctuations in the attempt to get a lower average cost per share.
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Additional Strategies
While Eclectic does not specifically use the investment strategies listed below, Eclectic
may recommend mutual funds that use these strategies in their management of the
funds or accounts. These may include but are not limited to the following:
1. Tactical asset allocation
2. Short-term trading
3. Short-selling
4. Option strategies
5. Market timing
6. Trend methodology
7. Defensive strategies
8. Hedging
9. Leverage
10. Margin
11. Inverse/enhanced market strategies
Clients interested in learning more about any of the above strategies should contact us
for more information and/or refer to the prospectus of the mutual fund. We may also
consider additional strategies by specific client request.
Deeds of Trust
Eclectic may recommend pooled investments of trust deeds to clients based on factors
that include but are not limited to accreditation status, the level of interest clients
express during meetings with Eclectic, and whether the program would offer
diversification to the client. A trust deed is a document recorded with a county recorder’s
office creating a secured lien on real property, which provides collateral for lenders and
trust deed holders. Some states use a mortgage instrument rather than a trust deed.
The borrower executes a promissory note wherein the borrower promises to repay the
lender. The recorded trust deed creates the secured interest attached to the borrower’s
real property.
If the borrower does not pay as promised, the lender/trust deed Investor can look to the
real property for repayment and/or recovery of their invested capital. A trust deed
investment occurs when an investor purchases all or part of the note and deed of trust.
The difference between a first and second trust deed is the priority of the lien based on
the recording date of the trust deed. The earlier recording date would have priority (i.e.,
first position). If an investor has a second trust deed and the borrower fails to pay the
first, the investor would be responsible to make the first trust deed payments or suffer
the risk of foreclosure and loss of invested capital.
Private Placements
Eclectic may recommend limited partnerships and/or private offerings to clients based
on factors that include but are not limited to accreditation status, the level of interest
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clients express during meetings with Eclectic, and whether the program would offer
diversification to the client. We consider these types of investments to carry a higher
degree of risk than mutual funds. These securities are only available to accredited
investors. Investments in such limited offerings will only occur after conducting
additional consultation with the client and after the client has approved of the investment
and strategy for his/her portfolio.
Investing Involves Risk
Prior to entering into an agreement with Eclectic, the client should carefully consider:
1. That investing in securities involves risk of loss which clients should be prepared
to bear;
2. That securities markets experience varying degrees of volatility;
3. That over time the client’s assets will fluctuate and at any time be worth more or
less than the amount invested; and
4. That clients should only commit assets that they feel are available for investment
on a long-term basis. This is typically a minimum of five to seven years.
Specific Security Risks
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may
decline in response to certain events taking place around the world. These include
events directly involving the issuers of securities held as underlying assets of mutual
funds in a client’s account, conditions affecting the general economy, and overall market
changes. Other contributing factors include local, regional, or global political, social, or
economic instability and governmental or governmental agency responses to economic
conditions. Finally, currency, interest rate, and commodity price fluctuations may also
affect security prices and income.
Mutual Funds (Open-end Investment Company)
A mutual fund is a company that pools money from many investors and invests the
money in stocks, bonds, short-term money-market instruments, other securities or
assets, or some combination of these investments. The portfolio of the fund consists of
the combined holdings it owns. Each share represents an investor’s proportionate
ownership of the fund’s holdings and the income those holdings generate. The price
that investors pay for mutual fund shares is the fund’s per share net asset value (NAV)
plus any shareholder fees that the fund imposes at the time of purchase.
The benefits of investing through mutual funds include:
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Professionally Managed
Mutual funds are professionally managed by investment advisers who research, select,
and monitor the performance of the securities the fund purchases.
Diversification
Mutual funds typically have the benefit of diversification, which is an investing strategy
that generally sums up as “Don’t put all your eggs in one basket.” Spreading
investments across a wide range of companies and industry sectors can help lower the
risk if a company or sector fails. Some investors find it easier to achieve diversification
through ownership of mutual funds rather than through ownership of individual stocks or
bonds.
Affordability
Some mutual funds accommodate investors who do not have a lot of money to invest by
setting relatively low dollar amounts for initial purchases, subsequent monthly
purchases, or both.
Liquidity
Usually, mutual fund investors can readily redeem their shares at the current NAV, less
any fees and charges assessed on redemption. Less frequently, some mutual funds
have the option to redeem shares using the underlying stocks in the fund’s portfolio or
may delay redemption for a defined period.
Mutual funds also have features that some investors might view as disadvantages:
Costs Despite Potential for Negative Returns
Investors must pay annual fees, and other expenses regardless of how the fund
performs. Depending on the timing of their investment, investors may also have to pay
taxes on any capital gains distribution they receive. This includes instances where the
fund went on to perform poorly after purchasing shares.
Lack of Control
Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given
time, nor can they directly influence which securities the fund manager buys and sells or
the timing of those trades.
Price Uncertainty
With an individual stock, investors can obtain real-time (or close to real-time) pricing
information with relative ease by checking financial websites or by calling a broker or
investment adviser. Investors can also monitor how a stock’s price changes from hour
to hour—or even second to second. By contrast, with a mutual fund, the price at which
an investor purchases or redeems shares will typically depend on the fund’s NAV, which
the fund might not calculate until many hours after the investor placed the order. In
general, mutual funds must calculate their NAV at least once every business day,
typically after the major U.S. exchanges close.
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Different Types of Funds
When it comes to investing in mutual funds, investors have literally thousands of
choices. Most mutual funds fall into one of three main categories; money market funds,
bond funds (also called “fixed income” funds), and stock funds (also called “equity”
funds). Each type has different features and different risks and rewards. Generally, the
higher the potential return, the higher the risk of loss.
Money Market Funds
Money market funds have relatively low risks, compared to other mutual funds (and
most other investments). By law, they can invest in only certain high quality, short-term
investments issued by the U.S. Government, U.S. and foreign corporations, state and
local governments, and bank issued certificates of deposit. Money market funds try to
keep their net asset value (NAV), which represents the value of one share in a fund, at
a stable $1.00 per share. However, the NAV may fall below $1.00 if the fund’s
investments perform poorly. Investor losses have been rare, but they are possible.
Money market funds pay dividends that generally reflect short-term interest rates, and
historically the returns for money market funds have been lower than for either bond or
stock funds.
Bond Funds
Bond funds generally have higher risks than money market funds, largely because they
typically pursue strategies aimed at producing higher yields. Unlike money market
funds, the SEC’s rules do not restrict bond funds to high quality or short-term
investments. Because there are many different types of bonds, bond funds can vary
dramatically in their risks and rewards.
Some of the risks associated with bond funds include:
Credit Risk
There is a possibility that companies or other issuers may fail to pay their debts
(including the debt owed to holders of their bonds). Consequently, this affects mutual
funds that hold these bonds. Credit risk is less of a factor for bond funds that invest in
insured bonds or U.S. Treasury Bonds. By contrast, those that invest in the bonds of
companies with poor credit ratings generally will be subject to higher risk.
Interest Rate Risk
There is a risk that the market value of the bonds will go down when interest rates go
up. Because of this, investors can lose money in any bond fund, including those that
invest only in insured bonds or U.S. Treasury Bonds. Funds that invest in longer-term
bonds tend to have higher interest rate risk.
Prepayment Risk
Issuers may choose to pay off debt earlier than the stated maturity date on a bond. For
example, if interest rates fall, a bond issuer may decide to “retire” its debt and issue new
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bonds that pay a lower rate. When this happens, the fund may not be able to reinvest
the proceeds in an investment with as high a return or yield.
Stock Funds
A stock fund’s value can rise and fall quickly (and dramatically) over the short term but
may demonstrate more stability over the long-term. Overall “market risk” poses the
greatest potential danger for investors in stocks funds. Stock prices can fluctuate for a
broad range of reasons, such as the overall strength of the economy or demand for
particular products or services. Not all stock funds are the same.
For example:
Growth Funds
Growth funds focus on stocks that generally do not pay a regular dividend but that have
the potential for large capital gains. These funds favor companies expected to grow
earnings, which could result in stock prices rising faster than the economy and may be
smaller and less seasoned companies. The smaller and less seasoned companies that
may be in a growth fund have a greater risk of price volatility. Growth stocks, sometimes
priced on future expectations rather than current results, may decline substantially from
unmet expectations in general weakened market conditions.
Equity Income Funds
Equity income funds stress current income over growth and may invest in stocks that
pay regular dividends. These funds are subject to dividend payout risk, which is the
possibility that a number of the companies in which the fund invests will reduce or
eliminate the dividend on the securities held by the fund.
Small Cap Funds
Funds that invest in stocks of small companies involve additional risks. Smaller
companies typically have a higher risk of failure than larger, well-established blue chip
companies do. Historically, smaller company stocks have experienced a greater degree
of market volatility than the overall market average.
Mid Cap Funds
Funds that invest in companies with mid-range market capitalizations involve additional
risks. The securities of these companies may be more volatile than the securities of
larger companies and contain less liquidity in securities markets.
Index Funds
Index funds aim to achieve the same return as a particular market index, such as the
S&P 500 Composite Stock Price Index, by investing in all or a representative sample of
the companies included in an index.
International Funds
International investments are subject to additional risks, including currency fluctuation,
political instability, and potential illiquid markets.
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Emerging Market Funds
Funds that invest in foreign securities of smaller, less-developed countries involve
special additional risks. These risks include, but are not limited to currency risk, political
risk and risk associated with varying accounting standards. Investing in emerging
markets may accentuate these risks.
Real Estate Investment Trust (REIT) Funds
REIT Funds include individual REIT shares within the underlying fund holdings. REITs
primarily invest in real estate or real estate-related loans. Equity REITs own real estate
properties, while mortgage REITs hold construction, development, and/or long-term
mortgage loans. REIT investments include illiquidity and interest rate risk.
Absolute Return Funds
Absolute return looks at the appreciation or depreciation (expressed as a percentage)
that a fund achieves over a given period. Absolute return differs from relative return
because it is concerned with the return of a particular asset and does not compare it to
any other measure or benchmark. In general, a mutual fund seeks to produce returns
that are better that its peers, its fund category, and/or the market as a whole. As an
investment vehicle, an absolute return fund seeks to make positive returns by
employing investment management techniques that differ from traditional funds, such as
short selling, futures, options, derivatives, arbitrage, leverage, and unconventional
assets.
Alternative Investment Funds
Alternative investments fall outside the three traditional asset types (stocks, bonds, and
cash), and include hedge funds, managed futures, real estate, commodities, and
derivatives contracts. Alternative investment funds generally provide returns with a low
correlation to returns of standard asset classes. Consequently, many large institutional
funds such as pensions and private endowments have begun to allocate a small portion
of their portfolios to alternative investments such as hedge funds. Each fund is subject
to specific and often enhanced risks, depending on the nature of the fund.
Tax Consequences of Mutual Funds
When investors buy and hold an individual stock or bond, the investor must pay income
tax each year on the dividends or interest the investor receives. However, the investor
will not have to pay any capital gains tax until the investor actually sells and makes a
profit. Mutual funds are different. When an investor buys and holds mutual fund shares,
the investor will owe income tax on any ordinary dividends in the year the investor
receives or reinvests them. Moreover, in addition to owing taxes on any personal capital
gains when the investor sells shares, the investor may have to pay taxes each year on
the fund’s capital gains. That is because the law requires mutual funds to distribute
capital gains to shareholders if they sell securities for a profit that cannot be offset by a
loss.
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Exchange-Traded Funds (ETFs)
An exchange-traded fund (“ETF”) is a type of Investment Company (usually, an open-
end fund or unit investment trust) containing a basket of stocks, fixed income
instruments, and/or commodities. ETFs may be structured to track the performance of
a particular market index, including broad-based or sector-specific indexes. These
“passive” ETFs seek to achieve investment results that correspond, before fees and
expenses, to the performance of the underlying index by generally holding the same
securities, or a representative sample of the securities, included in the index. However,
such ETFs may not perfectly track their target index due to fees, expenses, tracking
error, market conditions, or portfolio rebalancing. Other ETFs do not seek to replicate
the performance of a specific index and instead rely on active portfolio management.
Actively managed ETFs may invest in a more limited number of securities, may deviate
significantly from market indexes, and may underperform or outperform the broader
market depending on market conditions and the effectiveness of the investment
manager’s strategies.
Unlike traditional mutual funds, which can only be redeemed at the end of a trading day,
ETFs trade throughout the day on an exchange. Like mutual funds, the prices of the
underlying securities and the overall market generally affect ETF prices. Similarly,
factors affecting a particular industry segment typically affect ETF prices that track that
particular sector.
Deeds of Trust
There are risks associated with Trust Deed Investments that investors should
understand:
1. Neither the FDIC nor any other government agencies insure Trust Deed
Investments. The investments involve certain risks and are suitable only for
persons of adequate means who anticipate no need for immediate liquidity.
2. An appraiser assesses the value of property reflecting his/her opinion of the
value at a specific date. There is no assurance that the appraised value will
reflect a fair market value, as general and local economic conditions may
change.
3. Although the investor makes the investment decision, the success of the
investment will depend, in part, upon the experience and quality of the
management of the mortgage broker. Investors should not entrust all aspects of
the investment decision and subsequent servicing to the broker without full
understanding of the delegated responsibilities and rights.
4. The borrower’s ability to repay the loan will depend upon the borrower’s financial
condition, which could change over time.
5. There are general risks associated with real estate investments including general
or local economic conditions, neighborhood values, interest rates, real estate tax
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rates, the supply of and demand for properties of the type involved, the ability of
the borrower to obtain necessary alternative financing, governmental rules, and
acts of nature.
6. Default by the borrower could interrupt the investor’s monthly payments. Under
extreme cases, it may be necessary to foreclose or take other actions to protect
the investment. It is possible for the total amount recovered upon foreclosure to
be less than the amount of the total investment, resulting in loss of capital to the
investor.
7. The foreclosure process could stall if a borrower files a reorganization or full
insolvency bankruptcy. Trust deed investors could incur significant legal fees and
costs in attempting to obtain relief from the automatic freeze on collection
proceedings provided by the Bankruptcy Code. Relief consists of obtaining court
approval to release the property out of the bankruptcy so that the property can be
foreclosed. Furthermore, the court could modify the terms of the loan by
extending the due date, changing the interest rate and payment structure, or
causing the priority of the loan to be subordinated to a bankruptcy court-
approved financing plan.
Trust deeds are not liquid, not transferable and involve risk, including possible loss of
principal.
Private Placements
Generally, there is no ready market for private placement purchases and sales.
Therefore, private placements are less liquid than market-based securities and
considered risky investments. Consequently, investments in private placements are
limited to persons who meet certain income and/or net worth requirements. Eclectic will
recommend such securities only to clients who meet the necessary income and/or net
worth requirements and where Eclectic believes the investment is appropriate for the
client based on the client’s ability to accept the risk. At the time of recommendation,
Eclectic will disclose to the client any proprietary interest in the company.
Investing Outside the U.S.
Although we limit foreign investments to mutual funds that hold foreign securities, the
risks of foreign investing still apply to the underlying portfolios of funds. Investing
outside the United States involve additional risks of foreign investing. These risks may
include currency controls and fluctuating currency values, and different accounting,
auditing, financial reporting, disclosure, and regulatory and legal standards and
practices. Additional factors may include changing local, regional, and global economic,
political, and social conditions. Further, expropriation, changes in tax policy, greater
market volatility, different securities market structures, and higher transaction costs can
be contributors. Finally, various administrative difficulties, such as delays in clearing and
settling portfolio transactions or in receiving payment of dividends can also lead to
additional risk.
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Cash and Cash Equivalents
Cash and cash equivalents are the most liquid of investments. Cash and cash
equivalents are considered very low-risk investments meaning there is little risk of losing
the principal investment. Typically, low risk also means low return and the interest an
investor can earn on this type of investment is low relative to other types of investing
vehicles.
Other Risks
Cybersecurity
Information and technology systems can be vulnerable to damage or interruption from
computer viruses, network failures, computer and telecommunication failures,
infiltrations by unauthorized persons and security breaches, usage errors by its
professionals, power outages and catastrophic events such as fires, tornadoes, floods,
hurricanes, and earthquakes. Although we have implemented various measures to
manage risks relating to these types of events, if these systems are compromised, or
become inoperable for extended periods of time, or cease to function properly, we may
have to make a significant investment to fix or replace them. The failure of these
systems can cause significant interruptions in our operations and result in a failure to
maintain the security, confidentiality or privacy or sensitive data, including personal
information relating to clients. Such a failure could potentially harm our reputation,
subject us to legal claims, and otherwise have an adverse impact on our ability to
perform advisory functions.
Pandemics and Other Public Health Crises
Pandemics and other health crises, such as the outbreak of an infectious disease such
as severe acute respiratory syndrome, avian flu, H1N1/09 flu and COVID-19 or any
other serious public health concern, together with any resulting restrictions on travel or
quarantines imposed, could have a negative impact on the economy, and business
activity in any of the areas in which client investments may be located. Such disruption,
or the fear of such disruption, could have a significant and adverse impact on the
securities markets, lead to increased short-term market volatility or a significant market
downturn, and can have adverse long-term effects on world economies and markets
generally.
Financial Planning
The financial planning tools Eclectic uses to create financial plans for clients rely on
various assumptions, such as estimates of inflation, risk, economic conditions, and rates
of return on security asset classes. Return assumptions generally reflect asset class
returns instead of actual investment returns, and do not always include fees or
expenses that clients would pay if they invested in specific products.
Financial planning software is only a tool used to help guide Eclectic and the client in
developing an appropriate plan, and we cannot guarantee that clients will achieve the
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results shown in the plan. Results will vary based on the information provided by the
client regarding the client’s assets, risk tolerance, and personal information. Changes to
the program’s underlying assumptions or differences in actual personal, economic, or
market outcomes generally impact client results.
Clients should carefully consider the assumptions and limitations of the financial
planning software and should discuss the results of the plan with us before making any
changes to their investments or financial plan If the financial plan includes
recommendations for investing in securities, you should understand that investing in all
securities involves risk of loss, and you should be prepared to bear that risk.
ITEM 9 - DISCIPLINARY INFORMATION
Eclectic and our personnel seek to maintain the highest level of business
professionalism, integrity, and ethics. Eclectic does not have any disciplinary
information to disclose.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND
AFFILIATIONS
Eclectic does not offer any other services or have any affiliates in the financial industry.
Some associated persons of Eclectic serve on boards of directors for various
companies. In all such instances, either the company is not a client of Eclectic or if also
a client, Eclectic has no business dealings with the company other than the provision of
investment advisory services. A conflict arises when an affiliated person of Eclectic
exercises his or her vote as a member of a company’s board to hire Eclectic to manage
company assets. Similarly, a vote to retain Eclectic as the money manager for the
company where an advisory relationship already exists also creates a conflict. To
address these conflicts, Eclectic’s employees will recuse themselves from votes
involving decisions to hire or retain Eclectic as an investment adviser, when applicable.
Eclectic does not conduct shared operations or have shared premises with any
company where an associated person serves on a board.
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN
CLIENT TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
Eclectic believes that we owe clients the highest level of trust and fair dealing. As part of
our fiduciary duty, we place the interests of our clients ahead of the interests of the firm
and our personnel. Eclectic’s personnel are required to conduct themselves with
integrity at all times and follow the principles and policies detailed in our Code of Ethics.
Eclectic’s Code of Ethics attempts to address specific conflicts of interest that either we
have identified or that could likely arise. Eclectic’s personnel are required to follow clear
guidelines from the Code of Ethics in areas such as gifts and entertainment, other
business activities, prohibitions of insider trading, and adherence to applicable federal
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securities laws. Additionally, individuals who formulate investment advice for clients, or
who have access to nonpublic information regarding any clients’ purchase or sale of
securities, are subject to personal trading policies governed by the Code of Ethics (see
below).
Eclectic will provide a complete copy of the Code of Ethics to any client or prospective
client upon request.
Personal Trading Practices
Eclectic’s personnel are subject to personal trading policies governed by the Code of
Ethics. Eclectic and our personnel often invest in securities that we also recommend to
clients. However, the securities we trade in our own accounts sometimes trade at
different frequencies or include securities that we feel do not meet the criteria of our
investment process, and/or that we do not feel are appropriate for clients. This could
potentially lead to profits in personal accounts that would not also be earned by clients
holding both like and/or different positions.
Securities transactions on behalf of clients primarily consist of mutual funds, which do
not trade but are issued and redeemed once daily at the fund’s net asset value (“NAV”).
Therefore, we believe that personal transactions in mutual funds do not present a
conflict of interest to our clients. The Code of Ethics includes additional restrictions for
our personnel in the rare event that we make non-mutual fund purchases or sales in our
personal accounts.
Participation or Interest in Client Transactions
The following items represent situations where a conflict of interest may exist between
the client and Eclectic.
ITEM 12 - BROKERAGE PRACTICES
The Custodian and Brokers We Use
Clients must maintain assets in an account at a “qualified custodian,” generally a
broker-dealer or bank. We require that our clients use Charles Schwab & Co., Inc.
(Schwab), registered broker-dealer/member SIPC, as the qualified custodian. We are
independently owned and operated and unaffiliated with Schwab. Schwab will hold
client assets in a brokerage account and buy and sell securities when we instruct them
to.
While we require that clients use Schwab as the custodian/broker, the client must
decide whether to do so and open accounts with Schwab by entering into account
agreements directly with them. We do not open accounts for clients, although we may
assist them in doing so. Not all advisors require their clients to use a particular broker-
dealer or other custodian selected by the advisor. Even though clients maintain
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accounts at Schwab, we can still use other brokers to execute trades for client accounts
(see Client Brokerage and Custody Costs, below).
How We Select Brokers/Custodians
We seek to recommend a custodian/broker who will hold client assets and execute
transactions on terms that are, overall, most advantageous when compared to other
available providers and their services. We consider a wide range of factors, including,
among others:
1. Combination of transaction execution services and asset custody services
(generally without a separate fee for custody)
2. Capability to execute, clear, and settle trades (buy and sell securities for client
accounts)
3. Capability to facilitate transfers and payments to and from accounts (wire
transfers, check requests, bill payment, etc.)
4. Breadth of available investment products (stocks, bonds, mutual funds,
exchange-traded funds [ETFs], etc.)
5. Availability of investment research and tools that assist us in making investment
decisions
6. Quality of services
7. Competitiveness of the price of those services (commission rates, other fees,
etc.) and willingness to negotiate the prices
8. Reputation, financial strength, and stability
9. Prior service to Eclectic and our other clients
10. Availability of other products and services that benefit us, as discussed below
(see Products and Services Available to Us from Schwab)
Client Brokerage and Custody Costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge
separately for custody services. However, Schwab receives compensation by charging
commissions or other fees on trades that they execute or that settle into clients’ Schwab
accounts.
In addition to commissions, Schwab charges a flat dollar amount as a “prime broker” or
“trade away” fee for each trade that we have executed by a different broker-dealer, but
where the securities bought or the funds from the securities sold are deposited (settled)
into a client’s Schwab account. These fees are in addition to the commissions or other
compensation the client pays the executing broker-dealer. Because of this, in order to
minimize trading costs, we have Schwab execute most trades for client accounts. We
have determined that having Schwab execute most trades is consistent with our duty to
seek “best execution” of client trades. Best execution means the most favorable terms
for a transaction based on all relevant factors, including those listed above (see How
We Select Brokers/Custodians).
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Products and Services Available to Us from Schwab
Schwab provides Eclectic and our clients with access to their institutional brokerage,
trading, custody, reporting, and related services, many of which are not typically
available to Schwab retail customers. Schwab also makes available various support
services. Some of those services help us manage or administer our clients’ accounts;
others help us manage and grow our business. Schwab’s support services are generally
available on an unsolicited basis (we do not have to request them) and at no charge to
us.
The following is a more detailed description of Schwab’s support services:
Services That Benefit Our Clients
Schwab’s institutional brokerage services include access to a broad range of investment
products, execution of securities transactions, and custody of client assets. The
investment products available through Schwab include some to which we might not
otherwise have access or that would require a significantly higher minimum initial
investment by our clients. Schwab’s services described in this paragraph generally
benefit our clients and their accounts.
Services That May Not Directly Benefit Our Clients
Schwab also makes available to us other products and services that benefit us but may
not directly benefit our clients or their accounts. These products and services assist us
in managing and administering our clients’ accounts. They include investment research,
both Schwab’s own and that of third parties. We may use this research to service all or
a substantial number of our clients’ accounts, including accounts not maintained at
Schwab. In addition to investment research, Schwab also make available software and
other technology that:
1. Provide access to client account data (such as duplicate trade confirmations and
account statements)
2. Facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
3. Provide pricing and other market data
4. Facilitate payment of our fees from our clients’ accounts
5. Assist with back-office functions, recordkeeping, and client reporting
Services That Generally Benefit Only Us
Schwab offers services intended to help us manage and further develop our business
enterprise. These services include:
1. Educational conferences and events
2. Consulting on technology, compliance, legal, and business needs
3. Publications and conferences on practice management and business succession
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4. Access to employee benefits providers, human capital consultants, and
insurance providers
Schwab may provide some of these services themselves. In other cases, they will
arrange for third-party vendors to provide the services to us. Schwab may also discount
or waive fees for some of these services or pay all or a part of a third party’s fees.
Schwab may also provide us with other benefits, such as occasional business
entertainment of our personnel.
Although Eclectic believes that the products and services offered by Schwab are
competitive in the marketplace for similar services offered by other broker-dealers or
custodians, they can affect Eclectic’s independent judgment in selecting or maintaining
Schwab as the broker or custodian for client accounts. As part of its fiduciary duties to
clients, Eclectic endeavors at all times to put the interests of its clients first. Clients
should be aware, however, that the economic benefits we receive in and of itself creates
a potential conflict of interest.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to
produce or purchase them. Eclectic primarily supports our selection of Schwab by the
scope, quality, and price of Schwab’s services (see How We Select
Brokers/Custodians, above) and not Schwab’s services that benefit only us.
Directed Brokerage Transactions
Eclectic will not allow clients to direct us to use a specific broker-dealer to execute
transactions. Clients must use the broker-dealers that Eclectic recommends. Not all
investment advisers require their clients to trade through specific brokerage firms. Since
we require most of our clients to maintain their accounts with Schwab, it is also
important for clients to consider and compare the significant differences between having
assets custodied at another broker-dealer, bank, or other custodian prior to opening an
account with us. Some of these differences include, but are not limited to; total account
costs, trading freedom, transaction fees/commission rates, and security and technology
services. By requiring clients to use Schwab, Eclectic believes we may be able to more
effectively manage the client’s portfolio, achieve favorable execution of client
transactions, and overall lower the costs to the portfolio.
Clients with 401K or annuity accounts are not required to use Schwab and may appoint
a custodian of their choosing.
Aggregation and Allocation of Transactions
Eclectic enters transactions for each client independently and does not aggregate
(combine) client orders. Aggregating trades may benefit clients by purchasing or selling
in larger blocks in an attempt to take advantage of better pricing or lower trading costs.
We do not feel that clients are at a disadvantage because we do not aggregate client
orders. Eclectic primarily uses mutual funds to manage client accounts. Mutual funds
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are priced once daily. As the daily price is the same for each investor, we have no
opportunity to obtain better pricing through aggregating even if we place trades of the
same fund for multiple clients within a single order. Additionally, the broker-
dealer/custodians charge each account an individual transaction fee regardless of
whether we aggregate or not. This prevents us from lowering trading costs through
aggregation.
Eclectic’s investment recommendations for clients may include certain private
placements, including oil and gas investments and private REITs. Generally, these
types of investments are only available to clients that meet certain income and net worth
requirements. Additionally, these investments typically have a minimum investment
requirement. In some cases, the investments are limited in size, so that participation by
all of our clients for whom the investment is suitable and who meet the qualification
requirements to purchase these investments is not possible.
When the offering is limited in size, Eclectic allocates the offering to all eligible clients
according to the following policy:
1. To clients whose portfolio is sufficient in size such that the client meets the
minimum required investment of the offering; and
2. To clients, in order of when the investment was recommended to them, based on
the current cash available in their portfolio to participate in the offering.
ITEM 13 - REVIEW OF ACCOUNTS
Managed Account Reviews
Eclectic seeks to meet client objectives by monitoring accounts regularly and
rebalancing clients’ investment portfolios, as Eclectic deems appropriate. Clients with
accounts that fall below our minimum portfolio size of $400,000 may receive
rebalancing reviews less frequently, typically annually. All of Eclectic’s Financial
Planners perform reviews of client accounts. Eclectic is available to clients for
discussion and advice anytime during normal business hours.
Consulting Reviews
We conduct consulting services reviews at our hourly rate of $350 and only at the
request of the client.
Account Reporting
Investment management clients receive a written statement from the custodian that
includes an accounting of all holdings and transactions in the account for the reporting
period. In addition, Eclectic provides written reports detailing performance in investment
management client accounts on a quarterly basis. Managed accounts that do not meet
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our standard minimum account requirements and consulting services clients do not
receive reports from Eclectic.
Valuation of illiquid investments
In the event that Eclectic references private placements or other illiquid investments
owned by the client on any account report we prepare, the value(s) for all such assets
owned by the client will reflect the most recent valuation provided by the investment
sponsor/issuer. If no subsequent valuation post-purchase is provided by the investment
sponsor/issuer, then the valuation will reflect the initial purchase price (and/or an issuer-
provided value as of a previous date). If the valuation reflects initial purchase price
(and/or an issuer-provided value as of a previous date), the current value(s), to the
extent ascertainable, could be significantly more or less than original purchase price.
The client’s advisory fee will be based upon the most recent known value(s) using the
above methodology.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
Schwab Support Products and Services
We receive an economic benefit from Schwab in the form of the support products and
services they make available to us and other independent investment advisers whose
clients maintain their accounts at Schwab. These products and services, how they
benefit us, and the related conflicts of interest are described above (see Item 12 –
Brokerage Practices). We do not base particular investment advice, such as buying
particular securities for our clients, on the availability of Schwab’s products and services
to us.
Outside Referrals
Eclectic may refer clients to unaffiliated professionals for specific needs, such as
insurance, mortgage brokerage, real estate sales, and estate planning, legal, and/or
tax/accounting services. In turn, these professionals may refer clients to Eclectic for
investment management/financial planning needs. We do not have any agreements
with individuals or companies that we refer clients to, and we do not receive any
compensation for these referrals. However, it could be concluded that Eclectic is
receiving an indirect economic benefit from the arrangement, as the relationships are
mutually beneficial. For example, there could be an incentive for us to recommend
services of firms who refer clients to Eclectic.
Eclectic only refers clients to professionals we believe are competent and qualified in
their field, but it is ultimately the client’s responsibility to evaluate the provider, and
solely the client’s decision whether to engage a recommended firm. Clients are under
no obligation to purchase any products or services through these professionals, and
Eclectic has no control over the services provided by another firm. Clients who choose
to engage these professionals will sign a separate agreement with the other firm. Fees
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charged by the other firm are separate from and in addition to fees charged by Eclectic.
Eclectic does not receive any portion of fees paid to outside professionals.
If the client desires, Eclectic will work with these professionals or the client’s other
advisors (such as an accountant or attorney) to help ensure that the provider
understands the client’s financial plan/investments and to coordinate services for the
client. Eclectic does not share information with an unaffiliated professional unless first
authorized by the client.
ITEM 15 - CUSTODY
Eclectic has limited custody of our clients’ funds or securities when the client authorizes
us to deduct our management fees directly from the client’s account. A qualified
custodian (generally a broker-dealer, bank, trust company, or other financial institution)
holds clients’ funds and securities. Clients will receive statements directly from their
qualified custodian at least quarterly. The statements will reflect the client’s funds and
securities held with the qualified custodian as well as any transactions that occurred in
the account, including the deduction of our fee.
Clients should carefully review the account statements they receive from the qualified
custodian. When clients receive statements from Eclectic as well as from the qualified
custodian, they should compare these two reports carefully. Clients with any questions
about their statements should contact us at the address or phone number on the cover
of this brochure. Clients who do not receive a statement from their qualified custodian at
least quarterly should also notify us.
Eclectic is also deemed to have custody of clients’ funds or securities when clients have
standing authorizations with their custodian to move money from a client’s account to a
third-party (“SLOA”) and under that SLOA authorize us to designate the amount or
timing of transfers with the custodian. The SEC has set forth a set of standards intended
to protect client assets in such situations, which we follow.
ITEM 16 - INVESTMENT DISCRETION
Discretionary Management
For the majority of existing client accounts and for all new advisory account
relationships, Eclectic has full discretion to decide the specific security to trade, the
quantity, and the timing of transactions for client accounts. Eclectic will not contact
clients before placing trades in their account, but clients will receive confirmations
directly from the broker for any trades placed unless they have chosen to disable trade
alerts in their account. Clients grant us discretionary authority in the contracts they sign
with us. Clients also give us trading authority within their accounts when they sign the
custodian paperwork.
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Certain client-imposed conditions may limit our discretionary authority, such as where
the client prohibits transactions in specific security types. See also Tailored Services
and Client Imposed Restrictions under Item 4, above.
Non-Discretionary Management
For non-discretionary accounts honoring prior agreements, Eclectic makes
recommendations to clients on what securities or products to buy or sell, and it is up to
the client to approve (or reject) our recommendations. Upon client approval, we will
place the trades in the client’s account. Non-discretionary trades are typically placed
after trades in discretionary accounts due to the time lapse in receiving client approval
of non-discretionary investment recommendations and therefore may sometimes
receive less favorable pricing. Clients give us trading authority over their accounts when
they sign the custodian paperwork.
ITEM 17 - VOTING CLIENT SECURITIES
Proxy Voting
Eclectic generally votes securities (proxies) for accounts which the client grants us with
the authority to vote on their behalf. Absent special circumstances, which we describe in
our Proxy Voting Policies and Procedures, we will vote all proxies within the guidelines
we established and describe in our Proxy Voting Policies and Procedures, as we may
amend from time-to-time. At any time, clients may contact us to request information
about how we voted proxies for their securities or to get a copy of our Proxy Voting
Policies and Procedures. A brief summary of Eclectic’s Proxy Voting Policies and
Procedures is as follows:
We generally cast proxy votes in favor of proposals that:
1. Maintain or strengthen the shared interests of shareholders and management;
2. Increase shareholder value;
3. Maintain or increase shareholder influence over the issuer’s board of directors and
management;
4. Minimize cost of ownership; and
5. Maintain or increase the rights of shareholders.
We generally cast proxy votes against proposals having the opposite effect.
In the absence of specific voting guidelines from a client, Eclectic will vote proxies in a
manner that is in the best interest of the client, which may result in different voting
results for proxies for the same issuer. We will consider those factors that relate to the
client's investment or that are dictated by the client’s written instructions, including how
our vote will economically impact and affect the value of the client's investment.
Sometimes, not voting at all on a presented proposal may be in the best interest of the
client. Generally, we do not allow clients to direct our vote in a particular solicitation;
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however, we reserve the right to make exceptions in rare circumstances at a client’s
request.
Occasionally, we may have a conflict of interest in voting proxies due to a business or
personal relationship that we maintain with persons who have an interest in the
outcome of certain votes. In those cases, we will take steps to ensure that proxy voting
decisions are in the best interest of clients and are not the product of such conflict. Our
policies to address conflicts of interest include the following:
If an actual or potential conflict is found to exist, we will provide written notification of the
conflict (the “Conflict Notice”) to the client (or in the case of an employee benefit plan,
the plan's trustee or other fiduciary) in sufficient detail and with sufficient time to
reasonably inform the client (or in the case of an employee benefit plan, the plan's
trustee or other fiduciary) of the actual or potential conflict involved.
Specifically, the Conflict Notice describes:
1. The proposal to be voted upon;
2. The actual or potential conflict of interest involved;
3. Eclectic’s vote recommendation (with a summary of material factors supporting
the recommended vote); and
4. If applicable, the relationship between Eclectic and any Interested Person.
The Conflict Notice either will request the client’s consent to Eclectic’s vote
recommendation or may request the client to vote the proxy directly or through another
designee of the client.
Class Actions
Eclectic does not generally elect to participate in class action lawsuits on behalf of its
clients on an unsolicited basis. Rather, such decisions remain with the client or an entity
designated by the client. At our discretion, we may assist in determining whether the
client should pursue a particular class action lawsuit by assisting with the development
of an applicable cost-benefit analysis, for example. However, the final determination of
whether to participate, and the completion and tracking of any related documentation
generally rests with the client. Upon any client request, we will provide the client with the
transaction information we have pertaining to the client’s account needed to file a proof
of claim in a class action.
ITEM 18 - FINANCIAL INFORMATION
Registered investment advisers are required in this item to provide clients with certain
financial information or disclosures about the firm’s financial condition.
Eclectic does not require the prepayment of more than $1,200 in fees per client six
months or more in advance, does not have or foresee any financial condition that is
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reasonably likely to impair our ability to meet contractual commitments to clients, and
has not been the subject of a bankruptcy proceeding.
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Form ADV, Part 2B Brochure Supplement
David K. Little, CFP®, CFA®
Carl W. R. Lachman, CFP®
Russell W. Hall, CFP® , CPWA®
David K. MacLeod, CFP®, CFA
Travis J. McShane, CFP®, CFA
Aimee E. Calderon, CFP®
James I. Moore, CFP®
Amber M. Shrosbree, CFP®
Clarissa L. Hartono, CFP®
Russell E. Murdock, CFA®
Eclectic Associates, Inc.
1440 North Harbor Blvd.
Suite 220
Fullerton, CA 92835
(714) 738-0220
February 3, 2026
the above
individuals
is available on
This brochure supplement provides information about David Little, Carl Lachman, Russell
Hall, David MacLeod, Travis McShane, Aimee Calderon, James Moore, Amber
Shrosbree, Clarissa L. Hartono, and Russell Murdock that supplements the Eclectic
Associates, Inc. brochure. You should have already received a copy of that brochure.
Please contact our Client Services Department if you did not receive our brochure or if
you have any questions about the contents of this supplement. Additional information
about
the SEC’s website at
www.adviserinfo.sec.gov.
ITEM 1 - COVER PAGE
Description of Professional Designations Used in this Brochure
Supplement*
1Chartered Financial Analyst®
The Chartered Financial Analyst® (“CFA®”) designation is sponsored by the CFA®
Institute. To earn a CFA® charter, candidates must have four years of qualified
investment work experience, become a member of CFA® Institute, pledge to adhere to
the CFA® Institute Code of Ethics and Standards of Professional Conduct on an annual
basis, apply for membership to a local CFA® member society, and complete the CFA®
Program. The CFA® Program is organized into three levels, each culminating in a six-
hour exam. The three proctored course exams correspond to three 250-hour self-study
levels. Completing the Program takes most candidates between two and five years.
More information regarding the CFA® is available at https://www.cfainstitute.org.
2CERTIFIED FINANCIAL PLANNER™ professional
Certain persons, as identified in this Supplement below, are certified for financial
planning services in the United States by Certified Financial Planner Board of
Standards, Inc. (“CFP Board”). Therefore, they may refer to themselves as CERTIFIED
FINANCIAL PLANNER™ professionals or CFP® professionals and may use these and
CFP Board’s other certification marks (the “CFP Board Certification Marks”). The CFP®
certification is voluntary. No federal or state law or regulation requires financial planners
to hold the CFP® certification. You may find more information about the CFP®
certification at www.CFP.net.
CFP® professionals have met CFP Board’s high standards for education, examination,
experience, and ethics. To become a CFP® professional, an individual must fulfill the
following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or
university and complete CFP Board-approved coursework at a college or
university through a CFP Board Registered Program. The coursework covers the
financial planning subject areas CFP Board has determined are necessary for
the competent and professional delivery of financial planning services, as well as
a comprehensive financial plan development capstone course. A candidate may
satisfy some of the coursework requirement through other qualifying credentials.
CFP Board implemented the bachelor’s degree or higher requirement in 2007
and the financial planning development capstone course requirement in March
2012. Therefore, a CFP® professional who first became certified before those
dates may not have earned a bachelor’s or higher degree or completed a
financial planning development capstone course.
• Examination – Pass the comprehensive CFP® Certification Examination. The
examination is designed to assess an individual’s ability to integrate and apply a
broad base of financial planning knowledge in the context of real-life financial
planning situations.
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• Experience – Complete 6,000 hours of professional experience related to the
personal financial planning process, or 4,000 hours of apprenticeship experience
that meets additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and
Former CFP® Professionals Seeking Reinstatement and agree to be bound by
CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”),
which sets forth the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and
ethics requirements to remain certified and maintain the right to continue to use the CFP
Board Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This
includes a commitment to CFP Board, as part of the certification, to act as a
fiduciary, and therefore, act in the best interests of the client, at all times when
providing financial advice and financial planning. CFP Board may sanction a
CFP® professional who does not abide by this commitment, but CFP Board does
not guarantee a CFP® professional's services. A client who seeks a similar
commitment should obtain a written engagement that includes a fiduciary
obligation to the client.
• Continuing Education – Complete 30 hours of continuing education every two
years to maintain competence, demonstrate specified levels of knowledge, skills,
and abilities, and keep up with developments in financial planning. Two of the
hours must address the Code and Standards.
3Certified Private Wealth Advisor®
The Certified Private Wealth Advisor® (“CPWA®”) designation is issued by the
Investment Management Consultants Association. To earn the CPWA® designation,
each candidate is required to complete a six-month pre-study educational component
and an in-class program at The University of Chicago Booth School of Business, or
online program through Yale School of Management. Additionally, candidates must
meet all of the following requirements:
• Bachelor's degree from an accredited college or university or one of the following
designations or licenses: CIMA, CIMC, CFA, CFP, ChFC or CPA license;
• A satisfactory record of ethical conduct, as determined by IMCA’s Admissions
Committee; and
• Five years of professional client-centered experience in financial services or a
related industry.
CPWA® designees are also required to complete 40 hours of continuing education every
two years. More information regarding the CPWA designation® is available at
https://investmentsandwealth.org/.
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David K. Little, CFP®, CFA®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
David K. Little, President & Director, b. 1970
Education:
CFA®; Chartered Financial Analyst®1, CFA® Institute, 1997
CFP®; CERTIFIED FINANCIAL PLANNER™2, College for Financial Planning, 1995
B.S.; Business, Finance, Biola University, 1993
Business Background:
Eclectic Associates, Inc., President, 06/2016 to present
Eclectic Associates, Inc., Director, 12/1992 to present
Eclectic Associates, Inc., Vice President, 12/1992 to 06/2016
*Professional Designations:
David Little holds the following professional designations:
• Chartered Financial Analyst®1
• CERTIFIED FINANCIAL PLANNER™2
ITEM 3 - DISCIPLINARY INFORMATION
David Little has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
In addition to providing investment advice through Eclectic, Dave Little serves on the
Board of Directors for La Habra Community Support Foundation and La Habra Boys &
Girls Club. Eclectic has no business dealings with these entities other than the provision
of investment advisory services. Eclectic does not conduct shared operations or have
shared premises with these entities.
ITEM 5 - ADDITIONAL COMPENSATION
David Little’s only compensation comes from his regular salary and ownership of
Eclectic.
ITEM 6 - SUPERVISION
David Little, President, is responsible for supervising the advisory activities of Eclectic’s
Supervised Persons. He can be reached by calling (714) 738-0220.
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Carl W. R. Lachman, CFP®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Carl W. R. Lachman, Financial Planner, b. 1968
Education:
CFP®; CERTIFIED FINANCIAL PLANNER™2, College for Financial Planning, 2006
MBA; Management with an Emphasis in Finance, University of California, Los Angeles,
2003
ThM; Church History, Dallas Theological Seminary, 1999
AB; Economics, Mathematics Minor, Occidental College, 1990
Business Background:
Eclectic Associates, Inc., Vice President, 06/2016 to present
Eclectic Associates, Inc., Financial Planner, 11/2003 to present
First Evangelical Free Church, Financial Manager, 05/1999 to 10/2003
*Professional Designations:
Carl Lachman holds the following professional designations:
• CERTIFIED FINANCIAL PLANNER™2
ITEM 3 - DISCIPLINARY INFORMATION
Carl Lachman has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Carl Lachman’s only business is providing investment advice through Eclectic.
ITEM 5 - ADDITIONAL COMPENSATION
Carl Lachman’s only compensation comes from his regular salary and ownership of
Eclectic.
ITEM 6 - SUPERVISION
David Little, President, is responsible for supervising Carl Lachman’s activities. David
Little monitors the advice provided by Carl Lachman for consistency with client
objectives and Eclectic’s policies. David Little can be reached by calling (714) 738-0220.
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Russell W. Hall, CFP®, CPWA®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Russell W. Hall, Financial Planner, b. 1976
Education:
CPWA®; Certified Private Wealth Advisor®, Investments & Wealth Institute, 2023
CFP®; CERTIFIED FINANCIAL PLANNER™2, College for Financial Planning, 2007
PFP; Personal Financial Planning, University of California, Irvine, 2006
B.A.; Communication, Biola University, 2003
Business Background:
Eclectic Associates, Inc., Financial Planner, 09/2007 to present
Eclectic Associates, Inc., Paraplanner, 12/2001 to 09/2007
*Professional Designations:
Russell Hall holds the following professional designations:
• CERTIFIED FINANCIAL PLANNER™2
• Certified Private Wealth Advisor®3
ITEM 3 - DISCIPLINARY INFORMATION
Russell Hall has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Russell Hall’s only business is providing investment advice through Eclectic.
ITEM 5 - ADDITIONAL COMPENSATION
Russell Hall’s only compensation comes from his regular salary and ownership of
Eclectic.
ITEM 6 - SUPERVISION
David Little, President, is responsible for supervising Russell Hall’s activities. David
Little monitors the advice provided by Russell Hall for consistency with client objectives
and Eclectic’s policies. David Little can be reached by calling (714) 738-0220.
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David K. MacLeod, CFP®, CFA
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
David K. MacLeod, Chief Investment Officer, Financial Planner, b. 1985
Education:
CFA®; Chartered Financial Analyst®1, CFA® Institute, 2013
CFP®; CERTIFIED FINANCIAL PLANNER™2, College for Financial Planning, 2009
PFP; Personal Financial Planning, University of California, Irvine, 2008
B.S.; Business, Biola University, 2006
Business Background:
Eclectic Associates, Inc., Chief Investment Officer, 07/2019 to present
Eclectic Associates, Inc., Financial Planner, 08/2010 to present
Eclectic Associates, Inc., Paraplanner, 06/2006 to 08/2010
*Professional Designations:
David MacLeod holds the following professional designations:
• Chartered Financial Analyst®1
• CERTIFIED FINANCIAL PLANNER™2
ITEM 3 - DISCIPLINARY INFORMATION
David MacLeod has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
David MacLeod’s only business is providing investment advice through Eclectic.
ITEM 5 - ADDITIONAL COMPENSATION
David MacLeod’s only compensation comes from his regular salary and ownership of
Eclectic.
ITEM 6 - SUPERVISION
David Little, President, is responsible for supervising David MacLeod’s activities. David
Little monitors the advice provided by David MacLeod for consistency with client
objectives and Eclectic’s policies. David Little can be reached by calling (714) 738-0220.
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Travis J. McShane, CFP®, CFA
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Travis J. McShane, Financial Planner, b. 1988
Education:
CFA®; Chartered Financial Analyst®1, CFA® Institute, 2017
CFP®; CERTIFIED FINANCIAL PLANNER™2, College for Financial Planning, 2013
B.A.; Business Administration - Finance, California State University, Fullerton, 2010
Business Background:
Eclectic Associates, Inc., Financial Planner, 03/2013 to present
Eclectic Associates, Inc., Paraplanner, 09/2010 to 03/2013
JP Morgan Chase, Sales and Service Associate, 06/2009 to 09/2010
*Professional Designations:
Travis McShane holds the following professional designations:
• Chartered Financial Analyst®1
• CERTIFIED FINANCIAL PLANNER™2
ITEM 3 - DISCIPLINARY INFORMATION
Travis McShane has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Travis McShane’s only business is providing investment advice through Eclectic.
ITEM 5 - ADDITIONAL COMPENSATION
Travis McShane’s only compensation comes from his regular salary and ownership of
Eclectic.
ITEM 6 - SUPERVISION
David Little, President, is responsible for supervising Travis McShane’s activities. David
Little monitors the advice provided by Travis McShane for consistency with client
objectives and Eclectic’s policies. David Little can be reached by calling (714) 738-0220.
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Aimee E. Calderon, CFP®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Aimee E. Calderon, Financial Planner, b. 1977
Education:
CFP®; CERTIFIED FINANCIAL PLANNER™2, College for Financial Planning, 2001
B.A.; Business, Finance, Biola University, 1999
Business Background:
Eclectic Associates, Inc., Financial Planner, 10/2015 to present
For His Glory Community Church, Bookkeeper, 05/2014 to 12/2016
Peanut Pop, Owner, 08/2010 to 12/2014
Unemployed, 01/2009 to 07/2010
Eclectic Associates, Inc., Financial Planner, 01/1998 to 12/2008
*Professional Designations:
Aimee Calderon holds the following professional designations:
• CERTIFIED FINANCIAL PLANNER™2
ITEM 3 - DISCIPLINARY INFORMATION
Aimee Calderon has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Aimee Calderon’s only business is providing investment advice through Eclectic.
ITEM 5 - ADDITIONAL COMPENSATION
Aimee Calderon’s only compensation comes from her regular salary and ownership of
Eclectic.
ITEM 6 - SUPERVISION
David Little, President, is responsible for supervising Aimee Calderon’s activities. David
Little monitors the advice provided by Aimee Calderon for consistency with client
objectives and Eclectic’s policies. David Little can be reached by calling (714) 738-0220.
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James I. Moore, CFP®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
James I. Moore, Financial Planner, b. 1985
Education:
CFP®; CERTIFIED FINANCIAL PLANNER™2, College for Financial Planning, 2016
B.S.; Business Administration, Biola University, 2007
Business Background:
Eclectic Associates, Inc., Financial Planner, 05/2016 to present
Eclectic Associates, Inc., Paraplanner, 10/2013 to 05/2016
Evangelical Christian Credit Union, 08/2008 to 10/2013
*Professional Designations:
James Moore holds the following professional designations:
• CERTIFIED FINANCIAL PLANNER™2
ITEM 3 - DISCIPLINARY INFORMATION
James Moore has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
James Moore’s only business is providing investment advice through Eclectic.
ITEM 5 - ADDITIONAL COMPENSATION
James Moore’s only compensation comes from his regular salary and ownership of
Eclectic.
ITEM 6 - SUPERVISION
David Little, President, is responsible for supervising James Moore’s activities. David
Little monitors the advice provided by James Moore for consistency with client
objectives and Eclectic’s policies. David Little can be reached by calling (714) 738-0220.
x
Eclectic Associates, Inc.
Part 2B Supplements
Amber M. Shrosbree, CFP®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Amber M. Shrosbree, Financial Planner, b. 1996
Education:
CFP®; CERTIFIED FINANCIAL PLANNER™2, College for Financial Planning, 2021
B.A.; Economics and Business, Westmont College, 2017
Business Background:
Eclectic Associates, Inc., Financial Planner, 08/2021 to present
Eclectic Associates, Inc., Paraplanner, 09/2018 to 08/2021
Integrated Procurement Technologies, 01/2018 to 09/2018
Westmont College, Student, 09/2014 to 12/2017
*Professional Designations:
Amber M. Shrosbree holds the following professional designations:
• CERTIFIED FINANCIAL PLANNER™2
ITEM 3 - DISCIPLINARY INFORMATION
Amber M. Shrosbree has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Amber M. Shrosbree's only business is providing investment advice through Eclectic.
ITEM 5 - ADDITIONAL COMPENSATION
Amber M. Shrosbree's only compensation comes from her regular salary at Eclectic.
ITEM 6 - SUPERVISION
David Little, President, is responsible for supervising Amber M. Shrosbree's activities.
David Little monitors the advice provided by Amber M. Shrosbree for consistency with
client objectives and Eclectic’s policies. David Little can be reached by calling (714)
738-0220.
xi
Eclectic Associates, Inc.
Part 2B Supplements
Clarissa L. Hartono, CFP®
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Clarissa L. Hartono, Financial Planner, b. 2000
Education:
CFP®; CERTIFIED FINANCIAL PLANNER™2, College for Financial Planning, 2024
B.A.; Business Administration - Financial Planning, Biola University, 2021
Business Background:
Eclectic Associates, Inc., Financial Planner, 04/2024 to present
Eclectic Associates, Inc., Paraplanner, 05/2021 to 04/2024
Injoy Life Resources, Office Administration, 03/2021 to 11/2021
Student, 06/2014 to 12/2021
*Professional Designations:
Clarissa L. Hartono holds the following professional designations:
• CERTIFIED FINANCIAL PLANNER™2
ITEM 3 - DISCIPLINARY INFORMATION
Clarissa L. Hartono has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Clarissa L. Hartono’s only business is providing investment advice through Eclectic.
ITEM 5 - ADDITIONAL COMPENSATION
Clarissa L. Hartono’s only compensation comes from her regular salary at Eclectic.
ITEM 6 - SUPERVISION
David Little, President, is responsible for supervising Clarissa L. Hartono’s activities.
David Little monitors the advice provided by Clarissa L. Hartono for consistency with
client objectives and Eclectic’s policies. David Little can be reached by calling (714)
738-0220.
xii
Eclectic Associates, Inc.
Part 2B Supplements
Russell E. Murdock, CFA
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Russell E. Murdock, b. 1960
Education:
CFA®; Chartered Financial Analyst®1, CFA® Institute, 1998
Pepperdine University, CA; M.B.A., 1992
California State University, Fullerton, CA; B.A. Business, 1984
Business Background:
Eclectic Associates, Inc., Financial Advisor, 01/2026 to present
Seabreeze Capital Management, LLC; Managing Member/Principal, 01/2003 to Present
*Professional Designations:
Russell Murdock holds the following professional designations:
• Chartered Financial Analyst®1
ITEM 3 - DISCIPLINARY INFORMATION
Russell Murdock has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Russell Murdock’s only business is providing investment advice through Eclectic.
ITEM 5 - ADDITIONAL COMPENSATION
Russell Murdock’s compensation comes from a salary & bonus based on the business
he brings to Eclectic.
ITEM 6 - SUPERVISION
David Little, President, is responsible for supervising Russell Murdock’s activities. David
Little monitors the advice provided by Russell Murdock for consistency with client
objectives and Eclectic’s policies. David Little can be reached by calling (714) 738-0220.
xiii
Eclectic Associates, Inc.
Part 2B Supplements
Rev. April 2011
Privacy Information
FACTS WHAT DOES ECLECTIC ASSOCIATES, INC.
DO WITH YOUR PERSONAL INFORMATION?
Why?
Financial companies choose how they share your personal
information. Federal law gives consumers the right to limit some but
not all sharing. Federal law also requires us to tell you how we
collect, share, and protect your personal information. Please read
this notice carefully to understand what we do.
What?
The types of personal information we collect and share depend on
the product or service you have with us. This information can
include:
• Social Security number and income
• account balances and transaction history
• assets and risk tolerance
When you are no longer our customer, we continue to share your
information as described in this notice.
How?
All financial companies need to share customers’ personal
information to run their everyday business. In the section below, we
list the reasons financial companies can share their customers’
personal information; the reasons Eclectic Associates, Inc. chooses
to share; and whether you can limit this sharing.
Reasons we can share your personal
information
Can you limit
this sharing?
Does Eclectic
Associates,
Inc. share?
YES
NO
For our everyday business purposes -
as permitted by law
NO
For our marketing purposes - to offer our
products and services to you
We Don’t
Share
NO
For joint marketing with other financial
companies
We Don’t
Share
NO
We Don’t
Share
For our affiliates’ everyday business purposes -
information about your transactions and
experiences
NO
For our affiliates’ everyday business purposes -
information about your creditworthiness
We Don’t
Share
For nonaffiliates to market to you
NO
We Don’t
Share
Questions? Call (714) 738-0220 or go to www.eclecticassociates.com
Page 2
WHO WE ARE
Eclectic Associates, Inc.
Who is providing this
notice?
WHAT WE DO
How does Eclectic
Associates, Inc. protect
my personal
information?
To protect your personal information from unauthorized
access and use, we use security measures that comply
with federal law. These measures include computer
safeguards and secured files and buildings.
We collect your personal information, for example, when
you
How does Eclectic
Associates, Inc. collect
my personal
information?
tell us about your investment or retirement portfolio
tell us about your investment or retirement earnings
• seek advice about your investments
• enter into an investment advisory contract
•
•
• give us your contact information
We also collect your personal information from other
companies.
Federal law gives you the right to limit only:
Why can’t I limit all
sharing?
• sharing for affiliates’ everyday business purposes -
information about your creditworthiness
• affiliates from using your information to market to you
• sharing for nonaffiliates to market to you
State laws and individual companies may give you
additional rights to limit sharing.
DEFINITIONS
Affiliates
Companies related by common ownership or control.
They can be financial and nonfinancial companies.
• Eclectic Associates, Inc. has no affiliates
Nonaffiliates
Companies not related by common ownership or
control. They can be financial and non-financial
companies.
• Eclectic Associates, Inc. does not share with
nonaffiliates so they can market to you
Joint Marketing
A formal agreement between nonaffiliated financial
companies that together market financial products or
services to you.
• Eclectic Associates, Inc. doesn’t jointly market