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Item 1: Cover Page
Effective Assets, Inc.
2342 Shattuck Avenue, # 366
Berkeley, CA 94704
Form ADV Part 2A – Firm Brochure
(510) 549-2525
Dated February 4, 2026
This Brochure provides information about the qualifications and business practices of Effective Assets, Inc.,
“Effective Assets”. If you have any questions about the contents of this Brochure, please contact us at (510) 549-
2525. 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.
Effective Assets, Inc. is registered as an investment adviser with the U.S. Securities and Exchange Commission.
Registration of an investment adviser does not imply any level of skill or training.
Additional information about Effective Assets is available on the SEC’s website at www.adviserinfo.sec.gov
which can be found using the firm’s identification number (CRD) 285744.
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Since the last annual filing of this Form ADV Part 2A, dated January 25, 2025, there have been no material
changes.
Item 2: Material Changes
Please note that this item only discusses changes we consider material and no other changes that have occurred.
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Item 3: Table of Contents
Contents
Item 1: Cover Page ...................................................................................................................................... 1
Item 2: Material Changes ............................................................................................................................ 2
Item 3: Table of Contents ........................................................................................................................... 3
Item 4: Advisory Business ........................................................................................................................... 4
Item 5: Fees and Compensation ................................................................................................................. 8
Item 6: Performance-Based Fees and Side-By-Side Management ........................................................... 10
Item 7: Types of Clients ............................................................................................................................. 10
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 11
Item 9: Disciplinary Information ............................................................................................................... 13
Item 10: Other Financial Industry Activities and Affiliations .................................................................... 13
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............. 14
Item 12: Brokerage Practices .................................................................................................................... 15
Item 13: Review of Accounts .................................................................................................................... 16
Item 14: Client Referrals and Other Compensation ................................................................................. 16
Item 15: Custody ....................................................................................................................................... 17
Item 16: Investment Discretion ................................................................................................................ 17
Item 17: Voting Client Securities .............................................................................................................. 18
Item 18: Financial Information ................................................................................................................. 18
Form ADV Part 2B – Brochure Supplement .............................................................................................. 19
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Description of Advisory Firm
Item 4: Advisory Business
Effective Assets, Inc. is registered as an investment adviser with the U.S. Securities and Exchange Commission.
We were founded in November 2016. Justin Martello is the principal owner of Effective Assets. As of December
31, 2025, we manage $159,977,283 on a discretionary basis and $5,164,932 on a non-discretionary basis.
Types of Advisory Services
Investment Advisory Services and Third-Party Investment Management
We are in the business of advising on individually tailored, socially responsible investment portfolios. Our firm
provides continuous discretionary investment supervisory services to a client regarding the investment of client
funds based on the individual needs of the client. Through personal discussions in which goals and objectives
based on a client's particular circumstances are established, we develop a client's personal investment policy or
an investment plan with an asset allocation target and recommend and advise on a portfolio based on that
policy and allocation target. During our data-gathering process, we determine the client’s individual objectives,
time horizons, risk tolerance, social policy, and liquidity needs. We may also review and discuss a client’s prior
investment history, as well as family composition and background.
Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation, growth,
income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions,
including but not limited to generally recognized screening policies, focused on environmental, social, and
corporate governance factors, and adhere to specific social policy guidance on investing in certain securities,
types of securities, or industry sectors. Fees pertaining to this service are outlined in Item 5 of this brochure.
As part of this service, we may employ the use of unaffiliated sub-advisers to manage either a portion of, or the
entirety of, a client’s investment portfolio, or act as a co-advisor with a third-party money manager (“Outside
Manager”). Our review process and analysis of sub-advisers and Outside Managers is further discussed in Item
8 of this Form ADV Part 2A. Additionally, we will meet with the client on a periodic basis to discuss changes in
their personal or financial situation, suitability, and any new or revised restrictions to be applied to the account.
Fees pertaining to this service are outlined in Item 5 of this brochure. We may also recommend alternative funds
to clients, when suitable, for investment.
Investment Advice Relating to Retirement Accounts
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).
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• 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.
• Give you basic information about conflicts of interest.
In addition, and as required by this rule, we provide information regarding the services that we provide to you,
and any material conflicts of interest, in this brochure and in your client agreement.
Financial Planning
Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently
known variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect of
financial planning is that through the financial planning process, all questions, information, and analysis will be
considered as they impact and are impacted by the entire financial and life situation of the client. Clients
purchasing this service will receive a written or an electronic report, providing the client with a detailed financial
plan designed to achieve his or her stated financial goals and objectives.
The client always has the right to decide whether to act upon our recommendations. If the client elects to act
on any of the recommendations, the client always has the right to affect the transactions through anyone of
their choosing.
In general, the financial plan will address any or all the following areas of concern. The client and advisor will
work together to select the specific areas to cover. These areas may include, but are not limited to, the following:
• Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine
your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to
reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first
based on factors such as the interest rate of the debt and any income tax ramifications. We may also
recommend what we believe to be an appropriate cash reserve that should be considered for emergencies
and other financial goals, along with a review of accounts (such as savings accounts, money market funds
or community investment notes) for such reserves, plus strategies to save desired amounts.
• College Savings: Includes projecting the amount that will be needed to achieve college or other post-
secondary education funding goals, along with advice on ways for you to save the desired amount.
Recommendations as to savings strategies are included, and, if needed, we will review your financial
picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if
appropriate).
• Employee Benefits Optimization: We will provide review and analysis as to whether you, as an employee,
are taking the maximum advantage possible of your employee benefits. If you are a business owner, we
will consider and/or recommend the various benefit programs that can be structured to meet both
business and personal retirement goals.
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• Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate
plan, which may include whether you have a will, powers of attorney, trusts and other related documents.
Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing
appropriate estate planning strategies such as the use of applicable trusts.
We always recommend that you consult with a qualified attorney when you initiate, update, or complete
estate planning activities. We may provide you with contact information for attorneys who specialize in
estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will
participate in meetings or phone calls between you and your attorney with your approval or request.
• Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will
identify what you plan to accomplish, what resources you will need to make it happen, how much time
you will need to reach the goal, and how much you should budget for your goal.
•
Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term care,
liability, home and automobile.
•
Investment Analysis: This may involve developing an asset allocation strategy to meet clients’ financial
goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee
stock options, as well as assisting you in establishing your own investment account at a selected custodian.
The strategies and types of investments we may recommend are further discussed in Item 8 of this
brochure.
• Retirement Planning: Our retirement planning services typically include projections of your likelihood of
achieving your financial goals, typically focusing on financial independence as the primary objective. For
situations where projections show less than the desired results, we may make recommendations, including
those that may impact the original projections by adjusting certain variables (e.g., working longer, saving
more, spending less, taking risk with investments).
If you are near retirement or already retired, advice may be given on appropriate distribution strategies
to minimize the likelihood of running out of money or having to adversely alter spending during your
retirement years.
• Risk Management: A risk management review includes an analysis of your exposure to major risks that
could have a significantly adverse effect on your financial picture, such as premature death, disability,
property and casualty losses, or the need for long-term care. Advice may be provided on ways to minimize
such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and,
likewise, the potential cost of not purchasing insurance (“self-insuring”).
• Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part
of your overall financial planning picture. For example, we may make recommendations on which type of
account(s) or specific investments should be owned based in part on their “tax efficiency,” with
consideration that there is always a possibility of future changes to federal, state or local tax laws and
rates that may affect your situation.
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We recommend that you consult with a qualified tax professional before initiating any tax planning
strategy, and we may provide you with contact information for accountants or attorneys who specialize in
this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls
between you and your tax professional with your approval.
Newsletters
Effective Assets will periodically (generally quarterly) publish newsletters relating to investments and financial
planning. Effective Assets does not charge a fee for these newsletters.
Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all our clients. However, specific client financial plans and their
implementation are dependent upon a client’s suitability questionnaires, social policy questionnaires, and
investment policy statement, which outlines each client’s current situation (income, tax levels, and risk
tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches
restrictions, needs, and targets.
Wrap Fee Programs
We do not participate in wrap fee programs but may use Sub-Advisers who do. In the event a client is using a
Sub-adviser who participates in wrap fee programs, they will receive the Sub-adviser’s Wrap Program Brochure
in addition to its Form ADV Part 2.
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Item 5: Fees and Compensation
Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing the
investment advisory contract, the investment advisory contract may be terminated by the client within five (5)
business days of signing the contract without incurring any advisory fees and without penalty. How we are paid
depends on the type of advisory service we are performing. Please review the fee and compensation
information below.
Investment Advisory Services and Third-Party Investment Management
Our standard advisory fee is based on the market value of the assets under management and is calculated as
follows:
Account Value
Annual Advisory Fee
Annual Advisory Fee
Individual Bonds
Stocks and Funds
0.75%
1.25%
First $500,000
0.75%
1.10%
Next $500,000
0.75%
1.00%
Next $2,000,000
0.75%
0.90%
Next $2,000,000
0.75%
0.75%
Next $5,000,000
0.65%
0.65%
Next $10,000,000
Negotiable
Negotiable
$20,000,000 and Above
The annual fees include advisory fees paid to any sub-advisers and are negotiable and are paid in arrears on a
quarterly basis based on the average daily balance. The advisory fee is a blended fee and is calculated by
assessing the percentage rates using the predefined levels of assets as shown in the above chart, resulting in a
combined weighted fee. For example, a stock and fund account valued at $2,000,000 would pay an effective fee
of 1.09% with the annual fee of $21,750.00. The quarterly fee is determined by the following calculation:
(($500,000 x 1.25%) + ($500,000 x 1.10%) + ($1,000,000 x 1.00)) ÷ 4 = $5,437.50. No increase in the annual fee
shall be effective without agreement from the client by signing a new agreement or amendment to their current
advisory agreement.
Advisory fees are directly debited from client accounts, or the client may choose to pay by check. Accounts
initiated or terminated during a billing period will be charged a pro-rated fee based on the amount of time
remaining in the billing period. An account may be terminated with written notice at least 15 calendar days in
advance. Since fees are paid in arrears, no rebate will be needed upon termination of the account.
Orion Portfolio Solutions, LLC
We do have existing clients where we are co-advisors with Orion Portfolio Solutions, LLC where the client signs
and agreement both with us and Orion. We no longer offer their services to new accounts. For accounts in which
Orion Portfolio Solutions, LLC acts as the Outside Manager, the Total Client Fee consists of an Administration
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Fee, a Strategist Fee, and an Advisory Fee, is based on the market value of the account, and is calculated as
follows:
Account Value
Advisory
Fee
Orion Portfolio
Solutions Fee
Strategist
Fee
Total
Client Fee
0.85%
0.45%
.10%
1.40%
$0 - $50,000.00
0.85%
0.30%
.10%
1.25%
$50,000.01 - $100,000.00
0.85%
0.20%
.10%
1.15%
$100,000.01 - $500,000.00
0.85%
0.15%
.10%
1.10%
$500,000.01 - $1,000,000.00
0.85%
0.10%
.10%
1.05%
$1,000,000.01 - $5,000,000.00
0.85%
0.08%
.10%
1.03%
Over $5,000,000.00
This fee will be deducted from your account monthly in arrears and is based on the average daily balance for
the previous month. If your account was not open for the entire month, then the fee will be pro-rated.
Please note, the above fee schedule includes Effective Assets advisory fee. No increase in the annual fee shall
be effective without agreement from the client by signing a new agreement or amendment to their current
advisory agreement.
An account may be terminated with written notice. Since fees are paid in arrears, not in advance, no refund will
be needed upon termination of the account.
Alternative Investments including Direct Participation Programs (DPPs) & Private
Equity Funds
Our standard advisory fee is based on the market value of the assets invested in the fund and is 1.00% per year.
The annual fees are negotiable, are paid in arrears monthly from the distributions of the fund(s) by the fund
administrator, and remitted to Effective Assets, Inc. Alternatively, the client may pay Effective Assets, Inc.
directly.
Financial Planning Fixed Fee
Financial Planning will generally be offered on a fixed fee basis. The fixed fee will be agreed upon before the
start of any work. The fixed fee can range between $1,500 and $3,000 depending on complexity and client
needs. The fee is negotiable and payable by check. If a fixed fee program is chosen, half of the fee is due at the
beginning of the process and the remainder is due at completion of work, however, Effective Assets will not bill
an amount above $500.00 more than 6 months in advance. In the event of early termination, the client will be
billed for the hours worked at a rate of $200 per hour. If the initial deposit is greater than the amount billed,
then the client will be refunded the difference. If the initial deposit is less, then the client will be billed the
difference.
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Financial Planning Hourly Fee
The Financial Planning fee is an hourly rate of $200 per hour, depending on complexity. Clients are billed for the
actual time spent by our firm, assessed in 15-minute increments, and a partial increment will be treated. The
fee may be negotiable in certain cases and is due at the completion of the engagement and is payable by check.
In the event of early termination by the client, any fees for the hours already worked will be due, and any
completed planning work will be provided to the client. Since fees are paid at completion, there will be no refund
of fees.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses that
may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, and other third
parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund
and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus.
Such charges, fees and commissions are exclusive of and in addition to our fee, and we shall not receive any
portion of these commissions, fees, and costs.
Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for client’s
transactions and determining the reasonableness of their compensation (e.g., commissions).
We do not accept compensation for the sale of securities or other investment products including asset-based
sales charges or service fees from the sale of mutual funds.
We do not offer performance-based fees.
Item 6: Performance-Based Fees and Side-By-
Side Management
Item 7: Types of Clients
We provide financial planning and portfolio management services to individuals, high net-worth individuals,
trusts, pensions and profit-sharing plans, charitable organizations, corporations, or other businesses. Our
minimum client household account size requirement is $1,000,000.
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Evaluation of Third-Party Investment Advisers and Investment Companies
Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss
We utilize investment companies in our investment management and refer clients to third-party investment
advisers (“Sub-Advisers”). We prefer to invest client assets with managers who have demonstrated a capability
for integrating analysis of environmental, social, and governance (ESG) factors into the investment process. Our
analysis of Sub-Advisers involves the examination of the experience, expertise, investment philosophies, and
past performance of the Sub-Advisers to determine if that manager has demonstrated an ability to invest over
a period and in different economic conditions. We monitor the manager’s underlying holdings, strategies,
concentrations, and leverage as part of our overall periodic risk assessment. Additionally, as part of our due-
diligence process, we survey the manager’s compliance and business enterprise risks. A risk of investing with a
Sub-Adviser who has been successful in the past is that he/she may not be able to replicate that success in the
future. In addition, as we do not control the underlying investments in a Sub-Adviser’s portfolio, there is also a
risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a
less suitable investment for our clients. Moreover, as we do not control the manager’s daily business and
compliance operations, we may be unaware of the lack of internal controls necessary to prevent business,
regulatory, or reputational deficiencies.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment which you
should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities and any other
investment or security. Material risks associated with our investment strategies are listed below.
Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of
a general market decline, reducing the value of the investment regardless of the operational success of the
issuer’s operations or its financial condition.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended.
Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations
are often more volatile and less liquid than investments in larger companies. Small and medium cap companies
may face a greater risk of business failure, which could increase the volatility of the client’s portfolio.
Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A
high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result
in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s
performance.
Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be
more volatile than at other times. Under certain market conditions we may be unable to sell or liquidate
investments at prices we consider reasonable or favorable or find buyers at any price.
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Concentration Risk: Certain investment strategies focus on asset-classes, industries, sectors or types of
investment. From time to time these strategies may be subject to greater risks of adverse developments in such
areas of focus than a strategy that is more broadly diversified across a wider variety of investments.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall
below par value or the principal investment. The opposite is also generally true: bond prices generally rise when
interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price
changes. Most other investments are also sensitive to the level and direction of interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the
securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of your
investments remains the same.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities may have
other risks.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or
restructuring could lose all value. A slower-growth or recessionary economic environment could have an
adverse effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and
repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively,
investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest, but
rather are priced at a discount from their face values and their values accrete over time to face value at maturity.
The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and
maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest
rates fall. The longer the time a bond’s maturity, the greater its interest rate risk.
Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the
construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds.
However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax
return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal
bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk,
reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears
its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur
higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected
by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund
(such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a
market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that
utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials
deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide
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“circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser
has no control over the risks taken by the underlying funds in which clients invest.
Direct Participation Programs (DPPs) – Risks involved in DPP investing may include:
following the sale or distribution of assets an investor may receive less than their principal invested,
tenant turnover in Real Estate Investment Trusts, and
•
• a lack of a public market in certain issues,
•
limited liquidity and transferability,
• a fluctuation of value of the assets within the DPP,
•
reliance on the investment manager to select and manage assets,
• changes in interest rates, laws, operating expenses, and insurance costs,
•
• current market conditions.
Private Equity Fund Risk. Unlike mutual funds, which generally invest in publicly traded securities that are
relatively liquid, private equity funds generally invest in large amounts of illiquid securities from private
companies. Funds will have illiquid underlying investments that may not be easily sold, and investors may have
to wait for improvements or development before any redemption. Given the illiquid nature of the underlying
purchases made by private equity managers, private equity funds are considered long-term investments. With
long-term investments, clients should consider their financial ability to bear large fluctuations in value and hold
these investments over a number of years.
Criminal or Civil Actions
Item 9: Disciplinary Information
Effective Assets and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
Effective Assets and its management have not been involved in administrative enforcement proceedings.
Self-Regulatory Organization Enforcement Proceedings
Effective Assets and its management have not been involved in legal or disciplinary events that are material to
a client’s or prospective client’s evaluation of Effective Assets or the integrity of its management.
No Effective Assets employee is registered, or has an application pending to register, as a broker-dealer or a
registered representative of a broker-dealer.
Item 10: Other Financial Industry Activities and
Affiliations
No Effective Assets employee is registered, or has an application pending to register, as a futures commission
merchant, commodity pool operator or a commodity trading advisor.
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Effective Assets receives compensation from First Affirmative for marketing, distribution, and administrative
costs in relation to client investment in The First Affirmative Giving Fund, a donor advised fund owned and
administered by Impact Assets, Inc., an independent 501(c)3 organization.
Justin Martello is licensed to sell life, long-term care and long-term disability insurance and may engage in
product sales with our clients, for which he will receive compensation in the form of commissions. Any
commissions received through insurance product sales are separate and distinct from advisory fees that clients
may pay for advisory services under Effective Assets.
Recommendations or Selections of Other Investment Advisers
Effective Assets employs sub-advisers to manage client accounts. Effective Assets compensates these sub-
advisers out of its advisory fee. All situations where Effective Assets receives payment for services creates a
conflict of interest and Effective Assets has a financial incentive to employ sub-advisers that charge less for their
services. However, when employing sub-advisers, the client’s best interest and suitability of the sub-advisers
will be the main determining factors of Effective Assets. Effective Assets will only recommend another
investment adviser who is properly licensed or registered as an investment adviser.
Item 11: Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of
each client. Our clients entrust us with their funds and personal information, which in turn places a high standard
on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the
expected basis of all our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility
adopted by the CFP® Board of Standards Inc. and accepts the obligation not only to comply with the mandates
and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and
professionally responsible manner in all professional services and activities. Additionally, Effective Assets
requires adherence to its Insider Trading Policy.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its
specific provisions will not shield associated persons from liability for personal trading or other conduct that
violates a fiduciary duty to advisory clients. A summary of the Code of Ethics' Principles is outlined below.
•
Integrity - Associated persons shall offer and provide professional services with integrity.
•
Objectivity - Associated persons shall be objective in providing professional services to clients.
•
Competence - Associated persons shall provide services to clients competently and maintain the
necessary knowledge and skill to continue to do so in those areas in which they are engaged.
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•
Fairness - Associated persons shall perform professional services in a manner that is fair and reasonable
to clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such
services.
•
Confidentiality - Associated persons shall not disclose confidential client information without the specific
consent of the client unless in response to proper legal process, or as required by law.
•
Professionalism - Associated persons’ conduct in all matters shall reflect credit of the profession.
•
Diligence - Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm
access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our
firm will provide of copy of its Code of Ethics to any client or prospective client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflicts
of Interest
Neither our firm, its associates or any related person is authorized to recommend to a client, or effect a
transaction for a client, involving any security in which our firm or a related person has a material financial
interest, such as in the capacity as an underwriter, adviser to the issuer, etc.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
Our firm and its “related persons” do not invest in the same securities, or related securities, e.g., warrants,
options or futures, which we recommend to clients.
Trading Securities at/Around the Same Time as Client’s Securities
Because our firm and its “related persons” do not invest in the same securities, or related securities, e.g.,
warrants, options or futures, which we recommend to clients, we do not trade in securities at or around the
same time as clients.
Factors Used to Select Custodians and/or Broker-Dealers
Item 12: Brokerage Practices
Effective Assets, Inc. does not have any affiliation with Broker-Dealers. Specific custodian recommendations
are made to client based on their need for such services. We recommend custodians based on the reputation
and services provided by the firm.
1. Research and Other Soft-Dollar Benefits
We currently do not receive soft dollar benefits.
2. Brokerage for Client Referrals
We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third
party.
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3. Clients Directing Which Broker/Dealer/Custodian to Use
We do recommend a specific custodian for clients to use, however, clients may custody their assets at a
custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions. By
allowing clients to choose a specific custodian, we may be unable to achieve most favorable execution of client
transaction, and this may cost clients’ money over using a lower-cost custodian.
Aggregating (Block) Trading for Multiple Client Accounts
Investment advisers may elect to purchase or sell the same securities for several clients at approximately the
same time when they believe such action may prove advantageous to clients. This process is referred to as
aggregating orders, batch trading or block trading. We do not engage in block trading. It should be noted that
implementing trades on a block or aggregate basis may be less expensive for client accounts; however, it is our
trading policy is to implement all client orders on an individual basis. Therefore, we do not aggregate or “block”
client transactions. Considering the types of investments, we hold in advisory client accounts, we do not believe
clients are hindered in any way because we trade accounts individually. This is because we develop
individualized investment strategies for clients and holdings will vary. Our strategies are primarily developed for
the long-term and minor differences in price execution are not material to our overall investment strategy.
Sub-Advisers used by Effective Assets may block client trades at their discretion. Their specific practices are
further discussed in their ADV Part 2A, Item 12. In addition, since Effective Assets does not trade client accounts,
we do not aggregate trades.
Item 13: Review of Accounts
Client accounts with the Investment Management Service will be reviewed regularly on a quarterly basis by
Justin Martello, Financial Planner and CCO. The account is reviewed with regards to the client’s investment
policies and risk tolerance levels. Events that may trigger a special review would be unusual performance,
addition or deletions of client-imposed restrictions, excessive draw-down, volatility in performance, or buy and
sell decisions from the firm or per client's needs.
Clients will receive trade confirmations from the custodian(s) for each transaction in their accounts as well as
monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity
in the accounts, such as receipt of dividends and interest.
Effective Assets will not provide written reports to Investment Management clients.
We do not receive any economic benefit, directly or indirectly from any third party for advice rendered to our
clients. Nor do we directly or indirectly compensate any person who is not advisory personnel for client referrals.
Item 14: Client Referrals and Other
Compensation
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Third part managers recommended by us and contracted by our clients are properly registered in jurisdictions
where required.
Item 15: Custody
Effective Assets does not accept custody of client funds. Clients should receive at least quarterly statements
from the broker dealer, bank or other qualified custodian that holds and maintains client's investment assets.
We urge you to carefully review such statements and compare such official custodial records to the account
statements or reports that we may provide to you. Our statements or reports may vary from custodial
statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities.
Standing Letters of Authorization: Effective Assets does maintain a standing letter of authorization (SLOA)
where the funds or securities are being sent to a third party, and the following conditions are met:
a. The client provides an instruction to the qualified custodian, in writing, that includes the client’s
signature, the third party’s name, and either the third party’s address or the third party’s account
number at a custodian to which the transfer should be directed.
b. The client authorizes Effective Assets, in writing, either on the qualified custodian’s form or
separately, to direct transfers to the third party either on a specified schedule or from time to
time.
c. The client’s qualified custodian performs appropriate verification of the instruction, such as a
signature review or other method to verify the client’s authorization and provides a transfer of
funds notice to the client promptly after each transfer.
d. The client has the ability to terminate or change the instruction to the client’s qualified custodian.
e. Effective Assets has no authority or ability to designate or change the identity of the third party,
the address, or any other information about the third party contained in the client’s instruction.
f. The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
g. Effective Assets maintains records showing that the third party is not a related party of Effective
Assets or located at the same address as Effective Assets.
Item 16: Investment Discretion
For those client accounts where we provide investment management services, we maintain discretion over
client accounts with respect to the hiring or firing of sub-advisers. Discretion is explained to clients in detail
when an advisory relationship has commenced. At the start of the advisory relationship, the client will grant our
firm manager selection over the account. Additionally, the discretionary relationship will be outlined in the
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advisory contract and signed by the client. Clients may impose reasonable restrictions on investing in certain
securities, types of securities, or industry sectors.
Item 17: Voting Client Securities
Effective Assets does not vote Client proxies. Clients, or the Sub-Adviser(s), will maintain exclusive responsibility
for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client
shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder
communications relating to the Client’s investment assets. If the client would like our opinion on a particular
proxy vote, they may contact us at the number listed on the cover of this brochure.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event we
were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless
you have authorized our firm to contact you by electronic mail, in which case, we would forward you any
electronic solicitation to vote proxies.
Item 18: Financial Information
Registered investment advisers are required in this Item to provide you with certain financial information or
disclosures about our financial condition. We have no financial commitment that impairs our ability to meet
contractual and fiduciary commitments to clients, and we have not been the subject of a bankruptcy proceeding.
Additionally, we do not require or solicit prepayment of more than $1,200 in fees per client six months in
advance.
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Effective Assets, Inc.
2342 Shattuck Avenue, # 366
Berkeley, CA 94704
(510) 549-2525
Dated February 4, 2026
Form ADV Part 2B – Brochure Supplement
For
Justin Everett Martello
Financial Planner, and Chief Compliance Officer
This brochure supplement provides information about Justin Martello that supplements the Effective Assets,
Inc. (“Effective Assets”) brochure. A copy of that brochure precedes this supplement. Please contact Justin
Martello if the Effective Assets brochure is not included with this supplement or if you have any questions about
the contents of this supplement.
Additional information about Justin Martello is available on the SEC’s website at www.adviserinfo.sec.gov which
can be found using the identification number (CRD) 4751869.
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Item 2: Educational Background and Business
Justin Everett Martello
Born: 1973
Experience
Educational Background
• 2009 – Certified Financial Planner™ Practitioner, College for Financial Planning
• 1995 – Bachelor of Science – Natural Resources, University of Michigan
Business Experience
• 10/2016 – Present, Effective Assets, Inc., Financial Planner and CCO
• 01/2012 – 12/2017, Effective Assets, Financial Planner
• 01/2007 – 12/2011, Cambridge Investment Research, Inc., Registered Representative
• 08/2005 – 12/2006, Hornor, Townsend & Kent, Inc., Registered Representative
Professional Designations, Licensing & Exams
CERTIFIED FINANCIAL PLANNER™ professional
I am certified for financial planning services in the United States by Certified Financial Planner Board of
Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER™
professional or a CFP® professional, and I 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.
• 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.
• 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®
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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.
No management person at Effective Assets, Inc. has ever been involved in an arbitration claim of any kind or
been found liable in a civil, self-regulatory organization, or administrative proceeding.
Item 3: Disciplinary Information
Item 4: Other Business Activities
Justin Martello is an independent insurance agent. As such, Justin Martello, in his separate capacity as an
insurance agent, will be able to purchase insurance and insurance-related investment products (insurance) for
your account, for which he will receive separate and customary compensation. While Justin Martello endeavors
at all times to put the interest of our clients first as part of our firm's fiduciary duty, you should be aware that
the receipt of additional compensation itself creates a conflict of interest and may affect their judgment when
making recommendations. This activity accounts for approximately 5% of his time.
Justin Martello does not receive any economic benefit from any person, company, or organization, in exchange
for providing clients advisory services through Effective Assets, in addition to activities disclosed in Item 4 of this
Brochure Supplement.
Item 5: Additional Compensation
Justin Martello, as Financial Planner and Chief Compliance Officer of Effective Assets, is responsible for
supervision. He may be contacted at the phone number on this brochure supplement.
Item 6: Supervision
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