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As of October 27, 2025
Form ADV: Part 2 A & B
Part 2A: The Brochure: This brochure discloses information about the qualifications and business practices of the
investment Advisory firm named below for the benefit of its clients and prospective clients. Please note that the terms
“registered investment adviser” or “registered” do not imply a certain level of skill or training. If the adviser uses a
wrap fee program, it is found in Appendix 1. If you have any questions about the contents of this brochure, please
contact the investment Advisory firm at the contacts given below.
Part 2B: Brochure Supplements disclose information about persons providing advice.
2A: Brochure:
Item 1: Cover Page: for
Emerson Equity LLC
[“EMERSON EQUITY”]
155 Bovet Road, Suite 725
San Mateo, California 94402
[CRD # 130032 / SEC # 801-71293]
Telephone: 650-312-0200
or
Facsimile: 650-312-0206
Email: info@emersonequity.com
website: www.emersonequity.com
Please note that this brochure has not been approved by the Securities & Exchange Commission or by any state
securities authority. As of the date of this filing, the firm is an SEC registered investment adviser, as well as
registered/notice filed in multiple states; registration does not mean approval or verification by those regulators,
nor does it imply a certain level of skill or training. More information about the firm is at Investment Adviser Public
Disclosure: www.adviserinfo.sec.gov.
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2A: Brochure: Item 2: Material Changes: If we amend this disclosure brochure, we are to send you either a new
copy of the brochure or at least this item 2 describing the changes made so you can decide if you want us to send
you a complete, new copy. A summary of material changes is:
attached as an exhibit to or
included here as part of this updated brochure or
X
__ no summary of material changes is required because there have been no
material changes to this adviser’s brochure since its last annual updating
amendment on August 4, 2025.
Material Changes:
Sections 4, 8, 10, 12, 1nad 15 were updated to reflect the availability of the Goldman Sachs Concentrated Stock
Program.
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2A: Brochure: Item 3: Table of Contents:
Item 1. Cover Page: Emerson Equity LLC’s name, address, contact information.
Page 1, above
Item 2. Material Changes: Amendments.
Page 2, above
Item 3. Table of Contents:
Page 3
Item 4. Emerson Equity LLC’s Business Services: Services, Assets; Owners.
Pages 4 - 6
Item 5. Fees Compensation: How Emerson Equity LLC is compensated; fee schedules.
Pages 6 - 9
Item 6. Performance Based Fees and Side by Side Management:
Page 9
Item 7. Types of Clients: The types of client services; account requirements.
Page 9
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss:
Pages 9 - 14
Caution: Investing in securities involves risk of loss.
Item 9. Disciplinary Information: Legal or disciplinary events relating to Emerson
Equity LLC to evaluate the integrity of the firm and/or its management persons.
Pages 14
Item 10. Other Financial Industry Activities and Affiliates: Possible conflicts of
Interest and how they are addressed.
Pages 14 - 16
Item 11. Code of Ethics: Items A through D - Summary; Interest in client transactions.
Pages 16 - 17
Item 12. Brokerage Practices: How we select a broker; “soft dollars”.
Pages 17 - 18
Item 13. Reviews of Accounts & Reports to Clients:
Page 18 - 19
Item 14. Client Referral sand Other Compensation: Solicitors, etc.
Pages 19
Item 15. Custody:
Page 19
Item 16. Investment Discretion:
Pages 19 - 20
Item 17. Voting Client Securities: Proxy voting practices.
Page 20
Item 18. Financial Information: Disclosure of material financial information.
Page 20 - 21
Item 19. State registered investment advisers: Requirements.
Page 21
Part 2B Brochure Supplement
Page 22
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2A: Brochure: Items 4 – 18:
Item 4. Emerson Equity LLC’s (or “Emerson Equity”, “the firm”, or “the Adviser”) Business:
4. A. Emerson Equity LLC is a California limited liability company [IRS EIN 74-3109983] that registered to do business
as an investment Advisory firm on March 5, 2004. Note: The use of the phrase “registered investment adviser” or
the term “registered” do not imply a certain level of skill or training. The firm’s Managing Member and Chief
Compliance Officer is Dominic Baldini. The firm is dually registered as a broker-dealer, as well as being an investment
Advisory firm. The firm is licensed to sell insurance and is a registered securities broker-dealer as well as a registered
investment Adviser. Approximately 5% of the firm's time is expected to be spent on insurance activities, 85% on
brokerage activities, and 10% on investment Advisory activities.
While the Adviser has not formalized minimum standards of education and background for persons who represent
it in providing investment advice to clients, generally those persons are college graduates with at least three years
of business experience in the securities industry or other fields complementing their professional activities.
Normal business hours are from 6:00 AM TO 5:00 PM (Pacific Time)
4.B. Emerson Equity offers the following services:
Financial Planning
Portfolio Management and consulting for individuals, businesses and institutional clients
Insurance consulting
Portfolio Evaluation Services
Seminars
•
•
•
•
•
• Referrals to other investment advisers
• Management of Private Placement Life Insurance / Insurance Dedicated Funds (Single Investor Private Funds)
For certain clients, the Adviser provides various types of financial planning, such as estate planning, retirement
planning, investment planning, business succession planning, executive compensation planning, executive financial
services and deferred compensation planning.
Financial Planning, Portfolio Management, and Insurance Consulting:
The Adviser supervises and directs the investments of its clients in accordance with the investment
profile the client has communicated to the Adviser. The Adviser renders to the client a quarterly
inventory report.
In providing investment Advisory services, the sole standard of care of Adviser is to act with the care,
skill, prudence and diligence under the circumstances then prevailing that a prudent Adviser in a
fiduciary capacity and familiar with such matters would use in the conduct of an enterprise of a like
character and with like aims. The Adviser does not assume responsibility for the accuracy of information
furnished by any third party to the client.
Clients may or may not make investment and insurance applications at the time of a plan’s presentation.
Emerson Equity does not obligate any client to implement any recommendation or suggestion made by
the Adviser or to make any transaction through the Adviser or persons associated with the Adviser or
through any other particular broker-dealer.
The Adviser’s representative, in some instances, discusses interests in limited partnerships; investing
in equipment leasing; private capital such as private equity and real estate limited partnerships, LLCs,
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corporations, separate accounts, and limited partnerships investing in private equity funds; hedge
funds and limited partnerships investing in hedge funds (collectively, “Private Placements”). Though
the Adviser’s representatives recommend Private Placements where they are deemed appropriate for
the client’s portfolio, assets placed in these securities are not included as billable assets for purposes
of calculating Advisory fees. However, where the Adviser’s representative is also associated as a
registered representative of a broker-dealer, the Adviser’s representative receives a commission for
the sale of Private Placements. As such, there exists an inherent conflict of interest in recommending
such securities. We address this conflict by disclosing it here, as well as disclosing any such
commissions in conjunction with the sale of any such Private Placements. As discussed with other
investment recommendations, Emerson Equity does not obligate any client to implement any
recommendation or suggestion made by the Adviser or to make any transaction through the Adviser
or persons associated with the Adviser or through any other particular broker-dealer.
In some instances, the Adviser may recommend or you may seek utilizing your investments as
collateral to obtain a loan. We facilitate this through the Intermediary Loan Program provided
through Goldman Sachs Bank USA.
Additionally, the Adviser offers access to a Concentrated Stock Hedging & Monetization Program
using over-the-counter derivative transactions such as collars, covered calls, and prepaid variable
forwards executed with unaffiliated counterparties such as Goldman Sachs & Co. LLC. These
transactions are bilateral, involve pledged collateral, and entail risks including counterparty, collateral,
and tax risks. The Adviser does not act as counterparty, principal, or agent and does not provide tax or
legal advice.
If the client chooses to purchase a recommended product through Emerson Equity in its capacity as a
broker-dealer, the firm or persons associated with the firm will charge a fee on the transaction that is
equal to the ticket charge assessed by the Custodian or Executing Broker for that product, just as if the
client had purchased the product through someone else. This fee is not used to compensate Emerson
Equity or your Adviser.
Portfolio Evaluation Services
In certain instances, Adviser also provide clients with Portfolio Evaluation Services, which provides clients with
information to assess their portfolio performance with features such as tax lot reporting, realized and unrealized
gains and losses, performance measurement, and cash flow projections
Seminars
Emerson Equity also provides seminars to individuals or to groups of employees, associates and other organized
groups. The investment information our firm provides with this service is not intended to meet the objectives of
each individual client.
Referral to Other Investment Advisers
The Adviser, in some instances, recommends a third party investment Adviser to perform investment Advisory
services on behalf of the client. Adviser receives a percentage of the Advisory fee charged to the client by the third
party investment Adviser.
Management of Private Placement Life Insurance / Insurance Dedicated Funds (Single Investor Private Funds)
For certain accredited investors, the Adviser recommends the use of Private Placement Life Insurance. These
assets are single investor private funds (Insurance Dedicated Funds) into which the cash value of an insurance
policy of a single investor is placed. The fund itself is structured by the issuing insurance company. Once
structured and funded, the Adviser manages the underlying assets in the fund according to the investment
objectives identified by the fund documents. Adviser receives a referral fee from the issuing insurance company
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(this fee is paid by the insurance company, and it does not come from fund assets), as well as an ongoing asset
management fee as compensation for the management of the underlying assets in the fund (this management fee
is paid from fund assets).
4.C. Do we tailor our Advisory services to a client’s individual needs and how do we do so? Can clients impose
restrictions on investing in certain securities or types of securities?
By their nature, all of our investment Advisory services must be based on each client’s individual needs to have any
useful validity. As a fiduciary, an investment adviser is to make only those recommendations that demonstrably are
in the client’s own best interests, which means that they, too, must be based on an individual’s stated and/ or
established needs, goals, risk tolerance and investment time horizon. The firm seeks to establish this personal
dimension through a careful, fact-finding interview and discussions with each client.
Clients may impose reasonable restrictions on the adviser’s discretion to invest in certain securities or types of
securities if a client provides clear, written directions to that effect. Clients may opt to have their account managed
on a non-discretionary basis. The client allows the power of discretion to an adviser by means of a limited power of
attorney included as part of the advisory contract, which the client may revoke at any time. Where the account is
managed on a discretionary basis, the Adviser’s representative makes investment determinations and act upon such
determinations with respect to the assets in the account without further approval from the client, subject to any
restrictions placed on the account. Discretion does not allow the Adviser’s representative to withdraw funds,
transfer funds, or place assets in certain classes of securities (e.g., private placements). In the event the client
chooses to have the account managed on a non-discretionary basis, the adviser contacts the client to request
approval for each transaction effected for the account.
A client’s ability to impose restrictions on any third party investment adviser’s discretion occurs at the beginning of
the process at which time a client accepts or chooses not to engage the recommended adviser(s). Clients may
withdraw from the adviser(s) at any time as well, subject to the terms and conditions of the third party adviser’s
advisory agreement.
4.D. Do we participate in a wrap fee program providing portfolio management services? No, we do not.
4.E. As of 12.31.2024, the firm managed assets of $327,937,700 in a continuous and regular manner. Accounts are
discretionary and non-discretionary.
Item 5. Fees and Compensation: How Emerson Equity is compensated.
5.A. Fees are negotiable.
Financial Plans
The planner estimates the fee for preparing the plan, based on the complexity and amount of the work to be
accomplished. In all cases the client can accept or reject the estimate or fee for the plan before any work is
undertaken on the client’s behalf. At times, Adviser consults other professionals as necessary in working for the
client, with the client's prior approval.
For certain clients the Adviser prepares a financial plan for a flat fee which typically ranges from $1,500 to $75,000
or more, plus expenses. Payment is due upon delivery of the financial plan. If additional work becomes necessary,
the planner contacts the client for approval of the amount before further work is undertaken.
For certain clients, financial plans are prepared at an hourly rate of $75 to $250 plus expenses. The planner presents
the client with a proposed total fee for preparing the plan before work is begun. In the event that we determine the
cost is higher than the original agreement, the Adviser representative revisits with the client in order to sign a new
agreement. Payment is due upon receipt of the Adviser's invoice at the completion of the plan.
Investment portfolio management fees
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The Adviser calculates and bills its portfolio management fees at the end of each fiscal quarter, charging for services
during the last quarter.
The Adviser's current fees are based on the value of the account at the close of the last business day of the quarter,
and are charged at a rate of:
•
•
2.5% for those accounts with assets of $1 million and under, and
2.25% for accounts with assets in excess of $1 million.
Note: Loans received through the Intermediary Loan Program through Goldman Sachs Bank USA are not included in
your asset management fee, however, the assets used to collateralize such loans are still included in the asset
management fee calculation.
In addition to the above fees, the Advisor, as a registered Broker-Dealer, also receives 12b-1 fees for certain mutual
fund transactions. See section 5.E of this document for additional information regarding 12b-1 fees paid to Emerson
Equity.
Clients may opt to pay a flat fee for portfolio management services. The Adviser and the client negotiate the flat fee.
Either party may terminate a contract by giving written notice to the other delivered either personally or by mail.
The Adviser may not assign the agreement without the full knowledge and prior written consent of the client.
The rates set forth above are general rates for Adviser and are not necessarily the rate being charged to your account.
Some states take the position that an annual fee of 2% or greater of assets under management is generally higher
than the industry norm. In those instances, in which a client is charged 2% or higher, the Adviser believes that this
fee is based on its experience and skill. Similar services are available for a lower fee from other advisers.
Insurance Consulting
Emerson Equity’s adviser representatives, upon a client’s request, perform insurance consulting at an hourly rate.
This rate varies depending upon the client’s needs and the complexity of the review. The adviser representative
presents the client with a proposed total fee for the consultation before work is begun. In the event that we
determine the cost is higher than the original agreement, the Adviser representative revisits with the client in order
to sign a new agreement. Payment is due upon receipt of the Adviser's invoice at the completion of the consultation.
This fee is charged separately from advisory fees for managed assets. As part of this service, the adviser
representatives will review the client’s current insurance policies, as well as the client’s needs as outlined in the
investment profile to determine where there may be gaps in coverage or options available that will better suit the
client’s needs. As with all Emerson Equity advisory services, recommendations will only be made if they are in the
client’s best interest. The fact that this service results in fees paid to Emerson and the adviser representative creates
an inherent conflict of interest. We address that conflict by providing disclosure through this document, as well as
discussing the additional fees with the client and receiving written confirmation of their understanding and
agreement to the fees prior to providing the service.
With respect to any recommended product or strategy, the client always has the right to decide to act on the
recommendations of the Adviser, and, if they do decide to act, they always have the right to do so with a professional
of their choosing.
Portfolio Evaluation Services
Emerson Equity representatives provide portfolio evaluation services on a flat-fee basis. While this fee varies based
upon the complexity of the review and services requested, it typically approximates $1,500.
Seminars
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Emerson Equity representatives hold seminars on a negotiated fee basis, either as a flat amount per attendee, or
flat fee for a group of attendees. Fees are due upon completion of the seminar, and are the responsibility of the
attendee(s).
Third Party Investment Advisers’ Programs
In some instances, Emerson Equity’s representative recommends a suitable third party investment Adviser to
perform investment management services on behalf of the client. Emerson Equity receives a percentage of the
Advisory fee the client pays to the third party investment Adviser. This advisory fee varies, but presently is up to
2%. This fee varies by third party investment adviser, but it is always disclosed to the client prior to or concurrently
with the client’s engagement of the third party adviser.
Management of Private Placement Life Insurance / Insurance Dedicated Funds (Single Investor Private Funds)
For certain accredited investors, the Adviser recommends the use of Private Placement Life Insurance. Adviser
receives a referral fee from the issuing insurance company (this fee is paid by the insurance company, and it does
not come from fund assets), as well as an ongoing asset management fee as compensation for the management of
the underlying assets in the fund (this management fee is paid from fund assets). The referral fee (paid by the
insurance company) is 1% of the value of the assets placed in the fund and .15% per annum on the net cash value
of the policy. The ongoing management fee (paid by the assets of the fund) is negotiated with the client on a case-
by-case basis, but is typically either a flat fee ranging from $25,000-$50,000 per annum charged quarterly, in
advance, or a percentage fee up to 0.5% annually, capped at $50,000 per annum, charged quarterly (0.125%), in
advance. The calculation of the percentage fee to be charged is based on the value of the fund assets at the end of
the last business day of the preceding quarter. Both the referral fee and the ongoing management fee represent a
conflict of interest in the recommendation of Private Placement Life Insurance products. We address this conflict
through disclosure in this document, disclosure of the ongoing management fee in the fund documents, and a
general prohibition on such recommendations where it is not in the best interest of the client.
5.B. Disclosure: Emerson Equity bills its clients for the incurred Advisory fees by denoting the fee calculation in
the advisory agreement and obtaining each client’s signed permission to deduct the Advisory fees from the
client’s account held by the Custodian. A detailed statement for these fees will also be delivered to the client by
the Custodian. In limited instances, clients may select an alternative method of billing.
Adviser bills portfolio management fees each quarter, in arrears. Consulting fees are billed monthly.
In most instances, Adviser utilizes direct withdrawals of Advisory fees from client accounts. This practice, called
“direct billing,” requires our firm to obtain a client’s prior, written permission to deduct our fees directly from the
client’s account held by the Custodian. The Custodian provides each client with an account statement no less
frequently than quarterly. You should review these account statements promptly, and contact Emerson Equity
and/or the Custodian immediately in the event of a discrepancy.
The statement from the custodian details the assets held on the client’s behalf and the fees that the Custodian
deducts from the account to pay Adviser.
5.C. Disclosure: Other types of fees or expenses clients pay in connection with services provided by Emerson Equity:
Clients should be aware that opening an investment account carries with it costs beyond the Advisory
fee(s) Emerson Equity charges. When placing a transaction order to buy or sell securities, Advisory clients have to
pay any or all of the following charges assessed by broker-dealers and/or product sponsors with respect to client
accounts, in addition to the Advisory fees charged by Adviser (i.e., the below fees do not offset advisory fees).
• Brokerage commissions
• Custodian Fees
•
•
•
Postage Charges
Processing Charges
Ticket Charges
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Early Surrender
Transfer fees and administrative fees for investments in mutual funds
12b-1 fees and other marketing fees paid to a broker dealer by mutual funds
•
•
•
• Account maintenance fees charged by a broker dealer for an account, especially if inactive.
We direct clients to this brochure’s Item 12 for further discussion of brokerage costs.
5.D. Disclosure: Do clients pay fees in advance? How may a client obtain a refund of a pre-paid fee if the contract
is terminated prior to a billed period’s end? How will the amount of the refund be determined?
Financial plans
Either party may terminate a contract by providing written notice to the other delivered either personally or by mail.
Clients may cancel at any time, but the firm charges for the time already expended on the plan and for all out-of-
pocket expenses pursuant to the agreement provided for in section 5.A., above. Upon termination, Adviser
summarizes all work done, and client shall have access to the work done up to that point. Client is responsible for
fees for the work done and Adviser's expenses incurred on client's behalf and payment are due upon receipt of
Adviser's invoice.
Portfolio Management and Consulting
The firm charges its portfolio fees in arrears and prorates the fee for the actual time period during which the firm
provided services. The firm prorates the fee for termination prior to a quarter’s end. Any earned unpaid fees are
charged based on the early termination. Since the Advisory fees are paid in arrears, no refunds to clients for early
terminations are required. In limited instances, Adviser and clients may agree on an alternative method of billing.
Management of Private Placement Life Insurance / Insurance Dedicated Funds (Single Investor Private Funds)
Referral fees for Private Placement Life Insurance products are paid by the issuing insurance company, and they
do not come from fund assets. As such, these funds are never charged or refunded to the client. Ongoing
management fees for Private Placement Life Insurance products, however, are charged to fund assets in advance.
In the event that advisory services are terminated prior to the end of a quarter, the Adviser will calculate the
prorated balance of advisory fees remaining in the quarter. That calculation will be based upon the remaining
number of days in the quarter beginning with the first day following receipt of notification from the client that
they wish to terminate advisory services, or, if terminated by the Adviser, the date on which notification is issued
to the client by the Adviser. The Adviser will automatically issue the pro-rated refund by check (or, at the client
request, by wire) to the address on file within 10 business days.
5.E. Disclosure: Does the firm or any of its supervised persons 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?
Yes. Several Emerson Equity Advisory representatives are also registered representatives of the firm as broker
dealer agents. In that capacity, they earn the 12(b)-1 fees associated with any mutual funds in which they invest a
client. Emerson Equity LLC requires its Advisers to, at all times, act in the best interest of the client. As such,
Emerson Equity only allows its Advisers to recommend mutual fund shares that pay 12b-1 fees once the Adviser
has made a good faith effort to determine that such mutual fund shares are in your best interest despite such
additional compensation.
Disclosure 5.E.1. Whenever an investment Advisory firm’s representatives earns a commission, or mutual fund
management 12b-1 fees, or other forms of sales charges in their capacity as the registered representatives of a
broker-dealer, that arrangement creates an incentive to recommend those sales and, as a consequence, an inherent
conflict of interest. An Adviser is a fiduciary who is required to make only those recommendations for a client that
solely are in the client’s own best interest, uninfluenced by any calculation of personal gain.
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Our firm addresses this conflict of interest by informing clients of the conflict in this disclosure brochure.
Transactions are reviewed on a daily basis.
We do not normally reduce our Advisory fees to offset ticket charges or 12b-1 fees; there are no markups. The firm
keeps ticket charges at a nominal level. Ticket charges are used to offset those charges assessed by the Custodian
or Executing Broker-Dealer, and they are not used to compensate Emerson Equity or its Advisers.
With respect to any recommended product or strategy, the client always has the right to decide to act on the
recommendations of the Adviser, and, if they do decide to act, they always have the right to do so with a
professional of their choosing.
Disclosure 5.E.2. Clients always have the option to purchase through unaffiliated broker-dealers and their agents
those investment products our firm recommends.
Disclosure 5.E.3 Emerson Equity receives the majority of its revenue from commissions and other sales-based
compensation. The largest part of our firm’s income derives from brokerage business.
Disclosure 5.E.4. Do we charge Advisory fees in addition to commissions or markups? We do, of course, charge
Advisory fees. That is how most investment advisers perform business. Our investment Advisory firm is also a
broker dealer and therefore does receive a commission on non-discretionary trades. Additionally, where the
Custodian or Executing Broker-Dealer charges a ticket charge, we assess an equivalent charge on the transaction to
cover that ticket charge. This charge is merely a reimbursement and is not used to compensate the firm nor your
Adviser.
Other disclosures for this section: Our firm does recommend mutual funds to our clients. Those recommendations
are “no-load” funds, which impose no commission or sales charge (“load”) on the shareholder.
Item 6. Performance-Based Fees and Side-By-Side Management:
Does our firm charge performance-based fees [fees based on a portfolio’s increase in asset value]?
No, it does not.
Does our firm have a supervised person who manages an account that pays performance fees?
No, it does not.
Item 7. Types of Clients.
Typically, our clients include high net worth and other individuals, corporations and other businesses, trusts, and
pension and profit-sharing plan participants. We are prepared to provide services to charitable organizations and
estates as well. Emerson Equity does not require a minimum account size for its Advisory services, although some
third party Advisory investment programs do.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss.
8A. An adviser must describe its methods of analysis and investment strategies used in formulating its investment
advice. It must explain in detail any unusual risks.
Caution: Investing in securities involves risk of loss.
The Adviser utilizes information provided by the client in developing the investor profile to recommend the
appropriate strategy for the client. Strategies employed by the firm generally adhere to one of the following
categories based upon the individual client’s investor profile:
Preservation of Capital
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Preservation and Income
Income
Modest Growth and Income
Growth
Aggressive Growth
Regardless of the strategy, the Adviser generally employs one or more analytical methods, including charting,
cyclical, fundamental and/ or technical analysis in formulating investment advice.
Charting: Charting includes a variety of means of analysis that correlate charts, graphs, and similar market
information to detect patterns that are judged to be predictable, to reoccur in essentially the same way, given the
same chartable factors or relationships among factors. It seeks to predict trends and notice variations in those
trends, using various calculated averages.
Problems encountered using a charting analysis.
Charting assumes:
1) an accurate correspondence between real events and the factors charted as selected; and
2) and that patterns can be detected in such charts such that they are recognizable in advance,
predictable as drawn from recurring and therefore essentially mechanistic financial events.
It is a complicated theory. It depends upon a basic assumption that the fundamental financial influences are not
radically different in the time periods considered. That assumption is a concept that recently has been questioned
on a number of levels.
Particular stocks often diverge from the market/ sector averages radically. Charting therefore often needs to be
paired with another form of analysis such as fundamental or technical analyses in order to look more closely at
particular securities.
The time period most suitable for use in charting analyses is dependent upon the investor’s holding period, portfolio
structure, and other factors. The choice of relevant segments of performance over time and the understanding of
their place in mapping the forces within the larger time period framework is another consideration. Time spent using
one analytical method may compete with other analytical methods which might have proven more useful and
profitable.
Cyclical – This form of analysis classifies sector types of stock and possibly specific stocks with regard to their relation
to recurring up and down business cycles and/ or market movements.
Certain kinds of stock show marked tendencies to mirror these larger economic movements, either directly or
inversely. Automobile industry stocks, housing stocks, and many others belong to these groups. Others, such as food-
related stocks, have little or no relation to these cyclical economic movements. It is important for the analyst using
cyclical predictors to have a good understanding of how certain industries relate to the overall economy and any
verifiable changes occurring within the system, to ascertain which business sectors may be affected and how greatly
by economic changes.
Risks inherent in using a cyclical method of analysis: The analysis is applied to limited kinds of stocks, which either
could limit a portfolio or require other forms of investing whose analyses would then need to be related to and
integrated with the concepts and investment goals inherent in a cyclical view.
Understanding business cycles is a complicated endeavor at the least.
The time involved in these cycles is generally longer historical periods whose effectiveness can easily be eclipsed by
other forms of market action. Changes in the economy vary in the magnitude of their cyclical effects from period to
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period.
Deciding when to enter into a predicted cycle and when to leave can require very careful monitoring; demand for
certain cyclical industry items are not always predictable if a significant portion of consumption is from certain
foreign purchasers, the Chinese Peoples Republic, for example. Time spent using one analytical method may
compete with other analytical methods that might have proven more useful and profitable.
Fundamental Analysis – Called the “bottom-up” approach to investing, a fundamental analysis seeks an in-depth
understanding of a specific firm/ company to evaluate its intrinsic value and its future prospects before investing in
its stock. Such an analysis studies the firm’s management, its debt, equity and cash flow, history of financial
performance/ growth, dividend payout percentages, its products, operating efficiency and marketing structures,
among other factors. The firm’s balance sheet and income statement are two key sources of information about the
firm.
Fundamental Analysis compares a firm’s stock price with its earnings per share and its net earnings to its gross
revenues and compare both with the averages for that industry sector. The ratio of current liabilities to current
assets is another important element of this form of evaluation. A central focus is deciding whether the stock is
overvalued or undervalued.
As a term in large-scale economics, a fundamental analysis studies gross national product, inflation and interest
rates, trade and unemployment trends, consumer confidence, savings and spending patterns and inventories in
order to predict the larger movements of national and international economies. These larger concerns greatly
influence the elements considered in a fundamental analysis of any given company.
Risks inherent in using a fundamental analysis: The factors involved can require time-consuming study that can fall
behind the need to make decisions, if such factors begin to change rapidly. Few of the numbers are absolutes; many
are relative to other factors or industry sector information. Most require intelligent judgment and experience to be
applied meaningfully to stock values.
Fundamental analysis places value on the financial structure and health of the firm to be invested in. These factors
at times are of little or no interest to the market place, such that the stock prices for very sound companies may
wither when investors look to other reasons and areas for investing.
For a relatively short time period, a firm can falsify facts to hide poor performance or a fragile financial situation. The
independence of balance sheets and other reports’ numerical information from such possible manipulation may not
be readily verifiable.
Additionally, time spent using any one analytical method may compete with other analytical methods that might
have proven more useful and profitable.
Technical – Technical Analysis is, together with fundamental analysis, one of the two major schools of stock market
study. This form of value analysis focuses on patterns of volume and price fluctuations for a given stock as compared
to the activity of the larger, general market(s) indicators. Securities are evaluated for purchase or sale based on an
analysis of market statistics such as volume and prices over time as seen on charts, etc. that are believed to establish
relational patterns that can predict future movements in the markets.
This relative comparison has little or no concern for any company’s fundamental structure, production or worth.
Market indicators kept in view include volume and direction of market activity, as indicators of supply and demand
for securities, often using one or more established index/indices, such as the NASDAQ, S&P 500, and the Dow Jones
Industrial Average. Trends and Penetrations (e.g. of previous “highs”) are another type of indicator used. The
patterns discerned, often using charts for a quick grasp of the relationship of various factors, are used to predict
future market moves and their effects on stocks in general and/ or on particular sectors of the market.
Problems encountered using a technical analysis: Technical analysis purports to see patterns deemed repeatable in
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similar market conditions. Market conditions consist of many factors any one of which is capable of altering the
outcome of an otherwise very similar situation. No one indicator is absolutely reliable, and multiple indicators are
just as likely to complicate understanding and evaluation as much as or more than it allows deeper insight into the
market’s mechanics.
The understandings offered clients in explanation tend to use generic Technical Analysis, while the working concepts
that are derived from those basics and modified by experience and a firm’s emphasis may well be hidden in part or
completely as proprietary strategy /strategies that may let one Adviser or market participant outperform another.
Technical analysis assumes that all the market factors are known to and considered by all the market’s
participants, although, in fact, the market can act in highly partial and even apparently irrational ways. A market
termed “dynamic” indicates a sense that the underlying causal relationships may be shifting.
In formulating our investment advice, the firm uses research prepared by others, corporate rating services, annual
reports, prospectuses, and filings with the SEC, and company press releases.
Third Party Money Managers
In some instances, the Adviser recommends a third party investment Adviser to perform investment Advisory
services on behalf of the client. The Adviser receives a percentage of the Advisory fee charged to the client by the
third party investment Adviser. In such instances, Emerson Equity introduces clients to third party investment
Advisers who provide discretionary management of individual portfolios of equity and/or fixed income securities.
Risks in using these methods and strategies: As the managers’ strategies and methods vary widely, they include the
risks noted above in a fundamental analysis or others specific to their methods. None is a proven, absolutely sure
means of obtaining positive results. There is always a risk-return relationship - the greater the chance of a higher
return on an investment, the higher the risk of loss as well.
B. An Adviser must explain the material risks involved in frequent trading if its strategy involves frequent trading of
securities. An Adviser must explain how frequent trading can affect performance.
The firm’s trading strategies include holding for the long term purchases (a year or more), short-term purchases
(sold within a year), trading (securities sold within 30 days), short sales, margin transactions and option writing
(limited to short puts, long puts, and covered calls). These strategies come with significant risks, and they are only
utilized when they are determined to be in the best interest of the client:
Long term purchases: Loss of value, including some or all principal invested
Short term purchases: Loss of value, including some or all principal invested; short term gains taxes
Trading: Loss of value, including some or all principal invested; short term gains taxes; reduction of assets
through transaction fees
Short sales: Loss potential is theoretically unlimited in the event of a price increase on the shorted security;
often include higher transaction costs; carry costs will reduce returns
Margin transactions: Potential for loss of more than the invested principal; often include higher transaction
costs; carry costs will reduce returns
Options:
o With respect to short puts, there is a risk that you will be required to purchase the stock at the strike
price, resulting in potentially significant losses, as you would purchase the stock potentially well above
the market price.
o With respect to long puts and covered calls, there is a risk of loss of invested principal (i.e., the cost of
the options contract) in the event the option expires unexercised
What is regarded as “frequent trading” varies according to:
•
the client and the strategy for that client’s specific account;
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• one client may have multiple accounts that apply different strategies;
•
to the type of security or relative mix of securities involved; and
•
and to the current nature of the market.
Margin accounts require deposits by 10 am of the morning following the margin call, and options have an expiration
date, after which the option itself is worthless.
All these tactics are intended to enhance the portfolio’s value and ability to meet a client’s stated goals. All trades
add some costs to be deducted from a client’s account and could reduce the overall return or growth in a client’s
account, if carefully measured against what its value would have been had the adviser not placed the transactions.
The third party strategists review portfolios on a regular basis to rebalance them if needed in order to maintain the
agreed-upon weighting of asset classes. All trading adds costs against an account’s performance; frequent trading
increases those costs, reducing overall performance. To ascertain the effect, it is necessary to factor in the losses or
gains that would have proven true had the rebalancing not made the trades.
Derivative and OTC Strategy Risks:
Risks include counterparty default, illiquidity, collateral limitations, and potential constructive sale or straddle
treatment under U.S. tax law. OTC derivatives are not exchange-traded and may be illiquid or adjusted by
counterparties following corporate events. Clients must consult their tax and legal advisors prior to participation.
8.C. Do we recommend primarily a particular type of security? What are the material risks involved with that type
of security? Are those risks unusual or significant?
We are prepared to provide advice on most types of securities, including:
Equity Securities & Derivatives
Exchange-listed securities
Over-the-counter securities
Foreign issuers
Warrants
Options contracts on securities
Notable risks involved with this type of investment
Market fluctuations can bring losses, lower dividends
More susceptible to market fluctuations; higher risk
Not always under US financial reporting standards; higher risk
Same as OTC
Market fluctuations can bring losses; must make transaction to
realize profits; contracts expire worthless
Debt Securities
Corporate debt securities
Commercial Paper
Certificates of deposit
Municipal securities
US government securities
Notable risks involved with this type of investment
Same as exchange listed, corporate bonds involve credit risk
More susceptible to market fluctuations; higher risk of default
Limited liquidity
Same as exchange listed; It is possible that they can default
Returns can be low or even, rarely, negative. As hedge against
equity market risk, mirror them.
Investment company securities
Variable life insurance
Variable annuities
Mutual fund shares
Notable risks involved with this type of investment
Insurance company could go out of business; the value of the
subaccounts are subject to market fluctuation and loss
Same as variable life
Market fluctuations can bring losses; various fees
Interests in partnerships investing in
Notable risks involved with this type of investment
Historically prone to bubbles and after effects; may lose entire
Real estate, oil and gas,
private companies, other securities amount invested; not covered by SIPC; illiquid; highly unlikely to sell for
inherent value if forced to liquidate early. (Note: private placements are
not included in any billable asset calculations and thus not included in
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calculation of your advisory fee.)
Private Placement Life Insurance
& Annuities
Notable risks involved with this type of investment
Insurance company could go out of business; the value of the segregated
accounts are subject to losses in the underlying assets; underlying assets
include hedge funds and alternative assets, subject to significant risk of loss
of some or all of their value, as well as the illiquid nature of such products
Intermediary Loan Program (Offered
Notable risks and limitations involved with this type of investment
Through Goldman Sachs Bank USA) The bank is not obligated to approve the loan, and any loan approved may
be recalled for payment at any time; proceeds may not be used to buy
margin stocks; cannot be secured by IRAs or ERISA-covered accounts;
default on the loan results in foreclosure on assets used as collateral;
interest is assessed on the loan by the bank. (Note: while advisory fees are
still assessed against the collateral used to secure the loan, the loan itself is
not included in the calculation of your fee.)
Please see Item 12 for further description of our brokerage practices.
Item 9. Disciplinary Information:
Pursuant to subsection (C)(2) of this item, the firm and Dominic Baldini, a management person, per an Acceptance,
Waiver, and Consent (“AWC”) dated December 22, 2021, accepted and consented, without admitting or denying the
findings to the entry of findings by FINRA that the firm failed to establish, maintain, and enforce a supervisory system,
including written procedures, reasonably designed to achieve compliance with FINRA's suitability rule as it pertained
to short-term trading of mutual fund A and B shares from January, 2015 - June, 2020. Mr. Baldini was suspended in all
broker-dealer principal capacities for 20 business days and ordered to pay a fine of $5,000. The firm was fined
$60,000 and ordered to pay restitution in the amount of $2,013,071.20, the majority of which ($1,613,168.28) was
paid prior to the AWC. Both Mr. Baldini and the firm were credited by FINRA with extraordinary cooperation.
Neither the firm nor its associated persons have been the subject of any disciplinary actions requiring reporting
under this item, beyond that described above.
Item 10. Other Financial Industry Activities and Affiliations:
What material relationships does our firm or any of our management persons have with related financial industry
participants? What material conflicts of interest arise from these relationships and how are these conflicts
addressed?
A. Have we, or has any of our management persons, registered either as a broker-dealer or as the representative of
a broker-dealer? Or, do we or any management person have such a registration pending?
Yes. Emerson Equity LLC is an insurance agent and registered securities broker-dealer as well as a registered
investment Adviser. Approximately 5% of the firm's time is spent on insurance activities, 85% on brokerage activities,
and 10% on investment Advisory activities.
The Adviser at various times sells securities for or buy securities for investment Advisory clients or others as a broker-
dealer. As such the firm assesses a charge equal to the ticket charge assessed by the Custodian or Executing Broker-
Dealer on certain investments clients make. The products offered through this arrangement are the same as
investments offered currently by other brokerage firms, and commissions are those common in the industry. At
times, Emerson Equity recommends the purchase of securities or sale of securities in which the Adviser or persons
associated with it have a position. The Adviser or persons associated with the firm also purchase or sell securities
that have been recommended to clients.
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Any conflicts of interests are at all times spelled out in contracts with clients, and clients are informed that they
always have the right to decide to act on the financial planning recommendations of the Adviser, and, if they do
decide to act, they always have the right to do so with a professional of their choosing.
B. Have we, or has any of our management persons, registered as a futures commission merchant, commodity pool
operator, a commodity trading Adviser, or an associated person of any of these entities named here? Or, do we or
any management person have such a registration pending? No, none of these items apply to our firm.
C. Do we have any “related person” – a person or a firm that we control or that controls us through ownership or as
an officer – with whom we have a material relationship, any arrangement that causes a conflict of interest when
providing our clients with investment advice?
We do not believe that partial ownership by Oceanic Partners constitutes a conflict of interest when providing our
clients with investment advice. Tim Sullivan, President, is also Chief Executive Officer of Oceanic Partners, Inc. (CRD
# 174179), an exempt reporting Adviser in California. Oceanic advises a pooled investment vehicle (a private fund).
However, we do not recommend or place any Advisory client assets with any Oceanic sponsored or managed
offerings.
Emerson Equity does not have a related firm or person who is a:
• Municipal Securities Dealer
• Government Securities Dealer or Broker
• An investment company
• mutual fund,
• closed-end investment company
• unit investment trust
• private investment company
• offshore or other fund
• a futures commission merchant, commodity pool operator or commodity trading Adviser
• a bank or a thrift institution
• an accountant or accounting firm
• a lawyer or a law firm (Mr. Baldini is not an active attorney)
• a pension consultant
• a real estate broker or dealer
• a sponsor or syndicator or of limited partnerships (or equivalent), excluding pooled investment vehicles.
The firm’s representatives are in several instances also licensed to sell insurance through various insurance
companies, for which they receive the usual commission. The risk for a conflict of interest in any such arrangement
lies in the compensation to be received; it creates an incentive to recommend the service. We address this conflict
of interest by disclosing it here in this brochure. Further, the firm’s representatives are prohibited from
recommending any insurance products to Advisory clients unless they are in the client’s best interest.
With respect to any recommended product or strategy, the client always has the right to decide to act on the
recommendations of the Adviser, and, if they do decide to act, they always have the right to do so with a professional
of their choosing.
An Adviser’s related persons are: (1) the Adviser’s officers, partners, or directors (or any person performing similar
functions); (2) all persons directly or indirectly controlling, controlled by, or under common control with the
Adviser; (3) all of the Adviser’s current employees; and (4) any person providing investment advice on the adviser’s
behalf.
D. Do we recommend or select other investment advisers for our clients?
The Adviser, in some instances, recommends a third party investment Adviser to perform investment Advisory
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services on behalf of the client. Adviser receives a percentage of the Advisory fee charged to the client by the third
party investment Adviser. The compensation we receive, clients should note, creates an incentive to make the
recommendation and thereby an inherent conflict of interest. We address this conflict of interest by bringing it to
our clients’ attention in this disclosure brochure. Additionally, we inform clients that they always have the right to
decide whether or not to engage the recommended third party adviser.
The Adviser may recommend unaffiliated counterparties for derivative transactions but receives no compensation
from them. All such transactions are executed directly between the client and counterparty.
Do we have any other business relationships with these advisers that also could cause a conflict of interest and, if
“yes,” how do we address them? No, we do not.
Item 11. Code of Ethics: Advisory Persons’ own trading and possible personal interest in our clients’ trades.
A. As required by SEC rule 204A-1 or similar state rules our firm has adopted a Code of Ethics.
Our firm’s code of ethics states general standards of conduct for a fiduciary and establishes, among other
provisions, policies and procedures to monitor our associates’ investment activities. We review certain of our
associates’ trading activities and holdings to enforce the prohibition against using insider information. If you give
us a written request for one, we provide you, our client or prospective client, with a copy of our Code of Ethics.
Please note that using any insider information, information that is not readily available to all participants in the
securities markets (upon making a reasonable effort to obtain that information), for any person, ourselves or
relatives or clients or any other person, is strictly illegal and punishable by fines and imprisonment.
How our firm controls sensitive information:
Locked office doors after business hours
Fire prevention equipment
• Building security: security guard 24/7
•
• No computers are left unprotected in the office after hours, brokerage databases are password protected
•
• Office area under continual supervision during business hours
Steps the firm has taken to prevent employees from misusing any inside positions - because the firm is also a broker
dealer, the Chief Compliance Officer or Supervising Principal monitors all associates’ trades.
B. Does our firm or a related person recommend to our clients, or do we buy or sell for our clients’ accounts,
securities in which we or a related person has a material interest?
Our firm and/or its associates do:
• buy or sell for the firm or for themselves securities (other than shares of mutual funds) that we also
recommend to our Advisory clients;
• buy or sell for the firm or for themselves shares of mutual funds that we also recommend to our Advisory
•
•
•
clients;
recommend securities (or other investment products) to our Advisory clients in which our firm or any
person or other firm related to our firm has some other proprietary (ownership) or other financial
interest. [The Hedge Fund]
recommend purchase or sale of securities to Advisory clients for which our firm or any related person
has any other sales interest (other than the receipt of sales commissions as a broker or registered
representative of a broker-dealer)
invest or are permitted to invest in securities related to those we recommend to clients,
such as derivatives
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Our firm and its associates do not:
• buy securities for the firm or for themselves from Advisory clients (principal transactions);
•
sell securities the firm or its associates own to Advisory clients (principal transactions);
•
in their capacity as a broker/ dealer agent, transact purchases or sales of any client’s securities
directly to any other person (an “agency cross transaction” that side-steps using a securities market
place)
act as an investment adviser to an investment company that we recommend to our clients.
•
11.C. Personal Trading: Investing in the same or related securities.
Does our firm permit itself, its personnel, or a person related to our firm (by ownership or other forms of control)
to invest in the same securities that we recommend to our clients, or in securities that are related to those
securities, such as options or other derivatives?
Yes, we do allow it. As noted above in item 10. A., At times, Emerson Equity recommends the purchase of securities
or sale of securities in which the Adviser or persons associated with it have a position. The Adviser or persons
associated with the firm also purchases or sells securities that have been recommended to clients.
When our firm or its personnel buy or sell securities for their own accounts,
• we always place clients’ orders before our own; or
• we aggregate or “bunch” our orders with clients’ orders.
We enforce these guidelines by Principal reviews of associates’ trading activities.
The conflicts of interest that arise whenever we recommend, or, in our discretion, buy or sell for you a security that
we also buy or sell for ourselves are:
• using your order’s market effect to benefit ourselves (“front running”);
• using your order as “inside information” that would give us an unfair advantage in the markets to
•
benefit ourselves or any other person (which is an illegal act); and
gaining a lower brokerage cost for ourselves in bunching orders, which can create an incentive to
involve your account in that transaction.
Does any person in our firm participate in or have an interest in our clients’ transactions? How does such a person
participate or what is the interest and what conflicts of interest can that create? No. Though Tim Sullivan, President,
is also Chief Executive Officer of Oceanic Partners, Inc. (CRD # 174179), an exempt reporting Adviser in California,
which advises a pooled investment vehicle (a private fund), the Adviser does not recommend or invest Advisory
client assets in any offering sponsored or managed by Oceanic Partners, Inc.
11. D. Personal Trading: Investing in the same or related securities at the same time.
What specific conflicts do we have when our firm or a related person trades in the same securities at or about the
same time as it places trades for a client’s account? Our practice is to place clients’ trades first or to aggregate our
trades with clients’ trades.
Anyone in our firm might enter an order for her or his own account in the same security as an order for a client.
However, such transactions are only placed either after the client order or as part of the same lot. Note that these
restrictions are not applied to investments in mutual funds that are unaffiliated with our firm. Unaffiliated means a
mutual fund that we have not ourselves created or helped establish and/ or in some way act as the fund’s managers.
. Item 12. Brokerage Practices:
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A. Does our firm select a broker-dealer for you? On what basis do we do so? How do we determine the
reasonableness of the broker’s compensation (commission charges)?
Where deemed in the clients’ best interest we do recommend our own firm to be the broker-dealer for our clients’
transactions. We base our recommendation of our own broker-dealer for the level of commissions and the ease of
transmission of trading orders. An adviser has a duty to seek the best execution of trades for its clients, which
includes considerations in addition to the commission rate, however. We do not, however, select ourselves to be
the broker-dealer. The selection of the broker-dealer is the client’s.
12. A. 1. Research and other “Soft Dollar” benefits: Do we have any conflicts of interest such as receiving “soft
dollars” from the broker-dealer? No, Emerson Equity receives no soft dollars.
12.A. 2. Brokerage for client referrals:
Do we direct brokerage to a specific broker-dealer in return for client referrals either to our firm or to a related firm?
[Includes referrals from a BD or other third party.] No, we do not. [See 1A, Item 5]
12.A.3.
[a] Do we “routinely recommend, request or require” our clients to direct brokerage? Yes, we do routinely
recommend our firm to be the broker dealer; we do not, however, request or require our clients to use Emerson
Equity in that capacity. As noted below in Item 16: Discretion, the Adviser, in exercising discretionary authority,
normally determines which securities are bought and sold; the total amount of such purchases and sales and
whether a client's transactions should be combined with those of other clients and traded as a "block." Clients should
know that not all advisers do require directed brokerage.
Is the broker-dealer in question an affiliate of our firm or have some other economic relationship? Emerson Equity,
as previously stated, is registered both as an investment adviser and as a broker dealer. Yes. We inform our clients
here that such a relationship creates an inherent conflict of interest. By directing brokerage, we are not necessarily
able to achieve the most favorable execution for client transactions, at an increased cost to our clients than they
might have incurred with another broker-dealer.
The Adviser does not execute or clear OTC derivative transactions. All contracts are entered directly between the
client and third-party counterparties.
[b] Do we permit a client to direct brokerage to a specific broker-dealer? Yes. From time to time, a client may exercise
his right to direct Adviser to use a broker dealer of the client's choice. In the event that the client directs Adviser to
use a particular broker dealer, the Adviser is not necessarily able to negotiate commissions or obtain the best
execution. These circumstances sometimes cause a disparity in commission charges between the client and other
clients of the firm.
12.B. When we place orders with a broker/ dealer for our clients, do we aggregate or “bunch” your trade order with
orders for other clients? We do aggregate orders; in those instances, the firm applies benefits among the participants
according to their percentage of the order.
Item 13. Review of Accounts:
13.A. Does someone in our firm review your investment account portfolio and how often?
Emerson Equity performs monthly and quarterly reviews of securities positions and account activities; Additionally,
the firm reviews accounts in greater depth annually, depending on the size and complexity of the account. The
individual representative handling the account is the reviewer. The number of accounts assigned varies depending
on each Adviser. On a monthly basis, the Supervising Adviser also reviews a random sampling of accounts.
13.B. What factors might trigger a review in addition to our periodic reviews?
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Market or economic conditions could trigger more frequent reviews, as would the request of clients.
13.C. What regular reports do we or others provide you? Are they written reports? What do they contain?
Clients receive monthly and/or quarterly statements as well as annual statements from their custodial broker dealer.
In certain instances, Adviser also provide clients with Portfolio Evaluation Services, which provides clients with
information to assess their portfolio performance with features such as tax lot reporting, realized and unrealized
gains and losses, performance measurement, and cash flow projections. The Adviser renders to its portfolio
management clients a quarterly inventory report.
Item 14. Client Referrals and Other Compensation:
A. Does someone other than a client of our firm pay our firm or related persons, or otherwise provide some
economic benefit to our firm, for the investment advice we provide to our clients?
Yes. Advisory representatives who are also registered representatives of the related broker dealer receive 12(b)-1
fees if they place an Advisory client’s investments in mutual funds. The payment creates an incentive to recommend
such funds and thereby a conflict of interest. An investment adviser is to recommend to its clients only those
investments that are in the client’s own best interest, free of any taint of the influence that the prospect of additional
income exerts.
Yes, as noted above, when the Advisory representative also acts as the broker dealer agent for the purchase of
mutual funds, the mutual fund company pays that person a portion of the administration 12(b)-1 fees the client pays
to the mutual fund company. We address the conflict of interest for an Advisory representative in this situation by
disclosing it to our clients. The Advisory representative is prohibited from recommending any mutual fund company
transactions unless such recommendation is in the best interest of the client. Moreover, the client has the right to
decide to act on the recommendations of the Adviser, and, if they do decide to act, they always have the right to do
so with a professional of their choosing.
Yes. As noted above, when referring clients to a third party adviser or referring clients to an insurance company for
purposes of establishing a Private Placement Life Insurance policy, the Adviser and the Adviser representative
receive a referral fee. We address the conflict of interest for an Advisory representative in this situation by disclosing
it to our clients through this document. The Advisory representative is prohibited from making such referral
recommendations unless such recommendation is in the best interest of the client. Moreover, the client has the
right to decide to act on the recommendations of the Adviser, and, if they do decide to act, they always have the right
to do so with a professional of their choosing.
B. Does our firm or a firm related to us through some form of ownership pay someone, directly or indirectly, for
client referrals? No, we do not currently pay any solicitors; we may in the future. Adviser may in the future receive
referrals of clients from various persons ("solicitors"). These solicitors give clients so referred disclosure statement
in writing. The fee will not exceed 1.5% of the assets under management referred to Emerson by the solicitor,
prorated quarterly and based on the value of the assets at the end of the quarter, which is paid to the solicitor as
compensation for these referrals. This fee is calculated as a portion of the total advisory fees paid by the client to
Emerson Equity. Referred accounts do not pay more than the total fees shown on the fee schedule in Section 5.A. of
this Form ADV, Part 2A.
Item 15. Custody:
Does our firm have custody of your assets? The Adviser does not accept physical custody of any Advisory client’s
funds or securities. However, as noted above, Emerson Equity does bill its Advisory fees directly to the client’s
account held by the Custodian. This practice, called “direct billing,” is considered by regulators to be a form of
constructive custody that does not require annual audits. Direct billing also requires that the client receive at least
quarterly statements from the account Custodian, showing the Advisory fee.
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Who is/ are the qualified Custodian(s) of your assets’ account? Pershing LLC is the custodian unless otherwise
specifically directed by the Client to use a different custodian. At this time, Schwab and Interactive Brokers also
serve as the custodians for some client assets as a matter of convenience to those clients. The identity of the
custodian is disclosed as part of the advisory agreement between the Adviser and the client. In the case of assets
held directly with a product sponsor (e.g., mutual funds, private placement life insurance), the custodian of the
assets is the product sponsor/issuer.
The Custodian sends our clients at a minimum a quarterly account statement, monthly statements or confirmations
for any month in which there was trade transaction activity in the account. Quarterly statements will include a list
of all holdings held by the Custodian on the client’s behalf, as well as the amount of the advisory fee assessed as
denoted in your advisory agreement. NOTE: These statements should be reviewed carefully. Call the Adviser
promptly if there are any discrepancies in the Custodial statement. It is not the Custodian’s responsibility to ascertain
the accuracy of the calculation for fees subtracted from your account.
Securities pledged under derivative contracts may be held by the counterparty and may not appear on standard
custodian statements during the contract term.
Item 16. Investment Discretion:
A. Does our firm have discretionary authority over your assets? The Adviser does exercise discretion over its
clients’ accounts.
B. What limitations are there, or can you place, on our discretionary authority?
Suitability parameters, as the client and the adviser establish in the initial interview, are the overriding limitation on
any discretion. In exercising discretionary authority, the Adviser normally determines:
(1) which securities are bought and sold; and
(2) the total amount of such purchases and sales and whether a client's transactions should be combined with those
of other clients and traded as a "block."
If a client chooses to use Emerson Equity as the broker dealer, the firm provides the commission rate agreed to in
advance.
The firm gains discretionary authority over a client’s account only if and when that client signs a limited power of
attorney and contract specifically providing for discretion. A client may revoke that permission at any time by
written notice to the firm.
Neither insurance products, nor private placements can be purchased through discretion. Such products may only
be purchased with the client’s consent. Moreover, these products are not included in calculating your advisory fee.
However, your Adviser, in his/her role as an insurance and/or securities broker will receive a commission with
respect to transactions in these products. This commission represents an inherent conflict of interest. We address
this conflict through disclosure in this document, as well as through the brokerage commission schedule provided
to those clients who engage Emerson Equity as a broker-dealer. With respect to private placements, such
commissions are disclosed in the offering documents prior to the execution of any transaction. These products are
only recommended to the client when they are deemed in the client’s best interest.
Item 17. Voting Client Securities -proxy voting practices:
A. Does our firm have or will it accept authority to vote client securities?
For non-ERISA accounts, Adviser does not vote or take other action for securities in a client's account. The Custodian
or, the company sends proxies directly to the client, or the Adviser sends to the client any information and
documents the Adviser receives.
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For ERISA accounts, Adviser votes proxies for securities in a client's account and votes in a manner, which in the
Adviser's judgment, inures to the exclusive benefit of the client. A client may expressly retain the right to receive
proxy and related material, vote any proxies or take any action relating to investments in the client's account by
providing prior written notice to Adviser. To the extent that instructions regarding the voting of proxies are not
received, and as permitted by law, the Adviser complies with the rules of the New York Stock Exchange and the
Securities Exchange Commission and similar state statutes and rules relating to proxy voting.
B. This is our policy and our procedures - that we do not vote proxies for non-ERISA clients. We state this here in
these disclosures. Our firm urges our clients to read and participate in the voting process tied to the shares they own
in various companies as an excellent means for our clients to become familiar with those companies in which they
are invested.
Item 18. Financial Information:
18. A. Custody situations: Does our firm have custody of your funds or your securities investments?
• Do we require prepayment of a fee of $500 ($1200 for an SEC registrant) or more, 6 or more months in
advance of services? We do not.
• Do we practice “Direct Billing” (charging our fees to your account)? We do practice “direct billing” as
described above in Item 15: “Custody”
• Do we or someone in our firm act as the trustee for an Advisory client? No, we do not.
18. B. Financial difficulties: If our firm has discretionary authority over your assets [see Item 16] or custody of our
clients’ securities or funds, or require or solicit prepayment of fees of $500 or more), six or more months in advance,
then we must disclose if there is any financial condition reasonable likely to impair our firm’s ability to meet its
contractual commitments to its clients.
Does our firm have any financial condition that could reasonably seem likely to impair our ability to meet our
contractual commitments to you, our client? This question is important, especially if an investment adviser has
discretion, custody or both; if our financial condition were precarious, our clients would be exposed to increased
risks that we might not manage their assets properly, according to the SEC. Prepaid fees might not be refunded if
an Advisory firm were to cease being able to do business due to insolvency.
No, it does not. The firm has no financial difficulties as of the time of this ADV Part 2A; the firm undertakes to
inform clients if it were to have any threatening financial difficulties.
18. C. Has our firm been the subject of a bankruptcy petition during the last 10 years? No, it has not.
Item 19. Requirements for State Registered Investment Advisers:
19. A. The Managing Member of Emerson Equity LLC is Dominic Baldini. The education and business background
for Mr. Baldini is supplied on Form ADV Part 2B Brochure Supplement.
19. B. Information regarding any businesses in which Mr. Baldini is actively engaged (other than providing
investment advice) and the approximate time spent on that business is supplied elsewhere in the Form ADV (see
Item 10: Other Financial Industry Affiliations).
19. C. Neither Mr. Baldini nor any other supervised person are compensated for Advisory services with
performance-based fees.
19. D. There are no disciplinary events to disclose.
19. E. Emerson Equity LLC does not have any relationship with any issuer of securities.
22
Part 2B: The Brochure Supplement: Here we provide information about Advisory personnel on whom you
rely for investment advice. We must provide this supervised person’s supplement to you, our client initially
at or before the time when that specific supervised person begins to provide you with Advisory services.
Item 1. Cover Page.
This brochure supplement provides information about Advisory personnel that supplements the Emerson
Equity LLC brochure. You should have received a copy of that brochure. Please contact Mr. Baldini if you
did not receive Emerson Equity LLC’s brochure or if you have any questions about the contents of this
supplement. Additional information about Advisory personnel is available on the SEC’s website at
www.adviserinfo.sec.gov.
Dominic Baldini
Born 1965
CRD # 3082081
Item 2. Educational Background and Business Experience
Education: University of San Francisco, 1984-1988; BA in Business Administration and Finance, 1988; Golden Gate
University 1988-1991; JD Law 1991.
Business background: Managing Member LLC, Registered Principal, Options and Municipal Principal, FinOp,
Financial Adviser, for Emerson Equity LLC, 2004-present; Chief Executive Officer, Chief Compliance Officer, FinOp,
for SharesPost Financial Corporation, 2012 - 2015.
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Mr. Baldini:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes.
Are there events disclosed about this broker? Yes.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Baldini recommends a service to an Advisory client, and he himself is
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this conflict of interest by disclosing it to the firm’s
clients. The services that Mr. Baldini recommends include brokerage and insurance products.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Baldini receives 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his Advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he realizes.
Item 6. Supervision.
Mr. Baldini is his own supervisor. He maintains on file in the firm’s offices reports of his proprietary trading
activities and the formulation of his recommendations for the regulator to review at will. Mr. Baldini assigns the
reviews of his proprietary trading activities as an “access person” to another person, as noted in the firm’s Code
of Ethics.
23
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
24
Kristian Colvin
Born 1974
CRD # 2899449
Item 2. Educational Background and Business Experience:
Education: Westminster College, 1993-1998; BA in Accounting 1997; MBA in 1998.
Business background: Financial Consultant, Charles Schwab & Company, Inc., 1999-2009; Financial Consultant,
Emerson Equity LLC, 2009 – present.
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Kristian Colvin:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? No.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Colvin recommends a service to an Advisory client, and he himself is
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this conflict of interest by disclosing it to the firm’s
clients. The services that Mr. Colvin recommends include brokerage and insurance products.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Colvin receives 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his Advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he realizes.
Item 6. Supervision.
Mr. Baldini is Mr. Colvin’s supervisor. The firm maintains on file in its offices reports of the Advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
25
Dhruv Gupta
Born 1967
CRD #2671099
Item 2. Educational Background and Business Experience:
Education: California State University, Bachelor of Science in Business Administration, 1993; University of San
Francisco, Master of Business Administration, 2002.
Business background: LifeMark Securities Corp., Registered Representative, 2014 – 2017; Foresters Equity
Services, Inc., Investment Adviser and Registered Representative, 2017 – 2018; Creative Financial Designs, Inc.,
Investment Adviser and Registered Representative, 2018 – 2019; Essential Wealth Advisers LLC, Owner, 2015 –
Present; Haute Properties NV, Real Estate Agent, 2019 – Present; Emerson Equity LLC, Investment Adviser and
Registered Representative, 2019 – Present.
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Dhruv Gupta:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? No.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Gupta recommends a service to an Advisory client, and he himself is
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this conflict of interest by disclosing it to the firm’s
clients. The services that Mr. Gupta recommends include brokerage and insurance products.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Gupta receives 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his Advisory clients, that recommendation creates a
risk for a conflict of interest, due to the 12(b)-1 fees that he realizes.
Item 6. Supervision.
Sean Snyder is Ms. Gupta’s supervisor. The firm maintains on file in its offices reports of the Advisory
representative’s proprietary trading activities and the formulation of her recommendations for the regulator to
review at will.
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
26
Gregory Ritter
Born 1973
CRD # 3087358
Item 2. Educational Background and Business Experience:
Education: Ohio State University, 1991 - 1997; Family Financial Resource Management.
Business background: Chase Investment Services, 2005 - 2009, Financial Adviser; Family Financial of Central Ohio,
2010 to present, Managing Partner; Emerson Equity LLC, 2010 - present, Registered Representative and Financial
Adviser.
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Gregory Ritter:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? No.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Ritter recommends a service to an Advisory client, and he himself is the
paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a fiduciary
he must recommend only those services and products that are in a client’s own best interest, free of any influence
of possible gain for himself. The firm addresses this conflict of interest by disclosing it to the firm’s clients. The
services that Mr. Ritter recommends include brokerage and insurance products.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Ritter receives 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his Advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he realizes.
Item 6. Supervision.
Mr. Baldini is Mr. Ritter’s supervisor. The firm maintains on file in its offices reports of the Advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
27
Ryan Sherer
Born 1987
CRD #5952617
Item 2. Educational Background and Business Experience:
Education: Pace University, Bachelors of Business Administration, 2012.
Business Background: The Sherer Group, Member, 2014 – Present; Bank of America, N.A., Financial Adviser, 2013
– 2014; J.P. Turner & Company, LLC, Registered Representative, 2014 – 2015; SCF Securities, Inc., Registered
Representative, 2015 – 2019; SCF Investment Advisers, Inc., Investment Adviser, 2015 - 2019; Emerson Equity
LLC, Investment Adviser and Registered Representative, 2019 – Present.
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Ryan Sherer:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? No.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Sherer recommends a service to an Advisory client, and he himself is
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this conflict of interest by disclosing it to the firm’s
clients. The services that Mr. Sherer recommends include brokerage and insurance products.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Sherer receives 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his Advisory clients, that recommendation creates a
risk for a conflict of interest, due to the 12(b)-1 fees that he realizes.
Item 6. Supervision.
Mr. Baldini is Mr. Sherer’s supervisor. The firm maintains on file in its offices reports of the Advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
28
Timothy Sherer
Born 1948
CRD #833618
Item 2. Educational Background and Business Experience:
Education: Ohio University, Bachelor of Business Administration, 1970; Santa Clara University, Masters of
Business Administration, 1979.
Business Background: The Sherer Group, Managing Member, 2002 – Present; J.P. Turner & Company, LLC,
Registered Representative, 2007 – 2015; SCF Securities, Inc., Registered Representative, 2015 – 2019; SCF
Investment Advisers, Inc., Investment Adviser, 2015 - 2019; Emerson Equity LLC, Investment Adviser and
Registered Representative, 2019 – Present.
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Timothy Sherer:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? Yes, the details can be found on FINRA’s BrokerCheck system at
http://www.finra.org by utilizing the “Check the background of an investment professional” function.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Sherer recommends a service to an Advisory client, and he himself is
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this conflict of interest by disclosing it to the firm’s
clients. The services that Mr. Sherer recommends include brokerage and insurance products.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Sherer receives 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his Advisory clients, that recommendation creates a
risk for a conflict of interest, due to the 12(b)-1 fees that he realizes.
Item 6. Supervision.
Mr. Baldini is Mr. Sherer’s supervisor. The firm maintains on file in its offices reports of the Advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
29
Toni Sutherland
Born 1954
CRD #2729672
Item 2. Educational Background and Business Experience:
Education: University of California at San Diego, Bachelor of Arts Degree in Fine Art and Science 1979.
Business Background: Emerson Equity LLC - Registered Representative (RR) (March 2019 - Present); Investment
Adviser Representative (IAR) (March 2019 - Present); California Real Estate Agent, 2003 – Present;
Sandlapper Wealth Management, LLC, Registered Investment Adviser; Sandlapper Securities LLC, 2013 –
2019, Registered Representative; 2013 – 2019 Emerson Equity LLC, 2019 – Present, Registered Investment
Adviser and Registered Representative.
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Toni Sutherland:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? Yes, the details can be found on FINRA’s BrokerCheck system at
http://www.finra.org by utilizing the “Check the background of an investment professional” function.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Ms. Sutherland recommends a service to an Advisory client, and she herself
is the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary she must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for herself. The firm addresses this conflict of interest by disclosing it to the firm’s
clients. The services that Ms. Sutherland recommends include brokerage and insurance products.
Item 5. Additional Compensation.
As described in Part 2A, Ms. Sutherland receives 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If she recommends the purchase of mutual funds to her Advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that she realizes.
Item 6. Supervision.
Sean Snyder is Ms. Sutherland’s supervisor. The firm maintains on file in its offices reports of the Advisory
representative’s proprietary trading activities and the formulation of her recommendations for the regulator to
review at will.
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
30
Terry Tang
Born 1966
CRD #2625824
Item 2. Educational Background and Business Experience:
Education: University of California at Riverside, Bachelor of Arts and Business Economics, 1989.
Business Background: Financial West Group, Registered Representative, 2013 – 2017; Western International
Securities, Inc., Investment Adviser and Investment Adviser, 2018 – 2019; Southern California Wealth
Management Associates, LLC, Managing Member, 2014 – Present; Emerson Equity LLC, Investment Adviser and
Registered Representative, 2019 – Present.
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Terry Tang:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? Yes, the details can be found on FINRA’s BrokerCheck system at
http://www.finra.org by utilizing the “Check the background of an investment professional” function.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Tang recommends a service to an Advisory client, and he himself is the
paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this conflict of interest by disclosing it to the firm’s
clients. The services that Mr. Tang recommends include brokerage and insurance products.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Tang receives 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his Advisory clients, that recommendation creates a
risk for a conflict of interest, due to the 12(b)-1 fees that he realizes.
Item 6. Supervision.
Kevin Hickam is Mr. Tang’s supervisor. The firm maintains on file in its offices reports of the Advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
31
Jeff W. Webb
Born 1975
CRD #6486331
Item 2. Educational Background and Business Experience:
Education: Some College (approximately 2 years) Studies in Hydrological Engineering – No Degree
High School Diploma - 1993
Business background: Emerson Equity LLC, Registered Representative (May 2017 - Present) &
Investment Adviser Representative (August 2019 - Present); Kingstone Capital Partners Texas, LLC
(March 2017 – June 2019), Investment Adviser Representative; Mountain Financial, LLC (February
2006 – Present), President; Newport Coast Securities, Inc. (July 2015 - March 2017), Investment
Adviser Representative and Registered Representative
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Jeff Webb:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes. Mr. Webb has an
outstanding tax lien in the amount of $96,815.24.
Are there events disclosed about this broker? Yes. Mr. Webb has an outstanding tax lien in the
amount of $96,815.24.
Item 4. Other Business Activities.
As noted above in Part 2A, Mr. Webb is also engaged in securities activities as a broker dealer registered
representative of Emerson Equity LLC as well as an independent insurance agent through Mountain
Financial, LLC. In these roles, Mr. Webb recommends brokerage and insurance products. Whenever
Mr. Webb recommends a service to an Advisory client, and he receives compensation for that
recommended service, such a situation inherently creates a conflict of interest. As a fiduciary he must
recommend only those services and products that are in a client’s own best interest, free of any
influence of possible gain for himself. The firm addresses this conflict of interest by disclosing it to the
firm’s clients. Moreover, the client has the right to decide to act on the recommendations of the
Adviser, and, if they do decide to act, they always have the right to do so with a professional of their
choosing.
Item 5. Additional Compensation.
Other than the affiliations and activities disclosed in items 4, above, Mr. Webb does not receive any
additional compensation.
Item 6. Supervision.
Dominic Baldini is Mr. Webb’s supervisor. The firm maintains on file in its offices reports of the Advisory
representative’s proprietary trading activities and the formulation of his recommendations for the
regulator to review at will.
32
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
33
Scott M. Ozer
Born 1959
CRD # 3000966
Item 2. Educational Background and Business Experience:
Education: California State University, Northridge 1977-1981; Marketing
Business background:
Emerson Equity LLC – Registered Representative (RR) (Aug 2019 – Present)
Sandlapper Wealth Management, LLC – Investment Advisor Rep (IAR) (Jan 2015 – Aug. 2019)
Sandlapper Securities, LLC – Registered Representative (RR) (Nov 2013 – Aug. 2019)
Colony Park Financial Services, LLC (IAR) – (Jun. 2014 – Jan. 2015)
Sandlapper Wealth Management, LLC – (IAR) (Nov. 2013 – Jun. 2014)
Financial West Group (RR) – (Nov. 2002 – Feb. 2009)
Salomon Smith Barney Inc. (RR) – (Nov. 1992 – Sep. 2005)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Scott Ozer:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? Yes – 1 Final and 1 Pending. For more information,
please review Mr. Ozer’s BrokerCheck report located at
https://files.brokercheck.finra.org/individual/individual_1009252.pdf
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Ozer recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of
interest. As a fiduciary he must recommend only those services and products that are in a client’s own
best interest, free of any influence of possible gain for himself. The firm addresses this possible conflict
of interest by disclosing it to the firm’s clients. The services that Mr. Ozer may recommend include
brokerage and insurance products.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Ozer may receive 12(b)-1 fees from the administrative fees a client pays
to a mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that
recommendation creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Kevin Hickam is Mr. Ozer’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the
regulator to review at will.
34
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
35
John Hoffman
Born 1956
CRD #1582096
Item 2. Educational Background and Business Experience:
Education: B.A. in Economics; Carleton College 1978
Business background: Emerson Equity LLC, Registered Representative (January 2020 - Present) &
Investment Adviser Representative (March, 2020 - Present); Centaurus Financial, Investment Adviser
Representative and Registered Representative (July, 2014 – December, 2019)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding John Hoffman:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes, the details can be
found on the SEC’s Investment Adviser Public Disclosure system at https://adviserinfo.sec.gov/.
Are there events disclosed about this broker? Yes, the details can be found on FINRA’s BrokerCheck
system at https://brokercheck.finra.org.
Item 4. Other Business Activities.
As noted above in Part 2A, Mr. Hoffman is also engaged in securities activities as a broker dealer
registered representative of Emerson Equity LLC as well as an independent insurance agent. In these
roles, Mr. Hoffman recommends brokerage, insurance, and annuity products. Whenever Mr. Hoffman
recommends a service to an Advisory client, and he receives compensation for that recommended
service in the form of a commission and/or 12b-1 fee, such a situation inherently creates a conflict of
interest. As a fiduciary he must recommend only those services and products that are in a client’s own
best interest, free of any influence of possible gain for himself. The firm addresses this conflict of
interest by disclosing it to the firm’s clients. Moreover, the client has the right to decide to act on the
recommendations of the Adviser, and, if they do decide to act, they always have the right to do so with
a professional of their choosing.
Item 5. Additional Compensation.
Other than the affiliations and activities disclosed in items 4, above, Mr. Hoffman does not receive any
additional compensation.
Item 6. Supervision.
Forrest James is Mr. Hoffman’s supervisor. The firm maintains on file in its offices reports of the
Advisory representative’s proprietary trading activities and the formulation of his recommendations
for the regulator to review at will.
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
36
Andrew C. Bagnall
Born 1956
CRD # 4331728
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science from University of Indiana, Class of 1980 and a J.D. Degree from Whittier College
School of Law in 1988
Business background:
Emerson Equity LLC – Registered Representative (RR) & Investment Adviser Representative (July
2017 - Present);
First Heartland Capital – Registered Representative (RR) and Investment Adviser Representative
(2015 -2017)
Commonwealth Financial Network - Registered Representative (RR) and Investment Adviser
Representative (2007-2015)
Household Group Estate & Retirement Specialists – Investment Adviser Representative (2007-2003)
Sagepoint Financial, Inc. – Registered Representative (2005-2007)
Sunamerica Securities, Inc. – Registered Representative (2002-2005)
WMA Securities, Inc./World Group Securities, Inc. – Registered Representative (2001-2002)
Mr. Bagnall currently holds Series 6, 7, 26, 63, and 66 licenses. Mr. Bagnall is also a Certified Financial
Planner (CFP®).
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Mr. Bagnall: None
Is this Investment Adviser Representative currently suspended with any jurisdiction? NO.
Are there events disclosed about this Investment Adviser Representative? NO.
Are there events disclosed about this broker? NO.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Bagnall recommends a service to advisory clients, and he
himself will be the paid provider of that recommended service, such a situation inherently creates a
conflict of interest. As a fiduciary he must recommend only those services and products that are in a
client’s own best interest, free of any influence of possible gain for himself. The firm addresses this
possible conflict of interest by disclosing it to the firm’s clients. The services that Mr. BAGNALL may
recommend include brokerage and insurance products, as well as tax services.
Mr. Bagnall is also the owner of the Law Offices of Andrew C. Bagnall (1992 – present)
BLB Capital Ventures (2008 –present) - general partner of real estate holding company, not at branch
location, not investment related.
Seejay, LLC - managing member of real estate holding company, not at branch location, not
investment related (2008 – present)
Tart LLC, Tart Optical Enterprises, LLC, Tart Optical Enterprises, Inc. – CEO and Managing Member -
37
Eyewear manufacturing operating companies and trademark holding companies (2015 – present)
Item 5. Additional Compensation.
As described in Part 2A, Mr. Bagnall may receive 12(b)-1 fees from the administrative fees a client pays
to a mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that
recommendation creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Dominic Baldini is Mr. Bagnall’s supervisor. The firm maintains on file in its offices reports of the
advisory representative’s proprietary trading activities and the formulation of his recommendations
for the regulator to review at will.
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
38
Erick Baer
Born 1946
CRD # 2647074
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Business Administration from BYU, Class of 1969
Business background:
Emerson Equity LLC – Registered Representative (RR) (3 / 2018 – Present); Investment Adviser
Representative (IAR) (12 / 2019 – Present)
Former firm – Registered Representative (RR) (9 / 2015 – 11/ 2016); Investment Adviser
Representative (IAR) (9 / 2015 – 11/ 2016)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Mr. Baer:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 1 Final.
Are there events disclosed about this broker? Yes – 1 Final.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Baer recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of
interest. As a fiduciary he must recommend only those services and products that are in a client’s own
best interest, free of any influence of possible gain for himself. The firm addresses this possible conflict
of interest by disclosing it to the firm’s clients. The services that Mr. Baer may recommend include
brokerage and insurance products, as well as tax services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Baer may receive 12(b)-1 fees from the administrative fees a client pays to
a mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that
recommendation creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Dominic Baldini is Mr. Erick Baer’s supervisor. The firm maintains on file in its offices reports of the
advisory representative’s proprietary trading activities and the formulation of his recommendations
for the regulator to review at will.
Item 7. State Registration requirements.
There is no additional information to disclose under this item as it applies to this individual.
39
Kathleen Morrissey
Born 1961
CRD # 1771747
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science from Saint Mary’s College of California, Class of 1983
Business background:
Emerson Equity LLC – Registered Representative (RR), (Dec, 2005 – Present); Investment Adviser
Representative (IAR) (Dec, 2005 – Present); General Securities Principal (Dec, 2005 – Present); Chief
Operating Officer (Jul, 2016 – Present).
Girard Securities- OSJ Manager/Registered Representative (RR) (Jul, 2004- Dec, 2005); Investment
Adviser Representative (IAR) (Jul, 2004- Dec, 2005); General Securities Principal (Jul, 2004- Dec,
2005).
Banc of America Investment Services- Investment Consultant (RR)(Sep, 2001-Jul, 2004); Investment
Adviser Representative (IAR)(Jul, 2004-Dec, 2005).
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Kathleen Morrissey
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? No.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Ms. Morrissey recommends a service to advisory clients, and he
himself will be the paid provider of that recommended service, such a situation inherently creates a
conflict of interest. As a fiduciary he must recommend only those services and products that are in a
client’s own best interest, free of any influence of possible gain for himself. The firm addresses this
possible conflict of interest by disclosing it to the firm’s clients. The services that Ms. Morrissey may
recommend include brokerage and insurance products.
Item 5. Additional Compensation.
As described in Part 2A, Ms. Kathleen Morrissey may receive 12(b)-1 fees from the administrative fees
a client pays to a mutual fund. If he recommends the purchase of mutual funds to his advisory clients,
that recommendation creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Dominic Baldini is Ms. Morrissey’s supervisor. The firm maintains on file in its offices reports of the
advisory representative’s proprietary trading activities and the formulation of his recommendations
for the regulator to review at will.
Item 7. State Registration requirements.
40
There is no additional information to disclose under this item as it applies to this individual.
41
Ian McElreath
Born 1980
CRD # 4754189
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science, Business Administration from University of San Diego, Class of 2002
Business background:
Emerson Equity LLC – Registered Representative (RR) (April, 2021 – Present); Investment Adviser
Representative (IAR) (June 2021 – Present)
Ameritas Investment Corporation – Registered Representative (RR) (11/26/2019 - 04/06/2021);
20/20 Capital Management - Investment Adviser Representative (IAR) January 2020 – May 2021)
CANTOR FITZGERALD INVESTMENT ADVISORS - Investment Adviser Representative (1/19/2016 - 09/25/2019)
CANTOR FITZGERALD & CO. - Registered Representative (RR) (6/04/2009 - 12/08/2015)
REALTY CAPITAL SECURITIES, LLC - Registered Representative (RR) (4/17/2007 - 06/02/2009)
KBS CAPITAL MARKETS GROUP LLC - Registered Representative (RR) (3/11/2004 - 04/18/2007)
PACIFIC SELECT DISTRIBUTORS, INC. - Registered Representative (RR)( March 2004-April 2007)
OBAs:
Stryde Savings - Consultant, not investment related
Truchoice - Agent, investment related, fixed insurance business
Financial Independence Group - Agent, investment related, fixed insurance business
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Ian McElreath:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? NO
Are there events disclosed about this broker? NO.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. McElreath recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it
to the firm’s clients. The services that Mr. McElreath may recommend include brokerage and insurance products,
as well as tax services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. McElreath may receive 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Mike Culwell is Mr. McElreath’s supervisor. The firm maintains on file in its offices reports of the advisory
42
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements Mr. McElreath maintains registration as a representative of his firm with
the state of FL, among others.
43
Dieter Thurow
Born 1942
CRD # 1435375
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science from University of California-Los Angeles, Class of 1966
Master of Science in Management from Massachusetts Institute of Technology, Class of 1977
Business background:
Emerson Equity LLC – Registered Representative (RR) 8/2021 – Present); Investment Adviser Representative
(IAR) 8/2021– Present)
Former firm – Registered Representative (RR) (3/17 – 8/21); Investment Adviser Representative (IAR) (3/17 –
8/21)
01/2007 to 3/2017-The Planner’s Network-Registered Representative (RR); Investment Adviser Representative
(IAR); Insurance Agent
08/2008 to Present- Thurow Wealth Management Inc. DBA for Owner
06/1990 to Present- Dieter Thurow Fixed Insurance-Insurance Agent
06/1980 to Present- Dieter Thurow-Real Estate Broker
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Dieter Thurow
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes-1 Final
Are there events disclosed about this broker? Yes-1 Final
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Thurow recommends a service to advisory clients, and he himself will
be the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. Thurow may recommend include brokerage and insurance products, as
well as tax services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Thurow may receive 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Mike Culwell is Mr. Thurow’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements Mr. Thurow maintains registration as a representative of his firm with
the state of California among others.
44
YIPING CHOU
Born 1966
CRD # 4882398
Item 2. Educational Background and Business Experience:
Education & Licensing:
Master of Science Computer Engineering from University of Southern California, Class of 1991
Business background:
Emerson Equity LLC – Registered Representative (RR) (Oct, 2021– Present); Investment Adviser Representative
(IAR) (Oct, 2021 – Present)
NPB Financial Group LLC – Registered Representative (RR) (Jan 2014 – Oct 2021); Investment Adviser
Representative (IAR) (Jan 2014 – Oct 2021)
DBA CHOU FINANCIAL SERVICES GROUP (CFSG)9/2005- Present; FIXED INSURANCE SALES, INVESTMENT
RELATED
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding YIPING CHOU: CA
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 1 Final.
Are there events disclosed about this broker? Yes – 1 Final.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. YIPING CHOU recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for himself. The firm addresses this conflict of interest by disclosing it to the
firm’s clients and reviewing Mr. YIPING CHOU’s recommendations. The services that Mr. YIPING CHOU may
recommend include brokerage and insurance products, as well as tax services. When recommending insurance
products, he is compensated in the form of commissions.
Item 5. Additional Compensation.
As described in Part 2A, Mr. YIPING CHOU may receive 12(b)-1 fees from the administrative fees a client pays to
a mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Mike Culwell is Mr. YIPING CHOU’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements Mr. YIPING CHOU maintains registration as a representative of his firm
with the state of CA, NY, among others.
45
Douglas Zator
Born 4/3/1989
CRD # 6321246
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Communications from Western Michigan University Class of 2013
Business background:
Emerson Equity LLC – Registered Representative (November 2021 – Present); Investment Adviser
Representative (November 2021 – Present)
Great Point Advisors, LLC – Registered Representative (November 2020 – November 2021); Investment Adviser
Representative (November 2020 – November 2021
Cantor Fitzgerald Investment Advisors – Investment Adviser Representative (November 2018 – November 2020)
Cantor Fitzgerald & Co. – Registered Representative (November 2018 – November 2020)
JP Morgan Securities LLC – Registered Representative (May 2017 – November 2018); Investment Adviser
Representative (May 2017 – November 2018)
Merrill Lynch, Pierce, Fenner & Smith Incorporated – Registered Representative (June 2016 – March 2017);
Investment Adviser Representative (June 2016 – March 2017)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Douglas Zator:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No
Are there events disclosed about this Investment Adviser Representative? No
Are there events disclosed about this broker? No
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Douglas Zator recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it
to the firm’s clients. The services that Mr. Douglas Zator may recommend include brokerage and insurance
products, as well as tax services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Douglas Zator may receive 12(b)-1 fees from the administrative fees a client pays to
a mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Michael Culwell is Mr. Douglas Zator supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Mr. Douglas Zator maintains registration as a representative of his firm with the state of California among others.
46
Craig Gougis
Born 1970
CRD # 3258023
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science from University of Pepperdine, Class of 1996
Business background:
Emerson Equity LLC – Registered Representative (RR) (October, 2021 – Present); Investment Adviser
Representative (IAR) (October, 2021 – Present)
Former firm – Registered Representative (RR) (May 2009 – September 2021); Investment Adviser
Representative (IAR) (May 2009 - September 2021)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Craig Gougis: No
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 1 Final.
Are there events disclosed about this broker? Yes – 1 Final.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Craig Gougis recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it
to the firm’s clients. The services that Mr. Craig Gougis may recommend include brokerage and insurance
products, as well as tax services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Craig Gougis may receive 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Forrest James is Mr. Craig Gougis’ supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements Mr. Craig Gougis maintains registration as a representative of his firm
with the state of CA, among others.
47
Howard Davis
Born 1955
CRD # 1782118
Item 2. Educational Background and Business Experience:
Education & Licensing:
Mr. Davis attended California State University Northridge, University of Southern California and Kent State
University where he studied Finance and Accounting. Mr. Davis currently holds the following FINRA licenses:
7,24,24,63,65,79 and 99
Business background:
Emerson Equity LLC – Registered Representative (RR) (December 2021 – Present); Investment Adviser
Representative (IAR) (December 2021 – Present)
D-Merc Services LLC- Registered Representative (RR) (September 2020-Present)
Cabot Lodge Securities – Registered Representative (RR) (December 2014– March 2020); CL Wealth
Management-Investment Adviser Representative (IAR) (December 2014 – March 2020)
Sandlapper Securities LLC-Registered Representative (RR) (August 2013-September 2014); Sandlapper Wealth
Management, LLC (IAR) (August 2013-September 2014)
Financial West Group-Registered Representative (RR) (October 2007-September 2014)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Howard Davis:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 1 Final.
Are there events disclosed about this broker? Yes – 1 Final.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Howard Davis recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it
to the firm’s clients. The services that Mr. Howard Davis may recommend include brokerage and insurance
products, as well as tax services.
Mr. Davis is also the owner of Mountain Gate Advisors a business planning and strategic advisory firm (March
2020-Present). This activity is not investment-related.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Davis may receive 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Dominic Baldini is Mr. Davis’ supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Mr. Davis maintains registration as a representative of his firm with the state of CA.
48
Bryce Emo
Born 1975
CRD # 3103711
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Business Administration from University of Notre Dame Class of 1998
Business background:
Registered –
Emerson Equity LLC – Registered Representative (RR), Feb, 2022 – Present; Investment Adviser Representative
(IAR) (Feb 2022 – Present)
Non-Registered -
BEMO Ventures, Inc./DBA Sidecar Finance - CEO/Founder, Feb, 2022 – Present
Budgyt, Inc – Advisor/Investor, Feb 2020 – Present
Quid – VP Sales, April 2019 – Feb 2022
BEMO Ventures, Inc – Founder/Advisor, Feb 2018 – April 2019
4C Insights – VP of Sales, Feb 2014 – Feb 2018
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Bryce Emo:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No
Are there events disclosed about this Investment Adviser Representative? No
Are there events disclosed about this broker? No
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Emo recommends a service to advisory clients, and he himself will be
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. Emo may recommend include brokerage and insurance products, as well
as tax services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Emo may receive 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Matt Larson is Mr. Bryce Emo’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements Mr. Emo maintains registration as a representative of his firm with the
state of CA, among others.
49
Ernesto Chavez
Born 1961
CRD # 4315877
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science in Business Administration with a major in Finance from the University of Arizona, Class of
1984
Business background:
Emerson Equity LLC – Registered Representative (RR) (March 2022 – Present); Investment Adviser
Representative (IAR) (March 2022 – Present)
Former firm – Registered Representative (RR) (October 2015 – March 2022); Investment Adviser Representative
(IAR) (October 2015 – March 2022)
Item 3. Disciplinary Information The Investment Adviser Public Disclosure site states, regarding Ernesto Chavez:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 1 Final.
Are there events disclosed about this broker? Yes – 1 Final.
Item 4. Other Business Activities Mr. Chavez also sells fixed insurance products through an unaffiliated entity.
As noted above in Part 2A, whenever Mr. Chavez recommends a service to advisory clients, and he himself will
be the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As
a fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this conflict of interest by disclosing it to the
firm’s clients, as well as a general prohibition on any recommendation that is not in the best interest of the
customer. The services that Mr. Chavez may recommend include brokerage and insurance products, as well as
tax services.
Item 5. Additional Compensation As described in Part 2A, Mr. Chavez may receive 12(b)-1 fees from the
administrative fees a client pays to a mutual fund. If he recommends the purchase of mutual funds to his advisory
clients, that recommendation creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision Dominic Baldini is Mr. Chavez’s supervisor. The firm maintains on file in its offices reports of
the advisory representative’s proprietary trading activities and the formulation of his recommendations for the
regulator to review at will.
Item 7. State Registration requirements Mr. Ernesto Chavez maintains registration as a representative of his firm
with the state of Arizona, among others.
50
Brian Forrest Stokes
Born 1955
CRD # 1060238
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science from California State University, Fullerton, Class of 1976 Juris Doctor from Western State
University College of Law, Class of 1979 Currently seeking a Master’s Degree in military history from Norwich
University
Business background:
Emerson Equity LLC – Registered Representative (August 2022 – Present); Investment Adviser Representative
(IAR) (August 2022 – Present)
Independent Financial Group – Registered Representative (RR) (April 2009 – August 2022); Investment Adviser
Representative (IAR)
Linsco Private Ledger Registered Representative (RR) (April 2009 August 2022); Investment Adviser
Representative (IAR)
Bateman, Eichler, Hill, Richards – Registered Representative (RR) (April 2009 – April 2009); Investment Adviser
Representative (IAR)
LPL Financial– Registered Representative (RR) (April 1992 – April 2009); Investment Adviser Representative (IAR)
Kemper Securities Group, Registered Representative (RR) (April 1990 –March 1992 Drexel Burnham Lambert,
Registered Representative (RR) (April 1986 –March 1990
Merrill Lynch, Pierce Fenner, Smith, and Beane, Registered Representative (RR) (April 1992 – April 2009)
Stokes Insurance Services-Insurance Agent - August 2022 - Present
Stokes Antiquities – Owner – August 2018 – Present
San Diego Sword School – Owner August 2007 - Present
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Brian Stokes:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 1 Final.
Are there events disclosed about this broker? Yes – 1 Final.
For more information, please review this advisor’s background at
https://brokercheck.finra.org/individual/summary/1060238.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Stokes recommends a service to advisory clients, and he himself will be
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommends only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. All of Mr. Stokes’ recommendations are reviewed against this
threshold. The firm addresses this conflict of interest by disclosing it to the firm’s clients. The services that Mr.
Stokes may recommend include brokerage and insurance products, as well as tax services. Insurance products
are sold through Mr. Stokes’s insurance agency, Stokes Financial Services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Stokes receives 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he may realize. He also receives commissions on the sale of
insurance products. The firm reviews all of Mr. Stokes’s recommendations, and all products recommended must
be in the best interest of the client.
51
Item 6. Supervision.
Michael Culwell is Mr. Stokes’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Mr. Stokes maintains registration as a representative of his firm with the state of CA, among others.
52
Maximilian Shaulis
Born 1997
CRD # 7283721
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science from University of Denver, Class of 2020
Business background:
Emerson Equity LLC – Investment Adviser Representative (IAR) (09/2020 – Present)
Mountain Financial - Operations Administrator - (09/2020 – Present)
University OF Denver - Full Time Student – (09/2016 - 06/2020)
Smiling Moose Deli - Cook/Cashier - (06/2017 - 01/2018)
Unemployed - (05/2016 - 09/2016)
Evergreen High School - Full Time Student - (08/2012 - 05/2016)
Skyhawks Sports Camp - Coach - (06/2015 - 08/2015)
The Bistro - Dish Washer - (05/2014 - 08/2014)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Maximilian Shaulis:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 1 Final. Max Shaulis reached a
compromise with creditors after being made aware of an unpaid medical debt from childhood. The amount
paid and owed were $500 and $665, respectively.
Item 4. Other Business Activities.
As noted above in Part 2A, Mr. Shaulis works at Mountain Financial, an independent insurance brokerage. In
this role, he assists in administrative duties, client relations and scheduling, and manages interns. He may
receive compensation for insurance products recommended by others at the firm, however he does not
recommend insurance products to clients.
Item 5. Additional Compensation.
Other than the affiliations and activities disclosed in items 4, above, Mr. Shaulis does not receive any additional
compensation.
Item 6. Supervision.
Dominic Baldini is Mr. Shaulis’ supervisor. The firm maintains reports of the Advisory representative’s proprietary
trading activities and the formulation of his recommendations for the regulator to review at will.
Item 7. State Registration requirements.
Mr. Shaulis maintains registration as a representative of his firm with the state of Colorado.
53
Fred Chen
Born 1979
CRD # 5766069
Item 2. Educational Background and Business Experience:
Education & Licensing:
BA from University of California, Irvine - Class of 2001
Business background:
Emerson Equity LLC – Registered Representative (RR) (March 2020 – Present); Investment Adviser Representative
(IAR) (March 2020 – Present)
Former firm – Registered Representative (RR) (May 2018 – February 2020); Investment Adviser Representative
(IAR) (May 2018 – February 2020)
Strategic Horizon – Life Insurance Agent (October 2021 – Present)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Fred Chen:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No
Are there events disclosed about this broker? No
For more information, please review this advisor’s background at
https://brokercheck.finra.org/individual/summary/1060238.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Chen recommends a service to advisory clients, and he himself will be
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommends only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. All of Mr. Chen’s recommendations are reviewed against this threshold.
The firm addresses this conflict of interest by disclosing it to the firm’s clients. The services that Mr. Chen may
recommend include brokerage and insurance products, as well as tax services. Insurance products are sold
through Mr. Chen’s insurance agency, Strategic Horizon.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Chen receives 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he may realize. He also receives commissions on the sale of
insurance products. The firm reviews all of Mr. Chen’s recommendations, and all products recommended must
be in the best interest of the client.
Item 6. Supervision.
Forrest James is Mr. Chen’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Mr. Chen maintains registration as a representative of his firm with the state of California, among others.
54
Justin Wine
Born 1976
CRD # 4088317
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Arts from George Washington University Class of 2012
Business background:
Emerson Equity LLC – Registered Representative (RR) (Dec 2022– Present); Investment Adviser Representative
(IAR) (Dec 2022– Present)
Aspen Wealth Management, LLC – Investment Adviser Representative (IAR) (Sep 2021 – Present)
BCG Securities, Inc. – Registered Representative (RR) (Aug 2012 – July 2021); Investment Adviser Representative
(IAR) (Sep 2012 – July 2021);
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Justin Wine:
Is this Investment Adviser Representative currently suspended with any jurisdiction? NO.
Are there events disclosed about this Investment Adviser Representative? Yes – 1 Final, 1 Settled, 1 Closed w/
No Action, and 1 Employment Separation.
Are there events disclosed about this broker? Yes – 1 Final, 1 Settled, 1 Closed w/ No Action, and 1
Employment Separation.
For more information on the above matters, please visit:
https://files.brokercheck.finra.org/individual/individual_4088317.pdf
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Justin Wine recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it
to the firm’s clients. The services that Mr. Justin Wine may recommend include brokerage and insurance
products, as well as tax services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Justin Wine may receive 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Forrest James is Mr. Justin Wine’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Mr. Justin Wine maintains registration as a representative of his firm with the state of Florida, among others.
55
Adam Van Dyke
Born 1970
CRD # 3008054
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Arts in Biology and Asian Studies from Pepperdine University, Class of 1992
Business background:
Emerson Equity LLC – Registered Representative (RR) (January 2023 – Present); Investment Adviser
Representative (IAR) (January 2023 – Present)
Richer Experience – Owner/President (August 2005 – Present)
Cetera Advisor Networks LLC – Registered Representative (RR) (June 2021 – December 2022)
Voya Financial Advisors – Registered Representative (RR) (June 2013 – June 2021)
Wall Street Financial Group – Registered Representative (RR) (August 2005 – June 2013)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Adam Van Dyke:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 1 Final.
Are there events disclosed about this broker? Yes – 1 Final.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Van Dyke recommends a service to advisory clients, and he himself will
be the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. Van Dyke may recommend include brokerage and insurance products.
Mr. Van Dyke operates Richer Experience (DBA), which serves as a marketing vehicle through which his
Emerson Equity investment related business is marketed.
Mr. Van Dyke also sells term and whole life insurance products, fixed annuities, long-term care, disability
income insurance products, health insurance, etc. While these products are not sold through his relationship
with Emerson Equity, he may sell to Emerson Equity customers. All such recommendations are reviewed by the
firm and he is prohibited from recommending products to Emerson Equity customers that are not in the
customer’s best interest.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Van Dyke may receive 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Stephen Mark is Mr. Van Dyke’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
56
review at will.
Item 7. State Registration requirements
Mr. Van Dyke maintains registration as a representative of his firm with the state of Tennessee, among others.
57
Ashley Romiti
Born 1988
CRD # 7636987
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Anthropology from University of Los Angeles, Class of 2010
Business background:
Emerson Equity LLC – Registered Representative (RR) (October 2022 – Present); Investment Adviser
Representative (IAR) (January 2023 – Present)
Perch Wealth, Marketing Associate, 06/2022 – present
Verada Retail, Content Creator, 04/2022-present
Topside Real Estate, Marketing Manager, 10/2020 -present
Vantis Capital, Senior Sales Associate, 07/2019-09/2020
Self Employed, Freelance Writer, 01/2017-09/2022
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Ashley Romiti:
Is this Investment Adviser Representative currently suspended with any jurisdiction? NO
Are there events disclosed about this Investment Adviser Representative? NA
Are there events disclosed about this broker? NA
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mrs. Romiti recommends a service to advisory clients, and she herself will
be the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary she must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for herself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mrs. Romiti may recommend include brokerage and insurance products, as
well as tax services.
Mrs. Romiti is employed by Perch Wealth. This entity is the vehicle through which her securities and advisory
activities with Emerson Equity are marketed. In addition, Mrs. Romiti works for Verada Retail and Topside Real
Estate, both of which are investment related businesses, however, she does not work with Emerson clients
through these businesses.
Item 5. Additional Compensation.
As described in Part 2A, Mrs. Romiti may receive 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If she recommends the purchase of mutual funds to her advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that she may realize.
Item 6. Supervision.
Forrest James is Mrs. Romiti’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration Requirements.
Mrs. Romiti maintains registration as a representative of her firm with the state of CA, among others.
58
Ting-Yih Wu
Born 1997
CRD # 7316956
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science, Business Administration (Marketing) from San Jose State University, Class of 2020.
Business background:
Emerson Equity LLC – Registered Representative (RR) (June, 2022 – Present); Investment Adviser
Representative (IAR) (January 2023 - Present)
The Sherer Group – VP of Marketing (January 2023 – Present) ; Unlicensed Assistant (December 2020 –
December 2022)
San Jose State University Tower Foundation – Team Lead (October 2016 – June 2020)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Ting-Yih Wu:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No
Are there events disclosed about this Investment Adviser Representative? No
Are there events disclosed about this broker? No
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Wu recommends a service to advisory clients, and he himself will be
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. Wu may recommend include brokerage and insurance products, as well
as tax services. Mr Wu also acts as the VP of Marketing for The Sherer Group, a marketing vehicle through which
investment related business is done with Emerson Equity.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Wu may receive 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Dominic Baldini is Mr. Wu’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements.
Mr. Wu maintains registration as a representative of his firm with the state of California, among others.
59
Kenneth Zupo
Born 1977
CRD # 4509502
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science in Finance w/ minor in Economics from San Jose State University, Class of 2001
Business background:
Emerson Equity LLC – Registered Representative (RR) (January 2023 – Present); Investment Adviser
Representative (IAR) (January, 2023 – Present)
Whitehall-Parker Securities, Inc – Registered Representative (RR) (July 2009 – December 2022); Investment
Adviser Representative (IAR) (July 2009 – December 2022)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Kenneth Zupo:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 1 Final, 1 Settled, 1 Denied,
and 2 Open.
Are there events disclosed about this broker? Yes – 1 Final, 1 Settled, 1 Denied, and 2 Open.
For more details, please visit https://brokercheck.finra.org/individual/summary/4509502.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Kenneth Zupo recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it
to the firm’s clients. The services that Mr. Kenneth Zupo may recommend include brokerage and insurance
products, as well as tax services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Kenneth Zupo may receive 12(b)-1 fees from the administrative fees a client pays to
a mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Kevin Hickam is Mr. Kenneth Zupo’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements.
Mr. Kenneth Zupo maintains registration as a representative of his firm with the state of California, among others.
60
Daniel E. Pisenti
Born 1962
CRD # 1782562
Item 2. Educational Background and Business Experience:
Education & Licensing: University of California, Berkeley (1980-1984)
Bachelor of Science in Business Administration (Accounting/Finance), Class of 1984
Business background:
Emerson Equity LLC – Registered Representative (RR) (January, 2023 – Present); Investment Adviser
Representative (IAR) (January, 2023 – Present)
Whitehall-Parker Securities, Inc. – Registered Representative (RR) (November, 1991 – December, 2022);
Investment Adviser Representative (IAR) (July, 1997 – December, 2022)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Daniel E. Pisenti:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? No.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Pisenti recommends a service to advisory clients, and he himself will be
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. Pisenti may recommend include brokerage and insurance products, as
well as tax services.
Mr. Pisenti is also currently employed to assist in the closing of his former broker/dealer (Whitehall-Parker
Securities, Inc.) after 31+ years of service to that firm. However, no securities or advisory business is being
transacted through that entity.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Pisenti may receive 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Kevin Hickam is Mr. Pisenti’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements Mr. Pisenti maintains registration as a representative of his firm with the
state of California, among others.
61
Derek Vogel
Born 1993
CRD # 7501748
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science in Quantitative Economics from United States Naval Academy, Class of 2016.
Business background: Emerson Equity LLC – Registered Representative (RR) (April 2022 – Present); Investment
Adviser Representative (IAR) (January 2023 – Present).
Naval Officer (June 2016 – July 2022).
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Mr. Vogel:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? No.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Vogel recommends a service to advisory clients, and he himself will be
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. Vogel may recommend include brokerage and insurance products, as
well as tax services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Vogel may receive 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Mr. Forrest James is Mr. Vogel’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Mr. Vogel maintains registration as a representative of his firm with the state of California, among others.
62
Amy Strohn
Born 1984
CRD # 7100804
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of <Accounting> from University of <University of Phoenix>, Class of <2016>
Business background:
Emerson Equity LLC – Registered Representative (RR) (September,2023 – Present); Investment Adviser
Representative (September,2023 – Present)
Not Investment Related Roles*:
Strohn Livestock – Owner (December, 2019 – Present)
Dare to Dream Financial Services - Office Administrator (February, 2019 – Present)
Windermere Ranch - Ranch Manager (September, 2021 – January, 2023)
Self-Employed - Contract Labor (July, 2018 – September, 2021)
*This business is investment related, but Ms. Strohn’s role is not.
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Amy Strohn:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No
Are there events disclosed about this broker? No
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Ms. Amy Strohn recommends a service to advisory clients, and she herself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary she must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for herself. The firm addresses this conflict of interest by disclosing it to the
firm’s clients and reviewing Ms. Strohn’s recommendations. The services that Ms. Strohn may recommend
include brokerage products.
Ms. Strohn also performs administrative services for Dare to Dream Financial Services. However, her role is
clerical / ministerial only, and represents no conflict of interest with her advisory clients.
Item 5. Additional Compensation.
As described in Part 2A, Ms. Strohn may receive 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If she recommends the purchase of mutual funds to her advisory clients, that recommendation
creates a conflict of interest, due to the 12(b)-1 fees that she may realize. Similarly, Ms. Strohn may recommend
alternative investments. While these assets are not included in the calculation of your advisory fees, Ms. Strohn
will receive a commission for the sale of such products. The firm addresses this conflict through disclosure, as
well as a review of all recommendations by Ms. Strohn.
Item 6. Supervision.
Bruce Beetz is Ms. Strohn’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of her recommendations for the regulator to
63
review at will.
Item 7. State Registration requirements Ms. Strohn maintains registration as a representative of her firm with
the state of California.
64
Douglas Zator
Born 4/3/1989
CRD # 6321246
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Communications from Western Michigan University Class of 2013
Business background:
Emerson Equity LLC – Registered Representative (December, 2023 - Present); Investment Adviser
Representative (December, 2023 – Present)
Arkadios Capital – Registered Representative (August, 2023 – December, 2023)
Arkadios Wealth Advisors –Investment Adviser Representative (August, 2023 – December, 2023)
Emerson Equity LLC – Registered Representative (November 2021 – August, 2023); Investment Adviser
Representative (November 2021 – August, 2023)
Great Point Advisors, LLC – Registered Representative (November 2020 – November 2021); Investment Adviser
Representative (November 2020 – November 2021
Cantor Fitzgerald Investment Advisors – Investment Adviser Representative (November 2018 – November 2020)
Cantor Fitzgerald & Co. – Registered Representative (November 2018 – November 2020)
JP Morgan Securities LLC – Registered Representative (May 2017 – November 2018); Investment Adviser
Representative (May 2017 – November 2018)
Merrill Lynch, Pierce, Fenner & Smith Incorporated – Registered Representative (June 2016 – March 2017);
Investment Adviser Representative (June 2016 – March 2017)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Douglas Zator:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No
Are there events disclosed about this Investment Adviser Representative? No
Are there events disclosed about this broker? No
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Douglas Zator recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it
to the firm’s clients. The services that Mr. Douglas Zator may recommend include brokerage and insurance
products, as well as tax services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Douglas Zator may receive 12(b)-1 fees from the administrative fees a client pays to
a mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Forrest James is Mr. Douglas Zator supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Mr. Douglas Zator maintains registration as a representative of his firm with the state of California among others.
65
Renata Lance
Born 1981
CRD # 5020798
Item 2. Educational Background and Business Experience:
Education & Licensing:
Series 7, Series 63 and Series 66
Business background:
Emerson Equity LLC – Registered Representative (RR) (February 2024 – Present); Investment Adviser
Representative (IAR) (February 2024 – Present)
Cetera Investment Services LLC – Registered Representative (RR) (September 2021 – May 2022)
Cetera Investment Advisers LLC - Investment Adviser Representative (IAR) (May 2019 – September 2021)
Cetera Financial Specialists – Registered Representative (RR) (May 2019 – September 2021)
Cetera Investment Advisers LLC – Investment Adviser Representative (IAR) (May 2019 – September 2021)
Wellness Wealth Advisors – Registered Representative (RR) (June 2019 – May 2021)
Morgan Stanley – Financial Adviser Trainee (November 2018 – January 2019)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Renata Lance:
Is this Investment Adviser Representative currently suspended with any jurisdiction? NO.
Are there events disclosed about this Investment Adviser Representative? NO.
Are there events disclosed about this broker? NO.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mrs. Renata Lance recommends a service to advisory clients, and she herself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for herself. The firm addresses this possible conflict of interest by disclosing it
to the firm’s clients. The services that Mrs. Renata Lance may recommend include brokerage and insurance
products, as well as tax services.
In addition to her role with Emerson, Mrs. Lance is also involved in various non-investment related outside
businesses. The only such business that serves as a material source of income is Lance Enterprises, Inc., a Club
Pilates franchise owner. This entity does not reflect any conflicts with Mrs. Lance’s advisory business.
Item 5. Additional Compensation.
As described in Part 2A, Mrs. Renata Lance may receive 12(b)-1 fees from the administrative fees a client pays to
a mutual fund. If she recommends the purchase of mutual funds to her advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Matt Larson is Mrs. Renata Lance’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of her recommendations for the regulator to
review at will.
Item 7. State Registration requirements.
Mrs. Renata Lance maintains registration as a representative of her firm with the state of California among others.
66
Sejal Patel
Born 2000
CRD # 7445920
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Business Administration in Finance from Georgia State University, Class of 2022
Business background:
Emerson Equity LLC – Registered Representative (February 2025 – Present); Investment Adviser Representative
(February 2025 – Present)
Highland Capital Brokerage – Agent (February 2025 – Present)
Arcus Capital Partners LLC – Client Service and Operations Associate (June 2024 – January 2025)
Dempsey Lord Smith LLC - Registered Representative (January 2024 – May 2024); Investment Adviser
Representative (January 2024 – May 2024)
Unemployed – (November 2023 – December 2023)
The Prudential Insurance Company of America – Financial Professional (September 2023 – November 2023)
Pruco Securities LLC – Registered Representative (January 2023 – November 2023)
Post Grad Travel – Unemployed (June 2022 – December 2022)
Georgia State University – Full-Time Education in Finance (August 2019 – May 2022)
Nav Advisors - Full-Time Finance Intern/Front Desk (June 2021 – July 2021)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Ms. Patel:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No
Are there events disclosed about this broker? No
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Ms. Patel recommends a service to advisory clients, and she herself will be
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for herself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Ms. Patel may recommend include brokerage and insurance products, as well
as tax services.
Ms. Patel sells life, accident, health, and fixed insurance products through Highland Capital Brokerage. Where she
recommends the sale of such products to advisory clients, she must act in your best interest. The firm reviews
such recommendations and prohibits the recommendation and sale of insurance products that are not in your
best interest.
Item 5. Additional Compensation.
As described in Part 2A, Ms. Patel may receive 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If she recommends the purchase of mutual funds to her advisory clients, that recommendation creates a
risk for a conflict of interest, due to the 12(b)-1 fees that she may realize.
Item 6. Supervision.
Forrest James is Ms. Patel’s supervisor. The firm maintains on file in its offices reports of the advisory
67
representative’s proprietary trading activities and the formulation of her recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Ms. Patel maintains registration as a representative of her firm with the state of Georgia, among others.
68
Richard A. Borba
Born 1948
CRD # 811527
Item 2. Educational Background and Business Experience:
Education: AA and Bachelor of Arts from University of University of California Berkeley and California State
Hayward, Class of 1971
Business background:
Emerson Equity LLC – Registered Representative (RR) (October, 2024 – Present); Investment Adviser
Representative (IAR) (October, 2024 – Present)
Allianz Life – Agent January 2020 – Present)
National Western Life – Agent June 2018 to Present)
Portsmouth Financial, Inc. – Registered Representative (RR) - (January, 2024 – October, 2024);
Putney Advisors - Investment Advisor Representative (IAR) - (January, 2024 – October, 2024);
Arete Wealth Advisors, LLC – Investment Advisor Representative (IAR) (March, 2023 – January, 2024)
Center Street Advisors, LLC – Investment Advisor Representative (IAR) (June, 2021 – December, 2023)
Center Street Securities, Inc. – Registered Representative (RR) – (June, 2021 – December, 2023)
LifePro Asset Management, LLC – Investment Advisor Representative (IAR) October 2020 to June 2021)
Center Street Advisors, LLC – Investment Advisor Representative (IAR) (April, 2016 – October, 2020)
Center Street Securities, Inc. – Registered Representative (RR) – (May, 2013 – October, 2020)
Ohio National Financial Services – Agent (February, 1996 to June, 2021)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Richard A Borba:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 2 Closed-No Action, 1 Denied.
Are there events disclosed about this broker? Yes – 2 Closed-No Action, 1 Denied.
More information is available at https://adviserinfo.sec.gov/individual/summary/811527.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Borba recommends a service to advisory clients, and he himself will be
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this conflict of interest by prohibiting any
recommendation that is not in the client’s best interest, as well as disclosing it to the firm’s clients and reviewing
his advisory accounts. The services that Mr. Borba recommends include brokerage and insurance products, as
well as tax services.
Mr. Borba sells insurance products through Allianz Life & Annuity and National Western Life Insurance Company.
In addition, Mr. Borba markets his brokerage, advisory, and insurance activities through his DBA, Financial
Dynamics.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Borba may receive 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he may realize.
69
Item 6. Supervision.
Mike Culwell is Mr. Borba’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Mr. Borba maintains registration as a representative of his firm with the state of California, among others.
70
Nathaniel J. Russell
Born 1997
CRD # 7943714
Item 2. Educational Background and Business Experience:
Education & Licensing:
Eastern Michigan University, 2016 – 2017, The Ohio State University, 2017 – 2018, Associate Degree Equivalent
from The Ohio State University, 2018.
Ohio Insurance License – Resident Major Lines, Line(s) of Authority: Accident & Health, Life from The Ohio
Department of Insurance, 2023.
Business background:
Emerson Equity LLC – Registered Representative (RR) (June, 2024 – Present); Investment Adviser
Representative (IAR) (August 2024 – Present)
Nathaniel J. Russell Insurance – Licensed Agent (January 2023 – Present)
Additional work details:
Nathaniel J. Russell Insurance - Health Insurance and Fixed Insurance Sales, Independent Health and Life
Insurance Agent, Selling Health and Life Insurance Products to Individuals (January 2023 – Present).
Nathaniel J. Russell Sole Proprietor, Delivery Service, Delivery Driver for Uber, Amazon Flex and Shipt, Claim
Orders on Delivery Driving App, Pick Up Orders and Safely Delivering Those Orders to the Customers Location
(June 2021 – Present).
Unit Coordinator for Mount Carmel East Hospital (March 2020 – June 2021)
Nathaniel J. Russell Sole Proprietor, Brand Ambassador for Various Marketing Companies (October 2017 –
March 2022)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Nathaniel J. Russell:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? No.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Nathaniel J. Russell recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for himself.
The services that Mr. Russell may recommend include brokerage and insurance products, as well as tax services.
As an independent insurance agent, when Mr. Russell recommends the purchase of an insurance product, he will
receive the commission on that product if it is purchased through him. Similarly, when Mr. Russell recommends
a brokerage product, such as an alternative investment, in his role as a broker dealer registered representative,
he will receive a commission on that product if purchased through him. We address these conflicts of interest
through disclosure here, a general prohibition on any recommendation not in your best interest, and review of
Mr. Russell’s client accounts.
Mr. Russell also owns and operates his own delivery service which provides 10% or more of his income. However,
this business is not related to his advisory services or clients, and does not present a conflict of interest.
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Item 5. Additional Compensation.
As described in Part 2A, Nathaniel J. Russell may receive 12(b)-1 fees from the administrative fees a client pays
to a mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
As outlined in item 4 of this 2B, above, Mr. Russell will also receive commissions for insurance and brokerage
products purchased through him as a insurance agent and registered representative, respectively.
Item 6. Supervision.
Mr. Dominic Baldini is Nathaniel J. Russell’s supervisor. The firm maintains on file in its offices reports of the
advisory representative’s proprietary trading activities and the formulation of his recommendations for the
regulator to review at will.
Item 7. State Registration requirements
Nathaniel J. Russell maintains registration as a representative of his firm with the state of Ohio, among others.
72
Maxwell Luria
Born 2000
CRD # 7390535
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science in Business Administration with a Major in Finance from University of Arizona Eller College of
Management, Class of 2022
Business background:
Emerson Equity LLC – Registered Representative (RR) (November 2023 – Present); Investment Adviser
Representative (IAR) (November 2023 – Present)
Merrill Lynch – Registered Representative (RR) (July 2022 – October 2023); Investment Adviser Representative
(IAR) (July 2022 – October 2023)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Mr. Luria:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? No.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Luria recommends a service to advisory clients, and he himself will be
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. Luria may recommend include brokerage and insurance products, as well
as tax services.
Mr. Luria is also a wholesaler for Inspired Healthcare Capital ("IHC"), a private placements sponsor. Though
Emerson does not permit private placements to be included in assets under management for purposes of
calculating advisory fees, the purchase of such a product based on Mr. Luria’s recommendation would result in a
commission paid to Mr. Luria. This represents a conflict of interest wherein Mr. Luria is incentivized not only to
recommend such a product, but his role with IHC specifically incentivizes him to recommend IHC’s products over
those of other sponsors. The firm addresses this conflict through disclosure in this document, a general
prohibition on the recommendation of any product or service that is not in your best interest, and a requirement
that Mr. Luria review reasonably available alternatives to determine which product would meet that best interest
requirement prior to making any such recommendation. All private placement transactions are also reviewed by
a principal prior to approval.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Luria may receive 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Mr. Baldini is Mr. Luria supervisor. The firm maintains on file in its offices reports of the advisory representative’s
proprietary trading activities and the formulation of his recommendations for the regulator to review at will.
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Item 7. State Registration Requirements.
Mr. Luria maintains registration as a representative of his firm with the state of Arizona, among others.
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Lance Ichikawa
Born 1961
CRD # 1519862
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Liberal Arts from University of UC Berkeley, Class of 1985
Business background:
Emerson Equity LLC – Investment Adviser Representative (IAR) (February 2024 – Present)
C2C Wealth Management, LLC – Investment Adviser Representative (IAR) (June 2017 – February 2024)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Lance Ichikawa:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No
Are there events disclosed about this broker? No
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Ichikawa recommends a service to advisory clients, and he himself will
be the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. Ichikawa may recommend include brokerage and insurance products, as
well as tax services.
Mr. Ichikawa does maintain his insurance license, but he does not actively engage in insurance business, nor
would he do so with advisory customers, therefore this license does not represent any conflict of interest.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Ichikawa may receive 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a conflict of interest, due to the 12(b)-1 fees that he may realize. The firm mitigates this conflict through
review of all of Mr. Ichikawa’s transactions and a general prohibition on recommendations that are not in the
best interest of the customer.
Item 6. Supervision.
Dominic Baldini is Mr. Ichikawa’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements.
Mr. Ichikawa maintains registration as a representative of his firm with the state of California, among others.
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Shirley Wong
Born 1970
CRD # 4869184
Item 2. Educational Background and Business Experience:
Education & Licensing:
MBA of San Francisco State from University of California State, Class of 2004
Business background:
Emerson Equity LLC – Registered Representative (RR) (April 2024 – Present); Investment Adviser Representative
(IAR) (April 2024– Present)
Ni Advisors – Registered Representative (RR) (2012 – April 2024); Investment Adviser Representative (IAR)
(December 2012 –May 2024 )
Item 3. Disciplinary Information:
The Investment Adviser Public Disclosure site states, regarding Shirley Wong:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 9 Final, 1 Pending.
Are there events disclosed about this broker? Yes – 9 Final, 1 Pending.
Please review Ms. Wong’s history at https://brokercheck.finra.org/individual/summary/4869184 for more
details.
Item 4. Other Business Activities:
As noted above in Part 2A, whenever Shirley Wong recommends a service to advisory clients, and she herself will
be the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for herself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Shirley Wong may recommend include brokerage and insurance products, as
well as tax services.
Ms. Wong is president of AK Advisors, Inc., through which she recommends and sells fixed insurance products.
However, she does not recommend these products to her advisory clients. As such, there is no conflict.
Item 5. Additional Compensation:
As described in Part 2A, Shirley Wong may receive 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision:
Mr. Dominic Baldini is Shirley Wong’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7 State Registration Requirements:
Shirley Wong maintains registration as a representative of her firm with the state of California, among others.
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Peter Po
Born 1964
CRD # 3106974
Item 2. Educational Background and Business Experience:
Education & Licensing:
MBA from Oklahoma State University, Class of 1990
Business background:
Emerson Equity LLC – Registered Representative (RR) (May, 2024 – Present); Investment Adviser Representative
(IAR) (May 2024 – Present)
Ni Advisors – Registered Representative (RR) (8/2015 – 5/2024); Investment Adviser Representative (IAR)
(8/2015 – 5/2024)
Item 3. Disciplinary Information:
The Investment Adviser Public Disclosure site states, regarding Peter Po:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes.
Are there events disclosed about this broker? Yes.
Please review Mr. Po’s history at https://brokercheck.finra.org/individual/summary/3106974 for more details.
Item 4. Other Business Activities:
As noted above in Part 2A, whenever Mr. Peter Po recommends a service to advisory clients, and he himself will
be the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. Peter Po may recommend include brokerage and insurance products, as
well as tax services.
Item 5. Additional Compensation:
As described in Part 2A, Mr. Peter Po may receive 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision:
Dominic Baldini is Mr. Peter Po ’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7 State Registration Requirements:
Mr. Peter Po maintains registration as a representative of his firm with the state of CA, among others.
77
Rikin Patel
Born 1979
CRD # 4669036
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Bachelor of Arts from University of Maryland, Class of 2021
Business background:
Emerson Equity LLC – Registered Representative (RR) (March 2025 – Present); Investment Adviser
Representative (March 2025 – Present)
Kingswood Capital Partners, LLC – Registered Representative (RR) (02/2023 – 03/2025)
Kingswood Wealth Advisors, LLC - Investment Adviser Representative (01/2022 – 03/2025)
Benchmark Investments, LLC – Registered Representative (RR) (05/2020 – 05/2023)
Benchmark Advisory Services, LLC - Investment Adviser Representative (05/2020 – 01/2022)
SA Stone Investment Advisors Inc. – Investment Adviser Representative (06/2016 – 05/2020)
SA Stone Wealth Management Inc. - Registered Representative (RR) (03/2012 – 05/2020)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Rikin Patel:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? No.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Rikin Patel recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it
to the firm’s clients. The services that Mr. Rikin Patel may recommend include brokerage and insurance products,
as well as tax services.
Mr. Patel is involved in the following outside business activities which provide for a material portion of his income
or are investment related:
Kaushik Patel, LLC – Mr. Patel provides tax and accounting services through this entity. Advisory clients
may also be tax/accounting clients. Mr. Patel is required to adhere to his fiduciary duty when
recommending this service to advisory clients, and may only recommend them if he believes it is in your
best interest. When providing these services, Mr. Patel receives separate compensation beyond his
advisory fees.
Parkview Investment Advisors – through this entity, Mr. Patel provides services to a venture capital fund.
The fund, however, is fully invested and is in the process of waiting for those investments to wind down.
As such, there are no conflicts of interest in light of the fact that, since the fund is no longer seeking
78
investments, Mr. Patel could not recommend such investment by his advisory customers.
Double Vision Ventures, LLC – through this entity, Mr. Patel provides operations and strategic support to
several entities which are or are affiliated with product sponsors. While he does not derive income from
advisory clients for these activities, he receives compensation from sponsors or their affiliates for these
services, while potentially recommending the associated alternative investments through Emerson
Equity LLC’s broker dealer platform. All such transactions are reviewed on a case-by-case basis and must
only be recommended if Mr. Patel has reason to believe they are in your best interest. If approved, Mr.
Patel will receive compensation in the form of a commission from the offering or product sponsor.
SMR Capital, LLC – through this entity, Mr. Patel provides strategic advice, investor relations, and
operational oversight for a venture capital fund. It is possible that advisory clients could also become
investors in the fund. While he does not derive income from advisory clients for these activities, he
receives compensation from the fund.
The firm reviews the activities of Mr. Patel as it pertains to any recommendations that he would make to his
advisory clients with respect to the above activities to ascertain whether any such recommendation has been
determined to be in the best interest of the clients. Mr. Patel is strictly prohibited from making any
recommendation to his advisory clients that has not been determined to meet this standard.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Rikin Patel may receive 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Dominic Baldini is Mr. Rikin Patel’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Mr. Rikin Patel maintains registration as a representative of his firm with the state of NJ among others.
79
Jason Smith
Born 1980
CRD # 6060809
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Business from Texas Christian University, Class of 2003
Business background:
Emerson Equity LLC – Investment Adviser Representative (April 2025 – Present)
CF Financial – Investment Adviser Representative (Jan 2021 – Jan 2025)
Regal Investment Advisors LLC – Investment Adviser Representative (Aug 2016 – Jan 2021)
Regulus Financial Group, LLC – Registered Representative (Aug 2016 – Jan 2021)
Edward Jones – Registered Representative (June 2012 – Aug 2016); Investment Adviser Representative (Sep
2012 – Aug 2016)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Mr. Smith:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker?
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Smith recommends a service to advisory clients, and he himself will be
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. Smith may recommend include insurance products.
Mr. Smith owns and operates Southpaw Consulting, LLC, through which he provide business management
consulting. While Mr. Smith derives more than 10% of his income from this business, there is no relationship
between this business and his advisory clients, therefore there are no conflicts of interest.
Item 5. Additional Compensation.
Mr. Smith does not receive any additional compensation beyond that disclosed in the Part 2A and Item 4, above,
of this 2B.
Item 6. Supervision.
Milan Baldini is Mr. Smith’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Mr. Smith maintains registration as a representative of his firm with the state of Texas.
80
John J Ferneau
Born 1973
CRD # 6136562
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science from University of Nebraska-Lincoln, Class of 1998
Business background:
Emerson Equity LLC – Registered Representative (RR) (March 2025– Present); Investment Adviser
Representative (IAR) (March 2025– Present)
Former firm – Registered Representative (RR) (Kingswood US); Investment Adviser Representative (IAR)
(January 2022 – March 2025)
Benchmark Investments (August 2021 to May 2023)
Benchmark Advisory Services (August 2021 – January 2022)
BFC Planning Inc. (October 2013 – August 2021)
Berthel Fisher & Company Financial Services, Inc. (February 2013 – August 2021)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding John J Ferneau:
Is this Investment Adviser Representative currently suspended with any jurisdiction? NO
Are there events disclosed about this Investment Adviser Representative? Yes-1 Final
Are there events disclosed about this broker? Yes-1 Final
For more information, please review Mr. Ferneau’s BrokerCheck Report at
https://files.brokercheck.finra.org/individual/individual_6136562.pdf.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. John J Ferneau recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it
to the firm’s clients. The services that Mr. John J Ferneau may recommend include brokerage and insurance
products, as well as tax services.
Mr. Ferneau also operates Ferneau Asset Management. In addition to serving as a DBA through which Mr.
Ferneau markets his securities and advisory business through Emerson, Mr. Ferneau uses this entity to sell
accident, life, and health insurance. In instances where he recommends these products to advisory clients, he
must act in your best interest.
Item 5. Additional Compensation.
As described in Part 2A, Mr. John J Ferneau may receive 12(b)-1 fees from the administrative fees a client pays to
a mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Dominic Baldini is Mr. John J Ferneau supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
81
review at will.
Item 7. State Registration Requirements.
Mr. John J Ferneau maintains registration as a representative of his firm with the state of CO, among others.
82
Daniel King
Born 1988
CRD #5954543
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Arts from University of Buffalo, Class of 2011
Business background:
Emerson Equity LLC – Registered Representative (RR) (04/2025 – Present); Investment Adviser Representative
(04/2025 – Present)
Kingswood Capital Partners – Registered Representative (RR) (05/2023 – 04/2025)
Kingswood Wealth Advisors, LLC - Investment Adviser Representative (IAR) (07/2022 – 04/2025)
Benchmark Investments, Inc. – Registered Representative (02/2019 to 05/2023)
Newbridge Securities - _(11/2016 to 02/2019)
Legend Securities, Inc. - (03/2015 to 12/2016)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Mr. King:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 3 Final, 2 Settled.
Are there events disclosed about this broker? Yes – 3 Final, 2 Settled.
For more information about these matters, please review Mr. King’s BrokerCheck report at
https://brokercheck.finra.org/individual/summary/5954543.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. King recommends a service to advisory clients, and he himself will be
the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. King may recommend include brokerage and insurance products, as well
as tax services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. King may receive 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Kevin Hickam is Mr. King’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
83
Mr. King maintains registration as a representative of his firm with the state of CA among others.
84
Matthew Nielsen
Born 1972
CRD # 2762423
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Arts from Lake Forest College, Lake Forest, IL , Class of 1994
Business background:
Emerson Equity LLC – Registered Representative (RR) (March, 2025– Present); Investment Adviser
Representative (IAR) (March 2025– Present)
Former firm – Registered Representative (RR) (May 2023– March 2025); Investment Adviser Representative
(January 2022 – March 2025)
Benchmark Investment, Inc. – Registered Representative – (May 2020-January 2022)
Benchmark Advisory Services, Inc. – Investment Adviser Representative – (May 2020-January 2022)
Stonecrest Advisors, Inc. – Investment Adviser Representative – (June 2015-May 2020)
Stonecrest Capital Markets, Inc – Registered Representative – (April 2015 – May 2020)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Matthew Nielsen:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes
Are there events disclosed about this broker? Yes
For more information, visit the BrokerCheck website at
https://brokercheck.finra.org/individual/summary/2762423
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Nielsen recommends a service to advisory clients, and he himself will
be the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. Nielsen may recommend include brokerage and insurance products, as
well as tax services.
Mr. Nielsen recommends and sells disability insurance in limited circumstances. In some instances, the individuals
to whom he sells these policies are also advisory clients. Mr. Nielsen’s recommendation to purchase such policies
are limited to those instances wherein they are in the best interest of the client. When selling these policies, Mr.
Nielsen collects a commission.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Nielsen may receive 12(b)-1 fees from the administrative fees a client pays to a
mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
85
Kevin Hickam is Mr. Nielsen’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration Requirements.
Mr. Nielsen maintains registration as a representative of his firm with the state of CA, CT, IN, NJ, NY, PA, TN, TX,
among others.
86
Andrew Roberson
Born 1978
CRD # 4143407
Item 2. Educational Background and Business Experience.
Education & Licensing:
Bachelor of Commerce in Finance from Santa Clara University, Class of 2001
Series 7, 63 and 65 in 2005
Certified Financial Planner, American College in 2018
Business background:
Emerson Equity LLC – Registered Representative (RR) (August 2025 – Present); Investment Adviser
Representative (IAR) (August 2025 – Present)
Tarkenton Financial – Insurance Brokerage (August 2025 - Present )
Park Avenue Securities – Registered Representative (RR) (April 2018 –July 2025); Investment Adviser
Representative (IAR) (April 2010 –July 2025)
Guardian Life Insurance Company – Insurance Brokerage (April 2018 –July 2025)
SGC Financial – Registered Representative (RR) (June 2010 - April 2018); Investment Adviser Representative (IAR)
(April 2018 –July 2025)
Lincoln Financial Advisors – Registered Representative (RR) (Dec 2004 – June 2010)
Lincoln National Life Ins Co – Sales Agent/Registered Rep (RR) (Dec 2004- May 2006)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Andrew Roberson
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 2 Final.
Are there events disclosed about this broker? Yes – 2 Final.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Andrew Roberson recommends a service to advisory clients, and he
himself will be the paid provider of that recommended service, such a situation inherently creates a conflict of
interest. As a fiduciary he must recommend only those services and products that are in a client’s own best
interest, free of any influence of possible gain for himself. The firm addresses this possible conflict of interest by
disclosing it to the firm’s clients. Other services that Mr. Andrew Roberson may recommend include insurance
products sold through Tarkenton Financial. Mr. Roberson markets his Emerson-related advisory services through
the DBA, Diamond Mountain Financial, LLC.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Andrew Roberson may receive 12(b)-1 fees from the administrative fees a client pays
to a mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Dominic Baldini is Mr. Andrew Roberson’s supervisor. The firm maintains on file in its offices reports of the
advisory representative’s proprietary trading activities and the formulation of his recommendations for the
regulator to review at will.
Item 7. State Registration requirements.
87
Mr. Andrew Roberson maintains registration as a representative of his firm with the state of California, among
others.
88
Christian Truglio
Born 1991
CRD # 8156895
Item 2. Educational Background and Business Experience:
Education & Licensing:
Bachelor of Science in Management from Boston College (Carroll School of Management), Class of 2014
Business background:
- Emerson Equity LLC – Registered Representative (RR) (September 2025– Present); Investment Adviser
Representative (IAR) (September 2025 – Present)
- Artisanal Ventures (Investment Related) -- Head of Operations (Jan 2025 – May 2025)
- Sage Collective (Investment Related – VP Finance and Operations (Aug 2023 – Dec 2024)
- Unemployed (Aug 2022 – Jul 2023)
- Stress-Free Auto Care (Not Investment Related) – Founder/COO (Jan 2019 – Jul 2022)
- CarDash (Not Investment Related) – VP Finance and Operations (Jan 2018 – Dec 2018)
- Foundation Capital (Investment Related) – Fund Analyst (Sep 2016 – Dec 2017)
- Deloitte (Not Investment Related) – Consultant (Sep 2014 – Aug 2016)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Mr. Truglio:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? No.
Are there events disclosed about this broker? No.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Truglio recommends a service to advisory clients, and he himself will
be the paid provider of that recommended service, such a situation inherently creates a conflict of interest. As a
fiduciary he must recommend only those services and products that are in a client’s own best interest, free of
any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it to
the firm’s clients. The services that Mr. Truglio may recommend include brokerage and tax services.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Truglio may receive 12(b)-1 fees from the administrative fees a client pays to a mutual
fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation creates a risk
for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Matt Larson is Mr. Truglio’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Mr. Truglio maintains registration as a representative of his firm with the state of New York, among others.
Abbud, Joseph
89
Born 1988
CRD # 8130728
Item 2. Educational Background and Business Experience:
Education & Licensing:
Master of Business Administration from University of Colorado, Denver Class of 2020
Bachelor of Science from Clark University Class of 2011
Business background:
Emerson Equity LLC – Registered Representative (RR) (July 2025 – Present); Investment Adviser Representative
(July 2025 – Present)
EchoStar Corporation/DISH Network – Program Manager II, Finance (December 2022 – Present)
Tkrm, Ltd. – Founder (March 2020 – May 2025)
Broad Institute of Harvard and MIT – Software Engineer (January 2012 – November 2018)
Item 3. Disciplinary Information.
The Investment Adviser Public Disclosure site states, regarding Joseph Abbud:
Is this Investment Adviser Representative currently suspended with any jurisdiction? No.
Are there events disclosed about this Investment Adviser Representative? Yes – 1 Final.
Are there events disclosed about this broker? Yes – 1 Final.
Item 4. Other Business Activities.
As noted above in Part 2A, whenever Mr. Joseph Abbud recommends a service to advisory clients, and he himself
will be the paid provider of that recommended service, such a situation inherently creates a conflict of interest.
As a fiduciary he must recommend only those services and products that are in a client’s own best interest, free
of any influence of possible gain for himself. The firm addresses this possible conflict of interest by disclosing it
to the firm’s clients. The services that Mr. Joseph Abbud may recommend include brokerage products.
Item 5. Additional Compensation.
As described in Part 2A, Mr. Joseph Abbud may receive 12(b)-1 fees from the administrative fees a client pays to
a mutual fund. If he recommends the purchase of mutual funds to his advisory clients, that recommendation
creates a risk for a conflict of interest, due to the 12(b)-1 fees that he may realize.
Item 6. Supervision.
Dominic Baldini is Mr. Joseph Abbud’s supervisor. The firm maintains on file in its offices reports of the advisory
representative’s proprietary trading activities and the formulation of his recommendations for the regulator to
review at will.
Item 7. State Registration requirements
Mr. Joseph Abbud maintains registration as a representative of his firm with the state of Colorado, among others.
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