Overview
- Headquarters
- Madison, WI
- Average Client Assets
- $1.8 million
- Minimum Account Size
- $250,000
- SEC CRD Number
- 111234
Fee Structure
Primary Fee Schedule (ENRICH FINANCIAL PARTNERS FORM ADV PART 2 BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.10% |
| $500,001 | $1,000,000 | 0.80% |
| $1,000,001 | $5,000,000 | 0.60% |
| $5,000,001 | $10,000,000 | 0.40% |
| $10,000,001 | $20,000,000 | 0.30% |
| $20,000,001 | and above | 0.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $9,500 | 0.95% |
| $5 million | $33,500 | 0.67% |
| $10 million | $53,500 | 0.54% |
| $50 million | $158,500 | 0.32% |
| $100 million | $283,500 | 0.28% |
Clients
- HNW Share of Firm Assets
- 94.67%
- Total Client Accounts
- 1,636
- Discretionary Accounts
- 1,635
- Non-Discretionary Accounts
- 1
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection
Regulatory Filings
Primary Brochure: ENRICH FINANCIAL PARTNERS FORM ADV PART 2 BROCHURE (2026-03-19)
View Document Text
ENRICH FINANCIAL PARTNERS LLC
FORM ADV – PART 2A BROCHURE
EnRich Financial Partners LLC
6502 Grand Teton Plaza, Suite 201
Madison, WI 53719
Phone (608) 275-3442 / Fax (608) 275-3445
www.enrichpartners.com
March 19, 2026
This Brochure provides information about the qualifications and business practices of EnRich Financial
Partners LLC ("EnRich"). If you have any questions about the contents of this Brochure, please contact
EnRich at (608) 275-3442. The information in this Brochure has not been approved or verified by the United
States Securities and Exchange Commission ("SEC") or by any state securities authority.
EnRich is a registered investment adviser. Registration of an investment adviser does not imply any certain
level of skill or training.
Additional information about EnRich (CRD No. 111234), including a copy of its Form ADV Part 1, is available
on the SEC's website at www.adviserinfo.sec.gov.
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ITEM 2 – MATERIAL CHANGES
In this section, EnRich Financial Partners LLC (“EnRich”) discusses only material changes since the last annual
update of its Brochure. Each year, pursuant to SEC rules, EnRich will ensure that clients receive a summary of
all material changes, if any, to this and subsequent Brochures within 120 days of the close of its fiscal year.
EnRich may also provide other ongoing disclosure information about material changes as necessary. EnRich
will provide clients its brochure, at any time, without charge.
In this update we:
• Updated our assets under management in Item 4.
Additional Information
EnRich’s Brochure is available free of charge by contacting EnRich at (608) 275-3442.
Additional information about EnRich is also available via the SEC’s web site www.adviserinfo.sec.gov. The
SEC’s web site also provides information about any persons affiliated with EnRich who are registered, or are
required to be registered, as one of its investment adviser representatives of its firm.
(Brochure Date: 03/19/2026)
(Date of Most Recent Annual Updating Amendment: 03/19/2026)
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ITEM 3 – TABLE OF CONTENTS
ITEM 2 – MATERIAL CHANGES ........................................................................................................ 2
ITEM 3 – TABLE OF CONTENTS ........................................................................................................ 3
ITEM 4 – ADVISORY BUSINESS ......................................................................................................... 4
ITEM 5 – FEES AND COMPENSATION .............................................................................................. 9
ITEM 6 – PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT ........................ 12
ITEM 7 – TYPES OF CLIENTS/MINIMUM ACCOUNT SIZE ......................................................... 12
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ........ 12
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ........................ 17
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING .............................................................................................................. 18
ITEM 12 – BROKERAGE PRACTICES .............................................................................................. 19
ITEM 13 – REVIEW OF ACCOUNTS AND REPORTS ..................................................................... 22
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ................................................ 22
ITEM 15 - CUSTODY ........................................................................................................................... 23
ITEM 16 – INVESTMENT DISCRETION ........................................................................................... 23
ITEM 17 – VOTING CLIENT SECURITIES ....................................................................................... 24
ITEM 18 – FINANCIAL INFORMATION ........................................................................................... 24
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ITEM 4 – ADVISORY BUSINESS
EnRich Financial Partners LLC ("EnRich”) is a federally registered investment adviser which offers
comprehensive financial consulting and analysis, portfolio management, financial coaching, and
manager search and monitoring services. EnRich has been in business since 2003 and is owned by
Elaine Beckett Rich and Christopher D. Rich. EnRich is not under common control with any other firm,
nor does it control any other firm.
PARTNERSHIP ADVISORY SERVICES
Partnership Advisory Services include: "Strategic Partnership Services," which are financial planning and
investment consulting in nature; "Portfolio Management Services," which include investment
management; and "Full Partnership Services," which is a combination of Strategic Partnership Services
and Portfolio Management Services. Clients may choose the level of services to be provided by EnRich
through the client's applicable Advisory Services Retainer Agreement.
All services start with EnRich obtaining client information and determining which services will best
suit client’s needs and objectives.
Strategic Partnership Services
Strategic Partnership Services offered by EnRich can include any combination of the following topics, as
agreed on between EnRich and the client:
1. Investment Consulting - analysis of current investments and expected new ownership or
sale of investments and recommendations of an investment allocation designed to meet
the client's goals.
2. Retirement Funding and Income Analysis - analysis of retirement needs of the client, and
assistance with investment budgets designed to meet retirement goals.
3. Education Funding Analysis - analysis of the projected amount needed to fund education
of children or grandchildren, and assistance with budgeting for the same.
4. Life Insurance Needs Analysis - analysis to determine recommended coverage
amounts and benefits and costs of existing policies.
5. Disability Insurance Needs Analysis - analysis to review existing or proposed disability
insurance coverage with the client in relation to the client's expected wage and income
needs during disability.
EnRich may offer other Strategic Partnership Services as agreed upon by the client and EnRich.
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Financial Coaching Services
EnRich also offers Financial Coaching Services which is designed to assist the client in making financial
decisions and achieving peace of mind. The scope of the engagement is defined individually based upon
client needs. This service may or may not include a written analysis and may not be comprehensive.
"Specific Analysis" entails performing a specific analysis of individual assets such as stocks, bonds,
mutual funds, annuities, life insurance and health insurance policies. The service may also include
assisting employers and/or employees in providing advice on the types of investment plans and the
selection of various types of investments within a plan. Advice may also be provided concerning the
management of death proceeds from life insurance policies and the distribution from profit sharing
plans and/or retirement plans or any other analysis requested by the client.
Portfolio Management Services
Portfolio Management Services are investment advisory services offered by EnRich allowing clients
to maintain an account consisting generally of mutual funds and exchange-traded funds ("ETFs").
EnRich will obtain financial data from the client and assist the client in determining investment objectives
and restrictions. EnRich's advisors will regularly monitor the account and make investment strategy
recommendations based on the specific needs and investment goals of the client. The client shall have
reasonable access to one of EnRich's investment professionals to discuss their account.
EnRich shall be provided with written authority to determine which securities and the amounts of
securities that are bought or sold. However, clients may place reasonable limitations on its discretionary
authority in writing. Clients may change/amend these limitations, in writing, at any time.
The advisory Portfolio Management Services generally include the following:
1. Establishment of investment objectives consistent with the client's risk tolerance,
financial needs, and goals;
2. Establishment of asset allocation mix based on the client's financial position, cash flow,
risk preferences, and time horizon;
3. Assistance with setting up of accounts at the custodial level;
4. Implementation of all trades and account management;
5. Preparation of quarterly performance reports on all accounts; and
6. Periodic review meetings to update the client's ongoing financial planning and
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investment progress.
In some cases, EnRich may contract with third parties to provide certain reports or use those provided by
the funds and other securities.
Investment Management to Retirement Investors
EnRich has special and additional fiduciary responsibilities under the Title I of Employee Retirement
Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code Section 4975 (“IRC 4975”), as
applicable, when it provides investment advice or investment management services to individual
retirement account owners, ERISA plans, and ERISA plan participants. As such, EnRich is subject to
specific duties and obligations that include, among other things, prohibited transaction rules which are
intended to prohibit fiduciaries from acting on conflicts of interest. EnRich must either avoid or
eliminate the conflict or rely upon a prohibited transaction exemption.
EnRich is a fiduciary, when, for example, its advisors recommend a distribution or transfer (a “rollover”)
of a client’s tax-qualified ERISA-governed account including an IRA, to it for management. If it
recommends a roll over from a retirement plan account or a transfer of an IRA account into an account
to be managed by it, such a recommendation creates a conflict of interest if the retirement investor
accepts the recommendation as EnRich earns a fee on the market value of the rollover or transferred
IRA which would not be earned if the money was not placed under its management. To address this
conflict it must comply with the impartial conduct standards that require it to:
1. Always act in the client’s best interest by:
a. Meeting a professional standard of care when making investment recommendations (give
prudent advice);
b. Never putting its financial interests ahead of the client’s when making
recommendations (give loyal advice);
2. Avoid misleading statements about conflicts of interest, fees, and investments;
3. Follow policies and procedures designed to ensure that it gives advice that is in the
client’s best interest;
4. Charge no more than is reasonable for its services; and
5. Give the client basic information about its conflicts of interest.
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Retirement Plan Management and Consulting Service
EnRich also provides retirement plan services, pursuant to which it assists sponsors of self-directed
retirement plans with the selection and/or monitoring of investment alternatives from which plan
participants shall choose in self-directing the investments for their individual plan retirement accounts.
The nature of the engagement for retirement plan services will be set forth in the Advisory Services
Retainer Agreement. To the extent requested by the plan sponsor, EnRich may also provide participant
education designed to assist participants in identifying the appropriate investment strategy for their
retirement plan accounts.
Estate Planning
EnRich offers clients the ability to obtain estate planning documents such as a will, trust, financial
power of attorney, and medical/healthcare power of attorney. EnRich offers this service through a
third-party provider. The provider only prepares the documentation but does not provide legal advice
and is not the client’s attorney. EnRich also does not provide legal advice to the client, and the client
should consult with his/her attorney for estate planning legal advice.
General Information
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated
above, to the extent requested by a client, EnRich may provide financial planning and related consulting
services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc.
EnRich does not serve as an attorney or accountant, and no portion of its services should be construed
as legal or accounting services. Accordingly, EnRich does not prepare estate planning documents or tax
returns. To the extent requested by a client, EnRich may recommend the services of other professionals
for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance agents,
etc.), including representatives of EnRich in their separate individual capacities as licensed insurance
agents.
The client is under no obligation to engage the services of any such recommended professional. The
client retains absolute discretion over all such implementation decisions and is free to accept or reject
any recommendation from EnRich and/or its representatives. If the client engages any recommended
unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees
to seek recourse exclusively from and against the engaged professional.
Independent Managers. EnRich may allocate (and/or recommend that the client allocate) a portion of a
client's investment assets among unaffiliated independent investment managers in accordance with
the client's designated investment objective(s). In such situations, the independent manager(s) shall
have day- to-day responsibility for the active discretionary management of the allocated assets. EnRich
shall continue to render investment advisory services to the client relative to the ongoing monitoring
and review of account performance, asset allocation and client investment objectives. Factors which
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EnRich shall consider in recommending independent manager(s) include the client's designated
investment objective(s), management style, performance, reputation, financial strength, reporting,
pricing, and research.
The investment management fees charged by the designated independent manager(s), together with
the fees charged by the corresponding designated broker-dealer/custodian of the client's assets, are
exclusive of, and in addition to, EnRich's ongoing investment advisory fee. The total advisory fee for an
account utilizing independent managers shall not exceed 2.1% per annum.
Retirement Plan Rollovers – No Obligation. A person leaving an employer typically has four options
regarding an existing retirement plan (and may engage in a combination of these options): (1) leave the
money in the former employer's plan, if permitted, (2) roll over the assets to the new employer's plan, if
one is available and rollovers are permitted, (3) roll over to an Individual Retirement Account ("IRA"), or
(4) cash out the account value (which could, depending upon the client's age, result in adverse tax
consequences). If EnRich recommends that a client roll over their retirement plan assets into an account
to be managed by EnRich, such a recommendation creates a conflict of interest if EnRich will earn a new
(or increase its current) advisory fee as a result of the rollover. No person is under any obligation to roll
over retirement plan assets to an account managed by EnRich.
Non-Discretionary Service Limitations. Clients that determine to engage EnRich on a non-discretionary
investment advisory basis must accept that EnRich cannot affect any account transactions without
obtaining prior consent to such transaction(s) from the client. Thus, in the event that EnRich would like
to make a transaction for a client's account (including in the event of an individual holding or general
market correction), and the client is unavailable, EnRich will be unable to effect the account
transaction(s) (as it would for its discretionary clients) without first obtaining the client's consent.
eMoney Advisor Platform. EnRich may provide its clients with access to an online platform hosted by
"eMoney Advisor" ("eMoney"). The eMoney platform allows a client to view a complete asset allocation,
including those assets that EnRich does not manage (the "Excluded Assets"). EnRich does not provide
investment management, monitoring, or implementation services for the Excluded Assets. Therefore,
EnRich shall not be responsible for the investment performance of the Excluded Assets. Rather, the
client (and their other advisor(s), if any, that maintain management authority for the Excluded Assets)
shall be exclusively responsible for such investment performance. The eMoney platform also provides
access to other types of information and functionality, including financial planning concepts and
applications, which should not, in any manner whatsoever, be construed as services, advice, or
recommendations provided by EnRich. EnRich is not responsible for any adverse results a client may
experience if the client engages in financial planning or other functions available on the eMoney
platform without EnRich's assistance or oversight.
Outside Assets. If clients request, and we agree, we will provide, an as additional service, discretionary
investment advice for certain “outside accounts.” These outside accounts are primarily plan participant
retirement accounts. We will regularly review the available investment options in these accounts,
monitor them, and rebalance in the same way we do other accounts, though using different tools, as
necessary. We use a third-party platform to facilitate the management of most of these outside
accounts.
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For assets we manage through this third-party platform, clients are emailed a link by the platform
allowing the client to enter their credentials. By linking the account on the platform, we are allowed to
view the account allocation, and when deemed necessary by us, rebalance the outside accounts. In these
instances, we do not have access to clients’ credentials and therefore, do not have custody of the assets
held in these accounts. We are not affiliated with the third-party platform in any way, and do not receive
any compensation for using the platform. If you would like us to provide this additional service, you will
sign an addendum to your current agreement or, for new clients, Schedule B Additional Services for
Outside Accounts, which explains this service and our fee.
In certain circumstances, we are unable to utilize the third-party platform for the management of the
outside assets. In these instances, we manage the assets utilizing the clients’ login credentials. We have
determined that EnRich does not have the ability to direct assets outside of the clients’ accounts, and
thus EnRich does not claim custody of these assets.
Client Obligations. In performing its services, EnRich shall not be required to verify any information
received from the client or from the client's other professionals, and is expressly authorized to rely
thereon. Moreover, each client is advised that it remains their responsibility to promptly notify EnRich if
there is ever any change in their financial situation or investment objectives for the purpose of reviewing,
evaluating, or revising EnRich's previous recommendations or services.
Assets Under Management
As of December 31, 2025, EnRich had $556,514,357 in assets under management on a discretionary basis
and $297,683 in assets under management on a non-discretionary basis, for a total of $556,812,040 in
assets under management. EnRich also had $20,813,384 assets under advisement. Assets under
management and advised funds totaled $577,625,424.
ITEM 5 – FEES AND COMPENSATION
Partnership Advisory Services Fees
Full Partnership and Portfolio Management Services. Rates for Full Partnership and Portfolio
Management Services are based on a tiered fee schedule (details below) where the rate is reduced on
subsequent amounts as the total value of assets under management increase.
The initial fee for new accounts is based on the value of securities or cash deposited and prorated for
the previous quarter to the start date. Subsequent fee payments are due and will be assessed at the
beginning of each quarter based on the value of the account assets (securities, cash, and cash
equivalents) under management as of the close of business on the last business day of the preceding
quarter. If a client establishes a margin loan or a securities-based loan with their broker, EnRich bills on
the gross assets under management meaning, the margin balance is not deducted from the account
balance before the fee is applied.
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The Full Partnership and Portfolio Management Services fee schedule is as follows:
Market Value of Client
Assets Under Management
Negotiated
Annual Fee
On the first $500,000
1.10%
On the next $500,000
0.80%
On the next $4,000,000
0.60%
On the next $5,000,000
0.40%
On the next $10,000,000
0.30%
On all amounts over $20,000,000
0.25%
The above fees are subject to negotiation between EnRich and the applicable client.
Actual fees may differ. The actual fee will be set forth in the Advisory Services Retainer Agreement
between EnRich and the applicable client. If we manage a client’s outside accounts, our fee will be
calculated according to our fee schedule in Schedule A of our Advisory Services Retainer Agreement.
When we provide additional services to the outside accounts, we will not directly debit our fee from the
outside account. Instead, our fee will be paid from the client’s taxable account(s). If the client does not
have a taxable account, our fee is billed directly to the client.
Clients will be charged in advance at the beginning of each calendar quarter based on the previous
quarter-end market value. EnRich’s fee will be one-fourth of the applicable annual fee rate set forth
above multiplied by the fair market value of the assets in the account, determined by EnRich on the last
trading day of each calendar quarter. Fees are prorated for accounts opened or terminated during the
quarter. No portion of the fee will be credited to the client for the current calendar quarter should any
withdrawals from the portfolio occur in the same calendar quarter.
Strategic Partnership Services. The fee for this service is negotiable and is based on the anticipated
complexity and amount of work involved to complete the analysis. An annual fee quote is provided in
advance and fees are payable quarterly in advance. Strategic Partnership engagements are only able to
be terminated at a quarter-end and EnRich does not provide for any refunds in the event a client
terminates services during a quarter. Under certain circumstances, fees for Strategic Partnership
Services may be waived by EnRich in its sole discretion.
Coaching Services. Fees are $300 to $750 per hour or a negotiated flat project fee depending on the
anticipated complexity of the analysis and the anticipated amount of work that will be involved to
complete an analysis or to provide the coaching. The hourly rate is established with the client prior to
rendering the service. A six-hour minimum is preferred.
Coaching Services may be terminated by written notice to EnRich. EnRich will determine the number of
hours spent performing the service prior to receiving the written termination notice from the client.
Those hours will be billed at the predetermined hourly rate. The client will be responsible for any
amount earned by EnRich but not paid to the date of termination. Under certain circumstances, fees
for Coaching Services may be waived by EnRich in its sole discretion.
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Retirement Plan Management and Consulting Service Fees
For Retirement Plan Consulting Services, EnRich charges a quarterly fee and will bill clients, in advance,
based on the following fee schedule:
Market Value of Client Account
Annual
Fee
On the first $500,000
1.10%
On the next $500,000
0.80%
On the next $4,000,000
0.60%
On the next $5,000,000
0.40%
On the next $10,000,000
0.30%
On all amounts over $20,000,000
0.25%
In some cases, EnRich may instead charge a flat rate. The fees are subject to negotiation between
EnRich and the applicable client. Actual fees may differ. The actual fee will be set forth in the Advisory
Services Retainer Agreement between EnRich and the applicable client. In some cases, EnRich will bill on
other than a quarterly basis. The client agreement will specify the payment arrangements.
Additional Costs and Fees
As discussed below, unless the client directs otherwise or an individual client's circumstances require,
EnRich shall generally recommend that Schwab serve as the broker-dealer/custodian for client
investment advisory assets. Schwab generally does not charge clients for custody services but is
compensated by charging clients commissions or other fees on trades that it executes or that settle into
a client’s Schwab Account. Certain trades (for example, many mutual funds and U.S. exchange-listed
equities and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated
by earning interest on the uninvested cash in a client’s account in Schwab’s Cash Features Program.
These fees are in addition to EnRich's investment advisory fee.
Clients who engage EnRich will also incur, relative to all mutual fund and ETF purchases, charges imposed
at the fund level (e.g. management fees and other fund expenses). Clients and prospective clients should
also be aware that sale transactions in certain mutual funds made shortly after the purchase of the fund
may result in a fee or short-term trading penalty in a client's account. Short-term sales may, for example,
occur when a newly established fund position in a client's account is batched with sale orders in the same
fund for other client accounts for the purpose of rebalancing the account positions in that fund.
In connection with estate planning services described in Item 4, when a third-party provider is used by
a client to provide estate planning documents, the fee for said services may be negotiable, and the
third-party provider will be paid by the client.
Termination of Advisory Relationship. Advisory Services Retainer Agreement may be canceled at any
time, by either party, for any reason upon thirty (30) days’ advance written notice. Upon termination of
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any client agreement, fees will be prorated for the number of elapsed days of the billing period before
termination. Any unearned fees will be automatically refunded to the client.
Cash Positions. EnRich may maintain cash positions for defensive or tactical purposes. All cash
positions (money markets, etc.) shall be included as part of assets under management for purposes
of calculating EnRich's advisory fee.
Other Fees and Charges. Brokerage and execution costs associated with transactions will be the
obligation of the client. In addition, clients will pay other fees and expenses including: certain transfer
taxes, SEC fees, exchange fees, electronic fund and wire transfer fees, auction fees, debit balances,
margin interest, certain odd-lot differentials and mutual fund short-term redemption fees; trade away
fees, etc.
Fee Arrangements. Clients may elect to have EnRich's advisory fees deducted from their custodial
account. Both EnRich's Advisory Services Retainer Agreement and the custodial/clearing agreement
authorize the custodian to debit the account for the amount of EnRich's investment advisory fee and to
directly remit that management fee to EnRich in compliance with regulatory procedures. EnRich has
discretion to select securities to be sold in order to cover its fees and a client may incur tax
consequences. In the limited event that EnRich bills the client directly, payment is due upon receipt of
EnRich's invoice.
ITEM 6 – PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
EnRich does not charge performance-based fees (fees which are based on the share of capital gain or
capital appreciation) for its management services; however, its fees will generally increase as the
aggregate value of a client account increases, or decrease if the value of the account decreases, subject
to its fee schedule. EnRich does not participate in side-by-side management. Side-by-side management
refers to the practice of managing accounts that are charged performance-based fees while at the same
time managing accounts that are not charged a performance-based fee.
ITEM 7 – TYPES OF CLIENTS/MINIMUM ACCOUNT SIZE
EnRich makes its advisory services available to a wide variety of clients including, but not limited to,
individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations
and other business entities.
For portfolios supervised on a continuous, discretionary basis, EnRich generally imposes an initial
minimum asset value of $250,000. Full Partnership Service clients agree to have at least 80% of their
investable assets managed by EnRich. However, the minimum can be waived by EnRich depending upon
the type of account, kind of securities in the account, the dollar value of such securities, the projected
nature of trading and required monitoring for the account, other services anticipated for the account,
and the amount of work necessary to manage the account.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Methods of Analysis
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EnRich's security analysis method is primarily, but not limited to, fundamental analysis (evaluating
securities based upon its historical and projected financial performance). EnRich uses research material
provided by third parties, including security analysts, non-affiliated investment management firms,
economists, investment advisors, and rating services such as Morningstar.
EnRich's advisors attend conferences and teleconferences with investment managers, and investment
manager representatives.
EnRich's methods of analysis and investment strategies do not present any significant or unusual risks.
However, every method of analysis has its own inherent risks. To perform an accurate market analysis,
EnRich must have access to current/new market information. EnRich has no control over the
dissemination rate of market information; therefore, unbeknownst to EnRich, certain analyses may be
compiled with outdated market information, severely limiting the value of EnRich's analysis.
Furthermore, an accurate market analysis can only produce a forecast of market values. There can be
no assurances that a forecasted change in market value will materialize into actionable and/or
profitable investment opportunities.
Investment Strategies
EnRich's primary investment strategy - Long Term Purchases - is a fundamental investment strategy.
However, every investment strategy has its own inherent risks and limitations. For example, longer
term investment strategies require a longer investment time period to allow for the strategy to
potentially develop. Shorter-term investment strategies require a shorter investment time period to
potentially develop but, as a result of more frequent trading, may incur higher transactional costs when
compared to a longer-term investment strategy.
Availability of Mutual Funds or ETFs. EnRich will attempt to select, recommend and/or retain mutual
fund share classes that are in the best interest of the client considering specific custodial and/or mutual
fund company constraints, material tax consideration, and/or systematic investment plans. While EnRich
may recommend allocating investment assets to mutual funds or ETFs that are not available directly to
the public, EnRich may also recommend that clients allocate investment assets to publicly-available
mutual funds or ETFs that the client could obtain without engaging a registered investment advisor.
Other mutual funds, such as those issued by Dimensional Fund Advisors ("DFA"), are generally only
available through selected registered investment advisers. EnRich may allocate client investment assets
to DFA mutual funds.
Therefore, upon the termination of EnRich's services to a client, restrictions regarding transferability
and/or additional purchases of, or reallocation among DFA funds may apply.
Margin / Securities-Based Loans. Upon client request, EnRich may recommend that a client establish a
margin loan or a securities-based loan (collectively, "SBLs") with the client's broker-dealer/custodian or
their affiliated banks (each, an "SBL Lender") to access cash flow. Unlike a traditional real estate-
backed loan, an SBL has the potential benefit of enabling borrowers to access to funds in a shorter
period of time, providing greater repayment flexibility, and may also result in the borrower receiving
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certain tax benefits. Clients interested in learning more about the potential tax benefits of borrowing
money on margin should consult with an accountant or tax advisor.
The terms and conditions of each SBL are contained in a separate agreement between the client and the
SBL Lender selected by the client, which terms and conditions may vary from client to client. Borrowing
funds on margin is not suitable for all clients and is subject to certain risks, including but not limited to:
increased market risk, increased risk of loss, especially in the event of a significant downturn; liquidity
risk; the potential obligation to post collateral or repay the SBL if the SBL Lender determines that the
value of collateralized securities is no longer sufficient to support the value of the SBL; the risk that the
SBL Lender may liquidate the client's securities to satisfy its demand for additional collateral or
repayment / the risk that the SBL Lender may terminate the SBL at any time. Before agreeing to
participate in an SBL program, clients should carefully review the applicable SBL agreement and all risk
disclosures provided by the SBL Lender including the initial margin and maintenance requirements for
the specific program in which the client enrolls, and the procedures for issuing "margin calls" and
liquidating securities and other assets in the client's accounts.
If EnRich recommends that a client apply for an SBL instead of selling securities that EnRich manages for
a fee to meet liquidity needs, the recommendation presents an ongoing conflict of interest because
selling those securities (instead of leveraging those securities to access an SBL) would reduce the
amount of assets to which EnRich's investment advisory fee percentage is applied, and thereby reduce
the amount of investment advisory fees collected by EnRich. Likewise, the same ongoing conflict of
interest is present if a client determines to apply for an SBL on their own initiative. These ongoing
conflicts of interest would persist as long as EnRich has an economic disincentive to recommend that
the client terminate the use of SBLs. Clients are therefore reminded that they are not under any
obligation to employ the use of SBLs, and are solely responsible for determining when to use, reduce,
and terminate the use of SBLs. Although EnRich seeks to disclose all conflicts of interest related to its
recommended use of SBLs and related business practices, there may be other conflicts of interest that
are not identified above. Clients are therefore reminded to carefully review the applicable SBL
agreement and all risk disclosures provided by the SBL Lender as applicable, and contact EnRich's Chief
Compliance Officer with any questions regarding the use of SBLs.
Investment Risk
Investing in securities involves risk of loss that clients should be prepared to bear.
Different types of investments involve varying degrees of risk, and it should not be assumed that future
performance of any specific investment or investment strategy (including the investments and/or
investment strategies recommended or undertaken by EnRich) will be profitable or equal any specific
performance level(s).
Each type of investment has its own unique set of risks associated with it. The following provides a short
description of some of the underlying risks associated with the types of investments that EnRich
employs:
Market Risk. The price of a security may drop in reaction to tangible and intangible events and
conditions. This type of risk may be caused by external factors (such as economic or political factors),
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but may also be incurred because of a security's specific underlying investments. Additionally, each
security's price can fluctuate based on market movement, which may or may not be due to the
security's operations or changes in its true value. For example, political, economic and social conditions
may trigger market events which are temporarily negative, or temporarily positive.
Unsystematic Risk. Unsystematic risk is the company-specific or industry-specific risk in a portfolio that
the investor bears. Unsystematic risk is typically addressed through diversification. However, as
indicated above, diversification does not guarantee better performance and cannot eliminate the risk of
investment losses.
Value Investment Risk. Value stocks may perform differently from the market as a whole and following a
value-oriented investment strategy may cause a portfolio to underperform growth stocks.
Growth Investment Risk. Prices of growth stocks tend to be higher in relation to their companies'
earnings and may be more sensitive to market, political and economic developments than other stocks,
making their prices more volatile.
Small Company Risk. Securities of small companies are often less liquid than those of large companies
and this could make it difficult to sell a small company security at a desired time or price. As a result,
small company stocks may fluctuate relatively more in price. In general, small capitalization
companies are more vulnerable than larger companies to adverse business or economic
developments and they may have more limited resources.
Commodity Risk. The value of commodity-linked derivative instruments may be affected by changes in
overall market movements, commodity index volatility, changes in interest rates, or factors affecting a
particular industry or commodity, such as drought, floods, weather, livestock disease, embargoes,
tariffs, and international economic, political, and regulatory developments.
Foreign Securities and Currencies Risk. Foreign securities prices may decline or fluctuate because of: (i)
economic or political actions of foreign governments, and/or (ii) less regulated or liquid securities
markets. Investments holding these securities are also exposed to foreign currency risk (the possibility
that foreign currency will fluctuate in value against the U.S. dollar).
Interest Rate Risk. Fixed income securities and fixed income-based securities are subject to interest rate
risk because the prices of fixed income securities tend to move in the opposite direction of interest
rates. When interest rates rise, fixed income security prices tend to fall.
When interest rates fall, fixed income security prices tend to rise. In general, fixed income securities with
longer maturities are more sensitive to these price changes.
Inflation Risk. When any type of inflation is present, a dollar at present value will not carry the same
purchasing power as a dollar in the future, because that purchasing power erodes at the rate of
inflation.
Reinvestment Risk. Future proceeds from investments may have to be reinvested at a potentially lower
rate of return (i.e. interest rate), which primarily relates to fixed income securities.
Credit Risk. The issuer of a security may be unable to make interest payments and/or repay principal
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when due. A downgrade to an issuer's credit rating or a perceived change in an issuer's financial
strength may affect a security's value and impact performance. Credit risk is considered greater for
fixed income securities with ratings below investment grade. Fixed income securities that are below
investment grade involve higher credit risk and are considered speculative.
Call Risk. During periods of falling interest rates, a bond issuer will call or repay a higher-yielding
bond before its maturity date, forcing the investment to reinvest in bonds with lower interest rates
than the original obligations.
Regulatory Risk. Changes in laws and regulations from any government can change the market value of
companies subject to such regulations. Certain industries are more susceptible to government regulation.
For example, changes in zoning, tax structure or laws may impact the return on investments.
Mutual Fund Risk. Mutual funds are operated by investment companies that raise money from
shareholders and invest it in stocks, bonds, and/or other types of securities. Each fund will have a
manager that trades the fund's investments in accordance with the fund's investment objective. Mutual
funds charge a separate management fee for their services, so the returns on mutual funds are reduced
by the costs to manage the funds. While mutual funds generally provide diversification, risks can be
significantly increased if the fund is concentrated in a particular sector of the market. Mutual funds
come in many varieties. Some invest aggressively for capital appreciation, while others are conservative
and are designed to generate income for shareholders. In addition, the client's overall portfolio may be
affected by losses of an underlying fund and the level of risk arising from the investment practices of an
underlying fund (such as the use of derivatives).
Exchange Traded Fund Risk. ETFs are marketable securities that are designed to track, before fees and
expenses, the performance or returns of a relevant index, commodity, bonds or basket of assets, like an
index fund. Unlike mutual funds, ETFs trade like common stock on a stock exchange. ETFs experience
price changes throughout the day as they are bought and sold. In addition to the general risks of
investing, there are specific risks to consider with respect to an investment in ETFs, including, but not
limited to: (1) an ETF's shares may trade at a market price that is above or below its net asset value; (2)
the ETF may employ an investment strategy that utilizes high leverage ratios; or (3) trading of an ETF's
shares may be halted if the listing exchange's officials deem such action appropriate, the shares are de-
listed from the exchange, or the activation of market-wide "circuit breakers" (which are tied to large
decreases in stock prices) halts stock trading generally.
Interval Fund Risk. An interval fund is a type of closed-end fund containing shares that do not trade on the
secondary market. Instead, the fund periodically offers to buy back a percentage of outstanding shares at
net asset value.
The rules for interval funds, along with the types of assets held, make this investment largely illiquid
compared with other funds. The primary reasons for investors to consider investing in interval funds
EnRich may utilize include, but are not limited to, gaining exposure to certain risk categories that provide
diversified sources of expected returns, part of which may be in the form of illiquidity premiums. Access
to the intended risk and expected return characteristics may not otherwise be available in more liquid,
traditional investment vehicles.
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Where appropriate, EnRich may utilize certain interval funds structured as non-diversified, closed-end
management investment companies, registered under the Investment Company Act of 1940.
Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on
withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will
be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to
tender shares when or in the amount desired, and the fund may suspend or postpone purchases.
Clients should carefully review the fund’s prospectus to more fully understand the interval fund
structure and the corresponding liquidity risks. Because these types of investments involve certain
additional risk, these funds will only be utilized when consistent with a client’s investment objectives,
individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided
where an investor has a short-term investing horizon and/or cannot bear the loss of some or all of the
investment.
Cryptocurrency Risk. Investments in cryptocurrencies involve a high degree of risk and may not be suitable
for all investors. Cryptocurrencies are highly speculative and volatile, and their value can fluctuate
significantly in short periods of time. Cryptocurrencies are subject to changing regulatory environments.
Digital assets are subject to cybersecurity threats, including hacking, phishing, and fraud. Losses due to
theft or loss of private keys may be irreversible. Unlike traditional financial markets, most cryptocurrency
markets are not regulated and lack the investor protections provided by the SIPC or other similar
safeguards.
EnRich does not guarantee the results of the advice given. Thus, significant losses can occur by investing in
any security, or by following any strategy, including those recommended or applied by EnRich.
ITEM 9 – DISCIPLINARY INFORMATION
EnRich is required to disclose any legal or disciplinary events that are material to a client's or
prospective client's evaluation of the firm, its business or the integrity of its management or associated
persons. Neither EnRich nor any of its associated persons has any reportable disciplinary events to
disclose.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Certain of EnRich's advisors are, in their individual capacities, licensed insurance agents, and may
recommend the purchase of certain insurance-related products on a commission basis. Clients can engage
certain of EnRich's representatives to purchase insurance products on a commission basis.
The recommendation by EnRich's advisors that a client purchase insurance commission products
presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend
investment products based on commissions received, rather than on a particular client's need. No client
is under any obligation to purchase any insurance products from EnRich's representatives. Clients are
reminded that they may purchase insurance products recommended by EnRich through other, non-
affiliated insurance agents.
Neither EnRich, nor its advisors or supervised persons are: registered or have an application pending
to register, as a broker-dealer or a registered representative of a broker-dealer; are registered or
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have an application pending to register as a futures commission merchant, commodity pool operator,
a commodity trading advisor, or a representative of the foregoing; or receive, directly or indirectly,
compensation from investment advisors recommended or selected for clients.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING
Code of Ethics
EnRich has adopted a Code of Ethics that sets forth high ethical standards of business and professional
conduct which it requires its employees to follow. The Code of Ethics outlines proper conduct related to
all services provided to clients by EnRich and its associated persons and includes guidelines for
compliance with applicable laws and regulations governing its practice. EnRich’s goal is to always
protect its clients’ interests and demonstrate its commitment to its fiduciary duties of honesty, good
faith and fair dealing.
The owners of EnRich may host clients at their personal vacation property. Its use is intended solely for
hospitality purposes and is not offered as compensation, a gift, or as part of any advisory arrangement.
Any use of the property is offered at the sole discretion of the owners and is not intended to influence
investment decisions or create a conflict of interest.
Clients or prospective clients may obtain a free copy of EnRich’s Code of Ethics upon request by
contacting EnRich at (608) 275-3442.
Personal Securities Transactions and Interests
Through its professional activities, EnRich and its supervised persons are exposed to potential conflicts of
interest and the Code of Ethics contains provisions designed to mitigate certain of these potential
conflicts by governing the personal securities transactions of certain of its employees, officers, and
directors. In particular, the Code of Ethics governs the conduct of certain "access persons" in
circumstances where EnRich or access persons may desire to purchase or sell securities for their personal
accounts that are identical to those recommended by EnRich to its clients. For these purposes, the Code
of Ethics defines an "access" person as a supervised person of EnRich that (1) has access to nonpublic
information regarding any clients' purchase or sale of securities, (2) has access to nonpublic information
regarding the portfolio holdings of any fund the adviser or its control affiliates manage or sponsor, or (3)
is involved in making securities recommendations (or has access to such recommendations) to clients
that are nonpublic.
Access persons' trades must be executed in a manner consistent with the following principles: the
interests of client accounts will at all times be placed first; all personal securities transactions will be
conducted in such manner as to avoid any actual or potential conflict of interest or any abuse of an
individual's position of trust and responsibility; access persons must not take inappropriate advantage
of their positions; and preclearance of access persons' transactions in securities in a limited offering or
private placement is required.
Access persons must submit quarterly reports regarding securities transactions and newly opened
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accounts, as well as annual reports regarding holdings and existing accounts. EnRich monitors access
persons' personal trading activity at least quarterly to ensure compliance with internal control policies
and procedures and its Code of Ethics.
Neither EnRich nor its access persons have any material financial interest in client transactions beyond
the provision of investment advisory services or other services as disclosed in this Brochure. EnRich does
not engage in principal trading (i.e., the practice of selling stock to advisory clients from its inventory or
buying stocks from advisory clients into its inventory). Nor does EnRich engage in agency cross
transactions.
ITEM 12 – BROKERAGE PRACTICES
Directed Brokerage and Soft Dollar Arrangements
EnRich has established a brokerage relationship with Charles Schwab & Co., Inc. (“Schwab”), a
registered broker-dealer, member SIPC after it acquired TD Ameritrade, Inc. EnRich recommends that
clients use Schwab for custodial and transaction services. EnRich is independently owned and operated
and is not affiliated with Schwab. Schwab will hold client assets in a brokerage account and buy and sell
securities when EnRich instructs them to. While EnRich requests that clients use Schwab as
custodian/broker, the client will decide whether to do so and will open its own account with Schwab by
entering into an account agreement directly with Schwab. Schwab offers a program that will
automatically invest the free credit balance in a client’s account into a liquid investment to earn interest
(a “Cash Program”) as described in the Cash Features Disclosure Statement provided by Schwab. When
a client participates in a Cash Program, cash will earn income while EnRich decides how best to invest
those funds for the longer term. If a client’s account utilizes a Cash Program, Schwab’s affiliated bank,
also is compensated by earning interest on the uninvested cash in your account.
There is no direct link between EnRich's recommendation of Schwab and the investment advice it gives
to its clients, although EnRich receives economic benefits through its participation in Schwab Advisor
Services™ that are typically not available to Schwab’s retail investors. These benefits include the
following products and services (provided without cost or at a discount) duplicate client statements and
confirmations; research related products and tools; consulting services; access to a trading desk
servicing advisor participants; access to block trading (which provides the ability to aggregate securities
transactions for execution and then allocate the appropriate shares to client accounts); the ability to
have advisory fees deducted directly from client accounts; access to an electronic communications
network for client order entry and account information; access to mutual funds with no transaction fees
and to certain institutional money managers; and discounts on compliance, marketing, research,
technology, and practice management products or services provided to EnRich by third-party vendors.
Schwab also offers to pay for certain business consulting and professional services received by EnRich's
related persons and may also pay or reimburse expenses (including travel, lodging, meals, and
entertainment expenses) for EnRich's personnel to attend conferences or meetings relating to Schwab
Advisor Services or to Schwab’s advisor custody and brokerage services generally. Some of the products
and services made available through Schwab Advisor Services may benefit EnRich but may not benefit
its client accounts. These products or services may assist EnRich in managing and administering client
accounts, including accounts not maintained at Schwab. Other services made available by Schwab are
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intended to help EnRich manage and further develop its business enterprise. The benefits received by
EnRich through participation in the Schwab Advisor Services do not depend on the amount of brokerage
transactions directed to Schwab. Clients should be aware, however, that the receipt of economic
benefits by EnRich or its related persons in and of itself creates a potential conflict of interest and may
indirectly influence EnRich's recommendation of Schwab for custody and brokerage services.
The custodians recommended by EnRich, other than Schwab, may also, among other services, carry
client accounts on their records, process transactions ordered by EnRich, provide computer access to
EnRich for client positions and provide quotes and data needed by EnRich for its reports to clients.
These services are provided to EnRich at minimal or no cost. EnRich believes that use of the
recommended firm(s) is a convenient means of obtaining efficient transaction executions, account data
and reporting services for securities positions. However, receipt of such services at minimal or no cost also
creates an inducement and conflict of interest for EnRich since referring clients to any other firm(s) may
result in higher reporting and overhead costs to EnRich. EnRich also on occasion provides advisory
services to certain client investments that are unable to be custodied by Schwab but are required to be
custodied by the vendor.
Clients should be aware the receipt of economic benefits by EnRich described above, in and of
themselves, create a conflict of interest and influences EnRich's recommendation of those service
providers for custody and brokerage service. Thus, the receipt of these services creates an
incentive and conflict of interest for EnRich when it recommends Schwab’s services. Other than the
services described above, EnRich does not direct transactions or the commissions the transactions
generate (soft dollars) to brokerage firms or other parties to receive research or other benefits.
If the client is receiving discretionary advisory services, EnRich will have discretionary authority to
determine which securities are to be bought and sold and the price of such securities to effect such
transactions. EnRich recognizes that the analysis of execution quality involves a number of qualitative
and quantitative factors. EnRich will follow a process in an attempt to ensure that it is seeking to obtain
the most favorable execution under the prevailing circumstances when placing client orders. These
factors include, but are not limited, to the following:
1. The financial strength, reputation and stability of the broker-dealer;
2. The efficiency with which the transaction is affected; the ability to effect prompt and
reliable executions at favorable prices (including the applicable dealer spread or
commission, if any);
3. The availability of the broker-dealer to stand ready to effect transactions of varying
degrees of difficulty in the future;
4. The efficiency of error resolution, clearance and settlement;
5. Block trading and positioning capabilities;
6. Performance measurements;
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7. Online access to computerized data regarding customer accounts;
8. Availability, comprehensiveness, and frequency of brokerage and research services;
9. Commission rate;
10. The economic benefit to the clients; and
11. Related matters involved in the receipt of brokerage services.
EnRich is not required to select the broker or dealer that charges the lowest transaction cost, even if that
broker provides execution quality comparable to other brokers or dealers.
Although EnRich is not required to execute all trades through Schwab, EnRich has determined that
having Schwab execute most trades is consistent with its duty to seek “best execution” of your trades.
Best execution means the most favorable terms for a transaction based on all relevant factors, including
those listed above. By using another broker or dealer you may pay lower transaction costs.
Aggregation of Orders
When exercising discretion, EnRich may combine orders for more than one client or for more than one
client's account to form a "block" order for the purpose of seeking a better price and or execution. Block
trading permits the trading of the same security in multiple accounts at the same time in one order
whereby all accounts receive the same execution price for that day. If a block order is filled at several
different prices, through multiple trades, all such participating accounts will receive the average
execution price. Such aggregation of orders is done under the expectation that it will, on average,
improve execution. Should a block order only be partially filled, available shares are distributed in a
manner fair to all accounts.
Under certain circumstances we do not block trades such as:
1. transactions for open-end mutual funds which buy and sell at net asset values set by
the mutual fund at the end of each trading day;
2. to invest funds that are deposited into client accounts throughout the day;
3. to honor a distribution or transfer request, as these requests will be filled upon
receipt or as soon as administratively possible; and
4. client-directed trades.
Trade Errors
EnRich has the responsibility to process trade orders correctly, promptly and ensure the best interests of
its clients are served. From time to time, EnRich may make an error when submitting a trade such as,
the purchase or sale of the wrong security (e.g., use the wrong ticker symbol);
•
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the purchase or sale of an incorrect amount of shares of a security;
•
the purchase or sale of a security at a price not in accordance with instructions; or
•
a purchase of a security when the intent was to sell, or vice versa.
•
EnRich’s policy is to seek to identify and correct any errors as promptly as possible without
disadvantaging the client or benefiting EnRich.
Trade Error Losses - If a trade error occurs at Schwab and it results in a loss in the client’s account, the
client’s account is reimbursed for the entire amount of the loss as soon as practical after the discovery
of the error. If the loss is greater than $100, EnRich is invoiced by Schwab and will pay for the loss. If
the loss is less than $100 Schwab will absorb it to reduce its administrative time and expense.
Trade Error Gains - If a trade error at Schwab results in a gain less than $100, Schwab will retain the gain
to reduce its administrative time and expense. If a trade error results in a gain of $100 or more, the gain
will remain in the client’s account, unless the same error involved other client account(s) that should
have received the gain or it is not permissible for the client to retain the gain. If the gain does not
remain in the client’s account, Schwab will donate the amount of any gain of $100 or over to charity.
EnRich maintains appropriate records for all trade errors
ITEM 13 – REVIEW OF ACCOUNTS AND REPORTS
EnRich’s wealth advisors review quarterly portfolio reports provided to clients on a quarterly basis, or
more frequently if requested by a client. EnRich’s wealth advisors Christopher Rich, Elaine Rich, Neil
Dinndorf, and Trent Tredinnick are Certified Financial Planner™ practitioners. EnRich provides each
client with a review of the client's financial situation as frequently as deemed necessary. This review
includes goals and assumptions, financial statements, cash flow and taxes, investments, retirement
projections, insurance, estate, and general financial planning.
Annually, accounts are reviewed and if necessary rebalanced. Holdings are reviewed quarterly or more
frequently as contributions and economic situations change. All clients receiving Portfolio Management
Services receive quarterly portfolio performance reports from EnRich which provide clients with: (1)
performance history, net of fees; (2) portfolio composition, percentage weighting of each asset class; (3)
portfolio start date with initial value; (4) net additions/withdrawals; (5) quarter end portfolio value; (6)
time weighted return and comparison rates of return of other standard indices; and (7) listing of
portfolio holdings.
A statement showing the market value of the securities in a client's account is sent monthly or
quarterly by the investment company that holds the client's investments.
Summaries are prepared at the request for financial planning.
Clients receiving consulting services receive reports in the frequency and scope specified in the Advisory
Services Retainer Agreement.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
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EnRich does not currently have any client referral relationships. Thus, it does not pay any fee to a third
party for making client referrals to it.
As described in Item 12 – Brokerage Practices, EnRich receives economic benefits from Schwab in the
form of the support products and services it makes available to Enrich through Schwab Advisor
Services™. EnRich benefits from the products and services provided because the cost of these services
would otherwise be borne directly by us, and this creates a conflict of interest.
EnRich may sponsor social events for clients, the expenses of which may be paid, in whole or part, by
firms whose products and services are recommended to clients by EnRich. The firms absorbing such
expenses may include mutual fund companies and ETFs whose shares are recommended, attorneys
whose services are recommended, brokerage firms through which client account transactions are
processed, and other firms. These expense reimbursements create a conflict of interest for EnRich and its
managers because they are inclined to continue to recommend the products and services of these
providers due to the financial support provided to EnRich by them.
ITEM 15 - CUSTODY
EnRich has the ability to have its advisory fee for each client debited by the custodian on a quarterly
basis. Clients are provided with transaction confirmation notices and regular summary account
statements directly from the broker-dealer/custodian for the client accounts. Those clients to whom
EnRich provides investment supervisory services will also receive a quarterly report from EnRich
summarizing performance.
EnRich also has received standing letters of authorization from certain clients that direct EnRich to
transfer those clients' funds to third parties. These letters of authorization give EnRich custody over
those accounts pursuant to applicable law. EnRich and its custodians comply with guidance provided by
the SEC with regard to these letters of authorization, and as a result, EnRich does not undergo a surprise
examination.
To the extent that EnRich provides clients with periodic account statements or reports, EnRich urges
clients to carefully review those statements and compare them to custodial account statements. EnRich’s
statements may vary from custodial statements based on accounting procedures, reporting dates, or
valuation methodologies of certain securities. The account custodian does not verify the accuracy of
EnRich's advisory fee calculations.
ITEM 16 – INVESTMENT DISCRETION
The client can determine to engage EnRich to provide investment advisory services on a discretionary or
non-discretionary basis. Prior to EnRich assuming discretionary authority over a client's account, the
client shall be required to sign an Advisory Services Retainer Agreement granting EnRich full authority to
buy, sell, or otherwise execute investment transactions involving the assets in the client's name found
in the discretionary account. The custodian may also request the client sign documentation.
Clients who engage EnRich on a discretionary basis may, at any time, impose restrictions, in writing, on
EnRich's discretionary authority (i.e. limit the types/amounts of particular securities purchased for their
account, exclude the ability to purchase securities with an inverse relationship to the market, limit or
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proscribe EnRich's use of margin, etc.).
For qualified retirement plans that engage EnRich on a non-discretionary service, it will obtain the
client's approval and consent prior to the execution of any transactions in the account(s). With such an
arrangement, the client has the unrestricted right to decline to implement advice provided by EnRich on
a non-discretionary basis.
EnRich also recommends, on a non-discretionary basis, cash accounts to be maintained outside of its
investment advisory services. When appropriate and requested by the client, it will send the client an
invitation to assist them in initiating the account. During the sign-up process, clients will generally grant
EnRich access to their account balance information and routing numbers on the cash account, but it will
not have any ability to transfer cash in or out of the account for the client. All movements of cash must
be initiated by the client. EnRich can assist the client in setting up transfers between Schwab and the
new cash account, by completing the Schwab authorization form. EnRich does not manage these
accounts or charge any advisory fees on these accounts.
ITEM 17 – VOTING CLIENT SECURITIES
EnRich will not vote proxies on behalf of any client or respond to any legal notices or class action claims
on behalf of any client. It will instruct the qualified, independent custodian to forward all proxy
materials, legal notices and class action information to the client to review.
The client should make his or her own informed decision on how to vote or respond to a legal notice. In
the event EnRich receives such material, it will forward them directly to the client by mail or by electronic
mail (if the client has authorized electronic communication).
ITEM 18 – FINANCIAL INFORMATION
EnRich does not solicit fees of more than $1,200, per client, six (6) months or more in advance.
EnRich is unaware of any financial condition that is reasonably likely to impair its ability to meet its
contractual commitments relating to its discretionary authority over certain client accounts. EnRich
has not been the subject of a bankruptcy petition.
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