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Brochure
Form ADV Part 2A
Item 1 - Cover Page
CRD# 281661
302 French Street
Erie, Pennsylvania 16507
(814) 425-5182
April 29, 2026
This brochure provides information about the qualifications and business practices of AllStreet Financial,
LLC. If you have any questions about the contents of this Brochure, please contact us at (814) 425-5182. The
information in this brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority.
AllStreet Financial, LLC, operating under the tradename Evident Financial, is an Investment Adviser
registered with the Commonwealth of Pennsylvania. Registration does not imply a certain level of skill or
www.AdviserInfo.sec.gov
training. Additional information about AllStreet Financial, LLC is also available on the SEC’s website at
.
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Item 2 - Material Changes
Since the last required annual amendment to this disclosure brochure was submitted in March 2026 the
following material changes have been made:
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Richard Makowski was named the Chief Compliance Officer of the firm in March 2026 and Chief
Executive Officer of the firm in April 2026.
In March 2026, the firm’s assets under management reached a level requiring registration with the
U.S. Securities and Exchange Commission.
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Item 3 - Table of Contents
Page
Item 1 Cover Page ............................................................................................................................................................ 1
Item 2 Material Changes ............................................................................................................................................... 2
Item 3 Table of Contents ............................................................................................................................................... 3
Item 4 Advisory Business ............................................................................................................................................. 4
Item 5 Fees and Compensation .................................................................................................................................. 5
Item 6 Performance-Based Fees and Side-By-Side Management ................................................................. 6
Item 7 Types of Clients .................................................................................................................................................. 6
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 7
Item 9 Disciplinary Information ................................................................................................................................ 8
Item 10 Other Financial Industry Activities and Affiliations ............................................................................. 8
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...........8
Item 12 Brokerage Practices ...........................................................................................................................................9
Item 13 Review of Accounts ......................................................................................................................................... 10
Item 14 Client Referrals and Other Compensation ............................................................................................. 10
Item 15 Custody ................................................................................................................................................................ 10
Item 16 Investment Discretion ................................................................................................................................... 10
Item 17 Voting Client Securities .................................................................................................................................. 11
Item 18 Financial Information ..................................................................................................................................... 11
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Item 4 - Advisory Business
General Information
AllStreet Financial, LLC is a wholly-owned subsidiary of Evident Holding Company, LLC, both limited
liability companies organized in the Commonwealth of Pennsylvania. AllStreet Financial, LLC was first
registered as an investment advisory firm with the Pennsylvania Department of Banking and Securities in
February 2016 and moved to registration with the U.S. Securities and Exchange commission in April 2026.
AllStreet Financial, LLC operates under the tradename “Evident Financial” which is held out to the public
for marketing purposes.
As of December 31, 2025, Evident Financial managed $149,715,186 in regulatory assets under management
on a discretionary basis, and $0 on a non-discretionary basis.
Services Provided
Investment Advisory Services
Evident Financial offers discretionary investment advisory services to a wide variety of clients. Evident
Financial’s investment advisory service is personalized to each client’s risk tolerance, investment time
horizon, investment goals and objectives, investment restrictions, and best interests. Clients grant Evident
Financial discretionary authority to manage their accounts by entering into an Investment Management
Agreement with Evident Financial to provide any or all of the following services:
- Ongoing investment management
- Financial planning
- Trading and portfolio rebalancing through unaffiliated broker-dealer
- Custody through unaffiliated custodian
- Tax optimization and tax loss harvesting, as applicable
Financial Planning and Consulting Services
Financial planning involves an evaluation of a client’s current and future financial state by using currently
known variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of
financial planning is that through the financial planning process, all information and analysis will be
considered as they affect and are affected by the entire financial and life situation of the client. Clients will
have access to an online portal, providing a detailed financial plan designed to achieve the client’s goals and
objectives.
Retirement Plan Services
Evident Financial offers consulting services to retirement plans and their fiduciaries based upon the needs
of the plan and the services requested by the plan sponsor. In general, these services may include a plan
review, asset allocation advice, analysis of expenses, investment recommendations, assisting in the
appointment of a third-party recordkeeper and custodian, providing education services to plan
participants, investment performance monitoring, and ongoing consulting.
Where contracted, Evident Financial provides investment management services, including exercising
discretionary authority to select and manage the plan’s investment fund lineup, ensuring alignment with
the plan’s investment policies. However, the ultimate decision regarding choosing investment funds for
individual accounts is made by plan participants. In cases where participants do not select their own
investments, the plan sponsor engages Evident Financial to manage pooled investments on behalf of plan
participants.
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These engagements are typically regulated under the Employee Retirement Income Securities Act
("ERISA"). All services, whether discussed above or customized for the plan based upon requirements from
the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed
in a written agreement and shall be consistent with the parameters set forth in the plan documents.
General Consulting
Evident Financial may offer general consulting services to clients, typically on a project basis. These
services may include, but are not limited to, cash flow planning for education expenses or retirement, debt
management, estate planning analysis, income tax planning, insurance reviews, and other matters specific
to the client as requested and agreed upon by both the client and Evident Financial. In providing these
services, Evident Financial will coordinate with the client's professional advisors, such as accountants and
attorneys, to ensure a comprehensive and integrated approach to the client’s financial needs.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to clients regarding their retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. Our compensation structure may present potential conflicts of interest with our clients'
interests. To address this, we are governed by a fiduciary duty that requires us to act in our clients' best
interests and prioritize their needs over our own. Under this fiduciary standard, we are obligated to:
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Adhere to a professional standard of care when providing investment recommendations,
offering prudent advice;
Always prioritize our clients’ interests above our own, providing loyal and unbiased advice;
Avoid making misleading statements regarding any conflicts of interest, fees, and
investments;
Comply with policies and procedures that ensure our advice is always in the best interest
of our clients;
Charge only reasonable fees for our services; and
Disclose information regarding any conflicts of interest.
Item 5 - Fees and Compensation
General Fee Information
Fees paid to Evident Financial are exclusive of custodial and transaction fees, which are paid directly to the
client’s custodian, brokers or other third-party consultants. Additionally, the fees charged by Evident
Financial are separate from those imposed by mutual funds, ETFs (exchange traded funds) or other
investment pools, which are outlined in each fund’s prospectus or offering materials.
Clients are encouraged to review all fees charged by funds, brokers, Evident Financial, and other parties
involved to gain a complete understanding of the total costs associated with investment and financial
related services.
Investment Advisory Services Fees
Evident Financial’s standard investment advisory fees are based on the fee schedule outlined below. In most
cases, fees are billed quarterly in advance, though there may be exceptions which fees are billed in arrears.
Fees are calculated at the beginning of the quarter, based on the account’s market value as of the last trading
day of the preceding quarter. For accounts opened after the start of the quarter, fees will be prorated from
the date the account is funded for investment.
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Evident Financial’s fees are automatically deducted from the client’s accounts on a quarterly basis, unless
otherwise agreed upon by the client and Evident Financial. The fee schedule is set forth below:
Account Value (Tiered)
Annual Fee
First $250,000
1.25%
Next $250,000
0.75%
Next $500,000
0.65%
Next $1,000,000
0.55%
Next $3,000,000
0.35%
Over $5,000,000
Negotiable
Evident Financial may, at its discretion, make exceptions to its fee schedule or negotiate special fee
arrangements in which Evident Financial deems it appropriate under the circumstances. Either Evident
Financial or the client may terminate their Investment Management Agreement within 5 business days of
signing without penalty, subject to any written notice requirements in the Agreement. In the event of
termination, any paid but unearned fees will be refunded to the client based on the number of days that the
account was managed, and any fees due to Evident Financial from the client will be invoiced or deducted
from the client’s account prior to termination.
Financial Planning and Consulting Services Fees
Evident Financial may charge an hourly fee ranging from $125 to $250 for financial planning and consulting
services. The fee is negotiable, depending on the nature and complexity of each client’s circumstances. The
scope of services, associated fees, and the terms of the agreement will be tailored and negotiated on a case-
by-case basis with each client.
Retirement Plan Service Fee
Retirement Plan Services are typically charged the standard investment advisory fee rate, with a minimum
annual fee of $2,500. An additional one-time setup fee of $750 applies.
Item 6 - Performance-Based Fees and Side-By-Side Management
Evident Financial does not charge performance-based fees.
Item 7 - Types of Clients
Evident Financial primarily serves individuals, trusts, estates, charitable organizations, foundations,
retirement plans, and other business entities. Evident Financial typically requires a minimum relationship
size of $500,000. However, this minimum may be adjusted or waived at the discretion of Evident Financial.
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Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Modern Portfolio Theory
Modern Portfolio Theory is based on these principles:
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Investors are generally risk-averse and require compensation for taking on risk
Risk and return are related; higher risk demands higher expected returns
Markets are efficient, with equal access to information for all investors
Portfolio design is more important than selecting individual securities
Long-term investing (preferably 10+ years) is key to success, allowing asset classes' long-term
characteristics to emerge
Diversification across less correlated asset classes reduces portfolio risk
Passive and Active Investment Management
Evident Financial may use passive, active, or a blend of both investment styles. Passive investing builds
portfolios with distinct asset classes, aiming for a desired risk-return balance. Active investing involves
managers who seek to outperform the market or benchmark while managing risk and volatility. Evident
Financial focuses on constructing portfolios that align with clients' goals and minimize volatility, rather than
trying to beat an arbitrary index. Investment selections are based on factors like fund holdings, liquidity, tax
efficiency, with an emphasis on keeping costs low.
Strategic Asset Allocation
Evident Financial emphasizes diversifying across key asset classes (stocks, bonds, and cash equivalents)
and investment strategies (fundamental, quantitative, active, passive) to optimize risk and return. Evident
Financial employs both strategic and tactical allocation:
• Strategic allocation
establishes long-term target weights based on the client’s goals, risk tolerance,
• Tactical allocation
and time horizon.
makes short-term adjustments in response to market conditions and return
expectations.
Material Risks Involved
All investment strategies involve risk and may result in a loss of principal. Key risks include:
Investment value may decline due to general market conditions
Investment strategies may not perform as expected
Smaller companies tend to be more volatile and less liquid
: High portfolio turnover can increase costs and tax implications
Some securities may be hard to buy or sell, affecting pricing
Focusing on securities, specific sectors, or asset classes may increase risk
Bond prices fall as interest rates rise, particularly for longer-term bonds
• Market Risk:
• Strategy Risk:
• Small/Medium Cap Risk:
• Turnover Risk
• Liquidity Risk:
• Concentration Risk:
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Interest Rate Risk:
• Legal/Legislative Risk:
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Inflation Risk
Changes in laws or regulations could affect investments
: Inflation can erode purchasing power, even if investment values remain steady
Securities Risks
In addition to general investment risks, specific securities carry additional risks:
• Stocks
• Bonds
: Can be volatile, with potential for significant losses, especially in economic downturns
: Prices fluctuate with interest rates, credit quality, liquidity, and maturity. Longer-term bonds
are more sensitive to interest rate changes
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Investment Funds
: Clients incur fees from underlying funds, and overall performance can be
• Foreign investing:
affected by the fund’s investment strategies or losses.
Involves risks not typically associated with U.S. investments, and the risks
maybe exacerbated further in emerging market countries. These risks may include, among others,
adverse fluctuations in foreign currency values, as well as adverse political, social, and economic
developments affecting one or more foreign countries.
Item 9 - Disciplinary Information
Evident Financial has no disciplinary events to report.
Item 10 - Other Financial Industry Activities and Affiliations
Registration as a Broker/Dealer or Broker/Dealer Representative
Evident Financial is not registered and does not have an application pending to register, as a broker dealer
and its management persons are not registered as broker/dealer representative.
Registration as a Futures Commission merchant, Commodity Pool Operator
Evident Financial and its management persons are not registered and do not have application pending to
register, as a futures commission merchant, commodity pool operator/advisor.
Relationships Material to this Advisory Business and Possible Conflicts of Interest
Evident Financial does not maintain any other relationships that present conflicts of interest.
Selection of other Advisors
Evident Financial does not select or recommend other investment advisers.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics and Personal Trading
Evident Financial has adopted a Code of Ethics (“the Code”), the full text of which is available to you upon
request. Evident Financial’s Code has several goals. First, the Code is designed to assist Evident Financial in
complying with applicable laws and regulations governing its investment advisory business. Under the
Investment Advisors Act of 1940, Evident Financial owes fiduciary duties to its clients. Pursuant to these
fiduciary duties, the Code requires persons associated with Evident Financial (managers, officers, and
employees) to act with honesty, good faith and fair dealing in working with clients. In addition, the Code
prohibits such associated persons from trading or otherwise acting on insider information.
Next, the Code sets forth guidelines for professional standards for Evident Financial’s associated persons.
Under the Code’s Professional Standards, Evident Financial expects its associated persons to put the
interests of its clients first, ahead of personal interests. In this regard, Evident Financial associated persons
are not to take inappropriate advantage of their positions in relation to its clients. Third, the Code sets forth
policies and procedures to monitor and review the personal trading activities of associated persons. From
time to time Evident Financial’s associated persons may invest in the same securities recommended to
clients. Under its Code, Evident Financial has adopted procedures designed to reduce or eliminate conflicts
of interest that this could potentially cause. The Code’s personal trading policies include procedures for
limitations on personal securities transactions of associated persons, as well as reporting and review of
such trading. These policies are designed to discourage and prohibit personal trading that would
disadvantage clients. The Code also provides for disciplinary action as appropriate for violations.
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Participation or Interest in Client Transactions
As outlined above, Evident Financial has adopted procedures to protect client interests when its associated
persons invest in the same securities as those selected for or recommended to clients. In the event of any
identified potential trading conflicts of interest, Evident Financial’s goal is to place client interests first.
Consistent with the foregoing, Evident Financial maintains policies regarding participation in initial public
offerings (IPOs) and private placements to comply with applicable laws and avoid conflicts with client
transactions. If an Evident Financial associated person wishes to participate in an IPO or invest in a private
placement, a pre-clearance request must be submitted and approved by the Chief Compliance Officer.
Finally, if associated persons trade with client accounts (i.e., in a bundled or aggregated trade), and the trade
is not filled in its entirety, the associated person’s shares will be removed from the block, and the balance
of shares will be allocated among client accounts in accordance with Evident Financial’s written policy.
Item 12 - Brokerage Practices
Evident Financial will recommend that clients establish brokerage accounts with Charles Schwab & Co., Inc.
(Schwab), a broker-dealer registered with the Securities and Exchange Commission and a member of FINRA
and SIPC. While clients are required to use Schwab as custodian/broker, the client decides whether to do so
and opens its account with Schwab by entering into a brokerage account agreement directly with Schwab.
If the client does not wish to place his or her assets with Schwab, then Evident Financial cannot manage the
client’s account.
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like
Evident Financial. Through Schwab Advisor Services, Schwab provides Evident Financial and clients, with
access to its institutional brokerage services - trading, custody, reporting, and related services - many of
which are not typically available to individual clients. Some of those services helps Evident Financial
manage or administer its clients’ accounts, while others help manage and grow Evident Financial’s business.
Schwab’s support services described below are generally available on an unsolicited basis and at no charge
to Evident Financial. The availability of Schwab’s products and services is not based on giving particular
investment advice, such as buying particular securities for clients.
Below is a more detailed description of Schwab’s support services:
Schwab’s institutional brokerage services include access to a broad range of investment products, execution
of securities transactions, and custody of client assets. The investment products available through Schwab
include some to which Evident Financial might not otherwise have access or that would require a
significantly higher minimum initial investment by clients. Schwab’s services described in this paragraph
generally benefit the client.
Schwab also makes available to Evident Financial other products and services that may not directly benefit
clients These products and services assist Evident Financial in managing and administering clients’
accounts. They include investment research, both Schwab’s own and that of third parties. Evident Financial
may use this research to service all or some substantial number of clients’ accounts. In addition to
investment research, Schwab also makes available software and other technology that (i) provide access to
client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and
allocate aggregated trade orders for multiple client accounts; (iii) provide pricing and other market data;
(iv) facilitate payment of Evident Financial’s fees from clients’ accounts; and (v) assist with back-office
functions, recordkeeping and reporting.
Schwab also offers other services intended to help Evident Financial manage and further develop its
business enterprise. These services may include: (i) educational conferences and events; (ii) technology,
compliance, legal and business consulting; (iii) publications and conferences on practice management and
business succession; and (iv) access to retirement plan providers, consultants, and insurance providers.
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Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to Evident Financial. Schwab may also discount or waive its fees for some of these
services or pay all or a part of a third party’s fees. Schwab may also provide Evident Financial with other
benefits such as occasional business entertainment of personnel.
The availability of some services provided by Schwab benefits Evident Financial because we do not have to
produce or purchase them. We generally don’t have to pay for these services, and they are not contingent
upon Evident Financial committing any specific amount of business to Schwab trading commissions or
assets in custody. In light of our arrangements with Schwab, Evident Financial may have an incentive to
[recommend/require] that clients maintain their accounts with Schwab based on our interest in receiving
Schwab’s services that benefit our business rather than based on the client’s interest in receiving the best
value in custody services and the most favorable execution of transactions. This is a potential conflict of
interest. Evident Financial believes, however, that our selection of Schwab as custodian and broker is in the
best interests of clients. It is primarily supported by the scope, quality, and price of Schwab’s services and
not Schwab’s services that benefit only Evident Financial.
Soft Dollars
Schwab may provide us with certain brokerage and research products and services that qualify as
“brokerage or research services” under Section 28(e) of the Securities Exchange Act of 1934 (“Exchange
Act”). This is commonly referred to as a “soft dollar” arrangement. These research products and/or services
will assist us in our investment decision making process. Such research generally will be used to service all
of our client accounts, but brokerage charges paid by the client may be used to pay for research that is not
used in managing that specific client’s account.
Item 13 - Review of Accounts
Evident Financial advisors meet with clients and may meet with their designated third parties (e.g.,
accountants, attorneys) to gather information on financial situations, tax status, investment goals, risk
tolerance, and time horizons. This data is collected through interviews, questionnaires, and client profiles.
Portfolios are tailored to client objectives, and accounts are monitored regularly to ensure alignment with
ongoing needs. Annual meetings, or more frequent reviews triggered by significant events (e.g., market
changes, large deposits/withdrawals, client requests, change in tax status), are scheduled to reassess goals.
If a client declines a meeting, updates may be obtained via phone, email, or correspondence. Clients are
responsible for promptly notifying Evident Financial of any changes that may affect their financial situation
or objectives.
Item 14 - Client Referrals and Other Compensation
Evident Financial does not pay third parties for client referrals.
Item 15 – Custody
Under government regulations, Evident Financial is deemed to have custody of a client’s assets if the client
authorizes Evident Financial to instruct Schwab to deduct our advisory fees directly from the client’s
account; however, Schwab maintains actual custody of clients’ assets. Clients receive account statements
directly from Schwab at least quarterly. They will be sent to the email or postal mailing address the client
provides to Schwab. Clients should carefully review those statements when received. We urge clients to
compare Schwab’s account statements to reports received directly from Evident Financial.
Item 16 - Investment Discretion
In most cases, Evident Financial has the authority to determine, without obtaining specific client consent,
the securities to be bought and/or sold in client accounts and the amount of such securities to be bought
and/or sold. Evident Financial may provide non-discretionary asset management services. The terms and
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conditions of any services provided by Evident Financial are dictated by the agreement signed by the client
and Evident Financial.
Item 17 - Voting Client Securities
As a policy and in accordance with Evident Financial’s client agreement, Evident Financial does not vote
proxies related to securities held in client accounts. The custodian of the account will normally provide
proxy materials directly to the client. Clients may contact Evident Financial with questions relating to proxy
procedures and proposals; however, Evident Financial generally does not research particular proxy
proposals.
Item 18 - Financial Information
Evident Financial does not require nor solicit prepayment of more than $500 in fees per client, six months
or more in advance, and therefore has no disclosure required for this item. We do not have any financial
condition that is reasonably likely to impair our ability to meet contractual commitments to Clients.
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