Overview
- Headquarters
- Greenville, SC
- Average Client Assets
- $3.8 million
- Minimum Account Size
- $250,000
- SEC CRD Number
- 110945
Fee Structure
Primary Fee Schedule (ADV PART 2A FIRM BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $3,000,000 | 1.50% |
| $3,000,001 | $8,000,000 | 1.25% |
| $8,000,001 | and above | 1.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $70,000 | 1.40% |
| $10 million | $127,500 | 1.28% |
| $50 million | $527,500 | 1.06% |
| $100 million | $1,027,500 | 1.03% |
Clients
- HNW Share of Firm Assets
- 63.90%
- Total Client Accounts
- 650
- Discretionary Accounts
- 650
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting
Regulatory Filings
Primary Brochure: ADV PART 2A FIRM BROCHURE (2026-03-11)
View Document Text
Form ADV Part 2A Brochure
March 11, 2026
900 Pendleton St.,
Suite 200
Greenville, SC 29601
864-233-0808
www.familylegacyinc.com
This brochure provides information about the quali(cid:976)ications and business practices of
Family Legacy, Inc. If you have any questions about the contents of this Brochure, or would
like to request a copy free of charge, please contact Christopher A. Brown at 864-233-0808
or cbrown@familylegacyinc.com. The information in this brochure has not been approved
or veri(cid:976)ied by the United States Securities and Exchange Commission or by any state
securities authority.
Additional information about Family Legacy, Inc. is available on the SEC’s website at
www.adviserinfo.sec.gov. Family Legacy, Inc.’s CRD number is 110945.
Item 2 – Material Changes
These are the following material changes in this brochure from the last annual updating amendment
of Family Legacy, Inc. on March 3, 2025.
-
-
Item 10 has been amended to add Family Legacy Insurance Services, LLC as a new af(cid:976)iliate of
Family Legacy, Inc. effective January 1, 2026.
Item 10 has been amended to disclose that Legacy Insurance, LLC remains an af(cid:976)iliate of Family
Legacy, Inc.; however, it has ceased actively offering insurance services.
2
Item 3 -Table of Contents
Item 1 – Cover Page ....................................................................................................................................................................... i
Item 2 – Material Changes ........................................................................................................................................................ 2
Item 3 -Table of Contents ........................................................................................................................................................... 3
Item 4 – Advisory Business ...................................................................................................................................................... 4
Item 5 – Fees and Compensation ........................................................................................................................................... 6
Item 6 – Performance-Based Fees and Side-By-Side Management .......................................................................... 8
Item 7 – Types of Clients ........................................................................................................................................................... 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 9
Item 9 – Disciplinary Information ......................................................................................................................................... 9
Item 10 – Other Financial Industry Activities and Af(cid:976)iliations .................................................................................. 9
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ...................................10
Item 12 – Brokerage Practices ..............................................................................................................................................10
Item 13 – Review of Accounts ...............................................................................................................................................12
Item 14 – Client Referrals and Other Compensation ...................................................................................................12
Item 15 – Custody .......................................................................................................................................................................12
Item 16 – Investment Discretion ..........................................................................................................................................12
Item 17 – Voting Client Securities ........................................................................................................................................13
Item 18 – Financial Information ...........................................................................................................................................13
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Item 4 – Advisory Business
Family Legacy, Inc. has been serving clients since May of 1995. The advisory (cid:976)irm is owned by
Christopher A. Brown, a Certi(cid:976)ied Public Accountant and Personal Financial Specialist (PFS).
Christopher A. Brown is authorized by the Certi(cid:976)ied Financial Planner Board of Standards (CFP
Board) to use the CERTIFIED FINANCIAL PLANNER™ and CFP® certi(cid:976)ication marks in accordance
with CFP Board certi(cid:976)ication and renewal requirements.
Discretionary Portfolio Management Services:
Family Legacy, Inc. provides portfolio management and (cid:976)inancial planning services. Through
personal discussions in which goals and objectives based on a client’s particular circumstances are
established, Family Legacy, Inc. develops a client’s personal investment policy and creates and
manages a portfolio based on that policy. Our (cid:976)irm enters into a portfolio management agreement
with all clients, which enables us to make investment decisions for the client’s account according to
the investment objectives and (cid:976)inancial circumstances as shown in the client’s investment policy
statement.
Family Legacy, Inc. provides this service to individuals, pension and pro(cid:976)it-sharing plans, trusts,
estates, charitable organizations and corporations. Family Legacy, Inc. primarily manages advisory
accounts on a discretionary basis. Factors considered in making investment decisions include the
account size, risk tolerance and the client’s investment experience and any other pertinent
information discussed with a client during consultation or in the process of developing the client’s
investment policy.
Family Legacy, Inc. assists each client in determining the amount of risk versus return in various
investment vehicles and helps the client in allocating his or her assets between the various asset
classes.
Family Legacy, Inc. will maintain periodic and appropriate communication with the client. Family
Legacy, Inc. monitors the performance of the account and continually assesses the client’s risk
tolerance and changes the asset allocation as necessary.
Family Legacy, Inc. manages money on a discretionary basis in primarily two ways: through
individually managed accounts and through asset allocation portfolios.
Individually Managed Accounts:
Since the company’s inception, the company has utilized individually managed accounts, which
for larger accounts (typically a minimum account size of $250,000), have been primarily made
up of individually traded securities.
For individually managed accounts, our philosophy is conservative and emphasizes high-quality,
high-yielding stocks and other large-cap stocks for the majority of portfolio assets. We also use
mid-cap and other stocks to a lesser degree. Government bonds, preferred stocks, convertible
securities, real estate investment trusts, no-load mutual funds, exchange traded funds and other
investment vehicles may be utilized to achieve greater diversi(cid:976)ication and to include
international investing and other (cid:976)ixed instruments. Mutual funds and exchange traded funds will
be selected on the basis of any or all of the following criteria: The fund’s performance history, the
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industry sector in which the fund invests, the track record of the fund’s manager, the fund’s
investment objectives, the fund’s management style and philosophy and the fund’s management
fee structure. Portfolio weighting between funds and market sectors will be determined by each
client’s individual needs and circumstances. Clients will have the opportunity to place reasonable
restrictions on the types of investments which will be made on the clients’ behalf. Clients will
retain individual ownership of all securities.
Asset Allocation Portfolios:
Family Legacy, Inc. also offers asset allocation portfolios consisting of no-load mutual funds,
exchange traded funds and other pooled investment vehicles within Family Legacy, Inc.’s
discretion.
The use of no-load mutual funds, ETFs and other pooled investment vehicles allows Family
Legacy, Inc. to diversify accounts through the use of these investments rather than the
selection of individual stocks, bonds and other securities described above. Accounts that are
smaller than those accepted by Family Legacy, Inc. as individually managed accounts described
above may be accepted as asset allocation portfolios. In all cases, minimum account size is
negotiable.
Asset allocation portfolios using mutual funds, ETFs and other pooled investment vehicles may
be used for any size account depending on the client’s preferences and circumstances. Further,
Family Legacy, Inc. may accept some smaller accounts as individually managed accounts at its
discretion.
Family Legacy, Inc.’s asset allocation portfolios are constructed as model portfolios of mutual
funds, ETFs and other pooled investment vehicles. Client assets are managed according to a
model that is suitable to the client’s individual investment objectives, risk tolerance and
(cid:976)inancial circumstances. Clients may place reasonable restrictions on assets selected by Family
Legacy, Inc. for implementation of the client’s portfolio.
Retirement Plan Services:
Family Legacy, Inc. also provides advisory services to participant-directed employee retirement
bene(cid:976)it plans. Family Legacy, Inc. will analyze the plan's current investment platform and assist the
plan in creating an investment policy statement de(cid:976)ining the types of investments to be offered and
the restrictions that may be imposed.
Family Legacy, Inc. will recommend investment options to achieve the plan's objectives, provide
participant education meetings, and monitor the performance of the plan's investment vehicles.
Family Legacy, Inc. will recommend changes in the plan's investment vehicles as may be appropriate
from time to time and will review the plan's investment vehicles and investment policy as
necessary.
5
Financial Planning Services:
Family Legacy, Inc. will generally engage new clients in a discovery process to de(cid:976)ine goals and
explore a client’s values as they relate to their personal (cid:976)inancial situation. We will also meet with
clients on a periodic basis to review and update their individual (cid:976)inancial plan as appropriate.
Family Legacy, Inc. may offer investment advice and (cid:976)inancial planning services on a consultation
basis. Fees are charged on a (cid:976)ixed-fee basis, and a range of the fees to be charged for these services
are agreed upon before the work commences. In the client engagement letter, an actual schedule of
fees and dates to be paid are included. The client may terminate these services at any time and get a
full refund of any unearned portion of the fees upon written request.
Trustee Services:
When requested by clients, Christopher A. Brown or William W. Brown may act as trustee or
personal representative on a client’s behalf. Fees for these services are agreed upon with the client
and are separate and distinct from the advisory fees described in this section.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are (cid:976)iduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way we make money creates some con(cid:976)licts with your interests, so we
operate under a special rule that requires us to act in your best interest and not put our interest
ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give
prudent advice);
• Never put our (cid:976)inancial interests ahead of yours when making recommendations (give
loyal advice);
• Avoid misleading statements about con(cid:976)licts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about con(cid:976)licts of interest.
Regulatory Assets Under Management
As of December 31, 2025, Family Legacy, Inc. managed $377,277,747 on a discretionary basis. The
Firm did not manage assets on a non-discretionary basis.
Item 5 – Fees and Compensation
Family Legacy, Inc. uses the following fee schedules for assets under management and ongoing
(cid:976)inancial planning.
6
Individually Managed Accounts
Value of Account Annual Fee
1.50%
1.25%
1.00%
0 - $3,000,000
Next $5,000,000
Greater than $8,000,000
Asset Allocation Portfolios
Value of Account Annual Fee
$0 - $500,000
Next $500,000
Next $2,000,000
Greater than $3,000,000
1.50%
1.25%
1.00%
0.75%
Family Legacy, Inc. charges a management fee on asset allocation portfolios that is less than the fee
charged for individually managed accounts on account values above $500,000. While fees on these
portfolios paid to Family Legacy, Inc. may be lower, aggregate fees paid by the client may be higher
than individually managed portfolios because of expense ratios charged by the pooled investment
vehicles paid by the end client. Asset allocation portfolios are not speci(cid:976)ically tax-managed, which
Family Legacy, Inc. helps provide for in taxable individually managed accounts.
Fees are generally payable quarterly in advance. The initial billing period starts upon the receipt of
any funds or securities in the account. The (cid:976)irst payment will be prorated to cover the period from
the date the account is funded through the end of the current calendar quarter. Clients will be
invoiced in advance at the beginning of each calendar quarter based upon the value of the account
at the end of the previous quarter. In limited situations, fees are negotiable. If a portfolio
management agreement is terminated within (cid:976)ive days of execution, fees are completely refunded. If
a portfolio management agreement is otherwise terminated, refunds are made on a pro-rata basis
upon written request.
Retirement Plan Services
Value of Account Annual Fee
$0 - $5,000,000
Next $5,000,000
Greater than $10,000,000
0.50%
0.35%
0.25%
Fees for employee directed retirement plans are billed quarterly in arrears. In limited situations,
fees are negotiable.
All fees paid to Family Legacy, Inc. for investment advisory services are separate and distinct from
the fees and expenses charged by mutual funds to their shareholders. These fees and expenses are
described in each fund prospectus. These fees will generally include a management fee, other fund
expenses and a possible distribution fee. If the fund also imposes sales charges, a client may pay an
initial or deferred sales charge. A client could invest in a mutual fund directly, without the services
of Family Legacy, Inc. In that case, the client would not receive the services provided by Family
7
Legacy, Inc., which are designed, among other things, to assist the client in determining which
mutual fund or funds are most appropriate to each client’s (cid:976)inancial condition or objectives.
Accordingly, the client should review both the fees charged by the funds and the fees charged by
Family Legacy, Inc. to fully understand the total amount of fees to be paid by the client and to thereby
evaluate the advisor services being provided. Additionally, the custodian used will typically charge a
nominal fee on a per-trade basis.
Family Legacy, Inc.’s fees are exclusive of brokerage commissions, transaction fees, and other related
costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed
by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on
brokerage accounts and securities transactions. Such charges, fees, and commissions are exclusive of
and in addition to Family Legacy, Inc.’s fee, and Family Legacy, Inc. does not receive any portion of
these commissions, fees and costs.
Fees and account size are negotiable. For smaller accounts, Family Legacy will generally ask that the
client enter a periodic investment plan where the client adds an automatic deposit to the account on a
regular basis.
We charge a (cid:976)ixed fee for initial consultation which generally includes (cid:976)inancial planning services
based on an agreed upon amount decided with the client before beginning the engagement. In most
initial cases, the client will agree to an engagement letter. In the client engagement letter, an actual
schedule of fees and dates to be paid are included. For on-going consultation or special projects the
client may request to be billed as the work progresses. The client may terminate these services at
any time and receive a full refund of any unearned portion of the fees upon written request.
Item 6 – Performance-Based Fees and Side-By-Side Management
Family Legacy, Inc. does not charge any performance-based fees (fees based on a share of capital
gains on or capital appreciation of the assets of a client).
Item 7 – Types of Clients
Family Legacy, Inc. provides portfolio management services to individuals, high net worth
individuals, corporate, pension and pro(cid:976)it-sharing plans, charitable organizations, trusts, estates
and corporations.
The minimum size for new individually managed accounts is $250,000. However, Family Legacy,
Inc., under certain circumstances, will negotiate this minimum account size. This minimum account
size will apply to new accounts and will not change the status for existing accounts. There is no
minimum account size for an asset allocation portfolio.
8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
For individually managed accounts Family Legacy utilizes common stocks, ADR’s, REIT’s, bonds,
mutual funds, ETF’s, and other publicly traded instruments to build portfolios based on each client’s
individual risk tolerance.
We generally hold securities over a long period of time and seek capital appreciation in conjunction
with income to create long-term sustainable growth. Our style is that of long-term investors seeking
stability with reasonable returns. We do not hold ourselves out as traders. We are an investment (cid:976)irm
seeking wise investments over a long period of time.
For asset management portfolios, we search for no load funds with no transaction fees and reasonable
expense ratios that are generally rated three stars and greater in Morningstar. We also seek to utilize
high quality exchange traded funds (ETFs). We work diligently to design portfolios that will (cid:976)it within
a client’s stated risk tolerance.
For individually directed retirement plans, we recommend high quality mutual funds and exchange
traded funds that will meet the plan’s objectives as outlined in their investment policy statement.
In all of our portfolios, we seek to minimize risk. Philosophically, we are willing to let go of some
returns on the upside in the attempt to mitigate downside risk. Our portfolios tend to be more
conservative rather than aggressive.
While we make every effort to design portfolios that will meet our client’s goals, investing in
securities involves risk of loss that clients should be prepared to bear. Prior rates of return are not
guaranteed in future periods.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of Family Legacy, Inc. or the integrity
of its management. Family Legacy, Inc. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Af(cid:976)iliations
Family Legacy, Inc. is under common ownership and control with Family Legacy Business Services,
Inc., Family Legacy Insurance Services, LLC, and Legacy Insurance, LLC. Family Legacy Business
Services, Inc. is a CPA (cid:976)irm offering tax and accounting services as well as business consulting
services. Family Legacy Insurance Services, LLC offers insurance services. Legacy Insurance, LLC
remains an af(cid:976)iliate of Family Legacy, Inc.; however, it has ceased actively offering insurance
services.
During the course of providing investment advisory services and (cid:976)inancial planning services, we
may recommend the services offered by Family Legacy Business Services, Inc. and/or Family Legacy
Insurance Services, LLC to ful(cid:976)ill clients’ needs. If a client elects to engage Family Legacy Business
Services, Inc., such engagement will be under separate agreement, and the owners of this Family
Legacy Business Services, Inc., who are also owners of Family Legacy, Inc., will receive fees from the
client that are separate and distinct from the advisory fees charged by Family Legacy, Inc. If a client
elects to engage Family Legacy Insurance Services, LLC, such engagement will be under separate
9
agreement, and the owners of Family Legacy Insurance Services, LLC, who are also owners of
Family Legacy, Inc., will receive fees from the client and/or insurance commissions that are separate
and distinct from the advisory fees charged by Family Legacy, Inc.
Clients of Family Legacy, Inc. are under no obligation to engage Family Legacy Business Services,
Inc., Family Legacy Insurance Services, LLC, or Legacy Insurance, LLC.
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
Family Legacy, Inc. has adopted a Code of Ethics (“Code”) designed to comply with Rule 204A-1 under
the Investment Advisers Act of 1940 (“Advisers Act”). The Code establishes rules for all employees of
Family Legacy, Inc. and is designed to, among other things, govern personal securities trading
activities in the accounts of employees. If an employee of Family Legacy, Inc. would like to invest in the
same securities (or related securities, e.g. warrants, options or futures) that Family Legacy, Inc.
recommends to clients, we will aggregate clients’ trades with the employee’ trades so that all trades
are executed at the same time and at the same price. If it is not possible to aggregate the employee’s
transaction with those of our clients, the clients’ transactions will be placed ahead of the employee’s.
The Code is based upon the principal that Family Legacy, Inc. and its employees owe a (cid:976)iduciary duty
to Family Legacy, Inc.’s clients to conduct their affairs, including their personal securities transactions,
in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking
inappropriate advantage of their position with the (cid:976)irm and (iii) any actual or potential con(cid:976)licts of
interest or any abuse of their position of trust and responsibility.
The Code is designed to ensure that the high ethical standards long maintained by Family Legacy,
Inc. continue to be applied. The purpose of the Code is to preclude activities which may lead to or
give the appearance of con(cid:976)licts of interest, insider trading and other forms of prohibited or
unethical business conduct. The excellent name and reputation of our (cid:976)irm continues to be a direct
re(cid:976)lection of the conduct of each employee.
A complete copy of our Code of Ethics is available to clients or prospective clients at your request.
Item 12 – Brokerage Practices
For discretionary accounts, Family Legacy, Inc. requests that it be provided with written authority to
determine which securities and the amounts of securities are bought or sold. Any limitations on this
discretionary authority shall be included in this written authority statement. Clients may
change/amend these limitations as required. Such amendments shall be submitted in writing.
Clients may hold their assets with any custodian and Family Legacy, Inc. can provide advisory
services to them. If clients are in need of brokerage and custodial services recommendation, Family
Legacy, Inc. recommends Fidelity Brokerage Services, Inc. (“Fidelity”), and Charles Schwab & Co.,
Inc. Advisor Services (“Schwab”). When a client’s assets are held at Fidelity, Family Legacy will
generally place client securities transactions with Fidelity. Similarly, when a client’s assets are held
at Schwab, Family Legacy, Inc, will generally place client transactions with Schwab.
10
Family Legacy, Inc. may utilize block trades where possible and when advantageous to clients. The
blocking of trades permits the trading of aggregate blocks of securities composed of assets from
multiple client accounts. Block trading allows Family Legacy, Inc. to execute equity trades in a more-
timely, more-equitable manner. Block trades executed at Fidelity Investments and Charles Schwab
will be placed at different times.
Generally, orders are created in our portfolio accounting system, uploaded to Fidelity or Charles
Schwab and sent by them to the Markets. Orders placed through Fidelity’s electronic trading system
are sent directly to the Markets via Fidelity’s computer system. Orders placed through Charles
Schwab’s electronic trading system are sent directly to the Markets via Charles Schwab’s computer
system. Orders sent (cid:976)irst do not necessarily trade (cid:976)irst nor do these orders necessarily execute at
terms more or less favorable than orders sent later.
Family Legacy, Inc. receives bene(cid:976)its from Fidelity and Schwab, including research, that it would not
receive if it did not utilize these (cid:976)irms to place client securities transactions. These bene(cid:976)its do not
depend on the amount of transactions directed by Family Legacy, Inc. to Fidelity and Charles
Schwab.
These bene(cid:976)its include: A dedicated trading desk that services advisors exclusively, a dedicated
service group and an account services manager dedicated to Family Legacy, Inc.’s accounts, access
to a real-time order matching system, ability to “block” client trades, electronic download of trades,
balances and positions in portfolio management software, access, for a fee, to an electronic interface
with custodial account software, duplicate and batched client statements, con(cid:976)irmations and year-
end summaries, the ability to have advisory fees directly debited from client accounts (in
accordance with the federal and state requirements), quarterly newsletters, access to various
mutual funds, many funds NOT af(cid:976)iliated with Fidelity and Charles Schwab, ability to have loads
waived for Family Legacy, Inc.’s clients who invest in certain loaded funds, when certain conditions
are met and maintained and the ability to have custody fees reduced or waived (when negotiated by
the advisor and allowed under certain circumstances).
Family Legacy, Inc. also receives certain vendor discounts on software as part of doing business with
Fidelity and Schwab. Family Legacy, Inc. will always act in the best interest of its clients, consistent
with its (cid:976)iduciary duty, including when evaluating custodians/broker-dealers. Moreover, Family
Legacy, Inc. recommends custodians/ broker-dealers based on its duty to seek "best execution,"
which has the obligation to seek to execute securities transactions clients, consistent with its
(cid:976)iduciary duty, including accurate execution, prompt reconciliation, and trade error resolution,
competitive commission costs, access to low transaction fee ETFs, and professionalism that
ultimately bene(cid:976)its our clients. While Family Legacy, Inc. has a reasonable belief that Fidelity and
Schwab are able to obtain best execution and competitive prices, Family Legacy, Inc. will not be
independently seeking best execution price capability through other broker-dealers. Family Legacy,
Inc. conducts best execution reviews to ful(cid:976)ill its best execution obligation, including review of
reports provided by Fidelity and Charles Schwab.
For retirement plan services, Family Legacy, Inc. does not arrange for the execution of securities
transactions for employee retirement bene(cid:976)it plans as part of this service. Transactions are executed
directly through employee plan participation and the services of the TPA selected by the plan sponsor.
11
Item 13 – Review of Accounts
Discretionary portfolio management accounts are reviewed in their entirety initially upon
engagement and quarterly, semi-annually or annually thereafter. Periodic reviews are also
conducted with clients to review their individual performance, monitor risk tolerance and change
asset allocation, as determined by client.
Retirement plan assets are reviewed no less than annually.
For discretionary portfolio management accounts, reports are prepared and delivered quarterly.
For non-discretionary retirement plan advice, periodic reports and online access are provided by
the plan administrator.
Reviewers:
Christopher A. Brown, CPA, PFS, CFP® President
Jennifer W. Chandler CFP®, COO
William W. Brown, CPA, PFS, Vice President
Item 14 – Client Referrals and Other Compensation
Family Legacy, Inc. does not compensate others for client referrals.
Family Legacy does not receive any economic bene(cid:976)it from non-clients for providing investment advice
and advisory services to clients.
Item 15 – Custody
Family Legacy, Inc. is not a corporate trustee and does not act as a custodian for client funds or
securities. However, Family Legacy, Inc. is deemed to have custody of client assets because it
deducts advisory fees from client accounts. In addition, when requested by clients, Christopher A.
Brown or William W. Brown will act as trustee or personal representative on a client’s behalf, which
constitutes custody under the Advisers Act. As part of the safeguarding requirements for the funds
and securities over which it has custody (beyond constructive custody via direct fee deduction),
Family Legacy, Inc. has retained an independent public accountant to conduct an annual surprise
examination of these assets.
All clients receiving portfolio management services should receive at least quarterly statements from
the broker dealer, bank or other quali(cid:976)ied custodian that holds and maintains client’s investment
assets. Family Legacy, Inc. urges you to carefully review such statements and compare such of(cid:976)icial
custodial records to the account statements that we provide to you. Our statements may vary from
custodial statements based on accounting procedures, reporting dates, or valuation methodologies of
certain securities. Should you note any discrepancy including failure to receive a periodic statement,
please call Christopher A. Brown, the President at 864- 233-0808.
Item 16 – Investment Discretion
Family Legacy, Inc. usually receives written discretionary authority from the client at the outset of
an advisory relationship to select the identity and amount of securities to be bought or sold. In all
cases, however, such discretion is to be exercised in a manner consistent with the stated investment
objectives for the particular client account.
12
When selecting securities and determining amounts, Family Legacy, Inc. observes the investment
policies, limitations and restrictions of the clients for which it advises. Investment guidelines and
restrictions must be provided to Family Legacy, Inc. in writing.
Item 17 – Voting Client Securities
Family Legacy, Inc. will exercise proxy voting authority for clients who agree in writing to
participate in the proxy voting services offered by Broadridge, Inc. We believe that this service
provides the most consistent and thorough methodology of voting in shareholder interests. We will
not exercise proxy voting authority for clients who do not wish to participate in this service. Clients
may opt out of this service at no cost. Clients may request a complete copy of our proxy voting
policy and procedures and records regarding how their proxy statements have been voted by
contacting any of our (cid:976)irm’s members. The cost of this service is borne by Family Legacy, Inc. There
is no additional cost to the client.
Family Legacy, Inc. also has an agreement with Broadridge, Inc. to process and administer an asset
recovery service covering Global Securities Class Action lawsuits for its clients. As payment for this
service, Broadridge will receive a fee of 20% of the total reimbursement of any securities class
action settlement it collects. Broadridge will then distribute the remaining funds collected directly
to eligible clients for each class action settlement.
Item 18 – Financial Information
Registered investment advisers are required in this Item to provide you with certain (cid:976)inancial
information or disclosures about an adviser’s (cid:976)inancial condition. Family Legacy, Inc. has no
(cid:976)inancial commitment that impairs its ability to meet contractual and (cid:976)iduciary commitments to
clients and has not been the subject of a bankruptcy proceeding.
13