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Item 1
Cover Page
Farther Finance Advisors, LLC
Form ADV Part 2 Brochure
August 11, 2025
Contact: Christopher C. Powers, Chief Compliance Officer
345 California Street, Suite 600
San Francisco, CA 94104
www.farther.com
This brochure provides information about the qualifications and business practices of Farther
Finance Advisors, LLC. If you have any questions about the contents of this brochure, please contact
Christopher C. Powers at (628) 246-8004 or chris@farther.com. 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.
Additional information about Farther Finance Advisors, LLC also is available on the SEC’s website
at www.adviserinfo.sec.gov.
References herein to Farther Finance Advisors, LLC as a “registered investment adviser” or any
reference to being “registered” does not imply a certain level of skill or training.
Item 2
Material Changes
The main address of Farther Financial Advisors has moved from 575 Market Street, Suite 400, San
Francisco, CA, to 345 California Street, Suite 600, San Francisco, CA 94104.
Farther’s Chief Compliance Officer, Christopher Powers, remains available to address any questions that
an existing or prospective client may have regarding this Brochure.
Item 3
Table of Contents
Item 1 Cover Page .................................................................................................................................... 1
Item 2 Material Changes .......................................................................................................................... 2
Item 3
Table of Contents .......................................................................................................................... 2
Item 4 Advisory Business ........................................................................................................................ 3
Fees and Compensation .............................................................................................................. 10
Item 5
Performance-Based Fees and Side-by-Side Management .......................................................... 11
Item 6
Item 7
Types of Clients .......................................................................................................................... 12
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 12
Item 9 Disciplinary Information ............................................................................................................ 16
Item 10 Other Financial Industry Activities and Affiliations .................................................................. 16
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.............. 17
Item 12 Brokerage Practices .................................................................................................................... 18
Item 13 Review of Accounts .................................................................................................................... 19
Item 14 Client Referrals and Other Compensation .................................................................................. 20
Item 15 Custody ....................................................................................................................................... 21
Investment Discretion ................................................................................................................. 21
Item 16
Item 17 Voting Client Securities .............................................................................................................. 21
Item 18 Financial Information ................................................................................................................. 21
PAGE 2 OF 21
Item 4
Advisory Business
A. Farther Finance Advisors, LLC (“Farther”) is a limited liability company formed in the
state of Delaware. Farther became registered as an Investment Adviser Firm in July 2019.
Farther is solely owned by Farther, Inc., and Mr. Matthews and Mr. Genser are Farther’s
are founding members.
B.
INVESTMENT ADVISORY SERVICES
Farther typically offers advisory services through a website and mobile application portal
(“Platform”) designed to help clients accomplish both near-term and long-term personal
finance goals, where both preservation of capital and capital growth are important
considerations. Through this Platform, Farther offers an in person and online discretionary
investment management service, on a wrap fee basis, designed expressly for investors who
want investment advice for a reasonable price and without a significant time commitment.
Specifically, Farther offers clients investment advice based on personalized information
that each client provides via the firm’s Platform. Farther’s investment strategy is based on
Modern Portfolio Theory which strives to maximize return relative to risk.
Depending upon the circumstance Farther will craft bespoke portfolio allocations or use a
proprietary algorithm to implement model portfolios designed by investment experts with
target asset allocations of equity and fixed-income securities based on the client’s financial
situation, risk tolerance, and time horizon (“Objective”).
Clients who do not wish to use the Platform may also meet directly with several of the
firm’s representatives for advisory services.
When a client deposits money, Farther allocates that money to portfolios based on the
client’s goals, which may include saving for emergencies, retirement, large purchases, or
general long-term savings. In doing so, Farther constructs a combination of securities
purchases to align the client’s account with the corresponding target asset allocation. Upon
a client’s request to withdraw money, a combination of securities sales is initiated while
continuing to pursue the corresponding target asset allocation.
Clients may manually select one of the target asset allocations other than the one
recommended or currently in effect. As clients deposit or withdraw money the
corresponding transactions will rebalance to pursue the modified target asset allocation. If
the holdings of the account significantly deviate from the newly selected target asset
allocation, then Farther will initiate a rebalancing to bring the holdings within an acceptable
range of the target asset allocation.
In the model portfolios, Farther’s algorithm is designed to keep the holdings within each
client’s portfolio within a specified range of the target asset allocation, even when the
market prices fluctuate. Client holdings are rebalanced and dividends are reinvested
automatically. In general, Farther will consider rebalancing whenever the percentage
holding of one or more positions fluctuate 5% above or below its target allocation.
PAGE 3 OF 21
taking
into account
individual
The rebalancing process is automated and not limited to number or frequency of
rebalances. As a result, there is a possibility that Farther may sell overrepresented positions
and use the proceeds to buy underrepresented positions to bring portfolios towards its target
allocation without
tax consequences or market
circumstances.
FARTHER ADVISORS WRAP PROGRAM
Farther sponsors the Farther Advisors Wrap Program (the “Program”) through which it
offers all of its discretionary investment management services. The services offered under,
and the corresponding terms and conditions pertaining to, the Program are discussed in the
Wrap Fee Program Brochure, a copy of which is presented to all prospective Wrap Program
participants.
Under the Program, Farther is able to offer participants discretionary investment advisor
services, for a single specified annual Program fee, inclusive of trade execution, custody,
reporting, account maintenance, investment management fees.
The current annual Program fee generally ranges from 0.35% to 2.00%, depending upon
the complexity of the account, the amount of the client assets in the Program and the
independent/separately managed accounts utilized by the client’s investment portfolio.
The terms and conditions for client participation in the Program are set forth in detail in
the Wrap Fee Program Brochure, which is presented to all prospective Program participants
in accordance with disclosure requirements. All prospective Program participants should
read both the Brochure and the Wrap Fee Program Brochure, and ask any corresponding
questions that they may have, prior to participation in the Program.
As indicated in the Wrap Fee Program Brochure, participation in the Program may cost
more or less than purchasing such services separately. When managing a client’s account
on a wrap fee basis, Farther shall receive as payment for its asset management services, the
balance of the wrap fee after all other non-excluded costs incorporated into the wrap fee
have been deducted. As also indicated in the Wrap Fee Program Brochure, the Program fee
charged by Farther for participation in the Program may be higher or lower than those
charged by other sponsors of comparable wrap fee programs.
Wrap Program-Conflict of Interest. Under Farther’s wrap program, the client generally
receives investment advisory services, the execution of securities brokerage transactions,
custody and reporting services for a single specified fee. When managing a client’s account
on a wrap fee basis, Farther shall receive as payment for its investment advisory services,
the balance of the wrap fee after all other costs incorporated into the wrap fee have been
deducted.
Because wrap program transaction fees and/or commissions are being paid by Farther to
the account custodian/broker-dealer, Farther has an economic incentive to maximize its
compensation by seeking to minimize the number of trades in the client's account.
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RETIREMENT PLAN SERVICES
Farther also provides retirement plan consulting services, pursuant to which it assists
sponsors of self-directed and pooled retirement plans organized under the Employee
Retirement Security Act of 1974 (“ERISA”). The terms and conditions of the engagement
shall be set forth in the agreement between Farther and the plan sponsor.
If the plan sponsor engages Farther in a ERISA Section 3(21) capacity, Farther will assist
with the selection and/or monitoring of investment options (generally open-end mutual
funds and exchange traded funds) from which plan participants shall choose in self-
directing the investments for their individual plan retirement accounts.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. To the extent requested by a client, Farther may provide financial planning and
related consulting services. Neither Farther nor its investment adviser representatives assist
clients with the implementation of any financial plan, unless they have agreed to do so in
writing. Farther does not monitor a client’s financial plan, and it is the client’s
responsibility to revisit the financial plan with Farther, if desired.
Furthermore, although Farther may provide recommendations regarding non-investment
related matters, such as estate planning, tax planning and insurance, Farther does not serve
as a law firm or accounting firm and no portion of Farther’s services should be construed
as legal or accounting services. Accordingly, Farther does not prepare estate planning
documents or tax returns.
To the extent requested by a client, Farther may recommend the services of other
professionals for certain non-investment implementation purpose (i.e., attorneys,
accountants, insurance agents, etc.), including certain of its related persons in their capacity
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 Farther
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. At all times, the engaged licensed professional[s]
(i.e., attorney, accountant, etc.), and not Farther, shall be responsible for the quality and
competency of the services provided.
Cash Positions. Farther continues to treat cash as an asset class. As such, unless
determined to the contrary by Farther, all cash positions (money markets, etc.) shall
continue to be included as part of assets under management for purposes of calculating
Farther’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated market
conditions/events will occur), Farther may maintain cash positions for defensive purposes.
In addition, while assets are maintained in cash, such amounts could miss market advances.
Depending upon current yields, at any point in time, Farther’s advisory fee could exceed
the interest paid by the client’s money market fund.
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When the account is holding cash positions, those cash positions will be subject to the same
fee schedule as set forth below.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from
account transactions or new deposits, be swept to and/or initially maintained in a specific
custodian designated sweep account. The yield on the sweep account will generally be
lower than those available for other money market accounts. When this occurs, to help
mitigate the corresponding yield dispersion Farther shall (usually within 30 days thereafter)
generally (with exceptions) purchase a higher yielding money market fund (or other type
security) available on the custodian’s platform, unless Farther reasonably anticipates that
it will utilize the cash proceeds during the subsequent 30-day period to purchase additional
investments for the client’s account. Exceptions and/or modifications can and will occur
with respect to all or a portion of the cash balances for various reasons, including, but not
limited to the amount of dispersion between the sweep account and a money market fund,
the size of the cash balance, an indication from the client of an imminent need for such
cash, or the client has a demonstrated history of writing checks from the account.
The above does not apply to the cash component maintained within a Farther actively
managed investment strategy (the cash balances for which shall generally remain in the
custodian designated cash sweep account), an indication from the client of a need for access
to such cash, assets allocated to an unaffiliated investment manager and cash balances
maintained for fee billing purposes.
The client shall remain exclusively responsible for yield dispersion/cash balance decisions
and corresponding transactions for cash balances maintained in any Farther unmanaged
accounts.
Unaffiliated Private Investment Funds. Farther also provides investment advice
regarding private investment funds. Farther, on a non-discretionary basis, may recommend
that certain qualified clients consider an investment in private investment funds, the
description of which (the terms, conditions, risks, conflicts and fees, including incentive
compensation) is set forth in the fund’s offering documents. Farther’s role relative to
unaffiliated private investment funds shall be limited to its initial and ongoing due diligence
and investment monitoring services. If a client determines to become an unaffiliated private
fund investor, the amount of assets invested in the fund(s) shall be included as part of
“assets under management” for purposes of Farther calculating its investment advisory fee.
Farther’s fee shall be in addition to the fund’s fees. Farther’s clients are under absolutely
no obligation to consider or make an investment in any private investment fund(s).
Private investment funds generally involve various risk factors, including, but not limited
to, potential for complete loss of principal, liquidity constraints and lack of transparency,
a complete discussion of which is set forth in each fund’s offering documents, which will
be provided to each client for review and consideration. Unlike liquid investments that a
client may own, private investment funds do not provide daily liquidity or pricing. Each
prospective client investor will be required to complete a Subscription Agreement,
pursuant to which the client shall establish that he/she is qualified for investment in the
fund, and acknowledges and accepts the various risk factors that are associated with such
an investment.
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Valuation. In the event that Farther references private investment funds owned by the client
on any supplemental account reports prepared by Farther, the value(s) for all private
investment funds owned by the client shall reflect the most recent valuation provided by
the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated
valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase,
the fund provides an updated valuation, then the statement will reflect that updated value.
The updated value will continue to be reflected on the report until the fund provides a
further updated value.
As result of the valuation process, if the valuation reflects initial purchase price or an
updated value subsequent to purchase price, the current value(s) of an investor’s fund
holding(s) could be significantly more or less than the value reflected on the report. Unless
otherwise indicated, Farther shall calculate its fee based upon the latest value provided by
the fund sponsor.
Bitcoin, Cryptocurrency, and Digital Assets. Farther does not recommend or advocate
for the purchase of, or investment in, Bitcoin, cryptocurrencies, or digital assets. Such
investments are considered speculative and carry significant risk. For clients who want
exposure to Bitcoin, cryptocurrencies, or digital assets, Farther, may advise the client to
consider a potential investment in corresponding exchange traded securities, or an
allocation to separate account managers and/or private funds that provide cryptocurrency
exposure.
Bitcoin and cryptocurrencies are digital assets that can be used for various purposes,
including transactions, decentralized applications, and speculative investments. Most
digital assets use blockchain technology, an advanced cryptographic digital ledger to
secure transactions and validate asset ownership. Unlike conventional currencies issued
and regulated by monetary authorities, cryptocurrencies generally operate without
centralized control, and their value is determined by market supply and demand. While
regulatory oversight of digital assets has evolved significantly since their inception, they
remain subject to variable regulatory treatment globally, which may impact their risk
profile and liquidity.
Given that cryptocurrency investments are speculative and subject to extreme price
volatility, liquidity constraints, and the potential for total loss of principal, Farther does not
exercise discretionary authority to purchase cryptocurrency investments for client
accounts. Any investment in cryptocurrencies must be expressly authorized by the client.
Clients who authorize the purchase of a cryptocurrency investment must be prepared for
the potential for liquidity constraints, extreme price volatility, regulatory risk,
technological risk, security and custody risk, and complete loss of principal.
Retirement Rollovers-Potential for Conflict of Interest. A client or prospective client
leaving an employer typically has four options regarding an existing retirement plan (and
may engage in a combination of these options): (i) leave the money in the former
employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is
available and rollovers are permitted, (iii) roll over to an Individual Retirement Account
(“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age,
result in adverse tax consequences). If Farther recommends that a client roll over their
PAGE 7 OF 21
retirement plan assets into an account to be managed by Farther, such a recommendation
creates a conflict of interest if Farther will earn new (or increase its current) compensation
as a result of the rollover. If Farther provides a recommendation as to whether a client
should engage in a rollover or not, Farther is acting as a fiduciary 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. No client is under any
obligation to roll over retirement plan assets to an account managed by Farther.
Account Aggregation Reporting Services. Farther uses account aggregation software,
which can incorporate client investment assets that are not part of the assets that Farther
manages (the “Excluded Assets”). Unless agreed to otherwise, in writing, the client and/or
their other advisors that maintain trading authority, and not Farther, shall be exclusively
responsible for the investment performance of the Excluded Assets. Unless also agreed to
otherwise, in writing, Farther does not provide investment management, monitoring or
implementation services for the Excluded Assets. The client can engage Farther to provide
investment management services for the Excluded Assets pursuant to the terms and
conditions of the Investment Advisory Agreement between Farther and the client.
Independent Managers. Farther may allocate a portion of the 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. Farther shall continue to render investment supervisory services to the client relative
to the ongoing monitoring and review of account performance, asset allocation and client
investment objectives. Factors that Farther 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 fee charged by the Independent Manager[s] is separate from, and
in addition to, Farther’s investment advisory fee disclosed at Item 5 below.
the
Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing
involves
incorporation of Environmental, Social and Governance (“ESG”)
considerations into the investment due diligence process. Farther does not maintain or
advocate an ESG investment strategy but will seek to employ ESG if directed by a client
to do so. If implemented, Farther shall rely upon the assessments undertaken by the
unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to
determine that the fund’s or portfolio’s underlying company securities meet a socially
responsible mandate.
ESG investing incorporates a set of criteria/factors used in evaluating potential
investments: Environmental (i.e., considers how a company safeguards the environment);
Social (i.e., the manner in which a company manages relationships with its employees,
customers, and the communities in which it operates); and Governance (i.e., company
management considerations). The number of companies that meet an acceptable ESG
mandate can be limited when compared to those that do not and could underperform broad
market indices.
Investors must accept these limitations, including potential for underperformance.
Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited
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when compared to those that do not maintain such a mandate. As with any type of
investment (including any investment and/or investment strategies recommended and/or
undertaken by Farther), there can be no assurance that investment in ESG securities or
funds will be profitable or prove successful.
Use Mutual Funds and Exchange Traded Funds: Farther may recommend that clients
allocate investment assets to publicly available mutual funds and/or ETFs that the client
could obtain without engaging Farther as an investment adviser. However, if a client or
prospective client determines to allocate investment assets to publicly available mutual
funds or ETFs without engaging Farther as an investment adviser, the client or prospective
client would not receive the benefit of Farther’s initial and ongoing investment advisory
services.
Portfolio Activity. Farther has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Farther will review client
portfolios on an ongoing basis to determine if any changes are necessary based upon
various factors, including, but not limited to, investment performance, fund manager
tenure, style drift, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time
when Farther determines that changes to a client’s portfolio are neither necessary nor
prudent. Clients nonetheless remain subject to the fees described in Item 5 below during
periods of account inactivity.
Client Obligations. In performing its services, Farther 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 Farther if there is ever any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating or revising
Farther’s previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that Farther and its
third-party service providers use to provide services to Farther’s clients employ various
controls that are designed to prevent cybersecurity incidents stemming from intentional or
unintentional actions that could cause significant interruptions in Farther’s operations
and/or result in the unauthorized acquisition or use of clients’ confidential or non-public
personal information.
In accordance with Regulation S-P, Farther is committed to protecting the privacy and
security of its clients' non-public personal information by implementing appropriate
administrative, technical, and physical safeguards. Farther has established processes to
mitigate the risks of cybersecurity incidents, including the requirement to restrict access to
such sensitive data and to monitor its systems for potential breaches. Clients and Farther
are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause
them to incur financial losses and/or other adverse consequences.
Although Farther has established processes to reduce the risk of cybersecurity incidents,
there is no guarantee that these efforts will always be successful, especially considering
that Farther does not control the cybersecurity measures and policies employed by third-
party service providers, issuers of securities, broker-dealers, qualified custodians,
PAGE 9 OF 21
governmental and other regulatory authorities, exchanges, and other financial market
operators and providers. In compliance with Regulation S-P, Farther will notify clients in
the event of a data breach involving their non-public personal information as required by
applicable state and federal laws.
Disclosure Statement. A copy of Farther’s written Brochure as set forth on Part 2 of Form
ADV and Client Relationship Summary as set forth in Form CRS shall be provided to each
client prior to, or contemporaneously with, the execution of the Investment Advisory
Agreement.
C. Farther shall provide investment advisory services specific to the needs of each client. Prior
to providing investment advisory services, an investment adviser representative will
ascertain each client’s investment objective(s). Thereafter, Farther shall allocate and/or
recommend that the client allocate investment assets consistent with the designated
investment objective(s). The client may, at any time, impose reasonable restrictions, in
writing, on Farther’s services.
D. As discussed above, Farther only provides its investment management services on a wrap
fee basis. If a client determines to engage Farther, the client will pay a single fee for
bundled services (i.e., investment advisory, brokerage, custody) (See Item 4.B). The
services included in a wrap fee agreement will depend upon each client’s particular need.
When managing a client’s account on a wrap fee basis, Farther shall receive as payment
for its investment advisory services, the balance of the wrap fee after all other costs
incorporated into the wrap fee have been deducted.
E. As of June 26, 2025, Farther had $7,112,954,570 in assets under management on a
discretionary basis and $410,856,307on a non-discretionary basis.
Item 5
Fees and Compensation
A.
INVESTMENT ADVISORY SERVICES
Under the Program, Farther is able to offer participants discretionary investment
management services, for a single specified annual Program fee, inclusive of trade
execution, custody, reporting, account maintenance, investment management fees, and in
some instances, fees charged by independent managers and/or separately managed
accounts.
The current annual Program fee ranges from negotiable up to 2% of assets under
management, depending upon the complexity of the account, the amount of the client assets
in the Program and the independent/separately managed accounts utilized by the client’s
investment portfolio. Farther may, at its sole discretion, elect to offer its services on a
hourly rate basis, ranging from negotiable up to $1,000 per hour, or on a flat annual fee
basis.
Clients may be responsible for, but not limited to, fees for trades executed away from the
account’s custodian, trustee fees, mutual fund internal expenses, ETF internal expenses,
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mark-ups, mark-downs, transfer taxes, fees charged by independent managers and/or
separately managed accounts (when such managers require the client to enter into a dual
contract relationship) odd lot differentials, exchange fees, interest charges, American
Depository Receipt agency processing fees, and any charges, taxes or other fees mandated
by any federal, state or other applicable law or otherwise agreed to with regard to client
accounts (Such fees are in addition to any fees paid by the client to Farther and are between
the client and the account custodian). These fees are in addition to Farther’s Program fee.
RETIREMENT PLAN SERVICES
Farther provides retirement plan consulting services, in the capacity of a 3(21) advisor,
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. Farther’s
annual fee for these services shall generally range from negotiable up to 2.00% of the total
assets maintained within the plan.
B. Clients may elect to have Farther’s advisory fees deducted from their custodial account.
Both Farther's Investment Advisory Agreement and the custodial/clearing agreement may
authorize the custodian to debit the account for the amount of Farther's investment advisory
fee and to directly remit that management fee to Farther in compliance with regulatory
procedures. In the limited event that Farther bills the client directly, payment is due upon
receipt of Farther’s invoice.
C. As discussed below, unless the client directs otherwise or an individual client’s
circumstances require, Farther generally recommends that Charles Schwab Corporation
(“Schwab”), Apex Clearing Corporation, (“Apex”), Fidelity Investments (“Fidelity”)
and/or Pershing, LLC (“Pershing”) serve as the broker-dealer/custodian for client
investment management assets. Broker-dealers such as Schwab, Apex, Fidelity and
Pershing charge brokerage commissions and/or transaction fees for effecting certain
securities transactions. However, under Farther’s Program, Farther shall generally be
responsible for these fees.
D. Farther's annual investment advisory fee shall be prorated and paid monthly, in advance,
based upon the market value of the assets, on the last business day of the previous month.
The Investment Advisory Agreement between Farther and the client will continue in effect
until terminated by either party by written notice in accordance with the terms of the
Investment Advisory Agreement. Upon termination, Farther shall refund the pro-rated
portion of the advanced advisory fee paid based upon the number of days remaining in the
billing quarter.
E. Neither Farther, nor its representatives accept compensation from the sale of securities or
other investment products.
Item 6
Performance-Based Fees and Side-by-Side Management
Neither Farther nor any supervised person of Farther accepts performance-based fees.
PAGE 11 OF 21
Item 7
Types of Clients
Farther’s clients shall generally include individuals, trusts and estates.
Farther, in its sole discretion, may charge a lesser investment management fee based upon
certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets,
dollar amount of assets to be managed, householdings of related accounts, account
composition, negotiations with client, etc.).
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
A. Farther may utilize the following methods of security analysis:
● Fundamental - (analysis performed on historical and present data, with the goal of
making financial forecasts)
● Technical – (analysis performed on historical and present data, focusing on price
and trade volume, to forecast the direction of prices)
● Cyclical – (analysis performed on historical relationships between price and
market trends, to forecast the direction of prices)
Farther may utilize the following investment strategies when implementing investment
advice given to clients:
● Long Term Purchases (securities held at least a year)
● Short Term Purchases (securities sold within a year)
Investment Risk. 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 Farther) will be profitable or equal any specific performance level(s).
Investing in securities involves risk of loss that clients should be prepared to bear.
Investors generally face the following types investment risks:
●
Interest-rate Risk: Fluctuations in interest rates may cause investment prices
to fluctuate. For example, when interest rates rise, yields on existing bonds
become less attractive, causing their market values to decline.
● Market Risk: The price of a security, bond, or mutual fund may drop in
reaction to tangible and intangible events and conditions. This type of risk
may be caused by external factors independent of the fund’s specific
investments as well as due to the fund’s specific investments. Additionally,
each security’s price will fluctuate based on market movement and emotion,
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.
●
Inflation Risk: When any type of inflation is present, a dollar today will not
buy as much as a dollar next year, because purchasing power is eroding at the
rate of inflation.
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● Reinvestment Risk: This is the risk that future proceeds from investments may
have to be reinvested at a potentially lower rate of return (i.e., interest rate).
This primarily relates to fixed income securities.
● Liquidity Risk: Liquidity is the ability to readily convert an investment into
cash. Generally, assets are more liquid if many traders are interested in a
standardized product. For example, Treasury Bills are highly liquid, while real
estate properties are not.
● Financial Risk: Excessive borrowing to finance a business’ operations
increases the risk of profitability, because the company must meet the terms of
its obligations in good times and bad. During periods of financial stress, the
inability to meet loan obligations may result in bankruptcy and/or a declining
market value.
B. Farther’s method of analysis and investment strategy does not present any significant or
unusual risks.
However, every method of analysis has its own inherent risks. To perform an accurate
market analysis Farther must have access to current/new market information. Farther has
no control over the dissemination rate of market information; therefore, unbeknownst to
Farther, certain analyses may be compiled with outdated market information, severely
limiting the value of Farther’s analysis. Furthermore, an accurate market analysis can only
produce a forecast of the direction of market values. There can be no assurances that a
forecasted change in market value will materialize into actionable and/or profitable
investment opportunities.
Farther’s primary investment strategies - Long Term Purchases and Short Term Purchases
- are fundamental investment strategies. 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.
Borrowing Against Assets/Risks. A client who has a need to borrow money could
determine to do so by using:
● Margin-The account custodian or broker-dealer lends money to the
client. The custodian charges the client interest for the right to borrow
money, and uses the assets in the client’s brokerage account as
collateral; and,
● Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.)
to make a loan to the client, the client pledges its investment assets
held at the account custodian as collateral;
These above-described collateralized loans are generally utilized because they typically
provide more favorable interest rates than standard commercial loans. These types of
collateralized loans can assist with a pending home purchase, permit the retirement of more
expensive debt, or enable borrowing in lieu of liquidating existing account positions and
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incurring capital gains taxes. However, such loans are not without potential material risk
to the client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse
against the client’s investment assets in the event of loan default or if the assets fall below
a certain level. For this reason, Farther does not recommend such borrowing unless it is for
specific short-term purposes (i.e., a bridge loan to purchase a new residence). Farther does
not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in
the market). Regardless, if the client was to determine to utilize margin or a pledged assets
loan, the following economic benefits would inure to Farther:
● by taking the loan rather than liquidating assets in the client’s account,
●
●
Farther continues to earn a fee on such Account assets; and,
if the client invests any portion of the loan proceeds in an account to
be managed by Farther, Farther will receive an advisory fee on the
invested amount; and,
if Farther’s advisory fee is based upon the higher margined account
value, Farther will earn a correspondingly higher advisory fee. This
could provide Farther with a disincentive to encourage the client to
discontinue the use of margin.
The Client must accept the above risks and potential corresponding consequences
associated with the use of margin or a pledged assets loans.
Options Strategies.
In limited situations, generally upon client direction and/or, Farther may engage in options
transactions (or engage an independent investment manager to do so) for the purpose of
hedging risk and/or generating portfolio income. The use of options transactions as an
investment strategy can involve a high level of inherent risk. Option transactions establish
a contract between two parties concerning the buying or selling of an asset at a
predetermined price during a specific period of time. During the term of the option contract,
the buyer of the option gains the right to demand fulfillment by the seller. Fulfillment may
take the form of either selling or purchasing a security, depending upon the nature of the
option contract. Generally, the purchase or sale of an option contract shall be with the intent
of “hedging” a potential market risk in a client’s portfolio and/or generating income for a
client’s portfolio.
Certain options-related strategies (i.e., straddles, short positions, etc.), may, in and of
themselves, produce principal volatility and/or risk. Thus, a client must be willing to accept
these enhanced volatility and principal risks associated with such strategies. In light of
these enhanced risks, client may direct Farther, in writing, not to employ any or all such
strategies for his/her/their/its accounts.
Covered Call Writing.
Covered call writing is the sale of in-, at-, or out-of-the-money call options against a long
security position held in a client portfolio. This type of transaction is intended to generate
income. It also serves to create partial downside protection in the event the security position
declines in value. Income is received from the proceeds of the option sale. Such income
may be reduced or lost to the extent it is determined to buy back the option position before
its expiration. There can be no assurance that the security will not be called away by the
option buyer, which will result in the client (option writer) to lose ownership in the security
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and incur potential unintended tax consequences. Covered call strategies are generally
better suited for positions with lower price volatility.
C. Currently, Farther primarily allocates client investment assets among various exchange
traded funds, mutual funds, individual equities and fixed income securities on a
discretionary basis in accordance with the client’s designated investment objective(s).
Farther may also allocate investment management assets of its client accounts, on a
discretionary basis, among one or more of its asset allocation models described below.
Farther’s asset allocation model administration has been designed to comply with the
requirements of Rule 3a-4 of the Investment Company Act of 1940. Rule 3a-4 provides
similarly managed investment programs with a non-exclusive safe harbor from the
definition of an investment company. In accordance with Rule 3a-4, the following
disclosure is applicable to Farther’s management of client assets asset allocation models:
1. Initial Interview – at the opening of the account, Farther, through its designated
representatives, shall obtain from the client information sufficient to determine the client’s
financial situation and investment objectives;
2. Individual Treatment - the account is managed on the basis of the client’s financial
situation and investment objectives;
3. Quarterly Notice – at least quarterly Farther shall notify the client to advise Farther
whether the client’s financial situation or investment objectives have changed, or if the
client wants to impose and/or modify any reasonable restrictions on the management of the
account;
4. Annual Contact – at least annually, Farther shall contact the client to determine whether
the client’s financial situation or investment objectives have changed, or if the client wants
to impose and/or modify any reasonable restrictions on the management of the account;
5. Consultation Available – Farther shall be reasonably available to consult with the client
relative to the status of the account;
6. Quarterly Report – the client shall be provided with a quarterly report for the account
for the preceding period;
7. Ability to Impose Restrictions – the client shall have the ability to impose reasonable
restrictions on the management of the account, including the ability to instruct Farther not
to purchase certain securities;
8. No Pooling – the client’s beneficial interest in a security does not represent an undivided
interest in all the securities held by the custodian, but rather represents a direct and
beneficial interest in the securities which comprise the account;
9. Separate Account - a separate account is maintained for the client with the Custodian;
10. Ownership – each client retains indicia of ownership of the account (e.g., right to
withdraw securities or cash, exercise or delegate proxy voting, and receive transaction
confirmations).
Farther believes that its annual investment management fee is reasonable in relation to: (1)
the advisory services provided under the Investment Advisory Agreement; and (2) the fees
charged by other investment advisers offering similar services/programs. However,
Farther’s annual investment advisory fee may be higher than that charged by other
investment advisers offering similar services/programs. In addition to Farther’s annual
investment management fee, the client will also incur charges imposed directly at the
mutual and exchange traded fund level (e.g., management fees and other fund expenses).
PAGE 15 OF 21
Farther’s investment programs may involve above-average portfolio turnover which could
negatively impact upon the net after-tax gain experienced by an individual client in a
taxable account.
Item 9
Disciplinary Information
Farther has not been the subject of any disciplinary actions.
Item 10
Other Financial Industry Activities and Affiliations
A. Neither Farther, nor its representatives, are registered or have an application pending to
register, as a broker-dealer or a registered representative of a broker-dealer.
B. Neither Farther, nor its representatives, are registered or have an application pending to
register, as a futures commission merchant, commodity pool operator, a commodity trading
advisor, or a representative of the foregoing
C. Affiliated Investment Adviser Firm. Farther is under common ownership with Farther
Asset Management, LLC (“FAM”), an affiliated, SEC Registered investment advisor firm
(SEC# 801-128146). FAM generally provides discretionary investment management
services to institutional clients. Farther has been engaged by FAM to provide sub-advisory
services in connection with FAM’s discretionary investment management of client assets.
FAM clients do not pay an additional fee as a result of this sub-advisory relationship.
Affiliated Licensed Insurance Agency/Agents. Farther Insurance Group, LLC is an
affiliated licensed insurance agency. Furthermore, certain of Farther’s representatives, in
their individual capacities, are licensed insurance agents. Farther and/or its representatives
may recommend the purchase of certain insurance-related products on a commission basis.
As referenced in Item 4.B above, clients can engage certain of Farther’s representatives to
purchase insurance products on a commission basis.
The recommendation by representatives of Farther that a client purchase an insurance
commission product presents a conflict of interest, as the receipt of commissions may
provide an incentive to recommend investment products based on commissions to be
received, rather than on a particular client’s need. No client is under any obligation to
purchase any commission products from representatives of Farther or through Farther
Insurance Group, LLC in its capacity as a licensed insurance agency. Clients are reminded
that they may purchase insurance products recommended by Farther through other, non-
affiliated insurance agencies and/or agents.
D. Farther may recommend, for compensation the third-party plan administrator services of
NestEggs, an independent third-party plan administrator. NestEggs may also, from time-
to-time, refer plan sponsors to Farther for Retirement Plan Services (See Items 4 and 5
above). In addition to the compensation received from NestEggs for referrals, Farther has
an incentive to recommend NestEggs based upon the client introductions made to Farther
by NestEggs. No client or perspective client is obligated to engage the services of
PAGE 16 OF 21
NestEggs. Furthermore, Farther shall not receive any referral compensation from NestEggs
in connection with any plan for which Farther services as an ERISA fiduciary.
Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. Farther maintains an investment policy relative to personal securities transactions. This
investment policy is part of Farther’s overall Code of Ethics, which serves to establish a
standard of business conduct for all of Farther’s Representatives that is based upon
fundamental principles of openness, integrity, honesty and trust, a copy of which is
available upon request.
In accordance with Section 204A of the Investment Advisers Act of 1940, Farther also
maintains and enforces written policies reasonably designed to prevent the misuse of
material non-public information by Farther or any person associated with Farther.
B. Neither Farther nor any related person of Farther recommends, buys, or sells for client
accounts, securities in which Farther or any related person of Farther has a material
financial interest.
C. Farther and/or representatives of Farther may buy or sell securities that are also
recommended to clients. This practice may create a situation where Farther and/or
representatives of Farther are in a position to materially benefit from the sale or purchase
of those securities. Therefore, this situation creates a conflict of interest. Practices such as
“scalping” (i.e., a practice whereby the owner of shares of a security recommends that
security for investment and then immediately sells it at a profit upon the rise in the market
price which follows the recommendation) could take place if Farther did not have adequate
policies in place to detect such activities. In addition, this requirement can help detect
insider trading, “front-running” (i.e., personal trades executed prior to those of Farther’s
clients) and other potentially abusive practices.
Farther has a personal securities transaction policy in place to monitor the personal
securities transactions and securities holdings of each of Farther’s “Access Persons.”
Farther’s securities transaction policy requires that Access Person of Farther must provide
the Chief Compliance Officer or his/her designee with online access to their holdings and
securities transactions for monitoring and verification purposes.
D. Farther and/or representatives of Farther may buy or sell securities, at or around the same
time as those securities are recommended to clients. This practice creates a situation where
Farther and/or representatives of Farther are in a position to materially benefit from the
sale or purchase of those securities. Therefore, this situation creates a conflict of interest.
As indicated above in Item 11C, Farther has a personal securities transaction policy in place
to monitor the personal securities transaction and securities holdings of each of Farther’s
Access Persons.
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Item 12
Brokerage Practices
A. In the event that the client requests that Farther recommend a broker-dealer/custodian for
execution and/or custodial services (exclusive of those clients that may direct Farther to
use a specific broker-dealer/custodian), Farther generally recommends that investment
management accounts be maintained at Schwab, Apex, Fidelity or Pershing. Prior to
engaging Farther to provide investment management services, the client will be required
to enter into a formal Investment Advisory Agreement with Farther setting forth the terms
and conditions under which Farther shall manage the client's assets, and a separate
custodial/clearing agreement with each designated broker-dealer/ custodian.
Factors that Farther considers in recommending Schwab, Apex, Fidelity or Pershing (or
any other broker-dealer/custodian to clients) include historical relationship with Farther,
financial strength, reputation, execution capabilities, pricing, research, and service.
In seeking best execution, the determinative factor is not the lowest possible cost, but
whether the transaction represents the best qualitative execution, taking into consideration
the full range of broker-dealer services, including the value of research provided, execution
capability, commission rates, and responsiveness. Accordingly, although Farther will seek
competitive rates, it may not necessarily obtain the lowest possible commission rates for
client account transactions. Farther’s best execution responsibility is qualified if securities
that it purchases for client accounts are mutual funds that trade at net asset value as
determined at the daily market close.
1. Research and Additional Benefits
Although not a material consideration when determining whether to recommend that a
client utilize the services of a particular broker-dealer/custodian, Farther may receive
from Schwab, Apex, Fidelity or Pershing (or another broker-dealer/custodian,
investment manager, vendor, unaffiliated
investment platform, unaffiliated
product/fund sponsor, or vendor) without cost (and/or at a discount) support services
and/or products, certain of which assist Farther to better monitor and service client
accounts maintained at such institutions. Included within the support services that may
be obtained by Farther may be investment-related research, pricing information and
market data, software and other technology that provide access to client account data,
compliance and/or practice management-related publications, discounted or gratis
consulting services, discounted and/or gratis attendance at conferences, meetings, and
other educational and/or social events, marketing support, computer hardware and/or
software and/or other products used by Farther in furtherance of its investment
advisory business operations.
As indicated above, certain of the support services and/or products that may be received
may assist Farther in managing and administering client accounts. Others do not
directly provide such assistance, but rather assist Farther to manage and further develop
its business enterprise.
There is no corresponding commitment made by Farther to Schwab, Apex, Fidelity,
Pershing or any other entity to invest any specific amount or percentage of client assets
in any specific mutual funds, securities or other investment products as a result of the
above arrangement.
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Farther’s Chief Compliance Officer, Christopher Powers, remains available to address
any questions that a client or prospective client may have regarding the above
arrangement and any corresponding conflict of interest.
2. Farther does not receive referrals from broker-dealers.
3. Farther does not generally accept directed brokerage arrangements (when a client
requires that account transactions be effected through a specific broker-dealer). In such
client directed arrangements, the client will negotiate terms and arrangements for their
account with that broker-dealer, and Farther will not seek better execution services or
prices from other broker-dealers or be able to "batch" the client's transactions for
execution through other broker-dealers with orders for other accounts managed by
Farther. As a result, client may pay higher commissions or other transaction costs or
greater spreads, or receive less favorable net prices, on transactions for the account
than would otherwise be the case.
In the event that the client directs Farther to effect securities transactions for the client's
accounts through a specific broker-dealer, the client correspondingly acknowledges
that such direction may cause the accounts to incur higher commissions or transaction
costs than the accounts would otherwise incur had the client determined to effect
account transactions through alternative clearing arrangements that may be available
through Farther. Higher transaction costs adversely impact account performance.
Transactions for directed accounts will generally be executed following the execution
of portfolio transactions for non-directed accounts.
B. To the extent that Farther provides investment management services to its clients, the
transactions for each client account generally will be effected independently, unless
Farther decides to purchase or sell the same securities for several clients at approximately
the same time. Farther may (but is not obligated to) combine or “bunch” such orders to
seek best execution, to negotiate more favorable commission rates or to allocate equitably
among Farther’s clients differences in prices and commissions or other transaction costs
that might have been obtained had such orders been placed independently. Under this
procedure, transactions will be averaged as to price and will be allocated among clients in
proportion to the purchase and sale orders placed for each client account on any given day.
Farther shall not receive any additional compensation or remuneration as a result of such
aggregation.
Item 13
Review of Accounts
A. For those clients to whom Farther provides investment supervisory services, account
reviews are conducted on a periodic basis by Farther's representatives, at least annually.
All investment supervisory clients are advised that it remains their responsibility to advise
Farther of any changes in their investment objectives and/or financial situation. All clients
(in person or via telephone) are encouraged to review financial planning issues (to the
extent applicable), investment objectives and account performance with Farther on an
annual basis.
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B. Farther may conduct account reviews on an other than periodic basis upon the occurrence
of a triggering event, such as a change in client investment objectives and/or financial
situation, market corrections and client request.
C. Clients are provided, at least quarterly, with written transaction confirmation notices and
regular written summary account statements directly from the broker-dealer/custodian
and/or program sponsor for the client accounts. Farther may also provide a written periodic
report summarizing account activity and performance.
Item 14
Client Referrals and Other Compensation
A. As referenced in Item 12.A.1 above, Farther may receive an economic benefit from
Schwab, Apex, Fidelity or Pershing. Farther, without cost (and/or at a discount), receives
support services and/or products from Schwab, Apex, Fidelity and Pershing.
There is no corresponding commitment made by Farther to Apex, Schwab, Fidelity or
Pershing or any other entity to invest any specific amount or percentage of client assets in
any specific mutual funds, securities or other investment products as a result of the above
arrangement.
B. Farther engages independent promoters to provide endorsements. If a client is referred to
Farther by a promoter, this practice is disclosed to the client in writing by the promoter and
Farther pays the promoter out of its own funds—specifically, Farther generally pays the
promoter a portion of the advisory fees earned for managing the capital of the client or
investor that was referred. The use of promoters is strictly regulated under applicable
federal and state law. Farther’s policy is to fully comply with the requirements of Rule
206(4)-1, under the Investment Advisers Act of 1940, as amended, and similar state rules,
as applicable.
Farther may receive client referrals from Zoe Financial, Inc through its participation in Zoe
Advisor Network (ZAN). Zoe Financial, Inc is independent of and unaffiliated with Farther
and there is no employee relationship between them. Zoe Financial established the Zoe
Advisor Network as a means of referring individuals and other investors seeking fiduciary
personal investment management services or financial planning services to independent
investment advisors. Zoe Financial does not supervise Farther and has no responsibility for
Farther’s management of client portfolios or Farther’s other advice or services. Farther
pays Zoe Financial an on-going fee for each successful client referral. This fee is usually a
percentage of the advisory fee that the client pays to Farther (“Promoter Fee”). Farther will
not charge clients referred through Zoe Advisor Network any fees or costs higher than its
standard fee schedule offered to its clients. For information regarding additional or other
fees paid directly or indirectly to Zoe Financial Inc, please refer to the Zoe Financial
Disclosure and Acknowledgement Form.
PAGE 20 OF 21
Item 15
Custody
Farther shall have the ability to have its advisory fee for each client debited by the custodian
on a monthly basis. Clients are provided, at least monthly, with written transaction
confirmation notices and regular written summary account statements directly from the
broker-dealer/custodian and/or program sponsor for the client accounts. Farther may also
provide a written periodic report summarizing account activity and performance.
To the extent that Farther provides clients with periodic account statements or reports, the
client is urged to compare any statement or report provided by Farther with the account
statements received from the account custodian.
The account custodian does not verify the accuracy of Farther’s advisory fee calculation.
Item 16
Investment Discretion
The client can determine to engage Farther to provide investment advisory services on a
discretionary basis. Prior to Farther assuming discretionary authority over a client’s
account, client shall be required to execute an Investment Advisory Agreement, naming
Farther as client’s attorney and agent in fact, granting Farther full authority to buy, sell, or
otherwise effect investment transactions involving the assets in the client’s name found in
the discretionary account.
Clients who engage Farther on a discretionary basis may, at any time, impose restrictions,
in writing, on Farther’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 proscribe Farther’s use of margin, etc.).
Item 17
Voting Client Securities
A. Farther does not vote client proxies. Clients maintain exclusive responsibility for: (1)
directing the manner in which proxies solicited by issuers of securities beneficially owned
by the client shall be voted, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the
client’s investment assets.
B. Clients will receive their proxies or other solicitations directly from their custodian. Clients
may contact Farther to discuss any questions they may have with a particular solicitation.
Item 18
Financial Information
A. Farther does not solicit fees of more than $1,200, per client, six months or more in advance.
B. Farther 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.
C. Farther has not been the subject of a bankruptcy petition.
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