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Disclosure Brochure
Form ADV, Part 2A
October 6, 2025
FAS Wealth Partners, Inc.
4747 W 135 Street, Suite 100
Leawood, Kansas 66224
913-239-2300
www.faswealthpartners.com
This Brochure (Part 2A of Form ADV) provides information about the qualifications and business practices of
FAS Wealth Partners, Inc. ("FAS"). If you have any questions about the contents of this Brochure, please
contact us at 913-239-2300 or at www.faswealthpartners.com. The information in this Brochure has not been
approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state
securities authority.
FAS is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”).
Registration of an investment adviser does not imply any level of skill or training. The oral and written
communications of an adviser provide you with information you may use to help you determine whether or not
to hire or retain an adviser. Additional information about FAS also is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number known as a CRD number.
Our firm’s CRD number is 109796.
Item 2 – MATERIAL CHANGES____________________________________________________
Information contained in this section relates only to material changes that have occurred since our
last update on February 28, 2025. FAS defines a material change as any change a client would
consider important to know prior to making an investment decision. There are no material changes
incorporated since our last filing of this document.
We will ensure you receive a summary of material changes, if any, to this and subsequent
disclosure brochures within 120 days after our fiscal year-end. We may, at any time, update this
Brochure and either send you a copy or offer to send you a copy.
Currently our Brochure can be requested by contacting Jacque Glenn, Chief Compliance Officer, at
913-239-2300 or by email: jglenn@faswealthpartners.com.
Additional information about FAS is also available via the SEC’s website at
https://adviserinfo.sec.gov/firm/summary/109796. The SEC’s web site also provides information
about any persons affiliated with FAS who are registered, or are required to be registered, as
investment adviser representatives.
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Item 3 – TABLE OF CONTENTS___________________________________________________
Item 4 – ADVISORY BUSINESS ..................................................................................................... 4
Item 5 – FEES AND COMPENSATION ........................................................................................... 9
Item 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................ 12
Item 7 – TYPES OF CLIENTS ...................................................................................................... 12
Item 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .................... 12
Item 9 – DISCIPLINARY INFORMATION ....................................................................................... 15
Item 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................... 15
Item 11 – CODE OF ETHICS ...................................................................................................... 17
Item 12 – BROKERAGE PRACTICES ........................................................................................... 19
Item 13 – REVIEW OF ACCOUNTS .............................................................................................. 23
Item 14 – CLIENT REFERRALS AND OTHER COMPENSATION .................................................... 24
Item 15 – CUSTODY ................................................................................................................... 26
Item 16 – INVESTMENT DISCRETION ......................................................................................... 27
Item 17 – VOTING CLIENT SECURITIES ...................................................................................... 28
Item 18 – FINANCIAL INFORMATION .......................................................................................... 28
Item 19 – REQUIREMENTS FOR STATE-REGISTERED ADVISERS ............................................... 28
FAS PRIVACY POLICY…………………………......………….……………………………………..last page
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Item 4 – ADVISORY BUSINESS_______________________________________________ ____
FAS was founded by Max W. Greer, Jr., in 1979 and was registered with the SEC as a Registered
Investment Adviser in 1983 under the name of Financial Advisory Service, Inc. The firm changed
its name to "FAS Wealth Partners, Inc." in September 2022. Our principal place of business is
located in the State of Kansas. FAS is an S-Corp tax entity formed under the laws of the State of
Kansas. No shareholder directly or indirectly owns more than 25% of the firm. FAS provides fee-
based advisory services.
Assets Under Our Management - As of December 31, 2024, our total assets under management
are $3,085,389,749 of which $3,083,169,400 is managed on a discretionary basis and $2,220,348
is managed on a non-discretionary basis.
Types of Services We Provide
1. General Asset Management:
FAS offers ongoing discretionary asset management services based on your individual goals,
objectives, time horizon and risk tolerance. We provide these services for your individual, estate,
trust, business entity, IRA and other qualified retirement plan investment accounts as you may
choose.
Discretionary management is an arrangement in which we, as your investment manager, make the
buy/sell decisions on your assets and assets selection without consulting with you for every
transaction. You authorize discretionary asset management of your accounts on the Investment
Management Services Agreement you sign with FAS and the appropriate trading authorization
forms with the qualified custodian of your accounts. However, we must operate within the written
goals and agreed upon limits noted in your FAS Investment Objectives Questionnaire in order to
achieve your stated investment objectives.
Through personal discussions with you and/or with an online profile, we assist you in establishing
your goals and objectives based upon your particular circumstances. As appropriate, we also
review and discuss your present financial circumstances and prior investment history as well as
family composition and background. FAS determines your personal investment strategy and then
creates and manages an investment portfolio consisting of one or more FAS managed accounts
(“Investment Portfolio”) based on our mutually agreed upon strategy. FAS offers a menu of several
types of asset allocations for the Investment Portfolio we manage for you as determined by your
risk tolerance and time horizon.
We also manage, at your request and subject to our acceptance, non-discretionary portfolio
management of your accounts. Non-discretionary management is an arrangement where you
direct us to make the buy/sell decisions for your FAS Investment Portfolio.
The custody of your FAS managed assets are predominantly held in institutional accounts under
our master agreements with qualified custodians such as Charles Schwab, Fidelity or T.D.
Ameritrade. We manage some 401(k) participant assets and institutional trustee accounts by
using (1) ByAllAccounts, an account aggregator, or (2) an institutional trustee (i.e. bank trustee)
having custody of trust assets for which you are a grantor, account owner or beneficiary.
We do not accept physical custody of these assets. These qualified custodians provide securities
trading platforms and the electronic reporting and support we need to prepare your quarterly
management reports.
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Management of your Investment Portfolio is guided by your written stated objectives that include:
• Capital Preservation – You are seeking preservation of your capital and to a lesser extent,
having income available for distribution to you. Assets are allocated primarily among fixed
income instruments with minimal exposure to equities for diversification.
• Balanced Income – You are focused more with current income than capital appreciation;
• Balanced – You are focused more with a moderate amount of current income and a
moderate amount of capital appreciation. Assets are allocated approximately evenly
between fixed income and equity securities.
• Balanced Growth – You are concerned more with capital appreciation; generating current
income is a secondary concern. The majority of assets are allocated to equities with some
fixed income exposure for diversification.
• Growth – You are seeking capital appreciation. Assets are invested almost exclusively in
equities leading to both greater volatility and potential return. Current income is not a
concern.
You can request reasonable restrictions on your Investment Portfolio investing in certain securities,
types of securities, or industry sectors or ask us to retain certain securities as you direct, and we
will try to accommodate those requests.
Our investment advice is not limited to any particular or specific product or service offered by any
particular broker-dealer, bank, corporate trustee or insurance company and will include advice
regarding the following investments, if applicable:
Equity Securities
Exchange-listed securities including “ETFs”
Securities traded over-the-counter
Corporate debt securities (other than commercial paper)
Commercial paper
Certificates of deposit
Municipal securities
Variable life insurance
Variable annuities
Mutual fund shares
United States governmental securities
Municipal securities
Options contracts on securities
Alternative Strategies
Other
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• Warrants
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Some types of investments involve additional risk. These investments are only implemented or
recommended when consistent with your stated investment objectives, time horizon, and tolerance
for risk, liquidity and suitability.
2. Financial Planning Services:
We provide financial planning services through our CERTIFIED FINANCIAL PLANNER™
practitioners and other licensed professionals. Our financial planning process considers all of your
questions, information you have provided and analyses to determine the impact upon your entire
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financial and life situations. Our financial planning services are presented as either a
“Comprehensive Financial Plan” or a “Target Financial Plan.”
Comprehensive Financial Plan – This includes a comprehensive evaluation of your current and
future financial situation assessed by using currently known facts used to predict future cash flows,
asset values and withdrawal plans. You will receive a written individualized case study which
provides you with a detailed financial plan designed to assist you in achieving your financial goals
and objectives.
The Comprehensive Financial Plan can address all of the following areas:
•
Personal - We review family records, budgeting, personal liability, estate information
and financial goals;
•
Tax and Cash Flow - We analyze your income tax, spending and planning for past,
current and future years; then illustrate the impact of various investments on your
current income tax and future tax liability. We do not prepare tax returns for you nor do
we include specific tax advice.
•
Investments - We analyze investment alternatives and their effect on your portfolio;
•
Insurance - We review existing policies to ensure adequate coverage for life, health,
disability, long-term care, liability, home and automobile. We do not sell liability,
casualty, home or automobile insurance. Our affiliated broker-dealer, FAS Corp.,
makes available life insurance, annuities and long-term care products to you although
you are free to choose any insurance company/insurance agent you desire.
• Retirement - We analyze current strategies and investment plans to help you work
towards your retirement goals;
• Death and Disability - We review your cash needs at death, income needs of surviving
dependents, estate planning and disability income;
•
Estate - We assist you in assessing and developing long-term strategies. This
includes, as appropriate, living trusts, wills, powers of attorney, asset protection plans,
review of prospective estate/gift tax and/or probate exposure, nursing homes, Medicaid
and elder law. You will need to retain an attorney of your choice to prepare appropriate
estate plan documents.
We gather necessary information through in-depth personal interviews and fact-gathering forms.
Information gathered includes your current financial status, tax status, future goals, returns
objectives and attitudes towards risk. We carefully review documents you supply including a
questionnaire completed by you and prepare a written report outlining a proposed financial plan.
We use one or more licensed software programs to facilitate our financial planning services.
Should you choose to implement recommendations contained in the financial plan, we suggest you
work closely with your own attorney, accountant, insurance agent, and/or other financial advisors.
Implementation of financial plan recommendations is entirely at your discretion. We provide
general non-securities related advice on topics including tax and budgetary planning, retirement
planning, educational planning, estate planning and business planning. If FAS provides a
recommendation for non-investment related services (e.g. tax preparation, accountants or
insurance agents), you are under no obligation to engage the services of such professional.
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In conjunction with all the benefits recognized through the development and implementation of a
Comprehensive Financial Plan, we believe you will find the greatest benefit comes from our
ongoing administration of your plan if you so desire. We waive ongoing fees for administration of
your financial plan if you have assets under our management.
Target Financial Plan – This includes a more “targeted” review of specific areas of interest or
concern regarding your financial situation. A Target Financial Plan will encompass one to three
areas of your concern regarding any of the topics listed previously under Comprehensive Financial
Plan rather than a comprehensive review of all areas of your financial situation.
You will receive a written individualized case study which provides you with a targeted analysis
designed to assist you in achieving your financial goals and objectives for these particular areas.
You have the option of selecting from a broad array of topics which are of personal concern to your
financial situation. Following is a list of topics offered for review:
Investment Portfolio Design
Income Tax Planning
• Retirement Planning
•
•
• Debt Management
• Business Entity Planning
- New Company Start-up
- Acquisition and Disposition
- Buy-Sell Agreements
- Succession Planning
• Estate Planning
• Divorce Planning and Mediation
•
Insurance Planning
- Life
- Disability
- Health
- Long-Term Care
- Annuities
• Social Security Planning
These subject areas can be addressed individually in a detailed fashion to address potential gaps
in your general financial program.
Conflict of Interest - Our financial planning recommendations are not focused on or limited to any
specific product or service offered by any broker-dealer or insurance company. We do have an
affiliated broker-dealer, FAS Corp., that has life insurance and annuity products available. You are
free to choose an insurance company/agent of your choice. There will be a conflict of interest if
you choose to purchase insurance products through FAS Corp. Refer to Item 10 – FAS Corp. for
details regarding this conflict of interest.
3. Employer-Sponsored Defined Contribution Plan and Defined Benefit Plan Investment
Advice to Plan Sponsor:
FAS provides investment advisory and consulting services to Employer-Sponsored Defined
Contribution Plans and Defined Benefit Plans as an investment adviser as defined under Section
3(21) and Section 3(38) of the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). FAS does not custody plan assets and is not a record keeper or third-party
administrator.
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ERISA Section 3(21) - We offer non-discretionary investment consulting within the meaning of
ERISA Section 3(21) to Employer Defined Contribution Plans (“Plan”) and their fiduciaries based
upon the needs of the plan and the services requested by the plan sponsor or named fiduciary.
FAS serves in a co-fiduciary role along with the Plan Sponsor and other professionals in regards to
the Plan.
ERISA Section 3(38) - We offer, on a limited basis, discretionary investment management within
the meaning of ERISA Section 3)38) to Employer Defined Contribution Plans (“Plan”).
Your Responsibilities for All of our Services
It is your responsibility to keep us fully and continuously updated as to your personal and current
financial situation, investment objectives, personal circumstances, needs and goals, and promptly
inform us of any changes.
Nature of our Advice
We render advice to our clients based on our fiduciary standard. However, we cannot assure or
guarantee our advice or your investments will be profitable, or ensure or guarantee no losses will
occur in your assets managed by FAS.
Retirement Plan Rollovers
Effective December 20,2021 (or such later date as the US Department of Labor (“DOL”) Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s
Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the
following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way we make money creates some conflicts 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 financial interests ahead of yours when making recommendations (give
loyal advice);
• Avoid misleading statements about conflicts 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 conflicts of interest.
Use of Third-Party Managers
In certain circumstances, as determined by FAS and the client, FAS may engage third party
managers as independent managers to manage portfolios of individual securities for clients. In
these instances, the third-party managers’ fees are separate, distinct, and in addition to the
advisory fees charged by FAS
Strategies used by third-party managers primarily do not utilize leverage as part of the active
investment strategy and primarily do not use derivatives for leverage. For portfolio management
purposes, the strategies may use equity index futures, swaps, and/or currency forwards to equitize
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flows or for security-specific implementation efficiency to minimize transaction costs. In certain
cases, the strategies may also use derivatives as a tool for implementing country- or currency-
specific overlay views. For these portfolios, the currency forwards and country-level equity index
futures are implemented with the intention of expressing an active investment strategy. However,
for strategies that do not explicitly trade country and currency selection models, derivatives typically
represent only a more efficient means of gaining and managing risk exposures.
Item 5 – FEES AND COMPENSATION____________________________________ __________
1. General Asset Management:
Fee-based compensation is intended to align our interests with yours. This is because our
compensation increases when the assets we manage for you increase. However, this link
between the asset value of your account and our compensation can create a conflict of interest. If
your account value decreases, so does our compensation. This conflict could give us an incentive
to discourage you from withdrawing money from your account even if it might be in your best
interest to do so. Examples might include using money in your managed account to (1) pay down
debt; (2) purchase a home or car; or (3) travel.
Since we always strive to maintain a high degree of objectivity, our advice is not based on such
incentives. However, the conflict of interests exists, and you must be aware of that fact when you
consider our recommendations. Our goal is our advice to you remains at all times in your best
interest and is unbiased.
The structure and level of our advisory fee will vary by client based upon the level of services
provided and other considerations deemed relevant by FAS, but typically is in the form of a
percentage of assets under management ranging up to 1.50% per annum. However, our fee
sometimes is a mutually agreed upon flat dollar fee charged on either a quarterly or monthly basis.
FAS will apply a minimum quarterly fee, at our discretion and with a client’s approval, ranging up to
$1,250 ($5,000 annually) to manage your account(s). This minimum fee can cause you to
determine the cost of our management to be cost prohibitive, particularly clients with less than
$500,000 of “household assets” under our management. This minimum fee could also cause you
to pay a fee which could be greater than 1.50% per annum, depending upon the level of assets in
your portfolio. FAS, in its sole discretion, can decide to accept a lower minimum fee or no fee and a
lower amount of “household assets.” All fee arrangements are subject to negotiation.
We group together your related accounts, family accounts or corporate accounts for the purpose of
achieving the account and fee minimum requirements. We will, at our discretion, also establish a
“group fee rate” for an affiliated group of individuals or business entities.
The specific manner in which we charge fees to manage your investments is established in your
written Investment Management Services Agreement with us. We bill asset management fees on a
quarterly basis in arrears. We determine the dollar amount of the fee by multiplying one-fourth of
the annual percentage fee stated in your Investment Management Services Agreement by the
market value of the assets held in your account(s) on the last day of the previous quarter. The
specific annual fee schedule and/or quarterly fee schedule will be identified on Schedule A of the
Investment Management Services Agreement between FAS and you.
Accounts initiated or terminated during a calendar quarter are charged a prorated fee. Upon
termination of any account, any prepaid unearned fees are promptly refunded, but any earned,
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unpaid fees are due and payable. We can determine not to charge management fees to certain
family members and close associates of employees of FAS.
Your Investment Management Services Agreement authorizes us to directly debit our quarterly
fees from your custodial investment account(s) managed by FAS. If you choose not to have your
fee debited directly from your account, you must notify us in writing. Asset management fees are
prorated for each capital contribution and withdrawal made during the applicable calendar quarter.
Additional information can be found in some or all of the following documents:
• This ADV brochure
• Your FAS client agreement
• Custodial agreements with brokerage houses or trust companies
• Mutual funds’ prospectuses and Statements of Additional Information
Limited Negotiability of Fees for General Asset Management - Although we have established
the aforementioned fee range, we retain the discretion to negotiate alternative fees on a client-by-
client basis. Your facts, circumstances and needs are considered in determining your fee
schedule. These include the complexity of your situation, any planning services provided, assets
to be placed under management, anticipated future additional assets, related accounts, portfolio
style, account composition and reports among other factors. Your final fee schedule will be
memorialized in your Investment Management Services Agreement.
Our fee does not include brokerage commissions, transaction fees, and other related costs and
expenses so you can incur certain other charges imposed by custodians, brokers, third-party
investment managers and other third parties such as:
• Fees charged by fund managers
• Custodial fees
• Trustee fees
• Deferred sales charges
• Odd-lot differentials
• Transfer taxes
• Wire transfer and electronic fund fees
• Servicing fees
• Other fees and taxes on your brokerage accounts and securities transactions
Additionally, mutual funds and exchange-traded funds also charge internal management fees
which are disclosed in a fund’s prospectus. These charges and commissions are exclusive of and
in addition to our asset management fee, and we do not receive any portion of these types of
commissions, fees, and costs. Our affiliated broker/dealer, FAS Corp., receives fees known as
12(b)-1 fees as to an account of an FAS client carried on the books and records of FAS Corp. Item
12 further describes factors FAS considers in selecting or recommending broker-dealers for your
securities transactions and determining the reasonableness of their compensation (e.g.,
commissions).
Some client assets are managed utilizing “ByAllAccounts” an asset reporting and trading system.
Accordingly, you will be billed on the combined asset value for all of your accounts including those
managed via ByAllAccounts. The fee for account assets managed using ByAllAccounts is not
deducted directly from such account but is deducted from your other accounts we manage for you
or as we otherwise agree in writing.
Termination of Agreement - You have the right to terminate your Investment Management Services
Agreement, without a fee being charged to you, within five (5) business days after entering into the
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agreement. Thereafter, your agreement with us may be terminated by receipt of written notice of
cancellation by the party to whom the notice is sent. The asset management fee for the quarter in
which the cancellation occurs is prorated as of the date of cancellation.
2. Financial Planning Services:
FAS offers financial planning services either on an hourly basis or a fixed engagement fee. Hourly
engagements range up to $500 per hour. Fixed fee engagement fees range up to $25,000. Fees
may be negotiable based on the nature and complexity of the services to be provided and the
overall relationship with the Advisor. Fees are estimated by us upon a preliminary assessment of
the complexity of your financial circumstances, the level of skill required to perform the services
and accordingly, the time likely to be required to perform the services.
The exact fee amount and arrangement for payment of this fee will be specified in the Financial
Planning Agreement between FAS and you. A fee for subsequent updates of the financial plan (if
any) is charged in addition to the initial plan fee. However, the initial planning fee and/or update
fee can be waived by FAS if you have a mutually-agreed upon amount of “household assets” in
your Investment Portfolio.
Hourly or fixed fees are estimated by us upon a preliminary assessment of the complexity of your
financial circumstances, the level of skill required to perform the services and accordingly, the time
likely to be required to perform the services. Payment arrangements are specified in your Financial
Planning Agreement.
Some personnel and other related persons of FAS are licensed as registered representatives of
our affiliated broker-dealer, FAS Corp., and/or are licensed as insurance agents or brokers with
FAS Corp. In such separate capacities, these individuals are able to implement product
recommendations for you if you choose to do so, for separate and typical compensation (such as
commissions or other sales-related forms of compensation). This presents a conflict of interest to
the extent that these individuals recommend you purchase a product which, if purchased through
FAS Corp. results in a commission being paid to FAS Corp.
You are not under any obligation to engage these individuals for product purchase when
considering implementation of advisory recommendations. The implementation of any or all
recommendations is solely at your discretion and you may choose the person(s) you wish for
assistance.
3. Employer-Sponsored Defined Contribution Plan and Defined Benefit Plan Investment
Advice to Plan Sponsor:
Payment and computation of compensation due FAS for rendering its services to Employer-
Sponsored Defined Contribution Plans can range from 0.35% to 1.25% per annum payable
quarterly in arrears based upon the total value of Plan assets as valued by the custodian on the
last day of the applicable calendar quarter. The Plan Recordkeeper bills the Plan for the fee on
behalf of FAS and remits the fee to FAS after the end of each calendar quarter.
Third-Party Manager Fees
As stated above in Item 4, FAS (in coordination with the client) may decide to implement AQR as
an independent manager for the management of portfolios of individual securities. In these
instances, AQR will charge its own separate and distinct fee from the advisory fees charged by
FAS, which are noted above. Clients grant AQR authority at the client’s custodian for AQR to
directly debit client accounts for the Independent Manager’s fee.
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Item 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT______ ______
FAS does not charge any performance-based fees (fees based on a share of capital gains on or
capital appreciation of the funds in a client account) because of the potential conflict of interest.
However, the nature of asset-based fees allows us to participate in the growth of your wealth. This
also means our fees can decline when your portfolio declines in value.
Item 7 – TYPES OF CLIENTS______________________________________________________
FAS provides financial planning and asset management services to the following types of clients:
General Asset Management and Financial Planning:
Individuals (including high net worth individuals)
•
• Defined contribution and benefit plans
• Trusts, estates, charitable organizations
• Corporations and other Business entities
• Banking or Thrift Organizations
As previously disclosed in Item 5, we have established certain initial minimum account
requirements in order to maintain an asset management account with us based on the nature of
the service(s) provided. For a more detailed understanding of the requirements, please review the
disclosures provided in each applicable service.
Item 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS_ _____
FAS uses financial reporting services, Morningstar, Ycharts, multiple investment bank or brokerage
firm research products and numerous other investment information services for investment
research and analyses. Investment strategies and recommendations are based upon
consideration of any of the following:
• Diversification – Used for the purpose of balancing risk while maintaining the possibility of
gain primarily through mitigation of unsystematic risk.
• Risk Factors – Past performance is not indicative of future results, therefore it cannot be
assumed that the future performance of an investment or investment strategy will be
profitable. Risk tolerances can and will vary which is why your ability and willingness to take
risk must be decided on by you with guidance from your adviser. You should be aware of
the risks associated with any investment or investment strategy including, without limitation,
the following risk factors:
1. Market Risk – The possibility of experiencing losses due to factors affecting market
performance as a whole, not just specific sectors or asset classes; also known as
systematic risk or volatility. Equity markets are subject to general fluctuations, which
cannot be avoided. Diversification does not eliminate market, or systematic, risk.
2. Unsystematic Risk – Also known as specific risk and contrasted with market risk.
Unsystematic risk is the inherent uncertainty in a specific industry or company that
could lead to loss of an investment. Unsystematic risk can be reduced through
increased diversification.
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3. Concentration Risk – Over-concentration in one or few positions, sectors, industries or
asset classes has the potential to skew returns and can lead to higher correlation
between investors’ portfolios and the concentrated asset.
4. Manager Risk – Strategies utilized in client portfolios could fail to produce intended
results.
5. Purchasing Power Risk – The risk that cash flows or return from an investment can be
worth less in terms of today’s dollars, due to higher inflation and therefore higher
consumer prices.
6. Liquidity Risk – The risk stemming from the lack of marketability of an asset that cannot
be converted quickly enough to cash without suffering a loss.
7.
Interest Rate Risk – The risk that increases in market interest rates can reduce the
market value of individual bonds or bond mutual funds or ETFs held by an investor.
8. Reinvestment Risk – Conversely, declines in market interest rates can lead to the
increase in market value of fixed income investments, albeit with the risk that future
cash flows can then be reinvested in lower yielding securities.
9.
Leverage Risk – There is a risk of substantial loss associated with trading
commodities, futures, options and leverage. Before investing carefully consider your
financial position and risk tolerance to determine if the proposed trading style is
appropriate. Investors should realize that when engaging in leverage, trading futures,
commodities and/or granting/writing options one could lose the full balance of their
account. It is also possible to lose more than the initial deposit when engaging in
leverage, trading futures and/or granting/writing options. All funds committed should be
purely risk capital. Like any investment strategy designed to generate pre-tax returns,
tax-aware investment strategies are subject to the risk of pre-tax returns meaningfully
underperforming expectations.
• Asset Allocation – taking into consideration short-term and long-term liquidity needs,
blending of lesser and greater risk approaches, and combining income, growth, and mitigation
of unsystematic risk;
• Discipline – emphasizing commitment and follow through over a reasonable period of time in
order to permit the investment plan or recommendation(s) to achieve the intended result; or
•
Income Tax Considerations – FAS will at times utilize strategies to capture losses in
attempts to lower future income or capital gains taxes (i.e. tax-loss selling or tax-loss
harvesting). These should not replace economic benefits as the principal determinant of
investment decisions.
We use or consider one or more of the following methods of analyses in formulating our overall
investment advice and/or managing your FAS investment Portfolio:
• Top-Down Analysis. We consider and review current economic and financial factors
(including but not limited to the overall economy, industry, interest rates and credit market
conditions).
13 FAS Wealth Partners . Form ADV Part 2A Disclosure Brochure
February 28, 2025
• Bottom-Up Analysis. We evaluate specific companies or investment products before
evaluating broader economic factors or market conditions, basing decisions on the strength
of an individual company or manager.
• Technical Analysis. We analyze past market movements and apply that analysis to the
present in an attempt to recognize recurring patterns of investor behavior, which might
potentially predict future financial market movements.
• Thematic. We often make investment decisions with expectations of the future in mind,
rather than relying on past performance or market conditions.
• Asset Allocation. This is our primary method of managing your FAS Investment Portfolio.
We attempt to identify an appropriate ratio of equities, fixed income, and cash suitable to your
investment goals, time horizon and risk tolerance.
• Mutual Fund and/or ETF Analysis. We look at the experience and track record of the
manager of the mutual fund or ETF in an attempt to determine if that manager has
demonstrated an ability to invest over a period of time and in different economic conditions.
We look at the underlying assets in a mutual fund or ETF in an attempt to determine if there
is significant overlap in the underlying investments held in another fund(s) in your Investment
Portfolio managed by FAS. We also monitor the funds or ETFs in an attempt to determine if
they are continuing to follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful may
not be able to replicate that success in the future. In addition, as we do not control the
underlying investments in a fund or ETF, managers of different funds held by you can
purchase the same security increasing the risk to you if that security was to fall in value.
There is also a risk that a manager may deviate from the stated investment mandate or
strategy of the fund or ETF that could make the holding(s) less suitable for your Investment
Portfolio.
Please note: ETFs may be subject to trading constraints and delays in executing trades to
buy or sell and liquidity and/or pricing issues particularly in times of extreme financial market
conditions.
•
Interval Funds. This is a type of investment company that periodically offers to repurchase
its shares from shareholders. There is increased liquidity risk as the fund periodically offers
to buy back a stated portion of its shares from shareholders. Interval funds are classified as
closed-end funds but do not trade on secondary markets as their underlying holdings tend to
be private investments.
During the scheduled tender offer, there is the potential the fund will not be able to meet all of
the redemption requests resulting in a pro-rated amount in repurchases. When analyzing an
offering, we consider the following: the asset class exposure to the capital markets, the
investment manager’s track record, history of meeting previous redemption requests and
various fees/expenses.
• Alternative Investments. On a case-by-case basis, we will source private investment
14 FAS Wealth Partners . Form ADV Part 2A Disclosure Brochure
February 28, 2025
strategies for a select subset of our clients. The primary source of these options will be
through specialized platform providers. As a supplement to a platform provider’s due
diligence, we will review the investment manager’s process, philosophy and people along
with their track record of results. Additionally, when appropriate, we will allocate capital
directly to private investment managers utilizing a similar analytical approach.
• Structured Notes. These are instruments consisting of a bond component as well as an
imbedded derivative, traditionally linked to an asset or equity index and can be structured in a
variety of different ways. Depending on how the note is structured, they can be exposed to
several different risks such as market risk and volatility, interest rate risk, commodity prices,
foreign exchange prices and call risk. Structured notes that promise the repayment of
principal upon maturity are subject to credit risk, primarily in the form of the credit worthiness
of the issuing financial institution. Due to the customization of structured notes, the ability to
sell or trade the note prior to maturity can be limited, both from a marketability and mark-to-
market standpoint leading to increased liquidity risk.
Risks for all Forms of Analysis: Past performance does not guarantee future results and there is a
risk of loss in value of the assets in your FAS Investment Portfolio. It is important you work with us
to determine your own personal tolerance for risk.
Item 9 – DISCIPLINARY INFORMATION_____________________________________________
We are required to disclose any legal or disciplinary events material to your evaluation of our
advisory business or the integrity of our management. Our firm and management personnel have
no reportable disciplinary events to disclose.
Item 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS________________
FAS and its advisers endeavor at all times to put your interests first as part of our fiduciary duty.
You should be aware that our receipt of additional compensation from third parties creates a
conflict of interest itself and could affect our judgment when making recommendations. We take
the following steps to address any conflicts of interest:
• We disclose to you the existence of all material conflicts of interest, including the
potential for FAS and/or its advisers to earn compensation from you in addition to the
advisory fees we charge you;
• We disclose to you that you are not obligated to purchase recommended investment or
insurance products from our advisers or affiliated companies;
• We collect, maintain and document accurate, complete and relevant background
information on you, including your financial goals, objectives and risk tolerance;
• Our firm’s management conducts periodically reviews of your Investment Portfolio to
verify all recommendations made to you are suitable to your needs and circumstances;
• We require employees to seek prior approval of any outside employment or business
activity so we can ensure any conflicts of interests in such activities are properly
addressed;
• We periodically monitor these outside employment or business activities to verify any
conflicts of interest continue to be properly addressed by our firm; and
15 FAS Wealth Partners . Form ADV Part 2A Disclosure Brochure
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We educate our advisers regarding the responsibilities of a fiduciary, including the need for
having a reasonable and independent basis for the investment advice provided to you.
FAS Corp. – Some FAS Investment Adviser Representatives (“Investment Adviser Rep”) are also
registered with our affiliate, FAS Corp., as Registered Securities Representatives (“Registered
Rep”). FAS Corp. is an affiliated FINRA member broker-dealer and general insurance agency. It
does not custody assets and deals in insurance products and mutual funds only.
Some FAS advisers are licensed life and health insurance agents with FAS Corp. FAS Corp. has
arrangements to provide insurance or annuity products through a number of insurance companies.
A list of insurance companies represented is available upon your request.
FAS Corp. receives financial and/or product contributions from such companies to sponsor FAS
client events. These contributions for client events creates a conflict of interest as FAS will be
more inclined to recommend these particular insurance companies to you. To mitigate this risk, our
fiduciary duty to you requires us to only recommend products that are in your best interest.
You may decide to obtain insurance products or elect to have certain securities transactions in
mutual funds, variable life products and variable annuity products executed by our FAS advisers
specifically acting in their capacity as a FAS Corp. Registered Rep or insurance agent.
In such instances, an adviser of FAS could be compensated by FAS Corp., directly or indirectly, by
the payment of a portion of the commissions or fees it receives as a result of these securities or
insurance transactions.
As an affiliate, FAS financially benefits from the commissions or fees received by FAS Corp. or our
advisers who are licensed with FAS Corp. as Registered Reps. FAS Corp. pays investment
management fees to FAS to select and manage the fund allocations in the individual variable
annuity products purchased from FAS Corp. by its customers.
FAS Corp. and FAS utilize an expense sharing agreement between the two entities regarding each
entity’s use of office space, personnel, equipment, etc., at our office in Leawood, Kansas.
Midwest Trust – We provide financial planning advice and investment management to mutual
clients of FAS and Midwest Trust of Overland Park, KS. One of our shareholders, who is not an
IAR, is also an owner of Midwest Trust and as such, benefits from trust business we refer to
Midwest Trust.
FAS Tax Partners, LLC (“FAS Tax”) – FAS Tax is a wholly-owned subsidiary of FAS. FAS
clients needing assistance with tax preparation and/or accounting services may be referred to FAS
Tax to work with a licensed Certified Public Accountant (CPA). Because of the affiliation with FAS,
our referral to FAS Tax is not independent and the recommendation creates a conflict of interest
as FAS will be more inclined to recommend you use FAS Tax to prepare your tax returns. As an
affiliate, FAS financially benefits from the fees charged by FAS Tax. Clients are never obligated to
use the services of FAS Tax. Clients may pay fees and expenses to FAS Tax which are separate
from and in addition to the fees paid to FAS.
John A. Meier, Attorney at Law – If you request a referral for an attorney we might refer you to
John A. Meier, Attorney at Law, who can arrange to meet clients at our office. Mr. Meier is also
Senior General Counsel of FAS and General Counsel of FAS Corp., is an Investment Adviser Rep
of FAS and a Registered Principal and Registered Rep of FAS Corp.
16 FAS Wealth Partners . Form ADV Part 2A Disclosure Brochure
February 28, 2025
If you request Mr. Meier’s legal services, he charges you a fee for those services performed as an
attorney, independent of FAS. We are not permitted to practice law and we do not share in
attorney’s fees of Mr. Meier.
Jason M. Salinardi, Attorney at Law – If you request a referral for an attorney we might refer you
to Jason Salinardi, Attorney at Law, who can arrange to meet clients at our office. Mr. Salinardi is
an employee of FAS and serves as General Counsel. If you request Mr. Salinardi’s legal services,
he charges you a fee for those services performed as an attorney, independent of FAS. We are
not permitted to practice law and we do not share in attorney’s fees of Mr. Salinardi.
PLEASE NOTE – No portion of the financial planning advice or other services provided to you by
FAS should be interpreted as legal advice or tax advice.
Item 11 – CODE OF ETHICS ______________________________________________________
FAS has adopted a Code of Ethics (“Code”) which establishes rules of conduct for all employees
and is designed to, among other things; govern personal securities trading activities in the
accounts of employees.
The Code is based upon the principle that FAS and its employees owe a fiduciary duty to clients to
conduct employees’ affairs, including 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 firm and (iii) any actual or potential conflict of interest or any abuse of their
position of trust and responsibility. This means FAS has an affirmative duty of utmost good faith to
act solely in your best interests.
The Code is designated to ensure the high ethical standards long maintained by FAS continue to
be applied. Striving to maintain the reputation of our firm continues to be a direct reflection of the
conduct of each employee. We will provide a copy of our Code to any client or prospective client
upon request.
FAS Associated Persons’ Own Securities Transactions – Our owners, advisers and staff
(“Associated Persons”), or FAS’s tax-qualified employee retirement plan can acquire and own or
sell some of the same securities contained in your Investment Portfolio or otherwise recommended
to you.
At no time will such a transaction be of such a size to influence the market for the security. In
accordance with Rule 204-2(a)-12, we keep a current record of all Associated Persons’ investment
transactions. Each quarter, Associated Persons must report to the FAS compliance officer
regarding their personal securities holdings and transactions and adhere to our Code.
Participation or Interest in Client Transactions - An FAS Investment Adviser Rep can
recommend you acquire a particular type of investment, insurance or annuity product from FAS
Corp. or recommend custody of your account with a particular broker/dealer.
In other instances, you might request FAS or FAS Corp. to execute the purchase of a particular
investment or insurance product for your account. In such instances, FAS or FAS Investment
Adviser Reps, as Registered Reps of FAS Corp., directly or indirectly receives compensation
(including commissions) in addition to your financial service or investment management fees. This
compensation can be received in more than one capacity and from a number of affiliated and
unaffiliated sources.
17 FAS Wealth Partners . Form ADV Part 2A Disclosure Brochure
February 28, 2025
You are free to implement recommended purchases of various types of investment, insurance and
annuity products through any firm or individual, designate a particular broker-dealer, or custody an
account where you please.
There is no obligation to make such product purchases through FAS Corp. or FAS Investment
Adviser Reps, as Registered Reps of FAS Corp., or follow recommendations as to a particular
custodian or broker-dealer. FAS does not warrant or represent that commissions on product
purchases executed through FAS Corp. or FAS advisers will be the lowest commissions available
in the marketplace.
You possibly could obtain products at a lower cost from another broker/dealer or insurance agency.
Because commissions or fees are paid to FAS Corp. and/or its Registered Reps for purchases of
certain investments or insurance or annuity products executed on your behalf, a conflict of interest
will occur.
Also, since FAS or FAS Corp. receives benefits, services and/or fees by reason of you utilizing a
particular broker-dealer, a conflict of interest can occur.
FAS or FAS Corp. might recommend you source a variable life or variable annuity product, or a
non-variable life or health insurance product, from a number of non-affiliated third-party providers.
This would cause commission revenues to be shared with FAS Corp. if a product transaction is
placed with one of these companies.
Our Code further includes our policy prohibiting the use of material non-public information. While
we do not believe we have any particular access to non-public information, all employees are
reminded such information may not be used in a personal or professional capacity. A copy of our
Code is available to our advisory clients and prospective clients. You may request a copy by email
sent to our Chief Compliance Officer at jglenn@faswealthpartners.com or by calling 913-239-2300.
FAS, its retirement plan, and/or individuals associated with us are allowed to buy or sell for their
personal accounts securities identical to or different from those recommended to you. It is the
express policy of our firm that no person employed by FAS can purchase or sell any security prior
to a transaction(s) being implemented for an advisory account, thereby preventing these
employee(s) from benefiting from transactions placed on behalf of advisory accounts.
We aggregate our employee trades with your transactions where possible and when compliant with
our duty to seek best execution for you. In these instances, you will receive an average share price
but transaction costs will be charged the same as if the trades were placed individually for each
account.
In the instances where there is a partial fill of a particular batched order, we will allocate all
purchases pro-rata, with each account paying the average price. Our employee accounts will be
excluded in the pro-rata allocation.
Since the situations described above represent actual or potential conflicts of interest to you, we
have established the following policies and procedures for implementing our firm’s Code to ensure
our firm complies with its regulatory obligations and provides you and potential clients with full and
fair disclosure of such conflicts of interest:
• No principal or employee may put his or her own interest above your interests.
• No principal or employee may buy or sell securities for their personal portfolio(s) where
their decision is a result of information received as a result of their employment unless
the information is also available to the investing public.
18 FAS Wealth Partners . Form ADV Part 2A Disclosure Brochure
February 28, 2025
•
It is the express policy of our firm that no employee purchase or sell any security prior to
a transaction(s) being implemented for your account. This prevents employees from
benefiting from transactions placed on your behalf.
• Our firm requires prior approval for any IPO or private placement investments by related
persons of the firm.
• We have established procedures for the maintenance of all required books and records.
• All principals and employees must act in accordance with all applicable Federal and
State regulations governing registered investment advisory practices.
• We require delivery and acknowledgement of the Code by each supervised person of
our firm.
• We have established policies requiring the reporting of Code violations to senior
management
• Any individual who violates any of the above restrictions can be subject to termination.
As disclosed in the preceding section of this Brochure (Item 10), some related persons of our firm
are separately registered as securities representatives of a broker-dealer and/or licensed as an
insurance agent/broker of various insurance companies.
Please refer to Item 10 for a detailed explanation of these relationships and important conflict of
interest disclosures
Item 12 – BROKERAGE PRACTICES_______________________________________________
The Custodians and Brokers We Use
Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer
or bank. We seek to select or recommend a custodian/broker who will hold your assets and
execute transactions on terms that are, overall, most advantageous when compared to other
available products and their services.
FAS, as part of its investment management service, will recommend you establish securities
accounts with Charles Schwab & Company, Inc., Fidelity Institutional Wealth Services, Midwest
Trust Company or other qualified custodians (collectively referred to as Qualified Custodians)
through their Institutional Platforms or trust services.
Qualified Custodians are independent and unaffiliated SEC registered broker/dealers and or
registered trust/banks that are recommended to maintain custody of your assets and to effect
trades for your accounts. This provides us with access to their institutional trade execution,
clearance and settlement service and custody services which are typically not available to retail
investors.
These custodians/broker-dealers are either registered with the Securities and Exchange
Commission and are members of SIPC or are regulated by appropriate banking regulators in the
case of a trust company. FAS is independently owned and operated, and we are not affiliated with
any of these qualified custodians except in the case of Midwest Trust Company.
19 FAS Wealth Partners . Form ADV Part 2A Disclosure Brochure
February 28, 2025
One of our shareholders, who is not an IAR, is also a shareholder of Midwest Trust Company and
as such, can benefit from trust business we refer to Midwest Trust Company. These qualified
custodians will hold your assets in a brokerage or trust account and buy and sell securities when
we or you instruct them to do so.
Although we may recommend you use one or more of these custodians, you will decide whether to
do so and will open your account with them by entering into an account agreement directly with
them. We do not open the account for you although we will assist you with the custodian’s
required paperwork.
The following qualified broker/dealer custodians provide us and our clients with access to their
institutional brokerage – trading, custody, reporting, and related services – many of which are not
typically available to retail customers.
These qualified custodians also make available various support services. Some of those services
help us manage or administer our clients’ accounts; while others help us manage and grow our
business. These support services are generally available to us on an unsolicited basis (we do not
have to request them) and at no charge to us as long as our clients collectively maintain a certain
amount of assets at the custodian.
We encourage you to compare the account balances contained in your FAS quarterly report to
those balances reflected on the statements you receive directly from your account’s “Custodian(s)”
pertaining to the same quarterly reporting period. “Custodian” means the brokerage firm, trust
company, insurance company or mutual fund company actually having physical custody of the
assets shown in your account(s).
Charles Schwab & Co. (“Schwab”)
For our clients’ accounts Schwab maintains, Schwab generally does not charge you separately for
custody services but is compensated by charging you commissions or other fees on trades it
executes or that settle into your Schwab account.
Some of Schwab’s commission rates and/or asset-based fees applicable to your accounts were
negotiated based on the condition our clients collectively maintain a certain level of client assets in
accounts at Schwab. This commitment benefits you because the overall commission rates and/or
asset-based fees you pay are lower than they would be if we had not made the commitment.
In addition to commissions and/or asset-based fees, Schwab charges you a flat dollar amount as a
“prime broker” or “trade away” fee for each trade we have executed by a different broker-dealer but
where the securities bought or the funds from the securities sold are deposited (settled) into your
Schwab account.
Products and Services Available to Us from Schwab. Schwab Advisor Services is Schwab’s
business serving independent investment advisory firms like FAS. They provide us and our clients
with access to its institutional brokerage – trading, custody, reporting and related services – many
of which are not typically available to Schwab retail customers. Schwab also makes available
various support services. Some of those services help us manage or administer our clients’
accounts while others help us manage and grow our business. Following is a more detailed
description of Schwab’s support services:
Services that Benefit You. Schwab’s institutional brokerage services include access to a broad
range of investment products, execution of securities transactions, and custody of client assets.
The investment products available through Schwab include some to which we might not otherwise
20 FAS Wealth Partners . Form ADV Part 2A Disclosure Brochure
February 28, 2025
have access or that would require a significantly higher minimum initial investment by our clients.
Schwab’s services described in this paragraph generally benefit you and your accounts.
Services that Do Not Directly Benefit You. Schwab also makes available to us other products and
services that benefit us but does not directly benefit you or your account. These products and
services assist us in managing and administering our clients’ accounts.
They include investment research, both Schwab’s own and that of third parties. We use this
research to service all or some substantial number of our clients’ accounts, including accounts not
maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
• provide access to client account data (such as duplicate trade confirmations and
•
account statements);
facilitate trade execution and allocate aggregated trade orders for multiple client
accounts;
facilitate payment of our fees from our clients’ accounts; and
• provide pricing and other market date;
•
• assist with back-office functions, recordkeeping and client reporting.
Services that Benefit Only Us. Schwab also offers other services intended to help us manage and
further develop our business enterprise. These services include:
technology, compliance, legal, and business consulting;
• educational conferences and events;
•
• publications and conferences on practice management and business succession;
• access to employee benefits providers, human capital consultants and insurance
providers; and
financial support
•
Schwab provides some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Schwab also discounts or waives its fees for some of these
services or pays all or a part of a third party’s fees. Schwab also provides us with other benefits
such as occasional business entertainment of our personnel.
More specifically, Schwab has provided us and continues to provide us with financial assistance
that can be used towards technology-related or other operating expenses of our business. This
assistance is based on the expectation that we maintain or add to our client assets in custody with
Schwab. As such, this creates a conflict of interest in our recommending Schwab as the custodian
for client accounts. However, we remain cognizant of our duty of best execution and continue to
act in accordance with it.
In evaluating whether to recommend or require you to custody your assets at Schwab, we will take
into account the availability of some of the foregoing products, financial support and services and
other arrangements as part of the total mix of factors we consider and not solely on the nature,
cost or quality of custody and brokerage services provided by Schwab. This could create a
potential conflict of interest.
Fidelity Brokerage Services, LLC – FAS has an arrangement with National Financial Services
LLC, and Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") through which
Fidelity provides us with their "platform" services.
The platform services include among others: brokerage, custodial, administrative support, record
21 FAS Wealth Partners . Form ADV Part 2A Disclosure Brochure
February 28, 2025
keeping and related services intended to support intermediaries like FAS in conducting business
and in serving the best interests of our clients but that can also benefit us.
Fidelity charges brokerage commissions and transaction fees for effecting certain securities
transactions (i.e., transactions fees are charged for certain no-load mutual funds; commissions are
charged for individual equity and debt securities transactions).
Fidelity enables us to obtain many no-load mutual funds without transaction charges and other no-
load funds at nominal transaction charges. Fidelity’s commission rates are generally considered
discounted from customary retail commission rates. However, the commissions and transaction
fees charged by Fidelity from time to time may be higher or lower than those charged by other
custodians and broker-dealers.
As part of the arrangement, Fidelity also makes available to our firm, at no additional charge to us,
certain research and brokerage services, including research services obtained by Fidelity directly
from independent research companies, as selected by FAS (within specified parameters). These
research and brokerage services presently include services which are used by our firm to manage
accounts for which we have investment discretion.
FAS can also receive additional services. Without this arrangement, we might be compelled to
purchase the same or similar services at our own expense. As a result of receiving such services
for no additional cost, we have an incentive to continue to use or expand the use of Fidelity's
services.
We examined this potential conflict of interest when we chose to enter into the relationship with
Fidelity and have determined the relationship is in the best interests of FAS clients and satisfies
our client obligations, including our duty to seek best execution.
A client could pay a commission higher than another qualified broker-dealer might charge to effect
the same transaction where we determine in good faith that the commission is reasonable in
relation to the value of the brokerage and research services received. While FAS will seek
competitive rates to the benefit of all clients, we will not always obtain the lowest possible
commission rates for your account transactions.
Although the investment research products and services obtained by us will generally be used to
service all of our clients, a brokerage commission paid by you could be used to pay for research
not used in managing your account.
Other Custodians – Even though your account is maintained at one or more of the qualified
custodians, we can still use other brokers to execute trades for your account as described below.
While FAS generally executes substantially all your securities transactions through the qualified
custodian which has custody of your account(s) managed by us, there could be special situations
where we select another broker-dealer, trust company or bank to effect a securities transaction for
you (i.e. buying or selling individual municipal bonds, etc.).
You may also request/direct FAS to utilize a specific broker-dealer to execute a transaction for your
account managed by us and we will use all reasonable efforts to honor the request. In the event
you direct us to use a particular broker-dealer or bank, we may not be authorized under those
circumstances to negotiate commissions and would not be able to obtain volume discounts or best
execution.
22 FAS Wealth Partners . Form ADV Part 2A Disclosure Brochure
February 28, 2025
In addition, under these circumstances a disparity in commission charges could exist between the
commissions charged to you who directed us to use a particular broker-dealer or bank and other
clients who do not direct FAS to use a particular broker or dealer.
FAS, by using its discretion to select a particular broker-dealer or bank to affect your securities
transactions for your account(s) managed by us, could cause you to pay greater brokerage fees,
commissions or other charges (“Charges”) than another broker-dealer might charge.
As previously mentioned, FAS receives products, research and services from a particular broker-
dealer that does not benefit all clients or all clients equally. In selecting a broker-dealer or bank for
your securities transaction, we make a good faith determination the Charges are reasonable in
relation to the value of the brokerage services you receive. As a result, you will pay higher
Charges or other transactions costs, or greater spreads, or receive less favorable net prices on a
securities transaction than would otherwise be the case if we selected other or multiple broker-
dealers.
Item 13 – REVIEW OF ACCOUNTS_________________________________________________
Asset Management Accounts – FAS financial advisers monitor portfolios as part of an ongoing
process. Regular account reviews are usually conducted on a quarterly to semi-annual basis or
whenever requested by you. Reviews with clients generally include assessing your goals and
objectives, monitoring the portfolio, evaluating the investment strategy, and discussing any needed
changes in the investment strategy including the need to rebalance or re-allocate your investments
among various investment asset classes based on your stated investment objectives.
Reports - In addition to the monthly or quarterly statements and confirmations of transactions you
receive from your custodian, we provide written quarterly statements summarizing account
performance, balances and holdings sent to your address of record. You also have the ability to
review your account holdings and other documents on-line through a client portal.
We encourage you to compare the account balances contained in your FAS quarterly report to
those balances reflected on the statements you receive directly from your account’s “Custodian(s)”
pertaining to the same quarterly reporting period.
“Custodian” means the brokerage firm, trust company, insurance company or mutual fund
company actually having physical custody of the assets shown in your account(s).
Financial Plan Accounts – After your initial financial plan is completed, if you advise us of events
or circumstances which may affect your financial plan, or if you request an update, an FAS adviser
will review your most recent financial plan and if appropriate, suggest changes in specific portions
of the most recent financial plan including one or more of the following items: estate, retirement
and tax planning, investment planning and risk management.
Reports - Financial Planning clients receive a completed initial financial plan. Additional reports or
updates will not typically be provided unless otherwise requested or contracted by you.
Employer Sponsored Defined Contribution Plans - FAS advisors conduct a review with the Plan
sponsor and participants on at least a semi-annual basis.
23 FAS Wealth Partners . Form ADV Part 2A Disclosure Brochure
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Item 14 – CLIENT REFERRALS AND OTHER COMPENSATION__________ _______________
Client Referrals
Previously, we participated in the client referral programs of Charles Schwab & Co. and Fidelity.
Although FAS is no longer receiving referrals from these companies, the firm continues to pay the
fees to the referring party for previous client referrals.
FAS engages and pays fees to certain individuals and third-party companies (“Solicitors”) to refer
potential clients to FAS. Such an engagement is represented by a written agreement, pursuant to
which the Solicitor is paid a solicitation/referral fee. Each Solicitation Agreement is individually
negotiated and, therefore, the solicitation referral fee can vary from a flat fee per year, a flat fee for
each new client, a percentage fee based upon the amount of new funds under management, a
fixed fee or a combination of these compensation formulas.
Any such solicitation/referral fee is either paid from our investment management fee or FAS pays a
fixed fee and does not cause any additional or higher fee to a client. As a matter of firm practice,
the advisory fees paid to us by clients referred by solicitors are not increased as a result of any
referral.
It is our policy not to accept or allow our related persons to accept any form of compensation,
including cash, sales awards or other prizes from someone other than FAS in conjunction with the
advisory services we provide to our clients.
A Solicitor is required to disclose to the client the Solicitor’s referral/solicitor arrangement with FAS.
In each instance, the client receives a written confirmation statement and is required to sign a
statement acknowledging the client is aware of the arrangement with the particular solicitor and the
client received a copy of our Disclosure Brochures, Form CRS (Customer Relationship Summary)
and Form ADV, Part 2A.
Any Solicitation Agreement will comply with the Federal Regulations as set out in 17 C.F.R. Section
275-206(4)-3. FAS has read and understands the Federal Regulations with regard to the use of
solicitors, and will be in compliance with these Federal Regulations.
We refer clients to a Solicitor that FAS has a contractual arrangement with for insurance or
financial products offered by the Solicitor. Neither FAS nor its affiliate, FAS Corp., receives any
compensation from the Solicitor for a client FAS refers to the Solicitor.
State of California - FAS will furnish names and addresses of individuals soliciting investment
advisory services upon request by the California Department of Corporations. If the solicitor is
other than an individual, said solicitor will be licensed in California, or any other state requiring
such, as an investment adviser representative prior to any California client, or other resident of
other requiring state, being solicited.
Other Compensation
Charles Schwab & Co. (“Schwab”) – We receive an economic benefit from Schwab in the form
of financial support and other products and services it makes available to us from time to time.
These products and services, how they benefit us, and the related conflicts of interest are
described above under Item 12 – Brokerage Practices. The availability to FAS of Schwab’s
products and services is not based on us giving particular investment advice, such as buying
particular securities for our clients.
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Fidelity Brokerage Services, LLC (“Fidelity”) – FAS has an arrangement with National Financial
Services LLC and Fidelity Brokerage Services LLC (collectively, and together with all affiliates,
"Fidelity") through which Fidelity provides us with “institutional platform services.” The institutional
platform services include, among others, brokerage, custody, and other related services. Fidelity’s
institutional platform services that assist us in managing and administering client accounts include
software and other technology that:
• provides access to client account data (such as trade confirmations and account
statements);
•
facilitates trade execution and allocate aggregated trade orders for multiple client
accounts;
• provides research, pricing and other market data;
•
facilitates payment of fees from its clients’ accounts; and
• assists with back-office functions, recordkeeping and client reporting.
Fidelity also offers other services intended to help us manage and further develop our advisory
practice. Such services include, but are not limited to, performance reporting, financial planning,
contact management systems, third party research, publications, access to educational
conferences, roundtables and webinars, practice management resources, access to consultants
and other third party service providers who provide a wide array of business related services and
technology with whom we can contract directly.
Fidelity generally does not charge its advisor clients separately for custody services but is
compensated by account holders through commissions and other transaction-related or asset-
based fees for securities trades that are executed through Fidelity or that settle into Fidelity
accounts (i.e., transactions fees are charged for certain no-load mutual funds, commissions are
charged for individual equity and debt securities transactions).
Fidelity provides access to many no-load mutual funds without transaction charges and other no-
load funds at nominal transaction charges. FAS is independently operated and owned and is not
affiliated with Fidelity.
Additional Compensation
In consideration of furnishing financial services, our Advisers can directly and indirectly receive
compensation in addition to your investment management fees, in more than one capacity and
from a number of affiliated and unaffiliated sources.
For example, if you implement our recommendations by purchasing insurance or annuity products
through one of our Advisers (acting as a Registered Rep or traditional insurance agent), FAS
Corp., our affiliated broker-dealer, and/or the FAS Investment Adviser Rep will, in most cases,
receive additional compensation other than the fees you pay us in the form of commissions from
the insurance or annuity company.
Client Events and Other Support - FAS receives support services and products from broker-
dealers, custodians, mutual fund investment managers, insurance companies, banks, service
providers, or other financial institutions. The support services which are received include financial
and product contributions to FAS for client events and seminars and also for our ongoing
operations. Despite this, and not necessarily related to the soft-dollar benefits, various vendors,
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product providers, distributors and others may provide cash and no-cash compensation by paying
some expenses related to marketing, training, education, travel expenses, and attaining
professional designations. FAS may receive cash and non-cash compensation to subsidize its own
training programs. Certain vendors may invite FAS to participate in conferences, online training or
provide publications that may further the Advisor’s skill and knowledge. Some may occasionally
provide and/or contribute to an Advisor’s gifts, meals, and entertainment (holiday parties, etc.) of
reasonable value consistent with industry rules and regulations.
Item 15 – CUSTODY_____________________________________________________________
Custody, as it applies to SEC Registered Investment Advisers is defined by regulators as having
access or control over client funds and/or securities. In other words, custody is not limited to
physically holding client funds or securities.
If an investment adviser has the ability to access or control client funds or securities, the
investment adviser is deemed to have custody and must ensure proper procedures are
implemented. Actual physical custody of your assets is maintained with an independent, qualified
custodian such as Charles Schwab, Fidelity, or various other trust companies and banks. FAS has
determined it is subject to Rule 206(4)-2, “Custody of Funds or Securities of Clients by Investment
Advisers” of the Investment Advisers Act of 1940, as amended (“the Act”). This portion of the Act
is commonly referred to as “the Custody Rule”.
FAS has determined it has custody of some client funds as a consequence of the following:
Debiting of Investment Advisory Fees Directly from Client Account(s) - FAS has authority
given by you to directly debit advisory fees from your account(s) unless you have directed
otherwise in writing or if a qualified custodian of your account(s) does not have the capability to pay
advisory fees directly from your account(s). Because of this authority to debit fees directly to FAS
from your account(s), we are deemed to have custody of client funds according to the Custody
Rule.
However, if FAS meets certain specific conditions required by the SEC, the firm will not be required
to have an annual surprise examination of your account(s). We intend to comply with this
requirement and the other terms of the Custody Rule applicable to us.
Please note we continue to utilize the custodial services of Charles Schwab, Fidelity Investments,
and similar qualified custodians to maintain your funds and securities in separate accounts under
your name. The account statements from each custodian indicates the amount of advisory fees
deducted from your account(s) for each billing period.
As part of this billing process, the qualified custodian of your account is advised of the amount of
the fee to be deducted from your account. On at least a quarterly basis, the qualified custodian is
required to send you a statement showing all transactions within the account during the reporting
period.
Because we calculate the amount of the fee to be deducted and not the qualified custodian, we
strongly urge you to carefully compare the information provided on these statements to ensure all
account transactions, holdings and values are correct and current. Our statements can somewhat
vary from your custodial statements because of accounting procedures, reporting dates, or
valuation methodologies of certain securities.
You should contact FAS directly if you believe there is an error in your statement. In addition to the
26 FAS Wealth Partners . Form ADV Part 2A Disclosure Brochure
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periodic statements you receive directly from your qualified custodian(s), we also send account
statements directly to you on a quarterly basis.
Standing Letters of Authorization (“SLOA”) - If any of your managed accounts have SLOA
authority which authorizes FAS to transfer your funds to any account(s) not held at your current
custodian (e.g. to your bank account, accounts at different custodians, third party etc.) as
authorized by you in writing, we will be deemed by the SEC to have custody of those funds.
However, if FAS meets certain specific conditions required by the SEC, the firm will not be required
to have an annual surprise examination of these assets. We intend to comply with this
requirement and the other terms of the Custody Rule applicable to us.
Employee Benefit Plan Accounts – You can elect to provide FAS with your username and
password information to allow us to manage your employee benefit plan account(s). Accounts in
this category are generally employer sponsored retirement plan accounts or non-qualified deferred
compensation plan accounts (“Covered Accounts”). We will use the access to your Covered
Accounts in order to review and make necessary changes to the portfolio allocations and research
investment choices. FAS will supervise, provide ongoing management and direct the investments
of these Covered Accounts with respect to the purchase, sale or continued holding of securities,
subject to the investment objectives you have selected. We will not use the password access to
your Covered Accounts to withdraw funds or securities or transfer them to any other account in
your name at a qualified custodian or change your address of record with the qualified custodian.
FAS is taking a client-centric interpretation of the SEC’s definition of custody. We believe we are
subject to the Custody Rule in regard to some Covered Accounts we manage. For the protection
of our clients and because FAS believes it is subject to the Custody Rule for Covered Accounts,
the SEC requires an annual unscheduled and unannounced independent verification of your
Covered Accounts by actual examination of the Covered Accounts conducted by an independent
public accountant.
We have engaged an independent public accountant to verify our clients’ Covered Accounts by
way of an unannounced audit which will be conducted once per year by an independent public
accounting firm. The independent public accounting firm will file each annual surprise examination
report and Form ADV-E with the US Securities and Exchange Commission through the IARD. We
intend to comply with this requirement and the other terms of the Custody Rule applicable to us.
Item 16 – INVESTMENT DISCRETION_______________________________________________
Upon receiving written authorization from you in our standard client agreement, we will provide you
discretionary asset management services for one or more of your investment accounts in which
case we place trades in your account(s) without contacting you prior to each trade to obtain your
permission. Discretionary authority includes the ability to (1) determine the security to buy or sell
and/or (2) determine the amount of the security to buy or sell. In all cases, however, this discretion
is to be exercised in a manner consistent with your stated investment objectives.
We observe your stated investment objectives, limitations and restrictions when selecting securities
and determining amounts. Our authority to trade securities can also be subject to your personal
income tax considerations and certain federal securities laws and regulations. Investment
objectives and restrictions must be provided to FAS in writing. We recommend you advise us from
time to time of your personal income tax considerations.
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Item 17 – VOTING CLIENT SECURITIES_____________________________________________
Securities proxies are delivered directly to the client from the custodian or transfer agent. As a
matter of firm policy and practice, we do not vote securities proxies on your behalf. Therefore,
although we provide investment advisory services concerning your assets, you maintain exclusive
responsibility for receiving and voting proxies for any and all securities maintained in your
accounts. Upon request, FAS will provide advice to you regarding your voting of proxies. You may
call us at 913-236-2300 if you have questions about a proxy you receive.
Item 18 – FINANCIAL INFORMATION_______________________________________________
FAS does not have any financial impairment that will preclude us from meeting contractual
commitments to clients. We are not required to provide you a balance sheet because we do not
serve as a custodian for client funds or securities and we do not require prepayment of fees of
more than $1,200 per client, six months or more in advance. Neither FAS nor any of its affiliates
has ever been the subject of a bankruptcy petition at any time.
Item 19 – REQUIREMENTS FOR STATE-REGISTERED ADVISERS_________ _____________
Not Applicable.
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FAS Wealth Partners, Inc.
Customer Privacy Notice
Our Commitment to You...
We consider it our great privilege to serve your financial needs … and we value the trust you have placed
in us. An important component of our relationship with you is our commitment to safeguarding your
personal information. This notice will help you understand the measures we take to protect the privacy
and security of this information. Federal law requires us to tell you how we collect, share and protect your
personal information. Please read this notice carefully.
Information We Collect and How It Is Used
As part of providing you with financial services or products, we may obtain information about you from Qualified
Custodians of your financial accounts, applications, forms and other information you provide us, whether in writing, in
person, by telephone, electronically or by other means. This information may include your name, address, social
security number, date of birth, employment information, income and credit references, or credit history (i.e. Non-
Public Personal Information). Your information we receive will be used only for our everyday business purposes such
as to process your transactions, maintain your account(s) and to provide you with the services and products we offer.
Some of this information is used by our third-party vendors to assist in our reporting to you and the servicing your
account(s).
Information We Disclose and Why
We do not disclose the nonpublic personal information we collect about our customers to anyone except: (i) in
furtherance of our business relationship with them and then only to those persons necessary to effect the
transactions and provide the services you authorize (such as broker-dealers, custodians, independent managers,
insurance agencies, etc.); (ii) to persons assessing our compliance with industry standards (e.g. professional
licensing authorities, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law.
We are permitted by law to disclose customer nonpublic personal information about you to third parties in limited
circumstances where disclosure is required by legal or administrative proceeding or permitted under applicable law.
At the customer’s request, we may also disclose customer information to third parties such as the customer’s
accountant or attorney. If we provide nonpublic personal information to companies providing services to us, these
third parties receiving such information are prohibited to use or share the information for any other purpose.
Security of Your Information
We maintain physical, electronic, and procedural safeguards to protect customer information. Access to customer
information is limited to those employees who need the information to properly service and maintain accounts. All of
our employees sign a Confidentiality Agreement attesting they will not disclose customer information. We do not
market your information. Federal law gives you the right to limit only sharing for affiliates’ everyday business
purposes – information about your creditworthiness; affiliates from using your information to market to you and
sharing for non-affiliates to market to you.
Amendments and Former Customers
If at any time in the future it becomes necessary for us to disclose any nonpublic personal information in any manner
inconsistent with this policy, we will provide our customers advanced notice of the change to allow the customer the
opportunity to opt out of any disclosure. We reserve the right to amend our policy from time to time and will notify you
of any significant changes. If you decide to terminate your relationship with us, we will continue to adhere to the
privacy policies as set forth in this Statement, subject to future revisions.
Contact Information
Please call us at 913.239.2300 or email at info@faswealthpartners.com with any questions or comments. At all
times, you may view our current privacy policy on our website at www.faswealthpartners.com.
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