Overview
- Headquarters
- Cumming, GA
- Total Firm Assets
- $188 million
- Average High-Net-Worth Client Portfolio Size
- $1.8 million
Fee Structure
Primary Fee Schedule (ADV BROCHURE PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $2,000,000 | 0.90% |
| $2,000,001 | $3,000,000 | 0.80% |
| $3,000,001 | $5,000,000 | 0.65% |
| $5,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $40,000 | 0.80% |
| $10 million | $65,000 | 0.65% |
| $50 million | $265,000 | 0.53% |
| $100 million | $515,000 | 0.52% |
Clients
- High-Net-Worth Share of Firm Assets
- 62.74%
- Number of High-Net-Worth Clients
- 64
- Total Client Accounts
- 577
- Discretionary Accounts
- 567
- Non-Discretionary Accounts
- 10
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 108062
Additional Brochure: ADV BROCHURE PART 2A (2026-07-22)
View Document Text
Financial Consultants Group, Inc
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Financial Consultants Group,
Inc. If you have any questions about the contents of this brochure, please contact us at (770) 627-2121 or by email
at: Sandee@ForYourFuture.net. 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 Financial Consultants Group, Inc is also available on the SEC’s website at
www.adviserinfo.sec.gov. Financial Consultants Group, Inc’s CRD number is: 108062.
1080 Sanders Rd., Suite 300
Cumming, GA 30041
(770) 627-2121
Sandee@ForYourFuture.net
https://www.ForYourFuture.net
Registration does not imply a certain level of skill or training.
Version Date: July 22, 2026
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Item 2: Material Changes
The material changes in this brochure from the last annual update amendment of Financial Consultants
Group, Inc, on 03/11/2026 are described below. Material changes relate to Financial Consultants Group,
Inc’s policies, practices or conflicts of interests.
• Created Fountain Wealth Partners to serve as a DBA for the firm (See Item 4)
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Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes ...................................................................................................................................................................................................................... ii
Item 3: Table of Contents ..................................................................................................................................................................................................................... iii
Item 4: Advisory Business .................................................................................................................................................................................................................... 5
A. Description of the Advisory Firm ............................................................................................................................................................................................ 5
B. Types of Advisory Services ........................................................................................................................................................................................................ 5
C. Client Tailored Services and Client Imposed Restrictions ................................................................................................................................................... 6
D. Wrap Fee Programs .................................................................................................................................................................................................................... 6
E. Assets Under Management ........................................................................................................................................................................................................ 6
Item 5: Fees and Compensation ........................................................................................................................................................................................................... 7
A. Fee Schedule ................................................................................................................................................................................................................................. 7
B. Payment of Fees ............................................................................................................................................................................................................................ 7
C. Client Responsibility For Third Party Fees ............................................................................................................................................................................. 8
D. Prepayment of Fees ..................................................................................................................................................................................................................... 8
E. Outside Compensation For the Sale of Securities to Clients................................................................................................................................................ 8
Item 6: Performance-Based Fees and Side-By-Side Management ................................................................................................................................................. 8
Item 7: Types of Clients ......................................................................................................................................................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ............................................................................................................................................ 9
Methods of Analysis and Investment Strategies ......................................................................................................................................................... 9
A.
Material Risks Involved.................................................................................................................................................................................................... 9
B.
Risks of Specific Securities Utilized.............................................................................................................................................................................. 10
C.
Item 9: Disciplinary Information ....................................................................................................................................................................................................... 11
Criminal or Civil Actions ............................................................................................................................................................................................... 11
A.
Administrative Proceedings .......................................................................................................................................................................................... 11
B.
Self-regulatory Organization (SRO) Proceedings ...................................................................................................................................................... 11
C.
Item 10: Other Financial Industry Activities and Affiliations ...................................................................................................................................................... 11
Registration as a Broker/Dealer or Broker/Dealer Representative ...................................................................................................................... 11
A.
Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ................................... 11
B.
Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ................................................................ 11
C.
Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ..................................................... 12
D.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................................................................................... 12
Code of Ethics................................................................................................................................................................................................................... 12
A.
Recommendations Involving Material Financial Interests ...................................................................................................................................... 12
B.
Investing Personal Money in the Same Securities as Clients .................................................................................................................................. 12
C.
Trading Securities At/Around the Same Time as Clients’ Securities ................................................................................................................... 12
D.
Item 12: Brokerage Practices ............................................................................................................................................................................................................... 13
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Factors Used to Select Custodians and/or Broker/Dealers .................................................................................................................................... 13
A.
Research and Other Soft-Dollar Benefits ............................................................................................................................................................... 13
1.
Brokerage for Client Referrals.................................................................................................................................................................................. 13
2.
Clients Directing Which Broker/Dealer/Custodian to Use .............................................................................................................................. 13
3.
Aggregating (Block) Trading for Multiple Client Accounts.................................................................................................................................... 14
B.
Item 13: Review of Accounts .............................................................................................................................................................................................................. 14
Frequency and Nature of Periodic Reviews and Who Makes Those Reviews .................................................................................................... 14
A.
Factors That Will Trigger a Non-Periodic Review of Client Accounts ................................................................................................................. 14
B.
Content and Frequency of Regular Reports Provided to Clients ........................................................................................................................... 14
C.
Item 14: Client Referrals and Other Compensation ....................................................................................................................................................................... 15
Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ......................... 15
A.
Compensation to Non – Advisory Personnel for Client Referrals ......................................................................................................................... 15
B.
Item 15: Custody ................................................................................................................................................................................................................................... 15
Item 16: Investment Discretion .......................................................................................................................................................................................................... 15
Item 17: Voting Client Securities (Proxy Voting) ........................................................................................................................................................................... 16
Item 18: Financial Information ........................................................................................................................................................................................................... 16
Balance Sheet .................................................................................................................................................................................................................... 16
A.
Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ................................................... 16
B.
Bankruptcy Petitions in Previous Ten Years .............................................................................................................................................................. 16
C.
Item 19: Requirements For State Registered Advisers .................................................................................................................................................................. 16
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Item 4: Advisory Business
A. Description of the Advisory Firm
Financial Consultants Group, Inc (hereinafter “FCG”) is a Corporation organized in the
State of Georgia. The firm was formed in January 1996, and the principal owner is David
Lytal Fountain. The firm has established a DBA of Fountain Wealth Partners, but will
retain Financial Consultants Group, Inc as the legal name going forward. The new name
will reflect a broader array of services available through relationships with unaffiliated
firms.
B. Types of Advisory Services
Portfolio Management Services
FCG offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. FCG creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a
portfolio that matches each client's specific situation. Portfolio management services
include, but are not limited to, the following:
Investment strategy •
•
Asset allocation
•
Risk tolerance
Personal investment policy
Asset selection
Regular portfolio monitoring
•
•
•
FCG evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. FCG will request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement.
FCG seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of FCG’s economic, investment or
other financial interests. To meet its fiduciary obligations, FCG attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, FCG’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is FCG’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent among its
clients on a fair and equitable basis over time.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
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debt/credit planning.
Upon review of an investor's financial status, FCG may propose that the investor include,
as part of his or her financial portfolio, one or more types of products that are not part of
the investment advisory services provided by FCG, such as insurance products. If the
investor chooses to include such a product in his or her financial portfolio, the company
recommends that the investor work closely with his or her attorney, accountant, insurance
agent and other related professionals. Incorporation of the non-advisory financial product
into the investor's financial plan is entirely at the client's discretion.
For insurance products, the company provides access to a platform providing insurance
products by RetireOne, Inc. (“RetireOne”). The investor is under no obligation to use
RetireOne's service and may seek insurance advice from any licensed agent. The insurance
products and fee structures available from RetireOne may differ from those available from
other third-party insurance agents. FCG recommends that the investor fully evaluate
products and fee structures to determine which arrangements are most favorable to the
investor prior to making an investment decision.
C. Client Tailored Services and Client Imposed Restrictions
FCG will tailor a program for each individual client. This will include an interview session
to get to know the client’s specific needs and requirements as well as a plan that will be
executed by FCG on behalf of the client. FCG may use model allocations together with a
specific set of recommendations for each client based on their personal restrictions,
financial statements, needs, goals and risk tolerances. Clients may impose restrictions in
investing in certain securities or types of securities in accordance with their values or
beliefs. However, if the restrictions prevent FCG from properly servicing the client
account, or if the restrictions would require FCG to deviate from its standard suite of
services, FCG reserves the right to end the relationship.
D. Wrap Fee Programs
FCG does not have a Wrap Fee Program.
E. Assets Under Management
FCG has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$184,693,037
$3,478,523
December 31, 2025
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Item 5: Fees and Compensation
A. Fee Schedule
Portfolio Management Fees
The table below represents the maximum fee schedule for FCG. These fees are negotiable
depending upon the needs of the client and complexity of the situation, and the final fee
schedule is attached to the Investment Advisory Agreement as Exhibit II. Clients may
terminate the agreement without penalty for a full refund of FCG's fees within five
business days of signing the Investment Advisory Agreement. Thereafter, clients may
terminate the Investment Advisory Contract generally with 5 days' written notice.
Total Assets Under Management Maximum Annual Fees
First $1,000,000
1.00%
Next $1,000,000
0.90%
Next $1,000,000
0.80%
Next $2,000,000
0.65%
Over $5,000,000
0.50%
Advisory fee calculations will be based on the platform used, with accounts using
American Funds to be calculated using daily average balance. For other platforms, the
advisory fee is calculated using the fair market value of the assets in the Account on the
last business day of the prior billing period as calculated by the custodian.
Financial Planning Fees
The negotiated fixed rate for creating client financial plans is between $2,500 and $10,000.
Clients may terminate the agreement without penalty, for full refund of FCG’s fees, within
five business days of signing the Financial Planning Agreement. Thereafter, clients may
terminate the Financial Planning Agreement generally upon written notice.
B. Payment of Fees
Payment of Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a monthly or quarterly basis depending on the
custodian being used. Fees are paid in advance or in arrears, depending on the platform
used.
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Payment of Financial Planning Fees
Financial planning fees are paid via check, Venmo, or credit card. FCG will never possess
client credit card information. Fixed financial planning fees are paid in arrears upon
completion.
C. Client Responsibility For Third Party Fees
Client accounts are responsible for the payment of all third party fees (i.e., custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by FCG. Please see Item 12 of this brochure
regarding broker/custodian.
D. Prepayment of Fees
FCG collects certain fees in advance and certain fees in arrears, as indicated above.
Refunds for fees paid in advance will be returned within fourteen days to the client via
check, or return deposit back into the client’s account.
For all asset-based fees paid in advance, the fee refunded will be equal to the balance of
the fees collected in advance minus the daily rate* times the number of days elapsed in
the billing period up to and including the day of termination. (*The daily rate is calculated
by dividing the annual asset-based fee rate by 365.)
E. Outside Compensation For the Sale of Securities to Clients
Neither FCG nor its supervised persons accept any compensation for the sale of
investment products, including asset-based sales charges or service fees from the sale of
mutual funds.
Item 6: Performance-Based Fees and Side-By-Side Management
FCG does not accept performance-based fees or other fees based on a share of capital gains on or
capital appreciation of the assets of a client.
Item 7: Types of Clients
FCG generally provides advisory services to the following types of clients:
Individuals and Families
High-Net-Worth Individuals
Corporations and Trusts
❖
❖
❖
There is no account minimum for any of FCG’s services.
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Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
FCG’s methods of analysis include Fundamental analysis, Modern portfolio theory and
Technical analysis.
Fundamental analysis involves the analysis of financial statements, the general financial
health of companies, and/or the analysis of management or competitive advantages.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio
expected return for a given amount of portfolio risk, or equivalently minimize risk for a
given level of expected return, each by carefully choosing the proportions of various asset.
Technical analysis involves the analysis of past market data; primarily price and volume.
Investment Strategies
FCG uses long term trading.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
B. Material Risks Involved
Methods of Analysis
Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is
that the market will fail to reach expectations of perceived value.
Modern portfolio theory assumes that investors are risk averse, meaning that given two
portfolios that offer the same expected return, investors will prefer the less risky one.
Thus, an investor will take on increased risk only if compensated by higher expected
returns. Conversely, an investor who wants higher expected returns must accept more
risk. The exact trade-off will be the same for all investors, but different investors will
evaluate the trade-off differently based on individual risk aversion characteristics. The
implication is that a rational investor will not invest in a portfolio if a second portfolio
exists with a more favorable risk-expected return profile – i.e., if for that level of risk an
alternative portfolio exists which has better expected returns.
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Technical analysis attempts to predict a future stock price or direction based on market
trends. The assumption is that the market follows discernible patterns and if these patterns
can be identified then a prediction can be made. The risk is that markets do not always
follow patterns and relying solely on this method may not take into account new patterns
that emerge over time.
Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by
the Firm to service client accounts have artificial intelligence components. The use of
artificial intelligence and machine learning includes increased risk of data inaccuracies
and security vulnerabilities. Due to the rapid advancement of machine learning
technologies, future risks related to artificial intelligence are unpredictable. As a measure
to mitigate these risks to our clients, the Firm performs periodic due diligence of our
service providers for assurance that the service providers have appropriate controls in
place to protect our clients’ information and to limit data inaccuracies when artificial
intelligence is used by the service provider.
Investment Strategies
Long term trading is designed to capture market rates of both return and risk. Due to its
nature, the long-term investment strategy can expose clients to various types of risk that
will typically surface at various intervals during the time the client owns the investments.
These risks include but are not limited to inflation (purchasing power) risk, interest rate
risk, economic risk, market risk, and political/regulatory risk.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
C. Risks of Specific Securities Utilized
Clients should be aware that there is a material risk of loss using any investment strategy.
The investment types listed below are not guaranteed or insured by the FDIC or any other
government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may
lose money investing in mutual funds. All mutual funds have costs that lower investment
returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity”
nature.
Equity investment generally refers to buying shares of stocks in return for receiving a
future payment of dividends and/or capital gains if the value of the stock increases. The
value of equity securities may fluctuate in response to specific situations for each
company, industry conditions and the general economic environments.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges,
similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100%
loss in the case of a stock holding bankruptcy). Areas of concern include the lack of
transparency in products and increasing complexity, conflicts of interest and the
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possibility of inadequate regulatory compliance.
Past performance is not indicative of future results. Investing in securities involves a
risk of loss that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither FCG nor its representatives are registered as, or have pending applications to
become, a broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity Pool
Operator, or a Commodity Trading Advisor
Neither FCG nor its representatives are registered as or have pending applications to
become either a Futures Commission Merchant, Commodity Pool Operator, or
Commodity Trading Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business and
Possible Conflicts of Interests
David Lytal Fountain is a member of the board of directors at Forsyth County Chamber of
Commerce.
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D. Selection of Other Advisers or Managers and How This Adviser is
Compensated for Those Selections
FCG does not utilize nor select third-party investment advisers. All assets are managed
by FCG management.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
FCG has a written Code of Ethics that covers the following areas: Prohibited Purchases
and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions,
Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality,
Service on a Board of Directors, Compliance Procedures, Compliance with Laws and
Regulations, Procedures and Reporting, Certification of Compliance, Reporting
Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual
Review, and Sanctions. FCG's Code of Ethics is available free upon request to any client
or prospective client.
B. Recommendations Involving Material Financial Interests
FCG does not recommend that clients buy or sell any security in which a related person
to FCG or FCG has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of FCG may buy or sell securities for themselves that
they also recommend to clients. This may provide an opportunity for representatives of
FCG to buy or sell the same securities before or after recommending the same securities
to clients resulting in representatives profiting off the recommendations they provide to
clients. Such transactions may create a conflict of interest. FCG will always document any
transactions that could be construed as conflicts of interest and will never engage in
trading that operates to the client’s disadvantage when similar securities are being bought
or sold.
D. Trading Securities At/Around the Same Time as Clients’ Securities
From time to time, representatives of FCG may buy or sell securities for themselves at or
around the same time as clients. This may provide an opportunity for representatives of
FCG to buy or sell securities before or after recommending securities to clients resulting
in representatives profiting off the recommendations they provide to clients. Such
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transactions may create a conflict of interest; however, FCG will never engage in trading
that operates to the client’s disadvantage if representatives of FCG buy or sell securities at
or around the same time as clients.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
the market expertise and research access provided by
Custodians/broker-dealers will be recommended based on FCG’s duty to seek “best
execution,” which is the obligation to seek execution of securities transactions for a client
on the most favorable terms for the client under the circumstances. Clients will not
necessarily pay the lowest commission or commission equivalent, and FCG may also
consider
the broker-
dealer/custodian, including but not limited to access to written research, oral
communication with analysts, admittance to research conferences and other resources
provided by the brokers that may aid in FCG's research efforts. FCG will never charge a
premium or commission on transactions, beyond the actual cost imposed by the broker-
dealer/custodian.
FCG will require clients to use Axos Advisor Services, Capital Group (American Funds),
Ascensus and/or Charles Schwab & Co., Inc.
1. Research and Other Soft-Dollar Benefits
While FCG has no formal soft dollars program in which soft dollars are used to pay
for third party services, FCG may receive research, products, or other services from
custodians and broker-dealers in connection with client securities transactions (“soft
dollar benefits”). FCG may enter into soft-dollar arrangements consistent with (and
not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange
Act of 1934, as amended. There can be no assurance that any particular client will
benefit from soft dollar research, whether or not the client’s transactions paid for it,
and FCG does not seek to allocate benefits to client accounts proportionate to any soft
dollar credits generated by the accounts. FCG benefits by not having to produce or
pay for the research, products or services, and FCG will have an incentive to
recommend a broker-dealer based on receiving research or services. Clients should be
aware that FCG’s acceptance of soft dollar benefits may result in higher commissions
charged to the client.
2. Brokerage for Client Referrals
FCG receives no referrals from a broker-dealer or third party in exchange for using
that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
FCG will require clients to use a specific broker-dealer to execute transactions. Not all
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advisers require clients to use a particular broker-dealer.
B. Aggregating (Block) Trading for Multiple Client Accounts
If FCG buys or sells the same securities on behalf of more than one client, then it may (but
would be under no obligation to) aggregate or bunch such securities in a single transaction
for multiple clients in order to seek more favorable prices, lower brokerage commissions,
or more efficient execution. In such case, FCG would place an aggregate order with the
broker on behalf of all such clients in order to ensure fairness for all clients; provided,
however, that trades would be reviewed periodically to ensure that accounts are not
systematically disadvantaged by this policy. FCG would determine the appropriate
number of shares and select the appropriate brokers consistent with its duty to seek best
execution, except for those accounts with specific brokerage direction (if any).
Item 13: Review of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those
Reviews
All client accounts for FCG's advisory services provided on an ongoing basis are reviewed
at least Annually by the Client’s assigned advisor, with regard to clients’ respective
investment policies and risk tolerance levels. All accounts at FCG are assigned to this
reviewer.
All financial planning-only accounts are reviewed upon financial plan creation and plan
delivery by the Client’s assigned advisor. Financial planning-only clients are provided a
one-time financial plan concerning their financial situation. After the presentation of the
plan, there are no further reports. Clients may request additional plans or reports for a fee.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews may be triggered by material market, economic or political events, or by changes
in client's financial situations (such as retirement, termination of employment, physical
move, or inheritance).
With respect to financial plans, FCG’s services will generally conclude upon delivery of
the financial plan.
C. Content and Frequency of Regular Reports Provided to Clients
Each client of FCG's advisory services provided on an ongoing basis will receive a
quarterly report detailing the client’s account, including assets held, asset value, and
calculation of fees. This written report will come from the custodian.
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Each financial planning-only client will receive the financial plan upon completion.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered
to Clients (Includes Sales Awards or Other Prizes)
FCG has a material relationship with an issuer of securities and may receive support in
reference to seminar events. There is no requirement for FCG to invest client assets with
any issuer of securities in return for this economic benefit.
B. Compensation to Non – Advisory Personnel for Client Referrals
FCG does not directly or indirectly compensate any person who is not advisory personnel
for client referrals.
Item 15: Custody
When advisory fees are deducted directly from client accounts at client's custodian, FCG will be
deemed to have limited custody of client's assets and must have written authorization from the
client to do so. Clients will receive all account statements and billing invoices that are required in
each jurisdiction, and they should carefully review those statements for accuracy.
Some clients may execute limited powers of attorney or other standing letters of authorization
that permit the firm to transfer money from their account with the client’s independent qualified
custodian to third-parties. This authorization to direct the custodian may be deemed to cause our
firm to exercise limited custody over your funds or securities and for regulatory reporting
purposes, we are required to keep track of the number of clients and accounts for which we may
have this ability. We do not have physical custody of any of your funds and/or securities. Your
funds and securities will be held with a bank, broker-dealer, or other independent, qualified
custodian. You will receive account statements from the independent, qualified custodian(s)
holding your funds and securities at least quarterly. The account statements from your
custodian(s) will indicate any transfers that may have taken place within your account(s) each
billing period. You should carefully review account statements for accuracy.
Item 16: Investment Discretion
FCG provides discretionary investment advisory services to clients. The advisory contract
established with each client sets forth the discretionary authority for trading. Where investment
discretion has been granted, FCG generally manages the client’s account and makes investment
15
decisions without consultation with the client as to when the securities are to be bought or sold
for the account, the total amount of the securities to be bought/sold, what securities to buy or
sell, or the price per share. In some instances, FCG’s discretionary authority in making these
determinations may be limited by conditions imposed by a client (in investment guidelines or
objectives, or client instructions otherwise provided to FCG).
Item 17: Voting Client Securities (Proxy Voting)
FCG will not ask for, nor accept voting authority for client securities. Clients will receive proxies
directly from the issuer of the security or the custodian. Clients should direct all proxy questions
to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
FCG neither requires nor solicits prepayment of more than $1,200 in fees per client, six
months or more in advance, and therefore is not required to include a balance sheet with
this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet
Contractual Commitments to Clients
Neither FCG nor its management has any financial condition that is likely to reasonably
impair FCG’s ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
FCG has not been the subject of a bankruptcy petition in the last ten years.
Item 19: Requirements For State Registered Advisers
This section is not applicable because the firm is registered with the Securities and
Exchange Commission.
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