View Document Text
Form ADV Part 2 Brochure -
Dated February 2, 2026
Financial Enhancement Group LLC
2704 Enterprise Drive
Anderson, Indiana 46013
Phone(765)640-1524
(317) 744-1484
Fax
www .yourlifeafterwork.com
This Form ADV Part 2 ("Brochure") provides information about the
qualifications and business practices of Financial Enhancement Group LLC.
If you have any questions about the contents of this Brochure, please contact
us at (765) 640-1524. The information in this Brochure has not been
approved or verified by the United States Securities and Exchange
Commission ("SEC") or by any other state securities authority.
Additional information about Financial Enhancement Group LLC is also
available on the SEC's website at www.adviserinfo.sec.gov.
Financial Enhancement Group LLC is a registered Investment Advisor.
However, please note that registration as an Investment Advisor does not
imply any level of skill or training.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 1 of38
ITEM 2 - Material Changes
This Brochure, dated February 2, 2026, contains material changes from the
Firm's prior Brochure dated February 14, 2025, as follows:
There are no material changes from the firm's prior Brochure dated February
14, 2025, with the exception of the firm's updated Assets Under
Management figures as listed in Item 4. As of 12/31/2025 the firm managed
a total of$986,999,188 in Discretionary assets in 3,599 client investment
accounts.
Page 2 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
ITEM 3 - Table of Contents
ITEM
Number
Title
Page Number(s)
Cover Page
Material Changes
Table of Contents
Advisory Business
Fees and Compensation
Performance Based Fees &
1
2
3
4
5
6
1
2
3
4-8
8-11
12
Side-By-Side Management
12
12-29
7
8
Types of Clients
Methods of Analysis, Investment
Strategies, and Risk of Loss
9
10
Disciplinary Information
Other Financial Industry Activities
29
30-31
& Affiliations
11
31-32
Code of Ethics, Participation or
Interest in Client Transactions,
& Personal Trading
12
13
14
15
16
17
18
19
Brokerage Practices
Review of Accounts
Client Referrals & Other Compensation
Custody
Investment Discretion
Voting Client Securities
Financial Information
State Registered Advisors
32-33
34
34-36
36-37
37
38
38
38
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 3 of38
ITEM 4 - Advisory Business
Financial Enhancement Group LLC is an SEC registered Investment
Advisory firm whose Principal Officer and Managing Member is Joseph
Clark. The firm is owned by the Big Joe Money Show LLC, which is in tum
owned by Joseph Clark. Additionally, the firm is owned by Adam Harter,
Donald Hodson, Taylor Jenkinson, Aaron Rheaume, Vicky Mellady, Stacy
McNeal, Samuel Neff, Grant Soliven, Daren Hardesty, Seth Grimme, Paul
Karshner, Jamie Burton, and Dusty Emmons. While Taylor, Vicky, Stacy,
and Dusty are owners, they are not currently registered as Investment
Advisor Representatives. Their participation in firm business is limited to
operations; accordingly, they are not involved in any investment decisions of
the firm, nor do they discuss matters with clients or the public.
Financial Enhancement Group LLC provides Discretionary Asset
Management services to firm clients utilizing the strategies described more
fully in Item 8 of this Brochure. The firm also provides Financial Planning
Services. Our advisory services are provided to individuals, families,
retirement plans, trusts, estates, charitable organizations, or other business
entities.
The list of advisory services on the next page can be tailored to each client.
Therefore, if any client requires any restrictions on any types of stocks or
market segments, the client needs to inform their Advisory Representative of
the restrictions in writing. If, for any reason, the firm cannot meet the
client's restrictions, the firm will notify the client of that fact so that the
client can determine their individual requirements and needs.
Discretionary Advisory Services:
We provide advisory services in the form of Portfolio Management.
Portfolio Management Services provide clients with continuous and ongoing
supervision over their accounts. This means that FEG will continuously
manage a client's account and place trades when necessary pursuant to the
general strategies described in Item 8 - Methods of Analysis, Investment
Strategies, and Risk of Loss.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 4 of38
Services typically include:
1. Establishment and ongoing review/adjustment of Investment Objectives
2. Establishment and adjustment of overall asset allocation strategy
3. Selection, review and evaluation of investment portfolios
4. Performance analysis and evaluation
5. Portfolio rebalancing
6. Strategic risk management
Use of Other Investment Advisory Firms as Sub-Advisors
At its discretion FEG can decide to utilize unaffiliated investment advisory
firms as subadvisors to provide asset management services to selected
Model Portfolios according to the terms and conditions of a written Sub
Advisor Agreement. With respect to its sub-advisory services, FEG will
maintain both the initial and ongoing day-to-day relationship with the
underlying client, including initial and ongoing determination of client
suitability for the sub-advisor's Model Portfolios. In a sub-advisory
relationship, FEG is responsible for the recommendation and selection of the
Sub-Advisor on behalf of the client and can remove the client's assets from
the sub-advisor's management at our discretion.
Retirement Plan Services:
The Employee Retirement Income Security Act of 1974 ("ERISA") sets
forth rules under which Plan Fiduciaries may retain investment advisers for
various types of services with respect to Plan assets. For certain services,
Financial Enhancement Group will be considered a fiduciary under ERISA.
For example, Financial Enhancement Group will act as an ERISA § 3(21)
fiduciary when providing non-discretionary investment advice to the Plan
Fiduciaries by recommending a suite of investments as choices among
which Plan Participants may select. Alternatively, Financial Enhancement
Group can act as an ERISA § 3(38) fiduciary when providing discretionary
investment advice to the Plan Sponsor.
Page 5 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
Financial Enhancement Group offers pension planning and plan
implementation services to small and medium-sized businesses covering
Plan Consulting, Plan Investment, and Plan Participation Services. The
service will address the need of a company to install a comprehensive
retirement plan, provide an overview of the various plan design
characteristics, and assist with the selection of a recordkeeper and/or third
party administrator by utilizing the Ascensus platform as well as Pontara,
Charles Schwab, and Principal. The services provided will be detailed in the
consulting agreement.
Retirement Account Recommendations:
In complying with the Department of Labor's Prohibited Transaction
Exemption 2020-02 ("PTE 2020-02"), when applicable, Financial
Enhancement Group provides the following acknowledgment to clients:
When Financial Enhancement Group provides investment advice to clients
regarding their retirement plan account or individual retirement account, we
are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which
are laws governing retirement accounts. The way Financial Enhancement
Group is compensated could create some conflicts with the clients' interests,
so where applicable, we operate under an exemption that requires us to act in
the client's best interest and not put our interests ahead of the client's. Under
this exemption, we must:
• Meet a professional standard of care (give prudent advice),
• Never put our financial interests ahead of clients' (give loyal advice),
• A void misleading statements about conflicts of interest, fees, and
investments,
• Follow policies and procedures designed to ensure that we give advice that
is in the client's best interest,
• Charge no more than is reasonable for our services, and
• Give clients basic information about conflicts of interest.
Financial Enhancement Group benefits financially from the rollover of client
assets from a retirement account to an account that we manage because the
assets increase our assets under management, and, in turn, our advisory fees.
As a fiduciary, Financial Enhancement Group only recommends a rollover
when we believe it is in the client's best interest.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 6 of38
Financial Planning Services:
Financial Enhancement Group also offers comprehensive financial planning
services for our clients. Our Financial Planning services include data
gathering and analysis, and creation of a financial plan with specific
recommendations and implementation advice tailored to client needs.
Specific areas of advice include investment planning, insurance needs
assessment and advice, retirement planning, cash flow management, debt
consolidation and reduction, capital needs assessments, educational
planning, estate planning, business planning, and social security timing.
Wealth.com-Estate Planning
FEG has entered into an agreement with Wealth.com to provide our clients
with access to their estate planning document creation service through an on
line interface. Clients will create an estate plan based on either a revocable
living trust or a will, also including power of attorney, a healthcare directive,
and a schedule of assets. Additionally, trust-based estate plans will include a
trust funding guide, a trust certification, and a Pour Over Will. Also,
Wealth.com provides a probate service that prepares documents and
educates clients on the probate process in their respective jurisdiction. Both
services include varying levels of support and access to attorneys for
assistance.
Trustee Services
Financial Enhancement Group offers trustee services to our clients that are
interested in FEG managing the trust and its assets. FEG can serve as a co
trustee as well as a successor trustee. Please refer to item 10 for possible
conflict of interest.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 7 of38
Use of AI
Our investment team uses AI (Claude and ChatGPT) to improve clarity in
communication, enhance investment research, and streamline internal
processes. For marketing, we use ChatGPT as a research tool and
copywriting assistant to help generate drafts and refine messaging; however,
all AI-generated content is reviewed, edited, and approved by a human
member of our marketing and compliance team before publication. We do
not use personally identifiable information (PII) for marketing purposes.
Separately, our firm uses AI that is provided by- and integrated within-our
CRM (Practifi), operating in a closed-loop environment designed to keep
information contained within our systems and governance
controls. Practifi Intelligence is built on the same secure, SOC 2 Type II
certified infrastructure as Practifi.
ITEM 5 - Fees and Compensation
The firm's regular fee schedule for its managed account advisory services is
as follows:
Standard Annual Fee (billed quarterly)
Assets Under Management
Asset base below $0.00 to $749,999
Asset base from $750,000 to $999,999
Asset base from $1,000,000 to $2,999,999
Asset base from $3,000,000 to $7,499,999
Asset base from $7,500,000 to $11,999,999
Asset base from $12,000,000 to $15,000,000
1.50% *
1.25%
1.00%
.85%
.80%
.75%
*The firm has a minimum fee of $1,600.00
Fee percentage will vary based on deposits, withdrawals, market gains and
losses.
Page 8 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
All Advisory fees are negotiable. The Advisory Contract can be terminated
by either party at any time in writing, and a pro-rated refund of fees will be
provided to the client. Fees are charged in advance of a quarter, based on
the account value of the last day of the prior quarter as provided by Orion
Advisor Services. New Clients can expect the schedule shown above to
apply. However, there are additional fee schedules offered based on family,
employee, and legacy relationships. A detailed description of all fee
schedules is available for review in the firm's Investment Advisory
Agreement.
Sub-Adviser Manager Program Fees
FEG has developed, previously described in Item 4 of this disclosure
brochure, a process to allow us to recommend and select sub-adviser money
managers for you. Sub-advisers generally have account minimum
requirements that will vary among sub-adviser money managers. A complete
description of the sub-advisers' services, fee schedules and account
minimums will be disclosed in the sub-advisers' disclosure brochure which
will be provided to you prior to or at the time an agreement for services is
executed and the account is established.
The actual fee charged to you will vary depending on the sub-adviser money
manager. The fees charged by FEG do not include the fees charged by the
unaffiliated investment sub-adviser. Fees assessed by FEG are separate and
in addition to the fees charged by the sub-adviser. Both FEG and the sub
adviser manager are responsible for the calculation of their respective fees
and the debit to your account.
We strive to ensure that the combined fees charged by FEG, and the
unaffiliated sub-advisers do not exceed industry standards. Each firm is
separately responsible for calculating their fee and debiting their fee from
your account.
There may be other sub-adviser managers that may be suitable for that may
be more or less costly. No guarantees can be made that your financial goals
or objectives will be achieved. Further, no guarantees of performance can be
offered.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 9 of38
Financial Planning Fees:
For clients of our Discretionary Asset Management service, we offer
comprehensive financial planning as part of the annual percentage-based fee
for portfolio management services; however, a special project could arise
that would lead to a fee. As an example, a client could request our
involvement in the sale of a business or direct involvement in their Estate
Plan. This would fall outside the scope of providing financial services on the
individual level and would lead to an additional fee.
We also will provide comprehensive financial planning service to
individuals that do not utilize our Discretionary Assets Management
Services, which will lead to a fee regardless of the situation. From time to
time, we may, by request, engage with a client to create a one-time,
customized financial plan. Generally, our fees are charged on an hourly basis
of $500.00 per hour.
All fees for financial planning services are based on the breadth of services
provided, and the complexity of the client's situation. Any proposed fee will
be explained and agreed to in advance. Before commencing financial
planning services, the client must enter into an agreement outlining the fees
that will be charged and the services that will be provided. The agreement
may be cancelled at any time, for any reason, with written notice.
Depending on the arrangement, if the financial planning client engages FEG
for Discretionary Asset Management, FEG may offset all or a portion of its
fees for those services based upon the amount paid for the Financial
Planning Services.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 10 of38
Additional Fee Information and Disclosures:
All Advisory fees are negotiable between the firm and clients. Clients can
choose to have fees deducted directly from their accounts, or clients can
choose to be billed directly. The choice of direct billing or automatic
deduction of fees is made at the time of signing new account documents, as
outlined in the Advisory Contract. A client can choose at any time to change
the method of fee deduction/billing for their account.
Please note that the direct management fees paid to this firm are in addition
to the indirect management and expense fees charged by mutual funds,
variable contracts, and exchange traded products; therefore, clients whose
assets are positioned in these types of investments will pay both a direct
management fee to Financial Enhancement Group and an indirect
management fee through the mutual fund and/or the variable provider.
For all accounts held with outside custodians, note that the client will be
responsible for all transactions and other related costs along with other
account fees as agreed to in such Custodial/Brokerage Agreements.
In addition, trading and custodial fees will be charged to the client by the
individual brokerage firm that custodies client assets. Trading commissions
and related fees are disclosed directly by the brokerage/custodian firm at the
time of client account opening or thereafter.
This firm takes numerous actions to address these conflicts of interest. As a
Fiduciary, the firm, via its Management and Compliance Department, works
to ensure that clients' best interests are used when determining investment
recommendations, including review of all advisory recommendations.
Clients are always free to choose the investments made in their accounts per
item 4 and can always choose their own brokerage firm or custodian. In
addition, this firm maintains a Code of Ethics to help ensure that investment
decisions are in the best interest of clients, as disclosed in Item 11 below.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 11 of38
ITEM 6 - Performance Based Fees and
Side-By-Side Management
Financial Enhancement Group does not charge any performance-based fees
of any kind (those fees that are based upon a share of capital gains or capital
appreciation of client assets) or side-by-side management fees.
ITEM 7 - Types of Clients
Financial Enhancement Group provides its Advisory Services to individuals,
families, retirement plans, trusts, estates, charitable organizations, or other
business entities.
We provide account management services for Brokerage, Product
(Annuities), and Individual 401K's.
ITEM 8 - Methods of Analysis, Investment
Strategies, and Risk of Loss
Methods of Analysis:
In assessing the securities to be included in a client portfolio, FEG's primary
analytical focus is on the securities' fundamentals using both quantitative
and qualitative techniques as well as technical analysis. FEG relies on its
proprietary research models but also utilizes outside research reports and
rating services believed to be accurate.
Fundamental analysis: is a method of measuring a security's intrinsic
value by examining related economic and financial factors. Fundamental
analysts study anything that can affect the security's value, from
macroeconomic factors such as the state of the economy and industry
conditions to microeconomic factors like the effectiveness of the company's
management. Assets meeting the investment criteria utilized in the
fundamental analysis may lose value and may have negative investment
performance. The Portfolio Managers monitor these economic indicators to
determine if adjustments to strategic allocations are appropriate.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 12 of38
Technical analysis: is a trading discipline employed to evaluate investments
and identify trading opportunities in price trends and patterns seen on charts.
Technical analysts believe past trading activity and price changes of a
security can be valuable indicators of the security's future price movements.
Even if the trend will eventually reoccur, there is no guarantee that FEG will
be able to accurately predict such a recurrence.
Investment Strategies:
Our investment strategies include long-term, intermediate and/or short-term
purchases based on the Client's Profile, objectives, Risk Tolerance and
guidelines, which can be changed at any time. Clients can place reasonable
restrictions on the strategies to be employed and the types of investments to
be held in their accounts. It is important for the client to remember to update
us with any changes in investment objectives and guidelines.
Although we manage the client's assets in a manner consistent with the
client's risk tolerance and overall financial plan, there can be no guarantee
that our efforts will be successful. Clients should be prepared to bear the risk
of loss.
We monitor market conditions and make tactical adjustments to manage the
risk/reward profile of our various portfolios. In doing so, we will adjust the
allocation to stocks, ETF's, bonds, ETN's and alternatives in our various
portfolios as well as the weighting to different sectors or categories of equity
and bond components. These adjustments are anchored by proprietary tools
we have developed over time: which include, but are not limited to, our Risk
Barometer to control equity allocation and our Sector Overlay to control
exposure to the various sectors. We also utilize software and research tools
that help us measure the risk associated with the securities we select.
Sub-Adviser as Manager
If we determine a need for unique investment strategies, Such as Direct
Indexing or Personized Indexing, or Option Collars, we will research and
evaluate qualified sub-advisors to manage our client assets within the
strategy.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 13 of38
Direct Indexing -- Direct indexing is the process by which an investor
invests in an investment portfolio comprised of individual securities
intended to replicate the performance of one or more investment indexes,
strategies, or models (individually a "Benchmark" and when the portfolio
contains securities that reference more than one Benchmark, a "Blended
Benchmark"). The inputs include but are not limited to preferences, which
may include individual or lists of companies chosen for the portfolio; a
desired Benchmark or a relative allocation between Benchmarks ("Blended
Benchmark"); and investment strategy constraints, such as security
exposure, turnover, and trade thresholds and tax considerations.
Direct Indexing Products do not contain all constituent securities of the
Benchmark, may contain alternative securities, or may contain securities in
different weights or allocations than the Benchmark. As a result, the
portfolios will not track the Benchmark exactly and the gains or losses of the
portfolio may be greater or less than the gains or losses experienced by the
Benchmark. This difference is known as "tracking error."
FEG will take reasonable efforts to mitigate tracking errors within a set
target range by rebalancing the portfolio through the purchase and sale of
constituent securities but cannot guarantee that it will always be able to
successfully mitigate tracking errors. Any restrictions placed by the client on
(i) securities that may be held in a portfolio and (ii) the budget for realized
capital gains on transactions in the account may increase tracking error and
decrease the effectiveness of rebalancing. FEG cannot guarantee that the
dividend yield in any portfolio will accurately track the benchmark. In
taxable accounts, a strategy of tax loss harvesting is often employed in direct
indexing accounts. But tax-loss harvesting involves certain risks, including
that the new investment could have higher costs or perform worse than the
original investment and could introduce portfolio tracking error into
accounts. There may also be unintended tax implications. FEG does not hold
itself out as an accountant or tax adviser and does not provide such services.
Therefore, FEG recommends consulting with a tax adviser before engaging
in direct indexing for the purpose of tax loss harvesting.
Page 14 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
Option Collars are a financial strategy used to protect concentrated
investments from potential downside risks while still allowing for some
upside potential. However, like any investment strategy, options collars also
come with their own set of risks. Below are some of the key risks associated
with option collars:
Limited Upside Potential: One of the primary risks of using options collars
is that they limit the potential gains on the underlying asset. While this is
intentional as the collar is designed to protect against losses, investors need
to weigh the trade-off between downside protection and limited upside
potential.
Cost of Options: Establishing options collars involves buying both
protective puts and selling covered calls. The cost of purchasing these
options can reduce the overall returns on the underlying investment. You
should be aware of the impact of these costs on their overall portfolio
performance.
Complexity: Options trading can be complex, and options collars involve
multiple transactions. You should work with your Adviser to achieve a good
understanding of options and their market dynamics to effectively
implement and manage a collar strategy. Lack of understanding could lead to
unintended consequences.
Market Volatility: Options prices are influenced by market volatility. If the
market experiences significant and unpredictable price swings, the
effectiveness of the options collar in providing downside protection may be
impacted. Sudden and extreme market movements can result in unexpected
outcomes.
Expiration Risk: Options have expiration dates, and if the protective put
options expire before the collar is unwound or adjusted, the investor loses
the downside protection. Managing expiration dates and rolling options
positions require careful attention and monitoring.
Tax Implications: Depending on the specific structure of the options collar
and the tax regulations in each jurisdiction, there may be tax implications.
Investors should consult with tax professionals to understand the tax
consequences of options collar strategies.
Page 15 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
Underlying Asset Risk: The performance of the underlying asset itself can be
a significant factor. If the assets experience a sharp decline in value, the
protection provided by the collar may not be sufficient to offset significant
losses.
Risk of Loss:
All investment strategies involve the risk of loss and there is no guarantee
that any investment strategy will meet its objective. Our portfolio managers
constantly keep in mind the risk of loss. Depending on the type of strategy
the client is invested in, the client can face the following risks:
• Business Risk: Risk associated with economic, industry and financial
circumstances that could affect the price of a company's securities.
• Call Risk: The cash flow risk resulting from the possibility that a callable
bond will be redeemed before maturity. A bond that is called by an issuer
must be redeemed by the bondholder, usually so that the issuer can issue
new bonds at a lower interest rate. This forces the investor to reinvest the
principal sooner than expected, possibly at a lower interest rate.
• Credit Risk: Risk resulting in loss of principal or loss of interest
payments or dividends stemming from a borrower's failure to repay a
loan or otherwise meet a contractual obligation. Credit risk arises
whenever a borrower is expecting to use future cash flows to pay a
current debt. Investors are compensated for assuming credit risk through
interest payments from the issuer of a debt obligation.
• Cyber Security Risk. As the use of technology has become more
prevalent in the course of business, the Adviser has become more
susceptible to operational and financial risks associated with cyber
security, including: theft, loss, misuse, improper release, corruption and
destruction of, or unauthorized access to, confidential or highly restricted
data relating to the Adviser and its clients, and compromises or failures to
systems, networks, devices and applications relating to the operations of
the Adviser and its service providers. Cyber security risks may result in
financial losses to the Adviser and its clients; the inability of the Adviser
to transact business with its clients; delays or mistakes in materials
provided to clients; the inability to process transactions with clients or
other parties; violations of privacy and other laws; regulatory fines,
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 16 of38
penalties and reputational damage; and compliance and remediation
costs, legal fees and other expenses. The Adviser's service providers
(including any sub-advisers, administrator, transfer agent, and custodian
or their agents), financial intermediaries, companies in which client
accounts and funds invest and parties with which the Adviser engages in
portfolio or other transactions also may be adversely impacted by cyber
security risks in their own businesses, which could result in losses to the
Adviser or its clients. While measures have been developed which are
designed to reduce the risks associated with cyber security, there is no
guarantee that those measures will be effective, particularly since the
Adviser does not directly control the cyber security defenses or plans of
its service providers, financial intermediaries, and companies in which
they invest or with which they do business.
• Default Risk: The risk that a bond issuer will default by failing to repay
principal and interest in a timely manner. Bonds issued by the U.S.
government or a U.S. government agency historically have not defaulted,
although there can be no guarantee that a default will not occur in the
future. Bonds issued by corporations are more likely to default than
bonds issued by the federal government or a municipal issuer because of
insufficient cash flow to make interest and principal payments or the
potential for insolvency. Municipalities occasionally default, although
historically, this has been an infrequent occurrence.
• Diversification Risk: Concentrating investments in one or a few
industries or sectors can involve more risk than more diversified
investments, including the potential for greater volatility. Selecting
diverse investments with different rates of return could offset losses in
one area with gains in another.
• Economic Risk: In financing a project, the risk that the project's output
will not generate sufficient revenues to cover operating costs and to repay
debt obligations.
• Financial Risk: Excessive borrowing to finance business operations puts
a company's profitability at risk because the company must meet the
terms of its obligations in good times and bad. During periods of
financial stress, the inability to meet loan obligations can result in
default, bankruptcy and/or a declining market value.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 17 of38
• Fixed Income Risks: Portfolios that invest in fixed income securities are
subject to several general risks, including interest rate risks, default risks,
credit risks and market risks, which could reduce the yield that an
investor receives from his or her portfolio. These risks can occur from
fluctuations in interest rates, a change to an issuer's individual condition
or industry, or events in financial markets.
• Foreign (non-U.S.) investment risk, which is the risk that investing in
foreign securities result in the portfolio experiencing more rapid and
extreme changes in value than a portfolio that invests exclusively in
securities of U.S. companies. Risks associated with investing in foreign
securities include fluctuations in the exchange rates of foreign currencies
that may affect the U.S. dollar value of a security, the possibility of
substantial price volatility as a result of political and economic instability
in the foreign country, less public information about issuers of securities,
different securities regulation, different accounting, auditing and
financial reporting standards and less liquidity than in the U.S. markets.
• High-Yield Fixed-Income Securities Risk: Investments in high-yield
rated bonds involve higher risk than investment grade bonds because of
higher volatility and, a greater risk of default. Adverse conditions can
affect the issuer's ability to make timely interest and principal payments
on these securities.
• High Portfolio Turnover Risk. Certain strategies engage in active and
frequent trading leading to increased portfolio turnover, higher
transaction costs, and the possibility of increased capital gains, including
short- term capital gains that are generally taxable as ordinary income.
•
Inflation Risk: When any type of inflation is present, the dollar next year
will not buy as much as a dollar today, because purchasing power is
eroding at the rate of inflation.
•
Interest-Rate Risk: Interest rate risk affects the value of bonds more
directly than that of stocks. As interest rates rise, bond prices fall, and
when interest rates decrease, bond prices rise. Similarly, as interest rates
fluctuate, stocks can become more or less attractive alternative relative to
bonds.
Page 18 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
•
Investment Risk: Investment Risk is the probability that an actual return
on an investment will be lower than the investor's expectations. All
investments have some level of risk associated with them due to the
unpredictability of the market's direction.
• Liquidity Risk: When consistent with a client's investment objectives,
guidelines, restrictions, and risk tolerances, we can invest a portion of a
client's portfolio in illiquid securities, subject to applicable investment
standards. Investing in an illiquid, or difficult to trade, security could
restrict our ability to dispose of an investment in a timely fashion, if at
all, or at an advantageous price, which can limit the ability to take full
advantage of market opportunities.
• Market Risk: The price of a security can drop in reaction to tangible and
intangible events and conditions. This type of risk is caused by external
factors independent of a security's particular underlying circumstances.
For example, political, economic, and social conditions can trigger
adverse market events.
• Principal Risk: The risk of losing the amount invested due to bankruptcy
or default. There is always the possibility that, through some set of
circumstances, the principal amount of money invested will lose value or
be lost completely. In such case, principal is lost in addition to a share of
future profits.
• Pandemics and COVID-19!. Occurrences of epidemics or pandemics,
depending on their scale, may cause different degrees of damage to
global, national, and local economies, or extreme volatility in US or
global markets. COVID-19 (also known as novel coronavirus or
coronavirus disease 2019) presents unique, rapidly changing and hard to
quantify risks. In general, it has resulted in a significant reduction in
commercial activity on a global scale that has adversely impacted many
businesses. Governments, on the national, local, and state level, are
instituting a variety of measures including closing borders, lockdowns,
quarantines and states of emergencies, and disruption of supply chains,
which collectively may slow the national or global economy to the point
where it enters a recession. Although there is reason to believe that the
COVID-19 outbreak may be contained over a reasonable period of time,
there can be no assurance this will be the case and, in the meantime,
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 19 of38
global equity, bond and credit markets may be adversely affected. Such
disruption may adversely affect Client returns.
• Reinvestment Risk: The risk that future proceeds from investments can
be reinvested at a potentially lower rate of return (i.e. interest rate). This
primarily relates to fixed income securities.
• Small/Mid-Cap Risk: Stocks of small (market capitalization of between
$300 million and $2 billion) or mid-cap (market capitalization of between
$2 and $10 billion) companies can have less liquidity than those of larger
(market capitalization greater than $10 billion), established companies and
could be subject to greater price volatility and risk than the overall stock
market.
• Tactical Allocation Risk. The Adviser generally has discretion to make
term tactical allocations that increase or
short to intermediate
decrease the exposure to asset classes and investments. As a result of
these tactical allocations, a client account may deviate from its strategic
target allocations at any given time. A client's account's tactical
allocation strategy may not be successful in adding value, may increase
losses to the account or fund and/or cause the account to have a risk
profile different than that portrayed in the client account's strategic asset
allocations from time to time.
Regulatory Risks:
• Strategy Restrictions. Certain institutions may be restricted from directly
utilizing investment strategies of the type in which the Adviser may
engage. Such institutions, including entities subject to ERISA, should
consult their own advisors, counsel, and accountants to determine what
restrictions may apply and whether an investment is appropriate.
• Trading Limitations. For all securities, instruments and/or assets listed on
an exchange, including options listed on a public exchange, the exchange
generally has the right to suspend or limit trading under certain
circumstances. Such suspensions or limits could render certain strategies
difficult to complete or continue and subject an investor to loss. Also,
such a suspension could render it impossible for an investor to liquidate
positions and thereby expose the investor to potential losses.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 20 of38
• Conflicts of Interest: In the administration of client accounts, portfolios,
and financial reporting, the Adviser faces inherent conflicts of interest
which are described in this brochure. Generally, the Adviser mitigates
these conflicts through its Code of Ethics which ensures that the client's
interest is always held above that of the Firm and its associated persons.
• Supervision of Trading Operations. The Adviser, with assistance from its
brokerage and clearing firms, intends to supervise and monitor trading
activity in the portfolio accounts to ensure compliance with firm and
client objectives. Despite the Adviser's efforts, however, there is a risk
that unauthorized or otherwise inappropriate trading activity may occur
in portfolio accounts. Depending on the nature of the investment
management service selected by a client and the securities used to
implement the investment strategy, clients will be exposed to risks that
are specific to the securities in their particular investment portfolio.
Risks associated with certain types of Securities:
• Exchange-Traded Funds (ETFs ): ETFs are typically investment
companies that are legally classified as open-end mutual funds or UITs.
However, they differ from traditional mutual funds, in that ETF shares
are listed on a securities exchange. Shares can be bought and sold
throughout the trading day like shares of other publicly traded
companies. ETF shares may trade at a discount or premium to their net
asset value. This difference between the bid price and the ask price is
often referred to as the "spread." The spread varies over time based on
the ETF's trading volume and market liquidity and is generally lower if
the ETF has a lot of trading volume and market liquidity and higher if the
ETF has little trading volume and market liquidity. Although many ETFs
are registered as an investment company under the Investment Company
Act of 1940 like traditional mutual funds, some ETFs, in particular those
that invest in commodities, are not registered as an investment company.
ETFs may be closed and liquidated at the discretion of the issuing
company.
Page 21 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
Exchange-Traded Notes (ETNs): An ETN is a senior unsecured debt
obligation designed to track the total return of an underlying market index or
other benchmark. ETNs may be linked to a variety of assets, for example,
commodity futures, foreign currency and equities. ETNs are similar to ETFs
in that they are listed on an exchange and can typically be bought or sold
throughout the trading day. However, an ETN is not a mutual fund and does
not have a net asset value; the ETN trades at the prevailing market price.
Some of the more common risks of an ETN are as follows. The repayment
of the principal, interest (if any), and the payment of any returns at maturity
or upon redemption are dependent upon the ETN issuer's ability to pay. In
addition, the trading price of the ETN in the secondary market may be
adversely impacted if the issuer's credit rating is downgraded. The index or
asset class for performance replication in an ETN may or may not be
concentrated in a specific sector, asset class or country and may therefore
carry specific risks. ETN s may be closed and liquidated at the discretion of
the issuing company.
ETFs and ETN's are two forms of Exchange Traded Products, not to be
confused with other forms, as more fully explained below.
Exchange Traded Products (ETPs) are types of securities that derive their
value from a basket of securities such as stocks, bonds, commodities or
indices, and trade intra-day on a national securities exchange. Generally,
ETPs take the form of Exchange Traded Funds (ETFs) or Exchange Traded
Notes (ETNs).
Non-traditional ETPs employ sophisticated financial strategies and
instruments, such as leverage, futures, and derivatives, in pursuit of their
investment objectives. Leveraged and inverse ETPs are considered risky.
The use of leverage and inverse strategies by a fund increases the risk to the
fund and magnifies gains or losses on the investment. You could incur
significant losses even if the long-term performance of the underlying index
showed a gain. Typically, these products have one-day investment
objectives, and investors should monitor such funds on a daily basis. Non
traditional ETPs are generally categorized as leveraged, inverse, or
leveraged-inverse:
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 22 of38
• Leveraged: Uses financial derivatives and debt to multiply the returns of
an underlying index, commodity, currency, or basket of assets.
Leveraged ETPs may include the terms "double," "ultra," "triple," or
similar language in their security name/description.
•
Inverse: Uses various derivatives to seek profit from the decline in the
value of an underlying index, commodity, currency, or basket of assets;
used typically to hedge exposure to downward markets. Inverse ETPs
may include the term "contra," "short," or similar language in their
security name/description.
• Leveraged-Inverse: Uses swaps, futures contracts, options, and other
derivative instruments to seek to achieve a return that is a multiple of the
opposite performance of the underlying benchmark or index. Leveraged
inverse ETPs may include a combination of leveraged and inverse terms
such as "ultra-short" in their security name/description.
• The Financial Industry Regulatory Authority (FINRA) and the Securities
and Exchange Commission (SEC) seek to warn retail investors of the
risks associated with investing in non-traditional ETFs and issued an
Investor Alert entitled "Leveraged and Inverse ETFs: Specialized
Products with Extra Risks for Buy-and-Hold Investors," which is
available on FINRA's and the SEC's web sites.
•
Investors who choose to invest in non-traditional ETPs should be aware
of the risks, some of which are outlined below:
• Non-traditional ETPs are complex products that have the potential for
significant loss of principal and are not appropriate for all
investors. Investors should consider their financial ability to afford the
potential for a significant loss.
• Non-traditional ETPs seek investment results for a single day only. The
effect of compounding and market volatility could have a significant
impact upon the investment returns. Investors may lose a significant
amount of principal rapidly in these securities.
• Non-traditional ETPs may be volatile under certain market
conditions. Investors holding non-traditional ETPs over longer periods of
time should monitor those positions closely due to the risk of volatility.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 23 of38
• Non-traditional ETPs are focused on daily investment returns, and their
performance over longer periods of time can differ significantly from
their stated daily objective. Investors may incur a significant loss even if
the index shows a gain over the long term.
• Non-traditional ETPs use a variety of derivative products in order to seek
their performance objectives. The use of leverage in ETPs can magnify
any price movements, resulting in high volatility and potentially
significant loss of principal.
• Non-traditional ETPs may suffer losses even though the benchmark
currency, commodity, or index has increased in value. Investment returns
of non-traditional ETPs may not correlate to price movements in the
benchmark currency, commodity, or index the ETP seeks to track.
• Some non-traditional ETPs may have a low trading volume, which could
impact an investor's ability to sell shares quickly.
• Non-traditional ETPs may be less tax efficient than other ETPs. As with
any potential investment, an investor should consult with his or her tax
advisor and carefully read the prospectus to understand the tax
consequences of non-traditional ETPs.
• The specific risks associated with a particular ETP are detailed in the
fund's prospectus. Additional risks may include adverse market condition
risks, investment strategy risk, aggressive investment techniques risk,
concentration risk, correlation risk, counterparty risk, credit risk and
lower-quality debt securities risk, energy securities risk, equity securities
risk, financial services companies risks, interest rate risk, inverse
correlation risk, leverage risk, market risk, non-diversification risk,
shorting risk, small and mid-cap company risk, tracking error risk, and
special risks of exchange traded funds, among others. Investors should
refer to the ETP's prospectus to obtain a complete discussion of the risks
involved in that ETP before investing.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 24 of38
Structured Notes are securities issued by financial institutions whose returns
are based on, among other things, equity indexes, a single equity security, a
basket of equity securities, interest rates, commodities, and/or foreign
currencies. Thus, your return is "linked" to the performance of a reference
asset or index. Structured notes have a fixed maturity and include two
components - a bond component and an embedded derivative. Financial
institutions typically design and issue structured notes, and broker-dealers
sell them to individual investors.
Some common types of structured notes sold to individual investors include
principal protected notes, reverse convertible notes, enhanced participation
or leveraged notes, and hybrid notes that combine multiple characteristics.
Some of the risks associated with Structured notes are outlined below:
• Complexity. You and your broker should take time to fully
understand the way your return on a structured note is calculated.
You should understand the reference asset( s) or index( es) and
determine how the note's payoff structure incorporates such reference
asset(s) or index(es) in calculating the note's performance. This
payoff calculation may include leverage multiplied on the
performance of the reference asset or index, protection from losses
should the reference asset or index produce negative returns, and fees.
• Market risk. Some structured notes provide for the repayment of
principal at maturity, which is often referred to as "principal
protection." This principal protection is subject to the credit risk of the
issuing financial institution. Many structured notes do not offer this
feature. For structured notes that do not offer principal protection, the
performance of the linked asset or index may cause you to lose some,
or all, of your principal. Depending on the nature of the linked asset
or index, the market risk of the structured note may include changes in
equity or commodity prices, changes in interest rates or foreign
exchange rates, or market volatility.
•
Issuance price and note value. The price you will pay for a structured
note at issuance will likely be higher than the fair value of the
structured note on the date of issuance. Issuers now disclose an
estimated value of the structured note on the cover page of the
offering prospectus, allowing investors to gauge the difference
between the issuer's estimated value of the note and the issuance
pnce.
Page 25 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
The estimated value of the notes is likely lower than the issuance price
of the note to investors because issuers include the costs for selling,
structuring, or hedging the exposure on the note in the initial price of
their notes. After issuance, structured notes may not be re-sold on a
daily basis and thus may be difficult to value given their complexity.
• Liquidity. Your ability to trade or sell structured notes in a secondary
market is often very limited as structured notes ( other than exchange
traded notes known as ETNs) are not listed for trading on security
exchanges. As a result, the only potential buyer for your structured
note may be the issuing financial institution's broker-dealer affiliate
or the broker-dealer distributor of the structured note. In addition,
issuers often specifically disclaim their intention to repurchase or
make markets in the notes they issue. You should, therefore, be
prepared to hold a structured note to its maturity date, or risk selling
the note at a discount to its value at the time of sale.
• Payoff structure. Structured notes may have complicated payoff
structures that can make it difficult for you to accurately assess their
value, risk and potential for growth through the term of the structured
note. Determining the performance of each note can be complex and
this calculation can vary significantly from note to note depending on
the structure. Notes can be structured in a wide variety of ways.
Payoff structures can be leveraged, inverse, or inverse-leveraged,
which may result in larger returns or losses for you. You should
carefully read the prospectus for a structured note to fully understand
how the payoff on a note will be calculated and discuss these issues
with your broker. For example, the payoff on structured notes can
depend on:
• Participation rates. Some structured notes provide a minimum payoff
of the principal invested plus an additional payoff to you based on
multiplying any increase in the reference asset or index by a fixed
percentage. This percentage is often called the participation rate. A
participation rate determines how much of the increase in the
reference asset or index will be paid to investors of the structured
note. For example, if the participation rate is 50 percent, and the
reference asset or index increased 20 percent, then the return paid to
you would be 10 percent (which is 50 percent of 20 percent).
Page 26 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
• Capped maximum returns. Some structured notes may provide
payments linked to a reference asset or index with a leveraged or
enhanced participation rate, but only up to a capped, maximum
amount. Once the maximum payoff level is reached, you do not
participate in any additional increases in the reference asset or index.
For example, a note may provide the investor with 100% of all funds
invested at the end of two years, plus an enhancement of any rise in
the performance of the S&P 500 up to 20%. If the performance of the
S&P 500 increases 25% in those two years, you only receive a return
of20%.
• Knock-in feature. If the reference asset or index falls below a pre
specified level during the term of the note, you may lose some or all
of your principal investment at maturity and could lose coupon
payments scheduled throughout the term of the note. This pre
specified level may be called a barrier, trigger, or knock-in. When
this level is breached, the payout return changes on the note.
For example, if the reference asset or index falls below the knock-in
level and its value is lower than on the date of issuance, instead of
receiving a return of your principal, you may instead receive an
amount that reflects the decline in value of the reference asset or
index. For certain types of structured notes, you may receive the
reference asset that has declined in value during the term of the note.
• Credit risk. Structured notes are unsecured debt obligations of the
issuer, meaning that the issuer is obligated to make payments on the
notes as promised. These promises, including any principal
protection, are only as good as the financial health of the structured
note issuer. If the structured note issuer defaults on these obligations,
investors may lose some, or all, of the principal amount they invested
in the structured notes as well as any other payments that may be due
on the structured notes.
• Call risk. Some structured notes have "call provisions" that allow the
issuer, at its sole discretion, to redeem the note before it matures at a
price that may be above, below, or equal to the face value of the
structured note. If the issuer "calls" the structured note, investors may
not be able to reinvest their money at the same rate of return provided
by the structured note that the issuer redeemed.
Page 27 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
Tax considerations: The tax treatment of structured notes is complicated and,
in some cases, uncertain. Before purchasing any structured note, you may
wish to consult with a tax advisor. You also should read the applicable tax
risk disclosures in the prospectuses and other offering documents of any
structured note you are considering purchasing.
• Real estate risk, which is the risk that an investor's investments in Real
Estate Investment Trusts ("REITs") or real estate-linked derivative
instruments will subject the investor to risks similar to those associated with
direct ownership of real estate, including losses from casualty or
condemnation, and changes in local and general economic conditions,
supply and demand, interest rates, zoning laws, regulatory limitations on
rents, property taxes and operating expenses. An investment in REITs or real
estate-linked derivative instruments subject the investor to management and
tax risks.
• Commodity risk, generally commodity prices fluctuate for many reasons,
including changes in market and economic conditions or political
circumstances ( especially of key energy-producing and consuming
countries), the impact of weather on demand, levels of domestic production
and imported commodities, energy conservation, domestic and foreign
governmental regulation ( agricultural, trade, fiscal, monetary and exchange
control), international politics, policies of OPEC, taxation and the
availability of local, intrastate and interstate transportation systems and the
emotions of the marketplace. The risk of loss in trading commodities can be
substantial.
• Alternative investments/private funds risk, investing in alternative
investments is speculative, not suitable for all clients, and intended for
experienced and sophisticated investors who are willing to bear the high
economic risks of the investment, which can include:
• loss of all or a substantial portion of the investment due to leveraging,
short-selling or other speculative investment practices.
• lack of liquidity in that there may be no secondary market for the
investment, and none expected to develop.
• volatility of returns.
Page 28 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
•
restrictions on transferring interests in the investment.
• potential lack of diversification and resulting higher risk due to
concentration of trading authority when a single adviser is utilized.
• absence of information regarding valuations and pricing.
• delays in tax reporting.
• less regulation and higher fees than mutual funds.
• risks associated with the operations, personnel, and processes of the
manager of the funds investing in alternative investments.
• Closed-end funds risk, Closed-end funds typically use a high degree of
leverage. They may be diversified or non-diversified. Risks associated with
closed-end fund investments include liquidity risk, credit risk, volatility and
the risk of magnified losses resulting from the use of leverage. Additionally,
closed-end funds may trade below their net asset value.
• Variable Prepaid Forward Contract: A variable prepaid forward
(VPF) is a strategy that allows a shareholder immediate liquidity
against appreciated stock while deferring delivery (and often capital
gains recognition) until a future settlement date. At maturity, the
shareholder delivers a variable number of shares based on the stock
price, which generally creates a collar that is exposed to the
risks stated above.
ITEM 9 - Disciplinary Information
Firms are required to report any legal or disciplinary events that are material
to a client's evaluation of our advisory business and the integrity of our
management. There are no legal or disciplinary events that are reportable
under this Item for FEG.
Page 29 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
ITEM 10 - Other Financial Industry
Activities and Affiliations
FEG is not and does not have a related person that is a municipal securities
dealer, government securities dealer or broker, an investment company or
other pooled investment vehicle (including a mutual fund, closed-end
investment company, unit investment trust, private investment company or
"hedge fund," and offshore fund), a futures commission merchant,
commodity pool operator, or commodity trading advisor, a banking or thrift
institution, an accountant or accounting firm, a lawyer or law firm, an
insurance company or agency, a pension consultant, a real estate broker or
dealer, and a sponsor or syndicator of limited partnerships.
We are an independent registered investment advisor and only provide
investment advisory services. We are not engaged in any other business
activities and offer no other services except those described in this
Disclosure Brochure. However, while we do not sell products or services
other than investment advice, our representatives can sell other products or
provide services outside of their role as investment advisor representatives
with us.
Insurance Agent
You may also work with your investment advisor representative in his or
her separate capacity as an insurance agent. When acting in his or her
separate capacity as an insurance agent, the investment advisor
representative may sell, for commissions, general disability insurance, life
insurance, annuities, and other insurance products to you. As such, your
investment advisor representative in his or her separate capacity as an
insurance agent may suggest that you implement recommendations of FEG
by purchasing disability insurance, life insurance, annuities, or other
insurance products. This receipt of commission creates an incentive for the
representative to recommend those products for which your investment
advisor representative will receive a commission in his or her separate
capacity as an insurance agent. Consequently, there is a natural conflict of
interest created, and the advice rendered to you could be biased. You are
under no obligation to implement any insurance or annuity transaction
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 30 of38
through your investment advisor representative. To mitigate against these
conflicts, a separate firm Principal reviews all insurance proposal activity to
detect and prevent unsuitable transactions.
Trust Services
There are times when Financial Enhancement Group has been named as a
co-trustee or a successor trustee by a client. The fees related to acting as a
trustee are in addition to FEG's asset management fees. In these situations, a
conflict of interest is created when an FEG adviser recommends this service.
ITEM 11 - Code of Ethics, Participation or Interest
in Client Transactions, and Personal Trading
Code of Ethics:
Financial Enhancement Group maintains a Code of Ethics that requires
every aspect of our business to be conducted in a fair, lawful and
professional manner. Strict compliance with all laws and regulations
governing the securities industry is paramount. It is our obligation to respect
and protect the right to privacy of all our clients. Confidential or proprietary
information obtained in the course of doing business will not be used for
personal gain or shared with others for their personal benefit. All efforts are
made to avoid actual or potential conflicts of interest, and to ensure
disclosure of any actual or potential conflict of interest. In addition, the
Code requires that certain transactions by firm personnel be pre-approved,
and that firm personnel report all reportable holdings and transactions to
firm management on a regular basis. A copy of our Code of Ethics is
available to existing and prospective clients upon request - just call our main
office in Anderson, or request a copy from your Advisory Representative,
who will ensure that a copy is mailed to you at no charge.
Participation or Interest in Client Transactions and Personal Trading:
Registered and non-registered employees of FEG can manage his/her own
accounts. As such, firm personnel can own the same securities or other
investments that client accounts contain. Client transactions are executed
Page 31 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE
either prior to or simultaneously with those of the firm personnel. All
employee transactions are reviewed by the Compliance Department to
ensure that any conflicts can be identified and addressed.
FEG does not conduct 'Principal' transactions, does not engage in Cross
Trades between advisory clients, and does not participate in Agency Cross
Transactions ( wherein an advisory client buys or sells to or from a FEG
brokerage client).
Trade Rotation Policy:
FEG's policy is to provide a fair and equitable method of trade rotation in
placing trades for client's accounts. To meet this objective, FEG has
established a written trade rotation procedure.
Generally, FEG utilizes a trade rotation log when trading on multiple
platforms, which lists the trade rotation schedule for certain client accounts.
The log is designed as an internal control to help FEG ensure that it does not
treat client accounts unfairly to the extent reasonably practicable and that no
client account ( or group of accounts) receives placement priority over any
other participating accounts.
Trade Errors:
Even with our best efforts and controls, trade errors happen. All trade errors
are brought to the attention of the Allocation Department who work to
correct the error with the intent to make the client whole. If the error caused
a loss for the client, the firm will pay the lost amount to the custodian to
balance the transaction. If there were gains realized during the date of the
trade error and the date of the correction the custodian will donate those
funds to a charity.
ITEM 12 - Brokerage Practices
FEG will primarily recommend that advisory clients establish brokerage
account(s) with Charles Schwab, a FINRA-registered Broker-Dealer,
member SIPC, to maintain custody of clients' assets and to effect trades for
their accounts. Although FEG does recommend that clients establish
accounts at Charles Schwab, it is the client's decision to custody assets with
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 32 of38
Charles Schwab, and clients are free to choose any Broker/Dealer or account
Custodian that they desire. In addition, FEG may also recommend other
custodians dependent on their individual needs and services.
The firm considers the following factors before suggesting a particular
brokerage firm to clients: the products offered, the level of service, the
quality of trade execution, the record keeping and reporting capabilities,
software and related technological capabilities, the trading platforms offered,
and the ability to meet client needs. In assessing the reasonableness of their
commissions, the firm compares various brokerage firm rates on an ongoing
basis. In considering all these parameters, this firm recommends that clients
use Charles Schwab.
The firm remains flexible in the use of other brokerage firms upon client
request or where otherwise appropriate. Clients could receive lower overall
commission rates, enhanced execution, or other services at another
broker/dealer. Each client must evaluate each broker/dealer carefully to
ensure that the broker selected provides them with the best blend of cost,
clearance and settlement, and other services.
However, clients who direct their brokerage accounts to broker/dealers of
their own independent choosing may not receive best execution on their
trades. For example, such clients usually cannot participate in block orders
with other firm clients and the lower transaction costs such trades afford. In
such transactions, share prices are averaged across client accounts
participating in the block transaction (although clients could still be subject
to a minimum commission charge).
FEG participates in the Charles Schwab Institutional advisor program.
Charles Schwab Institutional is a division of Charles Schwab, Inc. ("Charles
Schwab") member FINRA/SIPC/NF A. Charles Schwab is an independent
and unaffiliated SEC-registered broker-dealer. Charles Schwab offers to
independent Investment Advisors services which include custody of
securities, trade execution, clearance, and settlement of transactions.
Advisor receives some benefits from Charles Schwab through its
participation in the program. (Please see the disclosure below and under
Item 14 below.)
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 33 of38
ITEM 13 - Review of Accounts
A member of the Compliance Department will review client accounts on an
ongoing basis as part of the Portfolio management process. Such reviews
are conducted at least quarterly.
Each month, clients receive a statement detailing asset holdings and
transactions directly from the broker/dealer, bank, or other qualified
custodian that holds and maintains client's investment assets. Each quarter,
clients receive written statements prepared by FEG detailing holdings and
investment performance as compared to appropriate benchmark indexes
depending on the model. Performance is calculated for the current period,
year-to-date, and 'Since Inception' of the account.
FEG clients are contacted through weekly video commentary, telephone
calls, and quarterly statement letters. In addition, FEG clients are invited to
two group events each year. Through these contacts FEG provides our
outlook for the financial markets, our investment strategies, review changes
in the client's financial situation, and any other topic clients would like to
explore.
We are pleased to discuss any topic of interest to a client at the client's
convenience, and clients are free to contact their Representative or any other
member of our management team at any time with questions, comments, or
concerns.
ITEM 14 - Client Referrals and Other Compensation
As disclosed under Item 12 above, Advisor participates in Charles Schwab's
institutional customer program and Advisor does recommend Charles
Schwab to Clients for custody and brokerage services. There is no direct
link between Advisor's participation in the program and the investment
advice it gives to its clients, although Advisor receives economic benefits
through its participation in the program that are typically not available to
Charles Schwab retail investors.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 34 of38
These benefits include the following products and services (provided
without cost or at a discount): receipt of duplicate Client statements and
confirmations; research related products and tools; consulting services;
access to a trading desk serving Advisor participants; access to block trading
(which provides the ability to aggregate securities transactions for execution
and then allocate the appropriate shares to Client accounts); the ability to
have advisory fees deducted directly from Client accounts; access to an
electronic communications network for Client order entry and account
information; access to mutual funds with no transaction fees and to certain
institutional money managers; and discounts on compliance, marketing,
research, technology, and practice management products or services
provided to Advisor by third party vendors.
Charles Schwab could also have paid for business consulting and
professional services received by Advisor's related persons. Some of the
products and services made available by Charles Schwab through the
program could benefit Advisor but may not benefit its client accounts.
These products or services could assist the Advisor in managing and
administering Client accounts, including accounts not maintained at Charles
Schwab. Other services made available by Charles Schwab are intended to
help Advisor manage and further develop its business enterprise.
The benefits received by Advisor or its personnel through participation in
the program do not depend on the amount of brokerage transactions directed
to Charles Schwab. As part of its fiduciary duties to clients, Advisor
endeavors always to put the interests of its clients first. Clients should be
aware, however, that the receipt of economic benefits by Advisor or It's
related persons in and of itself creates a potential conflict of interest and
could indirectly influence the Advisor's choice of Charles Schwab for
custody and brokerage services.
Referrals
FEG engages solicitors\Promoters ( or "referral agents") to introduce
potential clients to the firm. These solicitors are independent third parties or
employees of the firm who may receive compensation for their referrals in
accordance with a written agreement.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 35 of38
The compensation provided to solicitors may be in the form of a flat fee, a
percentage of the advisory fees paid by referred clients, or another agreed
upon arrangement. This compensation creates a conflict of interest because
solicitors have a financial incentive to refer clients to FEG rather than to
other advisers.
To address this conflict of interest, FEG ensures the following:
• Solicitors are required to provide prospective clients with a written
disclosure document outlining the terms of their compensation and
their relationship with FEG.
• The referral fees paid to solicitors do not result in any additional costs
or fees to the client.
Clients referred by solicitors are encouraged to review the solicitor's
disclosure document, which includes detailed information about their
compensation and any potential conflicts of interest. For more information
about these arrangements, please contact the Firm's Chief Compliance
Officer Donald Hodson at dhodson@yourlifeafterwork.com.
Vendors
FEG has a Service Agreement with Orion Advisor Services to provide
trading, billing, data aggregation, reporting and operation solutions, as well
as other advisor solutions, and our custodian Charles Schwab and Co, Inc.,
and other qualified custodians as approved by FEG. This agreement allows
Orion to perform certain trading, operational, data aggregation and other
administrative duties with these custodians on our behalf.
ITEM 15 - Custody
When authorized by clients, we will directly debit client advisory fees from
client accounts, which under applicable regulations is deemed a form of
custody. All funds are held by the Brokerage firm or Custodian firm of the
client's choosing. The Brokerage firm or Custodian firm sends monthly or
quarterly statements directly to clients on a regular basis.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 36 of38
Because the custodian does not calculate the amount of our advisory fee to
be deducted, it is important for clients to review their custodial statements
carefully and thoroughly. FEG encourages all clients to carefully compare
quarterly, or other reports provided by this firm to custodial or brokerage
statements issued by the applicable brokerage or custodial firms and should
immediately bring any discrepancies or questions to the attention of their
Advisory Representative.
Effective August 2020, FEG does maintain custody. This custody is held
within a limited number of client accounts for whom the firm or one of our
employees acts as a Trustee.
FEG has a contract in place with an independent public accounting firm to
conduct the required surprise custody audit, which is filed with the SEC on
ADV-E. Accounts of these clients will also be maintained with an outside
custodial firm, and clients will receive statements and other regular reports
from their custodian, which they should review carefully.
ITEM 16 - Investment Discretion
Financial Enhancement Group does maintain Discretionary authority in
client accounts, and clients must authorize the use of Discretion when
opening their account when signing the Investment Advisory
Contract/ Agreement. Discretion is limited discretion, allowing this firm to
execute trades, rebalance accounts, and buy and sell investments within
client accounts, in accordance with the Advisory Agreement and client
investment objectives.
As noted in Item 4 of this Brochure, firm advisory services can be tailored to
each client - as such, if a client requires any restrictions on any types of
investments, stocks, or market segments, the client needs to inform their
Advisory Representative of the restrictions in writing. If, for any reason, the
firm is not able to meet the client's restrictions, the firm will notify the client
of that fact so that the client can determine their requirements and needs.
FORM ADV PART 2A - DISCLOSURE BROCHURE
Page 37 of38
ITEM 17 - Voting Client Securities
Financial Enhancement Group does not, and will not, vote client proxies.
Clients retain the authority to vote proxies and will be responsible for
ensuring that all proxy materials are sent directly to them.
ITEM 18 - Financial Information
PEG does not require prepayment of more than $1,200 in fees per client six
months or more in advance - as such, a Balance Sheet is not required and
therefore not attached.
ITEM 19- State Registered Advisors
As PEG is an Advisor registered with the Securities Exchange Commission,
this item is not applicable.
Page 38 of38
FORM ADV PART 2A - DISCLOSURE BROCHURE