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ITEM 1 - COVER PAGE
ADV PART 2A BROCHURE
PANORAMIC INVESTMENT ADVISORS, LLC
D/B/A
FORTY NORTH WEALTH
650 S. CHERRY ST., SUITE 840
GLENDALE, CO 80246
P/ 303.691.1808
W/ FORTYNORTHWEALTH.COM
MARCH 2, 2026
This brochure provides information about the qualifications and business practices of Panoramic Investment Advisors, LLC d/b/a Forty North
Wealth (“Forty North”). If you have any questions about this brochure's contents, please contact us at (303) 691-1808. The information in
this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or any state securities
authority. Forty North is a Registered Investment Adviser (“RIA”). Registration as an Investment Adviser with the SEC or any state securities
authority does not imply a certain level of skill or training.
Additional information about Forty North is available on the SEC's website at http://www.adviserinfo.sec.gov/. You can search this site by a
unique identifying number called an IARD number. The IARD number for Forty North is 290770.
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ITEM 2 - MATERIAL CHANGES
SUMMARY OF MATERIAL CHANGES
Under federal and state law, fiduciaries must make full disclosure to Clients of all material facts relating to the
advisory relationship. This brochure provides clients or prospective clients with information and conflicts of
interest about Forty North Wealth that should be considered before or when obtaining our investment advisory
services. We are required to update this item to describe the material changes made to this brochure on an
annual basis and deliver to you, within 120 days of the end of the fiscal year, a free updated brochure that
includes or is accompanied by a summary of material changes; or a summary of material changes and an offer
to provide an updated brochure and how to obtain it. We will also provide interim disclosures regarding material
changes, as necessary.
Since our last annual amendment filing on March 28, 2026, the following material changes have occurred:
• The name that we primarily do business under changed from Panoramic Investment Advisors to Forty
North Wealth.
•
Item 4: We no longer offer services through Pontera.
This brochure may be updated periodically for non-material changes to clarify and provide additional
information.
QUESTIONS & CONCERNS
We encourage you to read this document in its entirety. Our Chief Compliance Officer, Lindsay Rider, remains
available to address any questions or concerns regarding this Part 2A Brochure, including any material change
disclosure or information described below. You can reach her by emailing info@fortynorthwealth.com.
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ITEM 3 - TABLE OF CONTENTS
ITEM 1 - COVER PAGE _______________________________________________________________________ 1
ITEM 2 - MATERIAL CHANGES ________________________________________________________________ 2
SUMMARY OF MATERIAL CHANGES _______________________________________________________ 2
QUESTIONS & CONCERNS ________________________________________________________________ 2
ITEM 3 - TABLE OF CONTENTS _______________________________________________________________ 3
ITEM 4 - ADVISORY BUSINESS ________________________________________________________________ 7
ABOUT OUR FIRM ________________________________________________________________________ 7
ADVISORY SERVICES WE OFFER ___________________________________________________________ 7
INVESTMENT ADVISORY SERVICES __________________________________________________________________ 7
LEGACY MANAGEMENT SERVICES __________________________________________________________________ 8
INDEPENDENT SUB-ADVISORY AND THIRD-PARTY MANAGER SERVICES ________________________________ 8
FINANCIAL PLANNING & CONSULTING SERVICES ____________________________________________________ 9
RETIREMENT PLAN SERVICES ______________________________________________________________________ 10
ROLLOVER RECOMMENDATION DISCLOSURE _______________________________________________________ 10
SEMINARS & WORKSHOPS _________________________________________________________________________ 11
CLIENT OBJECTIVES & RESTRICTIONS ____________________________________________________ 11
WRAP FEE PROGRAM ___________________________________________________________________ 11
REGULATORY ASSETS UNDER MANAGEMENT _____________________________________________ 11
ITEM 5 - FEES AND COMPENSATION _________________________________________________________ 11
INVESTMENT MANAGEMENT FEE ________________________________________________________ 11
LEGACY MANAGEMENT FEE _______________________________________________________________________ 12
INDEPENDENT SUB-ADVISORY & THIRD-PARTY MANAGER SERVICE FEES ______________________________ 12
FINANCIAL PLANNING & CONSULTING FEE _________________________________________________________ 13
RETIREMENT PLAN SERVICE FEE ___________________________________________________________________ 13
SEMINARS & WORKSHOPS FEE _____________________________________________________________________ 13
ADMINISTRATIVE SERVICES PROVIDED BY ADVYZON TECHNOLOGIES _______________________ 14
ADDITIONAL FEES & EXPENSES __________________________________________________________ 14
ITEM 6 - PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT __________________________ 15
ITEM 7 - TYPES OF CLIENTS _________________________________________________________________ 15
ITEM 8 - METHODS OF ANALYSIS, STRATEGIES, & RISK OF LOSS ________________________________ 15
METHODS OF ANALYSIS _________________________________________________________________ 15
CYCLICAL ________________________________________________________________________________________ 15
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FUNDAMENTAL ___________________________________________________________________________________ 16
MUTUAL FUND OR ETF ____________________________________________________________________________ 16
TECHNICAL ______________________________________________________________________________________ 16
RISKS FOR ALL FORMS OF ANALYSIS _______________________________________________________________ 16
INVESTMENT STRATEGIES _______________________________________________________________ 16
LONG-TERM HOLDING ____________________________________________________________________________ 16
USE OF ALTERNATIVE INVESTMENTS _______________________________________________________________ 17
DESCRIPTION OF MATERIAL, SIGNIFICANT OR UNUSUAL RISKS _______________________________________ 17
RISK OF LOSS __________________________________________________________________________ 17
ACTIVE MANAGEMENT RISK _______________________________________________________________________ 17
ALLOCATION RISK ________________________________________________________________________________ 17
ALTERNATIVE RISK ________________________________________________________________________________ 18
CAPITALIZATION RISK _____________________________________________________________________________ 18
COMPANY RISK ___________________________________________________________________________________ 18
CONCENTRATION RISK ___________________________________________________________________________ 18
CREDIT RISK ______________________________________________________________________________________ 18
CYBERSECURITY RISK ______________________________________________________________________________ 18
EQUITY RISK ______________________________________________________________________________________ 19
FIXED INCOME & DEBT RISK _______________________________________________________________________ 19
INTEREST RATE RISK ______________________________________________________________________________ 19
ISSUER RISK ______________________________________________________________________________________ 19
LEGACY HOLDING RISK ___________________________________________________________________________ 19
LIQUIDITY RISK ___________________________________________________________________________________ 20
MANAGEMENT RISK ______________________________________________________________________________ 20
MARKET RISK _____________________________________________________________________________________ 20
MUNICIPAL BOND RISK ____________________________________________________________________________ 20
MUTUAL FUND OR ETF RISK _______________________________________________________________________ 20
NON-LIQUID ALTERNATIVE INVESTMENT RISK ______________________________________________________ 21
OPTIONS RISK ____________________________________________________________________________________ 21
ITEM 9 - DISCIPLINARY INFORMATION _______________________________________________________ 21
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS ____________________________ 22
INSURANCE COMPANIES ________________________________________________________________ 22
ACCOUNTING & TAX SERVICES __________________________________________________________ 22
ITEM 11 - CODE OF ETHICS, PARTICIPATION & INTEREST IN CLIENT TRANSACTIONS, & PERSONAL
TRADING __________________________________________________________________________________ 22
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PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING ______________________ 23
ITEM 12 - BROKERAGE PRACTICES ___________________________________________________________ 23
INVESTMENT MANAGEMENT SERVICES ___________________________________________________ 23
CHARLES SCHWAB & CO. INC. ___________________________________________________________ 23
HOW OUR FIRM SELECTS CUSTODIAN-BROKER _____________________________________________________ 23
CLIENT BROKERAGE & CUSTODY COSTS ___________________________________________________________ 24
PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB ________________________________________ 24
SERVICES THAT BENEFIT OUR CLIENTS _____________________________________________________________ 24
SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS __________________________________________ 25
SERVICES THAT GENERALLY BENEFIT ONLY US ______________________________________________________ 25
OUR INTEREST IN SCHWAB’S SERVICES _____________________________________________________________ 25
BROKERAGE FOR CLIENT REFERRALS _______________________________________________________________ 26
AGGREGATION & ALLOCATION OF TRANSACTIONS _________________________________________________ 26
TRADE ERRORS ___________________________________________________________________________________ 27
DIRECTED BROKERAGE ___________________________________________________________________________ 27
ITEM 13 - REVIEW OF ACCOUNTS ____________________________________________________________ 28
CLIENT REVIEWS ________________________________________________________________________ 28
ITEM 14 - CLIENT REFERRALS & OTHER COMPENSATION ______________________________________ 28
BROKERAGE PRACTICES ________________________________________________________________ 28
LEAD GENERATION & REFERRALS ________________________________________________________ 29
LEAD GENERATION _______________________________________________________________________________ 29
OTHER PROFESSIONALS ___________________________________________________________________________ 29
ITEM 15 - CUSTODY ________________________________________________________________________ 29
FEE DEDUCTION _______________________________________________________________________ 29
STANDING LETTERS OF AUTHORIZATION (“SLOA”) ________________________________________ 30
ITEM 16 - INVESTMENT DISCRETION _________________________________________________________ 30
DISCRETIONARY AUTHORITY ____________________________________________________________ 30
ITEM 17 - VOTING CLIENT SECURITIES _______________________________________________________ 30
PROXY VOTING _________________________________________________________________________ 30
CLASS ACTION LAWSUITS _______________________________________________________________ 31
ITEM 18 - FINANCIAL INFORMATION _________________________________________________________ 31
FINANCIAL CONDITION ________________________________________________________________ 31
ADDITIONAL INFORMATION ________________________________________________________________ 31
PRIVACY POLICY ________________________________________________________________________ 31
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BUSINESS CONTINUITY PLAN ____________________________________________________________ 31
CONTACTING US _______________________________________________________________________ 32
VARYING DISRUPTIONS _________________________________________________________________ 32
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ITEM 4 - ADVISORY BUSINESS
ABOUT OUR FIRM
Panoramic Investment Advisors, LLC d/b/a Forty North Wealth is currently registered with the Securities and
Exchange Commission ("SEC") as an investment adviser, with its principal place of business located in Colorado.
Forty North Wealth has been in business since 2017, and its principal owners are Dustin Dinges and Nicholas
Schneider. Our Firm was registered with the SEC as an investment adviser in 2017. Registration as an Investment
Adviser with the United States SEC or any state securities authority does not imply a certain level of skill or
training. Our Firm currently has one office located in Glendale, Colorado.
This brochure is designed to provide detailed and precise information about each item noted in the table of
contents. Certain disclosures are repeated in one or more items, and other disclosures are referred throughout
to be as comprehensive as possible on the broad subject matters discussed.
Within this brochure, specific terms in either are used as follows:
•
•
•
•
•
•
“Forty North” refers to Panoramic Investment Advisors, LLC d/b/a Forty North Wealth.
“Firm,” “we,” “us,” and “our” refer to Panoramic Investment Advisors, LLC d/b/a Forty North Wealth.
“Advisor,” “Investment Advisor Representative,” and “IAR” refers to our professional representatives
who provide investment recommendations or advice on behalf of Panoramic Investment Advisors, LLC
d/b/a Forty North Wealth.
“You,” “yours,” and “Client” refers to Clients of Panoramic Investment Advisors, LLC d/b/a Forty North
Wealth and its advisors.
“Code” refers to our Firm’s Code of Ethics.
“CCO” refers to our Chief Compliance Officer, Lindsay Rider.
ADVISORY SERVICES WE OFFER
Our Firm offers a variety of advisory services, which include discretionary investment management, financial
planning, consulting services and assets under advisement, third-party money manager, and retirement services.
Before rendering any preceding advisory services, Clients must enter into one or more written Investment
Advisory Agreements (“Agreements”), setting forth the relevant terms and conditions of the advisory
relationship.
We do not provide tax or legal advice. Clients should consult with an expert on tax or legal issues.
Our Firm manages portfolios for individuals, high-net-worth individuals and families, estates, trusts, retirement
plans, and charitable foundations. We provide investment management and advisory services to multi-
generational families using separately managed accounts under a custodial relationship with an independent
brokerage firm.
INVESTMENT ADVISORY SERVICES
With our discretionary relationship, we will change the portfolio as appropriate to help meet your financial
objectives. We trade Client portfolios based on our Firm’s market views and the Client’s financial goals.
We primarily invest in equities, over-the-counter equities, foreign issues, American Depositary Receipts,
corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company
securities, and US Government Securities. A portion of the account may be held in cash, cash equivalents, or
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money market funds as part of the overall investment strategy. Cash balances may have a higher concentration
and represent a sizable portion of your overall portfolio, depending on the current investment outlook or
strategy.
Clients may impose reasonable restrictions on investing in certain securities by notifying Forty North through
written notification.
Where deemed appropriate, we may recommend that our Clients invest in alternative assets, including private
equity funds, real estate funds, and other alternative funds. Although the Investment Advisory Agreement with
our Clients gives us broad investment authority, we do not anticipate investing in other security types. A Client’s
investment allocation and our strategy will depend on the Client's responses in review meetings, written
questionnaires, stated goals, risk tolerance, objectives, and personal preference for Impact Investing.
Clients are advised to promptly notify us if there are changes in their financial situation or if they wish to place
any limitations on managing their portfolios.
Our Firm typically requires a minimum account size of $50,000 for advisory accounts. However, sometimes, at
our sole discretion, we may accept smaller accounts based on various criteria, such as anticipated future assets,
related accounts, and other individual Client circumstances.
LEGACY MANAGEMENT SERVICES
Our Firm may advise a Client about legacy positions or other investments in Client portfolios. Clients can
limit or restrict our trading and/ or billing in these positions.
INDEPENDENT SUB-ADVISORY AND THIRD-PARTY MANAGER SERVICES
If deemed appropriate, our Firm will utilize the services of a Sub-Advisor (“SMA” or “Manager”) or Independent
Third-Party Manager (“ITPM” or “Manager”) to manage your accounts. Investment recommendations and
securities trading will only be offered by or through the chosen SMA or ITPM. Our Firm will not advise on any
specific securities concerning this service.
Before referring you, our Firm will provide initial due diligence on SMA and ITPMs and ongoing reviews of their
management of your accounts. To assist in selecting an SMA or ITPM, our Firm will gather information about the
Client’s financial situation, investment objectives, and reasonable restrictions to be imposed upon the account
management.
Our Firm will periodically review the Manager reports provided to the Client. We will periodically contact the
Client to review their financial situation and objectives, communicate information to the Manager as warranted,
and assist you in understanding and evaluating the services provided. The Client will be expected to notify our
Firm of any changes in their financial situation, investment objectives, or account restrictions that could affect
their financial standing.
By executing an Investment Advisory Agreement with our Firm, the Client gives our Firm the discretionary
authority to hire or fire the Manager and to allocate assets among Managers without obtaining consent.
The services provided by the SMA and ITPM include:
Implementation of an asset allocation
• Assessment of your investment needs and objectives
•
• Delivery of suitable style allocations (e.g., Income, Large Cap, Small Cap, Growth, Value, etc.)
• Facilitation of portfolio transactions
• Ongoing monitoring of investment vehicles’ performance
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• Review of accounts for adherence to policy guidelines and asset allocation
• Reporting of your portfolio activity.
Each Manager has minimum account requirements that will vary between Managers. Account minimums are
typically higher for fixed-income accounts than for equity-based accounts. A complete description of the
Manager’s services, fee schedules, and account minimums will be disclosed in the Manager’s disclosure
brochure, which will be provided to you before or when an agreement for services is executed, and the account
is established.
FINANCIAL PLANNING & CONSULTING SERVICES
Our Firm offers financial planning and consulting services. Financial planning services involve preparing a written
financial plan covering specific or multiple topics. We provide full written financial plans, which may address one
or several topics: Investment Planning, Retirement Planning, Insurance Planning, Tax Planning, Education
Planning, Portfolios, and Allocation Review.
Our investment consulting services are designed to meet our Client’s financial goals, needs, and objectives
involving analysis of a Client’s investments, such as variable life insurance and annuity contracts and assets held
in employer-sponsored retirement plans, and qualified tuition plans (i.e., 529 plans) held externally from our
Firm. In these situations, our Firm may direct or recommend allocating assets among the various investment
options available within the product.
Unless otherwise agreed to in writing, the Client is solely responsible for determining whether to implement our
financial planning and/or consulting recommendations. Our financial planning and consulting services do not
involve implementing transactions on your behalf nor include active and ongoing monitoring or management of
your investments or accounts.
The Client must execute a separate written agreement if the Client elects to implement any of our investment
recommendations through our Firm or retain our Firm to monitor and manage investments actively.
MONEYGUIDE PRO ADVISOR PLATFORM
Our Firm makes available to Clients the “MoneyGuide Pro” platforms to provide periodic comprehensive
reporting services that can incorporate all the Client’s investment assets, including those investment assets
that are not part of the assets managed by our Firm (“Excluded Assets”). The Client and their other advisors
that maintain trading authority, and not our Firm, shall be exclusively responsible for the investment
performance of the excluded assets.
Unless otherwise expressly agreed to in writing, our Firm’s service relative to the excluded assets is limited
to reporting only. Therefore, we shall not be responsible for the investment performance of the excluded
assets. Instead, the Client and the Client’s designated outside investment professional(s) maintain
supervision, monitoring, and trading authority for the excluded assets. If our Client prefers, we will make
recommendations as to any excluded assets. The Client has no obligation to accept the recommendation,
and we shall not be responsible for any implementation error (timing, trading, etc.) relative to the excluded
assets. The Client may engage us under the terms and conditions of a Consulting or Investment Advisory
Agreement between our Firm and the Client.
MoneyGuide Pro Platform may also provide access to other types of information, including financial
planning concepts, which should not be construed as our Firm’s personalized investment advice or
recommendations. Without our assistance or oversight, we shall not be held responsible for any adverse
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results a Client may experience if the Client engages in financial planning or other functions available on
the MoneyGuide Pro Platform.
RETIREMENT PLAN SERVICES
When providing any non-discretionary investment advisory services, we will solely be making investment
recommendations to the Sponsor, and the Sponsor retains full discretionary authority or control over assets of
the retirement plan. We agree to perform any non-discretionary investment advisory services to the retirement
plan as a fiduciary, as defined in ERISA Section 3(21)(A)(ii). We will act in good faith and with the degree of
diligence, care, and skill that a prudent person rendering similar services would exercise under similar
circumstances.
When providing administrative services, we may support the Sponsor with plan governance and committee
education; vendor management and service provider selection and review; investment education; or plan
participant non-fiduciary education services. We agree to perform any administrative services solely in a capacity
that would not be considered a fiduciary under ERISA or any other applicable law.
When offering investment models to plan sponsors, under certain circumstances, we will act as a “fiduciary” as
defined under Section 3(21) of ERISA and Section 4975I (3) of the Internal Revenue Code of 1986, as amended
(the “Code”).
ROLLOVER RECOMMENDATION DISCLOSURE
Our Firm is considered a fiduciary under the Investment Advisers Act of 1940. When we provide
investment advice to you regarding your retirement plan account or individual retirement account, we
are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and
the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We must act
in your best interest and not put our interests ahead of yours. At the same time, how we make money
conflicts with Client interests.
A Client leaving an employer typically has four options regarding an existing retirement plan (and may
engage in a combination of these options):
•
•
•
•
leave the money in the former employer’s plan, if permitted,
roll over the assets to the new employer’s plan, if one is available and rollovers are permitted,
rollover to an Individual Retirement Account (“IRA”), or
cash out the account value (which depending upon the Client’s age, could result in adverse
tax consequences).
Our Firm may recommend a Client rollover plan assets to an IRA for which our Firm provides investment
advisory services. As a result, our Firm and its advisors may earn an asset-based fee on the rolled
assets. In contrast, a recommendation that a Client leave their plan assets with their previous employer
or rollover the assets to a plan sponsored by a new employer will result in no compensation to our Firm.
Therefore, our Firm has an economic incentive to encourage a Client to roll plan assets into an IRA that
our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are
numerous factors that our Firm will consider before recommending a rollover, including but not limited
to:
•
•
the investment options available in the plan versus the investment options available in an IRA,
fees and expenses in the plan versus the fees and expenses in an IRA,
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•
the services and responsiveness of the plan’s investment professionals versus those of our
Firm,
required minimum distributions and age considerations, and
• protection of assets from creditors and legal judgments,
•
• employer stock tax consequences, if any.
The Chief Compliance Officer remains available to address client questions regarding the supervision
and oversight of rollover and transfer assets.
SEMINARS & WORKSHOPS
Our Firm occasionally provides financial, retirement, estate, and college planning seminars. Seminars are always
offered on an impersonal basis and do not focus on the individual needs of participants.
CLIENT OBJECTIVES & RESTRICTIONS
Our Firm tailors our investment management and advisory services continuously to meet the needs of our
Clients. We seek to ensure Client portfolios are managed consistently with those needs and objectives in mind.
We meet with Clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity
constraints, and other related factors relevant to managing their portfolios. Clients may impose reasonable
restrictions on managing the accounts if the conditions do not impact the performance of a management
strategy.
WRAP FEE PROGRAM
Our Firm does not sponsor or participate in a Wrap Program.
REGULATORY ASSETS UNDER MANAGEMENT
As of December 31, 2025, our Firm had 350,608,741 in regulatory assets under management, approximately
$319,661,980 of which was managed on a discretionary basis and $30,946,761 on a non-discretionary basis.
ITEM 5 - FEES AND COMPENSATION
In addition to the information provided in Item 4 – Advisory Business, this section details our Firm’s services and
each service’s fees and compensation arrangement. The Client and Forty North Wealth’s Investment Advisory
Agreement will outline and agree upon the exact costs and other terms related to the Client’s Accounts.
INVESTMENT MANAGEMENT FEE
Our Firm offers investment management services for an annual fee based on the amount of assets under
management. Our maximum annual fee is 1.75%, and we have a minimum account size of $50,000. We retain
the right to waive the minimum account size at our discretion.
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Our annual fee is reasonable in relation to (1) the services provided and (2) the fees charged by other investment
advisers offering similar services/programs.
Our annual fee is prorated and charged quarterly in advance based on the value of the Client’s assets under
management as of the close of business on the last business day of the previous quarter. Cash and cash
equivalents, including money market funds, are subject to the agreed-upon advisory fee. Clients should
understand that the advisory fees charged on these balances may exceed the returns provided by cash, cash
equivalents, or money market funds, especially in low-interest rate environments.
Our Firm retains complete discretion to negotiate fees and may waive or impose different fees on any Client.
The investment advisory fees will be deducted from your account and paid directly to our Firm by the qualified
Custodian(s) of your account. The Client will authorize your account's qualified Custodian(s) to deduct fees from
the account and pay such fees directly to our Firm. All account assets, transactions, and advisory fees will be
shown on the monthly or quarterly statements provided by the Custodian. You should review your account
statements received from the qualified Custodian(s) and verify that appropriate investment advisory fees are
being deducted. The qualified Custodian(s) will not verify the accuracy of the investment advisory fees deducted.
We may aggregate related Client accounts to calculate the advisory fee applicable to the Client. The investment
management agreement will outline the fee charged to a Client and any breakpoints based on the level of assets
managed. The fees are subject to change with prior written notice to the Client.
Our annual investment advisory fee may be higher than that of other investment advisers that offer similar
services and programs. In addition to our compensation, you may incur charges imposed at the mutual fund
level (e.g., advisory fees and other fund expenses).
Accounts initiated or terminated during a calendar quarter will be charged a prorated fee based on the days the
Client account was open during that quarter. Any prepaid, unearned fees will be refunded upon termination of
any account.
LEGACY MANAGEMENT FEE
Managed legacy positions are included within our Firm’s standard investment management fee and are
outlined in the executed investment management agreement.
INDEPENDENT SUB-ADVISORY & THIRD-PARTY MANAGER SERVICE FEES
A complete description of the SMA and ITPM’s services, fee schedules, and account minimums will be disclosed
in Manager's disclosure brochure, which will be provided to you before or when an agreement for services is
executed, and the account is established. Each third-party investment adviser is required under federal securities
laws to provide their clients, including SMA and ITPM Clients, with a Form ADV Part 2A (“Adviser Brochure” or
“this Brochure”) that includes disclosures, and among other things, the fees charged to their clients.
The actual fee charged to the Client will vary depending on SMA or ITPM. All fees are calculated and collected
by the Manager, who will be responsible for delivering our Firm’s portion of the fee paid by the Client. With
SMA and ITPMs, you may incur additional charges, including mutual fund sales loads, 12b-1 fees and surrender
charges, and IRA and qualified retirement plan fees.
There is a potential conflict of interest in using independent Managers if they pay us a portion of their advisory
fee and have met the conditions of our Firm’s due diligence review. Our Firm is committed to always working in
the Client's best interest. There may be other Managers not affiliated with our Firm that may be suitable for a
Client or may be more or less costly. As with any Advisor, no guarantees can be made that the SMA or ITPM will
achieve your financial goals or objectives. Further, no guarantees of performance can be offered.
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Clients should review the SMA or ITPM’s Brochure in its entirety, along with this Brochure, to fully understand
the services, fees, agreements, and risks surrounding these arrangements and fully understand that these types
of arrangements have layers of fees that may or may not be apparent without reading the SMA or ITPM’s
Brochure and this Brochure, along with the offering document/prospectus for underlining investments.
FINANCIAL PLANNING & CONSULTING FEE
Our Firm provides financial planning services under a fixed fee arrangement. This arrangement charges a
mutually agreed-upon fee for financial planning services, not to exceed $15,000 depending on the scope and
complexity of each Client’s individual circumstances. At the discretion of the firm, financial planning and
consulting services may be included in the investment management fee.
Fees charged for our financial planning and/or consulting services are negotiable based upon the type of Client,
the services requested, the investment adviser representative providing advice, the complexity of the Client's
situation, the composition of the Client's account, other advisory services provided, and the relationship of the
Client and the investment adviser representative.
The amount of the fee for your engagement is specified in your financial planning agreement with us. At our
sole discretion, the Client may be required to pay the fee at the time the agreement is executed with our Firm;
however, our Firm does not require or solicit prepayment of more than $1,200 in fees per Client, six months or
more in advance. The fee is considered earned upon delivery of the financial plan, and any unpaid amount is
immediately due.
The Client may pay the fees owed for the financial planning and/or consulting services by submitting payment
directly via Advisor Pay, Check, or by deducting the fee from an existing investment account. If the Client elects
to pay by automatic deduction from an existing investment account, they will provide written authorization to
our Firm for such a charge.
If the Client terminates the financial planning services after entering into an agreement with our Firm, the Client
will be invoiced and responsible for immediate payment of any hourly financial planning services performed by
us before receiving notice of termination. For financial planning services, our Firm performs under a fixed fee
arrangement, the Client will be responsible for paying a pro-rated fixed fee equivalent to the percentage of work
that our Firm completed. If there is a remaining balance of any fees paid in advance after deducting fees from
the final invoice, those remaining proceeds will be refunded to the Client.
RETIREMENT PLAN SERVICE FEE
For Retirement Plan Advisory Services compensation, we charge an advisory fee as negotiated with the Plan
Sponsor and as disclosed in the Employer-Sponsored Retirement Plans Consulting Agreement (“Plan Sponsor
Agreement”).
Typically, the billing period for these fees is paid quarterly. This fee is negotiable, but the terms and the advisory
fee are agreed upon in advance and acknowledged by the Plan Sponsor Agreement or Plan Provider’s account
agreement. Fee billing methods vary depending on the Plan Provider.
Our Firm or the Plan Sponsor may terminate the Agreement upon 30 days written notice to the other party. The
Plan Sponsor is responsible for paying for the services rendered until the termination of the Agreement.
SEMINARS & WORKSHOPS FEE
Seminars and workshops offered by our Firm are complementary for clients and prospects.
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ADMINISTRATIVE SERVICES PROVIDED BY ADVYZON TECHNOLOGIES
Our Firm has contracted with Advyzon Technologies to utilize its technology platforms to support data
reconciliation, performance reporting, fee calculation, client relationship maintenance, quarterly performance
evaluations, and other functions related to managing Client accounts' administrative tasks. Due to this
arrangement, Advyzon will have access to client accounts, but Advyzon will not serve as an investment advisor
to our clients or bill the accounts. Advyzon charges our firm an annual fee for each account administered by its
software. Please note that our Firm’s annual fee to Advyzon will not increase the Client's fee. Our firm will pay
the annual fee from the portion of the management fee retained by Our Firm. Our Firm and Advyzon are non-
affiliated companies.
ADDITIONAL FEES & EXPENSES
In addition to the advisory fees paid to our Firm, Clients also incur certain charges imposed by other third parties,
such as broker-dealers, Custodians, trust companies, banks, and other financial institutions. These additional
charges include securities, transaction fees, custodial fees, fees charged by the SMA, ITPM, and Manager
charges imposed by a mutual fund or ETF (Exchange Traded Funds) in a Client’s account, as disclosed in the
fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions. Our brokerage practices are described at length in Item 12 below. Neither
our Firm nor its supervised persons accept commission compensation for selling securities or other investment
products. Further, we do not share any additional fees and expenses outlined above.
Our Firm’s investment strategies may include mutual and exchange-traded funds (“ETFs”). Our policy is to
purchase institutional share classes of those mutual funds selected for the Client’s portfolio. The institutional
share class generally has the lowest expense ratio. The expense ratio is the annual fee that all mutual funds or
ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal year for funds
expenses, including 12b-1 fees, management fees, administrative fees, operating costs, and all other asset-
based costs incurred by the fund. Some fund families offer different classes of the same fund, and one share
class may have a lower expense ratio than another. Mutual fund expense ratios are in addition to our fees; we
do not receive any portion of these charges. If an institutional share class is not available for the mutual fund
selected, the adviser will purchase the least expensive share class available for the mutual fund. As share classes
with lower expense ratios become available, we may use them in the Client’s portfolio or convert the existing
mutual fund position to the lower-cost share class. Clients who transfer mutual funds into their accounts with our
Firm would bear the expense of any contingent or deferred sales loads incurred upon selling the product. If a
mutual fund has a frequent trading policy, the policy can limit a Client’s transactions in fund shares (e.g., for
rebalancing, liquidations, deposits, or tax harvesting). All mutual fund expenses and fees are disclosed in the
respective mutual fund prospectus.
When selecting investments for our Clients’ portfolios, we might choose mutual funds on your account
Custodian’s Non-Transaction Fee (NTF) list. This means that your account Custodian will not charge a transaction
fee or commission associated with the purchase or sale of the mutual fund.
The mutual fund companies that choose to participate in the Client’s Custodial NTF fund program pay a fee to
the Custodian to be included in the NTF program. The mutual fund owners bear the fee that a company pays to
participate in the program, as captured in the fund’s expense ratio. When choosing a fund from the Client’s
Custodial NTF list, our Firm considers the expected holding period, position size, and expense ratio versus
alternative funds. Depending on our Firm’s analysis and future events, NTF funds might not always be in the
Client’s best interest.
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ITEM 6 - PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT
Performance-based fees are based on a share of capital gains on or appreciation of the assets in a Client’s
account.
Our Firm does not accept performance-based or other fees based on a share of capital gains or appreciation of
a Client's assets.
ITEM 7 - TYPES OF CLIENTS
Our Firm provides investment management, investment advice, financial planning, consulting and advisement,
and third-party portfolio management to individuals, high-net-worth individuals, families, estates, trusts,
partnerships, retirement plans, corporations, charitable foundations, investment companies, broker-dealer
clients, and pension plans.
Our firm requires a minimum account value of $50,000 for advisory services. Clients have the option to aggregate
all household accounts to meet this minimum. Exceptions to the minimum account requirement may be granted
based on the Client's relationship with their representative.
For fee calculation purposes, unless instructed otherwise, we will automatically aggregate related client
accounts, a practice commonly known as "householding" portfolios. Householding may result in lower fees than
if each account were billed separately, as the combined value is used to determine the account size and the
corresponding annualized fee.
Our approach to householding considers the overall family dynamic and relationship. Additionally, if applicable,
and as noted in Appendix B of the Investment Management Agreement, legacy positions may be excluded from
the fee calculation.
Clients must execute a written agreement with our Firm specifying the advisory services to establish a Client
arrangement with us.
ITEM 8 - METHODS OF ANALYSIS, STRATEGIES, & RISK OF LOSS
METHODS OF ANALYSIS
Our Investment Advisory Representatives will generally use the following analysis methods to formulate our
investment advice and manage Client assets. However, each IAR can manage its Client’s account as necessary,
and their specific analysis method may vary from below. Clients should acknowledge that investing in securities
involves the risk of loss, regardless of the strategies, that Clients should be prepared to bear.
CYCLICAL
In this type of technical analysis, we measure the movements of a particular stock against the overall market to
predict the security price movement.
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FUNDAMENTAL
Fundamental analysis attempts to identify stocks offering sturdy growth potential at a competitive price by
examining the underlying company's business and conditions within its industry or the broader economy.
Investors have traditionally used fundamental analysis for longer-term trades, relying on metrics such as earnings
per share, price-to-earnings ratio, price-to-earnings growth, and dividend yield.
MUTUAL FUND OR ETF
Our Firm examines the experience and track record of the Manager of the mutual fund or ETF to determine if
that Manager has demonstrated an ability to invest over a period of time and in different economic conditions.
Our Firm also looks at the underlying assets in a mutual fund or ETF to determine if there is a significant overlap
in the underlying investments held in other funds in the Client’s portfolio. Our Firm also monitors the funds or
ETFs to determine if they continue to follow their stated investment strategy.
TECHNICAL
Technical analysis is a form of security analysis that uses price and volume data, typically displayed graphically
in charts. The charts are analyzed using various indicators to make investment recommendations. Technical
analysis has three main principles and assumptions: (1) The market discounts everything, (2) prices move in trends
and countertrends, and (3) price action is repetitive, with specific patterns reoccurring.
RISKS FOR ALL FORMS OF ANALYSIS
Our Firm’s securities analysis method relies on the assumption that the companies whose securities we purchase
and sell, the rating agencies that review these securities, and other publicly available sources of information
about these securities, are providing accurate and unbiased data. While we are alert to indications that data
may be incorrect, there is always a risk that the analysis may be compromised by inaccurate or misleading
information.
INVESTMENT STRATEGIES
Our Firm may use any of the following investment strategies when managing Client assets and providing
investment advice:
LONG-TERM HOLDING
Our Firm purchases securities with the intent to hold them in the Client's account long-term (longer than one
year). In extreme circumstances, we may be forced to sell a fund completely within a year of buying it. An
example would be a fund Manager resigns, and we do not have confidence in the new management. Also, fund
positions may be trimmed occasionally to rebalance the portfolio.
A risk in a long-term purchase strategy is that holding the security for this length of time may decline in value
before we decide to sell. We do not guarantee the future performance of the account or any specific level of
performance, the success of any investment decision or strategy we may use, or the success of the overall
management of the account. The Client understands that the investment decisions our Firm makes for the
Client’s account are subject to various market, currency, economic, political, and business risks and that those
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investment decisions will not always be profitable. Clients are reminded that investing in any security entails the
risk of loss, which they should be willing to bear.
USE OF ALTERNATIVE INVESTMENTS
If deemed appropriate for your portfolio, our Firm may recommend "alternative investments.” Alternative
investments may include a broad range of underlying assets including hedge funds, private equity, venture
capital, registered, publicly traded securities, structured notes, and private real estate investment trusts.
Alternative investments are speculative, not suitable for all Clients, and intended for only experienced and
sophisticated investors who are willing to bear the high risk 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 fund and none expected to develop; volatility
of returns; potential for restrictions on transferring an interest in the fund; potential lack of diversification and
resulting higher risk due to concentration of trading authority with a single adviser; absence of information
regarding valuations and pricing; potential for delays in tax reporting; less regulation and often higher fees than
other investment options such as mutual funds. The SEC requires investors to be accredited to invest in these
more speculative alternative investments. Investing in a fund concentrating on a few holdings may involve
heightened risk and greater price volatility.
DESCRIPTION OF MATERIAL, SIGNIFICANT OR UNUSUAL RISKS
Our Firm generally invests client cash balances in money market funds, FDIC Insured Certificates of Deposit,
high-grade commercial paper and/or government backed debt instruments. Ultimately, our Firm tries to achieve
the highest return on client cash balances through relatively low-risk conservative investments. In most cases, at
least a partial cash balance will be maintained in a money market account so that our Firm may debit advisory
fees for our services related to our Asset Management and Comprehensive Portfolio Management services, as
applicable.
RISK OF LOSS
A Client’s investment portfolio is affected by general economic and market conditions, such as interest rates,
availability of credit, inflation rates, economic conditions, changes in laws, and national and international political
circumstances.
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Our Firm will assist Clients in determining an appropriate
strategy based on their tolerance for risk.
While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be
compromised by inaccurate or misleading information.
ACTIVE MANAGEMENT RISK
Due to its active management, a portfolio could underperform other portfolios with similar investment objectives
or strategies.
ALLOCATION RISK
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A portfolio may use an asset allocation strategy to pursue its investment objective. There is a risk that a portfolio’s
allocation among asset classes or investments will cause a portfolio to lose value or cause it to underperform
other portfolios with a similar investment objective or strategy or that the investments themselves will not
produce the returns expected.
ALTERNATIVE RISK
Alternative investments include other additional risks. Lock-up periods and other terms obligate Clients to
commit their capital investment for a minimum period, typically no less than one or two years and sometimes up
to 10 or more years. Illiquidity is considered a substantial risk and will restrict the ability of a Client to liquidate
an investment early, regardless of the success of the investment. Alternative investments are difficult to value
within a Client’s total portfolio. There may be limited availability of suitable benchmarks for performance
comparison; historical performance data may also be limited.
In some cases, there may be a lack of transparency and regulation, providing an additional layer of risk. Some
alternative investments may involve the use of leverage and other speculative techniques. As a result, some
alternative investments may carry substantial additional risks, resulting in the loss of some or all the investment.
Using leverage and certain other strategies will result in adverse tax consequences for tax-exempt investors,
such as the possibility of unrelated business taxable income, as defined under the U.S. Internal Revenue Code.
CAPITALIZATION RISK
Small-cap and mid-cap companies may be hindered due to limited resources or less diverse products or services.
Their stocks have historically been more volatile than the stocks of larger, more established companies.
COMPANY RISK
The risk related to a Firm’s business plans, stock valuation, profitability, accounting practices, growth strategy,
and other factors particular to a company rather than the overall market. Some of these risks cannot be predicted,
such as the retirement or death of a senior executive, which may lead to negative performance in the future.
CONCENTRATION RISK
Strategies concentrated in only a few securities, sectors or industries, regions or countries, or asset classes could
expose a portfolio to greater risk. They may cause the portfolio value to fluctuate more widely than a diversified
portfolio. Overexposure to certain sectors or asset classes (e.g., MLPs, REITs, etc.) may be detrimental to an
investor if there is a negative sector move.
CREDIT RISK
The credit rating of an issuer of a security is based on, among other things, the issuer’s historical financial
condition and the rating agencies’ investment analyses at the time of rating. An actual or perceived deterioration
of the ability of an issuer to meet its obligations would harm the value of the issuer’s securities.
CYBERSECURITY RISK
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Increased Internet use makes a portfolio susceptible to operational and informational security risks. In general,
cyber incidents can result from deliberate attacks or unintentional events. Cyberattacks include but are not
limited to infection by computer viruses or other malicious software code, gaining unauthorized access to
systems, networks, or devices through “hacking” or other means to misappropriate assets or sensitive
information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches of third-party
service providers may cause disruptions at third-party service providers and impact our business operations,
potentially resulting in financial losses; the inability to transact business; violations of applicable privacy and
other laws, regulatory fines, or penalties; reputational damage; unanticipated expenses or other compensation
costs; or additional compliance costs. Our Firm has an established business continuity and disaster recovery plan
and related cybersecurity procedures designed to prevent or reduce the impact of such risks; there are inherent
limitations in such plans and systems due in part to the evolving nature of technology and cyberattack tactics.
EQUITY RISK
Equity instruments are subject to equity market risk, the risk that common stock prices fluctuate over short or
extended periods. Equity securities have greater price volatility than fixed-income securities. The market price
of equity securities may increase or decrease, sometimes rapidly or unpredictably. Equity securities may decline
in value due to factors affecting markets, industries, sectors or geographic regions represented in those markets,
or individual security concerns.
FIXED INCOME & DEBT RISK
Debt securities are affected by changes in interest rates. When interest rates rise, the value of debt securities is
likely to decrease. Conversely, when interest rates fall, the values of debt securities are likely to increase. The
values of debt securities may also be affected by changes in the issuing entities' credit rating or financial
condition.
INTEREST RATE RISK
When interest rates increase, the value of the account’s investments may decline, and the account’s share value
may decrease. This effect is typically more pronounced for intermediate and longer-term obligations. This effect
is also typically more pronounced for mortgages and other asset-backed securities since the value may fluctuate
more significantly in response to interest rate changes. When interest rates decrease, the account’s current
income may decline.
ISSUER RISK
The risk is that an issuer of a security may perform poorly, and therefore, the value of its securities may decline.
Poor management decisions, competitive pressures, technological breakthroughs, reliance on suppliers, labor
problems or shortages, corporate restructurings, fraudulent disclosures, natural disasters, or other events,
conditions, or factors may cause inferior performance.
LEGACY HOLDING RISK
Investment advice may be offered on any investment a Client holds at the start of the advisory relationship.
Depending on tax considerations and Client sentiment, these investments will be sold over time, and the assets
invested in the appropriate strategy. As with any investment decision, there is the risk that timing with respect
to the sale and reinvestment of these assets will be less than ideal or even result in a loss to the Client.
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LIQUIDITY RISK
Low trading volume, large positions, or legal restrictions are some conditions that could limit or prevent a
portfolio from selling securities or closing positions at desirable prices. Securities that are relatively liquid when
acquired could become illiquid over time. The sale of any such illiquid investment might be possible only at
substantial discounts or might not be possible at all. Further, such investments may take more work to value.
MANAGEMENT RISK
An account is subject to the risk that judgments about the attractiveness, value, or potential appreciation of the
account’s investments may prove to be incorrect. If the selection of securities or strategies fails to produce the
intended results, the account could underperform other accounts with similar objectives and investment
strategies.
MARKET RISK
Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events
will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is
the risk that you will lose money, and your investment may be worth less upon liquidation. Due to a lack of
demand in the marketplace or other factors, an account may only be able to sell some or all the investments
promptly or may only be able to sell assets at desired prices.
MUNICIPAL BOND RISK
Investments in municipal bonds are affected by the municipal market and the factors in the cities, states, or
regions where the strategy invests. Issues such as legislative changes, litigation, business and political conditions
relating to a particular municipal project, municipality, state, or territory, and fiscal challenges can impact the
value of municipal bonds. These matters can also impact the ability of the issuer to make payments. Also, the
public information about municipal bonds is less than that for corporate equities or bonds. Additionally, supply
and demand imbalances in the municipal bond market can cause deterioration in liquidity and a lack of price
transparency.
MUTUAL FUND OR ETF RISK
Our models and accounts may use certain ETFs and mutual funds to invest primarily in alternative investments
or strategies. Investing in these alternative investments and strategies may only be suitable for some of our
Clients. These include special risks, such as those associated with commodities, real estate, and leverage, selling
securities short, use of derivatives, potential adverse market forces, regulatory changes, and potential ill-liquidity.
Special risks are associated with ETFs that invest principally in real estate securities, such as sensitivity to changes
in real estate values or changes in interest rates and price volatility due to the ETF’s concentration in the real
estate market.
The risks with mutual funds include the costs and expenses within the fund that can impact performance, change
of Managers, and the fund straying from its objective (i.e., style drift). Mutual funds have certain costs associated
with underlying transactions and operating costs, such as marketing and distribution expenses and advisory fees.
Mutual fund costs and expenses vary from fund to fund and will impact a mutual fund’s performance.
Additionally, mutual funds typically have different share classes, as further discussed below, that trade at different
Net Asset Values (“NAV”) as determined at the daily market close and have different fees and expenses.
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NON-LIQUID ALTERNATIVE INVESTMENT RISK
From time to time, our Firm will recommend to certain qualifying Clients that a portion of such Clients’ assets
be invested in private funds, private fund-of-funds, or other alternative investments (collectively, “Non-liquid
Alternative Investments”). Non-liquid Alternative Investments are not suitable for all our Firm’s Clients. They are
offered only to those qualifying Clients for whom our Firm believes such an investment is suitable and in line
with their overall investment strategy. Non-liquid Alternative Investments typically are available to only a limited
number of sophisticated investors who meet the definition of “accredited investor” under Regulation D of the
Securities Act of 1933, as amended (the “Securities Act”), or “qualified Client” under the Investment Advisers
Act of 1940 or “qualified purchaser” under the Investment Company Act of 1940. Non-liquid Alternative
Investments present special risks for our Firm’s Clients, including, without limitation, limited liquidity, higher fees
and expenses, volatile performance, no assurance of investment returns, heightened risk of loss, limited
transparency, additional reliance on underlying management of the investment, special tax considerations,
subjective valuations, use of leverage and limited regulatory oversight. When a Non-liquid Alternative
Investment invests part or all of its assets in real estate properties, there are additional risks that are unique to
real estate investing, including but not limited to: limitations of the appraisal value, the borrower’s financial
conditions (if a loan has obtained the underlying property), including the risk of foreclosures on the property;
neighborhood values; the supply of and demand for properties of like kind; and certain city, state or federal
regulations.
Additionally, real estate investing is also subject to possible loss due to uninsured losses from natural and artificial
disasters. The above list is not exhaustive of all risks related to an investment in Non-liquid Alternative
Investments. A more comprehensive discussion of the risks associated with a particular Non-liquid Investment is
set forth in that fund’s offering documents, which will be provided to each Client subscribing to a Non-liquid
Alternative Investment for review and consideration. It is important that each potential, qualified investor
carefully read each offering or private placement memorandum before investing.
OPTIONS RISK
Transactions in options carry a high degree of risk. A small market movement will have a proportionately larger
impact, which may work for or against the investor. The placing of certain orders, which are intended to limit
losses to certain amounts, may not be effective because market conditions may make it impossible to execute
such orders. Selling ("writing" or "granting") an option entails greater risk than purchasing options. Although
the premium received by the seller is fixed, the seller may sustain a loss well more than that amount. The seller
will also be exposed to the risk of the purchaser exercising the option and will be obliged to settle it in cash or
to acquire or deliver the underlying investment. The risk may be reduced if the option is "covered" by the seller
holding a corresponding position in the underlying investment or a future on another option.
ITEM 9 - DISCIPLINARY INFORMATION
Registered investment advisers are required to provide information about all disciplinary information that would
be material to a Client’s evaluation of our Firm or the integrity of its management. Clients should refer to the
Advisor’s Form ADV Part 2B Brochure Supplement. If the Client did not receive the Advisor’s Form ADV Part 2B
Brochure Supplement, the Client should contact the Chief Compliance Officer using the information provided
on the cover page of this Brochure. Our Chief Compliance Officer is available to address any questions a Client
or prospective client may have regarding the above or any information outlined in this Brochure.
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Our Firm has no legal or disciplinary events that are material to a Client or prospective clients, evaluation of our
advisory business, or the integrity of our management services.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS
Clients should review our IARs Form ADV Part 2B Brochure Supplement to determine whether the Client’s IAR
is engaged in any of the activities described below that may create a conflict of interest. If the Client did not
receive the Advisor’s Form ADV Part 2B Brochure Supplement, the Client should contact the Firm’s Chief
Compliance Officer using the information on the cover page of this Brochure. The Chief Compliance Officer is
available to address any questions a Client or prospective client may have regarding any of the below conflicts
of interest, or any other information outlined in this Brochure.
INSURANCE COMPANIES
In their individual capacities, some of our Firm’s IARs are agents for various third-party insurance companies. As
such, these individuals may receive separate yet customary commission compensation for implementing product
transactions on our advisory Clients' behalf. Clients, however, are not obligated to engage IARs when
considering implementing advisory or insurance recommendations. Implementing any or all recommendations
is solely at the Client's discretion.
ACCOUNTING & TAX SERVICES
Our Firm has entered into an agreement with Tanner and Company. Tanner and Company provide our Firm and
Clients with tax, accounting, and consulting services. In addition, we have entered into an agreement with Tanner
and Company that allows our IARs to offer our Clients tax preparation services performed by Tanner and
Company. In some instances, our Firm will include a tax preparation services fee in its investment advisory
services fee and pays Tanner and Company directly for the tax preparation services performed for the Client.
This is a service of convenience, and neither our Firm nor its IARs receive any economic benefit from Tanner and
Company.
ITEM 11 - CODE OF ETHICS, PARTICIPATION & INTEREST IN CLIENT
TRANSACTIONS, & PERSONAL TRADING
Our Firm maintains a Code of Ethics to reinforce the fiduciary principles governing our Firm and its employees.
The Code, among other things, requires all employees to act with integrity and ethics, and professionalism.
Policies against overreaching, self-dealing, insider trading, and conflicts of interest are outlined in our Code. Our
Code forbids employees from trading, either personally or on behalf of others, based on non-public material
information or communicating non-public material information to others violating the law.
Additionally, our Code sets forth restrictions and quarterly attestations on receiving gifts, outside business
activities, personal trading activity, maintenance of personal brokerage accounts, and other matters. The Code
is appropriately designed and implemented to prevent or eliminate potential conflicts of interest between our
Firm, our employees and IARs, Clients, and investors. We always strive to make decisions in our Client's best
interest should a conflict of interest arise.
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Clients should be aware that no set of rules, policies, or procedures can anticipate, avoid, or address all potential
conflicts of interest.
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING
Our employees, IARs, and our associated persons are not prohibited from owning or trading securities bought,
sold, and recommended to our Clients, provided such personal trading activity complies with the parameters,
limitations, and requirements of the Code. Employees, IARs, and associated persons must receive approval from
our Firm’s CCO when engaging in reportable securities transactions. Our CCO is responsible for reviewing all
employees', IARs, and associated persons' trading when they occur and periodically reviewing trading activity.
Our CCO has broad discretion to reject employee trading for any reason. Our Firm’s policies and procedures
related to the personal trading activity of employees aim to demonstrate our commitment to placing Clients’
interests ahead of our trading interests.
While our Firm does not maintain a proprietary trading account and therefore does not have a direct material
financial interest in any securities it recommends to Clients, in certain situations, our Firm’s employees and
associated persons may purchase interests in the same securities at the same or different portfolio percentages
or risk levels, in which one or more Clients is investing or has invested. Conversely, a Client may purchase
interests in security where our employees, IARs, and associated persons are investing or have invested.
Any exceptions to the Code require the prior approval of the CCO. We will provide a copy of the Code to any
Client or prospective client upon such written or verbal request. Such requests should be directed to our Firm’s
CCO at the contact information listed in Item 1 - Cover Page of this Brochure.
ITEM 12 - BROKERAGE PRACTICES
INVESTMENT MANAGEMENT SERVICES
Clients must maintain assets in an account with a “qualified Custodian,” a broker-dealer or bank. If our Firm is
asked to give a recommendation, our recommendation is based on the broker’s cost and fees, skills, reputation,
dependability, and compatibility with the Client. The Client may obtain lower commissions and fees from other
brokers.
CHARLES SCHWAB & CO. INC.
While our Firm recommends that Clients use Schwab as a Custodian, Clients must decide whether to do so and
open accounts with Schwab by entering into account agreements directly with them. The Client opens the
accounts with Schwab. The accounts will always be held in the Client's name and never in our Firm’s.
HOW OUR FIRM SELECTS CUSTODIAN-BROKER
Our Firm seeks to recommend a Custodian-Broker who will hold Client assets and execute the transactions on
terms that are, overall, most advantageous compared to other available providers and their services. Our Firm
considers a wide range of factors, including, among others:
Combination of transaction execution and asset custody services (without a separate fee for custody).
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• Capability to execute, clear, and settle trades (buy and sell securities for Client accounts).
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill
payments, etc.).
• The breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds
(ETFs), etc.).
• Availability of investment research and tools that assist us in making investment decisions.
• Quality of services.
• Competitiveness of the price of those services (commission rates, other fees, etc.) and willingness to
negotiate the prices.
• Reputation, financial strength, and stability.
• Prior service to our Firm and our other Clients.
Availability of other products and services that benefit our Firm, as discussed below (see “Products and Services
Available to Us from Schwab”).
CLIENT BROKERAGE & CUSTODY COSTS
For Clients' accounts, Schwab maintains and generally does not charge separately for custody services. However,
Schwab receives compensation by charging ticket charges or other fees on trades it executes or settling into
Clients' Schwab accounts. In addition to commissions, Schwab charges a flat dollar amount as a "prime broker"
or "trade away" fee for each trade that our Firm has executed by a different broker-dealer but where the
securities bought or the funds from the securities sold are deposited (settled) into a Client’s Schwab account.
These fees are in addition to the ticket charges or compensation the Client pays the executing broker-dealer.
Because of this, our Firm has Schwab execute most trades for Client accounts to minimize trading costs. Our
Firm has determined that having Schwab execute most trades is consistent with our duty to seek the "best
execution" of Client trades. Best execution means the most favorable terms for a transaction based on all
relevant factors, including those listed above (see How Our Firm Selects Custodian-Broker).
PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB
Schwab Advisor Services™ (formerly called Schwab Institutional®) provides independent investment advisory
Firms and Clients with access to its institutional brokerage, trading, custody, reporting, and related services,
many of which are not typically available to Schwab retail customers. Schwab also makes available various
support services. Some of those services help us manage or administer our Clients’ accounts; others help us
manage and grow our business. Schwab’s support services typically are available on an unsolicited basis and at
no charge to our Firm. These are typically considered soft dollar benefits because there is an incentive to do
business with Schwab. Receiving soft dollar benefits creates a conflict of interest. We have established policies
in this regard to mitigate any conflicts of interest. We believe our selection of Schwab as Custodian-Broker is in
the Clients' best interests. Our Firm will always act in the best interest of our Clients and act as fiduciary in
carrying out services to Clients. The following is a more detailed description of Schwab’s support services:
SERVICES THAT BENEFIT OUR CLIENTS
Schwab's institutional brokerage services include access to a broad range of investment products, execution of
securities transactions, and custody of Client assets. The investment products available through Schwab include
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some we might not otherwise have access to or would require a significantly higher minimum initial investment
by our Clients. Schwab’s services described in this paragraph benefit our Clients and their accounts.
SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS
Schwab also makes other products and services available that benefit our Firm but may not directly benefit our
Clients or their accounts. These products and services assist our Firm in managing and administering our Clients’
accounts. They include investment research, both Schwab’s own and that of third parties. Our Firm may use this
research to service all or a substantial number of our Client's accounts, including accounts not maintained at
Schwab. In addition to investment research, Schwab also makes available software and other technology that:
• Provides access to Client account data (such as duplicate trade confirmations and account statements).
• Facilitate trade execution and allocate aggregated trade orders for multiple Client accounts.
Provide pricing and other market data.
• Facilitate payment of our fees from our Clients’ accounts.
• Assist with back-office functions, recordkeeping, and Client reporting.
SERVICES THAT GENERALLY BENEFIT ONLY US
Schwab also offers other services to help our Firm manage and further develop our business enterprise.
These services include:
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide
the services to our Firm. Schwab may also discount or waive its fees for some of these services or pay all or a
part of a third party’s fees. Schwab may also provide our Firm with other benefits, such as occasional business
entertainment for our personnel.
OUR INTEREST IN SCHWAB’S SERVICES
• The availability of these services from Schwab benefits our Firm because we do not have to produce or
purchase them. These services are not contingent upon our Firm committing any specific amount of
business to Schwab in trading commissions. We believe our selection of Schwab as Custodian and
Broker is in our Client’s best interests.
Some of the products, services, and other benefits provided by Schwab benefit our Firm and may not benefit
our Client accounts. Our recommendation or requirement that you place assets in Schwab's custody may be
based, in part, on the benefits Schwab provides to our Firm or our Agreement to maintain certain Assets Under
Management at Schwab and not solely on the nature, cost, or quality of custody and execution services
provided by Schwab.
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• Our Firm places trades for our Clients' accounts subject to its duty to seek the best execution and other
fiduciary duties. Schwab's execution quality may be different from other broker-dealers.
Our Firm does not routinely recommend, request, or require that the Client direct us to execute the transactions
through a specified Custodian. Additionally, our Firm typically does not permit the Client to direct brokerage.
We place trades for Client accounts subject to our duty to seek the best execution and other fiduciary duties.
• We will aggregate trades for ourselves or our associated persons with your trades, providing that the
following conditions are met:
o Our policy for the aggregation of transactions shall be fully disclosed separately to our existing
Clients (if any) and the broker/dealer(s) through which such transactions will be placed.
o We will only aggregate transactions if we believe that aggregation is consistent with our duty
to seek the best execution (which includes the duty to seek the best price) for the Client and is
consistent with the terms of our investment advisory agreement.
o No advisory Client will be favored over any other Client; each Client that participates in an
aggregated order will participate at the average share price for all transactions in a given
security on a given business day, with transaction costs based on each Client's participation in
the transaction.
o Our Firm will prepare a written statement (“Allocation Statement”) specifying the participating
o
Client accounts and how to allocate the order among those Clients.
If the aggregated order is filled in its entirety, it will be allocated among Clients per the
allocation statement; if the order is partially filled, the accounts that did not receive the previous
trade's positions should be "first in line" to receive the next allocation.
o Notwithstanding the preceding, the order may be allocated on a basis different from that
specified if all Client accounts receive fair and equitable treatment. The reason for the
difference in allocation will be documented and reviewed by our Firm’s Compliance Officer.
Our Firm’s books and records will separately reflect, for each Client account, the orders which
are aggregated, and the securities held by and bought for that account.
o Our Firm will not receive additional compensation or remuneration of any kind because of the
o
proposed aggregation; and
Individual advice and treatment will be accorded to each advisory Client.
BROKERAGE FOR CLIENT REFERRALS
Our Firm does not receive Client referrals from any Custodian or third party in exchange for using that broker-
dealer or third party.
AGGREGATION & ALLOCATION OF TRANSACTIONS
Our Firm does not typically aggregate transactions; however, we may aggregate transactions if we believe that
aggregation is consistent with the duty to seek the best execution for our clients and is consistent with the
disclosures made to clients and terms defined in the client Investment Advisory Agreement. If we do aggregate
trades for ourselves or our associated persons with your trades, we will ensure that the following conditions are
met:
• When only a small percentage of the order is executed, with respect to purchase allocations, allocations
may be given to accounts high in cash.
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• Concerning sale allocations, allocations may be given to accounts low in cash.
• We may allocate shares to the account with the smallest order, to the smallest position, or to an account
that is out of line concerning security or sector weightings relative to other portfolios with similar
mandates.
•
•
• We may allocate one account when that account has limitations in its investment guidelines prohibiting
it from purchasing other securities that we expect to produce similar investment results, and other
accounts can purchase that in the block.
If an account reaches an investment guideline limit and cannot participate in an allocation, we may
reallocate shares to other accounts. For example, this may be due to unforeseen changes in an
account's assets after placing an order.
If a pro-rata allocation of a potential execution would result in a de minimis allocation in one or more
account(s), we may exclude the account(s) from the allocation.
• Our Firm will document the reasons for any deviation from a pro-rata allocation.
In certain cases, client requests or specific needs will trigger an unplanned transaction in a security where an
aggregate transaction occurred previously during the day. Under these circumstances, client transactions will be
excluded from the block transaction and receive differing pricing.
TRADE ERRORS
Our Firm has implemented procedures designed to prevent trade errors; however, our Firm cannot always avoid
Client trade errors.
Consistent with our Firm's fiduciary duty, it is our Firm’s policy to correct trade errors in a manner that is in the
Client's best interest. In cases where the Client causes the trade error, the Client will be responsible for any loss
resulting from the correction. Depending on the specific circumstances of the trade error, the Client may not be
able to receive any gains generated due to the error correction. In all situations where the Client does not cause
the trade error, the Client will be made whole, and we would absorb any loss resulting from the trade error if
our Firm caused the error. If the Custodian causes the error, the Custodian will cover all trade error costs. If an
investment error results in a gain when correcting the trade, the gain will be donated to charity. Our Firm will
never benefit or profit from trade errors.
DIRECTED BROKERAGE
Our Firm does not routinely recommend, request, or require that the Client direct us to execute the transaction
through a specified broker-dealer. Additionally, our Firm typically does not permit the Client to direct brokerage.
Our Firm places trades for Client accounts subject to its duty to seek the best execution and other fiduciary
duties.
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific
broker or dealer to obtain goods or services on the plan's behalf. Such direction is permitted provided that the
goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business
for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage
arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently,
we will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this
arrangement will be for the exclusive benefit of the plan.
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ITEM 13 - REVIEW OF ACCOUNTS
CLIENT REVIEWS
Our Firm reviews Client accounts and financial plans periodically. Our IARs will monitor Client accounts regularly
and perform annual reviews with each Client. All accounts are reviewed for consistency with Client investment
strategy, asset allocation, risk tolerance, and performance. More frequent reviews may be triggered by changes
in an account holder’s personal, tax, or financial status. Geopolitical and macroeconomic-specific events may
also trigger reviews. Our recommendations depend on the information provided by the Client. Our Client must
notify our Firm of any situation that would impair our ability to manage our Client accounts properly.
The Client receives a copy of each trade confirmation (unless the Client has authorized the Custodian to suppress
the confirmations) and the standard written account statement from the qualified account Custodian every
quarter.
ITEM 14 - CLIENT REFERRALS & OTHER COMPENSATION
BROKERAGE PRACTICES
As disclosed under Item 12 Brokerage Practices, we participate in the Custodian’s institutional customer
programs, and we may recommend a Custodian to our Clients for custody and brokerage services. There is no
direct link between our participation in the program and the investment advice we give to our Clients. However,
we receive economic benefits through our participation in the program that is typically not available to any other
independent advisors participating in the program. 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 adviser 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 certain institutional money Managers.
• Discounts on compliance, marketing, research, technology, and practice management products or
services provided to us by third-party vendors.
Custodians may also have paid for business consulting and professional services received by some of our IARs.
Some of the products and services made available by Custodians through the program may benefit us but may
not benefit your account. These products or services may assist us in managing and administering Client
accounts, including accounts not maintained at our recommended Custodian. Other services made available by
the Custodian are intended to help us manage and further develop our business enterprise. The benefits our
Firm or our IARs receive through participation in the program do not depend on the amount of brokerage
transactions directed to the Custodian. Due to these arrangements, our Client does not pay more for assets
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maintained at Schwab. As part of our fiduciary duties to Clients, we always endeavor to put our Client's interests
first. Clients should be aware, however, that receiving economic benefits from our Firm or our IARs in and of
itself creates a conflict of interest because the cost of these services would otherwise be borne directly by us.
These arrangements could indirectly influence our choice of Custodian for custody and brokerage services.
Clients should consider these conflicts of interest when selecting a Custodian. The products and services
provided by the Custodian, how they benefit us, and the related conflicts of interest are described above.
LEAD GENERATION & REFERRALS
LEAD GENERATION
Our Firm pays for lead generation services through other third parties. We subscribe to SmartAsset, a lead-
generation service for Registered Investment Advisors and other financial professionals. In exchange for these
services, we pay a monthly fee. Lead generation firms provide an online search tool to the public that allows
prospective clients to search for individual advisors within a selected state or region. These passive websites
may enable prospective clients to contact an advisor via electronic mail, telephone, or other contact information.
Clients who find our Firm this way do not pay more for their services than Clients referred in any other fashion.
There is no direct solicitation of Clients for the IAR by the lead generation service.
OTHER PROFESSIONALS
Our Firm may refer business to estate planning attorneys, accountants, insurance brokers, and other
professionals. However, we do not receive monetary or other material compensation for referring Clients to such
professionals. We also do not pay any person or firm commissions or other items of material value when referring
Clients to us. If we receive or offer an introduction to a Client, we do not pay or earn a referral fee, nor are there
established quid pro quo arrangements. Each Client can accept or deny such referral or subsequent services.
ITEM 15 - CUSTODY
Regulators have defined custody as having access or control over Client funds or securities. As it applies to our
Firm, we do not have physical custody of funds or securities.
FEE DEDUCTION
Our Firm is deemed to have constructive custody over those Client accounts where it can deduct our fees directly
from the Client account. If we comply with certain regulatory requirements, this constructive custody does not
mandate that our Firm undergo a surprise audit for those accounts. Our Clients receive account statements
directly from the qualified Custodian at least quarterly. Our Firm may send Clients quarterly reports that our Firm
produces using our portfolio accounting system, Advyzon.
We strongly urge our Clients to compare such reports with the statements received from the qualified Custodian.
Furthermore, when our Firm calculates our investment management fees and instructs the Custodian to remit
these fees to us directly from Clients’ accounts, the Custodian does not verify our calculation of fees. Our Firm
performs quarterly testing to ensure that our fees are charged per the Client’s Investment Advisory Agreement
on file with our Firm.
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STANDING LETTERS OF AUTHORIZATION (“SLOA”)
Additionally, our Firm is deemed to have custody of the Client’s funds or securities when you have standing
authorizations with their Custodian to move money from your account to a third-party Standing Letter of
Authorization (“SLOA”) and, under that SLOA, it authorizes us to designate the amount or timing of transfers
with the Custodian. The SEC has set forth standards to protect your assets in such situations, which we follow.
We do not have a beneficial interest in any of the accounts we are deemed to have Custody of where SLOAs
are on file. In addition, account statements reflecting all activity on the account(s) are delivered directly from the
qualified Custodian to each Client or the Client’s independent representative at least monthly. You should
carefully review those statements and are urged to compare the statements against reports received from us.
When you have questions about your account statements, contact us, your Advisor, or the qualified Custodian
preparing the statement.
ITEM 16 - INVESTMENT DISCRETION
DISCRETIONARY AUTHORITY
Upon receiving written authorization from the Client, our Firm provides discretionary investment advisory
services for Client accounts. For discretionary accounts, before engaging our Firm to provide investment
advisory services, you will enter into a written Investment Advisory Agreement with us granting our Firm the
authority to supervise and direct, on an ongoing basis, investments per the Client's investment objective and
guidelines. In addition, our Client will need to execute additional documents required by the Custodian to
authorize and enable our Firm, in its sole discretion, without prior consultation with or ratification by our Client,
to purchase, sell or exchange securities in and for your accounts. We are authorized, at our discretion and
without prior consultation with the Client, to (1) buy, sell, exchange, and trade any stocks, bonds, or other
securities or assets and (2) determine the amount of securities to be bought or sold and (3) place orders with the
Custodian. Any limitations to such discretionary authority will be communicated to our Firm in writing by you,
the Client.
The limitations on investment and brokerage discretion held by our Firm are:
• For discretionary accounts, we require that we be given the authority to determine which securities and
the amounts to be bought or sold.
• Any limitations on this discretionary authority shall be in writing as indicated in the Investment Advisory
Agreement. Clients may change or amend these limitations as required.
ITEM 17 - VOTING CLIENT SECURITIES
PROXY VOTING
Our Firm cannot vote for Client securities. Clients will receive proxies or other solicitations directly from the
Custodian or a transfer agent. Clients are responsible for obtaining and voting proxies for all securities
maintained in their portfolios. We may provide advice to you regarding your voting of proxies. Clients can
contact our Firm with any questions or concerns about a particular solicitation.
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CLASS ACTION LAWSUITS
Our Firm does not advise or instruct Clients on whether to participate as a member of class action lawsuits and
will not automatically file claims on the Client’s behalf. However, if a Client notifies us that they wish to participate
in a class action, we will provide the Client with transaction information about the Client’s account that is required
to file a proof of claim in a class action.
ITEM 18 - FINANCIAL INFORMATION
FINANCIAL CONDITION
Our Firm has no financial commitment that impairs its ability to meet Client contractual and fiduciary obligations
and has not been the subject of a bankruptcy proceeding. We do not require or solicit prepayment of more than
$1,200 in fees per Client six months or more in advance. Therefore, we are not required to include a balance
sheet for the most recent fiscal year.
ADDITIONAL INFORMATION
PRIVACY POLICY
Our Firm collects non-public personal information about Clients from information received on applications or
other forms and information about Client transactions with firm affiliates, others, or our Firm. We do not disclose
any nonpublic personal information about current or former Clients except as permitted by law or to provide
services. Firm employees have limited access to Clients' data based on their responsibilities to provide products
or services to Clients.
Our Firm maintains physical, electronic, and procedural safeguards in compliance with federal standards to
protect Client information. If the IAR servicing a Client account leaves our Firm to join another firm, the IAR is
not permitted to retain copies of specific Client information.
A copy of our Firm's Privacy Policy is given to each Client at account opening, upon request, and provided
annually.
BUSINESS CONTINUITY PLAN
Our Firm has developed a Business Continuity Plan to address how our Firm will respond to events that
significantly disrupt the operation of our business. Since the timing and impact of disasters and disruptions are
unpredictable, our Firm will be flexible in responding to current events as they occur.
Within 24 hours after a significant business disruption, our Firm plans to quickly recover and resume business
operations and respond by safeguarding employees and property, making a financial and operational
assessment, protecting our Firm’s books and records, and allowing Clients to transact business. Given the scope
and severity of the significant business disruption, our business continuity plan is designed to permit our Firm to
resume operations as quickly as possible.
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Our Firm’s business continuity plan addresses: data back-up and recovery; all mission critical systems; financial
and operational assessments; alternative communications with customers, employees, and regulators; alternate
physical location of employees; critical supplier, contractor, bank, and counter-party impact; regulatory
reporting; and assuring Clients’ prompt access to their funds and securities if our Firm is unable to continue as
a business.
Our Firm backs up essential records in a geographically separate area. At the same time, every emergency poses
unique problems based on external factors, such as the time of day and the severity of the disruption. Its
objective is to restore operations and be able to complete existing transactions and accept new transactions
and payments within four hours of the disruptive event. Client orders and requests for funds and securities could
be delayed during this period.
CONTACTING US
If a Client cannot contact our Firm via (303) 691-1808 after a significant business disruption to review updated
contact information.
VARYING DISRUPTIONS
Significant business disruptions can vary in scope, such as disruption that affects only our Firm, a single building
housing our Firm, the business district where our Firm is located, the city where our Firm is located, or the whole
region. Within each area, the disruption's severity can also vary from minimal to severe. In a disruption to only
our Firm or a building housing our Firm, our Firm will transfer operations to a local site when needed and expect
to recover and resume business within 24 hours.
In a disruption affecting our Firm’s business district, city, or region, our Firm will transfer operations to a site
outside the affected area and recover and resume business within three (3) days. In either situation, our Firm
plans to continue the business, transfer operations to its clearing firm if necessary, and provide Clients with
instructions on contacting our Firm by calling (303) 691-1808. If the significant business disruption is so severe
that it prevents our Firm from remaining in business, our Firm will ensure the Client’s prompt access to their
funds and securities.
This information is provided solely to Clients of our Firm, and no further distribution or disclosure is permitted
without the prior written consent of our Firm. No person other than our Firm Clients can rely on any statement
herein. Our Firm’s Business Continuity Plan is reviewed and updated regularly and is subject to change.
Please contact Forty North for the most current copy of this disclosure. You can request an updated copy by
contacting our Firm at (303) 691-1808 or writing our Firm at the following:
Forty North Wealth
650 S. Cherry St., Suite 840
Glendale, CO 80246
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