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Form ADV Part 2A – Firm Brochure
December 26, 2025
FOURTHOUGHT
FINANCIAL
PARTNERS, LLC
a Registered Investment Adviser
310 W. Venice Avenue, Suite 201
Venice, Florida 34285
(941) 408-8557
www.FourThought.com
This brochure provides information about the qualifications and business practices of FourThought
Financial Partners, LLC (hereinafter “FourThought” or the “Firm”). If you have any questions about the
contents of this Form ADV Part 2A brochure (“Brochure”), please contact Compliance at (941) 408-8557.
The information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission (“SEC”) or by any state securities authority. Additional information about
FourThought is available on the SEC’s website at www.adviserinfo.sec.gov.
FourThought is an SEC registered investment adviser. Registration does not imply any level of skill or
training.
Disclosure Brochure
December 26 , 2025
FourThought Financial
Item 2. Material Changes
In this section, we are required to summarize material changes to the brochure since our previous annual
amendment dated March 25, 2025.
• We updated Item 2 to include our current fee schedule.
• We updated Item 10 to provide detail on the compensation provided to our supervised persons who place
life insurance.
We will further provide you with a new brochure as necessary based on changes or new information, at
any time, without charge. Additional information about FourThought is also available via the SEC’s
website www.advisorinfo.sec.gov. The SEC’s website also provides information about any persons
affiliated with FourThought who are registered as investment advisor representatives of FourThought.
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Item 3. Table of Contents
Item 2. Material Changes .................................................................................................................................................. 2
Item 3. Table of Contents .................................................................................................................................................. 3
Item 4. Advisory Business ................................................................................................................................................. 3
Item 5. Fees and Compensation ....................................................................................................................................... 10
Item 6. Performance-Based Fees and Side-by-Side Management .................................................................................... 15
Item 7. Types of Clients .................................................................................................................................................. 15
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................. 16
Item 9. Disciplinary Information ..................................................................................................................................... 21
Item 10. Other Financial Industry Activities and Affiliations .......................................................................................... 22
Item 11. Code of Ethics ................................................................................................................................................... 27
Item 12. Brokerage Practices ........................................................................................................................................... 27
Item 13. Review of Accounts .......................................................................................................................................... 30
Item 14. Client Referrals and Other Compensation ......................................................................................................... 30
Item 15. Custody ............................................................................................................................................................ 32
Item 16. Investment Discretion ........................................................................................................................................ 32
Item 17. Voting Client Securities..................................................................................................................................... 32
Item 18. Financial Information ........................................................................................................................................ 32
Item 4. Advisory Business
FourThought Financial Partners, LLC acquired the advisory business of FourThought Financial, LLC which
has been registered as an investment adviser since November 2019. FourThought offers a variety of
advisory services, which include financial planning, consulting, and investment management services. Prior
to FourThought rendering any of the foregoing advisory services, clients are typically required to enter into
one or more written agreements with FourThought setting forth the relevant terms and conditions of the
advisory relationship (the “Advisory Agreement”).
FOCUS FINANCIAL PARTNERS, LLC
FourThought is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically,
FourThought is a wholly-owned indirect subsidiary of Focus LLC. Focus Financial Partners Inc. is the sole
managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of
directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and
collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment
vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because
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Disclosure Brochure
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FourThought Financial
FourThought is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment
vehicles are indirect owners of FourThought.
Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance
firms, business managers and other firms (the “Focus Partners”), most of which provide wealth
management, benefit consulting and investment consulting services to individuals, families, employers, and
institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment
companies as disclosed on their respective Form ADVs.
FourThought is managed by Scott Pinkerton and Chris Fagley (“FourThought Principal”), pursuant to a
management agreement between FTPW, LLC and FourThought. The FourThought Principals serve as
leaders and officers of FourThought and are responsible for the management, supervision and oversight of
FourThought.
While this brochure generally describes the business of FourThought, certain sections also discuss the
activities of its Supervised Persons, which refer to FourThought’s officers, partners, directors (or other
persons occupying a similar status or performing similar functions), employees or other persons who
provide investment advice on FourThought’s behalf and are subject to the Firm’s supervision or control.
As of December 31, 2024, FourThought had $1,589,562,254 in assets under management, all of which are
managed on a discretionary basis.
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FourThought Financial
Wealth Management Services
FourThought provides certain clients with wealth management services which include a broad range of
financial planning and consulting services as well as discretionary and/or non-discretionary management of
investment portfolios. FourThought primarily allocates client assets among various mutual funds,
exchange-traded funds (“ETFs”), individual debt and equity securities, structured notes, publicly and
privately traded REITs and independent investment managers (“Independent Managers”) in accordance
with their stated investment objectives. In addition, FourThought also recommends that certain eligible
clients invest in privately placed securities, which may include debt, equity and/or interests in pooled
investment vehicles (e.g., hedge funds).
Clients can engage FourThought to manage and/or advise on certain investment products that are not
maintained at their primary custodian, such as annuity contracts and assets held in employer sponsored
retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, FourThought directs or
recommends the allocation of client assets among the various investment options available with the product.
These assets are generally maintained at the underwriting insurance company, or the custodian designated
by the product’s provider.
FourThought tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on
a continuous basis, that client portfolios are managed in a manner consistent with those needs and
objectives. FourThought consults with clients on an initial and ongoing basis to assess their specific risk
tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their
portfolios.
Clients are advised to promptly notify FourThought if there are changes in their financial situation or if they
wish to place any limitations on the management of their portfolios. Clients can impose reasonable
restrictions or mandates on the management of their accounts if FourThought determines, in its sole
discretion, the conditions would not materially impact the performance of a management strategy or prove
overly burdensome to the Firm’s management efforts.
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FourThought Financial
Financial Planning and Consulting Services
FourThought offers clients a broad range of financial planning and consulting services, which include any,
some or all of the following functions:
•
Business Planning
•
Tax Planning
•
Cash Flow Forecasting
• Manager Due Diligence
•
Trust and Estate Planning
•
Asset Protection
•
Financial Reporting
•
Internet Protection
•
Investment Consulting
•
Liability Management
•
Insurance Planning
•
Social Security Planning
•
Retirement Planning
•
Education Planning
•
Risk Management
•
Family Business Transition
Planning
•
Philanthropic Planning
•
Long Term Care Planning
•
Distribution Planning
While each of these services is available on a stand-alone basis, especially where the amount of services
are in excess of what the fee would be under a wealth management agreement (as described above), certain
of them can also be rendered in conjunction with investment portfolio management as part of a
comprehensive wealth management engagement (described in more detail above). When performing the
Financial Planning and Consulting Services, we will work collaboratively with your attorney, tax advisor
and/or accountants. No portion of the services rendered by FourThought should be interpreted by you as
legal, tax or accounting advice.
In performing these services, FourThought is not required to verify any information received from the client
or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to
rely on such information. FourThought recommends certain clients engage the Firm for additional related
services, and/or other professionals to implement its recommendations. Clients are advised that a conflict
of interest exists for the Firm to recommend that clients engage FourThought or its affiliates to provide (or
continue to provide) additional services for compensation, including investment management services.
Clients retain absolute discretion over all decisions regarding implementation and are under no obligation
to act upon any of the recommendations made by FourThought under a financial planning or consulting
engagement. Clients are advised that it remains their responsibility to promptly notify FourThought of any
change in their financial situation or investment objectives for the purpose of reviewing, evaluating or
revising FourThought’s recommendations and/or services.
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FourThought Financial
Retirement Plan Consulting Services
FourThought provides various consulting services to qualified employee benefit plans and their fiduciaries.
This suite of institutional services is designed to assist plan sponsors in structuring, managing and
optimizing their corporate retirement plans. Each engagement is individually negotiated and customized,
and includes any or all of the following services:
•
Plan Design and Strategy
•
Plan Fee and Cost Analysis
•
Plan Review and Evaluation
•
Plan Committee Consultation
•
Executive Planning & Benefits
•
Fiduciary and Compliance
•
Investment Selection
•
Participant Education
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Disclosure Brochure
December 26, 2025
FourThought Financial
As disclosed in the Advisory Agreement, certain of the foregoing services are provided by FourThought as
a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with
respect to investment management services and investment advice provided to ERISA plans and ERISA
plan participants. FourThought, is also a fiduciary under section 4975 of the Internal Revenue Code of 1986,
as amended (the “IRC”) with respect to investment management services and investment advice provided
to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such,
FourThought is subject to specific duties and obligations under ERISA and the IRC, as applicable, that
include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from
acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain
conflicts of interest or rely upon an applicable prohibited transaction exemption.
As a fiduciary, FourThought has duties of care and of loyalty to you and are subject to obligations imposed
on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or
limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations
under the federal and state securities laws or as a waiver of any unwaivable rights you possess.
Use of Independent Managers
As mentioned above, FourThought selects certain Independent Managers to actively manage a portion of
some clients’ assets. The specific terms and conditions under which a client engages an Independent
Manager may be set forth in a separate written agreement with the designated Independent Manager. In
addition to this brochure, clients may also receive the written disclosure documents of the respective
Independent Managers engaged to manage their assets.
FourThought evaluates a variety of information about Independent Managers, which includes the
Independent Managers’ public disclosure documents, materials supplied by the Independent Managers
themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks
to assess the Independent Managers’ investment strategies, past performance and risk results in relation to
its clients’ individual portfolio allocations and risk exposure. FourThought also takes into consideration
each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing
and research capabilities, among other factors.
FourThought continues to provide services relative to the discretionary or non-discretionary selection of
the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being
managed by Independent Managers. FourThought seeks to ensure the Independent Managers’ strategies and
target allocations remain aligned with its clients’ investment objectives and overall best interests.
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Disclosure Brochure
December 26, 2025
FourThought Financial
Institutional Consulting Services
FourThought renders investment and non-investment related consulting services through its FourThought
Institution division, to various institutions and independent third parties as part of its institutional consulting
services. FourThought’s institutional consulting services are specialized engagements individually
negotiated with each institution based upon their specific needs. FourThought’s institutional consulting
services are not available to individuals, but rather address fundamental issues affecting various institutions
within FourThought’s area of concentration. FourThought charges a fixed fee and/or hourly fee for these
services and does not render such institutional consulting services to its investment advisory clients.
Cash and Cash Management Solutions, Focus Risk Solutions and Affiliated Entities
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial
institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates,
“UPTIQ”) and Flourish Financial LLC (“Flourish”). Please see Items 5 and 10 for a fuller discussion of
these services and other important information.
We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk
Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC.
Please see Items 5 and 10 for a fuller discussion of these services and other important information.
We have a business arrangement with SCS Capital Management LLC (“SCS”) and a subsidiary or
subsidiaries of Origin Investments Group, LLC
(“Origin”), who are each an indirect, wholly-owned
subsidiary of Focus LLC, under which certain clients of FourThought have the option of investing in certain
private investment vehicles managed by SCS and Origin. FourThought is an affiliate of SCS and Origin by
virtue of being under common control with it. Please see Items 5, 10, and 11 of this Brochure for further
details.
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Disclosure Brochure
December 26, 2025
FourThought Financial
Item 5. Fees and Compensation
FourThought offers services on a fee basis, which includes fixed fees, as well as fees based upon assets
under management.
Wealth Management Fees
FourThought offers investment management services for an annual fee based on the amount of assets under
the Firm’s management. This management fee is generally in accordance with the following blended fee
schedule:
Market Value of Assets
Annual Tier Rate
First $1,000,000
$1,000,000 to $2,500,000
$2,500,000 to $5,000,000
$5,000,000 to $10,000,000
Above $10,000,000
0.95%
0.85%
0.65%
0.55%
0.45%
The management fee is subject to negotiation, may be discounted, and can vary from client to client based
on a number of factors. The specific fee schedule charged by FourThought is provided in a client’s
investment advisory agreement with us. Some legacy clients are subject to different management fee rates
for different types of accounts, which rates are set forth in an agreement they signed prior to the Firm
adopting the fee schedule set forth above.
The annual fee is prorated and charged quarterly, in advance, based upon the average daily market value of
the assets being managed by FourThought during the preceding quarter, as provided by third-party sources.
For the initial quarter, the fee shall be prorated and calculated in arrears, based upon the funded asset value in
your Accounts on the day the Assets are received into the Accounts. Cash, accrued interest and the value of
securities held on margin are included in the valuation for billing purposes. In the event the advisory
agreement is terminated, the fee for the final billing period is prorated through the effective date of the
termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as
appropriate.
We have a conflict of interest when our fee rates vary based on the type of investment we are managing.
The differing rates give us an incentive to recommend that clients allocate away from laddered bonds, where
we charge a lower fee rate, to other managed assets where we charge a higher fee rate. We mitigate this
conflict of interest by disclosing it to you. In addition, we will only increase our fees as a result of allocating
assets from laddered bonds to other managed assets when we believe that the allocation change is in your
best interest. We eliminate this conflict in IRA accounts by charging a blended rate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
held-away assets, accommodation accounts, alternative investments, etc.), FourThought may negotiate a
fee rate that differs from the range set forth above. Clients are advised that a conflict of interest exists for
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Disclosure Brochure
December 26, 2025
FourThought Financial
the Firm to recommend that clients engage FourThought for additional services for compensation, including
rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute
discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the
recommendations.
Financial Planning and Consulting Fees
As described above, the Firm’s financial planning and consulting services are typically provided through
an asset-based fee for comprehensive wealth management. In certain circumstances, however, FourThought
charges a fixed fee for providing financial planning and consulting services under a stand- alone
engagement. These fees are negotiable but range from $2,000 to $75,000 depending upon the scope and
complexity of the services and the professional rendering the financial planning and/or the consulting
services. If the client engages the Firm for additional investment advisory services, FourThought may offset
all or a portion of its fees for those services based upon the amount paid for the financial planning and/or
consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the
Advisory Agreement and FourThought requires one-half of the fee (estimated hourly or fixed) payable upon
execution of the Advisory Agreement. The outstanding balance is due upon delivery of the financial plan
or completion of the agreed upon services. The Firm does not, however, take receipt of $1,200 or more in
prepaid fees in excess of six months in advance of services rendered.
Retirement Plan Consulting Fees
Retirement Plan Consulting Fees will be based upon the average daily market value of the assets being
managed by FourThought during the preceding quarter, as provided by third-party sources. For the initial
quarter, the fee shall be prorated and calculated in arrears, based upon the funded asset value in your
accounts on the day the Assets are received into the accounts. Fees paid as an annual fixed fee shall be paid
quarterly in advance. Fees may be paid by the client directly or paid out of the plan assets in accordance with
the client’s instructions. Retirement Plan Consulting Fees vary based on the scope of the services to be
rendered as well as the amount of assets being advised on. Fees paid as a percentage of assets are based on
the following fee
schedule:
PLAN ASSETS
BASE FEE
Up to $10,000,000
$10,000,000 to $100,000,000
$100,000,000 to $250,000,000
Above $250,000,000
0.25% – 0.50%
0.10% – 0.25%
0.04% – 0.10%
Negotiable
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Fee Discretion
FourThought may, in its sole discretion, negotiate to charge a lesser fee on all or a portion of the assets,
based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets,
dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client
relationship, account retention, and client hardship.
Additional Fees and Expenses
In addition to FourThought’s fees, clients are responsible for the fees and expenses associated with the
investment of their assets, including charges imposed directly by the custodian of the client’s account, any
transaction charges imposed by the broker-dealer executing securities transactions for the client’s account,
fees charged by external managers of separately managed accounts, and fees and expenses of mutual funds
and other pooled investment vehicles held in or for the client’s account. For further discussion concerning
Four Thought’s brokerage practices, please see Item 12 of this Disclosure Brochure. All fees paid to
FourThought are separate and distinct from the fees charged by third-party managers. The client should
review any fees charged by the third-party managers and/or pooled investment vehicles and the fees charged
by FourThought to fully understand the total amount of fees to be paid by the client and to thereby evaluate
the advisory services being provided.
Direct Fee Debit
Clients provide FourThought and/or certain Independent Managers with the authority to directly debit their
accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified
custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed
to send statements to clients not less than quarterly detailing all account transactions, including any amounts
paid to FourThought. Alternatively, clients may elect to have FourThought send a separate invoice for direct
payment.
Cash and Cash Management Solutions, Focus Risk Solutions and Affiliated Entities
FourThought clients can utilize margin in the client’s investment portfolio, although such borrowing is not
recommended by FourThought. The Firm’s fees are determined based upon the value of the assets being
managed gross of any margin or borrowing.
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial
institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates,
“UPTIQ”) and Flourish Financial LLC (“Flourish”). Focus Financial Partners, LLC (“Focus”) is a minority
investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party
financial institutions for serving our clients. The revenue paid to UPTIQ also benefits UPTIQ, Inc.’s
investors, including Focus, our parent company. When legally permissible, UPTIQ also shares a portion of
this earned revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For securities-backed lines
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FourThought Financial
of credit (“SBLOCs”) made to our clients, UPTIQ will share with FSH up to 75% of all revenue it receives
from such third-party financial institutions. For other loans (except residential mortgage loans) made to our
clients, UPTIQ will share with FSH up to 25% of all revenue it receives from such third-party financial
institutions. For cash management products and services provided to our clients, UPTIQ will share with
FSH up to 33% of all revenue it receives from the third-party financial institutions and other intermediaries
that provide administrative and settlement services in connection with this program. As noted above,
Flourish facilitates cash management solutions for our clients. When legally permissible, Flourish pays
FSH a revenue share of up to 0.10% of the total amount of cash held in Flourish cash accounts by our
clients. Although the amount of these revenue-sharing payments to FSH is not charged directly in the
calculation of the interest rate paid by clients on credit solutions facilitated by UPTIQ or the yield earned
by clients on cash management solutions facilitated by UPTIQ or Flourish, the compensation earned by
UPTIQ and Flourish is an expense of the third-party financial institutions that informs the interest rate paid
by clients on credit solutions and the yield earned by clients on cash management solutions. FSH distributes
this revenue to us when we are licensed to receive such revenue (or when no such license is required) and
the distribution is not otherwise legally prohibited. Further information on this conflict of interest is
available in Item 10 of this Brochure.
We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk
Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC.
FRS assists our clients with regulated insurance sales activity by advising our clients on insurance matters
and placing insurance products for them and/or referring our clients to certain third-party insurance brokers
(the “Brokers”), with whom FRS has agreements, which either separately or together with FRS place
insurance products for them. If FRS places an insurance product or refers one of our clients to a Broker and
there is a subsequent purchase of insurance through the Broker, then FRS will receive a portion of the
upfront and/or ongoing commissions associated with the sale by the insurance carrier with which the policy
was placed. The amount of revenue earned by FRS for the sale of these insurance products will vary over
time in response to market conditions and will also differ based on the type of insurance product sold and
which Broker placed the policy. The amount of insurance commission revenue earned by FRS is considered
for purposes of determining the amount of additional compensation that certain of our financial
professionals are entitled to receive. Additionally, in exchange for allowing certain of the Brokers to
participate in the FRS platform and, thereby, to offer their services to our clients and certain of our affiliates’
clients, FRS receives periodic fees (the “Platform Fees”) from such Brokers. The Platform Fees are
expected to change over time. Such Platform Fees are revenue for FRS and, ultimately, for our common
parent company, Focus, but we do not share in such revenue. FRS also indirectly benefits from our clients’
use of the services insofar as such use incentivizes the Brokers to maintain their relationship with FRS and
to continue paying Platform Fees to FRS, which could also support increases in the overall amount of the
Platform Fee rates in the future. Further information on this conflict of interest is available in Item 10 of
this Brochure.
We do not receive any compensation from SCS and Origin in connection with assets that our clients place
in SCS and Origin’s pooled investment vehicles. FourThought’s clients are not advisory clients of and do
not pay advisory fees to SCS and Origin. However, our clients bear the costs of SCS and Origin’s investment
vehicle or vehicles in which they are invested, including any management fees and performance fees payable
to SCS and Origin.
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FourThought Financial
The allocation of FourThought client assets to SCS and Origin’s pooled investment vehicles, rather than to
an unaffiliated investment manager, increases SCS and Origin’s compensation and the revenue to Focus
LLC relative to a situation in which our clients are excluded from SCS and Origin’s pooled investment
vehicles or invested in an unaffiliated third party's pooled investment vehicles. As a consequence, Focus
LLC has a financial incentive to cause us to recommend that our clients invest in SCS and Origin’s pooled
investment vehicles.
Account Additions and Withdrawals
Clients can make additions to and withdrawals from their account at any time, subject to FourThought’s
right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the right
to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients can
withdraw account assets on notice to FourThought, subject to the usual and customary securities settlement
procedures. However, the Firm designs its portfolios as long-term investments and the withdrawal of assets
may impair the achievement of a client’s investment objectives. FourThought may consult with its clients
about the options and implications of transferring securities. Clients are advised that when transferred
securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed
at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications.
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Item 6. Performance-Based Fees and Side-by-Side Management
FourThought does not provide any services for a performance-based fee (i.e., a fee based on a share of
capital gains or capital appreciation of a client’s assets).
Item 7. Types of Clients
FourThought offers services to individuals, high net worth individuals, pension and profit-sharing plans,
trusts, estates, charitable organizations, corporations and business entities, family foundations, community
foundations, non-profit organizations, and universities.
Minimum Account Value and Fee
As a condition for starting and maintaining an investment management relationship, FourThought imposes
a minimum portfolio value of $250,000 and a minimum fee of $750 per quarter. FourThought may, in its
sole discretion, accept clients with smaller portfolios or for a lesser or no fee based upon certain criteria,
including anticipated future earning capacity, anticipated future additional assets, dollar amount of assets
to be managed, related accounts, account composition, pre-existing client, account retention, FourThought
only accepts clients with less than the minimum portfolio size if the Firm determines the smaller portfolio
size will not cause a substantial increase of investment risk beyond the client’s identified risk tolerance.
FourThought may aggregate the portfolios of family members to meet the minimum portfolio size and fee.
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Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
FourThought provides comprehensive financial planning and investment services. As a registered
investment advisor, FourThought acts as a fiduciary in its client relationships.
The initial step in the Firm's investment strategy is understanding the objectives and goals of the client. To
help facilitate this understanding, the development of a client’s investment strategy begins with financial
planning. Building on that financial planning foundation, the Firm recommends strategies and investments
that it believes are in alignment with client's goals while managing risk.
Each client's investment strategy is customized based on their specific needs, objectives, risk tolerance
level, and FourThought's analysis. FourThought has firm principles that are universally employed:
1. We are long term strategic thinkers. (We are not Gods.)
2. Portfolios should be diversified. (Don't put all your eggs in one basket.)
3. Portfolios should be tailored to meet the client's specific. projected cash flow needs. (Protect the
goose that we hope is laying the golden eggs.)
4. Strategies should be constructed to survive worse case scenarios. (Be prepared for the flood.)
The Firms' investment committee selects assets through a rigorous evaluation and screening process. To
maintain a broadly diverse portfolio, FourThought selects assets and products from many asset classes,
including global and domestic equities, taxable and non-taxable fixed income and a variety of alternative
investments. The Firm believes that this approach to portfolio management provides each client with an
investment strategy tailored to their individual financial objectives and risk tolerance. The FourThought
Investment Committee has developed strategies to meet various client objectives. These include a dividend
growth strategy (Income Opportunities), a high income strategy (Alternative Income), a core stock strategy
(Dynasty Quant), growth strategies (Dynasty Growth and Concentrated Growth), small cap, high yield
municipal and international strategies. FourThought has also developed strategies using ETF and Mutual
Funds. FourThought blends these various strategies to meet a client’s specific needs.
The use of individual bonds. FourThought often utilizes short-term zero-coupon bonds with targeted
maturities to meet the cash flow demands of clients.
Cash Flow Analysis. FourThought projects available cash to meet client income needs. This goals- based
planning technique identifies specific investments that can help meet income needs. Income needs can be
met through dividends, interest, maturing fixed income instruments and required distributions from
qualified plans and IRAs.
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FourThought Financial
Risk of Loss
The following list of risk factors does not purport to be a complete enumeration or explanation of the risks
involved with respect to the Firm’s investment management activities. Clients should consult with their
legal, tax, and other advisors before engaging the Firm to provide investment management services on their
behalf.
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly. The profitability of a significant portion of FourThought’s recommendations and/or investment
decisions may depend to a great extent upon correctly assessing the future course of price movements of
stocks, bonds and other asset classes. In addition, investments may be adversely affected by financial
markets and economic conditions throughout the world. There can be no assurance that FourThought will
be able to predict these price movements accurately or capitalize on any such assumptions.
Volatility Risks
The prices and values of investments can be highly volatile, and are influenced by, among other things,
interest rates, general economic conditions, the condition of the financial markets, the financial condition
of the issuers of such assets, changing supply and demand relationships, and programs and policies of
governments.
Cash Management Risks
The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of
investments, during which time an advisory account may be prevented from achieving its investment
objective.
Equity-Related Securities and Instruments
The Firm may take long positions in common stocks of U.S. and non-U.S. issuers traded on national
securities exchanges and over-the-counter markets. The value of equity securities varies in response to many
factors. These factors include, without limitation, factors specific to an issuer and factors specific to the
industry in which the issuer participates. Individual companies may report poor results or be negatively
affected by industry and/or economic trends and developments, and the stock prices of such companies may
suffer a decline in response. In addition, equity securities are subject to stock risk, which is the risk that
stock prices historically rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced
periods of substantial price volatility in the past and may do so again in the future. In addition, investments
in small-capitalization, mid-capitalization and financially distressed companies may be subject to more
abrupt or erratic price movements and may lack sufficient market liquidity, and these issuers often face
greater business risks.
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Fixed Income Securities
Fixed income securities are subject to the risk of the issuer’s or a guarantor’s inability to meet principal and
interest payments on its obligations and to price volatility.
Interest Rate Risks
Interest rates may fluctuate significantly, causing price volatility with respect to securities or instruments
held by clients.
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF
shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for
a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily
per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption
fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual
NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a
mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may,
among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least
once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However,
certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There
is also no guarantee that an active secondary market for such shares will develop or continue to exist.
Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more).
Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may
have no way to dispose of such shares.
Use of Independent Managers
As stated above, FourThought selects certain Independent Managers to manage a portion of its clients’
assets. In these situations, FourThought continues to conduct ongoing due diligence of such managers, but
such recommendations rely to a great extent on the Independent Managers’ ability to successfully
implement their investment strategies. In addition, FourThought does not have the ability to supervise the
Independent Managers on a day-to-day basis.
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Structured Notes
Complexity. Structured notes are complex financial instruments. Clients should understand the reference
asset(s) or index(es) and determine how the note’s payoff structure incorporates such reference asset(s) or
index(es) in calculating the note’s performance. This payoff calculation includes leverage multiplied on the
performance of the reference asset or index, protection from losses should the reference asset or index
produce negative returns, and fees. Structured notes usually have complicated payoff structures that can
make it difficult for clients to accurately assess their value, risk and potential for growth through the term
of the structured note. Determining the performance of each note can be complex and this calculation can
vary significantly from note to note depending on the structure. Notes can be structured in a wide variety
of ways. Payoff structures can be leveraged, inverse, or inverse-leveraged, which may result in larger
returns or losses. Clients should carefully read the prospectus for a structured note to fully understand how
the payoff on a note will be calculated and discuss these issues with us.
Market risk. Some structured notes provide for the repayment of principal at maturity, which is often
referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing
financial institution. Many structured notes do not offer this feature. For structured notes that do not offer
principal protection, the performance of the linked asset or index may cause clients to lose some, or all, of
their principal. Depending on the nature of the linked asset or index, the market risk of the structured note
may include changes in equity or commodity prices, changes in interest rates or foreign exchange rates, or
market volatility.
Issuance price and note value. The price of a structured note at issuance will likely be higher than the fair
value of the structured note on the date of issuance. Issuers now disclose an estimated value of the structured
note on the cover page of the offering prospectus, allowing investors to gauge the difference between the
issuer’s estimated value of the note and the issuance price. The estimated value of the notes is likely lower
than the issuance price of the note to investors because issuers include the costs for selling, structuring or
hedging the exposure on the note in the initial price of their notes. After issuance, structured notes cannot
be re-sold on a daily basis and thus will be difficult to value given their complexity.
Liquidity. The ability to trade or sell structured notes in a secondary market is often very limited as
structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on security
exchanges. As a result, the only potential buyer for a structured note may be the issuing financial
institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In addition, issuers
often specifically disclaim their intention to repurchase or make markets in the notes they issue.
Clients should, therefore, be prepared to hold a structured note to its maturity date, or risk selling the note at
a discount to its value at the time of sale.
Credit risk. Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is
obligated to make payments on the notes as promised. These promises, including any principal protection,
are only as good as the financial health of the structured note issuer. If the structured note issuer defaults
on these obligations, investors could lose some, or all, of the principal amount they invested in the structured
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notes as well as any other payments that would be due on the structured notes.
Call risk. Some structured notes have “call provisions” that allow the issuer, at its sole discretion, to redeem
the note before it matures at a price that can be above, below or equal to the face value of the structured
note. If the issuer “calls” the structured note, clients may not be able to reinvest their money at the same
rate of return provided by the structured note that the issuer redeemed.
Tax considerations. The tax treatment of structured notes is complicated and, in some cases, uncertain.
Before purchasing any structured note, clients should consult with a tax advisor. Clients also should read
the applicable tax risk disclosures in the prospectuses and other offering documents of any structured note
they are considering purchasing.
Use of Private Collective Investment Vehicles
FourThought recommends that certain clients invest in privately placed collective investment vehicles (e.g.,
hedge funds, private equity funds, etc.). The managers of these vehicles have broad discretion in selecting
the investments. There are few limitations on the types of securities or other financial instruments which
may be traded and no requirement to diversify. Hedge funds may trade on margin or otherwise leverage
positions, thereby potentially increasing the risk to the vehicle. In addition, because the vehicles are not
registered as investment companies, there is an absence of regulation. There are numerous other risks in
investing in these securities. Clients should consult each fund’s private placement memorandum and/or
other documents explaining such risks prior to investing.
Use of Borrowing
While the use of margin or securities-backed lending can be beneficial, it may also increase overall portfolio
risk. Under certain circumstances, a lending financial institution may demand an increase in the underlying
collateral. If the client is unable to provide the additional collateral, the financial institution may liquidate
account assets to satisfy the client’s outstanding obligations, which could have extremely adverse
consequences.
Currency Risks
An advisory account that holds investments denominated in currencies other than the currency in which the
advisory account is denominated may be adversely affected by the volatility of currency exchange rates.
Cybersecurity
The computer systems, networks and devices used by FourThought and service providers to FourThought
and FourThought’s clients to carry out routine business operations employ a variety of protections designed
to prevent damage or
interruption from computer viruses, network failures, computer and
telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various
protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively
impacted as a result of a cybersecurity breach.
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Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from
computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise
disrupt operations, business processes, or website access or functionality. Cybersecurity breaches may
cause disruptions and impact business operations, potentially resulting in financial losses to a client;
impediments to trading; the inability by us and other service providers to transact business; violations of
applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other
compensation costs, or additional compliance costs; as well as the inadvertent release of confidential
information.
Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in
which a client invests; governmental and other regulatory authorities; exchange and other financial market
operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial
costs may be incurred by these entities in order to prevent any cybersecurity breaches in the future.
Item 9. Disciplinary Information
FourThought has not been involved in any legal or disciplinary events that are material to a client’s
evaluation of its advisory business or the integrity of its management.
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Item 10. Other Financial Industry Activities and Affiliations
This item requires investment advisers to disclose certain financial industry activities and affiliations.
Licensed Insurance Agents
Some of the Firm’s Supervised Persons are licensed insurance agents who receive normal and customary
compensation for certain life insurance policies. The compensation our supervised persons receive for
placing life insurance creates a conflict of interest with our clients, as it creates an incentive for our
supervised persons to recommend insurance based on the compensation the supervised person will receive
rather than based on a client's needs. We address this conflict of interest through this disclosure. Clients are
free to obtain insurance coverage through other vendors if they wish.
Credit and Cash Management Solutions
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial
institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates,
“UPTIQ”) and Flourish Financial LLC (“Flourish”). These third-party financial institutions are banks and
non-banks that offer credit and cash management solutions to our clients, as well as certain other unaffiliated
third parties that provide administrative and settlement services to facilitate UPTIQ’s cash management
solutions. UPTIQ acts as an intermediary to facilitate our clients’ access to these credit and cash
management solutions. Flourish acts as an intermediary to facilitate our clients’ access to cash management
solutions.
We are a wholly owned subsidiary of Focus Financial Partners, LLC (“Focus”). Focus is a minority investor
in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party financial
institutions for serving our clients. The revenue paid to UPTIQ also benefits UPTIQ, Inc.’s investors,
including Focus. When legally permissible, UPTIQ also shares a portion of this earned revenue with our
affiliate, Focus Solutions Holdings, LLC (“FSH”). For securities-backed lines of credit (“SBLOCs”) made
to our clients, UPTIQ will share with FSH up to 75% of all revenue it receives from such third-party
financial institutions. For other loans (except residential mortgage loans) made to our clients, UPTIQ will
share with FSH up to 25% of all revenue it receives from such third-party financial institutions. For cash
management products and services provided to our clients, UPTIQ will share with FSH up to 33% of all
revenue it receives from the third-party financial institutions and other intermediaries that provide
administrative and settlement services in connection with this program. As noted above, Flourish facilitates
cash management solutions for our clients. When legally permissible, Flourish pays FSH a revenue share
of up to 0.10% of the total amount of cash held in Flourish cash accounts by our clients. Although the
amount of these revenue-sharing payments to FSH is not charged directly in the calculation of the interest
rate paid by clients on credit solutions facilitated by UPTIQ or the yield earned by clients on cash
management solutions facilitated by UPTIQ or Flourish, the compensation earned by UPTIQ and Flourish
is an expense of the third-party financial institutions that informs the interest rate paid by clients on credit
solutions and the yield earned by clients on cash management solutions. FSH distributes this revenue to us
when we are licensed to receive such revenue (or when no such license is required) and the distribution is
not otherwise legally prohibited. This revenue is also revenue for FSH’s and our common parent company,
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Focus. Additionally, the volume generated by our clients’ transactions allows Focus to negotiate better
terms with UPTIQ and Flourish, which benefits Focus and us. Accordingly, we have a conflict of interest
when recommending UPTIQ’s and Flourish’s services to clients because of the compensation to us and to
our affiliates, FSH and Focus, and the transaction volume to UPTIQ and Flourish. We mitigate this conflict
by: (1) fully and fairly disclosing the material facts concerning the above arrangements to our clients,
including in this Brochure; and (2) offering UPTIQ’s and Flourish’s solutions to clients on a strictly
nondiscretionary and fully disclosed basis, and not as part of any discretionary investment services.
Additionally, we note that clients who use UPTIQ’s and Flourish’s services will receive product-specific
disclosures from the third-party financial institutions and other unaffiliated third-party intermediaries that
provide services to our clients.
We have an additional conflict of interest when we recommend credit solutions to our clients because our
interest in continuing to receive investment advisory fees from client accounts gives us a financial incentive
to recommend that clients borrow money rather than liquidate some or all of the assets we manage.
Credit Solutions
Clients retain the right to pledge assets in accounts generally, subject to any restrictions imposed by clients’
custodians. While credit solution programs that we offer facilitate secured loans through third-party
financial institutions, clients are free instead to work directly with institutions outside such programs.
Because of the limited number of participating third-party financial institutions, clients may be limited in
their ability to obtain as favorable loan terms as if the client were to work directly with other banks to
negotiate loan terms or obtain other financial arrangements.
Clients should also understand that pledging assets in an account to secure a loan involves additional risk
and restrictions. A third-party financial institution has the authority to liquidate all or part of the pledged
securities at any time, without prior notice to clients and without their consent, to maintain required
collateral levels. The third-party financial institution also has the right to call client loans and require
repayment within a short period of time; if the client cannot repay the loan within the specified time period,
the third-party financial institution will have the right to force the sale of pledged assets to repay those loans.
Selling assets to maintain collateral levels or calling loans may result in asset sales and realized losses in a
declining market, leading to the permanent loss of capital. These sales also may have adverse tax
consequences. Interest payments and any other loan-related fees are borne by clients and are in addition to
the advisory fees that clients pay us for managing assets, including assets that are pledged as collateral. The
returns on pledged assets may be less than the account fees and interest paid by the account. Clients should
consider carefully and skeptically any recommendation to pursue a more aggressive investment strategy in
order to support the cost of borrowing, particularly the risks and costs of any such strategy. More generally,
before borrowing funds, a client should carefully review the loan agreement, loan application, and other
forms and determine that the loan is consistent with the client’s long-term financial goals and presents risks
consistent with the client’s financial circumstances and risk tolerance.
We use UPTIQ to facilitate credit solutions for our clients.
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Cash Management Solutions
For cash management programs, certain third-party intermediaries provide administrative and settlement
services to our clients. Engaging the third-party financial institutions and other intermediaries to provide
cash management solutions does not alter the manner in which we treat cash for billing purposes. Clients
should understand that in rare circumstances, depending on interest rates and other economic and market
factors, the yields on cash management solutions could be lower than the aggregate fees and expenses
charged by the third-party financial institutions, the intermediaries referenced above, and us. Consequently,
in these rare circumstances, a client could experience a negative overall investment return with respect to
those cash investments. Nonetheless, it might still be reasonable for a client to participate in a cash
management program if the client prefers to hold cash at the third-party financial institutions rather than at
other financial institutions (e.g., to take advantage of FDIC insurance).
We use UPTIQ and Flourish to facilitate cash management solutions for our clients.
Focus Risk Solutions
We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk
Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners,
LLC (“Focus”).
FRS assists our clients with regulated insurance sales activity by advising our clients on insurance matters
and placing insurance products for them and/or referring our clients to certain third-party insurance brokers
(the “Brokers”), with whom FRS has agreements, which either separately or together with FRS place
insurance products for them. If FRS places an insurance product or refers one of our clients to a Broker and
there is a subsequent purchase of insurance through the Broker, then FRS will receive a portion of the
upfront and/or ongoing commissions associated with the sale by the insurance carrier with which the policy
was placed. The amount of revenue earned by FRS for the sale of these insurance products will vary over
time in response to market conditions and will also differ based on the type of insurance product sold and
which Broker placed the policy. The amount of insurance commission revenue earned by FRS is considered
for purposes of determining the amount of additional compensation that certain of our financial
professionals are entitled to receive. This revenue is also revenue for our and FRS’s common parent
company, Focus.
Additionally, in exchange for allowing certain of the Brokers to participate in the FRS platform and, thereby,
to offer their services to our clients and certain of our affiliates’ clients, FRS receives periodic fees (the
“Platform Fees”) from such Brokers. The Platform Fees are expected to change over time. Such Platform
Fees are revenue for FRS and, ultimately, for our common parent company, Focus, but we do not share in
such revenue. FRS also indirectly benefits from our clients’ use of the services insofar as such use
incentivizes the Brokers to maintain their relationship with FRS and to continue paying Platform Fees to
FRS, which could also support increases in the overall amount of the Platform Fee rates in the future.
Accordingly, we have a conflict of interest when recommending FRS’s services to clients because of the
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compensation to certain of our financial professionals and to our affiliates, FRS and Focus. We address this
conflict by: (1) fully and fairly disclosing the material facts concerning the above arrangements to our
clients, including in this Brochure; (2) offering FRS solutions to clients on a strictly nondiscretionary and
fully disclosed basis, and not as part of any discretionary investment services; and (3) not sharing in any
portion of the Platform Fees. Additionally, we note that clients who use FRS’s services will receive product-
specific disclosure from the Brokers and insurance carriers and other unaffiliated third-party intermediaries
that provide services to our clients.
The insurance premium is ultimately dictated by the insurance carrier, although in some circumstances the
Brokers or FRS may have the ability to influence an insurance carrier to lower the premium of the policy.
The final rate may be higher or lower than the prevailing market rate, and may be higher than if the policy
was purchased directly through the Broker without the assistance of FRS. We can offer no assurances that
the rates offered to you by the insurance carrier are the lowest possible rates available in the marketplace.
FourThought has a business relationship with other Focus firms that is material to our advisory business or
to our clients. Under certain circumstances we offer our clients the opportunity to invest in pooled
investment vehicles managed by SCS and Origin. SCS and Origin provides these services to such clients
pursuant to limited liability company agreement or limited partnership agreement documents and in
exchange for a fund-level management fee and performance fee paid by our clients and not by us. SCS and
Origin, like FourThought, are an indirect wholly owned subsidiary of Focus LLC and is therefore under
common control with FourThought. The allocation of our clients’ assets to SCS and Origin’s pooled
investment vehicles, rather than to an unaffiliated investment manager, increases SCS and Origin’s, and
indirectly, Focus LLC’s, compensation and revenue. As a consequence, Focus LLC has a financial incentive
to cause FourThought to recommend that our clients invest in SCS and Origin’s pooled investment vehicles,
which creates a conflict of interest with FourThought clients who invest, or are eligible to invest, in SCS
and Origin’s pooled investment vehicles. More information about Focus LLC can be found at
www.focusfinancialpartners.com.
We believe this conflict is mitigated because of the following factors: (1) this arrangement is based on our
reasonable belief that investing a portion of FourThought’s clients’ assets in SCS and Origin’s investment
vehicles is in the best interests of the clients; (2) SCS and Origin and its investment vehicles have met the
due diligence and performance standards that we apply to outside, unaffiliated investment managers; (3)
clients will invest in the pooled investment vehicles on a nondiscretionary basis through the completion of
subscription documentation; (4) subject to redemption restrictions, we are willing and able to reallocate
FourThought client assets to other unaffiliated or affiliated investment vehicles, in part or in whole, if SCS
and Origin’s services become unsatisfactory in our judgment and at our sole discretion; and (5) we have fully
and fairly disclosed the material facts regarding this relationship to you, including in this Brochure, and
FourThought clients who invest in SCS and Origin’s pooled investment vehicles have given their informed
consent to those investments.
Focus Financial Partners
As noted above in response to Item 4, certain investment vehicles affiliated with CD&R collectively are
indirect majority owners of Focus LLC, and certain investment vehicles affiliated with Stone Point are
indirect owners of Focus LLC. Because FourThought is an indirect, wholly-owned subsidiary of Focus LLC,
CD&R and Stone Point investment vehicles are indirect owners of FourThought.
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SmartAsset
As stated earlier in this Brochure, FourThought is a wholly owned subsidiary of Focus. Focus is also one of
several minority investors in SmartAsset, which seeks to match prospective advisory clients with investment
advisers. Focus has one director on SmartAsset’s board. FourThought’s payment of a fee to SmartAsset
benefits SmartAsset’s investors, including Focus, our parent company.
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Item 11. Code of Ethics
FourThought has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”)
that sets forth the standards of conduct expected of its Supervised Persons. FourThought’s Code of Ethics
contains written policies reasonably designed to prevent certain unlawful practices such as the use of
material non-public information by the Firm or any of its Supervised Persons and the trading by the same
of securities ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of FourThought’s personnel to report their personal securities
holdings and transactions and obtain pre-approval of certain investments . However, the Firm’s Supervised
Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable
manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established
recognizing that some securities trade in sufficiently broad markets to permit transactions by certain
personnel to be completed without any appreciable impact on the markets of such securities. Clients and
prospective clients may contact FourThought to request a copy of its Code of Ethics.
FourThought recommends that certain of our clients invest in a private investment fund managed by an
affiliated Focus partner firm. Please refer to Items 4, 5 and 10 for additional information.
Item 12. Brokerage Practices
Recommendation of Broker-Dealers for Client Transactions
FourThought generally recommends that clients utilize the custody, brokerage and clearing services of
National Financial Services LLC and Fidelity Brokerage Services LLC (together with affiliates, “Fidelity”)
for investment management accounts. The final decision to custody assets with Fidelity is at the discretion
of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client
is acting as either the plan sponsor or IRA accountholder. FourThought is not affiliated with Fidelity. Fidelity
provides FourThought with access to its institutional trading and custody services, which are typically not
available to retail investors.
Factors which FourThought considers in recommending Fidelity or any other broker-dealer/custodian to
clients include their respective financial strength, reputation, execution capabilities, pricing, research and
service. Fidelity enables the Firm purchase equity securities online for many clients at no charge, to obtain
many mutual funds without transaction charges and other mutual funds and other securities at nominal
transaction charges. The commissions and/or transaction fees charged by Fidelity may be higher or lower
than those charged by other Financial Institutions.
FourThought seeks competitive rates but may not necessarily obtain the lowest possible commission rates
for client transactions.
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FourThought periodically reviews the quality of the services provided by Fidelity in light of its duty to
obtain best execution.
Software and Support Provided by Financial Institutions
FourThought receives without cost from Fidelity administrative support, computer software, related
systems support, as well as other third-party support as further described below (together "Support") which
allow FourThought to better monitor client accounts maintained at Fidelity and otherwise conduct its
business. FourThought receives the Support without cost because the Firm renders investment management
services to clients that maintain assets at Fidelity. The Support is not provided in connection with securities
transactions of clients (i.e., not “soft dollars”). The Support benefits FourThought, but not its clients directly.
Clients should be aware that FourThought’s receipt of economic benefits such as the Support from a broker-
dealer creates a conflict of interest since these benefits will influence the Firm’s choice of broker-dealer over
another that does not furnish similar software, systems support or services, especially because the support
is contingent upon clients placing a certain level(s) of assets at Fidelity. In fulfilling its duties to its clients,
FourThought endeavors at all times to put the interests of its clients first and has determined that the
recommendation of Fidelity is in the best interest of clients and satisfies the Firm's duty to seek best execution.
Specifically, FourThought receives the following benefits from Fidelity: i) receipt of duplicate client
confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its
institutional traders; iii) access to block trading which provides the ability to aggregate securities
transactions and then allocate the appropriate shares to client accounts; and iv) access to an electronic
communication network for client order entry and account information.
Fidelity also makes available to the Firm, at no additional charge, certain research and brokerage services,
including research services obtained by Fidelity directly from independent research companies, as selected
by FourThought (within specified parameters). These research and brokerage services are used by the Firm
to manage accounts for which it has investment discretion. Without this arrangement, the Firm might be
compelled to purchase the same or similar services at its own expense.
These services generally are available to independent investment advisors on an unsolicited basis, at no
charge to them so long as a certain amount of the advisor’s clients’ assets are maintained in accounts at
Fidelity. Fidelity’s services include brokerage services that are related to the execution of securities
transactions, custody, research, including that in the form of advice, analyses and reports, and access to
mutual funds and other investments that are otherwise generally available only to institutional investors or
would require a significantly higher minimum initial investment.
For client accounts maintained in its custody, Fidelity generally does not charge separately for custody
services but is compensated by account holders through commissions or other transaction-related or asset-
based fees for securities trades that are executed through Fidelity or that settle into Fidelity accounts.
Fidelity also makes available to the Firm other products and services that benefit the Firm but may not
benefit its clients’ accounts. These benefits may include national, regional or Firm specific educational
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events organized and/or sponsored by Fidelity. Other potential benefits may include occasional business
entertainment of personnel of FourThought by Fidelity personnel, including meals, invitations to sporting
events, including golf tournaments, and other forms of entertainment, some of which may accompany
educational opportunities. Other of these products and services assist FourThought in managing and
administering clients’ accounts. These include software and other technology (and related technological
training) that provide access to client account data (such as trade confirmations and account statements),
facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide
research, pricing information and other market data, facilitate payment of the Firm's fees from its clients’
accounts, and assist with back-office training and support functions, recordkeeping and client reporting.
Many of these services generally may be used to service all or some substantial number of the Firm’s
accounts, including accounts not maintained at Fidelity. Fidelity also makes available to FourThought other
services intended to help the Firm manage and further develop its business enterprise. These services may
include professional compliance, legal and business consulting, publications and conferences on practice
management, information technology, business succession, regulatory compliance, employee benefits
providers, human capital consultants, insurance and marketing. In addition, Fidelity may make available,
arrange and/or pay vendors for these types of services rendered to the Firm by independent third parties.
Fidelity may discount or waive fees it would otherwise charge for some of these services or pay all or a part
of the fees of a third-party providing these services to the Firm. While, as a fiduciary, FourThought
endeavors to act in its clients’ best interests, the Firm's recommendation that clients maintain their assets in
accounts at Fidelity may be based in part on the benefits received and not solely on the nature, cost or quality
of custody and brokerage services provided by Fidelity, which creates a potential conflict of interest.
Brokerage for Client Referrals
FourThought does not consider, in selecting or recommending broker-dealers, whether the Firm receives
client referrals from the Financial Institutions or other third party.
Directed Brokerage
Clients are permitted to direct FourThought in writing to use a particular Financial Institution to execute
some or all transactions for the client. If clients do so, the client will negotiate terms and arrangements for the
account with that Financial Institution and the Firm will not seek better execution services or prices from
other Financial Institutions or be able to “batch” client transactions for execution through other Financial
Institutions with orders for other accounts managed by FourThought (as described above). As a result, the
client may pay higher commissions or other transaction costs, greater spreads or may receive less favorable
net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best
execution, FourThought may decline a client’s request to direct brokerage if, in the Firm’s sole discretion,
such directed brokerage arrangements would result in additional operational difficulties or violate
restrictions imposed by other broker-dealers (as further discussed below).
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Disclosure Brochure
December 26, 2025
FourThought Financial
Trade Aggregation
FourThought may (but is not obligated to) combine or “batch” such orders to obtain best execution, to
negotiate more favorable commission rates or to allocate equitably among the Firm’s clients differences in
prices and commissions or other transaction costs that might not have been obtained had such orders been
placed independently. Under this procedure, transactions will be averaged as to price and allocated among
FourThought’s clients pro rata to the purchase and sale orders placed for each client on any given day. To
the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including
securities in which FourThought’s Supervised Persons may invest, the Firm is required to do so in a manner
that is equitable to participating clients. FourThought does not receive any additional compensation or
remuneration as a result of the aggregation.
Item 13. Review of Accounts
Account Reviews
FourThought monitors client portfolios on an ongoing basis, and account reviews are conducted on at least
a quarterly basis. Such reviews are conducted by the Firm’s investment adviser representatives and their
associates as appropriate. All investment advisory clients are encouraged to discuss their needs, goals and
objectives with FourThought and to keep the Firm informed of any changes thereto. The Firm contacts
ongoing investment advisory clients at least annually to review its previous services and/or
recommendations discuss the impact resulting from any changes in the client’s financial situation and/or
investment objectives.
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements directly
from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise
requested, clients may also receive written or electronic reports from FourThought and/or an outside service
provider, which contain certain account and/or market-related information, such as an inventory of account
holdings or account performance. Clients should compare the account statements they receive from their
custodian with any documents or reports they receive from FourThought or an outside service provider.
Item 14. Client Referrals and Other Compensation
Client Referrals
FourThought does not receive compensation for any referrals it may recommend to clients.
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Disclosure Brochure
December 26, 2025
FourThought Financial
SmartAsset
We pay a fee to participate in an online matching program, SmartAsset, which seeks to match prospective
advisory clients who have expressed an interest in finding an investment adviser with investment advisory
firms such as FourThought. The adviser matching program provides the name and contact information of
such persons to the advisory firms as potential leads. For our participation in the program, we pay $199 per
lead (“lead fee”) for prospective clients with investible assets of more than $1 million. The lead fee we have
agreed to pay gives SmartAsset a financial incentive to match prospective clients to our firm. The lead fee
is payable regardless of whether the prospect becomes our advisory client. Atlas does not increase the fees
of advisory clients matched through the SmartAsset program to cover the lead fee. SmartAsset is not a
current investment client or investor of FourThought.
Other Compensation
See Item 10 (insurance solutions and cash management solutions) and Item 12 (economic benefits received
from Fidelity, conflicts of interest)
FourThought’s parent company is Focus Financial Partners, LLC (“Focus”). From time to time, Focus
holds partnership meetings and other industry and best-practices conferences, which typically include
FourThought, other Focus firms and external attendees. These meetings are first and foremost intended to
provide training or education to personnel of Focus firms, including FourThought. However, the meetings
do provide sponsorship opportunities for asset managers, asset custodians, vendors and other third-party
service providers. Sponsorship fees allow these companies to advertise their products and services to
Focus firms, including FourThought. Although the participation of Focus firm personnel in these meetings
is not preconditioned on the achievement of a sales target for any conference sponsor, this practice could
nonetheless be deemed a conflict as the marketing and education activities conducted, and the access
granted, at such meetings and conferences could cause FourThought to focus on those conference sponsors
in the course of its duties. Focus attempts to mitigate any such conflict by allocating the sponsorship fees
only to defraying the cost of the meeting or future meetings and not as revenue for itself or any affiliate,
including FourThought. Conference sponsorship fees are not dependent on assets placed with any specific
provider or revenue generated by such asset placement.
The following entities have provided conference sponsorship to Focus since January 1, 2024 to February 1,
2025: Advent Software, Inc. (includes SS&C), BlackRock, Inc., Blackstone Administrative Services
Partnership L.P., Capital Integration Systems LLC (CAIS), Charles Schwab & Co., Inc., Confluence
Technologies Inc., Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates), Fidelity
Brokerage Services LLC and Fidelity Distributors Company LLC (includes Fidelity Institutional Asset
Management and FIAM), Flourish Financial LLC, Franklin Distributors, LLC (includes O’Shaughnessy
Asset Management, L.L.C. (OSAM) and CANVAS), K&L Gates LLP, Nuveen Securities, LLC, Orion
Advisor Technology, LLC, Pinegrove Capital Partners LLC (includes Brookfield Oaktree Wealth
Solutions), Practifi, Inc., Salus GRC, LLC, Stone Ridge Asset Management LLC, The Vanguard Group,
Inc., TriState Capital Bank, UPTIQ, Inc.
You can access a more recently updated list of recent conference sponsors on Focus’ website through the
following link:
https://www.focusfinancialpartners.com/conference-sponsors
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Disclosure Brochure
December 26, 2025
FourThought Financial
Item 15. Custody
FourThought is deemed to have custody of client funds and securities because the Firm is given the ability
to debit client accounts for payment of the Firm’s fees. As such, client funds and securities are maintained
at one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such
qualified custodians will send account statements to clients at least once per calendar quarter that typically
detail any transactions in such account for the relevant period. FourThought also has custody of client assets
through standing letters of authorization (“SLOAs”) that authorize FourThought to direct the custodian to
transfer client funds to third parties. FourThought relies on the SEC no-action letter to the IAA in 2017 for
relief from the custody audit requirement.
As discussed in Item 13, FourThought will also send, or otherwise make available, periodic supplemental
reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions
and compare them to those received from FourThought. Any other custody disclosures can be found in the
Firm’s Form ADV Part 1.
Item 16. Investment Discretion
FourThought is given the authority to exercise discretion on behalf of clients. FourThought is considered
to exercise investment discretion over a client’s account if it can effect and/or direct transactions in client
accounts without first seeking their consent. FourThought is given this authority through a power-of-
attorney included in the agreement between FourThought and the client. Clients may request a limitation
on this authority (such as certain securities not to be bought or sold).
Item 17. Voting Client Securities
FourThought does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients
receive proxies directly from the Financial Institutions where their assets are custodied and may contact the
Firm at the contact information on the cover of this brochure with questions about any such issuer
solicitations.
Item 18. Financial Information
FourThought is not required to disclose any financial information due to the following:
• The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more
in advance of services rendered;
• The Firm does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
• The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
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