Overview
Assets Under Management: $248 million
High-Net-Worth Clients: 55
Average Client Assets: $3 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Clients
Number of High-Net-Worth Clients: 55
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 63.06
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 713
Discretionary Accounts: 709
Non-Discretionary Accounts: 4
Regulatory Filings
CRD Number: 330574
Last Filing Date: 2025-03-03 00:00:00
Website: https://fullfinancial.com
Form ADV Documents
Primary Brochure: FULL FINANCIAL INC. ADV PART 2 (2025-06-04)
View Document Text
Part 2A and 2B of Form ADV: Firm Brochure
ITEM 1
Cover Page
Full Financial Inc.
Matthew J. Rillos
Joseph L. Rillos
16475 W. 51st Place
Golden, CO 80403
www.fullfinancial.com
team@fullfinancial.com
June 4th, 2025
This brochure provides information about the qualifications and business practices of Full Financial Inc. If you
have any questions about the contents of this brochure, please contact us at team@fullfinancial.com. The
information in this brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority. Registration does not imply a certain level of skill or training.
Additional information about Full Financial Inc. also is available on the SEC’s website at
www.adviserinfo.sec.gov.
Firm IARD/CRD # 330574
ITEM 2
Material Changes
These are the material changes since the last annual update of this brochure.
2025.06.04 – Material Change Updates
- Chief Investment Officer has been identified in Appendix A
ITEM 3
Table Contents
ITEM 4: ADVISORY BUSINESS ......................................................................................... 4
ITEM 5: FEES AND COMPENSATION ................................................................................ 5
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ...................... 6
ITEM 7: TYPES OF CLIENTS ............................................................................................. 6
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ......... 6
ITEM 9: DISCIPLINARY INFORMATION ............................................................................. 7
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ......................... 7
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING ................................................................................................ 8
ITEM 12: BROKERAGE PRACTICES .................................................................................. 8
ITEM 13: REVIEW OF ACCOUNTS .................................................................................... 9
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION .......................................... 9
ITEM 15: CUSTODY ........................................................................................................ 10
ITEM 16: INVESTMENT DISCRETION .............................................................................. 10
ITEM 17: VOTING CLIENT SECURITIES .......................................................................... 10
ITEM 18: FINANCIAL INFORMATION ............................................................................... 10
PART 2B ITEM 1: COVER PAGE MATTHEW J. RILLOS .................................................... 12
PART 2B ITEM 1: COVER PAGE JOSEPH L. RILLOS ....................................................... 15
PRIVACY POLICY ............................................................................................................ 18
ITEM 4
Advisory Board
OVERVIEW
Full Financial Inc. is in the business of providing investment advice. Full Financial Inc. [Full
Financial] became incorporated in the state of Colorado on February 29th 2024. The principal
owner of Full Financial Inc. is Matt Rillos. Full Financial Inc. is an SEC registered advisor.
SERVICES
Full Financial Inc. provides a service of advising clients on the allocations of investments. We also
provide counsel regarding financial planning, business planning, funding education, retirement
planning, life and health insurance, estate planning, tax planning, for individuals and small
businesses. Full Financial Inc. is a fiduciary and as such we provide full disclosure to our clients
and always act in the best interest of our clients. We have discretionary authority over clients’
assets that we manage which allows us to make and implement investment decisions without the
clients’ written or verbal approval.
Full Financial Inc. generally provides investment advice on equity securities, investment company
securities, e.g. variable life insurance, annuities, mutual funds, exchange traded funds, and limited
partnerships. We use commercially available services concerning investments as well as,
taxation, numerous financial newspapers, periodicals, and issuer-prepared information. Outside
consultants may also be employed to provide additional expertise in certain situations.
In addition to investment advice, we can provide comprehensive financial planning, supplying
analysis and recommendations in the areas of business planning, education planning, retirement
planning, life and health insurance, estate planning, tax planning, as well as investments for
individuals and small businesses.
Full Financial Inc. provides investment advice on mutual funds, exchange traded funds, stocks,
bonds, options, certificates of deposit, money markets, and cash. Advice on investment types
outside of those listed above is limited. We can tailor our services based on the needs of a client.
For example, a client can impose restriction on investing in certain securities or types of securities.
ASSETS UNDER MANAGEMENT
As of 3/1/2025 Full Financial Inc. is managing $247,982,500 of assets under management for 264
clients.
• $225,293,145 for 259 clients on a discretionary basis.
• $22,689,355 for 5 clients on a non-discretionary basis.
ITEM 5
Fees and Compensation
ASSETS UNDER MANAGEMENT FEES
Full Financial Inc. provides a service of advising clients on the allocations of investments. Full
Financial Inc. charges a fee of 1% annually on the first $2 million dollars of assets under
advisement and a fee of 0.5% annually on all assets above $2 million dollars of assets under
advisement. This fee is billed quarterly and in advance. The service may be cancelled at any time
by the client. When a cancellation occurs mid-quarter the client may request that fees be
refunded on a pro rata basis. Our fees may be negotiable.
ACCOUNT MINIMUMS
Full Financial Inc. has account minimums which are determined by each individual advisor.
Account minimums may be negotiable.
HOURLY FEES
Full Financial Inc. is not for hire on an hourly basis.
COLLECTING FEES
In general, accounts under management will have their fee deducted from the accounts that are
being managed. Clients will receive a notice of the quarterly fee amount in their quarterly report.
OTHER FEES
Clients may pay for transaction fees through a custodian. We use Charles Schwab & Co., Inc. as
a custodian for individual investment accounts and Voya Financial, Principal, or ADP, for most
401k accounts. We use Mainstar Trust for self-directed IRA accounts. We use CollegeInvest for
Colorado 529 plans. These fees are reasonable and customary for buying and selling securities.
Some exchange traded funds and mutual funds at Charles Schwab & Co., Inc. do not have a
transaction fee. Full Financial Inc. does not receive any compensation from Charles Schwab &
Co., Inc., Voya Financial, Principal, ADP, Mainstar Trust or CollegeInvest. It is possible that lower
fees for comparable services may be available from other sources.
COMPENSATION FROM INVESTMENT PRODUCTS
Full Financial Inc. does not receive any compensation or commissions from the sale of investment
products. Full Financial Inc. specializes in no-load and low transaction fee investments. Joe
Rillos is licensed as an insurance agent in the state of Colorado and does receive commissions on
the sale of life and health insurance. Commissions from the sale of insurance products create a
conflict of interest and provides an incentive to recommend insurance products based on the
compensation received. We mitigate this risk by always putting our clients’ best interest first.
BROKERS
We primarily use Charles Schwab & Co., Inc.as a broker due to their discounted fees, vast
selection of investment choices, trading efficiencies, as convenience to the client, added
protection for the client, and as an efficiency for our own business. Clients do have the option to
purchase investment products that we recommend through other brokers or agents that are not
affiliated with us.
ITEM 6
Performance-Based Fees and Side-By-Side Management
Full Financial Inc. does not charge performance-based fees and does not have any conflicts of
interest with side-by-side management.
ITEM 7
Types of Clients
Full Financial Inc. generally provides investment advice to individuals, trusts, small businesses,
retirement plans, and foundations. Each advisor has their own aggregate account minimum for
opening or maintaining an account that may be negotiable.
ITEM 8
Methods of Analysis, Investment Strategies and Risk of Loss
METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
Full Financial Inc. recommends to investment advisory clients that they maintain a diversified
portfolio of investments. Implementing the recommendations requires that the client work closely
with their attorney and accountant. We generally construct portfolios to include multiple asset
classes and seek to minimize individual security risk. We generally use no-load mutual funds,
exchange traded funds, stocks, bonds, or CD’s that can be traded electronically and have a
reasonable number of shares being traded daily. Full Financial Inc. also has the ability to trade
options for those clients that may be interested in this service.
The construction of portfolios involves considering the client’s willingness for risk, desired potential
return or loss, goals for the funds, tax considerations, and the length of time until the funds are
needed. We use multiple tools to help construct a portfolio and to determine the historical
risk/reward of the portfolio. In analyzing stocks, we use multiple services to provide advice due to
the limited nature of our own bottom-up analysis. We also use multiple services to screen mutual
fund and exchange traded fund investments to determine their applicability to a client’s portfolio,
the historical investment performance, and our projection of their future potential.
We try to minimize frequent trading of securities as this can affect investment performance through
increased brokerage costs, taxes and increase the probability of bad timing.
Investing in securities involves risk of loss that clients should be prepared to bear.
ITEM 9
Disciplinary Information
Neither Full Financial Inc. nor any of its owners or employees has any legal or disciplinary events
to report.
ITEM 10
Other Financial Industry Activities and Affiliations
Full Financial Inc. uses Charles Schwab & Co., Inc. Institutional as a broker for the majority of our
clients. We also use Voya Financial, Principal, or ADP for most 401k accounts. We use Mainstar
Trust for self-directed IRA accounts. We use CollegeInvest for Colorado 529 plans. We primarily
use Charles Schwab & Co., Inc. due to their discounted fees, vast selection of investment choices,
trading efficiencies, as a convenience to the client, added protection for the client, and as an
efficiency for our own business.
As a service to our clients Full Financial Inc. may recommend other industry partners from time to
time such as lawyers, accountants, estate planners, real estate agents, or lenders. Full Financial
Inc. does not have any material relationships with these industry partners, nor do we receive any
material compensation for such referrals. Joseph Rillos is a licensed insurance agent in the state
of Colorado. He can provide accident and health insurance as well as life insurance for clients in
the state of Colorado. Insurance agents are paid commissions and thus create a conflict of
interest. We mitigate this conflict by always putting the best interest of the client first.
Full Financial Inc. is an investment advisor. We are not a broker dealer, not a futures commission
merchant, not a commodity pool operator, not a commodity trading advisor, nor do we recommend
other investment advisors to our clients.
ITEM 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Our company philosophy is to do the right thing and to treat people the way we wish to be treated.
Our goal is to provide the same investment advice to a client that they would arrive at on their own
if they had the same time, knowledge, ability, and inclination that we do. Our code of ethics is
based on seven principals of integrity, objectivity, competence, fairness, confidentiality,
professionalism, and diligence. All supervised persons are required to provide the CCO with
written acknowledgement of the code of ethics as well as reporting all violations to the CCO. A
copy of our code of ethics is available upon request. We make investment suggestions for clients
that are in line with the same investments that we use for our own personal investments
(assuming similar risk/reward profiles). Because of this we buy and sell the same or similar
securities for our own personal portfolios as we do for our clients. Buying and selling the same
securities as a client creates a conflict of interest. We mitigate this risk with our fiduciary
responsibility of always acting in the best interest of our clients.
We review each client’s portfolio at least on a quarterly basis and we review our own personal
portfolios at the same time. Implementation of recommendations often results in the same or
similar trades performed in our own accounts as well as those of a client. In most cases trades
associated with quarterly portfolio changes are implemented on the same one or two trading days
in all accounts.
ITEM 12
Brokerage Practices
See item Number 10.
We have an incentive to recommend Charles Schwab & Co., Inc. to clients in order to make our
business more efficient. Having all or most of our accounts at Charles Schwab & Co., Inc. allows
us to manage client portfolios, place trades, perform client fund transfers, and service accounts in
a more efficient manner. The same is true for recommending Voya Financial, Principal, or ADP for
most 401k accounts. We use Mainstar Trust for self-directed IRA accounts. We use CollegeInvest
for Colorado 529 plans.
As a benefit for advisors that use Charles Schwab & Co., Inc. they provide multiple research
capabilities for investments such as mutual funds, exchange traded funds, bonds, stocks, and
CD’s. We consider this a benefit to us and to our clients as we use these tools to help select the
most appropriate investments for a client.
We do not receive any direct compensation from recommending Charles Schwab & Co., Inc.,
Voya Financial, Principal, ADP, Mainstar Trust, or CollegeInvest. Any soft-dollar value we may
receive such as free investment research benefits are insignificant. Nor do we receive any client
referrals by recommending any of these firms.
While we prefer for most of our clients to use Charles Schwab & Co., Inc. we may consider
allowing a client to use another broker. By recommending Charles Schwab & Co., Inc. or any
such broker this may not achieve the most favorable execution of client transactions and may cost
clients more money. While we feel Charles Schwab & Co., Inc. provides good value it is
impossible for us to determine if they are the true low-cost leader. In addition, permitting a client
to choose their own brokerage firm may not achieve the most favorable execution of client
transactions and may cost clients more money. We believe Charles Schwab & Co., Inc.,
Principal, ADP, and Mainstar Trust all provide a fair value to the client.
Occasionally we will place block orders (buy many shares of a security for multiple clients and
then distribute the shares to the appropriate accounts) with Charles Schwab & Co., Inc.. This
does not reduce the transaction cost for the client, but it may have the potential to ensure that
orders are executed at a better price or a more consistent price for all clients.
ITEM 13
Review of Accounts
We review each of our client accounts at least on a quarterly basis. We are looking at the
portfolios to determine if we need to recommend any investment changes due to performance,
rebalancing, investment strategy, risk profile, market conditions, client requests, client cash needs,
or management fees. The portfolios are reviewed by at least one or more of the following
individuals quarterly: Matthew Rillos or Joseph Rillos. Client accounts may be reviewed more
frequently if extreme market conditions or significant changes have occurred. These changes
could be market gains/losses, significant changes in a particular investment, new assets, or other
reasons.
Clients receive a quarterly report from us that shows investment performance against
benchmark(s), asset allocation percentages, specific investments and current values,
contributions and gains/losses, returns, and a summary of fees to be deducted from accounts.
We also provide tax information as needed in a client’s end of year report.
ITEM 14
Client Referrals and Other Compensation
Full Financial Inc. generally does not provide any client referral compensation. If Full Financial
Inc. choses to provide any referral compensation, then full disclosure would be made to the new
client at the time of the referral.
ITEM 15
Custody
Full Financial Inc. does not maintain custody of client’s assets. Assets are held in the custody of
Charles Schwab & Co., Inc., Voya Financial, Principal, ADP, Mainstar Trust, or CollegeInvest.
When clients make new contributions, those funds go to the appropriate custodians and are not
held or deposited by Full Financial Inc.
Charles Schwab & Co., Inc., Principal, ADP, Mainstar Trust, Voya Financial, CollegeInvest, and the
mutual fund companies provide monthly or quarterly statements to clients that are available
electronically or by mail.
Clients are encouraged to compare the account statements they receive from us and the qualified
custodian for any discrepancies.
ITEM 16
Investment Discretion
Full Financial Inc. provides discretionary advice. This means that any investment advice we
recommend can be implemented without the client’s approval. If clients have questions, they can
contact us to get their questions answered. Discretionary authority also authorizes Full Financial
Inc. to make investment changes which are believed to be in the best interest of the client without
any client notification. Clients at Charles Schwab & Co., Inc. sign a power of attorney that allows
us to place trades on their behalf. These trades are in accordance with the discretionary policies
above. Clients that have retirement plans at Principal, ADP, or Voya Financial are responsible for
their own investment selections. Full Financial Inc. will help provide investment advice for
Principal, ADP, and Voya Financial clients upon their request.
ITEM 17
Voting Client Securities
Clients are responsible for voting for their own securities. Clients will receive their proxies or
other solicitation directly from their custodian or transfer agent. Clients are always welcome to
contact us via phone or e-mail regarding these solicitations and seek our advice. Clients may
request for Full Financial Inc. to vote securities on their behalf. If Full Financial Inc. is asked to
vote proxies for a client we will always vote in the best interest of the client.
ITEM 18
Financial Information
We have discretionary authority over funds in clients’ accounts, but we do not have any financial
conditions that would be reasonably likely to impair our ability to meet contractual commitments to
our clients. We collect fees on a quarterly basis. We do not collect fees of more than $1,200 per
client six months or more in advance. We have never been a subject of a bankruptcy as a
corporation nor as individuals.
Part 2B of Form ADV: Brochure Supplement
PART 2B ITEM 1
Cover Page Matthew J. Rillos
Matthew J. Rillos
team@fullfinancial.com
16475 W. 51st Place
Golden, CO 80403
Full Financial Inc.
16475 W. 51st Place
Golden, CO 80403
www.fullfinancial.com
June 4th, 2025
This brochure supplement provides information about Matthew J. Rillos that supplements the Full Financial
Inc. brochure. You should have received a copy of that brochure. Please contact Matt Rillos at
Team@FullFinancial.com if you did not receive the Full Financial Inc. brochure or if you have any question
about the contents of this supplement.
Additional information about Matthew Rillos is available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 2
Educational Background and Business Experience
Matthew Rillos (Matt) was born in 1977 and is the Founder and President of Full Financial Inc. Mr.
Rillos is a class of 2000 graduate of the United States Air Force Academy, receiving his bachelor’s
degree in mechanical engineering. Matt served the U.S. Air Force as an Acquisition officer from
2000-2005. In the Air Force he was a program manager responsible for a +$200M government
program. Following the Air Force, Matt worked at Lockheed Martin from 2005-2007. Some of his
responsibilities included providing direction and management for multimillion dollar corporate
satellite investments. In 2008 Matt began his wealth management career and purchased
ownership in Financial Counseling Associates, Inc. (FCA). He served as President of FCA from
2018 through 2024. On February 29th, 2024, Matt founded Full Financial Inc. and is currently
serving as President.
Matt holds a Series 65 securities license (Investment Advisor). Matt completed the three year
educational requirement for the Certified Financial Planner designation in August of 2008 at the
College for Financial Planning in Englewood, Colorado. Matt has also passed the Certified
Financial Planner certification exam and is a CERTIFIED FINANCIAL PLANNER™ practictioner.
The CERTIFIED FINANCIAL PLANNER™ designation requires a bachelor of science degree,
successful completion of financial education courses as approved by the CFP® board, successful
passing of the comprehensive CFP® exam, a minimum of three years of experience, and a
commitment to the CFP® boards ethics requirements. The designation also requires 30 hours of
continuing education every two years with 2 of those 30 hours going toward the CFP boards ethics
education requirement.
ITEM 3
Disciplinary Information
Matt has no disciplinary information to report.
ITEM 4
Other Business Activities
Matt Rillos has no other substantial business activities outside of Full Financial Inc.
ITEM 5
Additional Compensation
Matt Rillos receives no sales awards, no referral fees, nor any other sources of additional income.
ITEM 6
Supervision
Matt Rillos is the President and owner of Full Financial Inc. Joe Rillos and Matt Rillos work as a
team to implement Full Financials’ services for clients.
ITEM 7
Requirements for State-Registered
Matt Rillos has not been involved in any type of arbitration or bankruptcy.
Part 2B of Form ADV: Brochure Supplement
PART 2B ITEM 1
Cover Page Joseph L. Rillos
Joseph L. Rillos
team@fullfinancial.com
5163 Quaker St.
Golden, CO 80403
Full Financial Inc.
16475 W. 51st Place
Golden, CO 80403
www.fullfinancial.com
June 4th, 2025
This brochure supplement provides information about Joseph L. Rillos that supplements the Full Financial
Inc. brochure. You should have received a copy of that brochure. Please contact Matt Rillos at
Team@FullFinancial.com if you did not receive the Full Financial Inc. brochure or if you have any question
about the contents of this supplement.
Additional information about Joseph L. Rillos is available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 2
Educational Background and Business Experience
Joseph Rillos (Joe) was born in 1948 and has provided financial services to individuals and
businesses since 1978. With over 40 years in the industry Mr. Rillos serves his clients with a great
breadth and depth of experience. A former high school teacher and coach, he is a mathematics
graduate of the Colorado College in Colorado Springs, Colorado. Joe Rillos began his financial
career with Integrated Resources Equity Corporation from 1982 until 1989. He was then with
Royal Alliance Associates, Inc. from 1989 until 1996. Joe then co-founded Financial Counseling
Associates, Inc. where he worked from 1993 until 2024. Joe has been with Full Financial Inc.
since 2024. He has a Colorado Insurance Broker License and earned the designation of
Chartered Financial Consultant (ChFC). (ChFC) is the "Advanced Financial Planning" designation
conferred by The American College. The ChFC professional is qualified to assist individuals,
professionals, and small-business owners with comprehensive financial planning, including
insurance, income taxation, retirement planning, investments, and estate planning. The ChFC
curriculum provides an extensive education in financial planning, requiring nine courses, each of
which is followed by an exam.
ITEM 3
Disciplinary Information
Joe has no disciplinary information to report.
ITEM 4
Other Business Activities
Joe Rillos is licensed as an insurance agent in the state of Colorado and does receive
commissions on the sale of life and health insurance. Commissions from the sale of insurance
products create a conflict of interest and provides an incentive to recommend insurance products
based on the compensation received.
ITEM 5
Additional Compensation
Joe Rillos receives no sales awards, no referral fees, nor any other sources of additional income.
ITEM 6
Supervision
Joe Rillos is an employee of Full Financial Inc. Joe Rillos and Matt Rillos work as a team to
implement Full Financial Inc.’s services for clients.
ITEM 7
Requirements for State-Registered
Joe Rillos has not been involved in any type of arbitration or bankruptcy.
Privacy Policy
FULL FINANCIAL INC. PLEDGE TO YOU
The trust of our clients is our most precious asset. Protecting your privacy and safeguarding your personal financial
information is one of our highest priorities. The following Privacy Statement explains how we collect and protect your
information. By using Full Financial Inc. services, you give your consent to the collection and use of personal information
by Full Financial Inc. as explained in this statement. Any dispute over our Privacy Statement is subject to this notice and
the Full Financial Inc. client agreement, including arbitration of disputes and limitation of damages.
KEY ELEMENTS OF FULL FINANCIAL INC.PRIVACY PROGRAM
• We gather personal information about our clients in order to provide services, comply with laws, safeguard
assets, and improve our services.
• We do not share your information with unaffiliated companies or persons for marketing purposes without your
prior permission.
WHY
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit
some, but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal
information. Please read this notice carefully to understand what we do.
WHAT:
The types of personal information we collect and share depend on the product or service you have with us. This
information can include:
Social Security number and income.
Account balances, account numbers, and account transactions.
•
•
HOW
All financial companies need to share customers’ personal information to run their everyday business as permitted by law.
For example, if you have an account at Charles Schwab & Co., Inc. we share required information with Charles Schwab &
Co., Inc. to set up and maintain accounts you have at their institution. In the section below, we list the reasons financial
companies can share their customers’ personal information, the reasons Full Financial Inc. chooses to share and whether
you can limit this sharing.
Reasons We Share Your Personal Information
Can you limit
Sharing?
Does Full
Financial
Share?
Yes
No
For our everyday business purposes —
Such as to process your transactions, maintain your accounts,
respond to court orders and legal investigations, or report to credit
bureaus. This includes sharing information with Charles Schwab &
Co., Inc., Voya Financial, Principal, ADP, Mainstar Trust, or other
institutions which you have accounts where sharing is required to
conduct business.
No
We do not
Share
For our marketing purposes —
To offer products and services provided or endorsed by Full Financial
Inc.
No
We do not
Share
For joint marketing —
Sharing with other financial companies to jointly market the other
company’s products or services
For Non-Full Financial Inc. companies to market to you.
No
We do not
Share
WHAT WE DO
How does Full Financial Inc. protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal
law. These measures include computer safeguards, secured files and buildings.
How does Full Financial Inc. collect my personal information?
We collect your personal information, for example, when you:
Through phone conversations and meetings.
• Open an account, or deposit money.
•
If you have any questions that this statement does not address, please contact us.