Overview
Assets Under Management: $171 million
Headquarters: COOS BAY, OR
High-Net-Worth Clients: 65
Average Client Assets: $2 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Fee Structure
Primary Fee Schedule (FORM ADV2A/2B)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.50% |
| $1,000,001 | $3,000,000 | 1.20% |
| $3,000,001 | $5,000,000 | 1.00% |
| $5,000,001 | $10,000,000 | 0.80% |
| $10,000,001 | and above | 0.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $59,000 | 1.18% |
| $10 million | $99,000 | 0.99% |
| $50 million | $199,000 | 0.40% |
| $100 million | $324,000 | 0.32% |
Clients
Number of High-Net-Worth Clients: 65
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 89.19
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 300
Discretionary Accounts: 300
Regulatory Filings
CRD Number: 331566
Last Filing Date: 2025-01-24 00:00:00
Website: https://highroadwa.com
Form ADV Documents
Primary Brochure: FORM ADV2A/2B (2025-05-15)
View Document Text
D I S C L O S U R E B R O C H U R E
Item 1 Cover Page
F O R M A D V P A R T 2 A
HighRoad Wealth Advisors, LLC
Office Address:
nd
Street
170 S. 2
Suite 201
Coos Bay, Oregon 97420
Tel:
541-266-7623
Fax:
541-266-9173
Email:
jason.finnigan@highroadwa.com
Website:
www.highroadwa.com
May 15, 2025
This brochure provides information about the qualifications and business practices of
HighRoad Wealth Advisors, LLC. Being registered as an investment adviser does not imply
a certain level of skill or training. If you have any questions about the contents of this
brochure, please contact us at 541-266-7623. The information in this brochure has not
been approved or verified by the United States Securities and Exchange Commission, or by
ADDITIONAL INFORMATION ABOUT HIGHROAD WEALTH ADVISORS, LLC (CRD
any state securities authority.
#331566) IS AVAILABLE ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV.
i
Item 2: Material Changes
Annual Update
Material Changes since the Last Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Since the last filing of this brochure on January 24, 2025, the following changes have been
•
made:
•
Item 4 has been amended to include an updated Asset Under Management
calculation.
Full Brochure Available
Outside business activities updated in item 10 & 2B’s
This Firm Brochure being delivered is the complete brochure for the Firm.
ii
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................................... ii
Material Changes since the Last Update.................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Full Brochure Available .................................................................................................................................................. ii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions ............................................................................... 2
Wrap Fee Programs ......................................................................................................................................................... 2
Item 5: Fees and Compensation ....................................................................................................... 3
Client Assets Under Management .............................................................................................................................. 2
Method of Compensation and Fee Schedule .......................................................................................................... 3
Client Payment of Fees ................................................................................................................................................... 4
Additional Client Fees Charged ................................................................................................................................... 4
Prepayment of Client Fees ............................................................................................................................................ 4
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 5
External Compensation for the Sale of Securities to Clients ........................................................................... 4
Item 7: Types of Clients ....................................................................................................................... 5
Sharing of Capital Gains ................................................................................................................................................. 5
Description .......................................................................................................................................................................... 5
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 5
Account Minimums .......................................................................................................................................................... 5
Methods of Analysis ......................................................................................................................................................... 5
Investment Strategy ........................................................................................................................................................ 5
Item 9: Disciplinary Information ..................................................................................................... 8
Security Specific Material Risks .................................................................................................................................. 5
Criminal or Civil Actions ................................................................................................................................................ 8
Administrative Enforcement Proceedings ............................................................................................................. 8
Self- Regulatory Organization Enforcement Proceedings ............................................................................... 8
iii
Item 10: Other Financial Industry Activities and Affiliations ............................................... 8
Broker-Dealer or Representative Registration .................................................................................................... 8
Futures or Commodity Registration ......................................................................................................................... 8
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 8
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 8
Trading ..................................................................................................................................................... 8
Code of Ethics Description ............................................................................................................................................ 8
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest.... 9
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ... 9
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Item 12: Brokerage Practices ......................................................................................................... 10
Transactions and Conflicts of Interest ..................................................................................................................... 9
Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 10
Item 13: Review of Accounts ........................................................................................................... 11
Aggregating Securities Transactions for Client Accounts ............................................................................. 10
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 11
Review of Client Accounts on Non-Periodic Basis ........................................................................................... 11
Item 14: Client Referrals and Other Compensation ................................................................ 11
Content of Client Provided Reports and Frequency ........................................................................................ 11
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 11
Item 15: Custody .................................................................................................................................. 11
Advisory Firm Payments for Client Referrals .................................................................................................... 11
Item 16: Investment Discretion ..................................................................................................... 11
Account Statements ...................................................................................................................................................... 11
Item 17: Voting Client Securities ................................................................................................... 12
Discretionary Authority for Trading...................................................................................................................... 11
Item 18: Financial Information ...................................................................................................... 12
Proxy Votes ...................................................................................................................................................................... 12
Balance Sheet .................................................................................................................................................................. 12
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 12
Bankruptcy Petitions during the Past Ten Years .............................................................................................. 12
iv
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 14
Principal Executive Officer – Jason Finnigan ...................................................................................................... 14
CItem 2 - Educational Background and Business Experience ..................................................................... 14
Item 3 - Disciplinary Information ........................................................................................................................... 14
Item 4 - Other Business Activities ........................................................................................................................... 15
Item 5 - Additional Compensation .......................................................................................................................... 15
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 17
Item 6 - Supervision ..................................................................................................................................................... 15
Principal Executive Officer – Joshua Snoddy ...................................................................................................... 17
Item 2 - Educational Background and Business Experience ....................................................................... 17
Item 3 - Disciplinary Information ........................................................................................................................... 17
Item 4 - Other Business Activities ........................................................................................................................... 18
Item 5 - Additional Compensation .......................................................................................................................... 18
Item 6 - Supervision ..................................................................................................................................................... 18
v
Item 4: Advisory Business
Firm Description
Types of Advisory Services
HighRoad Wealth Advisors, LLC (“HighRoad”) was founded in 2013 and began offering
advisory services in 2024. Jason Finnigan and Joshua Snoddy are co-owners. Jason Finnigan
is the Chief Compliance Officer.
ASSET MANAGEMENT
HighRoad offers discretionary asset management services to advisory Clients. HighRoad
will offer Clients ongoing asset management services through determining individual
investment goals, time horizons, objectives, and risk tolerance. Investment strategies,
investment selection, asset allocation, portfolio monitoring and the overall investment
program will be based on the above factors. The Client will authorize HighRoad
discretionary authority to execute selected investment program transactions as stated
within the Investment Advisory Agreement.
As part of the recommendations provided, the Client may have a financial plan completed.
This may include but is not limited to a thorough review of all applicable topics such as
Wills, Estate Plans and Trusts, Investments, Taxes, Qualified Plans, Insurance, Retirement
Income, Social Security, and College Planning. If a conflict of interest exists between the
interests of HighRoad and the interests of the Client, the Client is under no obligation to act
upon HighRoad’s recommendation.
If the Client elects to act on any of the
recommendations, the Client is under no obligation to effect the transaction through
HighRoad. This service will be provided at no additional cost to the Client.
ERISA PLAN SERVICES
HighRoad provides service to qualified retirement plans including, but not limited to,
401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and
ERISA 3(38) Investment Manager.
deferred compensation plans as a 3(38) advisor:
HighRoad can also act as an ERISA 3(38) Investment Manager
in which it has discretionary management and control of a given retirement plan’s assets. HighRoad
would then become solely responsible and liable for the selection, monitoring and replacement of
the plan’s investment options.
1.
•
Fiduciary Services are:
•
HighRoad has discretionary authority and will make the final decision regarding the
initial selection, retention, removal, and addition of investment options in
accordance with the Plan’s investment policies and objectives.
•
Assist the Client with the selection of a broad range of investment options consistent
with ERISA Section 404(c) and the regulations thereunder.
•
Assist the Client in the development of an investment policy statement (“IPS”). The
IPS establishes the investment policies and objectives for the Plan.
Provide discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment option for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
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elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5).
2.
•
Non-fiduciary Services are:
•
Assist in the education of Plan participants about general investment information
and the investment options available to them under the Plan. Client understands
that HighRoad’s assistance in education of the Plan participants shall be consistent
with and within the scope of the Department of Labor’s definition of investment
education (Department of Labor Interpretive Bulletin 96-1). As such, HighRoad is
not providing fiduciary advice as defined by ERISA to the Plan participants.
HighRoad will not provide investment advice concerning the prudence of any
investment option or combination of investment options for a particular participant
or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
HighRoad may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between HighRoad and Client.
3.
HighRoad has no responsibility to provide services related to the following types of
•
assets (“Excluded Assets”):
•
•
•
•
•
•
not
Employer securities.
Real estate (except for real estate funds or publicly traded REITs).
Stock brokerage accounts or mutual fund windows.
Participant loans.
Non-publicly traded partnership interests.
Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
Other hard-to-value or illiquid securities or property.
Client Tailored Services and Client Imposed Restrictions
Excluded Assets will
be included in calculation of Fees paid to the Adviser on the ERISA
Agreement. Specific services will be outlined in detail to each plan in the 408(b)2
disclosure.
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the Client goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities.
Wrap Fee Programs
Agreements may not be assigned without written Client consent.
Client Assets Under Management
HighRoad does not sponsor any wrap fee programs.
HighRoad has the following Client assets under management:
Discretionary Amounts:
Non-discretionary Amounts:
Date Calculated:
$170,956,327
$0
May 8, 2025
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Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
HighRoad offers discretionary direct asset management services to advisory Clients.
HighRoad charges an annual investment advisory fee based on the total assets under
management as follows:
Assets Under Management
First $1,000,000 ($0-$1,000,000)
Your next $2,000,000 ($1,000,000.01 - $3,000,000)
Your next $2,000,000 ($3,000,000.01 - $5,000,000)
Your next $5,000,000 ($5,000,000.01 - $10,000,000)
Subsequent amounts ($10,000,000.01+)
Annual Fee
1.50%
1.20%
1.00%
0.80%
0.25%
Quarterly Fee
.3750%
.3000%
.2500%
.2000%
0.0625%
This is a tiered/blended fee schedule, the asset management fee is calculated by applying
different rates to different portions of the portfolio. HighRoad may group certain related
Client accounts for the purposes of achieving the minimum account size and determining
For example (based on quarterly billing period)
the annualized fee.
:
Client with $2,500,000 under management would pay $8,250.00 on a quarterly basis.
Quarterly fee
x 0.3750% =
x 0.3000% =
AUM
First $1,000,000
Next $1,500,000
Grand total for the quarter
Total
$3,750.00
$4,500.00
$8,250.00
The annual fee is negotiable based upon certain criteria (e.g., historical relationship, type of
assets, anticipated future earning capacity, anticipated future additional assets, dollar
amounts of assets to be managed, related accounts, account composition, negotiations with
Clients, etc.). HighRoad considers cash to be an asset class, and as such is included in fee
calculations. Also, to be noted, at times fees will exceed the money market yield. Fees are
billed quarterly in advance based on the amount of assets managed as of the close of
business on the last business day of the previous quarter.
Lower fees for comparable services may be available from other sources. Clients may
terminate their account within five (5) business days of signing the Investment Advisory
Agreement with no obligation and without penalty. After the initial five (5) business days,
the agreement may be terminated by HighRoad with thirty (30) days written notice to
Client and by the Client at any time with written notice to HighRoad. If cash and/or
securities are deposited into or withdrawn from an existing account mid billing period a
prorated fee will be charged for that portion of the account. For accounts opened or closed
mid-billing period, fees will be prorated based on the days services are provided during the
given period. All unpaid earned fees will be due to HighRoad. Additionally, all unearned
fees will be refunded to the Client. Client shall be given thirty (30) days prior written notice
of any increase in fees. Any increase in fees will be acknowledged in writing by both parties
before any increase in said fees occurs.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed
1%. The annual fee is negotiable and will be charged as a percentage of the Included Assets.
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Fees may be charged quarterly or monthly in arrears or in advance based on the assets as
calculated by the custodian or record keeper of the Included Assets. If the services to be
provided start any time other than the first day of a quarter or month, the fee will be
prorated based on the number of days remaining in the quarter or month. If this
Agreement is terminated prior to the end of the billing cycle, HighRoad shall be entitled to a
prorated fee based on the number of days during the fee period services were provided or
Client will be due a prorated refund of fees for days services were not provided in the
billing cycle.
Client Payment of Fees
The fee schedule, which includes compensation of HighRoad for the services, is described
in detail in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees;
however, the Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or
have fees deducted from Plan Assets. HighRoad does not reasonably expect to receive any
additional compensation, directly or indirectly, for its services under this Agreement. If
additional compensation is received, HighRoad will disclose this compensation, the
services rendered, and the payer of compensation. HighRoad will offset the compensation
against the fees agreed upon under the Agreement.
Fees for asset management services are deducted from a designated Client account. The
Client must consent in advance to direct debiting of their investment account.
Additional Client Fees Charged
Fees for ERISA services will either be deducted from Plan assets or paid directly to
HighRoad. The Client must consent in advance to direct debiting of their investment
account.
Prepayment of Client Fees
Custodians may charge transaction fees and other related costs on the purchases or sales of
mutual funds, equities, bonds, options and exchange-traded funds. Mutual funds, money
market funds and exchange-traded funds also charge internal management fees, which are
disclosed in the fund’s prospectus. HighRoad does not receive any compensation from
these fees. All of these fees are in addition to the management fee you pay to HighRoad. For
more details on the brokerage practices, see Item 12 of this brochure.
HighRoad does not require any prepayment of fees of more than $1,200 per Client and six
months or more in advance.
Investment management fees are billed quarterly in advance.
Fees for ERISA 3(38) services may be billed in advance.
If the Client cancels after five (5) business days, any unearned fees will be refunded to the
External Compensation for the Sale of Securities to Clients
Client, or any unpaid earned fees will be due to HighRoad.
Investment Advisor Representatives of HighRoad receive external compensation from sales
of investment related products such as insurance as licensed insurance agents. This
represents a conflict of interest because it gives an incentive to recommend products based
on the commission received. This conflict is mitigated by disclosures, procedures, and
HighRoad’s fiduciary obligation to place the best interest of the Client first and Clients are
not required to purchase any products or services. Clients have the option to purchase
these products through another insurance agent of their choosing.
- 4 -
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
HighRoad does not use a performance-based fee structure because of the conflict of
interest. Performance based compensation may create an incentive for HighRoad to
recommend an investment that may carry a higher degree of risk to the Client.
Item 7: Types of Clients
Description
Account Minimums
HighRoad generally provides investment advice to individuals, high net worth individuals,
and businesses. Client relationships vary in scope and length of service.
HighRoad does not require a minimum to open or maintain an account.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods may include Modern Portfolio Theory and Asset Allocation.
Investing in securities involves risk of loss that Clients should be prepared to bear. Past
performance is not a guarantee of future returns.
Modern Portfolio Theory is the theory of finance that attempts to maximize portfolio
expected return for a given amount of portfolio risk, or equivalently minimize risk for a
given level of expected return, by carefully choosing the proportions of various assets.
Investment Strategy
Asset allocation is an investment strategy that aims to balance risk and reward by
apportioning a portfolio's assets according to an individual's goals, risk tolerance and
investment horizon. The three main asset classes - equities, fixed-income, and cash and
equivalents - have different levels of risk and return, so each will behave differently over
time.
Security Specific Material Risks
The investment strategy for a specific Client is based upon the objectives stated by the
Client during consultations. The Client may change these objectives at any time by
providing written notice to HighRoad. Each Client executes a Client profile form or similar
form that documents their objectives and their desired investment strategy.
All investment programs have certain risks that are borne by the investor. Our investment
approach keeps the risk of loss in mind. Investors face the following investment risks and
• Market Risk
should discuss these risks with HighRoad:
: The prices of securities in which clients invest may decline in response to
certain events taking place around the world, including those directly involving the
companies whose securities are owned by a fund; conditions affecting the general
economy; overall market changes; local, regional or global political, social or economic
instability; and currency, interest rate and commodity price fluctuations. Investors
- 5 -
•
should have a long-term perspective and be able to tolerate potentially sharp declines
Interest-rate Risk
in market value.
•
: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
Inflation Risk
attractive, causing their market values to decline.
: When any type of inflation is present, a dollar today will buy more than a
• Currency Risk
dollar next year, because purchasing power is eroding at the rate of inflation.
: Overseas investments are subject to fluctuations in the value of the dollar
against the currency of the investment’s originating country. This is also referred to as
• Reinvestment Risk
exchange rate risk.
• Liquidity Risk
: This is the risk that future proceeds from investments may have to
be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily
relates to fixed income securities.
• Management Risk:
: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties are
not.
• Equity Risk:
The advisor’s investment approach may fail to produce the intended
results. If the advisor’s assumptions regarding the performance of a specific asset class
or fund are not realized in the expected time frame, the overall performance of the
client’s portfolio may suffer.
• Fixed Income Risk:
Equity securities tend to be more volatile than other investment choices.
The value of an individual mutual fund or ETF can be more volatile than the market as a
whole. This volatility affects the value of the client’s overall portfolio. Small- and mid-
cap companies are subject to additional risks. Smaller companies may experience
greater volatility, higher failure rates, more limited markets, product lines, financial
resources, and less management experience than larger companies. Smaller companies
may also have a lower trading volume, which may disproportionately affect their
market price, tending to make them fall more in response to selling pressure than is the
case with larger companies.
•
The issuer of a fixed income security may not be able to make
interest and principal payments when due. Generally, the lower the credit rating of a
security, the greater the risk that the issuer will default on its obligation. If a rating
agency gives a debt security a lower rating, the value of the debt security will decline
because investors will demand a higher rate of return. As nominal interest rates rise,
the value of fixed income securities held by a fund is likely to decrease. A nominal
Investment Companies Risk:
interest rate is the sum of a real interest rate and an expected inflation rate.
When a client invests in open end mutual funds or ETFs, the
client indirectly bears their proportionate share of any fees and expenses payable
directly by those funds. Therefore, the client will incur higher expenses, which may be
duplicative. In addition, the client’s overall portfolio may be affected by losses of an
underlying fund and the level of risk arising from the investment practices of an
underlying fund (such as the use of derivatives). ETFs are also subject to the following
risks: (i) an ETF’s shares may trade at a market price that is above or below their net
- 6 -
• Foreign Securities Risk:
asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s
officials deem such action appropriate, the shares are de-listed from the exchange, or
the activation of market-wide “circuit breakers” (which are tied to large decreases in
stock prices) halts stock trading generally. Adviser has no control over the risks taken
by the underlying funds in which client invests.
• Long-term purchases
Funds in which clients invest may invest in foreign securities.
Foreign securities are subject to additional risks not typically associated with
investments in domestic securities. These risks may include, among others, currency
risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and
economic instability, currency devaluations and policies that have the effect of limiting
or restricting foreign investment or the movement of assets), different trading
practices, less government supervision, less publicly available information, limited
trading markets and greater volatility. To the extent that underlying funds invest in
issuers located in emerging markets, the risk may be heightened by political changes,
changes in taxation, or currency controls that could adversely affect the values of these
investments. Emerging markets have been more volatile than the markets of developed
countries with more mature economies.
• Short-term purchases
: Long-term investments are those vehicles purchased with the
intention of being held for more than one year. Typically, the expectation of the
investment is to increase in value so that it can eventually be sold for a profit. In
addition, there may be an expectation for the investment to provide income. One of the
biggest risks associated with long-term investments is volatility, the fluctuations in the
financial markets that can cause investments to lose value.
: Short-term investments are typically held for one year or less.
Generally, there is not a high expectation for a return or an increase in value. Typically,
short-term investments are purchased for the relatively greater degree of principal
protection they are designed to provide. Short-term investment vehicles may be subject
to purchasing power risk — the risk that your investment’s return will not keep up with
• Trading risk
inflation.
: Investing involves risk, including possible loss of principal. There is no
• Foreign Investment Risk
assurance that the investment objective of any fund or investment will be achieved.
: Investments in foreign securities may be riskier than U.S.
investments because of factors such as, unstable international, political and economic
conditions, currency fluctuations, foreign controls on investment and currency
exchange, foreign governmental control of some issuers, potential confiscatory taxation
or nationalization of companies by foreign governments, withholding taxes, a lack of
adequate company information, less liquid and more volatile exchanges and/or
markets,
ineffective or detrimental government regulation, varying accounting
standards, political or economic factors that may severely limit business activities, and
legal systems or market practices that may permit inequitable treatment of minority
and/or non-domestic investors. Investments in emerging markets may involve these
and other significant risks such as less mature economic structures and less developed
and more thinly-traded securities markets.
- 7 -
Item 9: Disciplinary Information
Criminal or Civil Actions
Administrative Enforcement Proceedings
HighRoad and its management have not been involved in any criminal or civil action.
Self- Regulatory Organization Enforcement Proceedings
HighRoad and its management have not been involved in administrative enforcement
proceedings.
HighRoad and its management have not been involved in any self-regulatory organizational
enforcement proceedings that are material to a Client’s or prospective Client’s evaluation of
HighRoad or the integrity of its management.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Futures or Commodity Registration
HighRoad is not registered as a broker-dealer and no affiliated representatives of HighRoad
are registered representatives of a broker-dealer.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Neither HighRoad nor its affiliated representatives are registered or have an application
pending to register as a futures commission merchant, commodity pool operator, or a
commodity trading advisor.
Jason Finnigan and Joshua Snoddy are owners of a commercial real estate rental company,
HighRoad Real Estate, LLC. Approximately 5% of their time is spent on this activity. They
may offer Clients services from those activities. As an owner, they may receive separate yet
typical compensation.
This practice represents a conflict of interest because it gives an incentive to recommend
services based on the additional compensation received. This conflict is mitigated by
disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the
Client first. Clients have the option to choose a separate real estate rental company of their
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
choosing.
HighRoad does not select or recommend other investment advisors.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
include employees and/or
The affiliated persons (affiliated persons
independent
contractors) of HighRoad have committed to a Code of Ethics (“Code”). The purpose of our
Code is to set forth standards of conduct expected of HighRoad affiliated persons and
addresses conflicts that may arise. The Code defines acceptable behavior for affiliated
persons of HighRoad. The Code reflects HighRoad and
its supervised persons’
responsibility to act in the best interest of their Client.
- 8 -
One area which the Code addresses is when affiliated persons buy or sell securities for
their personal accounts and how to mitigate any conflict of interest with our Clients. We do
not allow any affiliated persons to use non-public material information for their personal
profit or to use internal research for their personal benefit in conflict with the benefit to
our Clients.
HighRoad’s policy prohibits any person from acting upon or otherwise misusing non-public
or inside information. No advisory representative or other affiliated person, officer or
director of HighRoad may recommend any transaction in a security or its derivative to
advisory Clients or engage in personal securities transactions for a security or its
derivatives if the advisory representative possesses material, non-public information
regarding the security.
HighRoad’s Code is based on the guiding principle that the interests of the Client are our
top priority. HighRoad’s officers, directors, advisors, and other affiliated persons have a
fiduciary duty to our Clients and must diligently perform that duty to maintain the
complete trust and confidence of our Clients. When a conflict arises, it is our obligation to
put the Client’s interests over the interests of either affiliated persons or the company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have
access to non-public information regarding any Clients' purchase or sale of securities, or
non-public information regarding the portfolio holdings of any reportable fund, who are
involved in making securities recommendations to Clients, or who have access to such
recommendations that are non-public.
HighRoad will provide a copy of the Code of Ethics to any Client or prospective Client upon
Investment Recommendations Involving a Material Financial Interest and Conflict of
request.
Interest
HighRoad and its affiliated persons do not recommend to Clients securities in which we
have a material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
HighRoad and its affiliated persons may buy or sell securities that are also held by Clients.
In order to mitigate conflicts of interest such as trading ahead of Client transactions,
affiliated persons are required to disclose all reportable securities transactions as well as
provide HighRoad with copies of their brokerage statements.
The Chief Compliance Officer of HighRoad is Jason Finnigan. He reviews all trades of the
affiliated persons each quarter. The personal trading reviews ensure that the personal
trading of affiliated persons does not affect the markets and that Clients of the firm receive
preferential treatment over associated persons’ transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
HighRoad does not have a material financial interest in any securities being recommended.
However, affiliated persons may buy or sell securities at the same time they buy or sell
securities for Clients. In order to mitigate conflicts of interest such as front running,
affiliated persons are required to disclose all reportable securities transactions as well as
provide HighRoad with copies of their brokerage statements.
- 9 -
The Chief Compliance Officer of HighRoad is Jason Finnigan. He reviews all trades of the
affiliated persons each quarter. The personal trading reviews ensure that the personal
trading of affiliated persons does not affect the markets and that Clients of the firm receive
preferential treatment over associated persons’ transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
HighRoad will require the use of a particular broker-dealer based on their duty to seek best
execution for the client, meaning they have an obligation to obtain the most favorable
terms for a client under the circumstances. The determination of what may constitute best
execution and price in the execution of a securities transaction by a broker involves a
number of considerations and is subjective. Factors affecting brokerage selection include
the overall direct net economic result to the portfolios, the efficiency with which the
transaction is affected, the ability to effect the transaction where a large block is involved,
the operational facilities of the broker-dealer, the value of an ongoing relationship with
such broker and the financial strength and stability of the broker. HighRoad will select
appropriate brokers based on a number of factors including but not limited to their
relatively low transaction fees and reporting ability. HighRoad relies on its broker to
provide its execution services at the best prices available. Lower fees for comparable
services may be available from other sources. Clients pay for any and all custodial fees in
addition to the advisory fee charged by HighRoad. HighRoad does not receive any portion
of the trading fees.
• Research and Other Soft Dollar Benefits
HighRoad will require the use of Altruist Corp. to custody assets.
• Brokerage for Client Referrals
The Securities and Exchange Commission defines soft dollar practices as
arrangement under which products or services other than execution services are
obtained by HighRoad from or through a broker-dealer in exchange for directing
Client transactions to the broker-dealer. HighRoad does not receive any soft dollars.
• Directed Brokerage
HighRoad does not receive client referrals from any custodian or third party in
exchange for using that broker-dealer or third party.
Aggregating Securities Transactions for Client Accounts
HighRoad does not allow directed brokerage accounts. Not all advisors require their
clients to direct brokerage.
HighRoad is authorized in its discretion to aggregate purchases and sales and other
transactions made for the account with purchases and sales and transactions in the same
securities for other Clients of HighRoad. All Clients participating in the aggregated order
shall receive an average share price with all other transaction costs shared on a pro-rated
basis. If aggregation is not allowed or infeasible and individual transactions occur (e.g.,
withdrawal or liquidation requests, odd-lot trades, etc.) an account may potentially be
assessed higher costs or less favorable prices than those where aggregation has occurred.
- 10 -
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed quarterly by the Chief Compliance Officer of HighRoad,
Jason Finnigan. Account reviews are performed more frequently when market conditions
dictate. Reviews of Client accounts include, but are not limited to, a review of Client
documented risk tolerance, adherence to account objectives, investment time horizon, and
suitability criteria, reviewing target allocations of each asset class to identify if there is an
opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities.
Review of Client Accounts on Non-Periodic Basis
Financial plans generated are updated as requested by the Client.
Content of Client Provided Reports and Frequency
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws,
new investment information, and changes in a Client's own situation.
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by HighRoad’s custodian. Client receives confirmations of
each transaction in account from custodian and an additional statement during any month
in which a transaction occurs. HighRoad does not provide additional reports to Clients.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest
Advisory Firm Payments for Client Referrals
HighRoad does not receive any economic benefits from external sources.
HighRoad does not compensate for Client referrals.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to Clients at their address of record at least quarterly. Clients are urged
to carefully compare the account statements received directly from their custodians to any
documentation or reports prepared by HighRoad.
HighRoad is deemed to have limited custody solely because advisory fees are directly
deducted from Client’s accounts by the custodian on behalf of HighRoad.
Item 16: Investment Discretion
Discretionary Authority for Trading
HighRoad requires discretionary authority to manage securities accounts on behalf of
Clients. HighRoad has the authority to determine, without obtaining specific Client consent,
the securities to be bought or sold, and the amount of the securities to be bought or sold.
HighRoad discretionary authority is stated within the Investment Advisory Agreement.
- 11 -
HighRoad allows Clients to place certain restrictions, as outlined in the Client’s Investment
Policy Statement or similar document. These restrictions must be provided to HighRoad in
writing.
The Client approves the custodian to be used and the commission rates paid to the
custodian. HighRoad does not receive any portion of the transaction fees or commissions
paid by the Client to the custodian.
Item 17: Voting Client Securities
Proxy Votes
HighRoad does not vote proxies on securities. Clients are expected to vote their own
proxies. The Client will receive their proxies directly from the custodian of their account or
from a transfer agent.
When assistance on voting proxies is requested, HighRoad will provide recommendations
to the Client. If a conflict of interest exists, it will be disclosed to the Client. If the Client
requires assistance or has questions, they can reach out to the investment advisor
representatives of the firm at the contact information on the cover page of this document.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided to Clients because HighRoad does not serve
as a custodian for Client funds or securities and HighRoad does not require prepayment of
fees of more than $1,200 per Client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
Bankruptcy Petitions during the Past Ten Years
HighRoad has no condition that is reasonably likely to impair our ability to meet
contractual commitments to our Clients.
HighRoad has not had any bankruptcy petitions
in
the
last
ten years.
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S U P E R V I S E D P E R S O N B R O C H U R E
Item 1 Cover Page
F O R M A D V P A R T 2 B
Jason Finnigan
HighRoad Wealth Advisors, LLC
Office Address:
nd
Street
170 S. 2
Suite 201
Coos Bay, Oregon 97420
Tel:
541-266-7623
Fax:
541-266-9173
Email:
jason.finnigan@highroadwa.com
Website:
www.highroadwa.com
May 15, 2025
This brochure supplement provides information about Jason Finnigan and supplements the
HighRoad Wealth Advisors, LLC brochure. You should have received a copy of that
brochure. Please contact Jason Finnigan if you did not receive the brochure or if you have
ADDITIONAL INFORMATION ABOUT JASON FINNIGAN (CRD #2827406) IS AVAILABLE
any questions about the contents of this supplement.
ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV.
- 13 -
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer – Jason Finnigan
•
CItem 2 - Educational Background and Business Experience
Year of birth: 1969
•
Educational Background:
University of Puget Sound; Bachelor of Arts in Economics; 1992
•
Business Experience:
•
HighRoad Wealth Advisors, LLC; Chief Compliance Officer/Investment Advisor
Representative; 08/2024-Present
•
HighRoad Real Estate, LLC; Co-Owner; 12/2014-Present
•
HighRoad Wealth Advisors, LLC.; Managing Member; 12/2013-Present
•
Jason Finnigan, Sole Proprietor; Insurance Agent; 01/2003-01/2025
Item 3 - Disciplinary Information
Wells Fargo Advisors Financial Network, LLC; Investment Advisor
Representative/Registered Representative; 02/2014-08/2024
1.
Mr. Finnigan has never been involved in a criminal or civil action in a domestic, foreign,
or military court of competent jurisdiction for which he:
a.
Was convicted of or pled guilty or nolo contender (“no contest”) to (a) any
felony; (b) misdemeanor that involved investments or an investment-related
business, fraud, false statement, or omissions, wrongful taking of property,
bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any
of these offenses.
b.
Is the named subject of a pending criminal proceeding that involves an
investment-related business, fraud, false statements, or omissions, wrongful
taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a
conspiracy to commit any of these offenses.
c.
Was found to have been involved in a violation of an investment-related statute
or regulation; or
d.
Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order?
2.
Mr. Finnigan never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory
authority in which he:
a.
Was found to have caused an investment-related business to lose its authorization
to do business, or the subject of an order by the agency or authority.
b.
Was found to have been involved in a violation of an investment-related statute or
regulation or was the subject of an order by the agency or authority.
a.
(a)denying, suspending, or revoking the authorization of the supervised person
to act in an investment-related business; (b) barring or suspending his
association with an investment-related business; (c) otherwise significantly
- 14 -
limiting his investment-related activities; or (d) imposing a civil money penalty
of more than $2,500 on him.
3.
Mr. Finnigan has never been the subject of a self-regulatory organization (SRO)
proceeding in which he:
a.
lose its
Was found to have caused an investment-related business to
authorization to do business; or
b.
Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members
or was expelled from membership; (b) otherwise significantly limited from
investment-related activities; or (c) fined more than $2,500.
4.
Item 4 - Other Business Activities
any other hearing or formal adjudication in
Mr. Finnigan has not been involved in
which a professional attainment, designation, or license of the supervised person was
revoked or suspended because of a violation of rules relating to professional conduct.
Jason Finnigan is an owner of a commercial real estate rental company, HighRoad Real
Estate, LLC. Approximately 5% of his time is spent on this activity. He may offer Clients
services from these activities. As an owner, he may receive separate yet typical
compensation.
Item 5 - Additional Compensation
This practice represents a conflict of interest because it gives an incentive to recommend
services based on the additional compensation received. This conflict is mitigated by
disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the
Client first. Clients have the option to choose a separate real estate rental company of their
choosing.
Mr. Finnigan does not receive any performance-based fees and does not receive any
additional compensation for performing advisory services other than what is disclosed in
Item 6 - Supervision
Item 5 of Part 2A.
Since Mr. Finnigan is the Chief Compliance Officer of HighRoad he is ultimately responsible
for supervision of investment advice offered to Clients. He will adhere to the policies and
procedures as described in the firm’s Compliance Manual. He can be reached at
jason.finnigan@highroadwa.com or 541-266-7623.
- 15 -
S U P E R V I S E D P E R S O N B R O C H U R E
Item 1 Cover Page
F O R M A D V P A R T 2 B
Joshua Snoddy
HighRoad Wealth Advisors, LLC
Office Address:
nd
Street
170 S. 2
Suite 201
Coos Bay, Oregon 97420
Tel:
541-266-7623
Fax:
541-266-9173
Email:
josh.snoddy@highroadwa.com
Website:
www.highroadwa.com
May 15, 2025
This brochure supplement provides information about Joshua Snoddy and supplements the
HighRoad Wealth Advisors, LLC brochure. You should have received a copy of that
brochure. Please contact Joshua Snoddy if you did not receive the brochure or if you have
ADDITIONAL INFORMATION ABOUT JOSHUA SNODDDY (CRD #5446837) IS
any questions about the contents of this supplement.
AVAILABLE ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV.
- 16 -
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer – Joshua Snoddy
•
Item 2 - Educational Background and Business Experience
Year of birth: 1981
•
Educational Background:
•
Eastern Oregon University; Bachelor of Science in Business Accounting CPA Track;
2004
SouthWestern Oregon Community College; Transfer degree; 2002
•
Business Experience:
•
HighRoad Wealth Advisors, LLC.; Investment Advisor Representative; 08/2024-
Present
•
HighRoad Real Estate, LLC; Co-Owner; 12/2014-Present
•
HighRoad Wealth Advisors, LLC.; Managing Member; 12/2013-Present
•
Joshua Snoddy, Sole Proprietor; Insurance Agent; 03/2008-03/2025
Item 3 - Disciplinary Information
Wells Fargo Advisors Financial Network, LLC; Investment Advisor
Representative/Registered Representative; 02/2014-08/2024
1.
Mr. Snoddy has never been involved in a criminal or civil action in a domestic, foreign,
or military court of competent jurisdiction for which he:
a.
Was convicted of or pled guilty or nolo contender (“no contest”) to (a) any felony;
(b) misdemeanor that involved investments or an investment-related business,
fraud, false statement, or omissions, wrongful taking of property, bribery, perjury,
counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses.
b.
Is the named subject of a pending criminal proceeding that involves an investment-
related business, fraud, false statements, or omissions, wrongful taking of property,
bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of
these offenses.
c.
Was found to have been involved in a violation of an investment-related statute or
regulation; or
d.
Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order?
2.
Mr. Snoddy never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory
authority in which he:
a.
Was found to have caused an investment-related business to lose its authorization
to do business, or the subject of an order by the agency or authority.
b.
Was found to have been involved in a violation of an investment-related statute or
regulation or was the subject of an order by the agency or authority.
- 17 -
a.
(a)denying, suspending, or revoking the authorization of the supervised person
to act in an investment-related business; (b) barring or suspending his
association with an investment-related business; (c) otherwise significantly
limiting his investment-related activities; or (d) imposing a civil money penalty
of more than $2,500 on him.
3.
Mr. Snoddy has never been the subject of a self-regulatory organization (SRO)
proceeding in which he:
a.
lose its
Was found to have caused an investment-related business to
authorization to do business; or
b.
Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members
or was expelled from membership; (b) otherwise significantly limited from
investment-related activities; or (c) fined more than $2,500.
4.
Item 4 - Other Business Activities
any other hearing or formal adjudication in which
Mr. Snoddy has not been involved in
a professional attainment, designation, or license of the supervised person was revoked
or suspended because of a violation of rules relating to professional conduct.
Joshua Snoddy is an owner of a commercial real estate rental company, HighRoad Real
Estate, LLC. Approximately 5% of his time is spent on this activity. He may offer Clients
services from this activity. As an owner, he may receive separate yet typical compensation.
Item 5 - Additional Compensation
This practice represents a conflict of interest because it gives an incentive to recommend
services based on the additional compensation received. This conflict is mitigated by
disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the
Client first. Clients have the option to choose a separate real estate rental company of their
choosing.
Mr. Snoddy does not receive any performance-based fees and does not receive any
additional compensation for performing advisory services other than what is disclosed in
Item 6 - Supervision
Item 5 of Part 2A.
Since Joshua Snoddy is part owner of HighRoad, he shares in the responsibility for
supervision and formulation and monitoring of investment advice offered to clients. Jason
Finnigan is the Chief Compliance Officer of HighRoad. Jason Finnigan reviews Joshua
Snoddy’s work through Client account reviews and quarterly personal transaction reports,
as well as face-to-face and phone interactions. Jason Finnigan can be reached at
jason.finnigan@highroadwa.com or 541-266-7623.
- 18 -