Overview
- Headquarters
- Pasadena, CA
- Total Firm Assets
- $127 million
- Average High-Net-Worth Client Portfolio Size
- $1.2 million
- Minimum Account Size
- $500,000
Fee Structure
Primary Fee Schedule (IMPACT FIDUCIARY ADV PART 2A & 2B)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.10% |
| $1,000,001 | $4,000,000 | 0.80% |
| $4,000,001 | $10,000,000 | 0.70% |
| $10,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,000 | 1.10% |
| $5 million | $42,000 | 0.84% |
| $10 million | $77,000 | 0.77% |
| $50 million | $277,000 | 0.55% |
| $100 million | $527,000 | 0.53% |
Clients
- High-Net-Worth Share of Firm Assets
- 71.65%
- Number of High-Net-Worth Clients
- 74
- Total Client Accounts
- 705
- Discretionary Accounts
- 705
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 288345
Primary Brochure: IMPACT FIDUCIARY ADV PART 2A & 2B (2026-07-28)
View Document Text
Item 1: Cover Page
Impact Fiduciary LLC
Office Address:
21 Miller Alley, Suite 210
Pasadena, CA 91105
Mailing Address:
21 Miller Alley, Suite 210
Pasadena, CA 91105
http://www.impactfiduciary.com
Form ADV Part 2A – Firm Brochure
Office: (323) 615-1427
Cellular: (323) 636-6997
Dated July 28, 2026
This Brochure provides information about the qualifications and business practices of Impact Fiduciary LLC,
“Impact Fiduciary”. If you have any questions about the contents of this Brochure, please contact us at (323)
615-1427. 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.
Impact Fiduciary LLC is registered as an Investment Adviser with the SEC. Registration of an Investment Adviser
does not imply any level of skill or training.
Additional information about Impact Fiduciary LLC is available on the SEC’s website at www.adviserinfo.sec.gov
which can be found using the firm’s identification number 288345.
1
Item 2: Material Changes
Since the last filing of the Form ADV Part 2 brochure for Impact Fiduciary LLC on February 9, 2026, the following
material changes have been made:
●
Item 4/5 - Adviser updated to disclose its minimum balance requirements.
Future Changes
From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes
in regulations and routine annual updates as required by the securities regulators. This complete Disclosure
Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change
occurs in the business practices of Impact Fiduciary LLC.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at http://www.adviserinfo.sec.gov by searching for our firm name or by our CRD number
288345.
You may also request a copy of this Disclosure Brochure at any time, by contacting us at (323) 615-1427.
2
Item 3: Table of Contents
Contents
Item 1: Cover Page
Item 2: Material Changes
Item 3: Table of Contents
Item 4: Advisory Business
Item 5: Fees and Compensation
Item 6: Performance-Based Fees and Side-By-Side Management
Item 7: Types of Clients
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Item 9: Disciplinary Information
Item 10: Other Financial Industry Activities and Affiliations
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12: Brokerage Practices
Item 13: Review of Accounts
Item 14: Client Referrals and Other Compensation
Item 15: Custody
Item 16: Investment Discretion
Item 17: Voting Client Securities
Item 18: Financial Information
Form ADV Part 2B – Brochure Supplement
Form ADV Part 2B – Brochure Supplement
1
2
3
4
7
10
10
10
13
13
14
15
16
17
17
18
18
18
19
22
3
Item 4: Advisory Business
Description of Advisory Firm
Impact Fiduciary LLC is an Investment Adviser registered with the SEC. We were founded in March 2017, and
Patrick Dinan is the principal owner of Impact Fiduciary LLC. As of July 28, 2026, Impact Fiduciary LLC currently
reports $155,000,000 in discretionary and no non-discretionary Assets Under Management.
Types of Advisory Services
Comprehensive Wealth Management & Financial Planning
We are in the business of managing individually tailored investment portfolios. Our firm provides continuous
advice to a client regarding the investment of client funds based on the individual needs of the client. Through
personal discussions in which goals and objectives based on a client's particular circumstances are established,
we develop a client's personal investment policy or an investment plan with an asset allocation target and create
and manage a portfolio based on that policy and allocation target. During our data-gathering process, we
determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may also
review and discuss a client’s prior investment history, as well as family composition and background.
Comprehensive wealth management clients receive financial planning at no additional cost.
Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation, growth,
income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on
investing in certain securities, types of securities, or industry sectors. Fees pertaining to this service are outlined
in Item 5 of this brochure.
Financial Planning
This service involves working one-on-one with a planner over an extended period of time. By paying a monthly
retainer, or meeting the minimum of assets under management, clients get continuous access to a planner who
will work with them to design their plan. The planner will monitor the plan, recommend any changes and ensure
the plan is up to date.
Upon desiring a financial plan, a client will be taken through establishing their goals and values around money.
They will be required to provide information to help complete the following areas of analysis: net worth, cash
flow, insurance, credit scores/reports, employee benefit, retirement planning, insurance, investments, college
planning and estate planning. Once the client’s information is reviewed, their plan will be built and analyzed, and
then the findings, analysis and potential changes to their current situation will be reviewed with the client.
Clients subscribing to this service will receive a written or an electronic report, providing the client with a
detailed financial plan designed to achieve his or her stated financial goals and objectives. If a follow up meeting
is required, we will meet at the client's convenience. The plan and the client’s financial situation and goals will be
monitored throughout the year and follow-up phone calls and emails will be made to the client to confirm that
any agreed upon action steps have been carried out. On an annual basis there will be a full review of this plan to
ensure its accuracy and ongoing appropriateness. Any needed updates will be implemented at that time.
4
We provide financial planning services on topics such as retirement planning, risk management, college savings,
cash flow, debt management, work benefits, and estate and incapacity planning.
Financial planning is an evaluation of a client’s current and future financial state by using currently known
variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect of financial
planning is that through the financial planning process, all questions, information and analysis will be considered
as they affect and are affected by the entire financial and life situation of the client. Clients purchasing this
service will receive a written or an electronic report, providing the client with a detailed financial plan designed
to achieve his or her stated financial goals and objectives.
In general, the financial plan will address any or all of the following areas of concern. The client and advisor will
work together to select the specific areas to cover. These areas may include, but are not limited to, the following:
● Business Planning: We provide consulting services for clients who currently operate their own business,
are considering starting a business, or are planning for an exit from their current business. Under this
type of engagement, we work with you to assess your current situation, identify your objectives, and
develop a plan aimed at achieving your goals.
● Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine
your current surplus or deficit along with advice on prioritizing how any surplus should be used or how
to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off
first based on factors such as the interest rate of the debt and any income tax ramifications. We may also
recommend what we believe to be an appropriate cash reserve that should be considered for
emergencies and other financial goals, along with a review of accounts (such as money market funds) for
such reserves, plus strategies to save desired amounts.
● College Savings: Includes projecting the amount that will be needed to achieve college or other
post-secondary education funding goals, along with advice on ways for you to save the desired amount.
Recommendations as to savings strategies are included, and, if needed, we will review your financial
picture as it relates to eligibility for financial aid or the best way to contribute to your children or
grandchildren (if appropriate).
● Employee Benefits Optimization: We will provide review and analysis as to whether you, as an
employee, are taking the maximum advantage possible of your employee benefits. If you are a business
owner, we will consider and/or recommend the various benefit programs that can be structured to meet
both business and personal retirement goals.
● Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current
estate plan, which may include whether you have a will, powers of attorney, trusts and other related
documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by
implementing appropriate estate planning strategies such as the use of applicable trusts.
We always recommend that you consult with a qualified attorney when you initiate, update, or complete
5
estate planning activities. We may provide you with contact information for attorneys who specialize in
estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will
participate in meetings or phone calls between you and your attorney with your approval or request.
● Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will
identify what you plan to accomplish, what resources you will need to make it happen, how much time
you will need to reach the goal, and how much you should budget for your goal.
●
Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term
care, liability, home and automobile.
●
Investment Analysis: This may involve developing an asset allocation strategy to meet clients’ financial
goals and risk tolerance, providing information on investment vehicles and strategies, reviewing
employee stock options, as well as assisting you in establishing your own investment account at a
selected broker/dealer or custodian. The strategies and types of investments we may recommend are
further discussed in Item 8 of this brochure.
● Retirement Planning: Our retirement planning services typically include projections of your likelihood of
achieving your financial goals, typically focusing on financial independence as the primary objective. For
situations where projections show less than the desired results, we may make recommendations,
including those that may impact the original projections by adjusting certain variables (e.g., working
longer, saving more, spending less, taking more risk with investments).
If you are near retirement or already retired, advice may be given on appropriate distribution strategies
to minimize the likelihood of running out of money or having to adversely alter spending during your
retirement years.
● Risk Management: A risk management review includes an analysis of your exposure to major risks that
could have a significant adverse impact on your financial picture, such as premature death, disability,
property and casualty losses, or the need for long-term care planning. Advice may be provided on ways
to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing
so and, likewise, the potential cost of not purchasing insurance (“self-insuring”).
● Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part
of your overall financial planning picture. For example, we may make recommendations on which type of
account(s) or specific investments should be owned based in part on their “tax efficiency,” with
consideration that there is always a possibility of future changes to federal, state or local tax laws and
rates that may impact your situation.
We recommend that you consult with a qualified tax professional before initiating any tax planning
strategy, and we may provide you with contact information for accountants or attorneys who specialize
6
in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls
between you and your tax professional with your approval.
Tax Planning Strategies
Impact Fiduciary engages third-party accountants for accountancy and/or tax services. The tax preparation
services are provided by qualified regulated accountants through Ontrail, Inc. DBA Uprise (“Uprise”). Clients who
elect to receive tax preparation services will be billed by Impact Fiduciary. Clients are under no obligation to use
our tax services, and may choose another provider. Advice may include ways to minimize current and future
income taxes as a part of your overall financial planning picture. For example, we may make recommendations
on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with
the consideration that there is always a possibility of future changes to federal, state or local tax laws and rates
that may impact your situation.
Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all of our clients. However, specific client financial plans and their
implementation are dependent upon each client’s current situation (income, tax levels, and risk tolerance levels)
and are used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions,
needs, and targets.
Wrap Fee Programs
Impact Fiduciary does not participate in any wrap fee programs.
Item 5: Fees and Compensation
Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing the
investment advisory contract, the investment advisory contract may be terminated by the client within five (5)
business days of signing the contract without incurring any advisory fees. How we are paid depends on the type
of advisory service we are performing. Please review the fee and compensation information below.
Comprehensive Wealth Management & Financial Planning
Our standard advisory fee is based on the market value of the assets under management and is calculated as
follows:
Account Value
Annual Advisory Fee
$0 - $1,000,000
1.10.%
$1,00,001 - $4,000,000
0.80%
$4,000,001 - $10,000,000
0.70%
$10,000,001 and above
0.50%
7
*Our minimum account size requirement is $500,000, accounts below the minimum will pay an annual advisory
fee of 1.1%.
The annual fees are negotiable and are pro-rated and paid in arrears on a quarterly basis. The advisory fee is a
blended fee and is calculated on an average daily balance by assessing the percentage rates using the predefined
levels of assets as shown in the above chart. No increase in the annual fee shall be effective without agreement
from the client by signing a new agreement or amendment to their current advisory agreement.
Advisory fees are directly debited from client accounts. Accounts initiated or terminated during a calendar
quarter will be charged a pro-rated fee based on the number of days under management during the billing
period. An account may be terminated with written notice at least 30 calendar days in advance. Since fees are
paid in arrears, no rebate will be needed upon termination of the account. Financial planning is included with
comprehensive wealth management at no additional cost.
Financial Planning
Financial Planning consists of an upfront charge ranging from $1,500 - $10,000 depending on complexity and an
ongoing fee that is paid monthly, in advance, at a rate of $400 - $3,500 per month. The fee may be negotiable in
certain cases.
For clients participating in Investment Management Services, the monthly fee is waived for Financial Planning.
The upfront fee for Financial Planning is waived if assets under management exceed $400,000.
Fees for this service may be paid by electronic funds transfer or check. This service may be terminated with 30
days’ notice. Upon termination of any account, for the upfront fee and any fees paid in advance, the fee will be
prorated and any unearned fee will be refunded to the client. Financial planning clients that have AUM that
terminate will move to the AUM fee schedule. A rate of 1.1% billing begins 30 days after the termination of this
service.
8
Single Engagement Financial Planning
Financial Planning will also be offered on a fixed fee one-time basis. The fixed fee will be agreed upon before the
start of any work. The fixed fee can range between $1,000 and $10,000. The fee is negotiable. If a fixed fee
program is chosen, half of the fee is due at the beginning of the process and the remainder is due at completion
of the engagement, however Impact Fiduciary will not bill an amount above $500 more than 6 months in
advance. Fees for this service may be paid by electronic funds transfer or check. Since fees are paid in arrears, no
rebate will be needed upon termination of the account.
Tax Planning Strategies
Simple return
● $600 payable in advance. Best suited for clients with straightforward filing needs. The fee is
non-negotiable. Fees for this service may be paid by electronic funds transfer or check. In the event of
early termination any prepaid but unearned fees will be refunded.
Comprehensive
● $1,250 payable in advance. Best suited for high-earning professionals and sole proprietors needing both
filing and tax analyses. The fee is non-negotiable. Fees for this service may be paid by electronic funds
transfer or check. In the event of early termination any prepaid but unearned fees will be refunded.
Business owner
● $2,750 payable in advance. Best suited for business owners needing filing and analyses across business
and personal. The fee is non-negotiable. Fees for this service may be paid by electronic funds transfer or
check. In the event of early termination any prepaid but unearned fees will be refunded.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which
may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, and other third
parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund
and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus.
Such charges, fees and commissions are exclusive of and in addition to our fee, and we shall not receive any
portion of these commissions, fees, and costs.
Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for client’s
transactions and determining the reasonableness of their compensation (e.g., commissions).
We do not accept compensation for the sale of securities or other investment products including asset-based
sales charges or service fees from the sale of mutual funds.
9
Item 6: Performance-Based Fees and
Side-By-Side Management
We do not offer performance-based fees.
Item 7: Types of Clients
We provide financial planning and portfolio management services to individuals, high net-worth individuals,
pension and profiting sharing plans, charitable organizations, and corporations or other businesses.
Our minimum account size requirement is $500,000, accounts below the minimum will pay an annual advisory
fee of 1.1%.
Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss
When clients have us complete an Investment Analysis (described in Item 4 of this brochure), we use a
combination of fundamental analysis, passive investment management and cyclical analysis. In addition we will
screen for socially responsible investments.
Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s
financial statements, details regarding the company’s product line, the experience, and expertise of the
company’s management, and the outlook for the company’s industry. The resulting data is used to measure the
true value of the company’s stock compared to the current market value. The risk of fundamental analysis is that
information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which
may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental
analysis may not result in favorable performance.
Passive Investment Management
We primarily practice passive investment management. Passive investing involves building portfolios that are
comprised of various distinct asset classes. The asset classes are weighted in a manner to achieve a desired
relationship between correlation, risk and return. Baskets of stocks and funds that passively capture the returns
of the desired asset classes are placed in the portfolio. The baskets of stocks and funds that are used to build
passive portfolios are typically, individual securities, index mutual funds or exchange traded funds.
Passive investment management is characterized by low portfolio expenses (i.e. the funds inside the portfolio
have low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency
(because the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal).
10
In contrast, active management involves a single manager or managers who employ some method, strategy or
technique to construct a portfolio that is intended to generate returns that are greater than the broader market
or a designated benchmark.
Socially Responsible Investing (SRI)
Within our ETF Strategy, Stock Strategy, and/or Fixed Income Strategy we will utilize a Socially Responsible
Investment (also known as Sustainable, Responsible Investing, Ethical Investing and Impact Investing) bias. In
general, SRI encourages corporate practices that promote environmental stewardship, consumer protection,
human rights, and diversity. Examples of SRI include but are not limited to avoiding businesses involved in fossil
fuels, tobacco, factory farming, and weapons production, while favoring businesses that serve low income and
underprivileged communities, clean technology businesses, generate jobs, and introduce products that will yield
community and environmental benefits. The Advisor will utilize a variety of resources to incorporate SRI
principles into the Stock, ETF, or Fixed Income Strategies.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment which you
should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities and any other
investment or security. Material risks associated with our investment strategies are listed below.
Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a
general market decline, reducing the value of the investment regardless of the operational success of the issuer’s
operations or its financial condition.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended.
Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations
are often more volatile and less liquid than investments in larger companies. Small and medium cap companies
may face a greater risk of business failure, which could increase the volatility of the client’s portfolio.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below
par value or the principal investment. The opposite is also generally true: bond prices generally rise when
interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price
changes. Most other investments are also sensitive to the level and direction of interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the
securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of your
investments remains the same.
Socially Responsible Investing (SRI): You should note that returns on investments of this type may be limited and
because of this limitation you may not be able to be as well diversified among various asset classes. The number
of publicly traded companies that meet socially responsible investment parameters is also limited. Therefore,
there could be a more pronounced positive or negative impact on a socially responsible portfolio, which could be
more volatile than a fully diversified portfolio.
11
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities may have
other risks.
Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or
less. Being unsecured the risk to the investor is that the issuer may default.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or
restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse
effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and
repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively,
investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but
rather are priced at a discount from their face values and their values accrete over time to face value at maturity.
The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and
maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest
rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk.
Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the
banking industry. Banks and other financial institutions are greatly affected by interest rates and may be
adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations.
Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the
construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds.
However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return
to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds
carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment
risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk.
Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the complete
loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is
written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered
calls, there is a risk the underlying position may be called away at a price lower than the current market price.
Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain
Exchange Traded Funds may not track underlying benchmarks as expected.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears
its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur
higher expenses, many of 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 asset value; (ii) the ETF may employ an investment strategy that
utilizes high leverage ratios; or (iii) 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
12
breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no
control over the risks taken by the underlying funds in which clients invest.
Item 9: Disciplinary Information
Criminal or Civil Actions
Impact Fiduciary LLC and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
Impact Fiduciary LLC and its management have not been involved in administrative enforcement proceedings.
Self-Regulatory Organization Enforcement Proceedings
Impact Fiduciary LLC and its management have not been involved in legal or disciplinary events that are material
to a client’s or prospective client’s evaluation of Impact Fiduciary LLC or the integrity of its management.
Item 10: Other Financial Industry Activities and
Affiliations
No Impact Fiduciary LLC employee is registered, or has an application pending to register, as a broker-dealer or a
registered representative of a broker-dealer.
No Impact Fiduciary LLC employee is registered, or has an application pending to register, as a futures
commission merchant, commodity pool operator or a commodity trading advisor.
Impact Fiduciary LLC does not have any related parties. As a result, we do not have a relationship with any
related parties.
Impact Fiduciary LLC only receives compensation directly from clients. We do not receive compensation from any
outside source. We do not have any conflicts of interest with any outside party.
13
Item 11: Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of
each client. Our clients entrust us with their funds and personal information, which in turn places a high standard
on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the
expected basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility
adopted by the CFP® Board of Standards Inc., and accepts the obligation not only to comply with the mandates
and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and
professionally responsible manner in all professional services and activities.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its
specific provisions will not shield associated persons from liability for personal trading or other conduct that
violates a fiduciary duty to advisory clients. A summary of the Code of Ethics' Principles is outlined below.
•
Integrity - Associated persons shall offer and provide professional services with integrity.
•
Objectivity - Associated persons shall be objective in providing professional services to clients.
Competence - Associated persons shall provide services to clients competently and maintain the
•
necessary knowledge and skill to continue to do so in those areas in which they are engaged.
•
Fairness - Associated persons shall perform professional services in a manner that is fair and reasonable
to clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services.
Confidentiality - Associated persons shall not disclose confidential client information without the specific
•
consent of the client unless in response to proper legal process, or as required by law.
•
Professionalism - Associated persons’ conduct in all matters shall reflect credit of the profession.
•
Diligence - Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm
access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm
will provide a copy of its Code of Ethics to any client or prospective client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest
Neither our firm, its associates or any related person is authorized to recommend to a client, or effect a
transaction for a client, involving any security in which our firm or a related person has a material financial
interest, such as in the capacity as an underwriter, adviser to the issuer, etc.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
14
Our firm and its “related persons” may buy or sell securities similar to, or different from, those we recommend
to clients for their accounts. In an effort to reduce or eliminate certain conflicts of interest involving the firm or
personal trading, our policy may require that we restrict or prohibit associates’ transactions in specific reportable
securities transactions. Any exceptions or trading pre-clearance must be approved by the firm principal in
advance of the transaction in an account, and we maintain the required personal securities transaction records
per regulation.
Trading Securities At/Around the Same Time as Client’s Securities
Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or
securities in which you are already invested. A conflict of interest exists in such cases because we have the
ability to trade ahead of you and potentially receive more favorable prices than you will receive. To mitigate
this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have
priority over your account in the purchase or sale of securities.
Item 12: Brokerage Practices
Factors Used to Select Custodians and/or Broker-Dealers
Impact Fiduciary LLC does not have any affiliation with Broker-Dealers. Specific custodian recommendations are
made to clients based on their need for such services. We recommend custodians based on the reputation and
services provided by the firm.
1. Research and Other Soft-Dollar Benefits
Impact Fiduciary participate(s) in soft dollar programs sponsored or offered by Altruist, and Goldman Sachs
Custody Solutions.
2. Brokerage for Client Referrals
We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third
party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
We do recommend a specific custodian for Investment Management clients to use, however, Financial Planning
clients may custody their assets at a custodian of their choice. Clients may also direct us to use a specific
broker-dealer to execute transactions. By allowing clients to choose a specific custodian, we may be unable to
achieve most favorable execution of client transactions and this may cost clients money over using a lower-cost
custodian.
The Custodian and Brokers We Use (Altruist)
Impact Fiduciary LLC offers investment advisory services through the custodial platform offered by Altruist
Financial LLC and its current clearing firm, Apex Clearing Corporation (each unaffiliated SEC-registered broker
dealers and FINRA/SIPC members), including by virtue of no commissions on orders executed through them, fully
digital account opening process, the variety of available investments, and integration with software tools that
can benefit Impact Fiduciary LLC and its clients.
The Custodian and Brokers We Use (Goldman Sachs Custody Solutions)
15
Impact Fiduciary participates in Window Trading, offered through Goldman Sachs Custody Solutions. It's often
referred to as “a Window”, is an innovative way to execute orders efficiently for long-term investors. Instead of
trades being executed immediately, trades are grouped together and sent to the market for execution one or
more times per trading day. After execution, securities are allocated to individual accounts, with every client
receiving the identical execution price to ensure compliance and consistency.
Orders are collected throughout the day and held until the next window trade cutoff. Currently, there are two
standard windows each business day (more can be provided on demand if needed) when U.S. securities markets
are open - 11:00 a.m. and 2:00 p.m. Eastern Time. Orders placed after the last window of a business day are
processed in the first window of the next trading day. Please read Folio's client agreement for more information
on Window Trading.
Advantages of window trading:
● Unlimited trades—including all mutual fund families—with no commissions
● Place orders in dollar amounts, or portfolio/model weights and percentages, rather than only in share
amounts
● Buy and sell both whole and fractional share quantities
● Buy and sell an entire portfolio in a single transaction
● All investors in any given security receive the same execution price within the same window
● Treat the smallest accounts the same as the largest, thereby expanding your business with the
opportunity to serve a wide variety of clients cost-effectively
The Custodian and Brokers We Use (Schwab)
Impact Fiduciary does not maintain custody of your assets that we manage, although we may be deemed to have
custody of your assets if you give us the authority to withdraw advisory fees from your account (see Item
15—Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a
broker-dealer or bank. We offer that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered
broker-dealer, member SIPC, as a qualified custodian. We are independently owned and operated and are not
affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we
instruct them to. While we offer that you use Schwab as custodian/broker, you will decide whether to do so and
will open your account with Schwab by entering into an account agreement directly with them. We do not open
the account for you, although we may assist you in doing so. If you do not wish to place your assets with Schwab,
then we cannot manage your account. Not all advisors require their clients to use a particular broker-dealer or
other custodian selected by the advisor.
Item 13: Review of Accounts
Client accounts with the Investment Management Service will be reviewed regularly on a quarterly basis by
Patrick Dinan, President and CCO. The account is reviewed with regards to the client’s investment policies and
risk tolerance levels. Events that may trigger a special review would be unusual performance, addition or
16
deletions of client imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions
from the firm or per client's needs.
Clients will receive trade confirmations from the broker for each transaction in their accounts as well as monthly
or quarterly statements and annual tax reporting statements from their custodian showing all activity in the
accounts, such as receipt of dividends and interest.
Impact Fiduciary LLC will provide written reports to Investment Management clients on a quarterly basis. These
reports may contain historical performance data, review of current holdings, and investment commentary. We
urge clients to compare these reports against the account statements they receive from their custodian.
Clients subscribing to Financial Planning will receive a written or an electronic report, providing the client with a
detailed financial plan designed to achieve his or her stated financial goals and objectives. If a follow up meeting
is required, we will meet at the client's convenience. The plan and the client’s financial situation and goals will be
monitored throughout the year and follow-up phone calls and emails will be made to the client to confirm that
any agreed upon action steps have been carried out. On an annual basis there will be a full review of this plan to
ensure its accuracy and ongoing appropriateness. Any needed updates will be implemented at that time.
Item 14: Client Referrals and Other
Compensation
We do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our
clients.
The Advisor engages independent, unaffiliated solicitors to provide client referrals. There is no employee
relationship between the solicitor and Impact Fiduciary LLC. If a client is referred to us by a solicitor, this practice
is disclosed to the client in writing by the solicitor and the Advisor pays the solicitor out of its own
funds—specifically, the Advisor generally pays the solicitor a portion of the advisory fees earned for managing
the capital of the client or investor that was referred. The use of solicitors is strictly regulated under applicable
federal and state law. The Advisor’s policy is to fully comply with the requirements of Rule 206(4)-3, under the
Investment Advisers Act of 1940, as amended, and similar state rules, as applicable.
Item 15: Custody
Impact Fiduciary LLC does not accept custody of client funds except in the instance of withdrawing client fees.
For client accounts in which the advisory fee is directly debited:
i.
ii.
iii.
The client will receive an advance billing notice detailing the fee(s) to be deducted.
The custodian will send at least quarterly statements to the client showing all disbursements for the
account, including the amount of the advisory fee.
The client will prove written authorization to Impact Fiduciary LLC, permitting them to be paid directly
for their accounts held by the custodian.
17
Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian
that holds and maintains the client's investment assets. We urge you to carefully review such statements and
compare such official custodial records to the account statements or reports that we may provide to you. Our
statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or
valuation methodologies of certain securities.
Item 16: Investment Discretion
For those client accounts where we provide investment management services, we maintain discretion over client
accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold.
Investment discretion is explained to clients in detail when an advisory relationship has commenced. At the start
of the advisory relationship, the client will execute a Limited Power of Attorney, which will grant our firm
discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory contract
and signed by the client.
Item 17: Voting Client Securities
We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2)
acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s
qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the
Client’s investment assets. If the client would like our opinion on a particular proxy vote, they may contact us at
the number listed on the cover of this brochure.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event we
were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless
you have authorized our firm to contact you by electronic mail, in which case, we would forward you any
electronic solicitation to vote proxies.
Item 18: Financial Information
Registered Investment Advisers are required in this Item to provide you with certain financial information or
disclosures about our financial condition. We have no financial commitment that impairs our ability to meet
contractual and fiduciary commitments to clients, and we have not been the subject of a bankruptcy proceeding.
We do not have custody of client funds or securities or require or solicit prepayment of more than $1,200 in fees
per client six months in advance.
18
Impact Fiduciary LLC
Office Address:
21 Miller Alley, Suite 210
Pasadena, CA 91105
Mailing Address:
21 Miller Alley, Suite 210
Pasadena, CA 91105
http://www.impactfiduciary.com
Office: (323) 615-1427
Cellular: (323) 636-6997
Dated July 28, 2026
Form ADV Part 2B – Brochure Supplement
For
Patrick Dinan - Individual CRD# 4974335
President, and Chief Compliance Officer
This brochure supplement provides information about Patrick Dinan that supplements the Impact Fiduciary LLC
(“Impact Fiduciary”) brochure. A copy of that brochure precedes this supplement. Please contact Patrick Dinan if
the Impact Fiduciary LLC brochure is not included with this supplement or if you have any questions about the
contents of this supplement.
Additional information about Patrick Dinan is available on the SEC’s website at www.adviserinfo.sec.gov which
can be found using the identification number 4974335.
Item 2: Educational Background and Business Experience
19
Patrick Dinan
Born: 1981
Educational Background
• 2004 – Bachelor of Science, Finance, University of Pittsburgh, Pittsburgh, Pennsylvania
Business Experience
• 05/2017– Present, Impact Fiduciary LLC, President and CCO
• 10/2012 – 05/2017 Personal Capital Advisors, Vice President
• 10/2009 – 10/2012 TD Ameritrade, Investment Consultant
• 11/2008 – 10/2009 US Bancorp Investments and Insurance, Financial Consultant
• 10/2007 - 11/2008 Navy Federal Investments and Insurance, Financial Services Representative
• 06/2005 - 10/2007 Federated Investors, Inc., Senior Internal Sales Associate
Professional Designations, Licensing & Exams
CFP (Certified Financial Planner)®: The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP
(with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the
United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial
planners to hold CFP® certification. It is recognized in the United States and a number of other countries for
its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and
(3) ethical requirements that govern professional engagements with clients. Currently, more than 71,000
individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of
financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college
or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include
insurance planning and risk management, employee benefits planning, investment planning, income tax
planning, retirement planning, and estate planning;
● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies
and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply
one’s knowledge of financial planning to real world circumstances;
● Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining
the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
20
● Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct.
The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary
standard of care. This means CFP® professionals must provide financial planning services in the best interests
of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP
Board’s enforcement process, which could result in suspension or permanent revocation of their
CFP® certification.
The Chartered SRI Counselor, or CSRIC® program, is a designation program for financial professionals. This
program provides experienced financial advisors and investment professionals with a foundation knowledge
of the history, definitions, trends, portfolio construction principles, fiduciary responsibilities, and best
practices for sustainable, responsible, and impact (SRI) investments.
Item 3: Disciplinary Information
No management person at Impact Fiduciary LLC has ever been involved in an arbitration claim of any kind or
been found liable in a civil, self-regulatory organization, or administrative proceeding.
Item 4: Other Business Activities
Patrick Dinan is not involved with outside business activities.
Item 5: Additional Compensation
Patrick Dinan does not receive any economic benefit from any person, company, or organization, in exchange for
providing clients advisory services through Impact Fiduciary LLC.
Item 6: Supervision
Patrick Dinan, as President and Chief Compliance Officer of Impact Fiduciary LLC, is responsible for supervision.
He may be contacted at the phone number on this brochure supplement.
21
Impact Fiduciary LLC
Office Address:
21 Miller Alley, Suite 210
Pasadena, CA 91105
Mailing Address:
21 Miller Alley, Suite 210
Pasadena, CA 91105
http://www.impactfiduciary.com
Office: (323) 615-1427
Cellular: (323) 636-6997
Dated July 28, 2026
Form ADV Part 2B – Brochure Supplement
For
Christopher Mastro - Individual CRD# 7509221
Investment Adviser Representative
This brochure supplement provides information about Christopher Mastro that supplements the Impact
Fiduciary LLC (“Impact Fiduciary”) brochure. A copy of that brochure precedes this supplement. Please contact
Patrick Dinan if the Impact Fiduciary LLC brochure is not included with this supplement or if you have any
questions about the contents of this supplement.
Additional information about Patrick Dinan is available on the SEC’s website at www.adviserinfo.sec.gov which
can be found using the identification number 7509221.
Item 2: Educational Background and Business Experience
22
Christopher Mastro
Born: 1979
Educational Background
• 2002 – Bachelor of Fine Arts, State University of New York - Purchase
Business Experience
• 10/2020– Present, Impact Fiduciary LLC, Investment Adviser Representative
• 12/2017 – 03/2022 Mirmir LLC, Creative Director
• 06/2014 – 02/2022 Best Beverage Catering, Bartender
• 02/2011 – 06/2014 Siren Studios, Manager
Professional Designations, Licensing & Exams
CFP (Certified Financial Planner)®: The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP
(with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the
United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial
planners to hold CFP® certification. It is recognized in the United States and a number of other countries for
its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and
(3) ethical requirements that govern professional engagements with clients. Currently, more than 71,000
individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of
financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college
or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include
insurance planning and risk management, employee benefits planning, investment planning, income tax
planning, retirement planning, and estate planning;
● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies
and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply
one’s knowledge of financial planning to real world circumstances;
● Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining
the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
23
● Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct.
The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary
standard of care. This means CFP® professionals must provide financial planning services in the best interests
of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP
Board’s enforcement process, which could result in suspension or permanent revocation of their
CFP® certification.
Item 3: Disciplinary Information
No management person at Impact Fiduciary LLC has ever been involved in an arbitration claim of any kind or
been found liable in a civil, self-regulatory organization, or administrative proceeding.
Item 4: Other Business Activities
Christopher Mastro is the owner of Wellness BioDental, this activity amounts to less than 10 percent of his time.
Item 5: Additional Compensation
Christopher Mastro does not receive any economic benefit from any person, company, or organization, in
exchange for providing clients advisory services through Impact Fiduciary LLC.
Item 6: Supervision
Patrick Dinan, as President and Chief Compliance Officer of Impact Fiduciary LLC, is responsible for supervision.
He may be contacted at the phone number on this brochure supplement.
24