Overview
- Average Client Assets
- $3.9 million
- Minimum Account Size
- $500,000
- SEC CRD Number
- 130070
Fee Structure
Primary Fee Schedule (ADV PART 2A FIRM BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $3,000,000 | 1.25% |
| $3,000,001 | $10,000,000 | 1.00% |
| $10,000,001 | and above | 0.75% |
Minimum Annual Fee: $6,250
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $57,500 | 1.15% |
| $10 million | $107,500 | 1.08% |
| $50 million | $407,500 | 0.82% |
| $100 million | $782,500 | 0.78% |
Clients
- HNW Share of Firm Assets
- 69.41%
- Total Client Accounts
- 354
- Discretionary Accounts
- 354
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Regulatory Filings
Primary Brochure: ADV PART 2A FIRM BROCHURE (2026-03-05)
View Document Text
Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
March 2026
Massapequa, NY
www.MyInvestmentInsight.com
Firm Contact:
Robert Sullivan
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Investment
Insight Wealth Management, LLC. If clients have any questions about the contents of this brochure,
please contact us at (516) 249-0060 or Bob@MyInvestmentInsight.com. The information in this
brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any State Securities Authority. Additional information about our firm is also
available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #130070.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
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Item 2: Material Changes
Investment Insight Wealth Management, LLC is required to advise you of any material changes to our
Firm Brochure (“Brochure”) and that may be important to them. Clients can then determine whether
to review the brochure in its entirety or to contact us with questions about the changes. Since the last
annual amendment filed on 02/24/2025, we have the following material change(s) to disclose:
• We have updated Item 5 to disclose that our firm may charge an hourly fee of up to $350 for
our Comprehensive Financial Planning service. Current clients will remain subject to the
terms of their signed agreement with our firm. Please see Item 5 for additional information.
• We have updated Item 5 to disclose that our firm will manage certain client account(s) that
are held at a custodian that is not directly accessible by our firm using Pontera Solutions, Inc.
(“Pontera”)’s order management system. The advisory fee payable for any held away
accounts will be deducted directly from another client account. If there are insufficient funds
available in another client account or our firm believes that deducting the advisory fee from
another client account would be prohibited by applicable law, we will invoice the client
directly. Please see Item 5 for additional information.
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Item 3: Table of Contents
Section: Page(s):
Item 1: Cover Page ....................................................................................................................................... 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Advisory Business.................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................. 6
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 9
Item 7: Types of Clients & Account Requirements .................................................................................................... 9
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................. 10
Item 9: Disciplinary Information .................................................................................................................................... 14
Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 14
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............. 14
Item 12: Brokerage Practices ........................................................................................................................................... 15
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 17
Item 14: Client Referrals & Other Compensation ..................................................................................................... 18
Item 15: Custody .................................................................................................................................................................... 18
Item 16: Investment Discretion ....................................................................................................................................... 19
Item 17: Voting Client Securities ..................................................................................................................................... 19
Item 18: Financial Information ........................................................................................................................................ 21
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Item 4: Advisory Business
We specialize in the following services: Investment Management, Comprehensive Financial Planning,
3(38) and 3(21) ERISA Investment Management, and 401(k) Plan Review. Our firm is dedicated to
providing individuals and other types of clients with a wide array of investment advisory services.
Our firm is a limited liability company formed under the laws of the State of New York. Our firm has
been in business as an investment adviser since 2004 and is owned 100% by Robert Sullivan.
Types of Advisory Services Offered
Investment Management:
As part of our Investment Management service, clients will be provided asset management and
financial planning or consulting services. This service is designed to assist clients in meeting their
financial goals through the use of a financial plan or consultation. Our firm conducts client meetings
(virtually and/or in person) to understand their current financial situation, existing resources,
financial goals, and tolerance for risk. Based on what is learned, an investment approach is presented
to the client, consisting of individual stocks, bonds, ETFs, options, mutual funds and other public and
private securities or investments. Once the appropriate portfolio has been determined, portfolios are
continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual
needs, stated goals and objectives. Upon client request, our firm provides a summary of observations
and recommendations for the planning or consulting aspects of this service.
Comprehensive Financial Planning:
Our firm provides a variety of financial planning and consultation services to individuals, families,
business and other clients regarding the management of their financial resources based upon an
analysis of client’s current situation, goals, and objectives. Generally, such services are financial
consulting for clients based on the client’s financial goals and objectives. This planning or consulting
service may encompass one or more of the following areas:
• Retirement Planning
• Tax Planning
• Estate Planning
• Education Planning
•
Insurance Planning
• Life Planning
Our written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. It should also
be noted that we may refer clients to an accountant, attorney or other specialist, as necessary, for
non-advisory related services. Financial consulting services are typically completed within 6 months
of the client signing a contract with us, assuming that all the information and documents we request
from the client are provided to us promptly. Implementation of the recommendations will be at the
discretion of the client. For financial consulting clients who wish to have our firm provide ongoing
asset management, a separate advisory agreement will need to be executed, and in certain
circumstances, their financial consulting fee will be waived.
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Retirement Plan Consulting:
Our firm provides Retirement Plan Consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
•
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
•
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance on
allocation strategies.
When providing Retirement Plan Consulting services, our firm does not provide any advisory
services with respect to the following types of assets: employer securities, real estate (excluding real
estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets,
other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All
Retirement Plan Consulting services shall be in compliance with the applicable state laws regulating
retirement consulting services. This applies to client accounts that are retirement or other employee
benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to
provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning
of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with
respect to the provision of services described therein.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Investment Management clients. The client’s
individual investment strategy is tailored to their specific needs and may include some or all of the
previously mentioned securities. Each portfolio will be initially designed to meet a particular investment
goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has
been determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio
based upon the client’s individual needs, stated goals and objectives. Each client has the opportunity to
place reasonable restrictions on the types of investments to be held in the portfolio. We emphasize
continuous and regular account supervision and individualized investment advice to clients.
We offer clients customized portfolios to suit a variety of investment objectives:
• Growth Portfolio – Primary focus is on making your capital grow, income is a not a
concern, comfortable with market fluctuation;
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• Equity Income Portfolio – Primary focus on making your capital grow; income is a
secondary focus; stock portfolio; comfortable with market fluctuation;
• Balanced Portfolio – Primary focus on making your capital grow; income is a secondary
•
focus; stock and bond portfolio; comfortable with market fluctuation;
Income Portfolio – Primary focus is for providing immediate income; growth is not a
concern, comfortable with a lower level of market fluctuation;
• Tax Free Bond Portfolio – Primary focus is for providing income that is free from income
tax; growth is not a concern, comfortable with a lower level of market fluctuation.
General investment advice will be offered to our Comprehensive Financial Planning and Retirement
Plan Consulting clients.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
Our firm managed $178,140,454 on a discretionary basis and $0 on a non-discretionary basis as of
December 31st, 2025.
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Investment Management:
Annual Percentage of Assets Charge
Assets Under Management
$0 to $3,000,000
$3,000,001 to $10,000,000
$10,000,001 and Above
1.25%
1.00%
0.75%
Clients are subject to the fee arrangement in their signed agreement with our firm. If disclosed in the
signed advisory agreement, we require an annual minimum fee of $6,250. If a client initially meets
the $500,000 account household value minimum but their account household value subsequently
falls below the minimum threshold, the client will be charged a flat rate of 1.25% of assets under
management rather than $6,250. These requirements are negotiable and may be waived at our firm’s
discretion.
Our firm’s fees are billed on a pro-rata annualized basis quarterly in arrears based on the time-
weighted daily average of the client account(s) during the previous quarter. In addition to our
management fee, each client is subject to a minimum fee of $100 annually to cover administrative
costs, account performance records, etc. The ultimate fee we charge clients will be determined on an
individualized basis and may be negotiated at the discretion of the advisor. Our firm bills on cash
unless indicated otherwise in writing. Fee adjustments will be made for deposits and withdrawals in
client accounts. Our firm does not offer direct invoicing. Fees will be deducted from client account(s).
As part of this process, clients understand the following:
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a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the assets and all account disbursements, including the
amount of the advisory fees paid to our firm.
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian.
c) If our firm sends a copy of our invoice to the client, our invoice will include a disclosure urging
the client to compare the information provided in our statement with those from the qualified
custodian.
Our Investment Management service typically includes asset management and financial planning or
consulting services for a single fee. However, if an Investment Management client does not maintain
$1 million in assets under management with our firm by the end of their first year as an Investment
Management client, they will be charged a separate fee for financial planning or consulting services
as outlined below.
In certain cases, our firm will manage client account(s) that are held at a custodian that is not directly
accessible by our firm using Pontera Solutions, Inc. (“Pontera”)’s order management system. The
advisory fee payable for any held away accounts will be deducted directly from another client
account. If there are insufficient funds available in another client account or our firm believes that
deducting the advisory fee from another client account would be prohibited by applicable law, we
will invoice the client directly.
Comprehensive Financial Planning:
We charge a maximum flat fee based on 1.5% of annual household income or an hourly fee of up to
$350 for our Comprehensive Financial Planning service. If the annual household income-based fee is
less than $3,750, our firm will charge a negotiated flat fee instead of the 1.5% annual household
income-based fee. We require a retainer of fifty percent (50%) of the estimated total Comprehensive
Financial Planning fee with the remainder of the fee directly billed to you and due to us within thirty
(30) days of your financial plan being delivered or consultation rendered to you. In all cases, we will
not require a retainer exceeding $1,200 when services cannot be rendered within six (6) months.
If a Comprehensive Financial Planning client subsequently becomes an Investment Management
client with at least $1 million in assets under management with our firm by the end of their first year
as an Investment Management client, we will reduce their Investment Management advisory fee by
the dollar amount paid for a comprehensive financial plan. However, we shall not rollover excess
financial planning fees into the second year if those fees are higher than the first year of Investment
Management fees.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed on an hourly fee, flat fee, or a fee based on the
percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee
charged, is based on the scope and complexity of our engagement with the client. The fee-paying
arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting
agreement. The maximum hourly fee to be charged will not exceed $350. Our flat fees range from
$1000 to $3000. Fees based on a percentage of managed Plan assets are outlined in the schedule
below:
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3(38) and 3(21) ERISA Investment Management Fee Schedule:
Assets Under Management
$0 - $500,000
$500,000 - $1,000,000
$1,000,000 - $2,000,000
$2,000,000 - $10,000,000
$10,000,000 - $20,000,000
Above $20,000,000
Annual Advisory Fee*
0.75%
0.40%
0.35%
0.30%
0.25%
0.20%
Our firm’s fees are billed on a pro-rata annualized basis quarterly in arrears based on the time-
weighted daily average of the account during the quarter. 401(k) account reviews are charged a flat
fee of $299. If the client is not satisfied with the plan or finds substantial savings, fees will be returned.
Other Types of Fees & Expenses
Clients will incur transaction charges for trades executed by their chosen custodian. These
transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen
custodian. Clients may also pay holdings charges imposed by the chosen custodian for certain
investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which
shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses),
initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable
annuity fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads paid to
market makers, fees for trades executed away from custodian, wire transfer fees and other fees and
taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these
fees.
Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and
exchange traded funds.
Fidelity Brokerage Services (“Fidelity”) eliminated transaction fees for U.S. listed equities and
exchange traded funds for clients who opt into electronic delivery of statements or maintain at least
$1 million in assets at Fidelity. Clients who do not meet either criteria will be subject to transaction
fees charged by Fidelity for U.S. listed equities and exchange traded funds.
Termination & Refunds
We charge our advisory fees quarterly in arrears for our Investment Management service. Either
party can terminate the Investment Management Agreement at any time by providing written notice
to the other party. Upon notice of termination, we will proceed to close your account and charge you
pro-rata advisory fee(s) for services rendered up to the point of termination.
Either party can terminate the Comprehensive Financial Planning Agreement at any time by
providing written notice to the other party. Upon notice of termination, we will charge the client an
hourly fee of $350 for work performed by our firm and provide a refund if prepaid fees exceed fees
for services provided. If prepaid fees do not cover the fees owed, we will invoice the client, which will
be due immediately.
Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing
written notice to the other party. Full refunds will only be made in cases where cancellation occurs
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within 5 business days of signing an agreement. After 5 business days from initial signing, either
party must provide the other party 30 days written notice to terminate billing. Billing will terminate
30 days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes
into account work completed by our firm on behalf of the client. Clients will incur charges for bona
fide advisory services rendered up to the point of termination (determined as 30 days from receipt
of said written notice) and such fees will be due and payable.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission. In order to sell securities for a
commission, we would need to have our associated persons registered with a broker-dealer. We
have chosen not to do so.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
Individuals
•
• High Net Worth Individuals
• Pension and Profit Sharing Plans
Our current requirements for opening and maintaining accounts or otherwise engaging us:
• We generally require a minimum household account balance of $500,000 and an annual
minimum fee of $6,250 for our Investment Management service. The minimum household
account balance and annual minimum fee requirements are negotiable in order to
accommodate clients subject to a previously offered fee arrangement with our firm. Clients
will remain subject to the fee arrangement in their signed agreement with our firm.
• We generally charge a minimum fee of $3,750 for Comprehensive Financial Planning service.
This minimum fee requirement is negotiable.
•
• Our Investment Management service typically includes asset management and financial
planning or consulting services for a single fee. However, if an Investment Management client
does not maintain $1 million in assets under management with our firm by the end of their
first year as an Investment Management client, they will be charged a separate fee for
financial planning or consulting services.
If a Comprehensive Financial Planning client subsequently becomes an Investment
Management client with at least $1 million in assets under management with our firm by the
end of their first year as an Investment Management client, we will reduce their Investment
Management advisory fee by the dollar amount paid for a comprehensive financial plan.
However, we shall not rollover excess financial planning fees into the second year if those
fees are higher than the first year of Investment Management fees.
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Clients who opt into electronic delivery of statements or maintain at least $1 million in assets at
Fidelity will not be charged transaction fees for U.S. listed equities and exchange traded funds.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the
intrinsic value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can
be made by purchasing the mispriced security and then waiting for the market to recognize its
"mistake" and reprice the security.; and (b) Technical analysis maintains that all information is
reflected already in the price of a security. Technical analysts analyze trends and believe that
sentiment changes predate and predict trend changes. Investors' emotional responses to price
movements lead to recognizable price chart patterns. Technical analysts also analyze historical
trends to predict future price movement. Investors can use one or both of these different but
complementary methods for stock picking. This presents a potential risk, as the price of a security
can move up or down along with the overall market regardless of the economic and financial factors
considered in evaluating the stock.
Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis: Analysis of the experience and
track record of the manager of the mutual fund or ETF in an attempt to determine if that manager
has demonstrated an ability to invest over a period of time and in different economic conditions. The
underlying assets in a mutual fund or ETF are also reviewed in an attempt to determine if there is
significant overlap in the underlying investments held in another fund(s) in the Client’s portfolio. The
funds or ETFs are monitored in an attempt to determine if they are continuing to follow their stated
investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments,
past performance does not guarantee future results. A manager who has been successful may not be
able to replicate that success in the future. In addition, as our firm does not control the underlying
investments in a fund or ETF, managers of different funds held by the Client may purchase the same
security, increasing the risk to the Client if that security were to fall in value. There is also a risk that
a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which
could make the holding(s) less suitable for the Client’s portfolio.
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Investment Strategies We Use
Our firm will make long term purchases (securities held at least a year), short term purchases
(securities sold within a year), trading (securities sold within 30 days), and short sales. Generally
there is more risk involved with shorter trading. We also use short sales to implement our strategies
in which we would hope to make a profit from prices going down. The related risks occur when the
price of the assets rises. There may also be costs for shorting such as a fee for borrowing the assets
and payment of any dividends on the borrowed assets. Similarly margin transactions, option writing,
including covered options, uncovered options or spreading strategies may be used to implement our
strategies.
Exchange Traded Funds (“ETFs”): An ETF is a type of Investment Company (usually, an open-end
fund or unit investment trust) whose primary objective is to achieve the same return as a particular
market index. The vast majority of ETFs are designed to track an index, so their performance is close
to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference
between the returns of a fund and the returns of the index, can arise due to differences in
composition, management fees, expenses, and handling of dividends. ETFs benefit from continuous
pricing; they can be bought and sold on a stock exchange throughout the trading day. Because ETFs
trade like stocks, you can place orders just like with individual stocks - such as limit orders, good-
until-canceled orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are
bought and redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought
and sold at the market prices on the exchanges, which resemble the underlying NAV but are
independent of it. However, arbitrageurs will ensure that ETF prices are kept very close to the NAV
of the underlying securities. Although an investor can buy as few as one share of an ETF, most buy in
board lots. Anything bought in less than a board lot will increase the cost to the investor. Anyone can
buy any ETF no matter where in the world it trades. This provides a benefit over mutual funds, which
generally can only be bought in the country in which they are registered.
One of the main features of ETFs are their low annual fees, especially when compared to traditional
mutual funds. The passive nature of index investing, reduced marketing, and distribution and
accounting expenses all contribute to the lower fees. However, individual investors must pay a
brokerage commission to purchase and sell ETF shares; for those investors who trade frequently,
this can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost
brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient.
Mutual Funds: A mutual fund is a company that pools money from many investors and invests that
money in a variety of differing security types based on the objectives of the fund. The portfolio of the
fund consists of the combined holdings it owns. Each share represents an investor’s proportionate
ownership of the fund’s holdings and the income those holdings generate. The price that investors
pay for mutual fund shares are the fund’s per share net asset value (“NAV”) plus any shareholder fees
that the fund imposes at the time of purchase (such as sales loads). Investors typically cannot
ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence
which securities the fund manager buys and sells or the timing of those trades. With an individual
stock, investors can obtain real-time (or close to real-time) pricing information with relative ease by
checking financial websites or by calling a broker or your investment adviser. Investors can also
monitor how a stock’s price changes from hour to hour—or even second to second. By contrast, with
a mutual fund, the price at which an investor purchases or redeems shares will typically depend on
the fund’s NAV, which is calculated daily after market close.
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The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an
investing strategy that generally sums up as “Don’t put all your eggs in one basket.” Spreading
investments across a wide range of companies and industry sectors can help lower the risk if a
company or sector fails. Some investors find it easier to achieve diversification through ownership of
mutual funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual
fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed
on redemption.
Mutual funds also have features that some investors might view as disadvantages: (a) Investors must
pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending
on the timing of their investment, investors may also have to pay taxes on any capital gains
distributions they receive. This includes instances where the fund performed poorly after purchasing
shares.; (b) Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given
time, nor can they directly influence which securities the fund manager buys and sells or the timing
of those trades.; and (c) With an individual stock, investors can obtain real-time (or close to real-
time) pricing information with relative ease by checking financial websites or by calling a broker or
your investment adviser. Investors can also monitor how a stock’s price changes from hour to hour—
or even second to second. By contrast, with a mutual fund, the price at which an investor purchases
or redeems shares will typically depend on the fund’s NAV, which the fund might not calculate until
many hours after the investor placed the order. In general, mutual funds must calculate their NAV at
least once every business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any
capital gains tax until the investor actually sells and makes a profit. Mutual funds, however, are
different. When an investor buys and holds mutual fund shares, the investor will owe income tax on
any ordinary dividends in the year the investor receives or reinvests them. Moreover, in addition to
owing taxes on any personal capital gains when the investor sells shares, the investor may have to
pay taxes each year on the fund’s capital gains. That is because the law requires mutual funds to
distribute capital gains to shareholders if they sell securities for a profit, and cannot use losses to
offset these gains.
Margin Transactions: Our firm may purchase securities for your portfolio with money borrowed
from your brokerage account. This allows you to purchase more stock than you would be able to with
your available cash and allows us to purchase securities without selling other holdings. Margin
accounts and transactions are risky and not necessarily appropriate for every client.
The potential risks associated with these transactions are (1) You can lose more funds than are
deposited into the margin account; (2) the forced sale of securities or other assets in your account;
(3) the sale of securities or other assets without contacting you; (4) you may not be entitled to choose
which securities or other assets in your account(s) are liquidated or sold to meet a margin call; and
(5) custodians charge interest on margin balances which will reduce your returns over time.
Options: An option is a financial derivative that represents a contract sold by one party (the option
writer) to another party (the option holder, or option buyer). The contract offers the buyer the right,
but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the
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strike price) during a certain period of time or on a specific date (exercise date). Options are
extremely versatile securities. Traders use options to speculate, which is a relatively risky practice,
while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option
buyers and writers have conflicting views regarding the outlook on the performance of a:
• Call Option: Call options give the option to buy at certain price, so the buyer would want the
stock to go up. Conversely, the option writer needs to provide the underlying shares in the
event that the stock's market price exceeds the strike due to the contractual obligation. An
option writer who sells a call option believes that the underlying stock's price will drop
relative to the option's strike price during the life of the option, as that is how he will reap
maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes
that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock
for a lower price and then sell it for a profit. However, if the underlying stock does not close
above the strike price on the expiration date, the option buyer would lose the premium paid
for the call option.
• Put Option: Put options give the option to sell at a certain price, so the buyer would want the
stock to go down. The opposite is true for put option writers. For example, a put option buyer
is bearish on the underlying stock and believes its market price will fall below the specified
strike price on or before a specified date. On the other hand, an option writer who sells a put
option believes the underlying stock's price will increase about a specified price on or before
the expiration date. If the underlying stock's price closes above the specified strike price on
the expiration date, the put option writer's maximum profit is achieved. Conversely, a put
option holder would only benefit from a fall in the underlying stock's price below the strike
price. If the underlying stock's price falls below the strike price, the put option writer is
obligated to purchase shares of the underlying stock at the strike price.
The potential risks associated with these transactions are that (1) all options expire. The closer the
option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move
very quickly. Depending on factors such as time until expiration and the relationship of the stock
price to the option’s strike price, small movements in a stock can translate into big movements in the
underlying options.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, and that their assets are appropriately diversified in
investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance.
Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that
you may lose 100% of your money. All investments carry some form of risk and the loss of capital is
generally a risk for any investment instrument.
Economic Risk: The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country that
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experiences wide swings from an economic standpoint or in situations where certain elements of an
investment instrument are hinged on dealings in such countries, the investment instrument will
generally be subject to a higher level of economic risk.
ETF & Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional
expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities, the ETF, or mutual fund holds. Clients will also
incur brokerage costs when purchasing ETFs.
Past Performance: Charting and technical analysis are often used interchangeably. Technical
analysis generally attempts to forecast an investment’s future potential by analyzing its past
performance and other related statistics. In particular, technical analysis often times involves an
evaluation of historical pricing and volume of a particular security for the purpose of forecasting
where future price and volume figures may go. As with any investment analysis method, technical
analysis runs the risk of not knowing the future and thus, investors should realize that even the most
diligent and thorough technical analysis cannot predict or guarantee the future performance of any
particular investment instrument or issuer thereof.
Description of Material, Significant or Unusual Risks
We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we
try to achieve the highest return on our client’s cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to comprehensive
portfolio management, asset management service and portfolio monitoring, as applicable.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Our firm has no other financial industry activities and affiliations to disclose.
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal
Trading
We recognize that the personal investment transactions of members and employees of our firm demand
the application of a high Code of Ethics and require that all such transactions be carried out in a way that
does not endanger the interest of any client. At the same time, we believe that if investment goals are
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similar for clients and for members and employees of our firm, it is logical and even desirable that there
be common ownership of some securities.
Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-
clearing procedure) with respect to transactions effected by our members, officers and employees for
their personal accounts1. In order to monitor compliance with our personal trading policy, we have a
quarterly securities transaction reporting system for all of our associates. Furthermore, our firm has
established a Code of Ethics which applies to all of our associated persons. An investment adviser is
considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full
disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We
have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our
Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and
Procedures. We require all of our supervised persons to conduct business with the highest level of
ethical standards and to comply with all federal and state securities laws at all times. Upon employment
or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that
they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised
persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that
might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is
provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client
wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Related persons of our firm may buy or sell securities for themselves at or about the same time they buy,
sell or recommend the same securities to client accounts. In order to minimize this conflict of interest,
our related persons will place client interests ahead of their own interests and adhere to our firm’s Code
of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities within 48 hours of buying, selling or recommending to our clients. If related
persons’ accounts are included in a block trade, our related persons will always trade personal accounts
last.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
Our firm has custodial arrangements with Fidelity Brokerage Services LLC (“Fidelity”), Charles Schwab
& Co., Inc. (“Schwab”), and American Funds Distributors, Inc. (“American Funds”) (collectively
“Custodians”). Custodians may offer our firm services which include, among others, brokerage,
custodial, administrative support, record keeping and related services that are intended to support our
firm in conducting business and in serving the best interests of our clients but may benefit our firm.
As part of the arrangement described above, Custodians also make certain research and brokerage
services available at no additional cost to our firm. These services include certain research and
brokerage services, including research services obtained by Custodians directly from independent
research companies, as selected by our firm (within specific parameters). Research products and
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our
associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for
which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which
our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in.
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services provided by Custodians to our firm may include research reports on recommendations or other
information about, particular companies or industries; economic surveys, data and analyses; financial
publications; portfolio evaluation services; financial database software and services; computerized
news and pricing services; quotation equipment for use in running software used in investment
decision-making; and other products or services that provide lawful and appropriate assistance by
Custodians to our firm in the performance of our investment decision-making responsibilities. The
aforementioned research and brokerage services are used by our firm to manage accounts for which
we have investment discretion. Without these arrangements, our firm might be compelled to
purchase the same or similar services at our own expense.
As a result of receiving the services discussed above for no additional cost, we may have an incentive to
continue to use or expand the use of Custodians’ services. Our firm examined this potential conflict of
interest when we chose to enter into the relationship with Custodians and we have determined that each
relationship is in the best interest of our firm’s clients and satisfies our client obligations, including our
duty to seek best execution. Custodians charge brokerage commissions and transaction fees for
effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual
funds, commissions are charged for individual equity and debt securities transactions). Custodians
enable us to obtain many no-load mutual funds without transaction charges and other no-load funds
at nominal transaction charges. Custodians’ commission rates are generally discounted from
customary retail commission rates. However, the commission and transaction fees charged by
Custodians may be higher or lower than those charged by other custodians and broker-dealers.
Our clients may pay a commission to Custodians that is higher than another qualified broker dealer
might charge to effect the same transaction where we determine in good faith that the commission is
reasonable in relation to the value of the brokerage and research services received. In seeking best
execution, the determinative factor is not the lowest possible cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s
services, including the value of research provided, execution capability, commission rates, and
responsiveness. Accordingly, although we will seek competitive rates, to the benefit or all clients, we
may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Although the investment research products and services that may be obtained by our firm will
generally be used to service all of our clients, a brokerage commission paid by a specific client may
be used to pay for research that is not used in managing that specific client’s account.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, we will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
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Aggregation of Purchase or Sale
We may aggregate the purchase or sale of securities for various client accounts in quantities sufficient
to obtain reduced transaction costs (known as bunching or block trading). There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives.
Although such concurrent authorizations potentially could be either advantageous or disadvantageous
to any one or more particular accounts, they are affected only when we believe that to do so will be in
the best interest of the effected accounts. When such concurrent authorizations occur, the objective is
to allocate the executions in a manner which is deemed equitable to the accounts involved.
In any given situation, we attempt to allocate trade executions in the most equitable manner possible,
taking into consideration client objectives, current asset allocation and availability of funds using price
averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
Our firm reviews accounts on at least a quarterly basis for our clients subscribing to our Investment
Management services. The nature of these reviews is to learn whether clients’ accounts are in line
with their investment objectives, appropriately positioned based on market conditions, and
investment policies, if applicable. The members of the investment committee will conduct these
reviews.
Our firm may review client accounts more frequently than described above. Among the factors which
may trigger an off-cycle review are major market or economic events, the client’s life events, requests
by the client, etc.
We do not provide written reports to Investment Management clients, unless asked to do so. Verbal
reports to clients take place on at least an annual basis when we meet with clients who subscribe to
our Investment Management service.
Comprehensive Financial Planning clients do not receive reviews of their written plans unless they
take action to schedule a financial consultation with us. We do not provide ongoing services to
Comprehensive Financial Planning clients, but are willing to meet with such clients upon their
request to discuss updates to their plans, changes in their circumstances, etc.
We offer business clients who have 401(k) accounts with assets over $1 million a plan assessment
summarized by a written review.
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Item 14: Client Referrals & Other Compensation
Custodial Arrangements
Apart from the arrangements disclosed in Item 12 of this Brochure, we do not have any additional
arrangements to disclose.
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm provides cash or
non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals). Such compensation arrangements will not result in
higher costs to the referred client. In this regard, our firm maintains a written agreement with each
unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of
$1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period
in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and
federal laws. The following information will be disclosed clearly and prominently to referred
prospective clients at the time of each testimonial or endorsement:
• Whether or not the unaffiliated person is a current client of our firm,
• A description of the cash or non-cash compensation provided directly or indirectly by our
firm to the unaffiliated person in exchange for the referral, if applicable, and
• A brief statement of any material conflicts of interest on the part of the unaffiliated person
giving the referral resulting from our firm’s relationship with such unaffiliated person.
In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are
paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm
is paying solicitation fees to another registered investment adviser, the licensure of individuals is the
other firm’s responsibility.
Item 15: Custody
Our firm does not have custody of client funds or securities. All of our clients receive account
statements directly from their qualified custodians at least quarterly upon opening of an account. If
our firm decides to also send account statements to clients, such notice and account statements
include a legend that recommends that the client compare the account statements received from the
qualified custodian with those received from our firm.
Third Party Money Movement:
The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under
the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody
Rule as well as clarified that an adviser who has the power to disburse client funds to a third party
under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has
adopted the following safeguards in conjunction with our custodians:
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• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Clients are encouraged to raise any questions with us about the custody, safety or security of their
assets and our custodial recommendations.
Item 16: Investment Discretion
Our firm exercises discretionary authority to manage securities accounts on behalf of some of our
clients. These clients need to sign a discretionary investment advisory agreement with our firm for
the management of their account.
Item 17: Voting Client Securities
SEC Rule 206(4)-6 requires investment advisers who have voting authority with respect to securities
held in their clients’ accounts to monitor corporate actions and vote proxies in their clients’
interests. We are required by the SEC to adopt written policies and procedures, make those policies
and procedures available to clients, and retain certain records with respect to proxy votes cast.
We consider proxy voting an important right of our clients as shareholders and believe that
reasonable care and diligence must be taken to ensure that such rights are properly and timely
exercised. When we have discretion to vote the proxies of our clients, we will vote those proxies in
your best interests and in accordance with these policies and procedures. Clients may request a copy
of our written policies and procedures regarding proxy voting and/or information on how particular
proxies were voted by contacting our chief compliance officer, Robert Sullivan by phone at 516-249-
0060 or email at bob@MyInvestmentInsight.com.
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Policy for Voting Proxies
We vote the proxies online as they come into our office. They are generally voted in accordance with
board recommendations and in a timely manner by our office. We look to ensure that our firm is
compliant with the New Exchange Act Rule 14a-11. In accordance with the aforementioned rule, our
firm provides shareholders with the opportunity to nominate directors at a shareholder meeting
under the applicable state or foreign law. Clients also have the ability to have their nominees included
in the company proxy materials sent to all of our shareholders. Furthermore, the clients as
shareholders also have the ability to use the shareholder proposal process to establish procedures
for the inclusion of shareholder director nominations in company proxy materials.
Proxies Voting Guidelines
Where voting authority exists, proxies are voted by our firm in the best interests of plan beneficiaries:
•
•
for directors and for management on routine matters.
for a limit on or reduction of the number of directors, and for an increase in the number
of directors on a case by case basis.
• against the creation of a tiered board.
•
•
•
•
•
•
•
•
•
•
for the elimination of cumulative voting.
for independence of auditors
for deferred compensation.
for profit sharing plans.
for stock option plans unless the plan could result in material dilution to shares
outstanding or is excessive.
for stock repurchases.
for an increase in authorized shares unless the authorization effectively results in a blind
investment pool for shareholders.
for reductions in the par value of stock.
for company name changes.
for routine appointments of auditors.
We abstain on motions to limit directors' liability. Material issues not addressed above (e.g., mergers,
poison pills, social investing and miscellaneous shareholder proposals) are dealt with on a case-by-
case basis.
Our firm will defer to client voting policies as directed. Eligible shares are monitored against ballots
received from custodians, and detailed records of all issues and votes are maintained and reported
to clients as requested.
We recognize that under certain circumstances we may have a conflict of interest between us and
our clients. Such circumstances may include, but are not limited to, situations where our firm or one
or more of our affiliates, including officers, directors and employees, has or is seeking a client
relationship with the issuer of the security that is the subject of the proxy vote. We shall periodically
inform our employees that they are under an obligation to be aware of the potential for conflicts of
interest on the part of our firm with respect to voting proxies on behalf of funds, both as a result of
our employee’s personal relationships and due to circumstances that may arise during the conduct
of our business, and to bring conflicts of interest of which they become aware to the attention of the
proxy manager. We shall not vote proxies relating to such issuers on behalf of client accounts until
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we have determined that the conflict of interest is not material or a method of resolving such conflict
of interest has been agreed upon by our management team. A conflict of interest will be considered
material to the extent that it is determined that such conflict has the potential to influence our
decision-making in voting a proxy. Materiality determinations will be based upon an assessment of
the particular facts and circumstances. If we determine that a conflict of interest is not material, we
may vote proxies notwithstanding the existence of a conflict. If the conflict of interest is determined
to be material, the conflict shall be disclosed to our management team and we shall follow the
instructions of the management team. We shall keep a record of all materiality decisions and report
them to the management team on an annual basis.
Our chief compliance officer will maintain files relating to our proxy voting procedures. Records will
be maintained and preserved for five years from the end of the fiscal year during which the last entry
was made on a record, with records for the last two years kept on our premises. Records of the
following will be included in the files:
•
copies of these proxy voting policies and procedures, and any amendments thereto.
• a copy of each proxy statement that we receive, provided however that our firm may rely
on obtaining a copy of proxy statements from the sec’s edgar system for those proxy
statements that are available.
• a record of each vote that we cast.
• a copy of any document we created that was material to making a decision how to vote
proxies, or that memorializes that decision.
• a copy of each written client request for information on how we voted such client’s
proxies, and a copy of any written response to any client request for information on how
we voted their proxies.
Clients may request a copy of our written policies and procedures regarding proxy voting and/or
information on how particular proxies were voted by contacting our chief compliance officer, Robert
Sullivan by phone at 516-249-0060 or email at bob@MyInvestmentInsight.com.
We do not rely on third-party proxy voting services to advise us in connection with voting client
securities. We do not pay for proxy voting services with soft dollars. Also, we do not charge an
additional fee to vote proxies.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
• We do not require, nor do we solicit prepayment of more than $1,200 in fees per client, six
months or more in advance, therefore we have not included a balance sheet for our most
recent fiscal year.
• There are no additional financial conditions to disclose that may impair our ability to meet
contractual commitments to our clients.
• We have not been subject of a bankruptcy petition at any time during the past ten years.
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