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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
March 2026
iWealth Financial, LLC
213 15th Ave. NE
Waseca, MN 56093
www.iWealthFinancial.com
Firm Contact:
Matt Potter
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of iWealth
Financial, LLC. If clients have any questions about the contents of this brochure, please contact us at
507-835-9111. 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 #329980.
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.
Item 2: Material Changes
iWealth Financial, LLC is required to notify clients of any information that has changed since the last
annual update of the Firm Brochure (“Brochure”) that may be important to them. Clients can request
a full copy of our Brochure or contact us with any questions that they may have about the changes.
Since our last ADV 2A filing, there have been no material changes to this brochure. To request an
additional copy, please contact your advisor.
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Item 3: Table of Contents
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 ................................................................................................................................................ 7
Item 6: Performance-Based Fees & Side-By-Side Management .......................................................................... 10
Item 7: Types of Clients & Account Requirements ................................................................................................... 10
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .................................................................. 10
Item 9: Disciplinary Information ...................................................................................................................................... 17
Item 10: Other Financial Industry Activities & Affiliations ................................................................................... 17
Item 11: Code of Ethics, Participation or Interest in ................................................................................................ 17
Item 12: Brokerage Practices ............................................................................................................................................. 18
Item 13: Review of Accounts or Financial Plans ........................................................................................................ 21
Item 14: Client Referrals & Other Compensation ...................................................................................................... 22
Item 15: Custody ...................................................................................................................................................................... 23
Item 16: Investment Discretion......................................................................................................................................... 24
Item 17: Voting Client Securities ...................................................................................................................................... 24
Item 18: Financial Information .......................................................................................................................................... 24
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Item 4: Advisory Business
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 Minnesota in 2024 and has been in business as an investment adviser since that time. Our
firm is wholly owned by KC Holdings I, LLC.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by getting to know our client. Our firm has established a service-oriented
advisory practice with open lines of communication for many different types of clients to help meet
their financial goals while remaining sensitive to risk tolerance and time horizons. Working with
clients to understand their investment objectives while educating them about our process facilitates
the kind of working relationship we value.
Types of Advisory Services Offered
Investment Management:
As part of our Investment Management service clients will be provided investment management and
offered 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 to understand their current financial situation, existing resources, financial goals, and
tolerance 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.
IWealth Financial may utilize the sub-advisory services of a third-party investment advisory firm or
individual advisor to aid in the implementation of an investment portfolio designed by our firm.
Before selecting a firm or individual, our firm will ensure that the chosen party is properly licensed
or registered. Our firm will not offer advice on any specific securities or other investments in connection
with this service. We will provide initial due diligence on third party money managers and ongoing
reviews of their management of client accounts. In order to assist in the selection of a third-party money
manager, our firm will gather client information pertaining to their financial situation, investment
objectives, and reasonable restrictions imposed upon the management of the account.
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Our firm will periodically review third party money manager reports provided to the client at least
annually. Our firm will contact clients from time to time in order to review their financial situation
and objectives; communicate information to third party money managers as warranted; and assist
the client in understanding and evaluating the services provided by the third-party money manager.
Clients will be expected to notify our firm of any changes in their financial situation, investment
objectives, or account restrictions that could affect their financial standing.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
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.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming
that all the information and documents requested from the client are provided promptly, plans or
consultations are typically completed within 6 months of the client signing a contract with our firm.
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.
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• 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.
In providing services for retirement plan consulting, 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. General
investment advice will be offered to our Financial Planning & Consulting, Retirement Plan Consulting,
and Referrals to Third Party Money Management clients.
Each Investment Management or Investment Management client has the opportunity to place
reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on
investments in certain securities or types of securities may not be possible due to the level of
difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
Our firm manages $ 311,606,497 in discretionary assets and $0 in non-discretionary assets as of
12/31/2025.
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Item 5: Fees & Compensation
Compensation for Our Advisory Services
Investment Management:
The maximum annual fee to be charged to the client’s account(s) will not exceed 1.90%. The fee to be
assessed to each account will be detailed in the client’s signed advisory agreement, LPL Account
Application, or LPL Tiered Fee Authorization form. For our clients with assets held with LPL Financial
LLC (“LPL”), fees are billed on a pro-rata basis quarterly in advance based on the value of the
account(s) on the last day of the previous quarter. For our clients with assets held with SEI
Investments Company (“SEI”), fees are billed on a pro-rata basis quarterly in arrears based on the
value of the account(s) on the last day of the previous quarter. Fees are negotiable and will be
deducted from the account(s). Adjustments will be made for deposits and withdrawals during the
quarter. If accounts are opened during the quarter, the pro-rata advisory fees will be deducted during
the next regularly scheduled billing cycle. As part of this process, Clients understand the following:
a) LPL as the client’s custodian sends statements at least quarterly, showing all disbursements
for each account, including the amount of the advisory fees paid to our firm;
b) Clients provide authorization permitting LPL to deduct these fees;
c) LPL calculates the advisory fees for all fee schedules and deducts them from the client’s
account.
The maximum combined fee shall not exceed 2.50%. Fees charged for third party manager services
shall be in addition to our advisory fees. The third-party money managers we recommend will not
directly charge you a higher fee than they would have charged without us introducing you to them.
Third party money managers establish and maintain their own separate billing processes over which
we have no control. In general, they will directly bill you and describe how this works in their
separate written disclosure documents.
Financial Planning & Consulting:
Our firm charges on an hourly or flat fee basis for financial planning and consulting services which
may be waived for Investment Management clients. 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 maximum
hourly fee to be charged will not exceed $500. Flat fees will not exceed $50,000. The fee-paying
arrangements will be determined on a case-by-case basis and will be detailed in the signed Financia
planning/consulting agreement. Our firm will not require a retainer exceeding $1,200 when services
cannot be rendered within 6 months.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed on an hourly or flat fee basis 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. Fees based on a
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percentage of managed Plan assets will not exceed 1.00%. The fee-paying arrangements will be
determined on a case-by-case basis and will be detailed in the signed consulting agreement.
Other Types of Fees & Expenses
Clients will incur transaction fees for trades executed by their chosen custodian, either based on a
percentage of the dollar amount of assets in the account(s) or via individual transaction charges.
These transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen
custodian.
Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and
exchange traded funds.
LPL offers a trading platform with select exchange traded funds (“ETFs”) that do not charge
transaction fees. The no-transaction-fee ETF trading platform is available to clients participating in
LPL Financial’s Strategic Wealth Management (“SWM”) programs. Clients will be subject to
transaction fees charged by LPL Financial for ETFs not included in LPL Financial’s platform and for
other types of securities. The limited number of ETFs available on LPL Financial’s no-transaction fee
platform may have higher overall expenses than other types of securities and ETFs not included in
the platform. Other major custodians have eliminated transaction fees for all ETFs and U.S. listed
equities, so clients may pay more for investing in the same securities at LPL Financial.
SEI may charge transaction fees for certain investments based on the type of client account.
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 (e.g., fund management fees and other fund expenses), distribution
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.
Termination & Refunds
Either party may terminate the signed advisory agreement at any time. Upon receipt of your notice
of termination, LPL will process a pro-rate refund of the unearned portion of the advisory fees
charged in advance at the beginning of the quarter.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm.
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
within 5 business days of signing an agreement. After 5 business days from initial signing, either
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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
Representatives of our firm are registered representatives of LPL Financial LLC, member
FINRA/SIPC. As such they are able to accept compensation for the sale of securities or other
investment products, including distribution or service (“trail”) fees. Clients should be aware that the
practice of accepting commissions for the sale of securities presents a conflict of interest and gives
our firm and/or our representatives an incentive to recommend investment products based on the
compensation received. Our firm generally addresses commissionable sales conflicts that arise when
explaining to clients these sales create an incentive to recommend based on the compensation to be
earned and/or when recommending commissionable mutual funds, explaining that “no-load” funds
are also available. Our firm does not prohibit clients from purchasing recommended investment
products through other unaffiliated brokers or agents.
Representatives of our firm are also associated with LPL as broker-dealer registered representatives
(“Dually Registered Persons”). In their capacity as registered representatives of LPL, certain Dually
Registered Persons may earn commissions for the sale of securities or investment products that they
recommend for brokerage clients. They do not earn commissions on the sale of securities or
investment products recommended or purchased in advisory accounts through our firm. Clients have
the option of purchasing many of the securities and investment products made available through
another broker-dealer or investment adviser. When purchasing these securities and investment
products away from our firm, however, Clients will not receive the benefit of the advice and other
services we provide.
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 and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension and Profit-Sharing Plans;
• Corporations, Limited Liability Companies and/or Other Business Types
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Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
us.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Charting: In this type of technical analysis, our firm reviews charts of market and security activity in
an attempt to identify when the market is moving up or down and to predict how long the trend may
last and when that trend might reverse.
Cyclical Analysis: Statistical analysis of specific events occurring at a sufficient number of relatively
predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical
forces drive price movements in the financial markets. Risks include that cycles may invert or
disappear, and there is no expectation that this type of analysis will pinpoint turning points, instead
be used in conjunction with other methods of analysis.
Duration Constraints: Our firm adheres to a discipline of generally maintaining duration within a
narrow band around benchmark duration in order to limit exposure to market risk. Our portfolio
management team rebalances client portfolios to their current duration targets on a periodic basis.
The risk of constraining duration is that the client may not participate fully in a large rally in bond
prices.
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
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movements lead to recognizable price chart patterns. Technical analysts also analyze historical
trends to predict future price movements. 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.
Qualitative Analysis: A securities analysis that uses subjective judgment based on unquantifiable
information, such as management expertise, industry cycles, strength of research and development,
and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on
numbers that can be found on reports such as balance sheets. The two techniques, however, will often
be used together in order to examine a company's operations and evaluate its potential as an
investment opportunity. Qualitative analysis deals with intangible, inexact concerns that belong to
the social and experiential realm rather than the mathematical one. This approach depends on the
kind of intelligence that machines (currently) lack, since things like positive associations with a
brand, management trustworthiness, customer satisfaction, competitive advantage and cultural
shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative
analysis is that subjective judgment may prove incorrect.
Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The
process usually consists of searching vast databases for patterns, such as correlations among liquid
assets or price-movement patterns (trend following or mean reversion). The resulting strategies may
involve high-frequency trading. The results of the analysis are taken into consideration in the
decision to buy or sell securities and in the management of portfolio characteristics. A risk in using
quantitative analysis is that the methods or models used may be based on assumptions that prove to
be incorrect.
Sector analysis involves identification and analysis of various industries or economic sectors that are
likely to exhibit superior performance. Academic studies indicate that the health of a stock sector is
as important as the performance of the individual stock itself. In other words, even the best stock
located in a weak sector will often perform poorly because that sector is out of favor. Each industry
has differences in terms of its customer base, market share among firms, industry growth,
competition, regulation, and business cycles. Learning how the industry operates provides a deeper
understanding of a company's financial health. One method of analyzing a company's growth
potential is examining whether the amount of customers in the overall market is expected to grow.
In some markets, there is zero or negative growth, a factor demanding careful consideration.
Additionally, market analysts recommend that investors should monitor sectors that are nearing the
bottom of performance rankings for possible signs of an impending turnaround.
Technical Analysis: A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the history
of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are mathematical
transformations of price, often including up and down volume, advance/decline data and other
inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
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probability of its direction and continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among traders
and financial professionals and is very often used by active day traders, market makers, and pit
traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
Investment Strategies We Use
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the
investor's risk tolerance, goals, and investment time frame. Asset allocation is based on the principle
that different assets perform differently in different market and economic conditions. A fundamental
justification for asset allocation is the notion that different asset classes offer returns that are not
perfectly correlated, hence diversification reduces the overall risk in terms of the variability of
returns for a given level of expected return. Although risk is reduced as long as correlations are not
perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation
and variance) that existed over some past period. Expectations for return are often derived in the
same way.
An asset class is a group of economic resources sharing similar characteristics, such as riskiness and
return. There are many types of assets that may or may not be included in an asset allocation strategy.
The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of
any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic,
foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally:
investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long-
term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these
three provides a starting point. Usually included are hybrid instruments such as convertible bonds
and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be
considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others.;
Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps;
insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products,
etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and
futures; foreign currency; venture capital; private equity; and/or distressed securities.
There are several types of asset allocation strategies based on investment goals, risk tolerance, time
frames, and diversification. The most common forms of asset allocation are strategic, dynamic,
tactical, and core-satellite.
• Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset
mix that seeks to provide the optimal balance between expected risk and return for a long-
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term investment horizon. Generally speaking, strategic asset allocation strategies are
agnostic to economic environments; i.e., they do not change their allocation postures relative
to changing market or economic conditions.
• Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in
that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance
between expected risk and return for a long-term investment horizon. Like strategic
allocation strategies, dynamic strategies largely retain exposure to their original asset
classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust
their postures over time relative to changes in the economic environment.
• Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a
more active approach that tries to position a portfolio into those assets, sectors, or individual
stocks that show the most potential for perceived gains. While an original asset mix is
formulated much like strategic and dynamic portfolio, tactical strategies are often traded
more actively and are free to move entirely in and out of their core asset classes
• Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core'
strategic element making up the most significant portion of the portfolio, while applying a
dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this
way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical
allocation strategies mentioned above.
Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed-income investments because of the
reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid
income face the risk of inflation eroding their spending power.
Some examples of fixed-income investments include treasuries, money market instruments,
corporate bonds, asset-backed securities, municipal bonds, and international bonds. The primary
risk associated with fixed-income investments is the borrower defaulting on his payment. Other
considerations include exchange rate risk for international bonds and interest rate risk for longer-
dated securities. The most common type of fixed-income security is bonds. Bonds are issued by
federal governments, local municipalities, and major corporations. Fixed-income securities are
recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio
dedicated to fixed income depends on your own personal investment style. There is also an
opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products,
such as junk bonds and longer-dated products, should comprise a lower percentage of your overall
portfolio.
The interest payment on fixed-income securities is considered regular income and is determined
based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-
income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate,
because they are considered riskier. The longer the security is on the market, the more time it has to
lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns
the amount borrowed, also referred to as the principal or par value.
Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively
long time (more than a year) in anticipation that the security’s value will appreciate over a long
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horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that
could have been profitable to your account, or it’s possible that the security’s value may decline
sharply before our firm makes a decision to sell.
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. It should be
noted that our firm bills advisory fees on securities purchased on margin which creates a financial
incentive for us to utilize margin in client accounts.
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.
Uncovered Options: Uncovered option writing is suitable only for the knowledgeable investor who
understands the risks, has the financial capacity and willingness to incur potentially substantial
losses, and has sufficient liquid assets to meet applicable margin requirements. If the value of the
underlying instrument moves against an uncovered writer’s options position, our firm may request
significant additional margin payments. If an investor does not make such margin payments, we may
be forced to close stock or options positions in the investor’s account.
The potential loss of uncovered call writing is unlimited. The writer of an uncovered call is in an
extremely risky position and may incur large losses if the value of the underlying instrument
increases above the exercise price.
As with writing uncovered calls, the risk of writing uncovered put options is substantial. The writer
of an uncovered put option bears a risk of loss if the value of the underlying instrument declines
below the exercise price. Such loss could be substantial if there is a significant decline in the value of
the underlying instrument.
Short Sales: A short sale is a transaction in which an investor sells borrowed securities in
anticipation of a price decline and is required to return an equal number of shares at some point in
the future. These transactions have a number of risks that make it highly unsuitable for the novice
investor. This strategy has a slanted payoff ratio in that the maximum gain is limited, but the
maximum loss is theoretically infinite. The following risks should be considered: (1) In addition to
trading commissions, other costs with short selling include that of borrowing the security to short it,
as well as interest payable on the margin account that holds the shorted security. (2) The short seller
is responsible for making dividend payments on the shorted stock to the entity from whom the stock
has been borrowed. (3) Stocks with very high short interest may occasionally surge in price. This
usually happens when there is a positive development in the stock, which forces short sellers to buy
the shares back to close their short positions. Heavily shorted stocks are also susceptible to “buy-ins,”
which occur when a broker closes out short positions in a difficult-to-borrow stock whose lenders
are demanding it back. (4) Regulators may impose bans on short sales in a specific sector or even in
the broad market to avoid panic and unwarranted selling pressure. Such actions can cause a spike in
stock prices, forcing the short seller to cover short positions at huge losses.
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Short-Term Purchases: When utilizing this strategy, our firm may also purchase securities with the
idea of selling them within a relatively short time (typically a year or less). Our firm does this in an
attempt to take advantage of conditions that our firm believes will soon result in a price swing in the
securities our firm purchases.
Risk of Loss
Investing in securities involves the 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.
Company Risk: When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as an unsystematic
risk and can be reduced through appropriate diversification. There is the risk that the company will
perform poorly or have its value reduced based on factors specific to the company or its industry.
For example, if a company’s employees go on strike or the company receives unfavorable media
attention for its actions, the value of the company may be reduced.
Credit Risk: Credit risk can be a factor in situations where an investment’s performance relies on a
borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or
unfavorable performance if a borrower does not repay the borrowed funds as expected or required.
Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit
risk.
Defensive Strategy Risk: Defensive strategies are primarily used in periods of high volatility or
economic uncertainty and aimed at reducing exposure to the equity market. Our goal is simply to
help our clients achieve their financial goals, regardless of market conditions. If our firm forecasts a
prolonged and substantial downturn for the equity markets, it may adopt a defensive strategy for
clients’ growth allocation by investing substantially in money market securities and/or short-term
fixed income securities. There can be no guarantee that our firm will accurately forecast any
prolonged and substantial downturn in the equity markets, or that the use of defensive techniques
would be successful in avoiding losses. The use of defensive strategies could result in a negative
outcome for a client. A few negative consequences could be high turnover, re-entry in the same
security at a higher price, loss of growth if the equity markets move up, high tax liability within
taxable accounts and higher trading cost.
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
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.
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Equity (Stock) Market Risk: Common stocks are susceptible to general stock market fluctuations
and, volatile increases and decreases in value as market confidence in and perceptions of their issuers
change. If you held common stock, or common stock equivalents, of any given issuer, you would
generally be exposed to greater risk than if you held preferred stocks and debt obligations of the
issuer.
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.
Growth Securities Risk: Securities of companies perceived to be “growth” companies may be more
volatile than other stocks and may involve special risks. The price of a “growth” security may be
impacted if the company does not realize its anticipated potential or if there is a shift in the market
to favor other types of securities.
Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds
from your investment will not be worth what they are today. Throughout time, the prices of resources
and end-user products generally increase and thus, the same general goods and products today will
likely be more expensive in the future. The longer an investment is held, the greater the chance that
the proceeds from that investment will be worth less in the future than what they are today. Said
another way, a dollar tomorrow will likely get you less than what it can today.
Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to
the investment holder. Once an investor has acquired or has acquired the rights to an investment that
pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market
will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing
interest rates in the market will have an inverse relationship to the value of existing, interest paying
investments. In other words, as interest rates move up, the value of an instrument paying a particular
rate (fixed or variable) of interest will go down. The reverse is generally true as well.
Market Risk: The value of your portfolio may decrease if the value of an individual company or
multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is
incorrect. Further, regardless of how well individual companies perform, the value of your portfolio
could also decrease if there are deteriorating economic or market conditions. It is important to
understand that the value of your investment may fall, sometimes sharply, in response to changes in
the market, and you could lose money. Investment risks include price risk as may be observed by a
drop in a security’s price due to company specific events (e.g. earnings disappointment or downgrade
in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock values fall in
general). For fixed-income securities, a period of rising interest rates could erode the value of a bond
since bond values generally fall as bond yields go up. Past performance is not a guarantee of future
returns.
Description of Material, Significant or Unusual Risks
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Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client 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 our Investment
Management and Investment Management services, 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
Representatives of our firm are Dually Registered Persons. LPL is a broker-dealer that is
independently owned and operated and is not affiliated with our firm. Please refer to Item 12 for a
discussion of the benefits our firm may receive from LPL Financial and the conflicts of interest
associated with receipt of such benefits.
Representatives of our firm are insurance agents/brokers. They offer insurance products and receive
customary fees as a result of insurance sales. A conflict of interest exists as these insurance sales
create an incentive to recommend products based on the compensation adviser and/or our
supervised persons may earn. To mitigate this potential conflict, our firm will act in the client’s best
interest.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to always act solely in the best interest of each of our clients. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. Our firm requires all representatives 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 with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives 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. 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.
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Our firm recognizes that the personal investment transactions of our representatives demand the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
In order to prevent conflicts of interest, our firm has established procedures for transactions affected by
our representatives for their personal accounts1. In order to monitor compliance with our personal
trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. 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.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. 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
securities that will be bought or sold in client accounts unless done so after the client execution or
concurrently as a part of a block trade.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
While our firm does not maintain physical custody of client assets, we are deemed to have custody of
certain client assets if given the authority to withdraw assets from client accounts (see Item 15
Custody, below). Client assets must be maintained by a qualified custodian. Our firm seeks to
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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recommend a custodian who will hold client assets and execute transactions on terms that are overall
most advantageous when compared to other available providers and their services. The factors
considered, among others, are these:
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
• Quality of services
With this in consideration, our firm has arrangements with LPL Financial LLC, SEI Investments
Company, and Charles Schwab & Co., Inc., collectively referred to as our “Custodians”, qualified
custodians from whom our firm is independently owned and operated. Our Custodians offer services
to independent investment advisers which includes custody of securities, trade execution, clearance
and settlement of transactions. Our Custodians enable us to obtain many no-load mutual funds
without transaction charges and other no-load funds at nominal transaction charges. Our Custodians
do not charge client accounts separately for custodial services. Client accounts will be charged
transaction fees, commissions or other fees on trades that are executed or settle into the client’s
custodial account. Transaction fees may be charged based on a percentage of the dollar amount of
assets in the account(s) or via individual transaction charges. These fees are negotiated with our
Custodians and are generally discounted from customary retail commission rates. This benefits clients
because the overall fee paid is often lower than would otherwise.
Our Custodians may make certain research and brokerage services available at no additional cost to
our firm. Research products and services provided by our Custodians 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 our Custodians to our firm in the performance of our investment decision-making
responsibilities. The research and brokerage services qualify for the safe harbor exemption defined in
Section 28(e) of the Securities Exchange Act of 1934.
Our Custodians make client brokerage commissions generated by client transactions for brokerage
accounts available for our firm’s use. The research and brokerage services are used by our firm to
manage accounts for which our firm has investment discretion.
As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of
our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm
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or our related persons creates a potential conflict of interest and may indirectly influence our firm’s
choice of our Custodians as a custodial recommendation. Our firm examined this potential conflict of
interest when our firm chose to recommend our Custodians and have determined that the
recommendation is in the best interest of our firm’s clients and satisfies our fiduciary obligations,
including our duty to seek best execution.
Our clients may pay a transaction fee or commission to our Custodians that is higher than another
qualified broker dealer might charge to effect the same transaction where our firm determines in
good faith that the commission is reasonable in relation to the value of the brokerage and research
services provided to the client as a whole.
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. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Soft Dollars
Our firm does not receive any transition assistance benefits from our custodians or broker dealers.
Our firm may receive soft dollar compensation in the form of educational meetings, research,
marketing reimbursements and technology discounts from our custodians.
Client Brokerage Commissions
LPL does not make client brokerage commissions generated by client transactions available for our
firm’s use.
Client Transactions in Return for Soft Dollars
Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar
benefits.
Brokerage for Client Referrals
Our firm does not receive compensation for client referrals.
Directed Brokerage
Neither our firm nor any of our firm’s representatives have discretionary authority in making the
determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale
of securities are placed for execution, and the commission rates at which such securities transactions
are affected. Our firm routinely requires that clients direct us to execute through a specified broker-
dealer. Our firm recommends the use of LPL or Schwab. Each client will be required to establish their
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account(s) with LPL or Schwab if not already done. Please note that not all advisers have this
requirement.
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, our firm 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.
Client-Directed Brokerage
Our firm does not allow client-directed brokerage outside our recommendations.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. 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 accounts, they are affected only when our firm believes 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, our firm attempts 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 management personnel or financial advisor reviews accounts on at least an annual basis for our
Investment Management, and Third-Party Money Management clients. The nature of these reviews
is to learn whether client accounts are in line with their investment objectives, appropriately
positioned based on market conditions, and investment policies, if applicable. Our firm does not
provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at
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least an annual basis when our Investment Management, and Third-Party Money Management clients
are contacted.
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.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to 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. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or update to their initial written financial plan.
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the
service. Our firm also provides ongoing services where clients are met with upon their request to
discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients
do not receive written or verbal updated reports regarding their plans unless they choose to engage
our firm for ongoing services.
Item 14: Client Referrals & Other Compensation
LPL Financial LLC
Our firm may receive from LPL or a mutual fund company, without cost and/or at a discount on non-
soft-dollar support services and/or products, to assist us in better monitoring and service client
accounts maintained at such institutions. Included within the support services our firm may receive
investment-related research, pricing information and market data, software and other technology
that provide access to client account data, compliance and/or practice management-related
publications, discounted or gratis consulting services, discounted and/or gratis attendance at
conferences, meetings, and other educational and/or social events, marketing support, computer
hardware and/or software and/or other products used by us to assist us in our investment advisory
business operations. Our clients do not pay more for investment transactions effected and/or assets
maintained at LPL because of this arrangement. There is no commitment made by us to LPL or any
other institution because of the above arrangement.
Charles Schwab & Co., Inc.
Our firm receives economic benefit from Schwab in the form of the support products and services
made available to our firm and other independent investment advisors that have their clients
maintain accounts at Schwab. These products and services, how they benefit our firm, and the related
conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of
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Schwab’s products and services is not based on our firm giving particular investment advice, such as
buying particular securities for our clients.
SEI Investments Company
Our firm may receive compensation in the form of soft dollars from SEI.
Product Sponsors
Our firm occasionally sponsors events in conjunction with our product providers in an effort to keep
our clients informed as to the services we offer and the various financial products we utilize. These
events are educational in nature and are not dependent upon the use of any specific product. While
a conflict of interest may exist because these events are at least partially funded by product sponsors,
all funds received from product sponsors are used for the education of our clients. We will always
adhere to our fiduciary duty in recommending appropriate investments for our clients.
Representatives of our firm will occasionally accept travel expense reimbursement provided by
product sponsors in order to attend their educational events. The reimbursement is not directly
dependent upon the recommendation of any specific product. Although we may be incentivized to
recommend products from product sponsors that reimburse our travel, our representatives will
always adhere to their fiduciary duty in recommending appropriate investments for our clients.
Client Referrals
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Item 15: Custody
Deduction of Advisory Fees:
While our firm does not maintain physical custody of client assets (which are maintained by a
qualified custodian, as discussed above), we are deemed to have custody of certain client assets if
given the authority to withdraw assets from client accounts, as further described below under “Third
Party Money Movement.” All of our clients receive account statements directly from their qualified
custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review
these statements. Additionally, if our firm decides to send its own account statements to clients, such
statements will include a legend that recommends the client compare the account statements
received from the qualified custodian with those received from our firm. Clients are encouraged to
raise any questions with us about the custody, safety or security of their assets and our custodial
recommendations.
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Third Party Money Movement:
On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to 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 authorization (“SLOA”) is deemed to have custody.
As such, our firm has adopted the following safeguards in conjunction with our custodian:
• 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.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, our firm is
authorized to execute securities transactions, determine which securities are bought and sold, and
the total amount to be bought and sold. Should clients grant our firm non-discretionary authority,
our firm would be required to obtain the client’s permission prior to effecting securities transactions.
Limitations may be imposed by the client in the form of specific constraints on any of these areas of
discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote for client securities. Clients will receive proxies
or other solicitations directly from their custodian or a transfer agent. If proxies are sent to our firm,
our firm will forward them to the appropriate client and ask the party who sent them to mail them
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directly to the client in the future. Clients may call, write or email us to discuss questions they may
have about particular proxy votes or other solicitations.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
• Our firm does not take custody of client funds or securities.
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
Our firm has never been the subject of bankruptcy proceedings.
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