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ITEM 1: COVER PAGE
Part 2A of Form ADV: Firm Brochure
August 22, 2025
Ascend Investment Partners
2225 Washington Blvd., Suite 110
Ogden, UT 84401
Firm Contact:
Garrett Smith
Chief Compliance Officer
firm
is also available on
This brochure provides information about the qualifications and business practices of Kesler,
Norman & Wride, LLC dba Ascend Investment Partners. If clients have any questions about the
contents of
this brochure, please contact us at (801) 476-1200 or via email at
garrett@ascendinvestment.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
the SEC’s website at
information about our
www.adviserinfo.sec.gov by searching CRD #307667.
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
Ascend Investment Partners 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 most recent Annual Amendment filing on 03/27/2025, the following changes have been
made:
• Our firm has added the Risks related to Structured Notes when added to a portfolio. (Item 8)
• Our firm has removed disciplinary history which was located under Item 9 due to change in
registration of Kevin Kesler.
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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 ....................................................................................................................... 6
Item 6: Performance-Based Fees & Side-By-Side Management .................................................................. 7
Item 7: Types of Clients & Account Requirements ...................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ........................................................... 8
Item 9: Disciplinary Information ................................................................................................................ 15
Item 10: Other Financial Industry Activities & Affiliations ....................................................................... 15
Item 11: Code of Ethics, Participation or Interest in ................................................................................... 16
Item 12: Brokerage Practices ...................................................................................................................... 18
Item 13: Review of Accounts or Financial Plans ........................................................................................ 20
Item 14: Client Referrals & Other Compensation....................................................................................... 21
Item 15: Custody ......................................................................................................................................... 21
Item 16: Investment Discretion ................................................................................................................... 22
Item 17: Voting Client Securities................................................................................................................ 22
Item 18: Financial Information ................................................................................................................... 22
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ITEM 4: ADVISORY BUSINESS
DESCRIPTION OF THE ADVISORY FIRM
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 Utah in 2009 and has been in business as an investment adviser since 2020. Our firm is owned
by CD Kesler Wealth Management, Inc., PM Norman Wealth Management, Inc., Haydar Properties,
LLC, GGS Wealth Management, Inc. and Brett Keller, which are owned and managed by Chris Kesler,
Paul Norman, Darcy Wride and Garrett Smith respectively.
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 knowing 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. In addition, our firm has developed a unique planning process that
is strong enough to be time tested but flexible enough to handle changing market. Our planning
method called the CLIMBTM method which is designed to help guide you to and through retirement
systematically. The CLIMBTM Process simplifies financial planning and asset management so as to not
overwhelm you from the start. The CLIMBTM Process includes (1) Characterizing your goals; (2)
Leveraging our knowledge; (3) Implementing a plan; (4) Monitoring and reviewing your accounts;
and then (5) Benefiting from your hard work.
TYPES OF ADVISORY SERVICES OFFERED
Wrap Asset Management:
Please refer to our Part 2A, Appendix 1 (“Wrap Fee Program Brochure”) for more information
regarding our Wrap Asset Management service offering.
Pontera® Held Away Accounts Service:
In certain instances, our firm will provide an additional service for client’s held away accounts
through the Pontera platform (“the platform”). The accounts are not directly held in our custody (i.e.,
held away), but are ones wherein we still have discretion, and may leverage an Order Management
System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf
of the client. These are primarily 401(k) accounts, HSA’s, and other assets we do not custody and
cannot manage through our Wrap Asset Management service.
If our firm offers a client this service, then a link will be provided to the client allowing them to
connect an account(s) to the platform. Once the client’s account(s) are connected to the platform, our
firm will review their current account allocations. Our firm will then review these accounts on a
regular basis and when deemed necessary, our firm will rebalance the account considering client
investment goals and risk tolerance. Any change in allocations will consider current economic and
market trends.
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Discretionary Advisory Services
Ascend offers separately managed accounts traded on a discretionary basis and advisory services of
First Clearing/Trade-PMR through their Advisory Program Account. A separate agreement will be
entered into between the client and First Clearing/Trade-PMR, that is in addition to the Advisory
Contract that you will enter into with Ascend. Program fees are paid to First Clearing/Trade PMR
and a portion of these fees will be paid to Ascend. Fees will be automatically deducted from your
account at First Clearing/Trade-PMR. Fees will not be more than 2.50% of assets held within the
Program.
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 sponsors 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.
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.
Annuity Consulting:
For annuity products that are commissioned products Ascend Investment Partners advises on these
as a consultant only. Ascend Investment Partners does not get paid by commission. Ascend Investment
Partners can advise on commissionable products already owned by clients or that clients are
considering purchasing as part of financial planning. For clients who would like advice and servicing
help on these commissionable products, they can assign Mutual Securities, LLC as the agent. Mutual
Securities provides servicing and then contracts with Ascend Investment Partners to provide
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investment advisory services for those clients who have provided written consent. Mutual Securities
pays Ascend Investment partners for consulting on these accounts and policies. See Item 10 for details
on this arrangement.
TAILORING OF ADVISORY SERVICES
Our firm offers individualized investment advice to our current Wrap Asset Management clients.
General investment advice will be offered to our Retirement Plan Consulting, and Referrals to Third
Party Money Management clients.
Each Wrap Asset 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.
Pontera® Held Away Accounts Service:
In certain instances, our firm will provide an additional service for client’s held away accounts
through the Pontera platform (“the platform”). The accounts are not directly held in our custody (i.e.,
held away), but are ones wherein we still have discretion, and may leverage an Order Management
System to implement tax-efficient asset location and opportunistic rebalancing strategies on behalf
of the client. These are primarily 401(k) accounts, HSA’s, and other assets we do not custody and
cannot manage through our Wrap Asset Management service.
If our firm offers a client this service, then a link will be provided to the client allowing them to
connect an account(s) to the platform. Once the client’s account(s) are connected to the platform, our
firm will review their current account allocations. Our firm will then review these accounts on a
regular basis and when deemed necessary, our firm will rebalance the account considering client
investment goals and risk tolerance. Any change in allocations will consider current economic and
market trends.
Participation in Wrap Fee Programs
Our firm offers and sponsors a wrap fee program. Asset Management services are only offered
through wrapped accounts, which are managed on an individualized basis according to the client’s
investment objectives, financial goals, risk tolerance, etc. Please see our firm’s Wrap Fee Program
Brochure for more information.
Regulatory Assets Under Management
As of December 31, 2024, our firm manages $585,439,168 of client assets on a discretionary basis
and $9,034,261 on a non-discretionary basis.
ITEM 5: FEES & COMPENSATION
COMPENSATION FOR OUR ADVISORY SERVICES AND PAYMENT OF FEES
Wrap Asset Management:
Please see our Wrap Fee Program Brochure for information regarding our fees and compensation
for Wrap Asset Management services.
Pontera® Held Away Accounts Service:
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As noted in Item 4 of this brochure, in certain instances, our firm will manage clients held away
accounts through the Pontera platform. While there are fees associated with this platform, our firm
feels that it is important to note that these fees will be paid by our firm and as such will not result in
the client paying higher fees than if the assets were custodied with our recommended custodian.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed 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 percentage of managed
Plan assets will not exceed 1.00%. Annualized advisory fees will be billed on a pro-rata basis
monthly in arrears based on the time-weighted daily average of the month.
Hourly Consulting and Financial Planning:
Financial plans and financial planning may include but are not limited to: investment planning;
tax concerns; retirement planning; college planning; debt credit planning, account management
for client heirs and other services as determined between the adviser and the client. Fee will be
agreed upon and may vary between $100 to $500 an hour depending upon the complexity of the
services rendered.
OTHER TYPES OF FEES & EXPENSES
Clients are responsible for the payment of all third-party fees that may include the following;
However, 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, 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. See Item 12 of this brochure regarding broker-dealer products.
Wrap clients will not incur transaction costs for trades by their chosen custodian. More information
about this can be found in our separate Wrap Fee Program Brochure.
TERMINATION & REFUNDS
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
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.
OUTSIDE-COMPENSATION FOR COMMISSIONABLE SECURITIES SALES
Our firm and representatives do not sell securities for a commission in advisory accounts.
ITEM 6: PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT
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Our firm does not accept performance-based fees or other fees based on a share of capital gains or
capital appreciation of the assets of a client.
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;
• Broker Dealer and other institutional clients; and
• Corporations, Limited Liability Companies and/or Other Business Types
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 when 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.
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.
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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.
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: 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's 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
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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
probability of its direction and of 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.
Third-Party Money Manager Analysis: The analysis of the experience, investment philosophies,
and past performance of independent third-party investment managers in an attempt to determine
if that manager has demonstrated an ability to invest over a period of time and in different economic
conditions. Analysis is completed by monitoring the manager’s underlying holdings, strategies,
concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of
the due-diligence process, the manager’s compliance and business enterprise risks are surveyed and
reviewed. A risk of investing with a third-party manager who has been successful in the past is that
they may not be able to replicate that success in the future. In addition, as our firm does not control
the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager
may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable
investment for our clients. Moreover, as our firm does not control the manager’s daily business and
compliance operations, our firm may be unaware of the lack of internal controls necessary to prevent
business, regulatory or reputational deficiencies.
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
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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-
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.
Duration Constraints: Our firm adhere 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.
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 a bond. 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
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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
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.
Master Limited Partnerships (“MLPs”): MLPs are publicly traded partnerships that trade mainly
on the New York Stock Exchange and/or the NASDAQ, the same as stocks. With a few exceptions,
MLPs hold and operate assets related to the transportation and storage of energy (certain MLPs may
have commodity risk). Most publicly traded companies are corporations. Corporate earnings are
usually taxed twice. The business entity is taxed on any money it makes and then shareholders are
taxed on the earnings the company distributes to them. In the 1980s, Congress allowed public trading
of certain types of companies as partnerships instead of corporations. The main advantage a
partnership has over a corporation is that partnerships are “pass through” entities for tax purposes.
This means that the company does not pay any tax on its earnings. Distributions are still taxed, but
this avoids the problem of double taxation that most publicly traded companies face. Congress
requires that any company designated as an MLP has to produce 90% of its earnings from “qualified
resources” (natural resources and real estate). Most MLPs are involved in energy infrastructure, i.e.
things like pipelines. MLPs are required to pay minimum quarterly distributions to limited partners.
A contract establishes the payments, so distributions are predictable. Otherwise, the shareholders
could find the company in breach of contract.
MLPs bear three primary risks: (a) The government could step in and change the rules of the game.
That can always happen. Since one of the main advantages of these securities is their tax advantages,
this poses a considerable risk for an investor.; (b) It is commonly thought that these types of
investments do better when interest rates are low, making their yield higher in relation to the safest
investments, such as Treasury bills and securities that are guaranteed by the U.S. government.
Consequently, MLPs may perform better during periods of declining or relatively low interest rates
or, more poorly during periods of rising or high interest rates.; and (c) MLPs are pass-through
entities, passing earnings through to the limited partners. Investors must be aware that there are
potentially significant tax implications of investing in MLPs and they should consult with their tax
advisor before investing in these securities.
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
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:
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• 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.
Margin Transactions: Our firm may purchase stocks, mutual funds, and/or other 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 stock 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; and (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.
Real Estate Investment Trusts (“REITs”): REITs primarily invest in real estate or real estate-
related loans. Equity REITs own real estate properties, while mortgage REITs hold construction,
development and/or long-term mortgage loans. Changes in the value of the underlying property of
the trusts, the creditworthiness of the issuer, property taxes, interest rates, tax laws, and regulatory
requirements, such as those relating to the environment all can affect the values of REITs. Both types
of REITs are dependent upon management skill, the cash flows generated by their holdings, the real
estate market in general, and the possibility of failing to qualify for any applicable pass-through tax
treatment or failing to maintain any applicable exempted status afforded under relevant laws.
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 purchase.
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Structured Note Risk: Investors in structured notes may lose some or all of their investment if the
underlying security or index decreases in value over the term of the note. They are also subject to
the credit risk of the issuer and can experience losses in the event of a default of the issuer
regardless of the performance of the underlying security.
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.
Cash & Cash Equivalents Risk: Cash and cash equivalents generally refer to either United States
dollars or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank
CD’s and commercial papers. Generally, these assets are considered nonproductive and will be
exposed to inflation risk and considerable opportunity cost risk. Investments in cash and cash
equivalents will generally return less than the advisory fee charged by our firm. Our firm may
recommend cash and cash equivalents as part of our clients’ asset allocation when deemed
appropriate and in their best interest. Our firm considers cash and cash equivalents to be an asset
class. Therefore, our firm assess an advisory fee on cash and cash equivalents unless indicated
otherwise in writing.
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.
Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with
prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk,
which is the risk that their value will generally decline as prevailing interest rates rise, which may
cause your account value to likewise decrease, and vice versa. How specific fixed income securities
may react to changes in interest rates will depend on the specific characteristics of each security.
Fixed-income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity
risk. Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely
manner, or that negative perceptions of the issuer’s ability to make such payments will cause the
price of a bond to decline.
Manager Risk: There is always the possibility that poor security selection will cause your
investments to underperform relative to benchmarks or other funds with a similar investment
objective.
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
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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.
Options Risk: Options on securities may be subject to greater fluctuations in value than an
investment in the underlying securities. Additionally, options have an expiration date, which makes
them “decay” in value over the amount of time they are held and can expire worthless. Purchasing
and writing put and call options are highly specialized activities and entail greater than ordinary
investment risks.
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
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 Wrap Asset
Management services, as applicable.
ITEM 9: DISCIPLINARY INFORMATION
There have been no criminal or civil actions, no administrative proceedings, and no self-regulatory
organization proceedings to report.
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS
REGISTRATION RELATIONSHIPS MATERIAL TO THIS ADVISORY BUSINESS
AND POSSIBLE CONFLICT OF INTERESTS
Representatives of our firm may sell insurance products and receive customary fees as a result of
insurance sales. A conflict of interest may arise as these insurance sales may create an incentive to
recommend products based on the compensation/commissions earned. To mitigate this potential
conflict, representatives of our firm as fiduciaries will act in the client’s best interest. Further, our
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firm’s representatives will not be offering insurance products outside of fee-only annuities, nor will
they receive customary fees/commissions as a result of insurance sales.
Representatives of our firm are also independent authors, who write books and author other
educational materials on the securities industry and personal finance. These books are offered
independently of the Educational Services, Materials, & Seminars described above in this Brochure
and are governed by a separate engagement agreement. Clients are under no obligation to utilize
these services.
FINANCIAL INSTITUTION CONSULTING SERVICES
Our firm has agreement(s) with broker/dealers (401K?) to provide investment consulting services
to Brokerage Customers. Broker/dealers pay compensation to our firm for providing investment
consulting services to Customers. This consulting arrangement does not include assuming
discretionary authority over Brokerage Customers’ brokerage accounts or the monitoring of
securities. These consulting services offered to Brokerage Customers may include a general review
of Brokerage Customers’ investment holdings, which may or may not result in our firm’s investment
adviser representative making specific securities recommendations or offering general investment
advice. Brokerage Customers will execute a written advisory agreement directly with our firm. This
relationship presents conflicts of interest. Potential conflicts are mitigated by Brokerage Customers
consenting to receive investment consulting services from our firm; by our firm not accepting or
billing for additional compensation on broker/dealers’ Assets Under Management beyond the
consulting fees disclosed in Item 5 in connection with the investment consulting services; and by our
firm not engaging as, or holding itself out to the public as, a securities broker/dealer. Our firm is not
affiliated with any broker/dealer.
SELECTION OF OTHER ADVISERS OR MANAGERS AND HOW THIS ADVISER IS
COMPENSATED FOR THESE SELECTIONS
Ascend offers separately managed accounts traded on a discretionary basis through First
Clearing/Trade PMR and the Advisory Services of Wells Fargo Advisors through their Advisory
Program Account. A separate agreement will be entered into between the client and First
Clearing/Trade-PMR, that is in addition to the Advisory Contract that you will enter into with
Ascend. Program fees are paid to First Clearing/Trade PMR and a portion of these fees will be paid
to Ascend. Fees will be automatically deducted from your account at First Clearing/Trade-PMR.
Fees will not be more than 2.50% of assets held within the Program.
Ascend has entered into an investment advisory contract with Mutual Securities, Inc. to provide
investment advisory services for their client’s variable annuity and variable life contracts. Ascend
receives a fee based on assets under management for the advisory services provided.
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN
Client Transactions & Personal Trading
CODE OF ETHICS
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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. 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.
TRADING SECURITIES AT OR AROUND THE SAME TIME AS CLIENTS’ SECURITIES
Our firm recognizes that the personal investment transactions of our representatives demands 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 effected 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.
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. 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 prior to buying or selling for our clients in the same day unless day unless
it is traded in the last 30 minutes of the trading day.
INVESTING PERSONAL MONEY IN THE SAME SECURITIES AS CLIENTS
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. 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.
RECOMMENDATIONS INVOLVING MATERIAL FINANCIAL INTERESTS
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.
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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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
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 an arrangement with First Clearing/Trade PMR and Altruist
Financial LLC (collectively, and together with all affiliates, "Altruist") through which Altruist provides
our firm with "institutional platform services." First Clearing/Trade PMR and Altruist are collectively
referred to as (“Custodians”), these qualified custodians are independently owned and operated from
our firm. Our Custodians offer services to independent investment advisers which includes custody
of securities, trade execution, clearance and settlement of transactions. Our Custodians enables 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 be 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,
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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 aforementioned research and brokerage services qualify for the safe harbor
exemption defined in Section 28(e) of the Securities Exchange Act of 1934.
Our Custodians do not make client brokerage commissions generated by client transactions available
for our firm’s use. The aforementioned research and brokerage services are used by our firm to
manage accounts for which our firm has investment discretion. Without this arrangement, our firm
might be compelled to purchase the same or similar services at our own expense.
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
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 has 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.
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 soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will
generally be used to service all of our clients but not necessarily all at any one particular time.
Client Brokerage Commissions
Our Custodians do 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 brokerage 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 recommends that clients direct us to execute through a specified
broker-dealer. Our firm recommends the use of First Clearing/Trade-PMR and Altruist Each client will
be required to establish their account(s) with Fist Clearing/ or Altruist if not already done. Please note
that not all advisers have this requirement.
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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 particular 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
FREQUENCY AND NATURE OF PERIODIC REVIEWS
Our management personnel or financial advisors review accounts on at least an annual basis for our
Wrap Asset 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
least an annual basis when our Wrap Asset Management and Third-Party Money Management clients
are contacted.
FACTORS THAT WILL TRIGGER A NON-PERIODIC REVIEW OF CLIENT ACCOUNTS
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.
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RETIREMENT PLAN CONSULTING CLIENTS RECEIVE REVIEWS
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
First Clearing/Trade PMR
Except for the arrangements outlined in Item 12 of this brochure, our firm has no additional
arrangements to disclose.
Altruist
Except for the arrangements outlined in Item 12 of this brochure, our firm has no additional
arrangements to disclose.
Product Sponsor Funded Events
In an effort to keep our clients informed as to the services we offer and the various financial products
we utilize, our firm occasionally sponsors events in conjunction with our product providers. These
events are educational in nature and are not dependent upon the use of any specific products. While
a conflict of interest may exist given that these events are at least partially funded by product
sponsors, all funds received from the sponsors are used for the education of our clients, and we will
always adhere to our fiduciary duties in selecting appropriate investments for our clients.
Referral Fees
Our Firm compensates third parties as lead generators for advisory referrals. Our Firm and the
referral entities comply with the SEC Promoter rules and regulations. Our Firm will provide data
regarding our services to the third party that may match certain clients with the services of the Firm.
Compensation will be paid by Ascend for referrals, and the fee for referrals will be properly disclosed
to any potential clients of Ascend in accordance with the Agreement entered between the parties.
Fees paid for referrals will not affect fees paid by clients or prospective clients.
Absolute Capital
Our Firm has entered into a party to a promoter's agreement with Absolute Capital. The Agreement
creates an opportunity for our Firm to receive payment for referring clients to a third party, under
the SEC requirements within Rule 206(4)-1 and any corresponding state securities laws.
ITEM 15: CUSTODY
Deduction of Advisory Fees:
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Our firm does not maintain physical custody of client assets. Client’s assets are maintained by a
qualified custodian, as discussed above., All 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.
Use of Pontera®:
Our firm has entered into an agreement with Pontera®, a platform allowing our firm to manage
accounts held away from our recommended custodian without obtaining client login information and
as such avoiding custody. Information about our services related to this platform is disclosed in Item
4 and 5 of this brochure.
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 provides discretionary and non-discretionary investment advisory services to clients. The
advisory contract established with each client sets forth the discretionary authority for trading.
Where investment discretion has been granted, we generally manage the client’s account and makes
investment decisions without consultation with the client as to when the securities are to be bought
or sold for the account, the total amount of the securities to be bought/sold, what securities to buy
or sell, or the price per share.
ITEM 17: VOTING CLIENT SECURITIES
Our firm will not ask for, nor accept voting authority for client securities. Client will receive proxies
directly from the issuer of the security or the custodian. Client should direct all proxy questions to
the issuer of the security.
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 a bankruptcy proceeding.
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