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ADV Part 2A Disclosure Brochure
226 W. Eldorado Street
Decatur, IL 62522
(217) 425-6340
www.investment-planners.com
June 9, 2025
This brochure provides information about the qualifications and business practices of IPI
Wealth Management, Inc. (also referred to in this brochure as “us,” “we,” “our” or the “firm”).
Our firm’s clients and prospective clients are referred to in this brochure as “you,” “your” or
“our clients.” If you have any questions about the contents of this brochure, please contact
us at (217) 425-6340 or compliance@investment-planners.com. The information in this
brochure has not been approved or verified by the United States Securities and Exchange
Commission (“SEC”) or by any state securities authority.
We are registered under the Investment Advisers Act of 1940. Registration of an adviser
does not imply a certain level of skill or training.
information about us also
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov.
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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ITEM 2: SUMMARY OF MATERIAL CHANGES
From time to time we may amend this Disclosure Brochure to reflect changes in our
business practices, changes in regulations and routine annual updates as required by the
securities regulators. Upon a material change occurring, IPI Wealth Management, Inc. will
then either provide you a complete Disclosure Brochure or offer to provide one to you upon
your written request.
Since our previous Disclosure Brochure of March 24, 2025 our material changes for this
filing are the following:
Item 4; page 5 – Use of Outsourced Agent (TAIKO) for Client Accounts
•
Item 5; page 15 – Fee Facilitation by Outsourced Agent (TAIKO)
•
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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ITEM 3: TABLE OF CONTENTS
ITEM 1: COVER PAGE ..................................................................................................................... i
ITEM 2: SUMMARY OF MATERIAL CHANGES .................................................................... ii
ITEM 3: TABLE OF CONTENTS ................................................................................................ iii
ITEM 4: ADVISORY BUSINESS ................................................................................................... 1
ITEM 5: FEES AND COMPENSATION ................................................................................... 10
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ........ 18
ITEM 7: TYPES OF CLIENTS ...................................................................................................... 18
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF
LOSS .................................................................................................................................................. 19
ITEM 9: DISCIPLINARY INFORMATION ............................................................................. 24
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ........ 24
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING ................................................................... 26
ITEM 12: BROKERAGE PRACTICES ...................................................................................... 27
ITEM 13: REVIEW OF ACCOUNTS .......................................................................................... 30
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION .................................. 32
ITEM 15: CUSTODY ...................................................................................................................... 32
ITEM 16: INVESTMENT DISCRETION .................................................................................. 33
ITEM 17: VOTING CLIENT SECURITIES .............................................................................. 34
ITEM 18: FINANCIAL INFORMATION .................................................................................. 34
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 1 of 34
ITEM 4: ADVISORY BUSINESS
IPI Wealth Management, Inc., previously known as IPI Asset Management, (collectively,
“IPIWM”), was founded in 1996 by David Koshinski, our principal owner. In 1999, we registered
with the SEC as an investment adviser offering a full array of portfolio management and
financial planning services to retail and institutional investors. Headquartered in Decatur,
Illinois, we have 41 other office locations located in eighteen states and Italy – AZ, CO, FL,
IA, IL, IN, KS, MI, MO, NC, NJ, NV, OH, PA, PR, SD, TN, and WI. Our investment advisor
representatives (or “IARs”) may also be registered representatives of our affiliated broker-
dealer, Investment Planners, Inc., an SEC registered broker-dealer clearing transactions
and introducing accounts on a fully disclosed basis to RBC Clearing and Custody, (or “RBC”).
Our affiliation with Investment Planners, Inc. is by common control and ownership. Both
Investment Planners, Inc. and RBC are members of the Financial Industry Regulatory
Authority (“FINRA”) and registered with the SEC as securities broker-dealers.
OUR ADVISORY SERVICES
IPIWM has built a strong reputation within the financial services industry through its open-
architecture model and commitment to service. We provide advisory services to clients
investment management, financial planning, consulting, and third-party
through
investment managers.
Private Portfolio Services of IPI Wealth Management
importantly,
Our Private Portfolio Services are those in which we actively manage your investment
portfolio based upon your individual financial and personal needs. We gather your
information through in-depth personal interviews. This includes one or more in-person
meetings and/or telephone calls. We gather information that includes, but is not limited to,
your current financial position, future goals, attitudes toward risk and your investment
objectives. We ask you to fill out a client profile questionnaire or similar document that we
will carefully review, along with all other documentation you supply. Because we only rely
upon the information you provide us and do not independently verify it, you should provide
us with accurate information, and we ask that you update your information whenever it
changes. Based on the information you provide, we will develop a personalized portfolio
designed to meet your investment goals and objectives through asset allocation, portfolio
individualized portfolio
monitoring, consolidated reporting, and most
management. Individualized portfolio management and a tailored investment strategy will
help us choose among various kinds of investments available in the market. Investments
include equity securities (stocks), warrants, corporate debt securities (bonds and notes),
certificates of deposit, municipal securities, investment company securities (mutual funds,
including money market funds), exchange-traded funds and United States government
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 2 of 34
securities. If appropriate, we may allocate your investments in accordance with our model
portfolios. A model portfolio is how we communicate to you what specific investments you
should have in your portfolio at any given time.
Model Portfolios Management Utilizing Proprietary Investment Strategies
We offer a suite of proprietary model investment strategies designed for different types of
investors. Collectively, our strategies are designed to provide a foundation for clients’
investment portfolios through both diversification and active management. These
proprietary strategies may be used exclusively or in combination with other strategies
within the client’s aggregate portfolio. In conjunction with the client’s primary advisor, our
professionals will offer specific guidance about which strategy or combination of strategies
will be best suited to each client’s investment objectives, risk tolerance and investment
time horizon, among other things, and the proper allocations within the client’s portfolio
framework. Due to the nature of managing a model portfolio, advisory accounts are
managed on a discretionary basis only.
IPI Intelligent Portfolios (Qualified & Non-Qualified): The IPI Intelligent Portfolios are
designed to accommodate a wide range of risk profiles, from capital preservation to
aggressive growth. These customized, risk-based models utilize a mix of actively managed
and passive mutual funds and ETFs, tailored for both tax-qualified and non-tax-qualified
accounts. The portfolios have long-term strategic focus while incorporating marginal
tactical tilts based on prevailing market conditions. Asset allocation decisions made by
the IPI Investment Committee in collaboration with Taiber Kosmala & Associates. Portfolio
positioning, performance, and active managers are actively monitored and reviewed on a
quarterly basis by the Investment Committee.
IPI Executive Portfolios (Qualified & Non-Qualified): Designed to be low cost, mostly
passive, risk-based portfolios anchored by a 50 Stock U.S. Large Cap Quantitative Strategy
managed by Taiber Kosmala & Associates. Asset allocation decisions made by the IPI
Investment Committee in collaboration with Taiber Kosmala & Associates. Portfolio
positioning and performance actively monitored and reviewed on a quarterly basis by the
Investment Committee.
IPI Intelligent ETF Portfolios (Qualified & Non-Qualified): The IPI Intelligent ETF Portfolios
are a series of risk-based ETF models for clients with smaller accounts or a preference for
ETF vehicles—built on the same asset allocation framework as the Intelligent Portfolios.
Asset allocation decisions made by the IPI Investment Committee in collaboration with
Taiber Kosmala & Associates. Portfolio positioning, performance, and active managers
are actively monitored and reviewed on a quarterly basis by the Investment Committee.
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 3 of 34
IPI Intelligent Income Portfolios (Qualified & Non-Qualified): Designed for clients who seek
to substitute or supplement personal income with portfolio distributions or are looking to
generate income for required minimum distributions. The portfolio’s span a spectrum of
risk tolerances, ranging from ultra-conservative to aggressive. The ultra-conservative
model prioritizes capital preservation and income generation, the more aggressive
income-focused model seeks to capture higher levels of income while maintaining a
secondary focus on capital preservation. Asset allocation decisions made by the IPI
Investment Committee in collaboration with Taiber Kosmala & Associates. Portfolio
positioning, performance, and active managers are actively monitored and reviewed on a
quarterly basis by the Investment Committee.
IPI ESG Portfolios: Risk-based portfolios constructed using a blend of actively managed
and passive ETFs and mutual funds, with a focus on companies demonstrating strong
environmental, social, and governance practices.
IPI Biblically Responsible Equity Portfolio: An all-equity portfolio using a mix of actively
managed and passive ETFs and mutual funds that follow a Biblically Responsible Investing
(BRI) approach, avoiding businesses involved in activities contrary to biblical principles.
Financial Planning Services
We provide both comprehensive and limited financial planning services. However, we
generally recommend comprehensive planning services as this provides your IAR an
opportunity to evaluate and make appropriate recommendations for you based on a
detailed and comprehensive evaluation of your current and intended future financial needs.
We will conduct an interview with you to obtain as much detail as possible on a number of
variables, including but not limited to your financial and life goals, situation, objectives, time
horizon and risk tolerance. The information we gather varies based on your individual needs
and objectives. As a result, we require your active participation while we obtain information
from you as we do not independently verify the accuracy of the data you give us and assume
that the information you provide is reliable and current.
Based on your request, plans can address some or all of the following items:
•
•
•
•
•
•
•
Estate Planning & Estate Goals
Retirement Planning
Education Planning
Insurance Planning/Risk Management
Investments
Cash Flow Analysis
Budget Planning
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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•
•
•
Tax Planning
Business Continuity, Succession and Exit Planning
Asset Allocation Services.
The specific financial planning services and fees applicable to you will be described in our
Investment Advisory Services Agreement (“Agreement”) that we will ask you to review and
sign prior to the engagement. For financial planning services, you can choose a modular
approach by focusing on a particular area, or a broader financial review, that covers multiple
topics. This means that you can work with us on a short-term, project retainer basis without
using our investment management services. After analysis and evaluation of your situation,
we will generally present you with a written report that summarizes the findings, potential
decision points, possible strategies (including their pros and cons), recommended course
and action items. However, in certain circumstances, as agreed with you, a report may not
be issued. We do not have any discretionary investment authority when providing hourly
financial planning and consulting services.
is a follow-up period before the project formally concludes.
Afterwards, there
Subsequently, you determine when to return for periodic updates or check-ups on a specific
part or on the entire plan. The engagement generally terminates upon the final consultation
unless you specifically request otherwise in our Agreement.
Implementation of any financial plan recommendation is solely at your discretion and you
will need to work with your other professionals, such as your attorney, accountant, banker,
insurance agent, stockbroker (or registered representative or financial consultant), among
others. Our IARs may also be licensed as insurance agents and registered representatives,
so your IAR is in a position to implement your plan recommendations. However, please
realize that you are under no obligation to use our IAR to implement any plan
recommendations.
IPIWM Investment Advice for Non-IPIWM Custodied Client Accounts
IPIWM, through its IARs, provides written asset allocation and/or specific investment
recommendations for clients on the investment options available within client accounts
held away from IPIWM custody firms. IARs provide advice and recommendations on assets
based on the financial and other information provided.
The IAR will tailor the
recommendation to your individual needs based upon the investment objective you choose.
The engagement terminates upon delivery of the written recommendation unless you
request otherwise in our Agreement.
IPIWM provides two different service levels with regards to held away assets. First, as a
non-discretionary service, you retain the sole responsibility for determining whether to
implement any recommendations made by your IAR and for placing any resulting
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 5 of 34
transactions with your outside accounts held away from the custodians we generally
recommend. In this service, we do not provide discretionary portfolio management
services. Second, we provide an additional service for accounts not directly held in our
custody, but where we do have discretion, and 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. We regularly review the available investment options in these accounts, monitor
them, and rebalance and implement our strategies in the same way we do other accounts,
though using different tools as necessary
USE OF OUTSOURCED AGENT (TAIKO) FOR CLIENT ACCOUNTS
We have entered into an agreement with Advisor OS LLC, doing business as TAIKO (“TAIKO”),
to act as an outsourced agent for certain client accounts. This relationship is designed to
support our advisory business by providing operational, administrative, and non-
discretionary trading execution services. TAIKO does not provide investment advice to
clients, does not have investment discretion, and does not custody client assets.
TAIKO supports us
in managing client accounts by facilitating trade execution,
implementing model portfolio allocations based on our instructions, assisting with billing
processes, maintaining data reconciliation, and delivering performance reporting and
technology support services through its proprietary platform (the “System”).
Client Account Coverage and Responsibilities – Covered Accounts, Authority and
Control, Custody and Trading
This arrangement applies only to those client accounts (“System Accounts”) that we direct
to participate in the System. We retain full fiduciary responsibility for managing client
relationships, determining suitable portfolio allocations, monitoring performance, and
ensuring that investment strategies align with each client’s objectives. TAIKO has no role in
assessing suitability or advising clients.
All trading activity and related operational tasks facilitated by TAIKO are executed based on
our express direction via a secure adviser portal. Custody of client assets remains with the
designated third-party custodian (e.g., Charles Schwab), and TAIKO does not take
possession of client funds or securities. TAIKO communicates trading instructions to
custodians solely as our agent and only in accordance with our instructions.
Client Restrictions
Clients may impose investment restrictions or preferences on their accounts. We are
responsible for collecting, evaluating, and enforcing those restrictions. TAIKO’s role is
limited to executing instructions we provide and has no obligation to evaluate client
suitability or impose restrictions independently.
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 6 of 34
Fees and Billing
TAIKO may facilitate billing processes on our behalf, including calculating advisory,
platform, and manager fees. However, TAIKO does not receive fees directly. Fees are
typically deducted from client accounts by the custodian per client authorization and then
distributed to the appropriate parties, including us as your adviser. TAIKO may instruct the
custodian to deduct and remit such fees only as our agent.
Disclosures and Records
Clients will receive disclosures as required under applicable law. These may include our
Form ADV, TAIKO’s Form ADV, disclosures from any third-party investment managers we
utilize through the System, and applicable privacy notices. We are responsible for ensuring
proper delivery of these materials and for maintaining client records related to their
participation in the System.
Schwab’s Custodial Classification of TAIKO
While TAIKO is not affiliated with Charles Schwab & Co., Inc. (“Schwab”) and is not a Schwab
service model, Schwab classifies firms like TAIKO under its “Outsourced Agent” (OA)
designation. This internal categorization governs how Schwab configures account access,
authority, and billing mechanics for service providers who operate on behalf of an adviser
but do not provide discretionary investment management.
This role is fundamentally different from that of a Turnkey Asset Management Provider
(TAMP) within Schwab’s system:
•
•
In a TAMP arrangement, the client signs a direct agreement with the TAMP, which
then assumes discretionary authority over account assets, including selecting
investments and executing trades independently.
In an outsourced agent arrangement like ours with TAIKO, you retain an advisory
relationship exclusively with us. TAIKO does not manage assets, cannot act without
our instruction, and is not authorized by clients directly.
Using an outsourced agent allows us to scale our operations and deliver enhanced
administrative efficiency while maintaining full control of your investment strategy. We
remain solely responsible for your account’s investment management and for upholding our
responsibilities to you.
Additional information about the roles and responsibilities of TAIKO, including applicable
fees, services, and limitations, is available upon request and will be provided to you in
connection with account onboarding and ongoing service updates.
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 7 of 34
Third Party Asset Management Program (“TAMP”) Services
IPIWM makes available advisory services and programs of several third-party investment
advisors. Under these TAMP programs, IPIWM through its IARs, provides ongoing
investment advice tailored to your individual needs.
As part of these TAMP services, your IAR will typically obtain the necessary financial data
from you to assist in determining appropriate investment objectives and selecting the
TAMP whose style and talent best fit your individual needs and circumstances, including
assistance in opening an account with the TAMP. Depending on the type of TAMP selected,
your IAR will usually assist you in selecting a model portfolio of securities designed by the
TAMP, or select a portfolio management firm to provide discretionary asset management
services.
You should understand that it is the third-party investment adviser (and not IPIWM or your
IAR) that has authority to purchase and sell securities on a discretionary or non-
discretionary basis pursuant to your investment objective. This authorization will be set out
in the TAMP client agreement. IPIWM currently offers advisory services through TAMPs
sponsored by RBC, Schwab, Trade PMR or Envestnet. Unless directed otherwise, your
agreement with the TAMP gives us the authority to hire or fire these managers on your
behalf. Once a manager is selected, your IAR will continue to monitor their performance.
Additionally, we will meet with you, at least annually, to determine whether any changes in
your financial status warrant adjustments to your investment objectives with the third-
party money manager. We will also be happy to meet with you more frequently, if requested.
in their respective service disclosure brochures.
If you are interested in learning more about any of these TAMP services, a complete
description of their programs, services, fees, payment structure and termination features
are found
investment advisory
agreements and account opening documents, all of which our IAR will provide you prior to
engaging their services.
From time to time we review other third-party investment managers and reserve the right
to make additional programs available to our clients, in our discretion, as we deem
appropriate and consistent with our investment strategies.
For these and other services we will receive a portion or all of the fees paid by you as
described in the “Fees and Compensation” section below.
Marketing and Sales Services for Registered Investment Advisers
IPIWM and its IARs act as marketing agents on behalf of third party registered investment
advisers (money managers) pursuant to a marketing/sales services agreement. In such
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 8 of 34
case, IPIWM provides marketing and sales services to the third-party investment adviser
related to introduction of an advisor or broker that manages primary client relationship. The
IAR also provides the broker or advisor with information with regards to money manager’s
investment strategies. IPIWM’s IARs do not provide ongoing investment advice or any other
advisory services or maintain any relationship with the individual investor.
Services Provided to Retirement Plan Sponsors
We provide investment management services to qualified retirement plans which are sub-
ject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). As part
of our services to qualified plans, we will act as either an ERISA 3(21) fiduciary advisor or an
ERISA 3(38) fiduciary manager. The key difference between these two types of fiduciaries
is whether you engage us as a discretionary manager. As a 3(38) manager, you give us
discretionary authority to manage your plan’s assets. This means that you shift your
fiduciary responsibility to us for the selection of your investments. If you hire us as a 3(21)
advisor, we will make recommendations, but it is ultimately up to you, as the plan sponsor,
to decide whether and how to act. As a 3(21) advisor, we will not have discretion to invest
and reinvest your assets without your prior consent. Thus, as a 3(21) advisor, we will share
responsibility for the selection of investments.
For all qualified plan clients, we start by assisting you with the creation and maintenance of
your investment policy statement. Your investment policy statement can place restrictions
on the types of investments the plan may invest its assets. We identify specific asset
categories to be represented in your plan’s investment menu. We then use our investment
process to select and advise on mutual funds and other securities that comprise your plan’s
investment menu. We ensure that the investment options are permitted under your
investment policy statement. We continually monitor the performance of all investment
options and communicate frequently with each mutual fund or collective trust fund
managers as needed.
We provide five risk-based asset allocation models that allow participants to invest
according to their specific goals, objectives, time to retirement, as well as risk tolerance.
We create our models by assigning a weighted allocation to the mutual funds in our
investment menu depending upon the objective of the particular model. The following is a
brief description of each of our models:
• The Income Model allows for preservation of capital and current income, with
long-term capital appreciation being secondary;
• The Conservative Model allows for preservation of capital and current income,
with consideration for long-term capital appreciation;
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 9 of 34
• The Moderate Model provides long-term capital appreciation and current income,
with consideration for preservation of capital;
• The Growth Model provides long-term capital appreciation and current income,
with reasonable risk; and
• The Aggressive Model provides long–term capital appreciation.
Participants of plans are permitted to invest in one or more of our models or individual
funds. If we provide individual investment advice to participants as described below, we
will only recommend investment in one model that meets the investment objectives, time
horizon to retirement, anticipated retirement income needs and risk tolerance of the
participant. We believe utilizing one model will provide participants with an investment
strategy that best meets their investment objectives given their personal risk tolerance.
Participant Advice
In addition to the investment supervisory services we provide to plan sponsors, the plan
sponsor can engage us to provide one-on-one investment advice to the participants of the
plan. We start this process by providing education to employees in group meetings. We
then meet individually with the participant. The participant will provide information to us
about their financial situation, risk tolerance, time horizon to retirement, anticipated
retirement income needs and investment objectives. We also provide information to the
participant on how various levels of wage deferral or contributions to their retirement plan
will impact their take-home pay. Taking all of this information into consideration, we will
recommend investments in an appropriate model.
We meet with newly eligible participants on a quarterly basis and we offer to meet with all
participants on a semi-annual basis or more or less frequently as requested by the plan
sponsor.
We believe that our individualized participant advice services tend to increase participant
retirement plan contributions and help to close the gap between a participant’s current
retirement funds and what a participant needs for retirement.
Retirement Rollovers
A client or prospective client leaving an employer typically has four options regarding an
existing retirement plan (and may engage in a combination of these options): (i) leave the
money in the former employer’s plan, if permitted, (ii) roll over the assets to the new
employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual
Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon
the client’s age, result in adverse tax consequences and possible penalties). If IPIWM and its
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and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 10 of 34
IAR recommend that a client roll over retirement plan assets into an account to be managed
by IAR, such a recommendation creates a conflict of interest if IAR will earn new or
increased compensation because of the rollover. If IPIWM IAR provides a recommendation
as to whether a client should engage in a rollover or not, whether it is from an employer’s
plan or an existing IRA, IPIWM and its IAR is acting as a fiduciary within the meaning of Title
I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. No client is under any obligation
to roll over retirement plan assets to an account managed by IPIWM or its IAR, whether it is
from an employer’s plan or an existing IRA.
ASSETS UNDER MANAGEMENT
We manage your assets on either a discretionary or nondiscretionary basis. As of December
31, 2024, we had $2,136,530,850 in client assets managed on a discretionary basis and
$112,463,591 in client assets managed on a nondiscretionary basis.
ITEM 5: FEES AND COMPENSATION
In this section, we explain how we are compensated for the various advisory services we
provide. We also describe some expenses you may experience related to those services.
We believe that our charges and fees are competitive with firms offering similar services.
However, lower fees for comparable services may be available from other sources. You can
invest in mutual funds and other securities directly, without our services. In that case, you
would not receive our assistance in determining which investments are most appropriate
to your financial situation and objectives. We also would not be able to help you maintain a
disciplined approach to portfolio rebalancing, anticipate tax consequences and minimize
emotional reactions to market events. Some investments may not be available to you
directly without the use of an IAR.
We want you to be aware of how we are paid as well as any fees and compensation that we
receive in connection with the advisory services we provide. This information can be found
in some or all of the various documents:
• ADV disclosure brochures
• Your client agreement
• Custodial agreements
• TAMP Fee Program Disclosure Brochure or similar document
• Mutual fund’s prospectuses and Statements of Additional Information.
Some of our IARs also receive commissions or other compensation as registered
representatives of our affiliated broker-dealer and/ or as insurance agents. This additional
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 11 of 34
compensation is separate and distinct from our advisory compensation. We discuss this in
more detail later in this section.
PRIVATE PORTFOLIO SERVICES
Generally, our fees for our Private Portfolio Services or individually managed accounts are
based on a percentage of assets under management. IPIWM’s portion of the annual fee will
not exceed 2% on any asset level. However, other program fees may increase the annual
fee above 2%. Below is our sample fee schedule:
Assets Under Management Annual Fee
2.0%
$ 0 - $250,000
1.5%
$ 250,001 to $500,000
1.25%
$ 500,001 to $1,000,000
1.00%
$1,000,001 to $3,000,000
.75%
$3,000,001 and above
This fee schedule can be negotiated with you on a case-by-case basis. We will take into
account the nature and complexity of the services we are providing you, our relationship
with you, the value of assets being managed, the value of other assets held in other
accounts we manage or advise for you, the potential for additional business or clients, the
amount of work anticipated, and the attention needed to manage your assets. The actual
billing rate will be specified in the Agreement. We rely upon your custodian’s account
statements for fee calculation purposes. Our advisory fees cover our investment advisory
services, but do not cover other charges as described below.
Our advisory fees will be paid monthly or quarterly, in advance or in arrears, as set forth in
our Agreement. For accounts opened or closed during the calendar month or quarter, the
fee will be prorated for the number of days our services were provided. If you terminate an
agreement with us, pre-paid and un-earned advisory fees are promptly refunded, generally
within 30 days. Fees paid in arrears will be charged through the date of termination.
Unless otherwise agreed, you will authorize us to deduct our periodic advisory fees from
your designated account. Your authorization is limited to our withdrawing our advisory fees
as and when due. We will provide your custodian with your written fee deduction
authorization. We will notify you of our fee deductions in advance of the withdrawal date at
the time and in the manner required by applicable regulatory requirements. We will not
make the fee withdrawal if you timely object, in writing, to us or your custodian. Your
account custodian will, on a quarterly basis, provide you with an account statement
indicating the advisory fees paid to us from your account. You may terminate your
authorization at any time, in writing, but you will remain responsible for promptly paying us
any advisory fees that remain due and unpaid.
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and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 12 of 34
If our direct fee deduction has been authorized, then our fees will be deducted from the cash
balance in your account. If insufficient cash is available, then we will typically liquidate a
sufficient amount of securities in your account to cover the balance due in the following
order: money market shares, mutual fund shares, and then other types of securities. For
taxable accounts, a liquidation of securities may result in taxable income.
DUAL CONTRACT SUB ADVISED FEE SCHEDULE
IPIWM will advise on third party assets through TAMP Programs, Managed Account and
Unified Managed Account platforms. The fee schedule for IPIWM’s portion of the
management of assets is as follows:
Assets Under Management
Up to $25 Million
$25 Million to $250 Million
$250 Million over
Management Fee
.50 - .75%
.40 - .50%
.25 - .40%
Fees are negotiable at the discretion of IPIWM.
WRAP FEE PROGRAMS
The sponsors of the wrap program have contracts with the client to perform investment
management, trading and/or custodian services. Clients pay a single all-inclusive fee
quarterly in advance or arrears to the wrap fee sponsor based on net assets under
management. From the all-inclusive or “wrap” fee, the sponsor will pay IPIWM an agreed
upon management fee which generally follows the dual contract or sub-adviser fee
schedule above.
MODEL PORTFOLIO ADVISOR
For our model portfolio advisor services, IPIWM will generally receive a management fee
consistent with the dual contract and sub-adviser relationships described above.
MARKETING AND SALES SERVICES FOR REGISTERED INVESTMENT
ADVISERS
Fees are negotiated with a Registered Investment Adviser and IPIWM’s IAR. Fees may be
basis points based on assets raised through sales with brokers and advisors. IPIWM will also
charge consulting fees for services such as: marketing, strategic planning and distribution
planning.
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and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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FINANCIAL PLANNING FEES
Planning Fees are based on the nature of the services provided and the complexity of your
needs. Fees are agreed upon and documented in your Agreement. At the beginning of the
service, we estimate the total cost of the Plan (either hourly or fixed fee, as described
below). Planning Fees are calculated and charged on either:
• A per-hour (or portion of an hour) basis. Hourly charges are negotiable, but
can range from $150 to $250 per hour or
• On a fixed fee basis with the total cost estimated at the beginning of the
relationship. Our experience indicates that fixed fee engagements can range
from $750 to $5,000 or more depending on your personal situation and
complexity.
We typically will request a retainer upon your signing of the agreement with us for services.
Retainers can be based on a number of hours up front or a fixed retainer amount. Hourly
charges are billed against the retainer. For fixed fees, we invoice you on agreed upon terms
in your Agreement. We do not charge advisory fees of $1,200 or more 6 or more months in
advance.
Generally, the balance due to IPIWM is requested upon the delivery of your Plan.
For services provided to retirement plan clients, we will typically enter into an agreement to
invoice you based upon our services and fees as described in your ERISA Investment
Management Agreement.
IPIWM INVESTMENT ADVICE FOR NON-IPIWM CUSTODIED CLIENT ACCOUNTS
The fee for this service is also negotiable. Please see the fee schedule above for “Private
Portfolio Services.” Fee for this service on a non-discretionary basis can be part of a
financial plan.
We also offer the ability to manage on a discretionary basis the held-away assets, these
Clients should be engaged in the financial planning process or an existing advisory client for
these services to be offered. This fee will be assessed and billed quarterly. Specifically, the
exact amount charged is determined by the quarter end balance in arrears or advance as
outlined in the investment advisory agreement. The current exception for this is directly-
managed held-away accounts, which are determined by the account value at the end of the
quarter and are only billed in advance. (This is due to limitations in our technology regarding
held-away accounts.) In either case, if the Adviser only manages your assets for part of a
quarter, the charge will be prorated.
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and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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The advisory fee is an agreed upon fixed fee and is calculated by assessing the percentage
agreed upon in the investment advisory agreement and applying the fee to the account
value as of the last day of the previous quarter (per the paragraph above). For example, an
account valued at $2,000,000 with an agreed upon fee of .75% with the annual fee being
$15,000 (a quarterly fee of $3,750). Investment management fees are generally directly
debited on a pro rata basis from client accounts. The exception for this is directly-managed
held-away accounts, such as 401(k)’s. As it is impossible to directly debit the fees from these
accounts, those fees will be assessed per the investment advisory agreement, by either
assigning them to the client’s taxable account or invoicing the client via direct billing, on a
pro-rata basis. If the client does not have a taxable account, those fees will be billed directly
to the client. Accounts initiated or terminated during a calendar quarter will be charged a
pro-rated fee based on the amount of time remaining in the billing period. An account may
be terminated with written notice at least 15 calendar days in advance. Since fees are paid
in advance, rebates will be calculated on a pro-rata basis determined by the days remaining
in the quarter.
THIRD PARTY ASSET MANAGEMENT PROGRAMS (TAMP) SERVICES
Your IAR may recommend that you use a TAMP. In these situations, our advisory fee
compensates your IAR for the on-going monitoring and review of the manager’s
performance. Unless the third-party manager bundles our fee with theirs, all fees are
separate from and in addition to our advisory fee. You may incur fees on top of those
charged by us including, the third-party manager’s fee and corresponding broker-dealer and
custodian fees.
As noted above, some third-party managers will bundle our advisory fee into their
management fee. In these cases, we will receive our fee directly from the third-party
manager. Our fee is paid solely from the third-party manager’s investment management fee
or wrap fee program fee (as appropriate) and does not result in any additional charge to you.
The following fees and expenses are generally related to the use of third-party
managers:
• Management fees paid to the Third Party
• Advisory fees paid to us as outlined in the client agreement that you sign
• Transaction costs – if applicable – which may be paid to purchase and sell such
securities
• Custody fees charged by the custodian
• Administrative and service fees.
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and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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Your account may be held with the third party manager’s custodian where your fees will be
assessed and deducted. Management fees charged by third party managers may not be
negotiable.
If the TAMP program is a wrap fee program, you should understand that the wrap fee cost
may be more than purchasing the program services separately. For example, paying fees
for the advisory services of the TAMP and the IAR, plus commissions for each transaction in
the account may increase your costs.
The investment products and services available to be purchased in a TAMP can generally be
purchased by clients outside of a TAMP account through us, or through broker-dealers or
other investment firms not affiliated with us or the TAMP.
For further details, please be sure to carefully review the third-party manager’s disclosure
brochure (or Wrap Fee Program Disclosure Brochure) and investment program agreements.
FEE FACILITATION BY OUTSOURCED AGENT (TAIKO)
For certain accounts, we utilize the services of Advisor OS LLC, doing business as TAIKO
(“TAIKO”), as an outsourced agent to facilitate administrative billing processes. TAIKO may
assist in calculating advisory, platform, or manager fees and in transmitting billing
instructions to custodians on our behalf. TAIKO does not receive any fees directly and acts
solely at our instruction. All fee deductions are made by the custodian, subject to client
authorization. We retain full responsibility for fee oversight and client billing accuracy.
FEES FOR RETIREMENT PLANS AND PARTICIPANT ADVICE
Our fees for advising qualified retirement plans are negotiable and based on a plan’s total
assets. The actual billing rate will be specified in your contract. We rely upon your
custodian’s account statements for fee calculation purposes. Our advisory fees are billed
to the plan’s sponsor, trustees or third party plan administrator depending upon your
wishes. Our fees will be due promptly upon receipt of our invoice.
FEE NEGOTIATION
As noted above, our IARs may negotiate our fees for any of our services taking into
consideration such things as the size of your account, the number of managed portfolios or
accounts, your relationship with other clients (e.g., family), the length of our relationship
with you, the complexity of your personal circumstances, the composition of your portfolio,
the complexity of investment strategies, the frequency of desired meetings or special
reporting and other factors that affect our cost of providing you services. If you, your family
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and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 16 of 34
or related persons also have accounts under our management, those accounts may be
aggregated for fee calculation purposes. For these reasons, our fees may vary among
clients who may otherwise be in similar circumstances. Other investment advisers may
charge higher or lower fees for comparable services.
FEE PRORATION AND ADJUSTMENTS
With your approval, we reserve the right to prorate our fees for large deposits to your
account made during a billing cycle. No adjustments or refunds will be made in respect of
the appreciation or depreciation of account asset values during a billing period or
withdrawals from your account during that period, unless otherwise agreed in writing.
OTHER MUTUAL FUND AND INSURANCE-RELATED EXPENSES
Mutual funds of all types charge their shareholders various advisory fees and expenses
associated with the establishment and operation of the funds. These fees and expenses
are described in each fund’s prospectus. These fees will generally include a management
fee, shareholder servicing, other fund expenses and sometimes a distribution fee. If the
fund also imposes sales charges, you may pay an initial or deferred sales charge. These
separate mutual fund fees are disclosed in each fund’s current prospectus, which is
available from the mutual fund and, upon request, can be provided by our firm.
Consequently, for any type of mutual fund investment, it is important for you to understand
that you are directly and indirectly paying two levels of advisory fees and expenses: one
layer of fees at the fund level and one layer of advisory fees and expenses to IPIWM.
Generally speaking, most mutual funds may be purchased directly without using our
services and without incurring our advisory fees. Moreover, many mutual funds pay
shareholder servicing fees
(12b-1 fees) to brokerage firms and their registered
representatives in consideration of their services to the fund’s shareholders. The receipt of
12b-1 fees by either our broker/dealer or advisory firm bought for or recommended to clients
may create a conflict of interest because many mutual funds offer a variety of share classes,
including some that may have available lower-cost share classes for the same mutual fund
that either does not charge a 12b-1 fee or charges a lower 12b-1 fee. It is usually in a client’s
best interest to invest in a lower-cost share class rather than a 12b-1 fee paying share class
because a client’s returns would not be reduced by the 12b-1 fees. As described below, we
will adjust our fees in view of 12b-1 fees that we may receive with respect to your account.
Like mutual funds, insurance companies charge a variety of fees and charges against the
assets invested in the separate accounts of their policy holders. As noted above, this means
that there are two layers of advisory fees incurred – one layer by the insurance company and
one layer to our firm for our advisory services. Additionally, commissions are usually paid
for the purchase of variable annuities and there may be substantial surrender charges. The
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and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 17 of 34
commission, surrender charges and other fees and expenses are disclosed in the
prospectus.
Reductions or Credits for Receipt of 12b-1 Fees
Investment Planners,
If your advisory account is custodied at RBC, mutual funds may separately pay our affiliated
broker-dealer,
Inc., 12b-1 fees for performing shareholder
recordkeeping and servicing functions for your account and other clients’ accounts.
Similarly, mutual fund sponsors and investment advisers may pay us out of their own
resources for performance of those functions. In order to avoid this conflict of interest, we
lower our advisory fees by either (i) crediting to your account a pro rata share of the 12b-1
fees we receive for mutual funds held in your account; or (ii) reducing the advisory fee rate
we charge to your account, as specified in our client services contract, and disclosing to
you that we will receive and retain the 12b-1 fees or (iii) suppress the position that pays 12b1
fee from quarterly billing. In making any billing adjustments, however, we will not refund
12b-1 fees to you in addition to the advisory fees that you have paid.
OTHER ACCOUNT-RELATED EXPENSES
In addition to our advisory fees, you may incur additional fees, either through assets-based
pricing or transaction-based pricing. Asset based pricing charges an additional fee to
cover costs associated with the trading of the account. Transaction based pricing involves
brokerage commissions, ticket charges, transaction fees and other related costs and
expenses. You may also incur certain charges imposed by custodians, brokers, third-party
investment managers and other third-parties, such as fees charged by managers, custodial
fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, other fees and taxes on brokerage accounts and securities
transactions. All such fees and expenses are disclosed to you in account opening
documents and disclosure brochures of third-party managers or TAMP sponsors.
TERMINATION OF SERVICES
Termination notices may be sent at any time and must be in writing. You are responsible for
any transaction for your account that has been initiated, but not settled, prior to our receipt
of your termination notice.
The unearned portion of advisory fees that you have paid us will be automatically refunded
to you promptly, less any amount required to satisfy your transaction-related obligations.
We base the refund pro rata on the number of elapsed days in the billing period as noted
above.
If you are an individual, your death, disability, or incompetency will not terminate or change
the terms of this Agreement or have any effect until we receive actual notice. However, your
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and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 18 of 34
personal representative, guardian, attorney in fact, or other authorized representative may
terminate this agreement by giving us written notice.
You may terminate the services of any TAMP service in accordance with the terms of the
Third-Party Manager’s client services agreement, subject to limitations imposed by
applicable laws or rules. You may terminate those services without terminating our
services. If you terminate our services, you may or may not be able to continue to utilize the
Third-Party Manager’s services (see the disclosures in the Third-Party Manager’s disclosure
brochure with respect to conditions for establishing or maintaining an account). Third Party
Managers are responsible for refunding the unearned portion of their fees, as described in
their disclosure brochures.
With regard to Financial Planning and Consulting Services, if you terminate the Agreement
prior to the delivery of your Plan, we will charge you for the time spent as documented in
your Agreement; any pre-paid and un-used fees (hourly retainer or fixed annual fee) will be
refunded to you within 30 days of the date of termination. To terminate an Agreement, we
require that you provide a written request to IPIWM.
For services provided to retirement plan clients, our agreement for services details the
method of termination. Generally, services can be terminated at any point and are not
restricted to certain dates (i.e., quarter-end). Should services be terminated, IPIWM has no
obligation to continue services beyond the date of termination.
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE
MANAGEMENT
We do not charge any performance-based fees (fees based on a share of capital gains on or
capital appreciation of your assets).
ITEM 7: TYPES OF CLIENTS
Our investment management and financial planning services are available to individuals,
high net worth individuals, businesses, pension, and profit-sharing plans, 401(k) plans,
trusts, estates and not-for-profit organizations.
We do not impose a minimum dollar value of assets or other conditions for opening or
maintaining an account. TAMP services may impose minimum account sizes and they will
vary by the investment management program you select. The TAMP disclosure documents
will provide information on any minimum account sizes required.
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and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 19 of 34
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND
RISK OF LOSS
METHODS OF ANALYSIS
Fundamental analysis is a technique that attempts to determine a security’s value by
focusing on the economic well-being of a financial entity as opposed to only its price
movements. When conducting fundamental analysis, we will review a company’s financial
statements and consider factors including, but not limited to, whether the company’s
revenue is growing, if the company is profitable, if the company is in a strong enough
position to beat its competitors in the future and if the company is able to repay its debts.
Because it can take a long time for a company’s value to be reflected in the market, the risk
associated with this method of analysis is that a gain is not realized until the stock’s market
price rises to the company’s true value.
The valuation method is a technique used to calculate a theoretical value for a security in
order to estimate potential future market prices. When utilizing the valuation method, we
will review such things as a security’s earnings per share, price to earnings, and growth rate.
We also utilize technical analysis to evaluate potential investments. Unlike fundamental
analysis, technical analysis does not analyze the company’s value, but instead analyzes the
stock’s price movement in the market. Charting is a form of technical analysis in which the
various technical factors are diagrammed in order to illustrate patterns. Technical analysis
studies the supply and demand in the market in an attempt to determine what direction or
trend will continue in the future. However, there are risks involved with this method,
including the risk that the trends will change unpredictably, which is why we use a
combination of methods and obtain information from a variety of sources.
We obtain information from a number of sources, both public and by subscription, including
financial newspapers and magazines, inspections of corporate activities, research
materials prepared by third-parties, corporate rating services, annual reports,
prospectuses, SEC filings and company press releases. We believe these resources for
information are reliable and we regularly depend on them for making our investment
decisions; however, we are not responsible for the accuracy or completeness of this
information.
For third-party money manager analysis for TAMP service offerings, we examine the
experience, expertise, 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.
We monitor the manager’s underlying holdings, strategies, concentrations and leverage as
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part of our overall periodic risk assessment. Additionally, as part of our due-diligence
process, we survey the manager’s compliance and business enterprise risks.
A risk of investing with a third-party manager who has been successful in the past is that
he/she may not be able to replicate that success in the future. In addition, as we do 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 we do not control
the manager’s daily business and compliance operations, we may be unaware of the lack of
internal controls necessary to prevent business, regulatory or reputational deficiencies.
There are risks in all forms of analysis. Our securities analysis methods rely on the
assumption that the companies whose securities we purchase and sell, the rating agencies
that review these securities and other publicly-available sources of information about these
securities are providing accurate and unbiased data. While we are alert to indications that
data may be incorrect, there is always a risk that our analysis may be compromised by
inaccurate or misleading information.
INVESTMENT STRATEGIES
We use a variety of investment strategies depending on your circumstances, financial
objectives and needs. We may recommend implementing one or more of the following
investment strategies: long-term purchases (held at least a year), short term purchases
(held less than a year), trading (sold within 30 days), margin transactions and option writing
(selling an option).
A primary strategy used for client accounts is strategic asset allocation. We use a variety
of asset classes and securities, including funds and individual equities and bonds.
Portfolios are diversified to control the risk presented by traditional markets. We may also
recommend unrelated TAMPS who have expertise in certain disciplines when appropriate
for the client.
We may recommend implementing these strategies using stocks, bonds, mutual funds (held
directly or held within variable annuities), municipal securities, option contracts,
certificates of deposits and other types of investments such as non-traded real estate
investment trusts, also known as “REITs.” We often recommend mutual funds of different
kinds to promote portfolio diversification within various asset classes, such as industry
sectors, domestic, international, or equities/bonds. We may recommend period purchases,
sales and exchanges of those mutual fund shares within mutual fund families and between
different mutual fund families when there are changes in your needs, market conditions or
economic developments.
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and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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TYPES OF INVESTMENTS AND RISK OF LOSS
We may recommend implementing these strategies using stocks, bonds, mutual funds (held
directly or held within variable annuities or life insurance products), exchange traded funds
(ETFs), municipal securities, options contracts and other types of investments.
Investing in securities involves risk of loss that you should be prepared to bear. Obtaining
higher rates of return on investments typically entails accepting higher levels of risk. We
will work with you to attempt to identify the balance of risks and rewards that is appropriate
and comfortable for you, and we will explain and answer any questions you have about these
kinds of investments. However, it is still your responsibility to ask questions if you do not
fully understand the risks associated with any investment or investment strategy.
Also, while we strive to render our best judgment on your behalf, many economic and market
variables beyond our control can affect the performance of your investments, we cannot
assure you that your investments will be profitable, or assure you that no losses will occur
in your investment portfolio. Past performance is one relatively important consideration
with respect to any investment or investment advisor, but it is not a predictor of future
performance.
Mutual Funds, Index Funds and Exchange-Traded Funds
We often recommend mutual funds of different kinds to promote portfolio diversification
within various asset classes, such as industry sectors, domestic/international or
equities/bonds. We may recommend periodic purchases, sales and exchanges of those
mutual fund shares within mutual fund families and between different mutual fund families
when there are changes in your needs, market conditions or economic developments.
The different kinds of mutual funds we use each have inherently different risk
characteristics and should not be necessarily be compared side by side. A bond fund with
below-average risk, for example, should not be compared to a stock fund with below
average risk. Even though both funds have low risk for their respective categories, stock
funds overall have a higher risk/return potential than bond funds.
Of all the asset classes, cash investments (i.e. money markets) offer the greatest price
stability, but have yielded the lowest long-term returns. Bonds generally experience more
short-term price swings, and, in turn, have generated higher long-term returns than cash.
However, stocks historically have been subject to the greatest short-term price
fluctuations and have provided the highest long-term returns.
The risk in any given mutual fund depends on the investments it holds. For example, a bond
fund has interest rate risk and income risk. Bond prices are inversely related to interest
rates. If interest rates go up, bond prices will go down and vice versa. Bond income is also
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Page 22 of 34
affected by a change in interest rates. Bond yields are directly related to interest rate
changes. If interest rates rise, bond yields rise and vice versa. Income risk is greater for a
short-term bond fund than for a long-term bond fund. However, in a long term bond fund,
your principal is subject to higher principal risk.
(which
invests
in a single
Similarly, a sector stock fund
industry, such as
telecommunications) is at risk that its price will decline due to developments in its industry.
A stock fund that invests across many industries is more sheltered from this industry
related risk. However, while diversification across industries can help reduce your risk of
loss from investing in a single sector, it may limit your opportunity for a significant gain if a
single industry or sector increases dramatically in value.
With respect to all classes of mutual funds and ETFs, diversification does not protect you
from an overall decline in the market. You should consider these risks in determining
whether to use our services.
Individual Stocks and Bonds
The risks inherent with individual stocks and bonds are similar to those described about
mutual funds. However, unlike mutual funds, individual securities carry more risk because
of the possible lack of diversification in the event that your portfolio is not spread across
many industries and companies. An owner of an individual security is subject not only to
market risk, but company risk, or “significant event” risk as in the case of bankruptcy, loss
of major customers, loss of earnings or similar factors. Typically, individual securities have
more volatility and potential for larger gains and losses. Unlike mutual funds, you face a
greater risk of losing your entire investment in an individual stock or bond. We seek to
mitigate these risks in the ownership of individual securities by sound research and
diversification.
Options
Where suitable and appropriate for clients, we may engage in a variety of transactions
involving options, although they do not represent a primary focus of our investment
strategy. Options are derivative financial instruments, the values of which depend upon, or
are derived from the value of something else, such as a stock or a stock index. Where
suitable for certain clients, we may make use of “short” options positions, the values of
which move in the opposite direction from the price of the underlying security. We also may
use options, both for hedging and non-hedging purposes, including as a substitute for a
direct investment in the securities of one or more issuers.
However, we may also choose not to use options, based on our evaluation of market
conditions or the availability of suitable options contracts.
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and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
Page 23 of 34
Options involve special risks and may result in losses. The successful use of options
depends on our ability to manage these sophisticated instruments. Some options
strategies are “leveraged,” which means that they expose the underlying portfolio to risk of
loss greater than the value of the investment in the options. As a result, options may
magnify or otherwise increase investment losses to the portfolio. The risk of loss from
certain options trading strategies is theoretically unlimited. The prices of options may
move in unexpected ways due to the use of leverage or other factors, especially in unusual
market conditions, and may result in increased volatility.
Options are not suitable for all clients. Your IAR can answer any questions you may have
about options and can provide you with the options disclosure booklet, Characteristics &
Risks of Standardized Options, upon request.
Variable Annuities
Variable annuities are highly complex financial products offered by insurance companies.
Investment in a variable annuity contract is subject to both general market risk and the
insurance company’s credit risk. These and other risks are described in the variable
annuities’ prospectuses. Variable annuities are regulated under both securities and
insurance laws and related rules and regulations. Variable annuities offer various benefits
and features which may, or may not, have value to you depending on your circumstances.
Like other types of investments, commissions are paid for the purchase of variable
annuities and there may be substantial surrender charges. The commission, surrender
charges and other fees and expenses are disclosed in the prospectus.
If suitable, we may recommend variable annuities from insurance companies whose
products allow us to manage each client’s separate accounts (the underlying portfolio) by
giving purchase and sell orders with no ticket (transaction) charges and simultaneously
manage multiple clients’ accounts, which permits us to more efficiently offer you better
service. However, these products are not suitable for all clients in all circumstances and
there are substantial costs associated with them, as described in each variable annuity’s
prospectus. For more information see the “Other Financial Industry Activities and
Affiliations” section below.
ETFs
Recommendations of particular types of securities - exchange traded funds (“ETFs”) are
professionally managed pooled vehicles that invest in stocks, bonds, short-term money
market instruments, other mutual funds, other securities or any combination thereof. ETF
managers trade fund investments in accordance with fund investment objectives. While
ETFs generally provide diversification, risks can be significantly increased for funds
concentrated in a particular sector of the market, or that primarily invest in small cap or
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Page 24 of 34
speculative companies, use leverage (i.e., borrow money) to a significant degree, or
concentrate in a particular type of security (i.e., equities) rather than balancing the fund
with different types of securities. ETFs can be bought and sold throughout the day like stock
and their price can fluctuate throughout the day. During times of extreme market volatility,
ETF pricing may lag versus the actual underlying asset values. This lag usually resolves itself
in a short period of time (usually less than one day), however, there is no guarantee this
relationship will always occur.
ITEM 9: DISCIPLINARY INFORMATION
We have no legal or disciplinary events to disclose. As a registered investment adviser, we
are required to disclose to you all material facts regarding any legal or disciplinary events
that would be material to your evaluation of our firm or the integrity of our management.
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND
AFFILIATIONS
We are also affiliated by common ownership with Investment Planners, Inc., a registered
broker-dealer and member of FINRA and SIPC. Investment Planners acts as a fully disclosed
introducing firm for RBC Correspondent Services holding client assets and executing
transactions for client accounts. We are not affiliated with RBC. For more information
about Investment Planners and its brokerage services, see the discussion below under the
heading, “Brokerage Practices.”
In addition, several of our IARs are also registered representatives of our affiliated broker-
dealer and can earn commissions on securities transactions and 12b-1 fees for mutual funds
that may be recommended by them in their capacity as representatives of Investment
Planners.
Commissions earned on variable insurance products are typically higher and in some
instances, substantial compared to commissions earned on mutual funds or other
securities. Because of this, there exists the potential conflict of interest in the
recommendation made by the representative that serves both as an advisor representative
and a registered representative earning a commission on the products that are
recommended by him or her. You are under no obligation to implement investment and
insurance recommendations through Investment Planners or through any insurance
companies with which representatives and/or employees of our firm are contracted.
Commissions may be higher or lower at Investment Planners than at other broker-dealers.
Full disclosure is provided to you prior to executing any transaction. Our firm and our
representatives receive no commission if you choose to purchase securities through a
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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broker-dealer other than Investment Planners. If commission is paid on the variable
insurance product, our IARs are not compensated for managing the subaccount.
Compensation paid to our affiliated company indirectly benefits us. These relationships
create a potential conflict of interest in our recommending the services of our affiliate. We
address these potential conflicts by disclosing these relationships and the compensation
we will earn or benefit from when you engage their services.
OUR RECOMMENDATION OF OTHER INVESTMENT ADVISERS IN THE RBC PROGRAMS
If appropriate in your circumstances, we may recommend the use of other investment
advisers who are part of the TAMP services described in the “Advisory Business” section
above. We generally receive a share of the ongoing management fees in these programs as
described in the “Fees and Compensation” section above. The fees for these programs are
shared among us, the other program sponsors, and the specified third-party investment
manager. This may create potential conflict of interest when our representatives choose
among the TAMP services and our own investment management services because we may
retain more of the fees in our own advisory programs. We seek to mitigate this conflict by
carefully reviewing the suitability of your participation in one or more of the programs
available and, in our judgment, recommending the program(s) that better match your needs,
goals and objectives. Since these programs allow us to determine the standard advisory
fees to our clients, we consider the total advisory fees you would incur and set our fees at
competitive levels. Similar advisory services may, however, be available from other
investment advisers at a lower cost.
RBC directly contracts with Investment Planners for its wrap fee programs and not IPIWM
due to the long-standing clearing relationship with our affiliated broker/dealer. This
arrangement limits the firm’s legal recourse if RBC, as the wrap fee sponsor, failed to
execute its responsibilities as offered through its wrap fee programs. We do not anticipate
this being an issue due to the long-standing relationship. However, if this occurs, IPIWM
would mitigate this issue through limiting the available RBC wrap fee program to clients to
ensure the client’s best interests are met through recommending other applicable
programs.
Benefits From Participation in the RBC ADVISOR COUNCIL
David P. Koshinski serves on the RBC Advisor Council (“Council”). The Council consists of
principals of Broker Dealers that advise RBC on issues relevant to the Broker Dealer
community. Mr. Koshinski may be called upon periodically to attend advisor council
meetings and participate on conference calls or outreaches on an as needed basis. Broker
Dealer principals are invited to serve on the Council for an ongoing term by RBC senior
management. RBC does not compensate Council members. Any benefits received by Mr.
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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Koshinski and/or IPI Wealth by serving on the Council do not depend on the amount of
brokerage transactions directed to RBC. Clients should be aware, however, that the receipt
of economic benefits by Mr. Koshinski and/or IPI Wealth in and of itself creates a potential
conflict of interest and may indirectly influence IPI Wealth’s recommendation of RBC for
custody and brokerage services.
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN
CLIENT TRANSACTIONS AND PERSONAL TRADING
CODE OF ETHICS
We have adopted a Code of Ethics (the “Code”) describing the standards of business conduct
we expect all officers, directors, employees and advisory representatives to follow. It
expresses our core fundamental values to be honest, fair and forthright in our dealings with
clients and others in the conduct of our business. Our Code also guides our practices in
giving investment advice to our clients and personal trading of securities for our employees
and their related accounts. The Code also describes certain reporting requirements with
which particular individuals, associated with or employed by us, must comply. You may
request a copy of our Code by contacting our Chief Compliance Officer, Lori Fuerstenberg
at (217) 425-6340.
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING
Our principal executive officers and most of our advisory representatives are also
registered representatives of our affiliated broker-dealer. We, and our registered
representatives, are able to execute buy and sell orders for securities on behalf of our
clients. When we do so, we may receive compensation in the form of commissions as a
result of placing such orders for clients. You are not under any obligation to use us as a
broker-dealer or our registered representatives in that capacity when considering our
advisory recommendations.
In addition, we and our registered representatives may benefit from our or their purchase
or sale of investments that we recommend to you. Our principals and representatives may
own or effect transactions in the same securities we recommend to you or our other clients.
Generally, these securities will be shares of open-end mutual funds or stocks and bonds
actively traded on a national securities exchange or market where the time and size of their
purchases or sales will not generally affect transactions for you or our other clients.
However, it is an express policy of our Code of Ethics that no person employed by us may
purchase or sell any security prior to a transaction being implemented for an advisory
account, thereby preventing such employee from benefiting from transactions placed on
behalf of advisory accounts. Nevertheless, in all cases when your representative trades
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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securities on the same day as you, you will get the best price or the trade will executed as a
block or batched trade (also called an aggregated order). In a batched trade, all orders for
accounts are combined in one order. All participants receive identical prices, which
prevents such employees (or associated persons) from benefiting from transactions placed
on behalf of advisory accounts. For more information on trade aggregation, see the
“Brokerage Practices” section that follows below.
While we generally do not give advice about thinly traded securities, if we recommend the
purchase or sale of a thinly traded security to you, we will ensure that our principals’ and
representatives’ transactions do not adversely affect you, nor improperly benefit them,
typically by imposing the same day black-out period.
We have these employee securities trading policies in our Code of Ethics to prevent our
employees from benefiting from transactions placed on behalf of any client’s account.
Because these situations have the potential of raising conflicts of interest, we have
established the following trading restrictions:
• Our representatives may not use information available to them because of
their employment with us to buy or sell securities for their personal portfolios,
unless the information is also available to the investing public upon
reasonable inquiry. A representative shall not favor his or her interests above
your interests.
• We inform you that our representatives may receive separate compensation
when implementing our financial plans.
• We require our representatives to act in accordance with all applicable
federal and state regulations that govern investment advisers and broker-
dealers.
A representative who violates these restrictions may be subject to disciplinary action, up to
and including termination.
ITEM 12: BROKERAGE PRACTICES
DIRECTED BROKERAGE
As noted above, we are affiliated with Investment Planners, Inc., a registered broker-dealer,
and most of our advisory representatives are registered through Investment Planners Inc.
to handle securities brokerage transactions. Additionally, Investment Planner’s clearing
firm, RBC Clearing and Custody, a division of RBC Capital Markets LLC is a qualified
custodian and provides the systems and technology we use to manage assets in your
account if you engage us for portfolio management services.
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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A conflict of interest exists with the long-standing clearing and custodian relationship of
Investment Planners and IPIWM with RBC, as the broker-dealer has and may receive in the
future remuneration from RBC in renewing its clearing agreement. Additionally, RBC may
discount ticket charges charged to the firms due to the clearing relationship; however,
clients may pay the full charge of the ticket. Other firms do not require clients to direct
brokerage to a specific broker-dealer.
However, if you engage us solely for financial planning or consulting services, you are never
obligated to use our services or our representatives to implement our financial planning or
consulting recommendations. Securities brokerage services are available from other
sources at lower cost; however, discount brokerage firms generally do not provide the
personalized investment advice or other customer services that we provide. Commissions,
implementation of our
12b-1 fees and other compensation received from the
recommendations are in addition to our compensation from financial planning, consulting
or investment management fees, as described above.
In the context of selecting and retaining RBC as our clearing broker-dealer firm and qualified
custodian to our advisory accounts, we fulfill our duty of best execution by taking into
account numerous factors regarding a broker-dealer’s execution of customer trades
including: (1) overall market quality, (2) speed of execution, (3) order size, (4) trading
characteristics of a particular security, (4) availability of accurate information affecting
choices of the most favorable market, (5) availability of economic access to various market
centers and (6) cost and difficulty associated with achieving an execution in a particular
market center. Our analysis of these factors is, among other considerations, based on
information provided on a quarterly basis by RBC relative to their trade executions.
IPIWM utilizes RBC for directed brokerage services through our affiliated broker/dealer,
Investment Planners, Inc. and its clearing broker/dealer, RBC, for some of our Portfolio
Management Services. With directed brokerage, you may be unable to achieve the most
favorable execution of your transactions which may cost more money for the transactions.
IPIWM also recommends other brokerage firms and trust companies (as qualified
custodians), such as Schwab Institutional, Trade PMR and RBC Correspondent Services.
IPIWM only receives fees or commissions as described herein from these arrangements,
such as 12b-1 fees and other compensation received from the implementation of
recommendations in addition to our compensation from financial planning, consulting or
investment management fees, as described above. IPIWM may benefit from electronic
delivery of client information, electronic trading platforms and other services provided by
custodians for the benefit of clients. IPIWM may also benefit from other services provided
by custodians, such as research, continuing education and practice management advice.
Research the firm receives from qualified custodians may benefit some clients and possibly
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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not others. These benefits are standard in a relationship with these custodians and are not
in return for client recommendations or transactions.
IPIWM also utilizes Trade-PMR, Inc. ("Trade-PMR") for brokerage and trade execution
services. Trade-PMR clears trades and custodies assets with First Clearing, FINRA member
broker-dealers. First Clearing is a trade name used by Wells Fargo Clearing Services, LLC.,
a non-bank affiliate of Wells Fargo & Company. Trade-PMR acts as an introducing broker
dealer on a fully disclosed basis. Trade-PMR and First Clearing are members of SIPC and are
unaffiliated registered broker dealers and FINRA members. The brokerage commissions
and/or transaction fees charged by Trade-PMR or any other designated broker-dealer are
exclusive of and in addition to IPIWM’s fee. IPIWM regularly reviews these programs to seek
to ensure that its recommendation is consistent with its fiduciary duty. Factors which
IPIWM considers in recommending Trade-PMR and First Clearing or any other broker-dealer
or custodian to clients include their respective financial strength, reputation, execution,
pricing, research, and service. The commissions and/or transaction fees charged by these
brokers may be higher or lower than those charged by other broker-dealers.
In addition, Trade-PMR provides IPIWM with access to its institutional trading and custody
services, which are typically not available to retail investors. These brokerage services
include the execution of securities transactions, research, and access to mutual funds and
other investments that are otherwise generally available only to institutional investors or
would require a significantly higher minimum initial investment.
Additionally, IPIWM may receive the following benefits from Trade-PMR: receipt of
duplicate client confirmations and bundled duplicate statements; access to a trading desk
that exclusively services its participants; access to block trading which provides the ability
to aggregate securities transactions and then allocates the appropriate shares to client
accounts; and access to an electronic communication network for client order entry and
account information.
Some wrap fee programs have selected third party managers who choose not to direct the
execution of a particular trade through the custodian. This is known as trading away. The
broker/dealer that executed the trades for the money manager may charge a commission
or fee for those transactions to a client in addition to the program’s wrap fee. These
additional costs will be included in the purchase or sale price of the transaction. Clients are
responsible for reviewing the third party manager’s disclosures relative to trade away
disclosures and costs as the manager has the fiduciary responsibility to provide this
information as well as best execution for the transactions. IPIWM does not evaluate the
suitability of a third party manager’s transactions nor does IPIWM evaluate whether the
manager is meeting its best execution obligation when trading away.
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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IPIWM reviews the execution of trades at each custodian annually and is documented
according to the "Policies and Procedures Manual." Trading fees charged by the custodians
are also reviewed on at least an annual basis. IPIWM does not receive any portion of the
trading fees.
AGGREGATION OF ORDERS
We have adopted a trade allocation policy to govern how we handle the aggregation of
orders for more than one client’s account. From time to time, and only where appropriate,
we aggregate orders for securities transactions for more than one client and, in appropriate
circumstances. In doing so, we strive to treat each client fairly and will not favor one client
over another client. When executed, we will allocate the aggregated order in accordance
with policies and procedures intended to achieve fair treatment. The purpose of
aggregating orders is for our administrative convenience and, in some transactions, to
obtain better execution for the aggregated order than might be achieved by processing
each of the transactions separately.
Each account that participates in an aggregated order will participate at the average share
price for all transactions ordered by our firm in that security on a given business day.
Transaction costs will be shared on a pro rata basis. Some broker-dealers charge brokerage
commissions to each participating client in accordance with the size of that client’s part of
the aggregated order, regardless of the total size of the aggregated order. If an aggregated
order is not filled in its entirety, it will be allocated among participating accounts on a pro
rata basis. Representatives submit aggregated order allocations to our Operations
Department and these orders are monitored for timing and completion at the end of each
trading day. Representatives that trade for their own accounts within models and are not
day trading a security may include their own personal account in an aggregated order.
ITEM 13: REVIEW OF ACCOUNTS
INVESTMENT SUPERVISORY SERVICES INDIVIDUAL PORTFOLIO
MANAGEMENT & MODEL PORTFOLIO MANAGEMENT
Reviews: While the underlying securities within accounts are continually monitored,
accounts are reviewed periodically on either a random or targeted basis. Accounts are
reviewed in the context of each client's stated investment objectives and guidelines. More
frequent reviews may be triggered by material changes in variables such as the client's
individual circumstances, or the market, political or economic environment. These
accounts are reviewed by firm supervisory personnel.
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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Reports: In addition to the monthly statements and confirmations of transactions that
clients receive from their broker-dealer, we may provide quarterly reports summarizing
account performance, balances and holdings.
QUALIFIED RETIREMENT PLANS
Reviews: IPIWM will review the client's Investment Policy Statement (“IPS”) whenever the
client advises us of a change in circumstances regarding the needs of the plan. IPIWM will
also review the investment options of the plan according to the agreed upon time intervals
established in the IPS. These accounts are reviewed by the Operations Department and/or
a designated supervisor at the time of the account opening and on a random or targeted
basis.
Reports: IPIWM will provide reports to Qualified Retirement Plan clients based on the terms
set forth in the client's IPS.
SELECTION and MONITORING of THIRD-PARTY MONEY MANAGERS
Reviews: These client accounts should refer to the independent registered investment
adviser’s Firm Brochure (or other disclosure document used in lieu of the brochure) for
information regarding the nature and frequency of reviews provided by that independent
registered investment adviser. IPIWM will provide reviews as contracted for at the
inception of the advisory relationship. These accounts are reviewed by supervisory
personnel of the firm on a random or targeted basis.
Reports: These clients should refer to the independent registered investment adviser’s
Firm Brochure (or other disclosure document used in lieu of the brochure) for information
regarding the nature and frequency of reports provided by that independent registered
investment adviser.
IPIWM may provide these client accounts with reports as contracted for at the inception of
the advisory relationship.
FINANCIAL PLANNING AND CONSULTING SERVICES
Reviews: While reviews may occur at different stages depending on the nature and terms
of the specific engagement, typically no formal ongoing reviews will be conducted for
financial planning clients unless otherwise contracted.
Reports: Financial planning clients will receive a completed financial plan. Additional
reports will not typically be provided unless otherwise agreed upon.
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
IPIWM may pay referral fees to independent persons or firms ("Solicitors") for introducing
clients to us. Whenever we pay a referral fee, we require the Solicitor to provide the
prospective client with a copy of this document (our Firm Brochure) and a separate
disclosure statement that includes the following information:
the Solicitor's name and relationship with our firm;
the fact that the Solicitor is being paid a referral fee;
the amount of the fee; and
•
•
•
• whether the fee paid to us by the client will be increased above our normal fees in
order to compensate the Solicitor.
As a matter of firm practice, the advisory fees paid to us by clients referred by solicitors are
not increased as a result of any referral.
It is our policy not to accept or allow our related persons to accept any form of
compensation, including cash, sales awards or other prizes, from a non-client in
conjunction with the advisory services we provide to our clients.
IPIWM will receive additional benefits from Trade-PMR which includes electronic systems
that assist in the management of IPIWM client accounts, access to research, the ability to
directly debit client fees, software and other technology that provide access to client
account data (such as trade confirmations and account statements), facilitate trade
execution (and allocation of aggregated trade orders for multiple client accounts), pricing
information and other market data, assist with back-office functions, recordkeeping and
client reporting.
ITEM 15: CUSTODY
We previously disclosed in the "Fees and Compensation" section of this Disclosure Brochure
that our firm directly debits advisory fees from client accounts.
As part of this billing process, the client's custodian is advised of the amount of our advisory
fee to be deducted from that client's account. This ability to deduct our advisory fees from
your accounts causes our firm to exercise limited custody over your funds or securities. On
at least a quarterly basis, the custodian is required to send to the client a statement showing
all transactions within the account during the reporting period.
Because the custodian does not calculate the amount of the fee to be deducted, it is
important for clients to carefully review their custodial statements to verify the accuracy of
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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the calculation, among other things. Clients should contact us directly if they believe that
there may be an error in their statement.
In some cases, our clients authorize us to move cash from/to their investment account at a
qualified custodian to/from their bank account or third party, by executing a Standing
Letter of Authorization (SLOA). SLOA forms are provided by the qualified custodians. Clients
identify the payee and either the third party’s address or account number at the custodian
when executing the SLOA. We do not have the discretion to change the payee name,
address, or other information on a SLOA.
After the custodian performs their verification of the client instructions, the custodian will
notify the client in writing to confirm the instructions. The custodian will also provide a
transfer of funds notice to the client promptly after each transfer.
In addition to the periodic statements that clients receive directly from their custodians, we
also may send performance reports directly to our asset management clients on at least a
quarterly basis. We urge our clients to carefully compare the information provided on these
statements to ensure that all account transactions, holdings and values are correct and
current.
Our firm does not have physical custody of client accounts. Your funds and securities are
held by the applicable custodian who will provide you account statements at least quarterly.
We urge you to carefully review such statements and compare these official custodial
records to the account statements or other reports that we may provide to you, as
described in the “Review of Accounts” section. Our advisory reports may vary from custodial
statements based on accounting procedures, reporting dates or valuation methodologies
of certain securities.
ITEM 16: INVESTMENT DISCRETION
We generally receive discretionary authority in writing from clients at the outset of an
advisory relationship in the Agreement. If you choose to do so, discretionary authority
grants us the ability to determine, without obtaining your specific consent, the securities to
be bought or sold for your portfolio, the amount of securities to be bought or sold, and in
most cases, the broker-dealer to be used and the commission rate to be paid. In all cases,
however, such discretion is to be exercised in a manner consistent with your stated
investment objectives for the account, by considering the size of your account and your risk
tolerance.
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.
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Also, you may sign an agreement with your custodian that generally includes a limited power
of attorney granting us authority to direct and implement the investment and reinvestment
of your assets within the account, but not direct the assets outside of the account.
When selecting securities and determining amounts, we observe any investment policies,
limitations and restrictions you provide to us in writing. For registered investment
companies, our authority to trade securities may also be limited by certain federal
securities and tax laws that require diversification of investments and favor the holding of
investments once made.
As described in more detail in the “Advisory Business” section, you may establish written
investment guidelines and restrictions.
ITEM 17: VOTING CLIENT SECURITIES
IPIWM will not vote proxies on behalf of advisory clients.
likely hold various investments in your account for which shareholders,
You will
stockholders, or investors may have the right to receive and vote proxies and proxy
statements from companies or funds pertaining to their corporate governance. Typically,
the custodian(s) for your account will send directly to you all proxy materials and related
corporate communications instead of to us. You will be solely responsible for voting all
proxies. We would be pleased to assist you by answering any questions and offering our
advice to help you make an informed decision. We will not have authority to vote on any
corporate matters as your proxy.
ITEM 18: FINANCIAL INFORMATION
We have no financial liabilities, obligations or commitments that impair our ability to meet
our contractual and fiduciary commitments. We have not been the subject of a bankruptcy
proceeding.
Securities and investment advice offered through Investment Planners, Inc. (Member FINRA/SIPC)
and IPI Wealth ManagementSM, 226 W. Eldorado St., Decatur, IL 62522. 217-425-6340.