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FORM ADV PART 2A
FIRM BROCHURE
October 2025
This Part 2A of Form ADV (“Brochure”) provides information about the qualifications and business
practices of Legacy Financial Group, LLC (the “Advisor”) or “LFG”). If you have any questions
about the contents of this brochure, please contact us at (515) 255-3306 or email
michelle.mccarthy@dinsmorecomplianceservices.com. The information in this brochure has not
been approved or verified by the United States Securities and Exchange Commission or any
state securities authority. Registration of an investment adviser does not imply any level of skill
or training.
Additional information about Legacy Financial Group, LLC is available on the SEC’s website at
www.adviserinfo.sec.gov. The site may be searched by a unique identifying number known as a
CRD number. Legacy Financial Group, LLC’s CRD number is 154927.
Phone: (515) 255-3306
Web site: www.lfgplanners.com
Address: 6000 Grand Avenue, Suite B, Des Moines, IA 50312
Item 2 Summary of Material Changes
This Disclosure Brochure, dated Octpber 2025, contains information regarding our qualifications,
business practices, nature of the advisory services we provide, as well as a description of potential
conflicts of interest relating to our advisory business that could affect a client’s account with us.
You should rely on the information contained in this document or other information we have
referred you to. We have not authorized anyone to provide you with information that is different.
Legacy Financial Group encourages all current and prospective clients to read this Disclosure
Brochure and discuss any questions you have with the Advisor. Adviser reports the following
material changes since our last annual amendment dated February 20, 2025:
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Item 12 updated to reflect the use of Altruist Financial LLC (“Altruist”) as a custodial
option.
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Item 3
Table of Contents
Item 2 Summary of Material Changes ...................................................................... 1
Item 3 Table of Contents .............................................................................................. 2
Item 4 Advisory Business ......................................................................................... 3
Item 5 Fees and Compensation ................................................................................ 7
Item 6 Performance-Based Fees and Side-By-Side Management ........................... 10
Item 7 Types of Clients .............................................................................................. 10
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ........................ 10
Item 9 Disciplinary Information ............................................................................. 13
Item 10 Other Financial Industry Activities and Affiliations ..................................... 14
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading ............................................................................................................ 15
Item 12 Brokerage Practices .................................................................................... 16
Item 13 Review of Accounts ..................................................................................... 19
Item 14 Client Referrals and Other Compensation ................................................... 19
Item 15 Custody ....................................................................................................... 21
Item 16
Investment Discretion ................................................................................. 21
Item 17 Voting Client Securities ............................................................................... 22
Item 18 Financial Information .................................................................................. 22
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Item 4 Advisory Business
Legacy Financial Group, LLC (“the Adviser”) has been in business as a Registered Investment
Adviser since 2010. The ownership of Legacy Financial Group, LLC has been changed effective
October 1, 2020. Spectrum Wealth Advisors, Inc., which is owned by William Elson, Brian Hood,
Rachel Wood, Scott Arnburg, and Scott Nelson own 100% of Legacy Financial Group, LLC. The
Adviser is a fiduciary and is required to act in a client’s best interest at all times.
TYPES OF ADVISORY SERVICES OFFERED
Investment Management
Adviser offers discretionary and non-discretionary investment advisory services to individuals,
high net worth individuals, families, and retirement plan accounts. The Adviser uses a time-tested,
disciplined approach to investing. The Adviser is a “total portfolio” manager using an active,
diversified investment approach. The Adviser believes that a portfolio should be diversified, and
excess returns can be achieved by overweighting undervalued asset classes and investment
styles. Typically, the Adviser tailors the portfolios to the individual needs of our clients by
developing an investment policy statement with each client. The written investment policy
statement sets forth the client’s investment guidelines and objectives, which the Adviser uses to
guide us in making investment decisions for each client. For discretionary accounts, we are
authorized to perform various functions without further approval from the client, such as the
determination of securities to be purchased or to be sold for the client’s account without
permission from the client prior to each transaction. For non-discretionary investment advisory
services, Adviser will obtain client approval prior to taking any action in the account, including but
not limited to, executing trades. We do not act as custodian of client assets, and the client will
always maintain control of their assets.
Financial Planning, Consulting Services, & Financial Education Services
The Adviser provides financial planning, consulting and plan update services to individuals and
businesses consistent with the clients’ financial and tax status, in addition to their risk profile and
return objectives.
The Adviser starts the financial planning process by gathering information through a personal
interview and taking a financial inventory. This generally involves gathering enough data to
perform an analysis of client liabilities, cash flow, net worth and tax assessments. The Adviser’s
next step typically involves assisting clients with formalizing their goals and plotting their
investment timeline as part of the financial planning process.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the client. For example,
recommendations may be made that the client begin or revise investment programs, create or
revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings,
or establish education or charitable giving programs. The Adviser may also provide non-securities
advice on topics that may include but are not limited to, business, retirement, estate, budgetary,
college, personal, and tax planning. It should be noted that the Adviser refers clients to
accountants, attorneys or other specialists, as necessary for non-advisory related services.
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We help both clients and their legal teams better understand the impact of the financial decisions
they make today and how that can impact the client’s financial future through divorce consulting.
We do not provide legal advice or draft legal documents, but recommend clients seek the counsel
of an attorney as needed.
The Adviser also provides education services about general investment principles. Some
education services are provided as presentations to employees at the request of an employer, or
during a classroom environment. Education presentations will not take into account the individual
circumstances of the attendees and individualized recommendations will not be provided unless
otherwise agreed upon.
Financial Planning & Consulting Conflicts of Interest
There is a conflict of interest because there is an incentive for the Adviser when offering financial
planning services to recommend products or services for which the Adviser or an associated
person will receive compensation. However, financial planning clients are under no obligation to
act upon any recommendations of the Adviser or to execute any transactions through the Adviser
or an associated person if they decide to follow the recommendations.
Retirement Plan Services
The Advisor offers services to both plan sponsors and participants of retirement plans. Such
services many consist of assisting employer plan sponsors in establishing, monitoring and
reviewing their company’s participant-directed retirement plan. In providing employee benefit
plan services, Advisor does not provide any advisory services with respect to the following type
of assets: employer securities, real estate (excluding real estate funds and publicly trade REITS),
participant loans, non-publicly traded securities or assets, other illiquid investments (collectively
“Excluded Assets”).
Advisor offers assistance in creating and establishing a plan’s asset allocation and in evaluating,
and monitoring investment options. This may include reviewing appropriate investment options
for the plan, asset classes and investment styles, evaluating and recommending investment
managers, types and selection of investment options. We may also conduct periodic reviews of
the plan’s investments to evaluate performance, risk characteristics and expenses and
recommend changes where appropriate.
In addition, we may also work directly with plan participants to help them evaluate their
retirement savings goals, determine appropriate investments for their specific retirement
accounts, and implement appropriate contribution amounts and investments available in the plan.
Advisor services plan participants on a discretionary or non-discretionary basis, pursuant to the
plan documents and the plan participants preference.
All pension consulting services follow the applicable state law(s) regulating pension consulting
services. This applies to client accounts that are pension or other employee benefit plans (“Plan”)
governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If
the client accounts are part of a Plan, and the Adviser accepts appointments to provide our
services to such accounts, the Adviser acknowledges that we are a fiduciary within the meaning
of Section 3(21) of ERISA (but only with respect to the provision of services described Advisor’s
401K Investment Management Agreement).
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The Firm does not act as custodian for any client account.
Pension Consulting Services
The Adviser provides pension consulting services to employer plan sponsors on an ongoing basis.
Generally, such pension consulting services consist of assisting employer plan sponsors in
establishing, monitoring and reviewing their company's participant-directed retirement plan. As
the needs of the plan sponsor dictate, areas of advising could include: investment options, plan
structure and participant education.
All pension consulting services follow the applicable state law(s) regulating pension consulting
services. This applies to client accounts that are pension or other employee benefit plans (“Plan”)
governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If
the client accounts are part of a Plan, and the Adviser accepts appointments to provide our
services to such accounts, the Adviser acknowledges that we are a fiduciary within the meaning
of Section 3(21) of ERISA (but only with respect to the provision of services described in section
1 of the Pension Consulting Agreement).
Divorce Planning
We help both clients and their legal teams better understand the impact of the financial decisions
they make today and how that can impact the client’s financial future. We do not provide legal
advice or draft legal documents, but recommend clients seek the counsel of an attorney as
needed.
Third Party Money Managers
The Adviser has established relationships with other investment advisers that offer a variety of
investment advisory programs and services that include separate account portfolio management
programs, asset allocation programs, wrap fee programs, and financial planning services. These
other investment advisers are registered investment advisers or exempt from registration as
investment advisers. The Adviser’s Investment Adviser Representatives (“IARs”) may recommend
these other investment advisers to clients based on clients’ financial needs.
Clients should understand that referral fees paid by these other investment advisers to the Adviser
and the Adviser IARs may differ from one investment adviser to another investment adviser. Such
conflicts could affect the independent judgment of the Adviser’s IARs in the selection of other
investment advisers that they recommend to clients. Establishing and terminating accounts with
other investment advisers is dependent on the other investment advisers’ termination policies and
procedures. A complete description of these other investment adviser programs, services,
termination provisions, and related fees and charges are described in these investment advisers’
agreements and their Form ADV Part 2 Disclosure Brochures.
The Adviser’s referrals to other investment adviser services are tailored to the individual needs of
each client. The Adviser obtains financial information from prospective clients to determine the
suitability of the Adviser’s referrals to other investment adviser services. Each client may impose
restrictions on the types of referrals provided by the Adviser. The Adviser’s IARs will be
continuously available to meet with clients who are referred to these other investment advisers
and open investment advisory accounts or establish financial planning services with these other
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investment advisers.
TAILORED RELATIONSHIPS
Advisor offers the same suite of services to all of its clients. The management services and
recommendations offered by the Advisor are based on the individual needs of our clients and the
suitability of products and services. Specific client financial plans and their implementation are
dependent upon each client’s current situation (income, objectives, and risk tolerance levels) and
is used to construct a client specific plan to aid in the selection of a portfolio that matches
restrictions, needs, and targets.
Clients have the opportunity to place reasonable restrictions on the types of investments to be
held in their portfolio. However, restrictions on investments in certain securities or types of
securities may not be possible due to the level of difficulty this would entail in managing the
account.
Persons Residing Outside of the United States
Services for clients living outside the United States may be restricted or limited due to custodial
rules or other factors. Investment options and strategies may differ from our typical
recommendations, including but not limited to the foreign tax treatment of investment
transactions in the United States. In addition, foreign laws or requirements may also impact our
ability to service accounts or require additional disclosure as determined on an individual country
basis. The client will be responsible for satisfying all legal and tax reporting requirements of the
United States and all applicable foreign governments. Any person located outside of the United
States who wishes to open an account or an existing client who is located outside of the United
States will be subject to the custodian’s policy regarding that country (including their right to
decline to open or maintain the account), and all applicable customer identification and anti-
money laundering regulations. In its sole discretion, Legacy Financial Group, LLC reserves the
right to decline an engagement with any prospective client outside of the United States, or
terminate an engagement with an existing client, if they move outside of the United States.
Accounting & Tax Services
Legacy Financial Group, LLC and LFG Tax and Accounting, LLC are under common ownership.
Clients needing assistance with tax preparation and/or accounting services may be referred to
LFG Tax and Accounting, LLC. Our affiliation with this entity presents a conflict of interest as each
of the Firms has an economic incentive to refer clients to each other instead of referring clients
to other like firms. Clients are not obligated to use the services of the entity for their tax or
accounting needs. However, if a client chooses to engage either of these entities, they may pay
fees and expenses for their services, separate from and in addition to the fees charged by Legacy
Financial Group, LLC.
Advisor may, at our discretion, offer complementary tax services provided by LFG Tax and
Accounting, LLC to client relationships with 2 million or more in assets under management.
WRAP FEE PROGRAMS
The Adviser does not offer a wrap fee program.
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ASSETS UNDER MANAGEMENT
The Adviser managed a total of $839,124,716 in discretionary regulatory assets under
management and $1,276,218 in non-discretionary regulatory assets under management, and had
$24,053,966 in assets under advisement as of December 31, 2024
Item 5 Fees and Compensation
Investment Management
Our standard advisory fee ranges from 0.70 to 1.2%, depending in part on, the size of the
account, prospective growth, complexity, and other factors that may differ from client to client,
with break points for AUM thresholds. Households are commonly considered to include spouses
and dependent children. It can also extend to other related individuals, such as parents or adult
children, but is considered on a case-by-case basis and at the discretion of the advisor. These fees
are billed quarterly, in advance, based on daily average balance of the Assets of the previous
quarter*. Fees do not include execution costs for brokerage transactions. All fees are negotiable
at the Adviser’s discretion. The fee you will pay will be disclosed in your advisory agreement.
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. Advisor will also bill on a pro rata basis
for any additional contributions made during a billing period after the initial contribution.
CASH POSITIONS
Legacy Financial Group, LLC continues to treat cash as an asset class. As such, unless determined
to the contrary by Legacy Financial Group, LLC, all cash positions (money markets, etc.) shall
continue to be included as part of assets under management for the purposes of calculating
Legacy Financial Groups, LLC advisory fee. In addition, while assets are maintained in cash, such
amounts could miss market advances. Depending upon current yields, at any point in time, Legacy
Financial Group, LLC’s advisory fee could exceed the interest paid by the client’s money market
fund.
Fees will be deducted from the client’s account at an independent qualified custodian upon their
written authorization. In rare cases, Adviser will agree to directly bill clients. As part of this
process, clients understand and acknowledge the following:
(a) The client’s independent custodian sends statements at least quarterly showing all
disbursements for the account, including the amount of the advisory fees paid to Adviser;
(b) The client provides authorization permitting Adviser to be directly paid by these terms;
Any client assets being managed by the Adviser that are held in a qualified retirement account
will be billed pursuant to the Client’s standard advisory fee and deducted from the account
specified by the Client on the advisory agreement.
Financial Planning & Consulting Fees
The Adviser charges clients a range of $150 - $250 an hour for financial planning and consulting
services. Clients are given a quote that is based on the hourly rate times an estimate of the
number of hours a project will take. This is based on the range and complexity of the services
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the Adviser will provide. Generally, projects fall within a 4-to-8-hour range which is $600-$2000
per engagement. The fee-paying arrangements for financial planning services will be detailed in
the signed Agreement.
The Adviser may waive the financial planning charges when clients receive advisory services
through persons associated with the Adviser.
If clients elect to implement recommendations made in a financial plan, their accounts may incur
retirement plan administration fees, and other mutual fund annual expenses that are charged by
broker-dealers, plan administrators or mutual fund companies that sell securities or provide
additional services to Adviser clients. These fees are in addition to and separate from financial
planning and consulting fees.
Fees are due and payable upon completion of the services. Under no circumstances will the
Adviser charge fees in excess of $1,200 more than six months in advance of services rendered.
Clients will have a period of five (5) business days from the date of signing an agreement to
unconditionally rescind the agreement and receive a full refund of all fees. Thereafter, clients may
terminate an agreement by providing the Adviser with written notice prior to delivery of the plan
or completion of the service. The Adviser may terminate an agreement by providing written notice
to clients. Since fees are payable only after services are provided, there are no unearned fees
and the client will not have a refund due upon early termination of the advisory agreement.
Financial Education Program Fees
For Financial Education services, the Adviser charges a flat fee or a fee of $100 - $150 per student
depending upon the educational program chosen.
Retirement Plan Services
Our standard advisory fee ranges from 0.70 to 1.2%, depending in part on, the size of the
account, prospective growth, complexity, and other factors that may differ from client to client,
with break points for AUM thresholds. The Plan Participant’s fee tier will be determined by the
total value of the Plan Assets. These fees are billed quarterly, in advance, based on daily average
balance (cash values unless exempted) and calculated based upon the total plan assets of the
previous quarter. Fees do not include execution costs for brokerage transactions. All fees are
negotiable at the Adviser’s discretion. The fee you will pay will be disclosed in your advisory
agreement. 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. Advisor will also bill on a pro rata
basis for any additional contributions made during a billing period after the initial contribution.
Fees will be deducted from the client’s account at an independent qualified custodian upon their
written authorization. In rare cases, Adviser will agree to directly bill clients. As part of this
process, clients understand and acknowledge the following:
Pension Consulting Fees
We charge on an hourly or flat fee basis for pension consulting services. The total estimated fee,
as well as the ultimate fee that we charge you, is based on the scope and complexity of our
engagement with you. Our hourly fee is $150. Our flat fees generally range from $750 to $10,000
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or may be charged as a percentage of assets within the pension plan not to exceed 1.5%. Flat
fees will be charged annually in arears for ongoing pension consulting services.
The fee-paying arrangements for pension consulting service will be determined on a case-by-case
basis and will be detailed in the signed Pension Consulting Agreement. The client will be invoiced
directly for the fees. In cases where the fee is charged as a percentage of assets within the plan,
the ongoing fee shall be due and payable quarterly in advance based upon the value of the Plan's
Account(s) on the last day of the quarter. Should the Plan have more than one Account, the Fee
shall be payable in proportion to the respective Account value(s). The Adviser's fees will be
debited directly from the Plan's Account(s) and Client authorizes the custodian for the Plan assets,
which may be upon instruction from the Plan's administrator, to deduct Adviser’s fees directly
from the Plan's Account(s). Adviser shall not be compensated on the basis of a share of capital
gains or capital appreciation of the Plan's Account(s).
In addition to Adviser’s consulting fee, the Client may also incur certain charges imposed by
unaffiliated third parties. Such charges include, but are not limited to, custodial fees,
administrative fees, brokerage commissions, transaction fees, charges imposed directly by a
mutual funds, index funds, or exchange traded funds purchased for the account which shall be
disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), wire
transfer fees and other fees and taxes on brokerage accounts and securities transactions.
TERMINATION AND REFUNDS
We charge our asset based advisory fees quarterly in advance. In the event that you wish to
terminate our services, we will refund the unearned portion of our advisory fee to you. You need
to contact us in writing and state that you wish to terminate our services. Upon receipt of your
letter of termination, we will proceed to close your account and process a pro-rata refund of
unearned advisory fees.
Financial Planning and Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. In the event of a termination before the
delivery of a financial plan, Clients will receive a refund of an unearned, prepaid fees and an
invoice documenting the time spent working on the financial plan up to the point of termination.
COMMISSIONABLE SECURITIES SALES
Certain Investment Adviser Representatives (IARs) with Legacy Financial Group are dually
Registered Representatives of Integrity Alliance, LLC (“Integrity Alliance”) a registered broker-
dealer, member of the Financial Industry Regulatory Authority, Inc. ("FINRA") and the Securities
Investor Protection Corporation (“SIPC”). In their positions as a registered broker the
representatives may sell and accept compensation for the sale of securities or other investment
products, including distribution or service (“trail”) fees from the sale of mutual funds. You should
be aware that the practice of accepting commissions for the sale of securities:
1. Presents a conflict of interest and gives the advisor an incentive to recommend investment
products based on the compensation received, rather than on the client’s needs. Our firm
generally addresses commissionable sales conflicts that arise when explaining to clients that
commissionable securities sales creates an incentive to recommend products based on the
compensation he may earn and/or when recommending commissionable mutual funds,
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explaining that “no-load” funds are also available.
2. In no way prohibits you from purchasing investment products recommended by us through
other brokers or agents which are not affiliated with us.
3. Does not exceed more than 50% of our revenue.
4. Does not reduce your advisory fees to offset the commissions our supervised persons receive.
Adviser notes that commissions are not charged to its fee-based / investment advisory clients. In
the event that a client pays a load fee for a mutual fund and then later wishes to move to a fee-
based account, Advisor does not charge fees on those impacted assets for any time remaining up
to twenty-four (24) months from when a commission was received.
TRADE ERRORS
Any Adviser created trade errors that result in a net debit to client accounts will be debited against
Adviser’s Error Account and the client made whole. Any Adviser created trade errors that result
in a net credit will be donated to a charity of the Custodian’s choice.
Item 6 Performance-Based Fees and Side-By-Side Management
The Adviser does not charge or receive, directly or indirectly, any performance-based fees and
does not participate in side-by-side arrangements.
Item 7
Types of Clients
The Adviser provides advisory services to:
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Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension and Profit Sharing Plans;
• Corporations, Limited Liability Companies and/or Other Business Types.
ACCOUNT MINIMUMS
The Adviser does not impose a minimum account requirement on clients.
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
The Adviser works with each client to design an appropriate investment strategy based on client
financial and tax status, risk tolerance and investment objectives. The Adviser usually
recommends investment strategies for the long-term, but may occasionally recommend short-
term investment and hedging strategies. The Adviser generally recommends a target asset mix
with periodic rebalancing.
The Adviser uses the following methods of analysis in formulating investment advice and may use
outside analysts to review the portfolios:
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Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic
value by examining related economic, financial and other qualitative and quantitative factors.
Fundamental analysts attempt to study everything that can affect the security's value, including
macroeconomic factors (like the overall economy and industry conditions) and individually specific
factors (like the financial condition and management of companies). The end goal of performing
fundamental analysis is to produce a value that an investor can compare with the security's
current price in hopes of figuring out what sort of position to take with that security (underpriced
= buy, overpriced = sell or short). This method of security analysis is considered to be significantly
different from technical analysis. Fundamental analysis is about using real data to evaluate a
security's value. Although most analysts use fundamental analysis to value stocks, this method of
valuation can be used for just about any type of security. In providing certain advice in connection
with certain clients, research, asset allocation methodologies and investment strategies are used.
Technical Analysis - Technical analysis is a method of evaluating securities by relying on the
assumption that market data, such as charts of price, volume and open interest can help predict
future (usually short- term) market trends. It attempts to predict a future stock price or
direction based on market trends. Technical analysis assumes that market psychology
influences trading in a way that enables predicting when a stock will rise or fall. The risk is that
markets do not always follow patterns and relying solely on this method may not work long
term. We may recommend the use of both fundamental and technical analysis strategies for a
client in order to provide yet another form of risk management by offering differing investment
styles.
The Adviser uses the following investment strategies when providing investment advice:
Long term purchases. Securities are purchased with the idea of holding them for a relatively long
time (typically held for at least a year).
Short term purchases. Securities are purchased with the idea of selling them within a relatively
short time (typically a year or less).
Options. Options are used to “hedge” the purchase of the underlying security. Options are
purchased to limit the potential upside or downside of a security purchased in a client’s portfolio.
Structured Notes. Structured notes may be used to reduce risk exposure in a client’s portfolio
based on current market trends.
This is not intended to be an all-inclusive list.
USE OF PRIMARY METHOD OF ANALYSIS OR STRATEGY
The Adviser’s primary method of analysis or strategy is long term purchases. Long term purchases
is a strategy in which investments (such as stocks, bonds, mutual funds, etc.) are bought and
held for a long period, which is generally at least one year or more. Generally, this strategy is
not influenced by short term market fluctuations because the approach rests upon the assumption
that long term prices will go up because of an expanding economy with profits, dividends and
increased stock prices. Long term purchases minimize portfolio turnover, which can reduce
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commission costs, and taxes can be reduced or deferred. Some of the risks involved with using
this method include short term market volatility causing investor concern, risk of loss when the
asset is sold, market or company volatility or loss. Investments carry a risk of loss of principal,
earnings or both. Past performance is not a guarantee of future performance.
RISK OF LOSS
Clients must understand that past performance is not indicative of future results. Therefore,
current and prospective clients should never assume that future performance of any specific
investment or investment strategy will be profitable. Investing in securities (including stocks,
mutual funds, and bonds) involves risk of loss. Further, depending on the different types of
investments there may be varying degrees of risk. Clients and prospective clients should be
prepared to bear investment loss including loss of original principal.
Because of the inherent risk of loss associated with investing, the Adviser is unable to represent,
guarantee, or even imply that our services and methods of analysis can or will predict future
results, successfully identify market tops or bottoms, or insulate a client from losses due to market
corrections or declines. There are certain additional risks associated when investing in securities.
• Market Risk – Either the stock market as a whole, or the value of an individual
company, goes down resulting in a decrease in the value of client investments. This
is also referred to as systemic risk.
• Equity (stock) market risk – Common stocks are susceptible to general stock market
fluctuations and to volatile increases and decreases in value as market confidence in
and perceptions of their issuers change. If you held common stock, or common stock
equivalents, of any given issuer, you would generally be exposed to greater risk than
if you held preferred stocks and debt obligations of the issuer.
• Company Risk. When investing in stock positions, there is always a certain level of
company or industry specific risk that is inherent in each investment. This is also
referred to as unsystematic risk and can be reduced through appropriate
diversification. There is the risk that the company will perform poorly or have its value
reduced based on factors specific to the company or its industry. For example, if a
company’s employees go on strike or the company receives unfavorable media
attention for its actions, the value of the company may be reduced.
• Fixed Income Risk. When investing in fixed income instruments such as bonds or
notes, there is the risk that issuer will default on the bond and be unable to make
payments. Further, individuals who depend on set amounts of periodically paid income
face the risk that inflation will erode their spending power. Fixed-income investors
receive set, regular payments that face the same inflation risk.
• Options Risk. Options on securities may be subject to greater fluctuations in value
than an investment in the underlying securities. Purchasing and writing put and call
options are highly specialized activities and entail greater than ordinary investment
risks.
• ETF and Mutual Fund Risk – When investing in an Exchange Traded Fund or mutual
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fund, a client will bear additional expenses based on the client’s pro rata share of the
ETF’s or mutual fund’s operating expenses, including the potential duplication of
management fees. The risk of owning an ETF or mutual fund generally reflects the
risks of owning the underlying securities the ETF or mutual fund holds. Clients will
also incur brokerage costs when purchasing ETFs.
• Management Risk – Your investments will vary with the success and failure of our
investment strategies, research, analysis and determination of portfolio securities. If
you implement our financial planning recommendations and our investment strategies
do not produce the expected results, the value of your investment may decrease.
• Credit Risk – Credit risk can be a factor in situations where an investment’s
performance relies on a borrower’s repayment of borrowed funds. With credit risk, an
investor can experience a loss or unfavorable performance if a borrower does not
repay the borrowed funds as expected or required. Investment holdings that involve
forms of indebtedness (i.e. borrowed funds) are subject to credit risk.
• Liquidity Risk – Certain assets may not be readily converted into cash or may have a
very limited market in which they trade. Thus, you may experience the risk that your
investment or assets within your investment may not be able to be liquidated quickly,
thus, extending the period of time by which you may receive the proceeds from your
investment. Liquidity risk can also result in unfavorable pricing when exiting (i.e. not
being able to quickly get out of an investment before the price drops significantly) a
particular investment and therefore, can have a negative impact on investment
returns.
This is not intended to be an all-inclusive list. Each client should review the mutual fund
prospectus for the specific risks related to each fund that is held in each account.
Item 9 Disciplinary Information
The Adviser does not have any disciplinary information to disclose.
ITEM 9.A – CRIMINAL OR CIVIL ACTIONS
Neither the Adviser nor any management person has been found guilty of or has any criminal or
civil actions pending in a domestic, foreign or military court.
ITEM 9.B – ADMINISTRATIVE PROCEEDINGS
Neither the Adviser nor any management person has any administrative proceedings pending
before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign
financial regulatory authority.
ITEM 9.C – SELF-REGULATORY ORGANIZATION (“SRO”) PROCEEDINGS
Neither the Adviser nor any management person has been found by any SRO to have caused an
investment-related business to lose its authorization to do business, or to have been involved in
a violation of the SRO’s rules, or been barred or suspended from membership or from association
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with other members, or expelled from membership, otherwise significantly limited from
investment-related activities, or fined.
Item 10 Other Financial Industry Activities and Affiliations
ITEM 10.A – BROKER-DEALER REGISTRATION
The IARs are Registered Representatives of Integrity Alliance, a member of FINRA/SIPC. Each
IAR, in his or her capacity as a Registered Representative, may recommend securities or other
products and receive normal transaction fees, commissions or other compensation. The
Investment Adviser Representative’s Integrity Alliance affiliation is an outside business activity
and is not monitored, endorsed, or supervised by the Adviser. Thus, a conflict of interest exists
between his interests and those of advisory clients. Clients are under no obligation to act upon
any of his recommendations or affect any transactions through him if they decide to follow his
recommendations.
ITEM 10.B – FUTURES COMMISSION MERCHANT/COMMODITIES
Commodity Broker
Neither the Adviser nor any management person is a commodity broker/futures commission
merchant, a commodity pool operator, commodity trading advisor or an associated person for the
foregoing entities; nor do they have any registration applications pending.
ITEM 10.C – RELATIONSHIPS WITH RELATED PERSONS
Certain associated persons are insurance agents appointed with various insurance companies. In
these capacities associated persons of the Adviser may recommend insurance, or other products,
and receive commissions and other compensation if products are purchased through any firms
with which any associated persons are affiliated. Thus, a conflict of interest exists between the
interests of associated persons and those of the advisory clients. However, clients are under no
obligation to act upon any of their recommendations or execute any transactions through them if
they decide to follow their recommendations.
ITEM 10.D – RELATIONSHIPS WITH OTHER ADVISERS
Legacy Financial Group, LLC has no advisory affiliates to disclose.
ITEM 10.E – RELATIONSHIPS WITH RELATED INSURANCE AGENCY
LFG Insurance services, LLC provides property and casualty coverage as well as life insurance
and is under common ownership with the Adviser.
Clients are never obligated or required to purchase insurance products from our affiliated
insurance company and may choose any independent insurance agent and insurance company
to purchase insurance products. Regardless of the insurance agent selected, the insurance agent
or agency will receive normal commissions from the sale. Please refer to ITEM 14- Client Referrals
and Other Compensation for more information regarding the insurance commissions received by
our affiliated insurance agency and the conflicts such compensation presents.
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ITEM 10.F – RELATIONSHIPS WITH RELATED TAX & INSURANCE AGENCY
LFG Tax & Accounting LLC provides accounting and tax preparation services, such as
preparing and filing individual and corporate tax returns and is under common ownership with
the Adviser.
These services are not exclusive to adviser clients, nor must a client have an advisory account
with adviser. Adviser clients are under no obligation to utilize LFG Tax & Accounting, and as a
result a conflict of interest may exist to the extent that adviser clients utilize the tax and
accounting services and as this is under common ownership the adviser would directly benefit
from the receipt of service fees paid by customers. Client data may be shared if the client has
an advisory relationship with adviser and utilizes LFG Tax & Accounting for their services. If
clients do not utilize both services, their information is not shared between the groups.
Code of Ethics, Participation or Interest in Client Transactions
Item 11
and Personal Trading
ITEM 11.A – CODE OF ETHICS
The Adviser has adopted a Code of Ethics that sets forth standards of conduct expected of
advisory personnel and to address conflicts that arise from personal trading by advisory personnel.
The Adviser and its investment adviser representatives act as fiduciaries with respect to our
investment management services under this agreement. As fiduciaries, we are required to act
prudently and put your interest above our own when managing your account, and receive no
more than reasonable compensation for our services. We will also adhere to the Impartial Conduct
Standards incorporated in certain prohibited transaction exemptions promulgated by the United
States Department of Labor when applicable to our services and activities under this agreement.
Advisory personnel are obligated to adhere to the Code of Ethics, and applicable securities and
other laws.
The Code covers a range of topics that may include: general ethical principles, reporting personal
securities trading, exceptions to reporting securities trading, reportable securities, initial public
offerings and private placements, reporting ethical violations, distribution of the Code, review and
enforcement processes, amendments to Form ADV and supervisory procedures. The Adviser will
provide a copy of the Code to any client or prospective client upon request.
ITEM 11.B – PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
Principal Trading
Neither the Adviser nor any affiliated broker-dealer affects securities transactions as principal with
the Adviser’s clients.
Personal Trading of Associates Affiliated with a Brokerage Firm
Each IAR, in his or her capacity as a Registered Representative of Integrity Alliance may receive
payments from certain mutual funds distributed pursuant to a 12b-1 distribution plan, or other
such plans, as compensation for administrative services, representing a separate financial interest.
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As such, a conflict of interest exist with respect to recommendations to buy or sell securities. In
all cases, recommendations are made in the best interests of the client. The Adviser does not
permit insider trading and has implemented procedures to ensure that its policy regarding insider
trading is being observed by associated persons.
Agency-Cross Action Transactions
Neither the Adviser nor any associated person recommends to clients or buys or sells for client
accounts securities in which the Adviser or an associated person has a material financial interest.
Neither the Adviser nor any associated person acting as a principal, buys securities from (or sells
securities to) clients, acts as general partner in a partnership in which Adviser solicits client
investments, or acts as an investment adviser to an investment company that the Adviser
recommends to clients.
ITEM 11.C – PERSONAL TRADING BY ASSOCIATED PERSONS
The Adviser recommends that clients invest in various types of assets. The Adviser and its
associated persons may invest in the same types of assets. Permitted investments for associated
persons are all asset classes. See Item 11.D for conflicts of interest.
ITEM 11.D – CONFLICTS OF INTEREST WITH PERSONAL TRADING BY ASSOCIATED PERSONS
Associated persons may own an interest in or buy or sell for their own accounts the same
securities, which may be recommended to advisory clients. Associated persons seek to ensure
that they do not personally benefit from the short-term market effects of their recommendations
to clients, and their personal transactions are regularly monitored.
Associated persons are aware of the rules regarding material non-public information and insider
trading. Associated persons may also buy or sell a specific security for their own account based
on personal investment considerations, which the Adviser does not deem appropriate to buy or
sell for clients.
Item 12 Brokerage Practices
The Adviser recommends that clients use Charles Schwab & Company, Inc. ("Schwab") member
of FINRA /SIPC and registered broker-dealers, or Altruist Financial, LLC (“Altruist”) as qualified
custodians. The Adviser is independently owned and operated and is not affiliated with Schwab
or Altruist. The Adviser takes into account a blend of different factors in determining which
qualified custodian may be used, but Clients should be aware that the costs associated with
using one qualified custodian over another will vary. The relationship described between the
Adviser and each qualified custodian herein varies, and this has an impact on the conflicts of
interest present which clients should be aware of.
Charles Schwab & Company, Inc. – The Adviser has evaluated Schwab and believes that it will
provide our clients with a blend of execution services, commission costs, and professionalism that
will assist the Adviser in meeting its fiduciary obligations to clients. The Adviser receives certain
benefits that it would not receive if it did not offer investment advice to clients. Schwab provides
the Adviser with access to its institutional trading and custody services, which are typically not
available to Schwab retail investors. These services generally are available to independent
investment advisers on an unsolicited basis, at no charge to them so long as a total of at least
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$10 million of the adviser's clients' assets are maintained in accounts at Schwab. These services
are not contingent upon our firm committing to Schwab any specific amount of business other
than maintaining the client asset level mentioned above (assets in custody or trading
commissions). Schwab's brokerage services include the execution of securities transactions,
custody, 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. For our client accounts maintained in its custody, Schwab generally does not charge
separately for custody services but is compensated by account holders through commissions and
other transaction-related or asset based fees for securities trades that are executed through
Schwab or that settle into Schwab accounts. Schwab also makes available to our firm other
products and services that benefit us but do not directly benefit our clients' accounts. Many of
these products and services are used to service all or some substantial number of our client
accounts. Schwab's products and services that assist us in managing and administering our clients'
accounts include software and other technology that provide access to client account data (such
as trade confirmations and account statements), that facilitate trade execution and allocate
aggregated trade orders for multiple client accounts, that facilitate payment of our fees from
clients' accounts and assist with back-office functions, recordkeeping and client reporting. Schwab
also offers other services intended to help us manage and further develop our business enterprise.
These services may include compliance, legal and business consulting; publications and
conferences on practice management and business succession; and access to employee benefits
providers, human capital consultants and insurance providers. Schwab makes available, arranges
and/or pays third-party vendors for the types of services rendered to the Adviser. Schwab
discounts or waives fees it would otherwise charge for some of these services or pay all or a part
of the fees of a third-party providing these services to our firm. Schwab also provides other
benefits such as educational events or occasional business entertainment of our personnel. In
evaluating whether to recommend or require that clients custody their assets at Schwab, we
generally take into account the availability of some of the foregoing products and services and
other arrangements as part of the total mix of factors we consider and not solely on the nature,
cost or quality of custody and brokerage services provided by Schwab, which creates a potential
conflict of interest.
Altruist Financial, LLC – The Adviser has considered several factors when recommending Altruist
for custodial services for its clients. Such factors include Altruist’s industry reputation and
financial stability, service quality and responsiveness, execution price, speed and accuracy,
reporting abilities, and general expertise. Assessing these factors as a whole allows Adviser to
fulfill its duty to seek best execution for its clients’ securities transactions. However, Adviser
does not guarantee that using Altruist for client transactions will necessarily provide the best
possible price, as price is not the sole factor considered when seeking best execution.
ITEM 12.A – FACTORS IN SELECTING OR RECOMMENDING BROKER-DEALERS
The Adviser seeks to recommend a custodian/broker who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. The Adviser considers a wide range of factors, including, among
others, these:
• Ability to maintain the confidentiality of trading intentions
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
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• Liquidity of the securities traded
• Willingness to commit capital
• Ability to place trades in difficult market environments
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
Each IAR, in his or her capacity as a Registered Representative of Integrity Alliance may also
suggest that clients implement recommendations through Integrity Alliance. If the client so elects,
the IAR would receive normal and customary commissions in his or her capacity as a registered
person of Integrity Alliance presenting a conflict of interest. Furthermore, in implementing a
financial plan, clients may pay commissions or fees that are higher or lower than those that may
be obtained elsewhere for similar services. Clients are advised that they are under no obligation
to implement the plan or its recommendations through the IAR in his or her capacities as a
Registered Representative.
Item 12.A1 – Research and Other Soft Dollar Benefits
The Adviser does not receive soft dollars generated by the securities transactions of its clients.
The term "soft dollars" refers to funds which are generated by client trades being used by the
Adviser to purchase products or services (such as research and enhanced brokerage services)
from or through the broker-dealers whom the Adviser engages to execute securities transactions.
Item 12.A2 – Brokerage for Client Referrals
The Adviser does not refer clients to particular broker-dealers in exchange for client referrals from
those broker-dealers.
Item 12.A3 – Directed Brokerage
The Adviser does not require that clients direct their brokerage business to any particular broker-
dealer.
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ITEM 12.B – TRADE AGGREGATION
On occasions when the Firm deems the purchase and sale of a security to be in the best interests
of more than one of its clients, the Firm may aggregate multiple contemporaneous client purchase
or sell orders into a block order for execution. Executed orders are allocated among participating
accounts according to each account's pre-determined participation in the transaction.
Clients' accounts for which orders are aggregated receive the average price of such transaction,
which could be higher or lower than the price that would otherwise be paid by a client absent the
aggregation. Any transaction costs incurred in the transaction will be assessed to each client
based on each client's level of participation in the transaction. Please refer to the Block Trading
Procedures for specifics.
Item 13 Review of Accounts
IARs perform reviews of investment advisory accounts no less than quarterly. Accounts are
reviewed for consistency with the investment strategy and performance, among other things.
Reviews may be triggered by changes in an account holder’s personal, tax, or financial status.
There is currently no limit on the number of accounts that can be reviewed by an IAR.
Financial plans are reviewed only upon request. Clients are notified prior to this review that a new
client engagement may be established, and any projected fees associated with the new
engagement will be disclosed.
The Adviser does not provide any periodic reports to clients unless asked to do so. Any reports
provided from the Adviser will be specific to the services client has requested pursuant to an
executed agreement with the Adviser.
Pension Consulting clients receive reviews of their pension plans for the duration of the pension
consulting service. We also provide ongoing services to Pension Consulting clients where we meet
with such clients upon their request to discuss updates to their plans, changes in their
circumstances, etc. Pension Consulting clients do not receive written or verbal updated reports
regarding their pension plans unless they choose to contract with us for ongoing Pension
Consulting services.
Item 14 Client Referrals and Other Compensation
CLIENT REFERRALS
If you were introduced to us through a promoter/endorser, we may pay that promoter/endorser
a referral fee in accordance with Rule 206(4)-1 of the Advisers Act and applicable state securities
laws. The referral fee shall be paid solely from the Management Fee as discussed above and shall
not result in any additional charge to you. If you were introduced to us through a
promoter/endorser, you acknowledge receipt of the promoter/endorser’s disclosures disclosing
the terms of the solicitation arrangement between us and the promoter/endorser, including the
compensation to be received by the promoter/endorser from us.
As part of our employee compensation package, incentive bonuses may be allocated based on
referring new client relationships.
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RECEIPT OF ADDITIONAL COMPENSATION
As disclosed under Item 12 of this Brochure, we participate in Schwab institutional customer
program and we may recommend Schwab to Clients for custody and brokerage services. There
is no direct link between our firm’s participation in the program and the investment advice we
give to our Clients, although we receive economic benefits through our participation in the
program that are typically not available to Schwab retail investors. These benefits include the
following products and services (provided without cost or at a discount): receipt of duplicate Client
statements and confirmations; research related products and tools; consulting services; access
to a trading desk serving our firm’s participants; access to block trading (which provides the ability
to aggregate securities transactions for execution and then allocate the appropriate shares to
Client accounts); the ability to have advisory fees deducted directly from Client accounts;
access to an electronic communications network for Client order entry and account information;
access to mutual funds with no transaction fees and to certain institutional money managers;
and discounts on compliance, marketing, research, technology, and practice management
products or services provided to us by third party vendors. Schwab may also have paid for
business consulting and professional services received by our firm’s related persons. Some of
the products and services made available by Schwab through the program may benefit our firm
but may not benefit our Client accounts. These products or services may assist us in managing
and administering Client accounts, including accounts not maintained at Schwab. Other services
made available are intended to help us manage and further develop our business enterprise.
The benefits received by our firm or our personnel through participation in the program do not
depend on the amount of brokerage transactions directed to Schwab. As part of our fiduciary
duties to our clients, we endeavor at all times to put the interests of our clients first. Clients
should be aware, however, that the receipt of economic benefits by our firm or our related
persons in and of itself creates a conflict of interest and may influence our firm’s choice of Schwab
for custody and brokerage services.
LFG Insurance Services, LLC is licensed to sell P&C insurance. LFG Insurance Services, LLC is
under common ownership with the Adviser. Any commissions received by the P&C insurance
agency will benefit the owners of the Adviser and clients of the Adviser will be solicited to purchase
P&C insurance. However, there is no obligation for any Adviser client to purchase P&C insurance
through the agency,
The Adviser’s related persons that are insurance agents and insurance agencies receive
commissions and other incentive awards for the recommendation/sale of insurance products. The
receipt of this compensation may affect the judgement of our related persons when
recommending products to its clients. While our related persons endeavor at all times to put the
interest of the clients first as part of our fiduciary duty, clients should be aware that the receipt
of commission and additional compensation itself creates a conflict of interest and may affect the
judgement of insurance agents when making insurance product recommendations.
LFG Tax and Accounting, LLC is licensed to provide tax preparation and accounting services. LFG
Tax and Accounting, LLC is under common ownership with the Adviser. Any fees received by the
Tax and Accounting practice will benefit the owners of the Adviser and clients of the Adviser will
be solicited to elect tax and accounting services. However, there is no obligation for any Adviser
client to engage LFG Tax and Accounting, LLC.
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Item 15
Custody
The Firm does not take or maintain physical possession of client funds or securities. All client
assets are held with a third-party qualified custodian, such as a bank or broker-dealer.
However, under Rule 206(4)-2 of the Investment Advisers Act of 1940 (the “Custody Rule”), an
adviser is deemed to have “custody” if it has the authority to withdraw client funds or securities.
The Firm is deemed to have custody of client assets in accounts where a client has provided a
Standing Letter of Authorization (“SLOA”) or another similar arrangement that permits the Firm
to direct the disbursement of funds to a third party.
As an adviser with custody, the Firm must ensure client assets are protected in accordance with
the Custody Rule. The Firm will comply with its obligations under the Rule by either: (1)
undergoing an annual surprise examination by an independent public accountant, or (2) adhering
to the specific conditions of an applicable exception to the surprise examination requirement as
permitted by SEC rules or staff guidance.
Clients should receive account statements directly from the qualified custodian holding their
funds and securities at least quarterly. We urge you to carefully review these statements and
compare them to any account information or reports you may receive from us. Please contact us
promptly with any questions.
Item 16
Investment Discretion
It is Adviser’s customary procedure to have full discretionary authority in order to supervise and
direct the investments of a client’s accounts. Client’s grant this authority upon execution of
Advisor’s Discretionary Investment Management Agreement. This authority is for the purpose of
making and implementing investment decisions, without the client’s prior consultation. All
investment decisions are made in accordance with the client’s stated investment objectives. Other
than management fees due to Adviser, which Adviser will receive directly from the custodian,
Adviser’s discretionary authority does not give authority to take or have possession of any assets
in the client’s account or to direct delivery of any securities or payment of any funds held in the
account to Adviser. Furthermore, Adviser’s discretionary authority by agreement does not allow
it to direct the disposition of such securities or funds to anyone except the account owner.
Clients may impose reasonable restrictions, in writing, on investing in certain securities or types
of securities in accordance with their values and beliefs. Adviser will make every effort to comply
with the wishes of the client but cannot guarantee absolute adherence due to our use of indexed
products, funds, and ETFs that are controlled by third party managers.
As discussed in Item 4, Advisor may manage employer sponsored retirement plans on a
nondiscretionary basis for certain plan participants pursuant to the plan documents and client
preference. All other client accounts will be managed on a discretionary basis. Adviser has a
limited number of nondiscretionary, but is not adding additional accounts at this time.
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Item 17 Voting Client Securities
The Adviser does not accept authority to vote proxies on behalf of clients as a matter of policy.
Clients will receive their proxy information directly from their custodian.
Clients may contact the Adviser with questions about a particular solicitation by telephone at
(515) 255-3306.
Item 18 Financial Information
The Adviser does not require or collect prepayment of more than $1,200 in fees, six months or
more in advance, so no balance sheet is being provided. There is no financial condition that is
reasonably likely to impair the Adviser’s ability to meet its contractual commitments to its clients.
The Adviser has not been subject to a bankruptcy petition at any time.
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