Overview
- Headquarters
- Traverse City, MI
- Total Firm Assets
- $123 million
- Average High-Net-Worth Client Portfolio Size
- $2.4 million
- Minimum Account Size
- $250,000
Fee Structure
Primary Fee Schedule (ADV 2022)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $249,000 | 1.75% |
| $249,001 | $500,000 | 1.50% |
| $500,001 | $1,000,000 | 1.00% |
| $1,000,001 | $2,000,000 | 0.90% |
| $2,000,001 | $3,000,000 | 0.80% |
| $3,000,001 | $5,000,000 | 0.70% |
| $5,000,001 | and above | Negotiable |
Minimum Annual Fee: $3,750
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $13,122 | 1.31% |
| $5 million | $44,122 | 0.88% |
| $10 million | Negotiable | Negotiable |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- High-Net-Worth Share of Firm Assets
- 67.74%
- Number of High-Net-Worth Clients
- 35
- Total Client Accounts
- 357
- Discretionary Accounts
- 357
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 140514
Primary Brochure: ADV 2022 (2026-05-19)
View Document Text
LEGACY FINANCIAL SERVICES GROUP, INC.
www.discoverlegacy.net
10691 E. Carter Rd. Suite 101
Traverse City, MI 49684
231-933-0631
231-933-0838
May 19, 2026
This brochure provides information about the qualifications and business
practices of Legacy Financial Services Group, Inc. If you have any
questions about the contents of this brochure, please contact us at: 231-
933-0631, or by email at: info@discoverlegacy.net. The information in this
brochure has not been approved or verified by the United States
Securities and Exchange Commission, or by any state securities authority.
Registration does not imply a certain level of skill or training.
Additional information about Legacy Financial Services Group, Inc. is
available on the SEC’s website at www.advisorinfo.sec.gov. You can
search this site by a unique identifying number, known as a CRD number.
The CRD number for Legacy Financial Services Group, Inc. is 140514.
Legacy Group
Item 2 – Material Changes
Summary of Material Changes
Legacy Financial Services Group, Inc, has amended this brochure since its last annual
updating amendment, dated March 3, 2026, to disclose the following material change.
On May 19, 2026, we amended this brochure in connection with our firm’s
application for registration with the U.S. Securities and Exchange Commission
(“SEC”) due to the level of assets under management maintained by our firm.
This registration change does not affect our day-to-day operations. If you have
any questions about this update, please contact us at 321-933-0631 and ask to
speak with our Chief Compliance Officer.
Full Brochure Available
Whenever you would like to receive a complete copy of our Firm Brochure, please
contact us by telephone at: 231-933-0631 or by email at: info@discoverlegacy.net.
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Legacy Group
Item 3 – Table of Contents
Table of Contents
Item 2 – Material Changes ........................................................................................................................... i
Item 3 – Table of Contents ......................................................................................................................... 1
Table of Contents ........................................................................................................................................ 1
Item 4 - Advisory Business ........................................................................................................................ 1
Item 5 - Fees and Compensation ............................................................................................................... 3
Item 6 - Performance-Based Fees ............................................................................................................. 7
Item 7 - Types of Clients ............................................................................................................................. 7
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 8
Item 9 - Disciplinary Information ............................................................................................................. 11
Item 10 - Other Financial Industry Activities and Affiliations ............................................................... 11
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .... 11
Item 12 - Brokerage Practices .................................................................................................................. 12
Item 13 - Review of Accounts .................................................................................................................. 13
Item 14 - Client Referrals and Other Compensation .............................................................................. 13
Item 15 – Custody ..................................................................................................................................... 13
Item 16 - Investment Discretion ............................................................................................................... 14
Item 17 - Voting Client Securities ............................................................................................................ 15
Item 18 - Financial Information ................................................................................................................ 15
Privacy Policy Notice ................................................................................................................................ 15
Form ADV Part 2B Brochure Supplement – Carolyn Weeks ................................................................ 17
Form ADV Part 2B Brochure Supplement – Kelly Kazmierski ............................................................. 19
TOC 1
Legacy Group
Item 4 - Advisory Business
Firm Description
This Disclosure document is being offered to you by Legacy Financial Services
Group, Inc. (“Legacy Group”) in connection with the investment advisory services
we provide. It discloses information about the services we provide and the manner
in which those services are made available to you, the client.
We are a fee-based investment management firm located in Traverse City,
Michigan, specializing in investment advisory services for investors. The firm was
established in 2001 and became a registered investment adviser in 2006. Derek
Weeks owns the firm.
We are committed to helping clients build, manage, and preserve your wealth and
to providing assistance to clients to help achieve their stated financial goals. We
may offer an initial complimentary meeting; however, investment advisory services
are initiated only after you and Legacy Group execute an engagement letter or
client agreement.
Investment Management and Supervision Services
financial planning and
Legacy Group provides personalized confidential
investment management. Advice is provided through consultation with the client
and may include: determination of financial objectives, identification of financial
problems, cash flow management, tax planning, insurance review, investment
management, education funding, retirement planning, and estate planning.
Investment advice is an integral part of our investment management. Investment
advice is provided, with the client making the final decision on investment
selection. A written evaluation of each client's initial situation is provided to the
client, often in the form of a net worth statement. Periodic reviews are also
communicated to provide reminders of the specific courses of action that need to
be taken. More frequent reviews occur but are not necessarily communicated to
the client unless immediate changes are recommended.
Most clients choose to have us manage their assets in order to obtain ongoing in-
depth advice and life planning. All aspects of the client’s financial affairs are
reviewed, including those of their children. Realistic and measurable goals are set
and objectives to reach those goals are defined. As goals and objectives change
over time, suggestions are made and implemented on an ongoing basis.
We offer discretionary investment management and investment supervisory
services for a fee based on a percentage of your assets under management. The
scope of work and fee for investment managementis provided to the client in
writing prior to the start of the relationship. A Wealth Management Agreement
includes: cash flow management; insurance review; investment management
(including performance reporting); education planning; retirement planning; estate
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Legacy Group
planning; and tax preparation, as well as the implementation of recommendations
within each area.
Upon the preliminary review, we determine your portfolio composition based on
your needs, portfolio restrictions, if any, financial goals and risk tolerances.
Through the initial phases of our relationship, we work with you to obtain
necessary information regarding your financial condition, investment objectives,
liquidity requirements, risk tolerance, time horizons, and any restrictions on
investing. This enables us to determine the portfolio best suited for your
investment objective and needs.
to engage
In performing our services, we are not required to verify any information received
from you or from other professionals. If you request, we may recommend and/or
engage the services of other professionals for implementation purposes. You are
under no obligation
the services of any such recommended
professional.
Once we have determined the types of investments to be included in your
portfolio, and allocated them, we will provide ongoing portfolio review and
management services. This approach requires us to review our portfolios on a
frequent basis.
We will rebalance the portfolio, as we deem appropriate, to meet your financial
objectives. We will trade these portfolios and rebalance them on a discretionary
basis.
While our advisory services are tailored to you as an individual, our multi-fund
manager approach makes it difficult for us to ensure that your portfolio will not
invest in a particular industry or security. However, we are happy to discuss your
preferences regarding socially conscious investment concerns and, we’ll try as
much as possible, to accommodate them.
In all cases, you have a direct and beneficial interest in your securities, rather
than an undivided interest in a pool of securities. We do not and will not have
custody of your funds or securities. We have limited authority to direct the
Custodian to deduct investment advisory fees, but only with the appropriate
authorization from you.
The initial meeting, which may be by telephone, is free of charge and is
considered an exploratory interview to determine the extent to which financial
planning and investment management may be beneficial to the client.
On more than an occasional basis, we furnish advice to clients on matters not
involving securities, such as financial planning matters, taxation issues, and trust
services that often include estate planning. This advice is included in our
Investment Management fee.
Wrap Fee Programs
We do not place Client assets into a wrap fee program.
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Assets
As of 12/31/2025, we manage $122,816,278 in assets on a discretionary basis.
We do not manage any non-discretionary assets.
Item 5 - Fees and Compensation
Investment Management Fees and Compensation
Legacy Group charges a fee as compensation for providing Investment
Management services to your account. These services include advisory and
consulting services, trade entry, investment supervision, and other account
maintenance activities. The custodian may charge custodial fees, transaction
costs, redemption fees, retirement plan and administrative fees or commissions.
See Additional Fees and Expenses below.
The fees for accounts are based on an annual percentage of your assets that we
manage. The fees are applied to the account asset value on a pro-rated basis,
billed monthly, in arrears. Fees are usually deducted from a designated client
account to facilitate billing. The client must consent in advance to direct debiting
of their investment account.
The initial fee will be based upon the market value of the account on the date the
account is accepted for management by execution of the investment advisory
contract by the Firm and the assets are transferred, and then prorated for the
number of days in the calendar month that your account is under management.
Thereafter, the fee will be based on the market value of the account on the last
day of the previous calendar month and will cover the period from the first day of
the calendar month through the last day of the calendar month. The market value
will be determined as reported by the Custodian. Fees are assessed on all assets
under management, including securities, cash and money market balances.
Margin debit balances do not reduce the value of assets under management.
Fees may vary based on the size of the account, complexity of the portfolio,
extent of activity in the account or other reasons agreed upon by us and you as
the client. Fees will generally follow the schedule of assets under management
outlined below. In certain circumstances at our discretion, we may allow you to
negotiate fees.
The annual Advisory Service Agreement fee is based on a percentage of the
investable assets according to the following schedule:
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Legacy Group
Maximum Annual Fee
Portfolio Size (Assets Under Management)
1.75%
Up to $249,000 (if accepted conditionally)
1.50%
$250,000 - $499,999
1.00%
$500,000 - $999,999
0.90%
$1,000,000 - $1,999,999
0.80%
$2,000,000 - $2,999,999
0.70%
$3,000,000 - $4,999,999
Determined at Engagement
$5,000,000 +
Current client relationships may exist where the fees are higher or lower than the
fee schedule above.
In our discretion, we may add (aggregate) asset amounts in accounts from your
same household together to determine the advisory fee for all your accounts. We
may do this, for example, where we also service accounts on behalf of your minor
children, individual and joint accounts for a spouse, and/or other types of related
accounts. This consolidation practice is designed to allow you the benefit of an
increased asset total, which could potentially cause your account(s) to be
assessed a reduced advisory fee based on the asset levels available in our fee
schedule.
You authorize us to debit your account for our fee. The independent qualified
custodian holding your funds and securities will debit your account directly for the
advisory fee and pay that fee to us.
You will provide written authorization permitting the fees to be paid directly from
your account held by the qualified custodian. Further, the qualified custodian
agrees to deliver an account statement at least quarterly directly to you indicating
all the amounts deducted from the account including our advisory fees. You are
encouraged to review your account statements for accuracy. We will receive a
duplicate copy of the custodian’s statement that was delivered to you.
Although the Wealth Management Agreement is an ongoing agreement and
constant adjustments are required, the length of service to the client is at the
client’s discretion. The client or Legacy Group may terminate the Agreement by
written notice to the other party. At termination, fees will be billed on a pro rata
basis for the portion of the month completed. The portfolio value at the
completion of the prior full billing month is used as the basis for the fee
computation, adjusted for the number of days during the billing month prior to
termination. Upon termination, you are responsible for monitoring the securities in
your account, and we will have no further obligation to act or advise with respect
to those assets.
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Legacy Group
Additional Fees and Expenses:
Advisory fees payable to us do not include the fees you may pay when we
purchase or sell securities for your Account(s). The following list of fees or
expenses are what you may pay directly to third parties, whether a security is
being purchased, sold or held in your Account(s) under our management.
• Brokerage commissions;
• Transaction fees;
• Exchange fees;
• SEC fees;
• Advisory fees and administrative fees charged by Mutual Funds (MF),
and/or Exchange Traded Funds (ETFs)
• Advisory fees charged by sub-advisers (if any are used for your account
• Custodial Fees;
• Deferred sales charges (on MF or annuities);
• Odd-Lot differentials;
• Transfer taxes;
• Wire transfer and electronic fund processing fees;
• Fees on existing variable annuities that may have been subject to trailing
service fees, deferred sales charges, and mortality and expense fees.
• Fees on Mutual fund assets deposited in the account that may have been
subject to deferred sales charges and 12 (b)(1) fees and other mutual fund
annual expenses as described in the fund’s prospectus.
Please refer to the “Brokerage Practices” for discussion of Legacy Group’s
brokerage practices.
Expense Ratios
Mutual funds generally charge a management fee for their services as
investment managers. The management fee is called an expense ratio. For
example, an expense ratio of 0.50 means that the mutual fund company charges
0.5% for their services. These fees are in addition to the fees paid by you to
Legacy Group.
Performance figures quoted by mutual fund companies in various publications
are after their fees have been deducted.
Past Due Accounts and Termination of Agreement
We reserve the right to stop work on any account that is more than 15 days
overdue. In addition, we reserve the right to terminate any engagement where a
client has willfully concealed or has refused to provide pertinent information
about financial situations when necessary and appropriate, in Legacy Group,
Inc.’s judgment, to providing proper financial advice. Any unused portion of fees
collected will be refunded on a prorated basis.
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Legacy Group
Compensation for the Sale of Securities or Other Investment Products
Certain Executive officers and other Associated Persons of our firm are licensed
as independent insurance agents. These persons will earn commission-based
compensation for selling insurance products, including insurance products they
sell to our clients. Insurance commissions earned by these persons are separate
from and in addition to our advisory fees. The sale of insurance instruments and
other commissionable products offered by Associated Persons are intended to
complement our advisory services. However, this practice presents a conflict of
interest because persons providing investment advice on behalf of our firm who
are insurance agents have an incentive to recommend insurance products to you
for the purpose of generating commissions rather than solely based on your
needs. We address this conflict of interest by recommending insurance products
only where we, in good faith, believe that it is appropriate for the client’s particular
needs and circumstances and only after a full presentation of the recommended
insurance product to our client. In addition, we explain the insurance underwriting
process to our clients to illustrate how the insurer also reviews the client’s
application and disclosures prior to the issuance of a resulting insuring
agreement. Clients to whom the firm offers advisory services are informed that
they are under no obligation to purchase insurance services. Clients who do
choose to purchase insurance services are under no obligation to use our
licensed Associated Persons and may use the insurance brokerage firm and
agent of their choice.
Where fixed annuities are sold, clients should also note that the annuity sales
result in substantial up-front commissions and ongoing trails based on the
annuity’s total value. In addition, many annuities contain surrender charges and/or
restrictions on access to your funds. Payments and withdrawals can have tax
consequences. Optional lifetime income benefit riders are used to calculate
lifetime payments only and are not available for cash surrender or in a death
benefit unless specified in the annuity contract. In some annuity products, fees
can apply when using an income rider. Annuity guarantees are based on the
financial strength and claims-paying ability of the issuing insurance company. We
urge our clients to read all insurance contract disclosures carefully before making
a purchase decision. Rates and returns mentioned on any program presented are
subject to change without notice. Insurance products are subject to fees and
additional expenses.
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Legacy Group
Item 6 - Performance-Based Fees
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of
managed securities.
Legacy Group does not use a performance-based fee structure because of the
potential conflict of interest. Performance-based compensation may create an
incentive for the advisor to recommend an investment that may carry a higher
degree of risk to the client.
Item 7 - Types of Clients
Description
Legacy Group generally provides investment advice to individuals, banks or thrift
institutions, investment companies, pension and profit sharing plans, trusts,
estates, or charitable organizations, corporations or business entities.
Client relationships vary in scope and length of service.
Account Minimums
The minimum account size is $250,000.00 of assets under management, which
equates to an annual fee of $3,750.00.
When an account falls below $250,000 in value, the management fee percentage
will remain unchanged. Depending upon circumstances, Legacy Group will
negotiate a lower rate.
Legacy Group has the discretion to waive the account minimum. Accounts of
less than $250,000 may be set up when the client and the advisor anticipate the
client will add additional funds to the accounts bringing the total to $250,000
within a reasonable time. Other exceptions will apply to employees of Legacy
Group and their relatives, or relatives of existing clients.
Clients receiving ongoing asset management services and with assets below the
minimum account size may pay a higher percentage rate on their annual fees
than the fees paid by clients with greater assets under management.
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Legacy Group
Item 8 - Methods of Analysis, Investment Strategies and Risk
of Loss
Methods of Analysis
Security analysis methods may include charting, fundamental analysis, technical
analysis, and cyclical analysis.
The main sources of information include financial newspapers and magazines,
inspections of corporate activities, research materials prepared by others,
corporate rating services, timing services, annual reports, prospectuses, filings
with the Securities and Exchange Commission, and company press releases.
Other sources of information that Legacy Group may use include Morningstar
Principia mutual fund information, Morningstar Principia stock information,
Investor’s Business Daily, and the World Wide Web.
Investment Strategies
The primary investment strategy used on client accounts is strategic asset
allocation based on each client’s timeframe and risk tolerance. Portfolios are
diversified in various asset classes which are reviewed and generally are
rebalanced on a quarterly basis. Portfolios are globally diversified to control the
risk associated with traditional markets.
The investment strategy for a specific client is based upon the objectives stated
by the client during consultations. The client may change these objectives at any
time. Each client executes an Investment Policy Statement that documents their
objectives and their desired investment strategy.
Other strategies may include long-term purchases, short-term purchases and
trading.
Recommendation of Particular Types of Securities
We primarily offer advice on equity securities, exchange traded funds, mutual
fund shares, and corporate debt securities. Additionally, we may advise you on
any type of investment that we deem appropriate based on your stated goals and
objectives. Each type of security has its own unique set of risks associated with it
and it would not be possible to list here all of the specific risks of every type of
investment. Even within the same type of investment, risks can vary widely.
However, in very general terms, the higher the anticipated return of an
investment, the higher the risk of loss associated with it.
Risks Associated with Investing in Equities
Investments in equities generally refer to buying shares of stocks by an individual
or firm in return for receiving a future payment of dividends and capital gains if
the value of the stock increases. There is an innate risk involved when
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purchasing a stock that it may decrease in value and the investment may incur a
loss.
Risks Associated with Fixed Income
When investing in bonds, there is the risk that the 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.
Risks Associated with Investing in Mutual Funds
Mutual funds are professionally managed collective investment systems that pool
money from many investors and invest in stocks, bonds, short-term money market
instruments, other mutual funds, other securities, or any combination thereof. The fund
will have a manager that trades the fund's investments in accordance with the fund's
investment objective. While mutual funds generally provide diversification, risks can be
significantly increased if the fund is concentrated in a particular sector of the market,
primarily invests in small cap or speculative companies, uses leverage (i.e., borrows
money) to a significant degree, or concentrates on a particular type of security (i.e.,
equities) rather than balancing the fund with different types of securities. The returns on
mutual funds can be reduced by the costs to manage the funds. In addition, while some
mutual funds are “no load” and charge no fee to buy into, or sell out of, other types of
mutual funds do charge such fees which can also reduce returns.
Risks Associated with Investing in Exchange Traded Funds (ETF): Investing in
ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock
holding bankruptcy). Investments in these securities are not guaranteed or insured by
the FDIC or any other government agency. Detailed information about the risks
associated with each ETF is provided in the relevant ETF’s prospectus.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to
bear. Please review the disclosures below to better understand the types of risk
that might be associated with your investments.
All investment programs have certain risks that are borne by the investor. Our
investment approach constantly keeps the risk of loss in mind. Investors face the
following investment risks:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment
prices to fluctuate. For example, when interest rates rise, yields on
existing bonds become less attractive, causing their market values to
decline.
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• Market Risk: The price of a security, bond, or mutual fund may drop in
reaction to tangible and intangible events and conditions. This type of risk
is caused by external factors independent of a security’s particular
underlying circumstances. For example, political, economic and social
conditions may trigger market events.
•
Inflation Risk: When any type of inflation is present, a dollar today will not
buy as much as a dollar next year, because purchasing power is eroding
at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the
value of the dollar against the currency of the investment’s originating
country. This is also referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments
may have to be reinvested at a potentially lower rate of return (i.e. interest
rate). This primarily relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a
particular company within an industry. For example, oil-drilling companies
depend on finding oil and then refining it, a lengthy process, before they
can generate a profit. They carry a higher risk of profitability than an
electric company, which generates its income from a steady stream of
customers who buy electricity no matter what the economic environment is
like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into
cash. Generally, assets are more liquid if many traders are interested in a
standardized product. For example, Treasury Bills are highly liquid, while
real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations
increases the risk of profitability, because the company must meet the
terms of its obligations in good times and bad. During periods of financial
stress, the inability to meet loan obligations may result in bankruptcy
and/or a declining market value.
Indexing: Direct
indexing strategies seek
to replicate
• Direct
the
performance of a market index by directly holding the individual securities,
or a representative sample of the individual securities, that make up the
index. Direct indexing can provide a more tax efficient means of investing,
and allows for more customized investment allocations, than investing in a
fund or other commingled product that seeks to replicate the index. The
potential benefits of direct indexing, however, will not necessarily be
realized if a client does not take advantage of tax planning or impose
account restrictions, such as account level security or sector-based
restrictions or customizations based on specific tax, Environmental,
Social, and Governance or other preferences. Fees and expenses for the
direct indexing strategy in some cases will be higher than the fees and
expenses associated with alternative index products. Higher fees and
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expenses could adversely impact account performance. The size of the
account and the number of securities in the index the account seeks to
replicate also limit the ability of the account to replicate the index. As a
result, the direct indexing strategy introduces the risk of tracking error
relative to the index and can cause a portfolio to underperform the index,
including as a result of customization.
Item 9 - Disciplinary Information
Legal and Disciplinary
The firm and its employees have not been involved in legal or disciplinary events
related to past or present investment clients.
Item 10 - Other Financial Industry Activities and Affiliations
Affiliations
Neither Legacy Group or its representatives have any other financial industry
affiliations.
Insurance
In addition, as a convenience to our, certain IAR’s of Legacy Group are also
licensed insurance agents and sell various life insurance products, long term
care and annuities. As a result, our IAR’s may receive compensation for these
activities as an insurance agent. A limited portion of the time they spend
(generally less than 10%) is in connection with these activities and it represents
less than 10% of our ongoing revenue. Clients are not under any obligation to
purchase insurance products. Please refer to Item 5 of this Brochure for more
information on the conflicts of interest associated with these activities, and how
we mitigate such conflicts.
Item 11 - Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Code of Ethics
The employees of Legacy Group have committed to a Code of Ethics that is
available for review by clients and prospective clients upon request. The firm will
provide a copy of the Code of Ethics to any client or prospective client upon
request.
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Participation or Interest in Client Transactions
Legacy Group and its employees may buy or sell securities that are also held by
clients. Employees may not trade their own securities ahead of client trades.
Employees comply with the provisions of the Legacy Group Compliance Manual.
Personal Trading
The Chief Compliance Officer of Legacy Group is Carolyn Weeks. She reviews
all employee trades each quarter. The personal trading reviews ensure that the
personal trading of employees does not affect the markets, and that clients of the
firm receive preferential treatment. Since most employee trades are small
mutual fund trades or exchange-traded fund trades, the trades do not affect the
securities markets.
Item 12 - Brokerage Practices
Selecting Brokerage Firms
Legacy Group does not have any affiliation with product sales firms. Specific
custodian recommendations are made to Clients based on their need for such
services. Legacy Group recommends custodians based on the proven integrity
and financial responsibility of the firm and the best execution of orders at
reasonable commission rates.
Legacy Group recommends discount brokerage firms and trust companies
(qualified custodians), such as Altruist Financial LLC. The broker-dealer/
custodian is not affiliated with Legacy Group and does not supervise Legacy
Group, its representatives, or its activities.
Legacy Group does not receive fees or commissions from any of these
arrangements.
Best Execution
Legacy Group reviews the execution of trades at each custodian each quarter.
The review is documented in the Legacy Group Compliance Manual. Trading
fees charged by the custodians is also reviewed on a periodic basis. Legacy
Group does not receive any portion of the trading fees.
Order Aggregation
Most trades are mutual funds or exchange-traded funds where trade aggregation
does not garner any client benefit.
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Item 13 - Review of Accounts
Periodic Reviews
Account reviews are performed quarterly by Kelly Kazmierski, Advisor. Account
reviews are performed more frequently when market conditions dictate.
Review Triggers
Other conditions that may trigger a review are changes in the tax laws, new
investment information, and changes in a client's own situation.
Regular Reports
Account reviewers are members of the firm's Investment Committee. They are
instructed to consider the client's current security positions and the likelihood that
the performance of each security will contribute to the investment objectives of
the client.
Clients receive periodic communications on at least an annual basis. Wealth
Management clients receive written quarterly updates. The written updates may
include a net worth statement, portfolio statement, and a summary of objectives
and progress towards meeting those objectives.
Net Worth Statements
Clients are frequently provided net worth statements and net worth graphs that
are generated from our client relationship management system. Net worth
statements contain approximations of bank account balances provided by the
client, as well as the value of land and hard-to-price real estate. The net worth
statements are used for long-term financial planning where the exact values of
assets are not material to the financial planning tasks.
Item 14 - Client Referrals and Other Compensation
We do not receive any compensation from any third party in connection with providing
investment advice to you, nor do we compensate any individual or firm for client
referrals.
Item 15 – Custody
Custody, as it applies to investment advisors, has been defined by regulators as
having access or control over client funds and/or securities. In other words,
custody is not limited to physically holding client funds and securities. If an
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investment advisor has the ability to access or control client funds or securities,
the investment advisor is deemed to have custody and must ensure proper
procedures are implemented.
Legacy Group is deemed to have custody of client funds and securities whenever
Legacy Group is given the authority to have fees deducted directly from client
accounts. However, this is the only form of custody Legacy Group will ever
maintain. It should be noted that authorization to trade in client accounts is not
deemed by regulators to be custody.
For accounts in which Legacy Group is deemed to have custody, the firm has
established procedures to ensure all client funds and securities are held at a
qualified custodian in a separate account for each client under that client’s name.
Clients or an independent representative of the client will direct, in writing, the
establishment of all accounts and therefore are aware of the qualified custodian’s
name, address and the manner in which the funds or securities are maintained.
Finally, account statements are delivered directly from the qualified custodian to
each client, or the client’s independent representative, at least quarterly. Advisor
is not affiliated with the custodian. The custodian does not supervise the advisor,
its agents or activities. When clients have questions about their account
statements, they should contact Legacy Group or the qualified custodian
preparing the statement.
When fees are deducted from an account, Legacy Group is responsible for
calculating the fee and delivering instructions to the custodian.
Performance Reports
Clients are urged to compare the account statements received directly from their
custodians to the performance report statements provided by Legacy Group .
Item 16 - Investment Discretion
Discretionary Authority for Trading
Legacy Group accepts discretionary authority to manage securities accounts on
behalf of clients. Legacy Group has the authority to determine, without obtaining
specific client consent, the securities to be bought or sold, and the amount of the
securities to be bought or sold. However, Legacy Group consults with the client
prior to each trade to obtain concurrence if a blanket trading authorization has
not been given.
The client approves the custodian to be used and the commission rates paid to
the custodian. Legacy Group does not receive any portion of the transaction
fees or commissions paid by the client to the custodian on certain trades.
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Legacy Group
Discretionary trading authority facilitates placing trades in your accounts on your
behalf so that we may promptly implement the investment policy that you have
approved in writing.
Limited Power of Attorney
A limited power of attorney is a trading authorization for this purpose. You sign a
limited power of attorney so that we may execute the trades that you have
approved.
Item 17 - Voting Client Securities
Proxy Votes
Legacy Group does not vote proxies on securities. Clients are expected to vote
their own proxies.
When assistance on voting proxies is requested, Legacy Group will provide
recommendations to the Client. If a conflict of interest exists, it will be disclosed
to the Client.
Item 18 - Financial Information
Financial Condition
Legacy Group does not have any financial impairment that will preclude the firm
from meeting contractual commitments to clients.
A balance sheet is not required to be provided because Legacy Group does not
serve as a custodian for client funds or securities, and does not require
prepayment of fees of more than $1,200 per client, and six months or more in
advance.
Privacy Policy Notice
Information Security
Legacy Group maintains an information security program to reduce the risk that
your personal and confidential information may be breached.
Privacy Notice
Legacy Group is committed to maintaining the confidentiality, integrity and
security of the personal information that is entrusted to us.
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Legacy Group
The categories of nonpublic information that we collect from you may include
information about your personal finances, information about your health to the
extent that it is needed for the financial planning process, information about
transactions between you and third parties, and information from consumer
reporting agencies, e.g., credit reports. We use this information to help you meet
your personal financial goals.
With your permission, we disclose limited information to attorneys, accountants,
and mortgage lenders with whom you have established a relationship. You may
opt out from our sharing information with these nonaffiliated third parties by
notifying us at any time by telephone, mail, fax, email, or in person. With your
permission, we share a limited amount of information about you with your
brokerage firm in order to execute securities transactions on your behalf.
We maintain a secure office to ensure that your information is not placed at
unreasonable risk. We employ a firewall barrier, secure data encryption
techniques and authentication procedures in our computer environment.
We do not provide your personal information to mailing list vendors or solicitors.
We require strict confidentiality in our agreements with unaffiliated third parties
that require access to your personal information, including financial service
companies, consultants, and auditors. Federal and state securities regulators
may review our Company records and your personal records as permitted by
law.
Personally identifiable information about you will be maintained while you are a
client, and for the required period thereafter that records are required to be
maintained by federal and state securities laws. After that time, information may
be destroyed.
We will notify you in advance if our privacy policy is expected to change. We are
required by law to deliver this Privacy Notice to you annually, in writing.
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Legacy Group
Carolyn Weeks
LEGACY FINANCIAL SERVICES GROUP, INC.
www.discoverlegacy.net
10691 E. Carter Rd. Suite 101
Traverse City, MI 49684
231-933-0631
231-933-0838
Form ADV Part 2B Brochure Supplement – Carolyn Weeks
May 19, 2026
The Brochure Supplement provides information about Carolyn Weeks that supplements
the Legacy Financial Services Group, Inc. Brochure. You should have received a copy
of the Brochure. Please contact Carolyn Weeks, Chief Compliance Officer if you did not
receive Legacy Financial Services Group, Inc.’s Brochure or if you have any questions
about the contents of this supplement.
Additional information about Carolyn Weeks is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Legacy Group
Carolyn Weeks, Financial Adviser/Operations Manager/Chief
Compliance Officer
Date of Birth: July 28, 1973
Educational Background:
• Series 65 Investment Adviser Representative
Business Experience:
• Legacy Financial Services Group, Traverse City, MI, Chief Operations
Officer and Chief Compliance Officer (2001 – Present)
Disciplinary Information
• Registered investment advisers are required to disclose all material facts
regarding any legal or disciplinary events that would be material to your
evaluation of Ms. Weeks and Legacy Financial Services Group, Inc. Ms.
Weeks has not been involved in any reportable disciplinary events.
Other Business Activities:
• Owner of the retail store Metal Arts & Home Décor in Traverse City, MI.
The store specializes in selling Metal wall art, fireplace sets, and home
décor items.
• Owner of the restaurant Park Street Cafe in Traverse City, MI. The café
serves breakfast and lunch in a quick service setting.
Additional Compensation:
• None
Supervision:
Ms. Weeks, Chief Compliance Office is supervised by the firms Compliance
Manual and Code of Ethics.
SUPERVISOR’S contact information:
231-933-0631
cweeks@discoverlegacy.net
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Legacy Group
Kelly Kazmierski
LEGACY FINANCIAL SERVICES GROUP, INC.
www.discoverlegacy.net
10691 E. Carter Rd. Suite 101
Traverse City, MI 49684
231-933-0631
231-933-0838
Form ADV Part 2B Brochure Supplement – Kelly Kazmierski
May 19, 2026
information about Kelly Kazmierski
The Brochure Supplement provides
that
supplements the Legacy Financial Services Group, Inc. Brochure. You should have
received a copy of the Brochure. Please contact Carolyn Weeks, Chief Compliance
Officer if you did not receive Legacy Financial Services Group, Inc.’s Brochure or if you
have any questions about the contents of this supplement.
Additional information about Kelly Kazmierski is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Legacy Group
Kelly Kazmierski, Financial Advisor
Date of birth: December 25, 1972
Educational Background:
• FINRA: Series 65 Investment Adviser Representative
• FINRA: Series 6 and 63 (inactive in fee-based advisory firm)
• Licenses: Michigan Life and Health Licenses (and appropriate jurisdictions)
• Michigan State University, East Lansing B.A (1995)
Business Experience:
• Legacy Financial Services Group, Traverse City, MI, Investment
Adviser Representative: (2004 – Present)
Pre-RIA registration: (2001 – 2006) (insurance services)
• Linsco/Private Ledger, Traverse City, MI, Registered Representative and
Advisory Representative
Broker/Dealer and Investment Advisor: (2004 – 2006)
• Huntington Bankshares, Traverse City, MI, Trust Officer Banking: (2002
– 2004)
• Grand Traverse Area Catholic Schools, Traverse City, MI, Director
School System: (1997 – 2002)
• PVC Geomembrane Institute, Traverse City, MI, Executive Director
Marketing: (1995 – 2007)
Disciplinary Information
Registered investment advisers are required to disclose all material facts
regarding any legal or disciplinary events that would be material to your
evaluation of Ms. Kamierski and Legacy Financial Services Group, Inc. Ms.
Kamierski has not been involved in any reportable disciplinary events.
Other Business Activities:
fixed or variable
life
insurance
Ms. Kamierski is an insurance agent. In such capacity, she may offer fixed and
variable life insurance products and receive normal and customary commissions
as a result of any purchases made by clients. The client is under no obligation to
purchase
through Ms Kamierski on a
commissionable basis.
In addition, Ms. Kamierski may receive other
compensation such as fixed or variable life trails. The potential for receipt of
commissions and other compensation gives her an incentive to recommend
insurance products based on the compensation received, rather than on the
client’s needs. To address this, disclosure is made to the client at the time
purchase is made, indentifying the nature of the transaction or relationship, the
role to be played and any compensation (e.g., commissions, trails) to be paid by
the client and/or received by the insurance agent.
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Legacy Group
Additional Compensation:
None
through our client
Supervision:
Kelly Kazmierski is supervised by Ms. Weeks. She reviews Kelly Kazmierski’s
work through frequent office interactions as well as remote interactions. She also
reviews Kelly’s Kazmierski’s activities
relationship
management system.
SUPERVISOR’S contact information:
231-933-0631
dweeks@discoverlegacy.net
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Legacy Group