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Disclosure Brochure
February 6, 2026
LIFTPOINT FAMILY WEALTH ADVISORS, LLC
a Registered Investment Adviser
49 Route 202 Bldg 13A #8
Far Hills, NJ 07931
(862) 412-8862
This brochure provides information about the qualifications and business practices of LiftPoint Family Wealth
Advisors, LLC (hereinafter “LiftPoint” or the “Firm”). If you have any questions about the contents of this
brochure, please contact the Firm at the telephone number listed above. The information in this brochure has
not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state
securities authority. Additional information about the Firm is available on the SEC’s website at
www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level
of skill or training.
Disclosure Brochure
LiftPoint Family Wealth Advisors, LLC
Item 2. Material Changes
In this Item, LiftPoint is required to discuss any material changes that have been made to the brochure since
the last annual amendment.
Item 9. The Firm has added Charles Schwab as an additional qualified custodian for client assets.
Item 17. The Firm updated its proxy voting practices to reflect changes in proxy voting authority,
including reliance on Independent Managers to exercise proxy voting authority for assets they manage.
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Item 3. Table of Contents
Item 2. Material Changes .............................................................................................................................................. 2
Item 3. Table of Contents .............................................................................................................................................. 3
Item 4. Advisory Business ............................................................................................................................................ 4
Item 5. Fees and Compensation ..................................................................................................................................... 6
Item 6. Performance-Based Fees and Side-by-Side Management ................................................................................. 9
Item 7. Types of Clients ................................................................................................................................................ 9
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss .......................................................................... 9
Item 9. Disciplinary Information ................................................................................................................................. 13
Item 10. Other Financial Industry Activities and Affiliations ..................................................................................... 13
Item 11. Code of Ethics ............................................................................................................................................... 13
Item 12. Brokerage Practices....................................................................................................................................... 14
Item 13. Review of Accounts ...................................................................................................................................... 18
Item 14. Client Referrals and Other Compensation ..................................................................................................... 18
Item 15. Custody ......................................................................................................................................................... 18
Item 16. Investment Discretion ................................................................................................................................... 19
Item 17. Voting Client Securities ................................................................................................................................ 19
Item 18. Financial Information .................................................................................................................................... 20
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Item 4. Advisory Business
LiftPoint offers a variety of advisory services, which include financial planning, consulting, and investment
management services. Prior to LiftPoint rendering any of the foregoing advisory services, clients are
required to enter into one or more written agreements with LiftPoint setting forth the relevant terms and
conditions of the advisory relationship (the “Advisory Agreement”).
LiftPoint filed for registration as an investment adviser in July 2025 and is owned by Timothy Starkey and
Evan Steinfeld. As of 12/31/2025, LiftPoint had $187,722,047 in assets under management, all of which
was managed on a discretionary basis.
While this brochure generally describes the business of LiftPoint, certain sections also discuss the activities
of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying
a similar status or performing similar functions), employees or other persons who provide investment advice
on LiftPoint’s behalf and are subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
LiftPoint offers clients a broad range of financial planning and consulting services, which include any or
all of the following functions:
Business Planning
Retirement Planning
Cash Flow Forecasting
Risk Management
Trust and Estate Planning
Charitable Giving
Financial Reporting
Distribution Planning
Investment Consulting
Tax Planning
Insurance Planning
Education Planning
While each of these services is available on a stand-alone basis, certain of them can also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below).
In performing these services, LiftPoint is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely
on such information. LiftPoint recommends certain clients engage the Firm for additional related services,
its Supervised Persons in their individual capacities as insurance agents and/or other professionals to
implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to
recommend that clients engage LiftPoint or its affiliates to provide (or continue to provide) additional
services for compensation, including investment management services. Clients retain absolute discretion
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over all decisions regarding implementation and are under no obligation to act upon any of the
recommendations made by LiftPoint under a financial planning or consulting engagement. Clients are
advised that it remains their responsibility to promptly notify the Firm of any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating or revising LiftPoint’s
recommendations and/or services.
Wealth Management Services
LiftPoint provides clients with wealth management services which include a broad range of financial
planning and consulting services as well as discretionary management of investment portfolios.
LiftPoint primarily allocates client assets among various independent investment managers (“Independent
Managers”) as well as exchange traded funds (“ETFs”) and structured notes (for a limited number of
appropriate clients) in accordance with their stated investment objectives. The Independent Managers will
typically invest client assets in global equities and fixed income.
Where appropriate, the Firm also provides advice about any type of legacy position or other investment
held in client portfolios, but clients should not assume that these assets are being continuously monitored
or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage LiftPoint to
manage and/or advise on certain investment products that are not maintained at their primary custodian,
such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans
and qualified tuition plans (i.e., 529 plans). In these situations, LiftPoint directs or recommends the
allocation of client assets among the various investment options available with the product. These assets
are generally maintained at the underwriting insurance company or the custodian designated by the
product’s provider.
LiftPoint tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives.
LiftPoint consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time
horizon, liquidity constraints and other related factors relevant to the management of their portfolios.
Clients are advised to promptly notify LiftPoint if there are changes in their financial situation or if they
wish to place any limitations on the management of their portfolios. Clients can impose reasonable
restrictions or mandates on the management of their accounts if LiftPoint determines, in its sole discretion,
the conditions would not materially impact the performance of a management strategy or prove overly
burdensome to the Firm’s management efforts.
Use of Independent Managers
As mentioned above, LiftPoint primarily allocates client assets to Independent Managers to actively manage
a portion of its clients’ assets. The specific terms and conditions under which the Firm engages the
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Independent Manager for the client are set forth in a separate written agreement. That agreement can be
with the designated Independent Manager but is more commonly with a turnkey asset management program
(“Program”) platform such as Advyzon Investment Management, LLC (“AIM”) or others. In addition to
this brochure, clients will typically also get access to the written disclosure documents of the respective
Independent Managers engaged to manage their assets. You should read those documents carefully to be
sure you understand the Program.
LiftPoint evaluates a variety of information about Independent Managers, which includes the Independent
Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and
other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the
Independent Managers’ investment strategies, past performance and risk results in relation to its clients’
individual portfolio allocations and risk exposure. LiftPoint also takes into consideration each Independent
Manager’s management style, returns, reputation, financial strength, reporting, pricing and research
capabilities, among other factors.
LiftPoint continues to provide services relative to the discretionary selection of the Independent Managers.
On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent
Managers. LiftPoint seeks to ensure the Independent Managers’ strategies and target allocations remain
aligned with its clients’ investment objectives and overall best interests.
Item 5. Fees and Compensation
LiftPoint offers services on a fee basis, which includes fixed fees, as well as fees based upon assets under
management or advisement. Additionally, certain of the Firm’s Supervised Persons, in their individual
capacities, offer insurance products under a separate commission-based arrangement.
Financial Planning and Consulting Fees
LiftPoint charges a fixed fee for providing financial planning and consulting services under a stand-alone
engagement. These fees are negotiable, but range from $3,000 to $25,000, depending upon the scope and
complexity of the services and the professional rendering the financial planning and/or the consulting
services. If the client engages the Firm for additional investment advisory services, LiftPoint can offset all
or a portion of its fees for those services based upon the amount paid for the financial planning and/or
consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the
Advisory Agreement. LiftPoint requires one-half of the fee payable upon execution of the Advisory
Agreement. The outstanding balance is due upon delivery of the financial plan or completion of the agreed
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upon services. The Firm does not, however, solicit $1,200 or more in prepaid fees, six or more months in
advance of services rendered.
Investment Management Fees
LiftPoint offers investment management services for an annual fee based on the amount of assets under the
Firm’s management. This management fee varies in accordance with the following blended fee schedule:
PORTFOLIO VALUE
BASE FEE
First $999,999
Next $2,000,000
Next $2,000,000
Next $5,000,000
Next $15,000,000
Next $25,000,000
$50,000,000 and Above
1.10%
0.80%
0.70%
0.60%
0.50%
0.40%
Negotiable
The Firm can also negotiate a fixed annual rate in lieu of the above fee schedule. The annual fee is prorated
and charged quarterly, in advance, based upon the market value of the assets being managed by LiftPoint
on the last day of the previous billing period as determined by a party independent from the Firm (including
the client’s custodian or another third-party). If a valuation for private securities is not available through
the custodian, the Firm will typically rely on the valuation provided by the issuer. Because valuations may
only be provided periodically (including monthly, quarterly or even annually), the Firm can be billing on a
valuation that would be different if updated. That valuation can be higher or lower depending on the
increase or decrease in value of the private investment.
The Firm includes cash in a client’s account in determining the valuation for billing purposes. The Firm
may, in its sole discretion, not include cash in determining the fee, especially where a client has a high
percentage of cash for reasons other than the Firm's investment management decision.
If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee
payable with respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial
period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is
terminated, the fee for the final billing period is prorated through the effective date of the termination and
the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
held-away assets, accommodation accounts, alternative investments, etc.), LiftPoint can negotiate a fee rate
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that differs from the range set forth above. Clients are advised that a conflict of interest exists for the Firm
to recommend that clients engage LiftPoint for additional services for compensation, including rolling over
retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion
over all decisions regarding engaging the Firm and are under no obligation to act upon any of the
recommendations.
Fee Discretion
LiftPoint may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as
anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, pre-existing/legacy client relationship, account retention,
pro bono activities, or competitive purposes.
Additional Fees and Expenses
In addition to the advisory fees paid to LiftPoint, clients also incur certain charges imposed by other third
parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions
(collectively “Financial Institutions”). These additional charges include securities brokerage commissions,
transaction fees, custodial fees, fees attributable to alternative assets, fees charged by the Independent
Managers, margin and other borrowing costs, charges imposed directly by a mutual fund or ETF in a client’s
account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses),
deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other
fees and taxes on brokerage accounts and securities transactions. The Firm’s brokerage practices are
described at length in Item 12, below.
Direct Fee Debit
Clients provide LiftPoint and/or certain Independent Managers with the authority to directly debit their
accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified
custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed
to send statements to clients not less than quarterly detailing all account transactions, including any amounts
paid to LiftPoint.
Account Additions and Withdrawals
Clients can make additions to and withdrawals from their account at any time, subject to LiftPoint’s right
to terminate an account. Additions can be in cash or securities provided that the Firm reserves the right to
liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients
can withdraw account assets on notice to LiftPoint, subject to the usual and customary securities settlement
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procedures. However, the Firm designs its portfolios as long-term investments and the withdrawal of assets
may impair the achievement of a client’s investment objectives. LiftPoint may consult with its clients about
the options and implications of transferring securities. Clients are advised that when transferred securities
are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the
mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications.
Unmanaged Assets
From time to time, a Client may decide to hold certain securities or other property for which our Firm
does not provide investment advisory services ("Unmanaged Assets") in the account(s) held at the
Custodian or outside the Custodian. Unmanaged assets will be shown on LiftPoint reports as unmanaged
assets. It is the client’s sole responsibility to verify the accuracy of the Unmanaged status of any and all
investments in their accounts and to notify LiftPoint in writing of any corrections or adjustments that need
to be made. Our Firm will have no duty, responsibility or liability whatsoever with respect to these assets,
and therefore, our Firm will not charge an investment advisory fee. However, if you have an account that
solely contains Unmanaged Assets, the Custodian may charge an account maintenance fee as disclosed in
the Custodian account paperwork executed by the Client. In all cases, it is the clients sole responsibility
to monitor, manage, and transact all Unmanaged Assets (securities and/or accounts).
Item 6. Performance-Based Fees and Side-by-Side Management
LiftPoint does not provide any services for a performance-based fee (i.e., a fee based on a share of capital
gains or capital appreciation of a client’s assets).
Item 7. Types of Clients
LiftPoint offers services to individuals, trusts, estates, charitable organizations, corporations and other
business entities.
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Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
At the core of LiftPoint’s advisory practice is a fiduciary commitment: to act in the best interest of the
Firm’s clients with transparency, diligence, and integrity. LiftPoint’s standard of care is reinforced by a
thorough due diligence process, supported by independent research, collaborative planning, and deep
industry experience. Each client’s strategy is driven by how wealth can help achieve what is most important
to them.
In implementing its investment process, the Firm takes a manager-agnostic approach to investment
selection, meaning LiftPoint is not tied to any particular firm or investment platform. The Firm believes
this independence allows it to source what it considers best-in-class investment managers from across the
industry based on comprehensive qualitative and quantitative due diligence process.
LiftPoint’s wealth management framework is built around four core pillars:
1. Wealth Enhancement – The goal is to minimize the tax impact on clients’ investment returns while
ensuring the cash flow they need.
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2. Wealth Protection – this includes all concerns about protecting the clients’ wealth against catastrophic
loss, potential creditors, litigants, children’s spouses and potential ex-spouses.
3. Wealth Transfer – this is about finding and facilitating the most tax-efficient way to pass assets to a
spouse and succeeding generations in ways that meet the client’s wishes.
4. Charitable Giving – this encompasses all issues related to fulfilling the client’s charitable goals in the
most impactful way possible. It can often support efforts in other areas of concern, including taxes.
The Firm’s process begins with a deep understanding of the client’s financial picture, followed by tailored
planning, implementation, and continuous review. LiftPoint works in coordination with tax professionals,
estate attorneys, and insurance experts to integrate the aspects of the client's financial life into one cohesive
strategy.
The Firm believes this structure allows it to act not only as advisors but as stewards—helping families
grow, protect, and purposefully use their wealth across generations, with independence and accountability.
Risk of Loss
The following list of risk factors does not purport to be a complete enumeration or explanation of the risks
involved with respect to the Firm’s investment management activities. Clients should consult with their
legal, tax, and other advisors before engaging the Firm to provide investment management services on their
behalf.
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly. The profitability of a significant portion of LiftPoint’s recommendations and/or investment
decisions may depend to a great extent upon correctly assessing the future course of price movements of
stocks, bonds and other asset classes. In addition, investments may be adversely affected by financial
markets and economic conditions throughout the world. There can be no assurance that LiftPoint will be
able to predict these price movements accurately or capitalize on any such assumptions.
Volatility Risks
The prices and values of investments can be highly volatile, and are influenced by, among other things,
interest rates, general economic conditions, the condition of the financial markets, the financial condition
of the issuers of such assets, changing supply and demand relationships, and programs and policies of
governments.
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Cash Management Risks
The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of
investments, during which time an advisory account may be prevented from achieving its investment
objective.
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF
shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for
a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily
per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption
fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual
NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a
mutual fund’s shares may differ from the NAV during periods of market volatility, which may, among other
factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at
least once daily for index-based ETFs and potentially more frequently for actively managed ETFs.
However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata
NAV. There is also no guarantee that an active secondary market for such shares will develop or continue
to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares
or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a
shareholder may have no way to dispose of such shares.
Finally, some mutual funds and ETFs may have lock-up periods that restrict an investor from selling their
position for a period of time. Other mutual funds and ETFs could also have early redemption fees that are
taken if the investor sells their position before a certain amount of time.
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Interval Fund Risks
Where suitable, our Firm may utilize interval funds in client portfolios. An interval fund is a non-
traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding
shares from shareholders. Investments in an interval fund involve additional risk, including lack of
liquidity and restrictions on withdrawals at the fund sponsor’s sole discretion. During any time periods
outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the
interval fund. There is no assurance that an investor will be able to tender shares when or in the amount
desired. There can also be situations where an interval fund has a limited amount of capacity to
repurchase shares and may not be able to fulfill all purchase orders. In addition, the eventual sale price for
the interval fund could be less than the interval fund value on the date that the sale was requested. While
an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that
investors may sell their shares at any given time or in the desired amount. As interval funds can expose
investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment.
Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus,
there is no secondary market for the fund's shares. Because these types of investments involve certain
additional risk, these funds will only be utilized when consistent with a client's investment objectives,
individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided
where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the
investment. The fund sponsor determines the fund price which investors will transact at based solely on
its internal policies and procedures for valuing the non-traded assets withing the fund. There can be no
assurance that an interval fund investment will prove profitable or successful. In light of these enhanced
risks, a client may direct LiftPoint, in writing, not to employ any or all such strategies for the client's
account. Certain Traded Interval Funds can be purchased by LiftPoint directly with the Client’s custodian
without any prior authorization from the client. In these cases, LiftPoint will purchase these interval funds
on a discretionary basis only when it deems the investments to be suitable for the client. In other cases,
certain Non-Traded Interval Funds required the client to execute fund documents in order to invest. In
these situations, LiftPoint will not be able to purchase the Non-Traded Interval Funds on a discretionary
basis. Both Traded and Non-Traded Interval Funds are subject to all of the risks and limitations outlined
above.
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Alternative Investments
Investments classified as "alternative investments" may include a broad range of underlying assets
including, but not limited to, hedge funds, managed futures funds, long-short equity funds, private equity,
venture capital, and registered, publicly traded securities. Alternative investments are speculative, not
suitable for all clients and intended for only experienced and sophisticated investors who are willing to
bear the high risk of the investment, which can include: loss of all or a substantial portion of the
investment due to leveraging, short-selling, or other speculative investment practices; lack of liquidity in
that there may be no secondary market for the fund and none expected to develop; volatility of returns;
potential for restrictions on transferring interest in the fund; potential lack of diversification and resulting
higher risk due to concentration of trading authority with a single advisor; absence of information
regarding valuations and pricing; potential for delays in tax reporting; less regulation and typically higher
fees than other investment options such as mutual funds. The SEC may require investors be accredited to
invest in these more speculative alternative investments. Investing in a fund that concentrates its
investments in a few holdings may involve heightened risk and result in greater price volatility.
Use of Independent Managers
As stated above, LiftPoint selects certain Independent Managers to manage a portion of its clients’ assets.
In these situations, LiftPoint continues to conduct ongoing due diligence of such managers, but such
recommendations rely to a great extent on the Independent Managers’ ability to successfully implement
their investment strategies. In addition, LiftPoint does not have the ability to supervise the Independent
Managers on a day-to-day basis.
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Structured Products Risks
A structured product, also known as a market-linked product, is generally a pre-packaged investment
strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities,
debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually
issued by investment banks or affiliates thereof. They have a fixed maturity, and have two components: a
note and a derivative. The derivative component is often an option. The note provides for periodic interest
payments to the investor at a predetermined rate, and the derivative component provides for the payment at
maturity. Some products use the derivative component as a put option written by the investor that gives the
buyer of the put option the right to sell to the investor the security or securities at a predetermined price.
Other products use the derivative component to provide for a call option written by the investor that gives
the buyer of the call option the right to buy the security or securities from the investor at a predetermined
price. A feature of some structured products is a "principal guarantee" function, which offers protection of
principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation
insured; they may only be insured by the issuer, and thus have the potential for loss of principal in the case
of a liquidity crisis, or other solvency problems with the issuing company. Investing in structured products
involves a number of risks including but not limited to: fluctuations in the price, level or yield of underlying
instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on
participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer;
conflicts of interest; and, other events that are difficult to predict.
Concentration Risks
The risk of amplified losses that may occur from having a large portion of your holdings in a particular
investment, asset class or market segment relative to your overall portfolio.
Cyber Security
With the increased use of technologies such as the internet to conduct business, the Firm and other service
providers used by the Firm, of as well as the underlying investments made by clients are susceptible to
operational, information security and related risks. In general, cyber incidents can result from deliberate
attacks or unintentional events and may arise from external or internal sources. Cyber incidents have the
ability to cause disruptions and impact business operations, potentially resulting in financial losses, the
release of investor information or confidential business information, interference with the ability to
calculate the value of client investments, destruction to equipment and systems, violations of applicable
privacy and other laws, regulatory fines or penalties, reputation damage, or additional compliance costs.
The Firm will seek to implement safeguards to protect clients against cyber attacks. However, there can be
no assurance that the Firm will be successful in preventing the occurrence of cyber attacks or mitigating
the impact of cyber attacks.
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Artificial Intelligence
Certain service providers utilized by the Firm to service client accounts have artificial intelligence
components, such as our client relationship management system that utilizes artificial intelligence to
summarize client meeting notes. The use of artificial intelligence and machine learning includes increased
risk of data inaccuracies and security vulnerabilities. Due to the rapid advancement of machine learning
technologies, future risks related to artificial intelligence are unpredictable. As a measure to mitigate these
risks to our clients, our Firm performs periodic due diligence of our service providers for assurance that
the service providers have appropriate controls in place to protect our clients’ information and to limit
data inaccuracies when artificial intelligence is used by the service provider.
Use of Margin
There may be times when a client decides to use margin in their account. Use of margin in an investment
advisory account can increase a client’s asset-based advisory fee. If margin is used to purchase additional
securities, for instance, the total value of eligible account assets (to which the LiftPoint advisory fee is
applied) will also increase. Notably, the opportunity to increase assets via margin debt presents a
potential conflict of interest for LiftPoint. We recognize that margin debt is not suitable for all investors.
It is our practice to recommend that clients utilize such financing in a prudent manner (if at all). Buying
securities on margin also subjects clients to additional costs and risks that should be carefully considered
before opening a margin account.
Interest Rate Risks
Interest rates may fluctuate significantly, causing price volatility with respect to securities or instruments
held by clients.
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Item 9. Disciplinary Information
LiftPoint has not been involved in any legal or disciplinary events that are material to a client’s evaluation
of its advisory business or the integrity of its management.
Item 10. Other Financial Industry Activities and Affiliations
This item requires investment advisers to disclose certain financial industry activities and affiliations.
Licensed Insurance Agents
A number of the Firm’s Supervised Persons are licensed insurance agents and offer certain insurance
products on a fully-disclosed commissionable basis. A conflict of interest exists to the extent that LiftPoint
recommends the purchase of insurance products where its Supervised Persons are entitled to insurance
commissions or other additional compensation. The Firm has procedures in place whereby it seeks to
ensure that all recommendations are made in its clients’ best interest regardless of any such affiliations.
Item 11. Code of Ethics
LiftPoint has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that
sets forth the standards of conduct expected of its Supervised Persons. LiftPoint’s Code of Ethics contains
written policies reasonably designed to prevent certain unlawful practices such as the use of material non-
public information by the Firm or any of its Supervised Persons and the trading by the same of securities
ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of LiftPoint’s personnel to report their personal securities holdings
and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited
offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also
recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and
procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently
broad markets to permit transactions by certain personnel to be completed without any appreciable impact
on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the
policies stated below.
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no
Supervised Person with access to this information may knowingly effect for themselves or for their
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immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that
security unless:
•
the transaction has been completed;
•
the transaction for the Supervised Person is completed as part of a batch trade with clients; or
•
a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii)
money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements and other high quality short-term debt instruments, including repurchase
agreements; (iii) shares issued by money market funds; and iv) shares issued by other unaffiliated open-end
mutual funds.
Clients and prospective clients may contact LiftPoint to request a copy of its Code of Ethics by contacting
the Firm at the phone number on the cover page of this brochure.
Item 12. Brokerage Practices
Recommendation of Broker-Dealers for Client Transactions
LiftPoint recommends that clients utilize the custody, brokerage and clearing services of National Financial
Services LLC, Fidelity Brokerage Services LLC (together with affiliates, “Fidelity”) or Charles Schwab
for investment management accounts. The final decision to custody assets with Fidelity or Charles
Schwab is at the discretion of the client, including those accounts under ERISA or IRA rules and
regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. LiftPoint is
independently owned and operated and not affiliated with Fidelity or Charles Schwab. Fidelity and
Charles Schwab provide LiftPoint with access to Independent Managers and institutional trading and
custody services, which are typically not available to retail investors.
Factors which LiftPoint considers in recommending Fidelity, Charles Schwabor any other broker-dealer
to clients include their respective financial strength, reputation, execution, pricing, research and service.
Fidelity and Charles Schwab enable the Firm to obtain many mutual funds without transaction charges
and other securities at nominal transaction charges. The commissions and/or transaction fees charged by
Fidelity or Charles Schwab may be higher or lower than those charged by other Financial Institutions.
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The commissions paid by LiftPoint’s clients to custodians comply with the Firm’s duty to obtain “best
execution.” Clients may pay commissions that are higher than another qualified Financial Institution might
charge to effect the same transaction where LiftPoint determines that the commissions are reasonable in
relation to the value of the brokerage and research services received. In seeking best execution, the
determinative factor is not the lowest possible cost, but whether the transaction represents the best
qualitative execution, taking into consideration the full range of a Financial Institution’s services, including
among others, the value of research provided, execution capability, commission rates and responsiveness.
LiftPoint seeks competitive rates but may not necessarily obtain the lowest possible commission rates for
client transactions.
LiftPoint periodically and systematically reviews its policies and procedures regarding its recommendation
of Financial Institutions in light of its duty to obtain best execution.
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Software and Support Provided by Financial Institutions
LiftPoint receives without cost from Custodian administrative support, brokerage support, computer
software, related systems support, research and other third-party support as further described below
(together "Support") which allow LiftPoint to better monitor client accounts maintained at the Custodian
and otherwise conduct its business. LiftPoint receives the Support without cost because the Firm renders
investment management services to clients that maintain assets at the Custodian. The Support is not
provided in connection with securities transactions of clients (i.e., not “soft dollars”). The Support
benefits LiftPoint, but not its clients directly. Clients should be aware that LiftPoint’s receipt of economic
benefits such as the Support from a broker-dealer creates a conflict of interest since these benefits will
influence the Firm’s choice of broker-dealer over another that does not furnish similar software, systems
support or services. In fulfilling its duties to its clients, LiftPoint endeavors at all times to put the interests
of its clients first and has determined that the recommendation of the Custodian is in the best interest of
clients and satisfies the Firm's duty to seek best execution.
Specifically, LiftPoint receives the following benefits from Custodians: i) receipt of duplicate client
confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its
institutional traders; iii) access to block trading which provides the ability to aggregate securities
transactions and then allocate the appropriate shares to client accounts; and iv) access to an electronic
communication network for client order entry and account information.
These services generally are available to independent investment advisors on an unsolicited basis, at no
charge to them so long as a certain amount of the advisor’s clients’ assets are maintained in accounts at
the Custodian. The Custodian’s services include brokerage services that are related to the execution of
securities transactions, custody, research, including that in the form of advice, analyses and reports, 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.
The Custodians also make available to the Firm other products and services that benefit the Firm but may
not benefit its clients’ accounts. These benefits may include national, regional or Firm specific
educational events organized and/or sponsored by the Custodian. Other potential benefits may include
occasional business
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entertainment of personnel of LiftPoint by the Custodian personnel, including meals, invitations to sporting
events and other forms of entertainment, some of which may accompany educational opportunities. Other
of these products and services assist LiftPoint in managing and administering clients’ accounts. These
include software and other technology (and related technological training) that provide access to client
account data (such as trade confirmations and account statements), facilitate trade execution (and
allocation of aggregated trade orders for multiple client accounts), provide research, pricing information
and other market data, facilitate payment of the Firm's fees from its clients’ accounts, and assist with
back-office training and support functions, recordkeeping and client reporting. Many of these services
generally may be used to service all or some substantial number of the Firm’s accounts, including accounts
not maintained at the Custodian. The Custodians also make available to LiftPoint other services intended
to help the Firm manage and further develop its business enterprise. These services may include
professional compliance, legal and business consulting, publications and conferences on practice
management, information technology, business succession, regulatory compliance, employee benefits
providers, human capital consultants, insurance and marketing. In addition, the Custodian may make
available, arrange and/or pay vendors for these types of services rendered to the Firm by independent
third parties. The Custodian may discount or waive 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 the Firm. While, as a
fiduciary, LiftPoint endeavors to act in its clients’ best interests, the Firm's recommendation that clients
maintain their assets in accounts at the Custodian may be based in part on the benefits received and not
solely on the nature, cost or quality of custody and brokerage services provided by the Custodian, which
creates a conflict of interest.
Brokerage for Client Referrals
LiftPoint does not consider, in selecting or recommending broker-dealers, whether the Firm receives client
referrals from the Financial Institutions or other third party.
Directed Brokerage
The client may direct LiftPoint in writing to use a particular Financial Institution to execute some or all
transactions for the client. In that case, the client will negotiate terms and arrangements for the account
with that Financial Institution and the Firm will not seek better execution services or prices from other
Financial Institutions or be able to “batch” client transactions for execution through other Financial
Institutions with orders for other accounts managed by LiftPoint (as described above). As a result, the
client may pay higher commissions or other transaction costs, greater spreads or may receive less favorable
net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best
execution, LiftPoint may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such
directed brokerage arrangements would result in additional operational difficulties such as an inability to
access Independent Managers.
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Trade Aggregation
Transactions for each client will be effected independently, unless LiftPoint, the Independent Manager
and/or the TAMP decides to purchase or sell the same securities for several clients at approximately the
same time. LiftPoint, the Independent Manager and/or the TAMP may (but are not obligated to) combine
or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate
equitably among the Firm’s clients differences in prices and commissions or other transaction costs that
might not have been obtained had such orders been placed independently. Under this procedure,
transactions will be averaged as to price and allocated among LiftPoint’s clients pro rata to the purchase
and sale orders placed for each client on any given day. To the extent that the Firm, the Independent
Manager and/or the TAMP determine to aggregate client orders for the purchase or sale of securities,
including securities in which LiftPoint’s Supervised Persons may invest, the Firm, the Independent
Manager and/or the TAMP does so in accordance with applicable rules promulgated under the Advisers
Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. Neither
the Firm, the Independent Manager nor the TAMP receive any additional compensation or remuneration as
a result of the aggregation.
In the event that the Firm, the Independent Manager and/or the TAMP determine that a prorated allocation
is not appropriate under the particular circumstances, the allocation will be made based upon other relevant
factors, which include: (i) when only a small percentage of the order is executed, shares may be allocated
to the account with the smallest order or the smallest position or to an account that is out of line with respect
to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be
given to one account when one account has limitations in its investment guidelines which prohibit it from
purchasing other securities which are expected to produce similar investment results and can be purchased
by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an
allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an
account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to
accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de
minimis allocation in one or more accounts, the Firm may exclude the account(s) from the allocation; the
transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a
small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts
on a random basis.
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Item 13. Review of Accounts
Account Reviews
LiftPoint monitors client portfolios on a continuous and ongoing basis and regular account reviews are
conducted on at least an annual basis. Such reviews are conducted by the Firm’s investment adviser
representatives. All investment advisory clients are encouraged to discuss their needs, goals and objectives
with LiftPoint and to keep the Firm informed of any changes thereto.
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements directly
from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise
requested, clients may also receive written or electronic reports from the Firm, AIM and/or an outside
service provider, which contain certain account and/or market-related information, such as an inventory of
account holdings or account performance. Clients should compare the account statements they receive
from the Firm, qualified custodians, AIM and/or an outside service provider with any documents or reports
they receive from LiftPoint or an outside service provider.
Item 14. Client Referrals and Other Compensation
Client Referrals
The Firm does not currently provide compensation to any third-party solicitors for client referrals.
Other Compensation
The Firm receives economic benefits from its recommended custodians. The benefits, conflicts of interest
and how they are addressed are discussed above in response to Item 12.
Item 15. Custody
LiftPoint is deemed to have custody of client funds and securities because the Firm is given the ability to
debit client accounts for payment of the Firm’s fees. As such, client funds and securities are maintained at
one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such
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qualified custodians will send account statements to clients at least once per calendar quarter that typically
detail any transactions in such account for the relevant period.
In addition, as discussed in Item 13, LiftPoint will also send, or otherwise make available, periodic
supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial
Institutions and compare them to those received from LiftPoint. Any other custody disclosures can be
found in the Firm’s Form ADV Part 1.
Item 16. Investment Discretion
LiftPoint is given the authority to exercise discretion on behalf of clients. LiftPoint is considered to exercise
investment discretion over a client’s account if it can effect and/or direct transactions in client accounts
without first seeking their consent. LiftPoint is given this authority through a power-of-attorney included
in the agreement between LiftPoint and the client. Clients may request a limitation on this authority (such
as certain securities not to be bought or sold). LiftPoint takes discretion over the following activities:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold;
• When transactions are made; and
• The Independent Managers to be hired or fired.
Item 17. Voting Client Securities
Our Firm will not vote proxies on your behalf. The Firm will rely on the Independent Managers to vote
proxies since they are making the decisions to buy, hold or sell those securities. In addition, the Firm will
not vote proxies for assets held in accounts that are excluded from management. Independent Managers
vote proxies in accordance with their own proxy voting policies and procedures. We do not act with
respect to any securities or other investments that become the subject of any legal proceedings, including
bankruptcies. Clients can contact our office with questions about a particular proxy solicitation by phone
at (862) 412-8862.
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Item 18. Financial Information
LiftPoint is not required to disclose any financial information listed in the instructions to Item 18
because:
• The Firm does not require or solicit the prepayment of more than $1,200 in
fees six months or more in advance of services rendered;
• The Firm does not have a financial condition that is reasonably likely to
impair its ability to meet contractual commitments to clients; and
• The Firm has not been the subject of a bankruptcy petition at any time during the past ten
years.
Privacy Policy
Our Firm collects nonpublic personal information about Clients from information provided on
applications or other forms, as well as from information regarding Client transactions with our
Firm, our affiliates, or others. In accordance with Regulation S-P, our Firm does not disclose any
nonpublic personal information about current or former Clients to third parties, except as
permitted or required by law, or as necessary to service Client accounts. Access to Client
information is restricted to Firm personnel who require such information to provide investment
advisory services. Our Firm maintains physical, electronic, and procedural safeguards designed to
protect Client information in compliance with federal standards and Regulation S-P. Our Firm
provides a copy of its Privacy Policy to Clients at the time of account opening, upon request, and
annually if the Policy is amended.
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