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ITEM 1 – COVER PAGE
SEC FORM ADV PART 2A
“Brochure”
LongView Wealth Management, Inc.
5605 Glenridge Drive, Suite 300
Atlanta, GA 30342
P: 404-843-3100
www.LongViewWealthManagement.com
February 25, 2026
This Brochure provides information about the qualifications and business practices of LongView
Wealth Management, Inc. If you have any questions about the contents of this Brochure, please
contact us by phone at 404-843-3100 or send an email to jhayes@lvwm.com. The information in
this Brochure has not been approved or verified by the United States Securities and Exchange
Commission (“SEC”) or by any state securities authority.
Additional information about LongView Wealth Management also is available on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for LongView Wealth
Management is 136214. Any references to LongView Wealth Management as a registered
investment adviser or its related persons as registered investment advisory representatives does
not imply a certain level of skill or training.
LongView Wealth Management
ITEM 2 - MATERIAL CHANGES
The Material Changes section of this brochure will be updated annually or when material changes occur
since the previous release of the Firm Brochure. Each year, we will ensure that you receive a summary
of any material changes to this and subsequent brochures by April 30th. This Brochure contains updated
information about LongView’s business since our last annual filing in March of 2025. We have provided
updates on our business and enhanced disclosures regarding the following items:
There have been no material changes to the firm disclosure document.
LongView will further provide you with a new Brochure as necessary based on changes or new
information, at any time, without charge. Currently, LongView’s Brochure may be requested by
contacting Mr. John Hayes, Chief Compliance Officer at (404) 843-3100 or jhayes@lvwm.com.
information about LongView
is also available via
the SEC’s web
Additional
site
www.adviserinfo.sec.gov . The searchable IARD/CRD number for LongView is 136214. The SEC’s web
site also provides information about any persons affiliated with LongView who are registered, or are
required to be registered, as investment adviser representatives of LongView.
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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...................................................................................... 8
ITEM 6 – PERFORMANCE –BASED FEES AND SIDE BY SIDE MANAGEMENT .............. 12
ITEM 7 – TYPES OF CLIENTS.................................................................................................. 12
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 12
ITEM 9 - DISCIPLINARY INFORMATION.............................................................................. 15
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............... 15
ITEM 11 – CODE OF ETHICS, PARTICIPATION OF INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING ....................................................................... 16
PROHIBITION ON USE OF INSIDER INFORMATION.......................................................... 17
ITEM 12 – BROKERAGE PRACTICES .................................................................................... 17
ITEM 13 - REVIEW OF ACCOUNTS ........................................................................................ 20
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION....................................... 21
ITEM 15 - CUSTODY.................................................................................................................. 21
ITEM 16 - INVESTMENT DISCRETION .................................................................................. 22
ITEM 17 – VOTING CLIENT SECURITIES ............................................................................. 22
ITEM 18 – FINANCIAL INFORMATION ................................................................................. 22
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ITEM 4 - ADVISORY BUSINESS
LongView Wealth Management, Inc. (hereinafter referred to as “LongView” or “we”) is an investment
advisory firm offering a variety of advisory services customized to your individual needs.
A. LongView was created in 1978 and is organized as a corporation. Larry Quinton Fisher is our
CEO and Jennifer Stewart is our President.
B. LongView offers the following advisory services. Each of the services is more fully described
below.
Initial and/or Periodic Financial Planning and Asset Allocation Services
• Asset Management
•
• Divorce Planning Services
• Analysis, Recommendation and Monitoring of Third-Party Managed Programs
C. LongView tailors the advisory services it offers to you to meet your individual needs. LongView
will ask for financial documents and have you complete a data gathering questionnaire which will
assist LongView with obtaining information about your financial situation and history.
Additionally, LongView will meet with you in person or virtually to discuss your goals and timelines
which will assist LongView in providing you with the services requested and pertinent to your
financial situation. Documents frequently requested will include but not limited to:
• Financial Statements
• Tax Records
• Cash flow analysis
• Other applicable financial information required by LongView in order to provide the
investment advisory services requested.
As of December 31, 2025, we managed approximately $1,153,580,840 of client assets under
management on a discretionary basis and $188,490 on a non-discretionary basis.
D. Asset Management Services
LongView offers continuous and ongoing asset management services based on a client’s individual
needs. LongView has arrangements with multiple broker/dealers to offer clients custodial services
and enable LongView to manage client’s assets. Please refer to the disclosures in Item 12 for
additional information about the relationship between LongView and the broker/dealers.
Accounts are managed by LongView on a discretionary or non-discretionary basis as agreed to
between the client and LongView. For the accounts managed on a discretionary basis, you will
give LongView the authority to determine the securities to be purchased and sold in the account
and alter the securities holdings from time to time, without prior consultation with you. Such
discretionary authority will be granted in the Client Agreement executed by you and LongView. If
you elect to have your accounts managed on a nondiscretionary basis, no changes will be made to
the allocation of your account without prior consultation with you and your expressed agreement.
LongView primarily uses open-ended mutual funds, ETF’s, stocks, and bonds.
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Clients are advised that transactions that occur in the account such as account reallocations and
rebalancing can trigger a taxable event for the client. However, note that LongView does not
provide tax advice and you are encouraged to consult a tax professional to evaluate any tax
implications.
E. LongView offers Advisory Services through the following programs:
• LongView Wealth Management Program Wrap
• LongView Wealth Management Program Non-Wrap
• LongView Wealth Management Financial Planning Engagement
• Divorce Planning
• Third-Party Money Managers
• Envestnet
• Frontier
LongView Wealth Management Program (Wrap)
LongView uses a wrap program which for a management fee will include LongView’s charge for
managing your account as well as ticket charges assessed by the custodian for transactions placed in
your account. Be aware the custodian does charge other fees which will not be covered by the wrap fee.
A full list of charges assessed by the custodian is available for your review provided by the custodian.
Typically, a wrap program is more suitable for clients who will have more frequent trading in securities
for which the custodian charges transaction fees. Custodial services are made available through Schwab
Institutional a division of Charles Schwab & Co., Inc. (“Schwab”) and National Financial Services LLC
or Fidelity Brokerage Services LLC (“Fidelity”), both of which are a registered broker/dealer and
member SIPC. Refer to Item 12 for additional information about Schwab and Fidelity.
LongView Wealth Management Program (Non-Wrap)
LongView uses a non-wrap program which for a management fee will only include LongView’s charge
for managing your account. Transaction fees in the form of ticket charges will be assessed by the
custodian for transactions placed in your account. Be aware the custodian does charge other fees and a
full list of charges assessed by the custodian is available for your review provided by the custodian.
Typically, a non-wrap program is more suitable for clients who will have more less frequent trading in
securities for which the custodian charges transaction fees. Custodial services are made available through
Schwab Institutional a division of Charles Schwab & Co., Inc. (“Schwab”) and National Financial
Services LLC or Fidelity Brokerage Services LLC (“Fidelity”), both of which are a registered
broker/dealer and member SIPC. Refer to Item 12 for additional information about Schwab and Fidelity.
Initial and/or Periodic Financial Planning and Asset Allocation Services
Initial and/or Periodic Financial Planning Advisory Services include the initial writing and formulation
of a personal financial plan. Services may be inclusive or limited, as agreed.
Periodic Financial Planning Advisory Services include the design, construction, asset allocation,
implementation, and monitoring of investment portfolios.
Miscellaneous Services include evaluation, analysis, and recommendations concerning specific, isolated
financial planning problems or investment decisions.
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LongView furnishes financial planning advice by way of incidental consultations. These consultations
can contain advice about securities and are not included in any manner described above.
Asset allocation services include the design, construction of an asset allocation and periodic monitoring of
the account. If LongView or your LongView Advisory Representative is not the representative of record
on the account, the client will be responsible for implementation of the designed asset allocation plan.
Further, unless duplicate statements and confirmation can be sent by the account custodian to LongView it
will be the client’s responsibility to provide at least quarterly statements to LongView. These services are
periodic and are not meant to be considered or held out as continuous and ongoing asset management
services. Advice will be provided upon the request of the client or as a result of a market event.
The above services can be combined. Our advice will be based on information, documents, and risk
guidelines which clients provide.
During the financial planning process, LongView works with clients to define personal goals, evaluate
existing financial circumstances and develop coordinated strategies to meet financial objectives. The
client may, at his or her discretion, choose to implement the plan with LongView. Implementation of
the plan requires LongView to work closely with the client's attorney, accountant, banker, or other
trusted financial advisors. Finally, LongView can work with the client to review and update their plan
on a regular basis.
The Financial Plan includes written presentation of client objectives and goals, a summary of
assumptions used in preparing financial analyses, a summary of significant events occurring during the
planning period, a discussion addressing each of the client's objectives, and assessing his or her ability
to achieve each goal, and recommendations detailing the steps the clients must take to achieve the
financial objectives.
Financial analyses are devised in applicable areas of tax planning, budgeting, children's education,
retirement planning, insurance and disability protection, estate planning, investments and business
planning.
Financial planning services are based on the client’s financial situation at the time and are based on
financial information disclosed by the client to LongView. Clients are advised certain assumptions are
made with respect to interest and inflation rates and use of past trends and performance of the market
and economy. However, past performance is in no way an indication of future performance. LongView
cannot offer any guarantees or promises that client’s financial goals and objectives will be met. Further,
client must continue to review any plan and update the plan based upon changes in the client’s financial
situation, goals, or objectives or changes in the economy. Should client’s financial situation or
investment goals or objectives changes, clients must notify LongView promptly of these changes.
Once the client receives written recommendations, it is client’s decision alone to implement the
recommendations, either completely, in part, or not at all.
Divorce Planning (Consulting)
Certain Advisory Representatives of Long View offer divorce-consulting services. Services will include but will not
be limited to summary of income and expenses (pre and post-divorce), summary of present financial position
(community and separate property), options regarding division of property, projected net worth (post-divorce),
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projected cash flow (post-divorce), recommended financial plan, expert witness regarding financial matters, all
post-divorce services related to the divorce.
Third-Party Managed Programs
LongView and its Advisory Representative(s) provide asset allocation advice through various third-party
fund management programs, such as Envestnet and Frontier. Advisory Representative will assist the
client in selecting a suitable investment portfolio and asset allocation strategy that will be used by the
program sponsor to properly allocate the client’s assets in the investment portfolio. Advisory
Representative provide initial and ongoing client education concerning the asset allocation strategy
selected by client, explain rebalancing guidelines utilized with the investment allocation strategy selected
and meet with client periodically to discuss changes in client’s investment objectives and risk tolerance.
The investment portfolio will be created by the program sponsor, which typically determines the funds
included in the portfolio it creates, the specific asset allocations within each portfolio, and rebalances the
portfolio periodically. The program sponsor will periodically change the relative allocations among
funds in the portfolio.
The third party will generally determine the minimum investment amount for client participation.
Disclosure of the third-party manager’s minimum account requirements will be disclosed in the third-
party manager’s disclosure brochure.
Clients are advised that third-party managed programs can be more or less expensive than if the client
obtained services directly from the third-party manager or obtained services separately.
It is important to read the third-party manager’s Disclosure Brochure before entering into a third-party
program.
Held-Away Accounts
We use a third-party platform (Pontera) to facilitate management of held away assets such as defined
contribution plan participant accounts, with discretion. The platform allows us to avoid being considered
to have custody of Client funds since we do not have direct access to Client log-in credentials to affect
trades. We are not affiliated with the platform in any way and receive no compensation from them for
using their platform. A link will be provided to the Client allowing them to connect an account(s) to the
platform Once client account(s) is connected to the platform, Adviser will review the current account
allocations. When deemed necessary, Adviser will rebalance the account considering client investment
goals and risk tolerance, and any change in allocations will consider current economic and market trends.
The goal is to improve account performance over time and manage internal fees that harm account
performance. Client account(s) will be reviewed at least quarterly, and allocation changes will be made
as deemed necessary.
General Information
You are advised the investment recommendations and advice offered by LongView are not legal, tax or
accounting advice. You should coordinate and discuss the impact of financial advice with your attorney
and/or accountant. You are advised that it is necessary to inform LongView promptly with respect to
any changes in your financial situation and investment goals and objectives. Failure to notify LongView
of any such changes could result in investment recommendations not meeting your needs.
Advisory Representatives recommend to clients the use of various share classes of mutual funds
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including no transaction fee funds. This will create conflicts of interest as the IAR will be incentivized
to recommends funds which will not charge them a ticket charge for wrap accounts and is not necessarily
in your best interest. Generally, clients should select the lowest cost available share class for wrap
accounts. For Non-Wrap accounts a client should weigh the benefit of not paying a ticket charge with
the increased cost for the share class.
Clients are advised of the following:
1. Class I shares generally have lower internal expenses and no upfront fees. There may be minimums
to utilize this share class.
2. No Transaction fee funds typically have higher internal expenses that can outweigh the benefits of
not paying a ticket charge.
Disclosure of the costs and expenses of various share classes is contained in the prospectus. Clients
should read the prospectus prior to investing.
The cost to the client will vary depending on the type of share class of mutual funds purchased, amount
of trading, and amount of service requested by the client. Clients are advised that clients will continue
to pay internal expenses of the mutual fund even after the termination of the advisory agreement. It is
important to consider and evaluate the internal costs. Though internal costs are not evident on statements
and confirmations, such costs and expenses should be considered along with the advisory fee you pay
LongView, when determining your total cost of investing.
There is no assurance that the level of experience and service each individual IAR provides is uniform.
LongView clients can pay more or less for the same service due to the experience and time required to
complete plan and sophistication of its Financial Planner.
ITEM 5 - FEES AND COMPENSATION
Asset Management Services: LongView Wealth Management Wrap and Non-Wrap
Program
A. Fees are negotiable and are not based on a share of capital gains or capital appreciation of the
funds or any portion of the funds. Fees will vary from client-to-client and are detailed in the
Client Agreement provided to the client. Fees are determined by the Investment Advisor
Representative and agreed on by you the client. An IAR will use many factors to determine the
fee charged to include but not limited to the complexity of the services needed, time required
for completion, and the experience level of the IAR. Therefore, a client can pay more or less
than another client serviced by the same or another Advisory Representative.
Your Advisory Representative has an incentive in the advisory fee paid by the client since the
Advisory Representative will receive a portion of the advisory fee collected by LongView.
Your account balance will fluctuate throughout the quarter due to asset appreciation or depreciation
or account withdrawals and deposits, however these fluctuations will not affect your billing. For
accounts billed in advance billings are calculated based on the account value of the account on the
last day of the prior quarter. For accounts billed in arrears billings are calculated based on the account
value of the account on the last day of the quarter.
Your Advisory Representative may choose to aggregate a client’s household managed accounts
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together. This aggregation will increase the total managed assets and the higher amount will help
a client reach a breakpoint or participate in higher tiers which are generally charged a smaller
fee. Management Fees are charged in one of three ways.
Breakpoint fee – The fee is determined by a reducing fee schedule based on predetermined asset
ranges. The fee charged will be the fee for the corresponding range the assets fall into.
Tier fee – The fee is determined on a reducing schedule in which the assets are charged the value
in each tier for the portion of the assets that fit into each tier. So instead of only paying one fee at
the highest range the client will pay at each range as described below. The account balance is 2
million dollars.
Calculated Amount for $2,000,000.00
FROM
$0
$100,000.00
$250,000.00
$500,000.00
$1,000,000.00
TO
$100,000
$250,000
$500,000
$1,000,000
and higher
CLIENT FEE
1.75%
1.50%
1.25%
1.20%
1.00%
$100,000.00 x 1.75% = $1,750.00
$150,000.00 x 1.50% = $2,250.00
$250,000.00 x 1.25% = $3,125.00
$500,000.00 x 1.20% = $6,000.00
$1,000,000.00 x 1.00% = $10,000.00
$23,125.00 = blended rate of 1.16%
Flat Rate – The fee for flat rate is determined by multiplying the assets by the rate agreed upon.
Actual fees are negotiable and based upon the services requested by the client, the complexity of
the client’s situation, and the amount of time required to provide the services. Further, advisory
fees vary based on the IAR and their experience. Therefore, clients are advised that certain
Advisory Representatives of LongView charge more or less than others so the fee quoted to you
as the client will be more or less than other clients.
LongView can change the fee schedule upon 30-days prior written notice to you.
Advisory fees will generally be collected directly from your account, provided you have given
LongView written authorization. You will be provided with an account statement reflecting the
deduction of the advisory fee direct from the account custodian. If the account does not contain
sufficient funds to pay advisory fees, LongView has limited authority to sell or redeem securities
in sufficient amounts to pay advisory fees. You may reimburse the account for advisory fees paid
to LongView, except for ERISA and IRA accounts.
B. In addition to the advisory fees set forth above, there may also be account maintenance fees,
custodial fees, transaction fees, and retirement fees for maintaining their portfolio. LongView does
not share in any portion of these fees. However, clients participating in a wrap account where the
client pays one fee for asset management and transactional charges will not be assessed separate
transactions charges. Instead, the client will pay one all-inclusive fee that includes LongView’s
fee and LongView will pay any transaction fees. As noted elsewhere in this Brochure, this creates
a conflict of interest for LongView as it will have an incentive to limit transactions in wrap fee
accounts to no-transaction fee funds to reduce costs.
You will pay your proportionate share of the fund’s management and administrative fees and sales
charges as well as the mutual fund adviser’s fee of any mutual fund they purchase. Such advisory
fees are not shared with LongView and are compensation to the fund-manager.
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C. Advisory fees are charged on a quarterly basis in advance or in arrears, depending on the Advisory
Representative and as negotiated with the client. Quarterly periods can be on a calendar year basis
or every three months starting on cycle as agreed between client and Advisory Representative. If
a client relationship is established or closed during a quarterly period, the client may be charged a
prorated portion of the fee for the quarter. In cases where fees are charged in advance, the initial
fee will be based on the value of the account upon establishment and will be prorated based on the
number of days remaining in the quarterly period. In cases where the fee is charged in arrears, the
initial fee will be a prorated fee based on the number of days the account was under management
and based on the value of the account as of the last business day of the quarter. Thereafter the fees
will be calculated based on the value of the account on the last business day of the just completed
quarterly period.
A set-up fee not to exceed one percent (1%) of the initial account value may be charged. The set-
up fee will be billed in full along with the first quarter fee. The set-up fee is negotiable.
You can purchase the securities recommended by LongView directly or through other brokers or
agents not affiliated with LongView.
Termination Provisions
For the above services, client may terminate LongView’s engagement within five business days
following receipt of Part 2 of Form ADV and receive a full refund of all prepaid fees paid to
LongView. Thereafter, client may terminate upon LongView’s receipt of client’s written notice
to terminate and receive a pro rata portion of the prepaid advisory fee based upon the time
remaining under the client Agreement from the date of receipt of client’s written notice to
terminate to the end of the quarterly period. Clients who are paying in arrears will be charged a
prorated fee for the quarter up to the date of receipt of client’s written notice to terminate.
Termination Provisions
For the above services, client may terminate LongView’s engagement within five business days
following receipt of Part 2 of Form ADV and receive a full refund of all prepaid fees paid to
LongView. Thereafter, client may terminate upon LongView’s receipt of client’s written notice to
terminate and receive a pro rata portion of the prepaid advisory fee based upon the time remaining
under the client Agreement from the date of receipt of client’s written notice to terminate to the
end of the calendar quarter. Clients who are paying in arrears will be charged a prorated fee for the
quarter up to the date of receipt of client’s written notice to terminate.
Initial and/or Periodic Financial Planning and Asset Allocation Services
You are advised that fees for planning and asset allocation services are strictly for planning services.
Therefore, you will pay fees and/or commissions for additional services obtained such as asset
management or products purchased such as securities or insurance.
Fees are negotiable. Your fees will be dependent on several factors including time spent with LongView,
number of meetings, complexity of your situation, amount of research, services requested and staff
resources.
A - Initial Financial Planning and Periodic Financial Planning Services can be charged as follows: (a)
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minimum fees are $1,000 for inclusive planning and $500 for limited areas of concern and (b)
miscellaneous advice is up to $500 per planner hour billed monthly. Fixed fees will not exceed
$15,000. Actual fees are based upon the services requested by the client, the complexity of the
client’s situation, and the amount of time required to provide the services. Further, advisory fees
vary based on the Advisory Representative and their experience. Therefore, clients are advised that
certain Advisory Representatives of LongView charge more or less than the fee quoted to the client.
A fee payment schedule will be agreed upon with the client prior to execution of the client agreement
and initiation of the services. Client may be required to pay a deposit in the amount of ½ of the initial
advisory fee agreed upon by client upon execution of the client agreement. At presentation of the
financial plan client will be required to pay the remaining balance of the advisory fee. Advisory
representative may negotiate with the client that the remaining balance may be waived if client
implements recommendations with the Advisory Representative. Hourly fees are billed monthly in
arrears based on time spent.
B- Asset Allocation Services
Asset allocation services are charged based on one of the options (Option A or Option B) disclosed
below and selected by the client. The annual fee is determined and calculated as of the date of
execution of the agreement.
Option A – The annual fee will be determined based on a percentage of the value of the account for
which monitoring, and asset allocation services are being provided and divided by four. The fee is
paid quarterly in advance in equal installments. The annual fee will be adjusted each year based on
the value of the account on the anniversary date, which is the date of execution of the Agreement
between client and LongView or another date as agreed between LongView and the client.
From
To
$0
$250,000.01
$500,000.01
$1,000,000.01
$250,000
$500,000
$1,000,000
and higher
Maximum Client
Fee
1.50%
1.25%
1.00%
1.00%
Option B – Flat Fee
A flat fee not to exceed $15,000. Actual fees are based upon the services requested by the client, the
complexity of the client’s situation, and the amount of time required to provide the services. A flat
dollar fee in lieu of a percentage fee may be proposed where the client’s assets are expected to vary
greatly over the period of the agreement. A flat fee can be inclusive of periodic planning and asset
allocation services.
The fee will be payable every three months in advance in equal installments.
Termination Provisions
Client may terminate advisory services obtained from LongView, without penalty, upon written
notice within five (5) business days after entering into the advisory agreement with LongView.
Thereafter, client may terminate upon LongView’s receipt of client’s written notice to terminate and
receive a pro- rata portion of the advisory fee based upon the time remaining under the Client
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Agreement.
Third Party Managed Programs
LongView is compensated for its services as it relates to the Third-Party Managed Programs as follows:
Details of the fees, billing details and additional information about the program are disclosed in the Form
ADV Part 2A of the Third Party. Clients are encouraged to read these disclosures carefully prior to entering
into an advisory agreement.
Divorce Planning (Consulting)
Client agrees to pay LongView a retainer upon the execution of the Divorce Planning Services
Agreement. The retainer will be applied to the full and final fee incurred by the client. Generally, the
retainer is $2,500. Compensation to LongView will be at a rate up to four hundred ($400) dollars per
hour for Advisory Representative’s services and one hundred fifty ($150) dollars per hour for
administrative time. Hourly fees are negotiable. The fee includes any and all time spent by Advisory
Representative related to his or her divorce consultation services. Client will be billed monthly or
quarterly at LongView’s discretion commencing 30 days after the execution of the Divorce Planning
Services Agreement and/or payment of the retainer described above. Clients have the option to facilitate
payment by credit card. Any payments not received by LongView within 30 days of billing will accrue
interest at a rate of 12% per year. Client will also be responsible for all reasonable costs associated with
LongView’s and Advisory Representative’s representation.
The term of this Agreement will be for an initial period of one year. In the event, neither party gives the
other written notice within sixty (60) days of the expiration of said initial one year term, the Agreement
will be renewed for subsequent one year periods on the same terms. Client will be responsible for all
time spent by LongView on the provision of the services. Any refund of prepaid fees will be calculated
based on time spent multiplied by the hourly rate subtracted from the retainer.
ITEM 6 – PERFORMANCE –BASED FEES AND SIDE BY SIDE MANAGEMENT
This section is not applicable to LongView since LongView does not charge performance-based fees.
ITEM 7 – TYPES OF CLIENTS
LongView’s services are geared toward individuals, including high net worth (i.e. clients with a net worth
of $1,000,000), pension and profit-sharing plans, and corporations or other businesses. There is no
required minimum for clients.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
A. LongView conducts economic, fundamental and technical market analysis with the goal to
determine the market trends and uncover investment opportunities. Fundamental analysis
generally involves assessing a public company’s or security’s value based on factors such as sales,
assets, markets, management, products and services, earnings, and financial structure.
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Technical analysis generally involves studying trends and movements in a security’s price, trading
volume, and other market-related factors in an attempt to discern patterns.
LongView uses various research methods in conducting the analysis. It may use, among other
methods, review, study, and analysis of public company filings and company-sponsored
information such as press releases, presentations, product descriptions; attend meetings with public
company executives at industry conferences; conduct research on the target company’s customers,
suppliers, competitors, and partners; analysis of historical company and industry financial data and
others.
B. You are advised that investing in securities involves risk of loss, including the loss of principal.
Therefore, your participation in any of the management programs offered by LongView will
require you to be prepared to bear the risk of loss and fluctuating performance.
LongView does not represent, warrant or imply that the services or methods of analysis used by
LongView can or will predict future results, successfully identify market tops or bottoms, or
insulate you from losses due to major market corrections or crashes. Past performance is no
indication of future performance. No guarantees can be offered that your goals or objectives will
be achieved. Further, no promises or assumptions can be made that the advisory services offered
by LongView will provide a better return than other investment strategies.
All investment strategies have certain risks that are borne by the clients. LongView’s investment
approach keeps the risk of loss in mind. The following is intended to provide the client with a
summary of certain investment risks they may face, however, note that this list is not exhaustive:
1. Market Risk: Market risk involves the possibility that an investment’s current market value
will fall because of a general market decline, reducing the value of the investment regardless
of the operational success of the issuer’s operations or its financial condition.
2. Strategy Risk: The adviser’s investment strategies and/or investment techniques may not work
as intended.
3. Regulatory Risk: Legislative changes or court rulings may impact the value of investments, or
the securities’ claim on the issuer’s assets and finances.
4. Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar
value of your investments remains the same.
5. Cybersecurity Risks. These risks may include deliberate attacks or unintentional events and
are not limited to gaining unauthorized access to systems, and misappropriating assets or
sensitive information, such as personal identifiable information, corrupting data, or causing
operational disruption, including the denial-of-service attacks on websites. Cybersecurity
failures or breaches have the ability to cause disruptions and impact business operations,
potentially resulting in financial losses, the inability to transact business, violations of
applicable privacy and other laws.
6. Risk Associated with Specific Types of Securities. As noted, LongView primarily uses mutual
funds, but may also use stocks, bonds and ETFs.
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a. Mutual Funds and ETFs. When investing in an ETF or mutual fund, you will bear
additional expenses based on your pro rata share of the ETF’s or mutual fund’s
operating expenses. When a mutual fund is not fully invested and maintains a portion
of its portfolio in cash or cash equivalents, there is a risk that the market will begin to
rise and cause the mutual fund to miss capturing the full effect of changing market
conditions. Some mutual funds may use leverage as part of their investment strategy.
Using leverage can magnify a mutual fund’s potential for gain or loss and, therefore,
amplify the effects of market volatility on a mutual fund’s share price. A mutual fund
may be subject to the risk that its assets are invested in a particular sector or group of
sectors in the economy, and as a result, the value of the mutual fund may be adversely
impacted by events or developments in a sector or group of sectors.
ETFs are subject to market risk, including the possible loss of principal. ETFs trade
like a stock and the value of the ETF will fluctuate with the value of the underlying
securities. ETFs at times trade for more or less than their net asset value. ETFs will
have underlying investment strategy risks consistent with the underlying investments
in the ETFs’ portfolios. The types of investments held in ETFs may include but are not
limited to equities, commodities, bonds, real estate and international securities or
currencies. Due to their narrow focus, sector-based investments typically exhibit
greater volatility. There are special considerations associated with international
investing, including the risk of currency fluctuations and political and economic events.
Investing in emerging markets may involve greater risk and volatility than investing in
more developed countries. When investing in real estate companies, property values
can fall due to environmental, economic, or other reasons, and changes in interest rates
can negatively impact the performance. The risk of loss in trading commodities and
futures can be substantial. The high degree of leverage that is often obtainable in
commodity trading can work either for or against the performance of this type of
investment.
Common Stocks. The risks of investing in common stocks include: (i) stock market risk, which is the
risk that stock prices overall will decline (stock markets tend to move in cycles, with periods of rising
prices and periods of falling prices); (ii) Sector risk, which is the risk that significant problems will affect
a particular sector, or that returns from that sector will trail returns from the overall stock market (daily
fluctuations in specific market sectors are often more extreme than fluctuations in the overall market;
and (iii) Difficulty in identifying undervalued stocks (there are no assurances that such opportunities
will be successfully recognized or acquired).
Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by the Firm to
service client accounts have artificial intelligence components. 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, the 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.
Epidemics, Pandemics, Outbreaks of Disease and Public Health Issues. Our business activities could be
materially adversely affected by pandemics, epidemics and outbreaks of disease in Asia, Europe, North
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America and/or globally or regionally, such as COVID-19, Ebola, H1N1 flu, H7N9 flu, H5N1 flu,
Severe Acute Respiratory Syndrome (SARS), and/or other epidemics, pandemics, outbreaks of disease,
viruses and/or public health issues. Specifically, COVID-19 has spread (and is currently spreading)
rapidly around the world since its initial emergence in China in December 2019 and has severely
negatively affected (and may continue to materially adversely affect) the global economy and equity
markets (including, in particular, equity markets in Asia, Europe and the United States). Although the
long-term effects or consequences of COVID-19 and/or other epidemics, pandemics and outbreaks of
disease cannot currently be predicted, previous occurrences of other pandemics, epidemics and other
outbreaks of disease, such as H5N1 flu, H1N1 flu, SARS and the Spanish flu, had a material adverse
effect on the economies and markets of those countries and regions in which they were most prevalent.
Any occurrence or recurrence (or continued spread) of an outbreak of any kind of epidemic,
communicable disease or virus or major public health issue could cause a slowdown in the levels of
economic activity generally (or cause the global economy to enter into a recession or depression), which
would adversely affect the business, financial condition and operations of the Adviser. Should these or
other major public health issues, including pandemics, arise or spread farther (or continue to spread or
materially impact the day to day lives of persons around the globe), the Adviser could be adversely
affected by more stringent travel restrictions, additional limitations on the Adviser’s operations or
business and/or governmental actions limiting the movement of people between regions and other
activities or operations (or to otherwise stop the spread or continued spread of any disease or outbreak).
ITEM 9 - DISCIPLINARY INFORMATION
Neither LongView nor any of its supervised persons have been the subject of any legal or disciplinary
events that would be material to an evaluation of LongView or the integrity of LongView’s management.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
A. LongView’s investment advisor representatives may also be registered representatives of M.S.
Howells & Co., a registered broker/dealer, and Member of FINRA/SIPC. Clients are not
obligated to purchase or sell securities through the investment advisor representatives in these
separate capacities. However, if clients choose to implement the advice provided by Advisor
through its investment advisor representatives in their separate capacities as registered
representatives, M.S. Howells & Co. will be used, and commissions will be earned in addition to
any fees paid for advisory services.
B – C. LongView is an insurance agency and offers various insurance products. Should a client
participate in insurance products or services through LongView, commissions will be earned.
Clients are under no obligation to purchase insurance products or services through LongView.
The products through LongView may be more or less expensive than those products offered
through other insurance companies.
LongView attempts to mitigate the conflicts of interest with the potential receipt of commissions
if recommendations are implemented by developing and implementing compliance policies and
procedures, including the Code of Ethics described below, supervising and monitoring the
Advisory Representatives’ activities to ensure compliance with the applicable laws and
LongView’s policies. Further, you are encouraged to consult other professionals and may
implement recommendations through financial professionals. Furthermore, if your Investment
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Advisor Representative is a registered representative with M.S. Howells & Co., Registered
Representatives are subject to a supervisory structure at M.S. Howells & Co. for its securities
business.
LongView and its management persons are not actively engaged in any other business.
D. As stated under Item 4, Advisory Business above, LongView recommends other investment
advisers (i.e. third-party managers) and will receive a portion of the fee charged to you by the
investment adviser or will charge a fee in addition to the third-party managers. Since LongView
has an interest in the compensation this is considered a material conflict of interest. LongView
selects third party managers based on several criteria including cost, type of management, past
history, ability to meet a need and provide a unique service. Since the fee charged to you is based on
the value of your portfolio, all parties have an incentive to work toward performance goals and
objectives. Consequently, if the third-party manager does not adequately manage your account and
the value of your portfolio goes down, so does the third-party manager’s and LongView’s
compensation.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OF INTEREST IN
CLIENT TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
A. LongView has a fiduciary duty to you to act in your best interest and always place your interests
first and foremost. LongView takes its compliance and regulatory obligations seriously and
requires all staff to comply with such rules and regulations as well as LongView’s policies and
procedures. Further, LongView strives to handle your non-public information in such a way to
protect information from falling into hands that have no business reason to know such information
and provides you with LongView’s Privacy Policy. As such, LongView maintains a code of ethics
for its Advisory Representatives, supervised persons and staff (the “Code of Ethics”). The Code
of Ethics contains provisions for standards of business conduct that are designed to uphold
compliance with applicable laws and regulations; maintain integrity, honesty, loyalty, and good
faith; prevent improper conduct, eliminate or reduce conflicts of interest. The Code prohibits,
limits, restricts, or avoids insider trading, improper gifts, outside employment, political
contributions, and self-dealing... A copy of our Code of Ethics will be provided to you upon
request.
B. Neither LongView nor its advisory personnel recommend to clients or buys or sells for client
accounts any securities in which we have a material financial interest.
C. LongView and its advisory personnel buy or sell securities identical to those securities
recommended to you. Therefore, LongView and/or its advisory personnel have an interest or
position in certain securities that are also recommended and bought or sold to you. LongView and
its advisory personnel will not put their interests before your interest. LongView and its advisory
personnel may not trade ahead of you or trade in such a way to obtain a better price for themselves
than for you or other clients except when determined to be a de minimus amount. LongView uses
$25.00 will be used a threshold Longview has determined that
All advisory personnel is required to provide LongView with their and their immediate families’
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annul holdings reports and quarterly transactions reports which are reviewed by LongView to
ensure compliance with the applicable laws and regulations and LongView’s personal trading
policies and procedures.
You have the right to decline any investment recommendation. LongView and its advisory
personnel are required to conduct their securities and investment advisory business in accordance
with all applicable Federal and state securities regulations.
Prohibition on Use of Insider Information
LongView has also adopted policies and procedures to prevent the misuse of “insider” information (i.e.
material n, non-public information). A copy of such policies and procedures is available to any person
upon request.
ITEM 12 – BROKERAGE PRACTICES
Brokerage and custodial services are made available through Fidelity Brokerage Services LLC
or Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC. Each option has
unique benefits and conflicts in which your IAR will explain fully. LongView is independently owned
and operated and not affiliated with Schwab or Fidelity.
Longview does not maintain custody of your assets [that we manage/on which we advise],
although we may be deemed to have custody of your assets if you give us authority to withdraw assets
from your account (see Item 15—Custody, below). Your assets must be maintained in an account at a
“qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use either
Fidelity or Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, as the
qualified custodian. Fidelity or Schwab will hold your assets in a brokerage account and buy and sell
securities when [we/you] instruct them to. While we [recommend that you use Fidelity or Schwab as
custodian/broker, you will decide whether to do so and will open your account by entering into an
account agreement directly with them. Conflicts of interest associated with this arrangement are
described below as well as in Item 14 (Client referrals and other compensation). You should consider
these conflicts of interest when selecting your custodian. We do not open the account for you, although
we may assist you in doing so. [If you do not wish to place your assets with Fidelity or Schwab, then
we cannot manage your account.] [Not all advisors require their clients to use a particular broker-dealer
or other custodian selected by the advisor.] Even though your account is maintained at Cambridge or
Schwab, and we anticipate that most trades will be executed through that broker they select, we can still
use other brokers to execute trades for your account as described below (see “Your brokerage and
custody costs”).
How we select brokers/custodians
When we recommend a custodian/broker, to hold your assets and execute transactions that are
advantageous to you when compared with other available providers and their services, we take into
account a wide range of factors, including:
separate fee for custody)
• Combination of transaction execution services and asset custody services (generally without a
•
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests,
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bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs],
etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest rates, other fees,
etc.) and willingness to negotiate the prices
• Reputation, financial strength, security and stability
• Prior service to us and our clients
• Services delivered or paid for by Schwab
• Availability of other products and services that benefit us, as discussed below (see “Products and
services available to us from Schwab”)
Your brokerage and custody costs
Schwab:
If Schwab is selected by the client, Schwab generally does not charge you separately for
custody services but is compensated by charging you commissions or other fees on trades that it executes
or that settle into your Schwab account. Certain trades (for example, stocks and ETFs) do not incur
Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the
uninvested cash in your account in Schwab’s Cash Features Program. For some Envestnet accounts,
Schwab charges you a percentage of the dollar amount of assets in the account in lieu of commissions.
Schwab’s commission rates [and] asset-based fees applicable to our client accounts were negotiated
based on the total dollar amount of assets in accounts at Schwab. This commitment benefits you because
the overall [commission rates [and] asset-based fees] you pay are lower than they would be otherwise.
In addition to [commissions [and] asset-based fees], Schwab charges you a flat dollar amount as a “prime
broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where
the securities bought or the funds from the securities sold are deposited (settled) into your Schwab
account. These fees are in addition to the commissions or other compensation you pay the executing
broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most
trades for your account. We are not required to select the broker or dealer that charges the lowest
transaction cost, even if that broker provides execution quality comparable to other brokers or dealers.
Although we are not required to execute all trades through Schwab, we have determined that having
Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best
execution means the most favorable terms for a transaction based on all relevant factors, including those
listed above (see “How we select brokers/custodians above”). By using another broker or dealer you
may pay lower transaction costs. Products and services available to us from Schwab (Schwab Advisor
Services) is Schwab’s business serving independent investment advisory firms like us. They provide us
and our clients with access to their institutional brokerage services (trading, custody, reporting, and
related services), many of which are not typically available to Schwab retail customers. However, certain
retail investors may be able to get institutional brokerage services from Schwab without going through
us. Schwab also makes available various support services. Some of those services help us manage or
administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support
services are generally available on an unsolicited basis (we don’t have to request them) and at no charge
to us. Following is a more detailed description of Schwab’s support services:
Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of
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investment products, execution of securities transactions, and custody of client assets. The investment
products available through Schwab include some to which we might not otherwise have access or that
would require a significantly higher minimum initial investment by our clients. Schwab’s services
described in this paragraph generally benefit you and your account.
Services that do not directly benefit you. Schwab also makes available to us other products and services
that benefit us but do not directly benefit you or your account. These products and services assist us in
managing and administering our clients’ accounts and operating our firm. They include investment
research, both Schwab’s own and that of third parties. We use this research to service all or a substantial
number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment
research, Schwab also makes available software and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and account
statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us. Schwab also offers other services intended to help us manage
and
further develop our business enterprise. These services include:
• Educational conferences and events
• Consulting on technology and business needs
• Consulting on legal and compliance related needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing consulting and support
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to us. Schwab also discounts or waives its fees for some of these services or pays
all
or a part of a third party’s fees. Schwab also provides us with other benefits, such as occasional business
entertainment of our personnel. If you did not maintain your account with Schwab, we would be required
to pay for those services from our own resources.
LongView mitigates the conflicts of interest resulting from receiving these benefits by periodically
reviewing other options for custody and trade execution cost for our clients. Longview does this by
reviewing the cost for our clients as a whole and does not make any representation for any specific client
or account.
The availability of these services from Schwab benefits us because we do not have to produce or
purchase
them. We don’t have to pay for Schwab’s services. Schwab has also agreed to pay for certain technology,
research, marketing, and compliance consulting products and services on our behalf once the value of
our
clients’ assets in accounts at Schwab reaches certain thresholds. These services are not contingent upon
us committing any specific amount of business to Schwab in trading commissions or assets in custody.
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The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of
Schwab rather than making such a decision based exclusively on your interest in receiving the best value
in custody services and the most favorable execution of your transactions. This is a conflict of interest.
In some cases, the services that Schwab pays for are provided by affiliate of ours or by another party
that has some pecuniary, financial or other interests in us (or in which we have such an interest). This
creates an additional conflict of interest. We believe, however, that taken in the aggregate our
recommendation of Schwab as custodian and broker is in the best interests of our clients. Our selection
is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/
custodians”) and Schwab’s services that benefit only us.
Aggregated or Block Trade Policy
Due to the individual management of client accounts, we do not aggregate the purchase or sale of
securities for various client accounts. Generally, this will not affect the price a client obtains since
LongView’s business is primarily conducted in mutual funds and transactions where block trading has
no impact. However, to the degree a client's account contains securities which are purchased and sold in
an auctionable market the lack of block trading could affect the price the client receives. Therefore,
clients could pay as a result of LongView generally not participating in block transactions.
ITEM 13 - REVIEW OF ACCOUNTS
A.
If you are participating in the Asset Managements and Third Party Managed Programs you will be
invited to participate in a review not less than at least annually or as agreed by you and your
Advisory Representative. You may request more frequent reviews and may set thresholds for
triggering events that would cause a review to take place. Your Advisory Representative will
monitor for changes or shifts in the economy, changes to the management and structure of a mutual
fund or company in which your assets are invested, and market shifts and corrections.
Periodic Financial Planning and Asset Allocation Services reviews will be at a frequency as agreed
to between you and your Advisory Representative. You will be invited to participate in a review
not less than annually.
All other Planning Services will not receive regular reviews. However, the time and frequency of
the reviews is solely your decision. Other than the initial plan or analysis, there will be no other
reports issued.
The Advisory Representative selected by the client will conduct the review.
B. You must notify your Advisory Representative promptly of any changes to your financial goals,
objectives or financial situation as such changes may require him review the portfolio allocation
and make recommendations for changes.
C. Clients participating in managed account programs will be provided statements at least quarterly
directly from the account custodian. Additionally, you will receive confirmations of all transactions
occurring directly from the account custodian. You may request additional account summary
reports from LongView at any time. You should compare any report produced by LongView with
statements received from the account custodian. Should there be any discrepancy the account
custodian’s report will prevail.
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ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
Investment product vendors recommended by LongView can provide monetary and non-monetary
assistance with client events, provide educational tools and resources. LongView does not select
products as a result of any monetary or non-monetary assistance. LongView’s due diligence of a product
does not take into consideration any assistance it may receive. However, the receipt of any form of
compensation, either directly or indirectly, is considered a conflict of interest.
We also, receive an economic benefit from Schwab in the form of the support products and services it
makes available to us and other independent investment advisors whose clients maintain their accounts
at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we
would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a
certain size. You do not pay more for assets maintained at Schwab as a result of these arrangements.
However, we benefit from the arrangement because the cost of these services would otherwise be borne
directly by us. You should consider these conflicts of interest when selecting a custodian. The products
and services provided by Schwab, how they benefit us, and the related conflicts of interest are described
above. LongView mitigates this conflict of interest by supervising the activities of the Advisory
Representatives, reviewing the investment recommendations provided to the clients, implementing
policies and procedures, including the Code of Ethics. We also encourage you to discuss any
recommendations provided by your Advisory Representative with another financial professional if you
have any concerns about the appropriateness of the recommendation based on your financial situation.
Our firm may engage in promoter arrangements for client referrals. These individual promoters offer our
services to the public. The Firm pays a referral fee to the promoter based on a portion of the
management fees charged by the Firm and memorialized in a written agreement (“Promoter
Agreement”). In all cases, the Firm will comply with the cash solicitation rules established by the SEC,
state regulators and the client disclosure requirements. If a referred prospective client enters into an
investment advisory agreement with the Firm, a referral fee is paid to the referring party. The referral
relationship will not result in clients being charged any fees over and above the normal advisory fees
charged for the advisory services provided. The Firm will pay the promoter their share of the total fee.
The Promoter Agreement requires that the promoter be appropriately registered under federal and state
securities laws where applicable. Clients receive all related agreements and disclosures prior to or at the
time of entering into an Investment Advisory Agreement with the Firm.
ITEM 15 - CUSTODY
All client accounts are held at qualified custodians. LongView does not take physical custody of your
funds or securities. LongView may be deemed to have constructive custody if a client has a standing
letter of authorization (SLOA) to transfer funds or securities to a third party and LongView has the
ability to direct transfers, change the amount, and/or the timing of the transfer.
Under the applicable regulations, we are deemed to have custody of your assets if, for example, you
authorize us to instruct your account custodian to deduct our advisory fees directly from your account
or if you grant us authority to move your money to another person’s account. Your custodian maintains
physical custody of your assets. You will receive account statements directly from your account
custodian at least quarterly. They will be sent to the email or postal mailing address you provided. You
should carefully review those statements promptly when you receive them.
Standing Letters of Authorization
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Some clients may execute limited powers of attorney or other standing letters of authorization that
permit the firm to transfer money from their account with the client’s independent qualified Custodian
to third-parties. This authorization to direct the Custodian may be deemed to cause our firm to exercise
limited custody over your funds or securities and for regulatory reporting purposes, we are required to
keep track of the number of clients and accounts for which we may have this ability. We do not have
physical custody of any of your funds and/or securities. Your funds and securities will be held with a
bank, broker-dealer, or other independent, qualified custodian. You will receive account statements from
the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account
statements from your custodian(s) will indicate any transfers that may have taken place within your
account(s) each billing period. You should carefully review account statements for accuracy.
ITEM 16 - INVESTMENT DISCRETION
You may grant LongView authorization to manage your account on a discretionary basis. Discretionary
authority will give LongView authority to buy, sell, exchange, convert securities in your managed
accounts. You will grant such authority to LongView by execution of the client agreement. You may
terminate discretionary authorization at any time by providing a written notice to LongView.
Additionally, you are advised that:
1) You may set parameters with respect to when account should be rebalanced and set trading
restrictions or limitations.
2) Your written consent is required to establish any mutual fund, variable annuity, or brokerage
account.
3) LongView will not have the ability to withdraw your funds or securities from the account with
the exception of the deduction of LongView’s advisory fees from the account, or if you have
authorized automatic deductions.
ITEM 17 – VOTING CLIENT SECURITIES
LongView does not vote your securities. Unless you suppress proxies, securities proxies will be sent
directly to you by the account custodian or transfer agent. You may contact LongView if you have
questions on how to vote the proxies, however, you will be the one to make and execute the voting
decision.
ITEM 18 – FINANCIAL INFORMATION
LongView has discretionary authority or custody of Client funds or securities. There is no financial
condition that is reasonably likely to occur that would impair LongView’s ability to meet contractual
commitments to Clients. LongView has not been the subject of a bankruptcy petition during the past
ten years.
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