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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
July 2025
732 S. 6th St. #4119
Las Vegas, NV 89101
Firm Contact:
Clifton Yasutomi
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Mission
Financial Group, LLC. If clients have any questions about the contents of this brochure, please contact
us at clifton@missionfinancial.com. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any State Securities
Authority. Additional information about our firm is also available on the SEC’s website at
www.adviserinfo.sec.gov by searching CRD #311876.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Mission Financial Group, LLC is required to notify clients of any information that has changed since
the last annual update of the Firm Brochure (“Brochure”) that may be important to them. Clients can
request a full copy of our Brochure or contact us with any questions that they may have about the
changes.
Since our last annual amendment filing, we have the following material changes to report:
• We now offer non-wrap Comprehensive Portfolio Management.
• We have added the use of third party managed accounts. Please see Item 5 below for further
details.
• We have added language to Item 14 below describing our receipt of compensation from third-
parties sponsoring our client events.
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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 & Compensation ................................................................................................................. 6
Item 6: Performance-Based Fees & Side-By-Side Management ....................................................... 8
Item 7: Types of Clients & Account Requirements ............................................................................. 9
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................ 9
Item 9: Disciplinary Information ......................................................................................................... 19
Item 10: Other Financial Industry Activities & Affiliations ............................................................ 19
Item 11: Code of Ethics, Participation or Interest in ........................................................................ 19
Client Transactions & Personal Trading ............................................................................................ 19
Item 12: Brokerage Practices ............................................................................................................... 20
Item 13: Review of Accounts or Financial Plans ............................................................................... 23
Item 14: Client Referrals & Other Compensation ............................................................................. 23
Item 15: Custody ...................................................................................................................................... 24
Item 16: Investment Discretion............................................................................................................ 25
Item 17: Voting Client Securities .......................................................................................................... 25
Item 18: Financial Information ............................................................................................................ 25
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Item 4: Advisory Business
Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company formed under the laws of the
State of Hawaii in 2018 and has been in business as an investment adviser since 2020. Our firm is
owned by Clifton Yasutomi and Nick Abbott.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Types of Advisory Services Offered
Comprehensive Portfolio Management
As part of our Comprehensive Portfolio Management service clients will be provided asset
management and financial planning or consulting services. This service is designed to assist clients
in meeting their financial goals through the use of a financial plan or consultation. Our firm conducts
client meetings to understand their current financial situation, existing resources, financial goals, and
tolerance for risk. Based on what is learned, an investment approach is presented to the client,
consisting of individual stocks, bonds, ETFs, options, mutual funds and other public and private
securities or investments. Once the appropriate portfolio has been determined, portfolios are
continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual
needs, stated goals and objectives. Upon client request, our firm provides a summary of observations
and recommendations for the planning or consulting aspects of this service.
Asset Management for Held Away Accounts:
Our firm has entered into a service agreement with Pontera to provide asset management services for
accounts held away from Fidelity Brokerage Services. Through this, we are able to create a portfolio,
consisting of the securities/investment opportunities available depending on the type of held away
account being managed by our firm. The Pontera 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.
The client’s individual investment strategy is tailored to their specific needs and may include some or all
of the securities made available. Portfolios will be designed to meet a particular investment goal,
determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been
determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
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Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Clients will typically be provided with a detailed Investment Policy Statement and a
Written Financial planning calendar. Financial consultations are not typically accompanied by a
written summary of observations and recommendations, as the process is less formal than the
planning service. Assuming that all the information and documents requested from the client are
provided promptly, plans or consultations are typically completed within 6 months of the client
signing a contract with our firm.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
•
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
•
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance on
allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the
provision of services described therein.
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Tailoring of Advisory Services
Our firm offers individualized investment advice to our Wrap Comprehensive Portfolio Management
clients. General investment advice will be offered to our Financial Planning & Consulting and
Retirement Plan Consulting, clients.
Each Wrap Comprehensive Portfolio Management client has the opportunity to place reasonable
restrictions on the types of investments to be held in the portfolio. Restrictions on investments in
certain securities or types of securities may not be possible due to the level of difficulty this would
entail in managing the account.
Participation in Wrap Fee Programs
Our firm is in the process of converting our Wrap Comprehensive Portfolio Management Service into
the above described non-wrap offering. All accounts are managed on an individualized basis
according to the client’s investment objectives, financial goals, risk tolerance, etc. Please see our Part
2A, Appendix 1 (the “Wrap Fee Program Brochure”) for more information.
Our firm also recommends the use of certain third-party managed accounts, which are outside of our
Wrap Free Program. Fees for these services are separate and in addition to the fees charged by our
firm. The terms and conditions of these arrangements are disclosed to enrolled clients via execution
of a separate agreement and provision of the chosen manager’s ADV disclosure documents.
Regulatory Assets Under Management
As of December 31, 2024, our firm manages $202,737,841 in assets on a discretionary basis and
$30,083,329 on a non-discretionary basis.
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Comprehensive Portfolio Management
The maximum annual fee charged for this service will not exceed 1.20%. Fees to be assessed will be
outlined in the advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata
basis monthly in arrears based on the value of the account(s) on the last day of the month with
adjustments made for all deposits and withdrawals. Certain illiquid alternative investments with a
valuation lag will be billed upon their most recently available valuation. Fees are negotiable and will
be deducted from client account(s). It should be noted that unless otherwise agreed to in writing, we
will assess our advisory fee on cash and cash equivalents. In rare cases, our firm will agree to directly
invoice clients through AdvicePay. As part of this process, Clients understand the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
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c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Where appropriate, we recommend that certain clients utilize third party managed accounts. The
fees for third party manager services are separate and in addition to our firm’s advisory fees. These
fees are disclosed to each client via execution of a separate agreement and receipt of the chosen
manager’s Form ADV disclosures.
Asset Management For Held Away Accounts:
The maximum annual fee charged for this service will not exceed 1.20%. The exact fees to be assessed
will be outlined in Schedule A and/or B of the executed Agreement. Annualized fees are billed on a
pro-rata basis monthly in arrears based on the value of the account(s) on the last day of the month.
Fees are negotiable and will be deducted from Client account(s) by MFG. Adjustments will be made
for deposits and withdrawals during the month. In rare cases, MFG will agree to directly invoice. As
part of this process, Clients understand the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Financial Planning & Consulting:
Our firm charges on a flat fee basis for financial planning and consulting services. The total estimated
fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with
the client. Flat fees range from $2,000 to $5,000. The fee-paying arrangements will be determined on
a case-by-case basis and will be detailed in the signed consulting agreement. Our firm will not require
a retainer exceeding $1200 when services cannot be rendered within 6 months.
Retirement Plan Consulting:
Our Retirement Plan Consulting services are billed on a fee based on the percentage of Plan assets
under management. The total estimated fee, as well as the ultimate fee charged, is based on the scope
and complexity of our engagement with the client. Fees based on a percentage of managed Plan assets
will not exceed 1.20%. The fee-paying arrangements will be determined on a case-by-case basis and
will be detailed in the signed consulting agreement.
Other Types of Fees & Expenses
Non-Wrap Clients will incur transaction fees for trades executed by their chosen custodian, either
based on a percentage of the dollar amount of assets in the account(s) or via individual transaction
charges. These transaction fees are separate from our firm’s advisory fees and will be disclosed by
the chosen custodian.
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Fidelity Brokerage Services (“Fidelity”) eliminated transaction fees for U.S. listed equities and
exchange traded funds for clients who opt into electronic delivery of statements or maintain at least
$1 million in assets at Fidelity. Clients who do not meet either criteria will be subject to transaction
fees charged by Fidelity for U.S. listed equities and exchange traded funds.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (e.g., fund management fees, distribution fees, surrender charges,
variable annuity fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads
paid to market makers, fees for trades executed away from custodian, wire transfer fees and other
fees and taxes on brokerage accounts and securities transactions). Our firm does not receive a
portion of these fees.
Wrap clients will not incur transaction costs for trades by their chosen custodian. More information
about this can be found in our separate Wrap Fee Program Brochure.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for Wrap Comprehensive
Portfolio Management or our Comprehensive Portfolio Management services in writing at any time.
Upon notice of termination pro-rata advisory fees for services rendered to the point of termination
will be charged. If advisory fees cannot be deducted, our firm will send an invoice for due advisory
fees to the client.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm.
Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing
written notice to the other party. Full refunds will only be made in cases where cancellation occurs
within 5 business days of signing an agreement. After 5 business days from initial signing, either
party must provide the other party 30 days written notice to terminate billing. Billing will terminate
30 days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes
into account work completed by our firm on behalf of the client. Clients will incur charges for bona
fide advisory services rendered up to the point of termination (determined as 30 days from receipt
of said written notice) and such fees will be due and payable.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
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Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension and Profit Sharing Plans;
• Corporations, Limited Liability Companies and/or Other Business Types
Our requirements for opening and maintaining accounts or otherwise engaging us:
• Our firm requires a minimum account balance of $250,000 for our Wrap Comprehensive
Portfolio Management or our Comprehensive Portfolio Management service. Generally, this
minimum account balance requirement is negotiable and can be waived at the firm’s sole
discretion.
• Written financial plans are generally assessed a minimum fee of $2,000.
Clients who opt into electronic delivery of statements or maintain at least $1 million in assets at
Fidelity will not be charged transaction fees for U.S. listed equities and exchange traded funds.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Charting: In this type of technical analysis, our firm reviews charts of market and security activity in
an attempt to identify when the market is moving up or down and to predict how long the trend may
last and when that trend might reverse.
Cyclical Analysis: Statistical analysis of specific events occurring at a sufficient number of relatively
predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical
forces drive price movements in the financial markets. Risks include that cycles may invert or
disappear and there is no expectation that this type of analysis will pinpoint turning points, instead
be used in conjunction with other methods of analysis.
Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the
intrinsic value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can
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be made by purchasing the mispriced security and then waiting for the market to recognize its
"mistake" and reprice the security.; and (b) Technical analysis maintains that all information is
reflected already in the price of a security. Technical analysts analyze trends and believe that
sentiment changes predate and predict trend changes. Investors' emotional responses to price
movements lead to recognizable price chart patterns. Technical analysts also analyze historical
trends to predict future price movement. Investors can use one or both of these different but
complementary methods for stock picking. This presents a potential risk, as the price of a security
can move up or down along with the overall market regardless of the economic and financial factors
considered in evaluating the stock.
Technical Analysis: A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the history
of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are mathematical
transformations of price, often including up and down volume, advance/decline data and other
inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
probability of its direction and of continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among traders
and financial professionals and is very often used by active day traders, market makers and pit
traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The
process usually consists of searching vast databases for patterns, such as correlations among liquid
assets or price-movement patterns (trend following or mean reversion). The resulting strategies may
involve high-frequency trading. The results of the analysis are taken into consideration in the
decision to buy or sell securities and in the management of portfolio characteristics. A risk in using
quantitative analysis is that the methods or models used may be based on assumptions that prove to
be incorrect.
Qualitative Analysis: A securities analysis that uses subjective judgment based on unquantifiable
information, such as management expertise, industry cycles, strength of research and development,
and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on
numbers that can be found on reports such as balance sheets. The two techniques, however, will often
be used together in order to examine a company's operations and evaluate its potential as an
investment opportunity. Qualitative analysis deals with intangible, inexact concerns that belong to
the social and experiential realm rather than the mathematical one. This approach depends on the
kind of intelligence that machines (currently) lack, since things like positive associations with a
brand, management trustworthiness, customer satisfaction, competitive advantage and cultural
shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative
analysis is that subjective judgment may prove incorrect.
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Security Analysis: Analysis of tradeable financial instruments called securities. These can be
classified into debt securities, equities, or some hybrid of the two. More broadly, futures contracts
and tradeable credit derivatives are sometimes included. Security analysis is typically divided into
fundamental analysis, which relies upon the examination of fundamental business factors such as
financial statements, and technical analysis, which focuses upon price trends and momentum.
Quantitative analysis may use indicators from both areas.
Sector Analysis: Sector analysis involves identification and analysis of various industries or
economic sectors that are likely to exhibit superior performance. Academic studies indicate that the
health of a stock's sector is as important as the performance of the individual stock itself. In other
words, even the best stock located in a weak sector will often perform poorly because that sector is
out of favor. Each industry has differences in terms of its customer base, market share among firms,
industry growth, competition, regulation and business cycles. Learning how the industry operates
provides a deeper understanding of a company's financial health. One method of analyzing a
company's growth potential is examining whether the amount of customers in the overall market is
expected to grow. In some markets, there is zero or negative growth, a factor demanding careful
consideration. Additionally, market analysts recommend that investors should monitor sectors that
are nearing the bottom of performance rankings for possible signs of an impending turnaround.
Investment Strategies We Use
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the
investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle
that different assets perform differently in different market and economic conditions. A fundamental
justification for asset allocation is the notion that different asset classes offer returns that are not
perfectly correlated, hence diversification reduces the overall risk in terms of the variability of
returns for a given level of expected return. Although risk is reduced as long as correlations are not
perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation
and variance) that existed over some past period. Expectations for return are often derived in the
same way.
An asset class is a group of economic resources sharing similar characteristics, such as riskiness and
return. There are many types of assets that may or may not be included in an asset allocation strategy.
The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of
any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic,
foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally:
investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long-
term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these
three provides a starting point. Usually included are hybrid instruments such as convertible bonds
and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be
considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others.;
Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps;
insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products,
etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and
futures; foreign currency; venture capital; private equity; and/or distressed securities.
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There are several types of asset allocation strategies based on investment goals, risk tolerance, time
frames and diversification. The most common forms of asset allocation are: strategic, dynamic,
tactical, and core-satellite.
• Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset
mix that seeks to provide the optimal balance between expected risk and return for a long-
term investment horizon. Generally speaking, strategic asset allocation strategies are
agnostic to economic environments, i.e., they do not change their allocation postures relative
to changing market or economic conditions.
• Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in
that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance
between expected risk and return for a long-term investment horizon. Like strategic
allocation strategies, dynamic strategies largely retain exposure to their original asset
classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust
their postures over time relative to changes in the economic environment.
• Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a
more active approach that tries to position a portfolio into those assets, sectors, or individual
stocks that show the most potential for perceived gains. While an original asset mix is
formulated much like strategic and dynamic portfolio, tactical strategies are often traded
more actively and are free to move entirely in and out of their core asset classes
• Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core'
strategic element making up the most significant portion of the portfolio, while applying a
dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this
way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical
allocation strategies mentioned above.
Alternative Investments: Hedge funds, commodity pools, Real Estate Investment Trusts (“REITs”),
Business Development Companies (“BDCs”), and other alternative investments involve a high degree
of risk and can be illiquid due to restrictions on transfer and lack of a secondary trading market. They
can be highly leveraged, speculative and volatile, and an investor could lose all or a substantial
amount of an investment. Alternative investments may lack transparency as to share price, valuation
and portfolio holdings. Complex tax structures often result in delayed tax reporting. Compared to
mutual funds, hedge funds and commodity pools are subject to less regulation and often charge
higher fees and may require “capital calls” which would require additional investment. Alternative
investment managers typically exercise broad investment discretion and may apply similar
strategies across multiple investment vehicles, resulting in less diversification.
Cryptocurrency Products: We may recommend investment in digital (crypto) currency products.
These products may are generally structured as a trust or exchange traded fund which pool capital
together to purchase holdings of digital currencies or derivatives based on their value. Such products
are extremely volatile and are suitable only as a means of diversification for investors with high risk
tolerances. Furthermore, these securities carry very high internal expense ratios, and may use
derivatives to achieve leverage or exposure in lieu of direct cryptocurrency holdings. This can result
in tracking error and may sell at a premium or discount to the market value of their underlying
holdings. Security is also a concern for digital currency investments which make them subject to the
additional risk of theft, as they are typically held with a non-traditional custodial platform.
Exchange Traded Funds (“ETFs”): An ETF is a type of Investment Company (usually, an open-end
fund or unit investment trust) whose primary objective is to achieve the same return as a particular
market index. The vast majority of ETFs are designed to track an index, so their performance is close
to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference
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between the returns of a fund and the returns of the index, can arise due to differences in
composition, management fees, expenses, and handling of dividends. ETFs benefit from continuous
pricing; they can be bought and sold on a stock exchange throughout the trading day. Because ETFs
trade like stocks, you can place orders just like with individual stocks - such as limit orders, good-
until-canceled orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are
bought and redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought
and sold at the market prices on the exchanges, which resemble the underlying NAV but are
independent of it. However, arbitrageurs will ensure that ETF prices are kept very close to the NAV
of the underlying securities. Although an investor can buy as few as one share of an ETF, most buy in
board lots. Anything bought in less than a board lot will increase the cost to the investor. Anyone can
buy any ETF no matter where in the world it trades. This provides a benefit over mutual funds, which
generally can only be bought in the country in which they are registered.
One of the main features of ETFs are their low annual fees, especially when compared to traditional
mutual funds. The passive nature of index investing, reduced marketing, and distribution and
accounting expenses all contribute to the lower fees. However, individual investors must pay a
brokerage commission to purchase and sell ETF shares; for those investors who trade frequently,
this can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost
brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient.
Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed-income investments because of the
reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid
income face the risk of inflation eroding their spending power.
Some examples of fixed-income investments include treasuries, money market instruments,
corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary risk
associated with fixed-income investments is the borrower defaulting on his payment. Other
considerations include exchange rate risk for international bonds and interest rate risk for longer-
dated securities. The most common type of fixed-income security is a bond. Bonds are issued by
federal governments, local municipalities and major corporations. Fixed-income securities are
recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio
dedicated to fixed income depends on your own personal investment style. There is also an
opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products,
such as junk bonds and longer-dated products, should comprise a lower percentage of your overall
portfolio.
The interest payment on fixed-income securities is considered regular income and is determined
based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-
income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate,
because they are considered riskier. The longer the security is on the market, the more time it has to
lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns
the amount borrowed, also referred to as the principal or par value.
Individual Stocks: A common stock is a security that represents ownership in a corporation. Holders
of common stock exercise control by electing a board of directors and voting on corporate policy.
Investing in individual common stocks provides us with more control of what you are invested in and
when that investment is made. Having the ability to decide when to buy or sell helps us time the
taking of gains or losses. Common stocks, however, bear a greater amount of risk when compared to
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certificate of deposits, preferred stock and bonds. It is typically more difficult to achieve
diversification when investing in individual common stocks. Additionally, common stockholders are
on the bottom of the priority ladder for ownership structure; if a company goes bankrupt, the
common stockholders do not receive their money until the creditors and preferred shareholders
have received their respective share of the leftover assets.
Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively
long time (more than a year) in anticipation that the security’s value will appreciate over a long
horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that
could have been profitable to your account, or it’s possible that the security’s value may decline
sharply before our firm makes a decision to sell.
Mutual Funds: A mutual fund is a company that pools money from many investors and invests that
money in a variety of differing security types based on the objectives of the fund. The portfolio of the
fund consists of the combined holdings it owns. Each share represents an investor’s proportionate
ownership of the fund’s holdings and the income those holdings generate. The price that investors
pay for mutual fund shares are the fund’s per share net asset value (“NAV”) plus any shareholder fees
that the fund imposes at the time of purchase (such as sales loads). Investors typically cannot
ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence
which securities the fund manager buys and sells or the timing of those trades. With an individual
stock, investors can obtain real-time (or close to real-time) pricing information with relative ease by
checking financial websites or by calling a broker or your investment adviser. Investors can also
monitor how a stock’s price changes from hour to hour—or even second to second. By contrast, with
a mutual fund, the price at which an investor purchases or redeems shares will typically depend on
the fund’s NAV, which is calculated daily after market close.
The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an
investing strategy that generally sums up as “Don’t put all your eggs in one basket.” Spreading
investments across a wide range of companies and industry sectors can help lower the risk if a
company or sector fails. Some investors find it easier to achieve diversification through ownership of
mutual funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual
fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed
on redemption.
Mutual funds also have features that some investors might view as disadvantages: (a) Investors must
pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending
on the timing of their investment, investors may also have to pay taxes on any capital gains
distributions they receive. This includes instances where the fund performed poorly after purchasing
shares.; (b) Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given
time, nor can they directly influence which securities the fund manager buys and sells or the timing
of those trades.; and (c) With an individual stock, investors can obtain real-time (or close to real-
time) pricing information with relative ease by checking financial websites or by calling a broker or
your investment adviser. Investors can also monitor how a stock’s price changes from hour to hour—
or even second to second. By contrast, with a mutual fund, the price at which an investor purchases
or redeems shares will typically depend on the fund’s NAV, which the fund might not calculate until
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many hours after the investor placed the order. In general, mutual funds must calculate their NAV at
least once every business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any
capital gains tax until the investor actually sells and makes a profit. Mutual funds, however, are
different. When an investor buys and holds mutual fund shares, the investor will owe income tax on
any ordinary dividends in the year the investor receives or reinvests them. Moreover, in addition to
owing taxes on any personal capital gains when the investor sells shares, the investor may have to
pay taxes each year on the fund’s capital gains. That is because the law requires mutual funds to
distribute capital gains to shareholders if they sell securities for a profit, and cannot use losses to
offset these gains.
Preferred Stocks: The preferred securities that the money manager may invest include preferred
stock. Preferred securities have similar characteristics to bond in that preferred securities are
designed to make fixed payments based on a percentage of their par value and are senior to common
stock. Like bonds, the market value of preferred securities is sensitive to changes in interest rates as
well as changes in issuer credit quality. Preferred securities, however, are junior to bonds with regard
to the distribution of corporate earnings and liquidation in the event of bankruptcy. Preferred
securities that are in the form of preferred stock also differ from bonds in that dividends on preferred
stock must be declared by the issuer’s board of directors, whereas interest payments on bonds
generally do not require action by the issuer’s board of directors, and bond holders generally have
protections that preferred stockholders do not have, such as indentures that are designed to
guarantee payments – subject to the credit quality of the issuer – with terms and conditions for the
benefit of bondholders. In contrast preferred stocks generally pay dividends, not interest payments,
which can be deferred or stopped in the event of credit stress without triggering bankruptcy or
default. Another difference is that preferred dividends are paid from the issue’s after-tax profits,
while bond interest is paid before taxes.
Real Estate Investment Trusts (“REITs”): REITs primarily invest in real estate or real estate-
related loans. Equity REITs own real estate properties, while mortgage REITs hold construction,
development and/or long-term mortgage loans. Changes in the value of the underlying property of
the trusts, the creditworthiness of the issuer, property taxes, interest rates, tax laws, and regulatory
requirements, such as those relating to the environment all can affect the values of REITs. REITs are
dependent upon management skill, the cash flows generated by their holdings, the real estate market
in general, and the possibility of failing to qualify for any applicable pass-through tax treatment or
failing to maintain any applicable exempted status afforded under relevant laws.
REITs involve a high degree of risk and can be illiquid due to restrictions on transfer and lack of a
secondary trading market. They can be highly leveraged, speculative and volatile, and an investor
could lose all or a substantial amount of an investment. Additionally, they may lack transparency as
to share price, valuation and portfolio holdings as they are subject to less regulation and often charge
higher fees.
Structured Products: Structured products are designed to facilitate highly customized risk-return
objectives. While structured products come in many different forms, they typically consist of a debt
security that is structured to make interest and principal payments based upon various assets, rates
or formulas. Many structured products include an embedded derivative component. Structured
products may be structured in the form of a security, in which case these products may receive
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benefits provided under federal securities law, or they may be cast as derivatives, in which case they
are offered in the over-the-counter market and are subject to no regulation.
Investing in structured products includes significant risks, including valuation, lack of liquidity, price,
credit and market risks. The relative lack of liquidity is due to the highly customized nature of the
investment and the fact that the full extent of returns from the complex performance features is often
not realized until maturity.
Another risk with structured products is the credit quality of the issuer. Although the cash flows are
derived from other sources, the products themselves are legally considered to be the issuing financial
institution's liabilities. The vast majority of structured products are from high-investment-grade
issuers only. Also, there is a lack of pricing transparency. There is no uniform standard for pricing,
making it harder to compare the net-of-pricing attractiveness of alternative structured product
offerings than it is, for instance, to compare the net expense ratios of different mutual funds or
commissions among broker-dealers.
Sector Allocation: Our firm allocates client assets to various sectors of the fixed income market,
including US Treasury obligations, federal agency securities, corporate notes, mortgage-backed
securities and others, based on our quantitative and qualitative analysis in order to manage client
exposure to a given sector and to provide exposure to sectors our firm believes to have good value.
The risk of sector allocation is that clients may not participate fully in an increase in value in any
specific sector.
Trading: Our firm purchase securities with the idea of selling them very quickly (typically within 30
days or less). Our firm do this in an attempt to take advantage of our predictions of brief price swings.
Trading involves risk that may not be suitable for every investor, and may involve a high volume of
trading activity. Each trade generates a commission and the total daily commission on such a high
volume of trading can be considerable. Active trading accounts should be considered speculative in
nature with the objective being to generate short-term profits. This activity may result in the loss of
more than 100% of an investment.
Preferred Securities
We prefer to invest our advisory client’s in the following securities in managing client accounts,
provided that such securities are appropriate to the needs of the client and consistent with the
client's investment objectives, risk tolerance, and time horizons, among other considerations:
• ETF’s
• Mutual Funds
•
Individual Securities
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, and that their assets are appropriately diversified in
investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance.
Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that
you may lose 100% of your money. All investments carry some form of risk and the loss of capital is
generally a risk for any investment instrument.
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Company Risk: When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk
and can be reduced through appropriate diversification. There is the risk that the company will
perform poorly or have its value reduced based on factors specific to the company or its industry.
For example, if a company’s employees go on strike or the company receives unfavorable media
attention for its actions, the value of the company may be reduced.
Credit Risk: Credit risk can be a factor in situations where an investment’s performance relies on a
borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or
unfavorable performance if a borrower does not repay the borrowed funds as expected or required.
Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit
risk.
Economic Risk: The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country that
experiences wide swings from an economic standpoint or in situations where certain elements of an
investment instrument are hinged on dealings in such countries, the investment instrument will
generally be subject to a higher level of economic risk.
Equity (Stock) Market Risk: Common stocks are susceptible to general stock market fluctuations
and, volatile increases and decreases in value as market confidence in and perceptions of their issuers
change. If you held common stock, or common stock equivalents, of any given issuer, you would
generally be exposed to greater risk than if you held preferred stocks and debt obligations of the
issuer.
ETF & Mutual Fund Risk: 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, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities, the ETF, or mutual fund holds. Clients will also
incur brokerage costs when purchasing ETFs.
Financial Risk: Financial risk is represented by internal disruptions within an investment or the
issuer of an investment that can lead to unfavorable performance of the investment. Examples of
financial risk can be found in cases like Enron or many of the dot com companies that were caught
up in a period of extraordinary market valuations that were not based on solid financial footings of
the companies.
Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with
prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk,
which is the risk that their value will generally decline as prevailing interest rates rise, which may
cause your account value to likewise decrease, and vice versa. How specific fixed income securities
may react to changes in interest rates will depend on the specific characteristics of each security.
Fixed-income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity
risk. Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely
manner, or that negative perceptions of the issuer’s ability to make such payments will cause the
price of a bond to decline.
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Growth Securities Risk: Securities of companies perceived to be “growth” companies may be more
volatile than other stocks and may involve special risks. The price of a “growth” security may be
impacted if the company does not realize its anticipated potential or if there is a shift in the market
to favor other types of securities.
Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to
the investment holder. Once an investor has acquired or has acquired the rights to an investment that
pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market
will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing
interest rates in the market will have an inverse relationship to the value of existing, interest paying
investments. In other words, as interest rates move up, the value of an instrument paying a particular
rate (fixed or variable) of interest will go down. The reverse is generally true as well.
Legal/Regulatory Risk: Certain investments or the issuers of investments may be affected by
changes in state or federal laws or in the prevailing regulatory framework under which the
investment instrument or its issuer is regulated. Changes in the regulatory environment or tax laws
can affect the performance of certain investments or issuers of those investments and thus, can have
a negative impact on the overall performance of such investments.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited
market in which they trade. This can create a substantial delay in the receipt of proceeds from an
investment. Liquidity risk can also result in unfavorable pricing when exiting (i.e. not being able to
quickly get out of an investment before the price drops significantly) a particular investment and
therefore, can have a negative impact on investment returns.
Manager Risk: There is always the possibility that poor security selection will cause your
investments to underperform relative to benchmarks or other funds with a similar investment
objective.
Market Risk: The value of your portfolio may decrease if the value of an individual company or
multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is
incorrect. Further, regardless of how well individual companies perform, the value of your portfolio
could also decrease if there are deteriorating economic or market conditions. It is important to
understand that the value of your investment may fall, sometimes sharply, in response to changes in
the market, and you could lose money. Investment risks include price risk as may be observed by a
drop in a security’s price due to company specific events (e.g. earnings disappointment or downgrade
in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock values fall in
general). For fixed-income securities, a period of rising interest rates could erode the value of a bond
since bond values generally fall as bond yields go up. Past performance is not a guarantee of future
returns.
Margin Transactions: Our firm may purchase securities for your portfolio with money borrowed
from your brokerage account. This allows you to purchase more stock than you would be able to with
your available cash and allows us to purchase securities without selling other holdings. Margin
accounts and transactions are risky and not necessarily appropriate for every client.
The potential risks associated with these transactions are (1) You can lose more funds than are
deposited into the margin account; (2) the forced sale of securities or other assets in your account;
(3) the sale of securities or other assets without contacting you; (4) you may not be entitled to choose
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which securities or other assets in your account(s) are liquidated or sold to meet a margin call; and
(5) custodians charge interest on margin balances which will reduce your returns over time.
Margin Loans: Our firm may allow or recommend that you to pledge securities from your portfolio
as collateral for a loan by using margin in brokerage account. This allows you to own more stock than
you would be able to with your available cash. Margin accounts and transactions are risky and not
necessarily appropriate for every client.
Operational Risk: Operational risk can be experienced when an issuer of an investment product is
unable to carry out the business it has planned to execute. Operational risk can be experienced as a
result of human failure, operational inefficiencies, system failures, or the failure of other processes
critical to the business operations of the issuer or counter party to the investment.
Strategy Risk: There is no guarantee that the investment strategies discussed herein will work under
all market conditions and each investor should evaluate his/her ability to maintain any investment
he/she is considering in light of his/her own investment time horizon. Investments are subject to
risk, including possible loss of principal.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to our Wrap
Comprehensive Portfolio Management services, as applicable.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are registered representatives of Independent Financial Group, LLC (IFG)
member FINRA/SIPC, and licensed insurance agents. As a result of these transactions, they receive
normal and customary commissions. Additionally, our firm received a one time payment to facilitate
the transition to IFG from our previous broker dealer. A conflict of interest exists as these
commissionable securities sales and transition assistance create an incentive to recommend
products based on the compensation earned. To mitigate this potential conflict, our firm will act in
the client’s best interest.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the
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underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. Our firm requires all representatives to conduct business with the
highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
our representatives for their personal accounts1. In order to monitor compliance with our personal
trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities prior to buying or selling for our clients in the same day unless included in
a block trade.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
While our firm does not maintain physical custody of client assets, we are deemed to have custody of
certain client assets if given the authority to withdraw assets from client accounts (see Item 15
Custody, below). Client assets must be maintained by a qualified custodian. Our firm seeks to
recommend a custodian who will hold client assets and execute transactions on terms that are overall
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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most advantageous when compared to other available providers and their services. The factors
considered, among others, are these:
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
• Quality of services
Our firm has an arrangement with National Financial Services LLC and Fidelity Brokerage Services LLC
(collectively, and together with all affiliates, "Fidelity") through which Fidelity provides our firm with
"institutional platform services." Our firm is independently operated and owned and is not affiliated with
Fidelity. The institutional platform services include, among others, brokerage, custody, and other related
services. Fidelity's institutional platform services that assist us in managing and administering clients'
accounts include software and other technology that (i) provide access to client account data (such as
trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated
trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv)
facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions,
recordkeeping and client reporting.
Fidelity may make certain research and brokerage services available at no additional cost to our firm.
Research products and services provided by Fidelity may
include: research reports on
recommendations or other information about particular companies or industries; economic surveys,
data and analyses; financial publications; portfolio evaluation services; financial database software and
services; computerized news and pricing services; quotation equipment for use in running software
used in investment decision-making; and other products or services that provide lawful and appropriate
assistance by Fidelity to our firm in the performance of our investment decision-making responsibilities.
The aforementioned research and brokerage services qualify for the safe harbor exemption defined in
Section 28(e) of the Securities Exchange Act of 1934.
Fidelity does not make client brokerage commissions generated by client transactions available for
our firm’s use. The aforementioned research and brokerage services are used by our firm to manage
accounts for which our firm has investment discretion. Without this arrangement, our firm might be
compelled to purchase the same or similar services at our own expense.
As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of
our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm
or our related persons creates a potential conflict of interest and may indirectly influence our firm’s
choice of Fidelity as a custodial recommendation. Our firm examined this potential conflict of interest
when our firm chose to recommend Fidelity and have determined that the recommendation is in the
best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best
execution.
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Our non-wrap fee clients may pay a transaction fee or commission to Fidelity that is higher than
another qualified broker dealer might charge to effect the same transaction where our firm
determines in good faith that the commission is reasonable in relation to the value of the brokerage
and research services provided to the client as a whole.
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
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Soft Dollars
Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will
generally be used to service all of our clients but not necessarily all at any one particular time.
Client Brokerage Commissions
Fidelity does not make client brokerage commissions generated by client transactions available for
our firm’s use.
Client Transactions in Return for Soft Dollars
Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar
benefits.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
Neither our firm nor any of our firm’s representatives have discretionary authority in making the
determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale
of securities are placed for execution, and the commission rates at which such securities transactions
are effected. Our firm routinely recommends that clients direct us to execute through a specified
broker-dealer. Our firm recommends the use of Fidelity. Each client will be required to establish their
account(s) with Fidelity if not already done. Please note that not all advisers have this requirement.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
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sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
Client-Directed Brokerage
Our firm does not allow client-directed brokerage outside our recommendations.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when our firm believes
that to do so will be in the best interest of the effected accounts. When such concurrent authorizations
occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, our firm attempts to allocate trade executions in the most equitable
manner possible, taking into consideration client objectives, current asset allocation and availability of
funds using price averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
Our management personnel or financial advisors and Chief Compliance Officer Clifton Yasutomi
reviews accounts on at least an annual basis for our Wrap Comprehensive Portfolio Management and
our Comprehensive Portfolio Management clients. The nature of these reviews is to learn whether
client accounts are in line with their investment objectives, appropriately positioned based on
market conditions, and investment policies, if applicable. Our firm does not provide written reports
to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when
our Wrap Comprehensive Portfolio Management and or our Comprehensive Portfolio Management
clients are contacted.
Our firm may review client accounts more frequently than described above. Among the factors which
may trigger an off-cycle review are major market or economic events, the client’s life events, requests
by the client, etc.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or update to their initial written financial plan.
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the
service. Our firm also provides ongoing services where clients are met with upon their request to
discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients
do not receive written or verbal updated reports regarding their plans unless they choose to engage
our firm for ongoing services.
Item 14: Client Referrals & Other Compensation
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Mission Financial Group, LLC
Product Sponsors and Platforms
Our firm occasionally sponsors events in conjunction with other business partners in an effort to
keep our clients informed as to the services we offer and the various financial products we utilize.
These events are educational in nature and are not dependent upon the use of any specific product.
While a conflict of interest may exist because these events are at least partially funded by product
sponsors or platforms we use, all funds received are used for the education of our clients. We will
always adhere to our fiduciary duty in recommending appropriate investments for our clients.
Referral Fees
Our firm does not pay referral fees (non-commission based) to independent solicitors (non-
registered representatives) for the referral of clients to our firm.
Item 15: Custody
Deduction of Advisory Fees:
While our firm does not maintain physical custody of client assets (which are maintained by a
qualified custodian, as discussed above), we are deemed to have custody of certain client assets if
given the authority to withdraw assets from client accounts, as further described below under “Third
Party Money Movement.” All our clients receive account statements directly from their qualified
custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review
these statements. Additionally, if our firm decides to send its own account statements to clients, such
statements will include a legend that recommends the client compare the account statements
received from the qualified custodian with those received from our firm. Clients are encouraged to
raise any questions with us about the custody, safety or security of their assets and our custodial
recommendations.
Third Party Money Movement:
On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client
funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody.
As such, our firm has adopted the following safeguards in conjunction with our custodian:
• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
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Mission Financial Group, LLC
• The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, our firm is
authorized to execute securities transactions, determine which securities are bought and sold, and
the total amount to be bought and sold. Should clients grant our firm non-discretionary authority,
our firm would be required to obtain the client’s permission prior to effecting securities transactions.
Limitations may be imposed by the client in the form of specific constraints on any of these areas of
discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write or email us to discuss questions
they may have about particular proxy votes or other solicitations.
Third party money managers selected or recommended by our firm may vote proxies for clients.
Therefore, except in the event a third party money manager votes proxies, clients maintain exclusive
responsibility for: (1) directing the manner in which proxies solicited by issuers of securities
beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s
investment assets. Therefore (except for proxies that may be voted by a third party money manager),
our firm and/or the client shall instruct the qualified custodian to forward to copies of all proxies and
shareholder communications relating to the client’s investment assets.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
• Our firm does not take custody of client funds or securities.
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
• Our firm has never been the subject of a bankruptcy proceeding.
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Mission Financial Group, LLC