Overview
- Headquarters
- Baltimore, MD
- Total Firm Assets
- $109 million
- Average High-Net-Worth Client Portfolio Size
- $2.3 million
Fee Structure
Primary Fee Schedule (NORTHBROOK FINANCIAL ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $2,000,000 | 0.75% |
| $2,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $32,500 | 0.65% |
| $10 million | $57,500 | 0.58% |
| $50 million | $257,500 | 0.52% |
| $100 million | $507,500 | 0.51% |
Clients
- High-Net-Worth Share of Firm Assets
- 50.00%
- Number of High-Net-Worth Clients
- 24
- Total Client Accounts
- 474
- Discretionary Accounts
- 474
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection, Educational Seminars
Regulatory Filings
- SEC CRD Number
- 309060
Primary Brochure: NORTHBROOK FINANCIAL ADV PART 2A (2026-05-18)
View Document Text
Item 1: Cover Page
Northbrook Financial Planning, LLC
1340 Smith Avenue, Suite 200
Baltimore, Maryland 21209
Form ADV Part 2A – Firm Brochure
(410) 941-9709
Dated May 18, 2026
www.northbrookfinancial.com
This Brochure provides information about the qualifications and business practices of Northbrook Financial
Planning, LLC, “Northbrook Financial”. If you have any questions about the contents of this Brochure, please
contact us at (410) 941-9709. 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.
Northbrook Financial Planning, LLC is registered as an Investment Adviser with the State of Maryland.
Registration of an Investment Adviser does not imply any level of skill or training.
Additional information about Northbrook Financial is available on the SEC’s website at www.adviserinfo.sec.gov,
which can be found using the firm’s identification number, 309060.
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Item 2: Material Changes
Since the last filing of the Form ADV Part 2A for Northbrook Financial on June 16, 2025, we have made
no material changes.
Future Changes
From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices,
changes in regulations, and routine annual updates as required. Either this complete Disclosure Brochure
or a Summary of Material Changes shall be provided to each Client annually and if a material change
occurs in the business practices of Northbrook Financial Planning, LLC.
At any time, you may view the current Disclosure Brochure online at the SEC's Investment Adviser
Public Disclosure website at http://www.adviserinfo.sec.gov by searching for our firm name or by our
CRD number 309060.
You may also request a copy of this Disclosure Brochure at any time, by contacting us at (410)
941-9709.
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Item 3: Table of Contents
Contents
Item 1: Cover Page
Item 2: Material Changes
Item 3: Table of Contents
Item 4: Advisory Business
Item 5: Fees and Compensation
Item 6: Performance-Based Fees and Side-By-Side Management
Item 7: Types of Clients
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Item 9: Disciplinary Information
Item 10: Other Financial Industry Activities and Affiliations
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12: Brokerage Practices
Item 13: Review of Accounts
Item 14: Client Referrals and Other Compensation
Item 15: Custody
Item 16: Investment Discretion
Item 17: Voting Client Securities
Item 18: Financial Information
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Item 4: Advisory Business
Description of Advisory Firm
Northbrook Financial Planning, LLC initially filed for registration with the Securities Exchange Commission as
a registered as an Investment Adviser on May 18, 2026. We were founded in April, 2020. MDFP LLC 100%
owned by Michael J. Delaney, and NORTHBROOK HOLDINGS, LLC, 100% owned by Elliot J, Pepper are
equal co-owners of Northbrook Financial. Michael J. Delaney is our Chief Compliance Officer. Northbrook
Financial currently reports $108,760,000 in discretionary and $0 in non-discretionary Assets Under Management
as of May 18, 2026.
Types of Advisory Services
Investment Management Services
We are in the business of managing individually tailored investment portfolios. Our firm provides continuous
advice to a Client regarding the investment of Client funds based on the individual needs of the Client. Through
personal discussions in which goals and objectives based on a Client's particular circumstances are established, we
develop a Client's personal investment policy or an investment plan with an asset allocation target and create and
manage a portfolio based on that policy and allocation targets. We will also review and discuss a Client’s prior
investment history, as well as family composition and background.
Account supervision is guided by the stated objectives of the Client (e.g., maximum capital appreciation, growth,
income, or growth, and income), as well as tax considerations. Clients may impose reasonable restrictions on
investing in certain securities, types of securities, or industry sectors. Fees pertaining to this service are outlined in
Item 5 of this brochure.
Use of Third Party Managers, Outside Managers, or Sub-Advisors (TAMPs)
We offer the use of Third Party Managers, Outside Managers, or Sub-Advisors (TAMPs) for portfolio
management services. We assist Clients in selecting an appropriate allocation model, completing the Outside
Manager’s investor profile questionnaire, interacting with the Outside Manager and reviewing the Outside
Manager. Our review process and analysis of outside managers is further discussed in Item 8 of this Form ADV
Part 2A. Additionally, we will meet with the Client on a periodic basis to discuss changes in their personal or
financial situation, suitability, and any new or revised restrictions to be applied to the account. Fees pertaining to
this service are outlined in Item 5 of this brochure.
Altruist as a Sub-Advisor (CRD#299274)
Northbrook Financial offers investment advisory services through the use of Altruist Financial, LLC’s proprietary
automated investment management platform. We provide clients a customized portfolio of exchange traded funds
(“ETFs”), publicly-traded equities, fixed income securities, mutual funds, closed end funds (“CEFs”). Altruist
provides Northbrook Financial with technology and related trading and account management services, and acts as
the limited agent of Northbrook Financial for the purposes of implementing investment advice and directions,
including by:
1. Reflecting Northbrooks Financials asset allocations
a. Operating the Allocation to:
i.
Implement Northbrook Financial’s portfolio selections, allocations, modifications and
replacements for client accounts, and
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ii.
iii.
Perform the automatic rebalancing for the client’s accounts; and
Carrying out the trade order management process
Pontera
In cases where the client chooses to have Northbrook Financial advise on assets that are not held at a qualified
custodian in which Northbrook Financial has an advisory relationship (See Item 12 of this brochure) Northbrook
Financial is able to provide investment management services of those held away accounts through a third party
portfolio management provider, Pontera. Such accounts will be studied, analyzed, asset-allocated, monitored,
managed, tactically adjusted and rebalanced when necessary and periodically reviewed by the Firm in detail on
behalf of the Client, taking into account the Client’s evolving individual circumstances, goals and objectives just
as Northbrook Financial does for assets managed directly at the firm’s recommended custodian.
Access to held away accounts is achieved by the Client giving permission via a provided link through Pontera for
the Firm to make asset allocation changes via the Client’s online login credentials. These online credentials are
never made available to, held or stored by Northbrook Financial. Access is restricted and the Firm will only have
permissions to make changes to the allocation of funds or other securities in the account and will not at any time
be able to adjust, add to or subtract from investment options, or any other plan policies or fees assessed by the
plan or the fund providers, access the financial assets in the account, make deposits, withdrawals or distributions.
These assets will be monitored using third party account aggregation software where the account values and
holdings are transmitted and viewed from the account aggregation software. These assets are included in
calculating the total assets under management when assessing the annual advisory fee.
Retirement Income Planning Services
With this service we do not manage assets. We provide investment advice, and ongoing comprehensive financial
planning services to Clients with assets not under our management. Prior to providing any services, Northbrook
Financial will provide Client’s with an investment management & Ongoing Comprehensive Financial Planning
Agreement. Under the Agreement, the Client’s provide their current and anticipated financial condition as well
as their investment objectives and risk tolerance. Northbrook Financial begins by assessing Client risk profiles
through questionnaires. Clients will receive investment management strategies, and advice on the following:
(maximizing social security, tax strategies, cash flow analysis, charitable giving, employer benefits plan
optimization, stock options, 529 plans, and debt management).
Financial planning involves an evaluation of a Client's current and future financial state by using currently known
variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of financial
planning is that through the financial planning process, all questions, information, and analysis will be considered
as they affect and are affected by the entire financial and life situation of the Client. Clients purchasing this
service will receive a written or an electronic report, providing the Client with a detailed financial plan designed
to achieve his or her stated financial goals and objectives.
In general, the financial plan will address any or all of the following areas of concern. The Client and advisor will
work together to select specific areas to cover. These areas may include, but are not limited to, the following:
Business Planning: We provide consulting services for Clients who currently operate their own business, are
considering starting a business, or are planning for an exit from their current business. Under this type of
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engagement, we work with you to assess your current situation, identify your objectives, and develop a plan
aimed at achieving your goals.
Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine
your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to
reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first
based on factors such as the interest rate of the debt and any income tax ramifications. We may also
recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and
other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus
strategies to save desired amounts.
College Savings: Includes projecting the amount that will be needed to achieve college or other
post-secondary education funding goals, along with advice on ways for you to save the desired amount.
Recommendations as to savings strategies are included, and, if needed, we will review your financial picture
as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if appropriate).
Employee Benefits Optimization: We will provide review and analysis as to whether you, as an employee,
are taking the maximum advantage possible of your employee benefits. If you are a business owner, we will
consider and/or recommend the various benefit programs that can be structured to meet both business and
personal retirement goals.
Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate
plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. Our
advice also typically includes ways for you to minimize or avoid future estate taxes by implementing
appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you
consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may
provide you with contact information for attorneys who specialize in estate planning when you wish to hire an
attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and
your attorney with your approval or request.
Financial Goals: We will help Clients identify financial goals and develop a plan to reach them. We will
identify what you plan to accomplish, what resources you will need to make it happen, how much time you
will need to reach the goal, and how much you should budget for your goal.
Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term care,
liability, home, and automobile.
Investment Analysis: This may involve developing an asset allocation strategy to meet Clients’ financial
goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee
stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer
or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of
this brochure.
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Retirement Planning: Our retirement planning services typically include projections of your likelihood of
achieving your financial goals, typically focusing on financial independence as the primary objective. For
situations where projections show less than the desired results, we may make recommendations, including
those that may impact the original projections by adjusting certain variables (e.g., working longer, saving
more, spending less, taking more risk with investments).If you are near retirement or already retired, advice
may be given on appropriate distribution strategies to minimize the likelihood of running out of money or
having to adversely alter spending during your retirement years.
Risk Management: A risk management review includes an analysis of your exposure to major risks that
could have a significant adverse impact on your financial picture, such as premature death, disability, property
and casualty losses, or the need for long‐term care planning. Advice may be provided on ways to minimize
such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise,
the potential cost of not purchasing insurance (“self‐insuring”).
Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part of
your overall financial planning picture. For example, we may make recommendations on which type of
account(s) or specific investments should be owned based in part on their “tax efficiency,” with the
consideration that there is always a possibility of future changes to federal, state or local tax laws and rates
that may impact your situation.
We recommend that you consult with a qualified tax professional before initiating any tax planning strategy.
Elliot Pepper is a CPA and Managing Member of Northbrook Financial, LLC, a tax planning and preparation
firm. Advisory Clients of Northbrook Financial Planning, LLC may, but are not required to, engage
Northbrook Financial, LLC, a separate entity, to provide tax services. Clients who do so will remit fees to
Northbrook Financial Planning, LLC and Northbrook Financial Planning, LLC will remit fees for tax services
to Northbrook Financial, LLC.
Ongoing Comprehensive Financial Planning
This service involves working one-on-one with a planner over an extended period of time. By paying a fixed
monthly fee, Clients get to work with a planner who will work with them to develop and implement their plan.
The planner will monitor the plan, recommend any changes and ensure the plan is up to date.
Upon desiring a comprehensive plan, a Client will be taken through establishing their goals and values around
money. They will be required to provide information to help complete the following areas of analysis: net worth,
cash flow, insurance, credit scores/reports, employee benefit, retirement planning, insurance, investments, college
planning, and estate planning. Once the Client's information is reviewed, their plan will be built and analyzed, and
then the findings, analysis and potential changes to their current situation will be reviewed with the Client. Clients
subscribing to this service will receive a written or an electronic report, providing the Client with a detailed
financial plan designed to achieve his or her stated financial goals and objectives. If a follow-up meeting is
required, we will meet at the Client's convenience. The plan and the Client's financial situation and goals will be
monitored throughout the year and follow-up phone calls and emails will be made to the Client to confirm that
any agreed upon action steps have been carried out. On an annual basis, there will be a full review of this plan to
ensure its accuracy and ongoing appropriateness. Any needed updates will be implemented at that time.
Employee Benefit Plan Services
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Our firm provides employee benefit plan services to employer plan sponsors on an ongoing basis. Generally, such
services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's
participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include:
investment options, plan structure, and participant education.
In providing employee benefit plan services, 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”).
Speaking Engagements
We may speak in front of public groups seeking general advice on investments and other areas of personal
finance. These seminars are purely educational in nature and do not involve the sale of any investment products.
Information presented will not be based on any individual’s person’s need, nor does Northbrook Financial provide
individualized investment advice to attendees during these speaking engagements.
Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all of our Clients. However, specific Client financial plans and their
implementation are dependent upon the Client Investment Policy Statement which outlines each Client’s current
situation (income, tax levels, and risk tolerance levels) and is used to construct a Client specific plan to aid in the
selection of a portfolio that matches restrictions, needs, and targets.
Clients are able to specify, within reason, any limitations they would like to place on discretionary authority as it
pertains to individual securities and/or sectors that will be traded in their account, by notating these items on the
executed advisory agreement.
Wrap Fee Programs
We participate in a wrap fee program which is outlined in detail within the Form ADV Part 2A Appendix 1 (the
“Wrap Fee Brochure”). A wrap fee program allows our clients to pay a specified fee for investment advisory
services and the execution of transactions. The advisory services may include portfolio management, and the fee
is not based directly upon transactions in your account. Your fee is bundled with our costs for executing
transactions in your account(s). By participating in a wrap fee program, you may end up paying more or less than
you would through a non-wrap fee program where a lower advisory fee is charged, but trade execution costs are
passed directly through to you by the executing broker.
Item 5: Fees and Compensation
Please note, unless a Client has received the firm’s Disclosure Brochure at least 48 hours prior to signing the
investment advisory contract, the investment advisory contract may be terminated by the Client within five (5)
business days of signing the contract without incurring any advisory fees. How we are paid depends on the type of
advisory service we are performing. Please review the fee and compensation information below. Lower fees may
be available for the same or similar services.
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Investment Management Services
Our standard advisory fee is based on the market value of the assets under management and is calculated as
follows:
Account Value
Annual Advisory Fee
$0 - $1,000,000
1.00%
$1,000,001 - $2,000,000
0.75%
$2,000,001 and Above
0.50%
The annual fees are negotiable and are pro-rated and paid in arrears on a monthly or quarterly basis. The advisory
fee is a blended fee and is based on the average daily balance over the previous billing period. No increase in the
annual fee shall be effective without agreement from the Client by signing a new agreement or amendment to
their current advisory agreement.
Advisory fees are directly debited from Client accounts, or the Client may choose to pay by check. Accounts
initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time
remaining in the billing period. An account may be terminated with written notice at least 30 calendar days in
advance. Since fees are paid in arrears, no refund will be needed upon termination of the account.
Use of Third Party Managers, Outside Managers, or Sub-Advisors (TAMPs)
The standard advisory fee is based on the market value of the account and is calculated as follows:
Account Value
Annual Advisory Fee
$0 - $1,000,000
1.00%
$1,000,001 - $2,000,000
0.75%
$2,000,001 and Above
0.50%
The annual fees are negotiable and are pro-rated and paid in arrears on a monthly or quarterly basis, The advisory
fee is a blended fee and is based on the average daily balance over the previous billing period. Altruist calculates
fees based on a daily balance. For example a client with an account value of $500,000 will have a monthly fee of
$424.66, ($500,000 x 1.00%) x (31/365) = $424.66. The daily rate is $13.70, ($424.66/31) = $13.70.
When an Outside Manager is used, the Outside Manager will debit the Client’s account for both the Outside
Manager’s fee, and Northbrook Financial’s advisory fee, and will remit Northbrook Financial’s fee to Northbrook
Financial. The Client will designate which account(s) the advisory fees will be deducted from on the Agreement
with Northbrook Financial. Alternatively, the Client may choose to pay electronic funds transfer or by check.
Please note, the above fee schedule does include the Outside Manager’s fee. No increase in the annual fee shall be
effective without agreement from the Client by signing a new agreement or amendment to their current advisory
agreement.
Accounts initiated or terminated during a calendar quarter will be charged a prorated fee based on the amount of
time remaining in the billing period. An account may be terminated with written notice at least 30 calendar days
in advance. Since fees are paid in arrears, no refund will be needed upon termination of the account.
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Ongoing Comprehensive Financial Planning
Ongoing Financial Planning Fees consist of an upfront fee ranging from $200 to $2,000, followed by an ongoing
fee that is paid monthly, in arrears, at the rate of $200 - $5,000 per month. The fee may be negotiable in certain
cases.
The upfront portion of the fee is for Client onboarding, data gathering, and setting the basis for the financial plan.
This work will commence immediately after the fee is paid, and will be completed within the first 30 days of the
date the fee is paid. Therefore, the upfront portion of the fee will not be paid more than 6 months in advance.
Fees for this service may be paid by electronic funds transfer or check. This service may be terminated with 30
days’ notice. In the event of early termination any prepaid but unearned fees will be refunded to the Client and
any completed deliverables of the financial plan will be provided to the Client and no further fees will be charged.
Ongoing Comprehensive Financial Planning & Tax Preparation
Financial planning & tax preparation fee consists of an upfront onboarding fee of $1,000, followed by an annual
fee starting at $3,600 for individuals, and $4,800 for couples that is paid monthly in arrears. The fee is
negotiable, increases with complexity and may require an annual commitment.
Financial planning & tax preparation includes all of the following:
● New Client onboarding (3-5 meetings)
● Annual client Meeting (3-5 meetings per year)
● Annual Tax Return Filing
The upfront portion of the fee is for Client onboarding, data gathering, and setting the basis for the financial
planning & tax preparation. This work will commence immediately after the fee is paid, and will be completed
within the first 30 days of the date the fee is paid. Therefore, the upfront portion of the fee will not be paid more
than 6 months in advance.
Fees for this service may be paid by electronic funds transfer or check. This service may be terminated with 30
days’ notice. In the event of early termination any prepaid but unearned fees will be refunded to the Client and
any completed deliverables of the financial plan will be provided to the Client and no further fees will be charged.
Retirement Income Planning
Retirement income planning Fees consist of an upfront fee ranging from $1,000 to $10,000, followed by an
ongoing fee that is paid monthly, in arrears, at the rate of $500 per month. The fee may be negotiable in certain
cases.
The upfront portion of the fee is for Client onboarding, data gathering, and setting the basis for the financial plan.
This work will commence immediately after the fee is paid. The upfront portion of the fee will not be paid more
than 6 months in advance.
Fees for this service may be paid by credit card, electronic funds transfer, or check. This service may be
terminated with a 30 day’s notice. In the event of early termination any prepaid but unearned fees will be refunded
to the Client and any completed deliverables of the financial plan will be provided to the Client and no further
fees will be charged.
Financial Planning, Tax Preparation, and Investment management
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Financial planning, tax preparation, and investment management fee consists of an upfront onboarding fee of
$1,000, followed by an annual fee starting at $3,600 for individuals, and $4,800 for couples. The fee is
negotiable, increases with complexity and may require an annual commitment.
Financial Planning, Tax Preparation, and Investment management includes all of the following:
● New Client onboarding (3-5 meetings)
● Annual client Meeting (3-5 meetings per year)
● Annual Tax Return Filing
●
Investment Management
The investment management fees are negotiable and are pro-rated and paid in arrears on a monthly or quarterly
basis. The advisory fee is a blended fee and is based on the average daily balance over the previous billing period.
No increase in the annual fee shall be effective without agreement from the Client by signing a new agreement or
amendment to their current advisory agreement.
Advisory fees are directly debited from Client accounts, or the Client may choose to pay by check. Accounts
initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time
remaining in the billing period. An account may be terminated with written notice at least 30 calendar days in
advance. Since fees are paid in arrears, no refund will be needed upon termination of the account.
The upfront portion of the fee is for Client onboarding, data gathering, and setting the basis for the financial
planning, tax preparation, and the initial investment portfolio review. This work will commence immediately after
the fee is paid, and will be completed within the first 30 days of the date the fee is paid. Therefore, the upfront
portion of the fee will not be paid more than 6 months in advance.
Fees for this service may be paid by electronic funds transfer or check. This service may be terminated with 30
days’ notice. In the event of early termination any prepaid but unearned fees will be refunded to the Client and
any completed deliverables of the financial plan will be provided to the Client and no further fees will be charged.
Employee Benefit Plan Services
Account Value
Northbrook Financial’s Fee
$0 - $3,000,000
0.50%
$3,000,001 - $5,000,000
0.40%
$5,000,001 - $10,000,000
0.30%
$10,000,001 and Above
0.20%
Northbrook Financial will be compensated for Employee Benefit Plan services according to the value of plan
assets based on the table above. This does not include fees to other parties, such as RecordKeepers, Custodians, or
Third-Party-Administrators. Fees for this service are either paid directly by the plan sponsor or deducted directly
from the plan assets by the Custodian on a quarterly basis, and Northbrook Financial’s fee is remitted to
Northbrook Financial. The Client will designate which account(s) the advisory fees will be deducted from on the
Agreement with Northbrook Financial. Alternatively, The Client may choose to pay electronic funds transfer or by
check.
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Some clients request to have Northbrook Financial manage “held away” assets (e.g. Company 401(k)). Collection
of asset management fees for held-away accounts is commonly accomplished by means of quarterly invoicing.
Clients will be invoiced quarterly in arrears for the asset management fees for held-away accounts, based on the
account balance at the end of the billed period. The Client will agree to pay advisory fees in full to the Firm upon
receipt of the quarterly invoice.
Speaking Engagements
Generally, fees for seminars and speaking engagements range from free to $2,000, depending on sponsor, date,
location, and program requested. Half of the fees are due prior to the engagement, and the other half is to be paid
the day of, no later than the conclusion of the Seminar. The fee range is based on the content, amount of research
conducted, the number of hours of preparation needed, and the number of attendees. The content is based on
topics that are currently relevant in the financial planning environment.
Fees for this service may be paid by electronic funds transfer or check. In the event the Client decides to cancel,
the Client will be refunded for the cost of the seminar or speaking engagement.
Educational Seminars and Speaking Engagements may be provided pro-bono at our discretion.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which
may be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third
parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and
exchange-traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such
charges, fees, and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of
these commissions, fees, and costs. Please see our Wrap Fee Brochure detailed within the Form ADV Part 2A
Appendix 1 for more information on what transaction fees are included in our fees.
Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for Client’s
transactions and determining the reasonableness of their compensation (e.g., commissions).
We do not accept compensation for the sale of securities or other investment products including asset-based sales
charges or service fees from the sale of mutual funds.
Item 6: Performance-Based Fees and
Side-By-Side Management
We do not offer performance-based fees and do not engage in side-by-side management.
Item 7: Types of Clients
We provide financial planning and portfolio management services to individuals and high net-worth individuals.
We do not have a minimum account size requirement.
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Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss
Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s
financial statements, details regarding the company’s product line, the experience, and expertise of the company’s
management, and the outlook for the company’s industry. The resulting data is used to measure the true value of
the company’s stock compared to the current market value. The risk of fundamental analysis is that the
information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which
may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental
analysis may not result in favorable performance.
Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick
sectors that may outperform market indices. However, there is no assurance of accurate forecasts or that trends
will develop in the markets we follow. In the past, there have been periods without discernible trends and similar
periods will presumably occur in the future. Even where major trends develop, outside factors like government
intervention could potentially shorten them.
Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into
price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical
method may fail to identify trends requiring action. In addition, technical methods may overreact to minor price
movements, establishing positions contrary to overall price trends, which may result in losses. Finally, a technical
trading method may underperform other trading methods when fundamental factors dominate price moves within
a given market.
Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and trends based
upon business cycles. Economic/business cycles may not be predictable and may have many fluctuations between
long-term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy
and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the
changing value of securities that would be affected by these changing trends.
Charting analysis involves the gathering and processing of price and volume information for a particular
security. This price and volume information is analyzed using mathematical equations. The resulting data is then
applied to graphing charts, which is used to predict future price movements based on price patterns and trends.
Charts may not accurately predict future price movements. Current prices of securities may not reflect all
information about the security and day-to-day changes in market prices of securities may follow random patterns
and may not be predictable with any reliable degree of accuracy.
Modern Portfolio Theory
The underlying principles of MPT are:
●
Investors are risk averse. The only acceptable risk is that which is adequately compensated by an expected
return. Risk and investment return are related and an increase in risk requires an increased expected
return.
● Markets are efficient. The same market information is available to all investors at the same time. The
market prices every security fairly based upon this equal availability of information.
● The design of the portfolio as a whole is more important than the selection of any particular security. The
appropriate allocation of capital among asset classes will have far more influence on long-term portfolio
performance than the selection of individual securities.
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●
●
Investing for the long-term (preferably longer than ten years) becomes critical to investment success
because it allows the long-term characteristics of the asset classes to surface.
Increasing diversification of the portfolio with lower correlated asset class positions can decrease
portfolio risk. Correlation is the statistical term for the extent to which two asset classes move in tandem
or opposition to one another.
Use of Outside Managers: We may refer Clients to third-party investment advisers ("outside managers"). Our
analysis of outside managers involves the examination of the experience, expertise, investment philosophies, and
past performance of the outside managers in an attempt to determine if that manager has demonstrated an ability
to invest over a period of time and in different economic conditions. We monitor the manager's underlying
holdings, strategies, concentrations, and leverage as part of our overall periodic risk assessment. Additionally, as
part of our due diligence process, we survey the manager's compliance and business enterprise risks. A risk of
investing with an outside manager who has been successful in the past is that he or she may not be able to
replicate that success in the future. In addition, as we do not control the underlying investments in an outside
manager's portfolio. There is also a risk that a manager may deviate from the stated investment mandate or
strategy of the portfolio, making it a less suitable investment for our Clients. Moreover, as we do not control the
manager's daily business and compliance operations, we may be unaware of the lack of internal controls necessary
to prevent business, regulatory or reputational deficiencies.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment which you
should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other
investment or security. Material risks associated with our investment strategies are listed below.
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.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended.
Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations
are often more volatile and less liquid than investments in larger companies. Small and medium cap companies
may face a greater risk of business failure, which could increase the volatility of the Client’s portfolio.
Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A
high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in
the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s
performance.
Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be
more volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate
investments at prices we consider reasonable or favorable or find buyers at any price.
Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of
investment. From time to time these strategies may be subject to greater risks of adverse developments in such
areas of focus than a strategy that is more broadly diversified across a wider variety of investments.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall
below par value or the principal investment. The opposite is also generally true: bond prices generally rise when
interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price
changes. Most other investments are also sensitive to the level and direction of interest rates.
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Northbrook Financial Planning, LLC Form ADV Part 2A May 18, 2026
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Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the
securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your
investments remains the same.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities may have
other risks.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or
restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse
effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and
repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively,
investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but
rather are priced at a discount from their face values and their values accrete over time to face value at maturity.
The market prices of debt securities fluctuate depending on factors such as interest rates, credit quality, and
maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest
rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk.
Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions.
Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the
following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (II)
the ETF may employ an investment strategy that utilizes high leverage ratios; or (IIi) trading of an ETF’s shares
may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the
exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices)
halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the
Clients invest.
Mutual Funds: When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its
proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur
higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be affected by
losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund
(such as the use of derivatives).
Item 9: Disciplinary Information
Criminal or Civil Actions
Northbrook Financial and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
Northbrook Financial and its management have not been involved in administrative enforcement proceedings.
Self-Regulatory Organization Enforcement Proceedings
Northbrook Financial and its management have not been involved in legal or disciplinary events that are material
to a Client’s or prospective Client’s evaluation of Northbrook Financial or the integrity of its management.
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Northbrook Financial Planning, LLC Form ADV Part 2A May 18, 2026
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Item 10: Other Financial Industry Activities and
Affiliations
No Northbrook Financial employee is registered, or have an application pending to register, as a broker-dealer or a
registered representative of a broker-dealer.
No Northbrook Financial employee is registered, or have an application pending to register, as a futures
commission merchant, commodity pool operator or a commodity trading advisor.
Northbrook Financial does not have any related parties. As a result, we do not have a relationship with any related
parties.
Northbrook Financial only receives compensation directly from Clients. We do not receive compensation from
any outside source. We do not have any conflicts of interest with any outside party.
Elliot Pepper is a CPA and Managing Member of Northbrook Tax, LLC, a tax planning and preparation firm. Mr.
Pepper spends approximately 25 hours per week (15 hours per week during trading hours) on this activity.
Michael Delaney is also a Member of Northbrook Tax, LLC. Mr. Delaney spends approximately 5 hours per week
(5 hours per week during trading hours) on this activity. Advisory Clients of Northbrook Financial Planning, LLC
may, but are not required to, engage Northbrook Tax, LLC, a separate entity, to provide tax services. Clients who
do so will remit fees to Northbrook Financial Planning, LLC and Northbrook Financial Planning, LLC will remit
fees for tax services to Northbrook Tax, LLC.
Item 11: Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of
each Client. Our Clients entrust us with their funds and personal information, which in turn places a high standard
on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected
basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted
by the CFP® Board of Standards Inc., and accepts the obligation not only to comply with the mandates and
requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and
professionally responsible manner in all professional services and activities.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its
specific provisions will not shield associated persons from liability for personal trading or other conduct that
violates a fiduciary duty to advisory Clients. A summary of the Code of Ethics' Principles is outlined below.
Integrity - Associated persons shall offer and provide professional services with integrity.
●
● Objectivity - Associated persons shall be objective in providing professional services to Clients.
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Northbrook Financial Planning, LLC Form ADV Part 2A May 18, 2026
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● Competence - Associated persons shall provide services to Clients competently and maintain the
necessary knowledge and skill to continue to do so in those areas in which they are engaged.
● Fairness - Associated persons shall perform professional services in a manner that is fair and reasonable
to Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such
services.
● Confidentiality - Associated persons shall not disclose confidential Client information without the specific
consent of the Client unless in response to proper legal process, or as required by law.
● Professionalism - Associated persons' conduct in all matter shall reflect the credit of the profession.
● Diligence - Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm
access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm
will provide a copy of its Code of Ethics to any Client or prospective Client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest
Neither our firm, its associates or any related person is authorized to recommend to a Client or effect a transaction
for a Client, involving any security in which our firm or a related person has a material financial interest, such as
in the capacity as an underwriter, adviser to the issuer, etc.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
Our firm and its “related persons” may buy or sell securities similar to, or different from, those we recommend to
Clients for their accounts. In an effort to reduce or eliminate certain conflicts of interest involving the firm or
personal trading, our policy may require that we restrict or prohibit associates’ transactions in specific reportable
securities transactions. Any exceptions or trading pre-clearance must be approved by the firm principal in advance
of the transaction in an account, and we maintain the required personal securities transaction records per
regulation.
Trading Securities At/Around the Same Time as Client’s Securities
From time to time, our firm or its “related persons” may buy or sell securities for themselves at or around the
same time as clients. This may provide an opportunity for representatives of Northbrook Financial to buy or sell
securities before or after recommending securities to clients resulting in representatives profiting off the
recommendations they provide to clients. Such transactions may create a conflict of interest; however, Northbrook
Financial will never engage in trading that operates to the client’s disadvantage if representatives of Northbrook
Financial buy or sell securities at or around the same time as clients.
Item 12: Brokerage Practices
Factors Used to Select Custodians and/or Broker-Dealers
Northbrook Financial Planning, LLC does not have any affiliation with Broker-Dealers. Specific custodian
recommendations are made to the Client based on their need for such services. We recommend the custodial and
brokerage services of MTG, LLC dba Betterment Securities, Altruist, and Schwab, based on the reputation and
services provided by the firms.
1. Research and Other Soft-Dollar Benefits
We currently do not receive soft dollar benefits.
2. Brokerage for Client Referrals
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Northbrook Financial Planning, LLC Form ADV Part 2A May 18, 2026
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We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
We do recommend a specific custodian for Clients to use, however, Clients may custody their assets at a custodian
of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions. By allowing
Clients to choose a specific custodian, we may be unable to achieve the most favorable execution of Client
transactions and this may cost Clients money over using a lower-cost custodian.
Aggregating (Block) Trading for Multiple Client Accounts
Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we
manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares
to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically
proportionate to the size of the account, but it is not based on account performance or the amount or structure of
management fees. Subject to our discretion, regarding particular circumstances and market conditions, when we
combine orders, each participating account pays an average price per share for all transactions and pays a
proportionate share of all transaction costs. Please see our Wrap Fee Brochure detailed within the Form ADV Part
2A Appendix 1 for more information on what transaction fees are included within our fee schedule. Accounts
owned by our firm or persons associated with our firm may participate in block trading with your accounts;
however, they will not be given preferential treatment.
Outside Managers used by Northbrook Financial may block Client trades at their discretion. Their specific
practices are further discussed in their ADV Part 2A, Item 12.
Item 13: Review of Accounts
Northbrook Financial will work with Clients to obtain current information regarding their assets and investment
holdings and will review this information as part of our financial planning services. Northbrook Financial does
not provide specific reports to financial planning Clients, other than financial plans.
Northbrook Financials Chief Compliance Officer or delegated Investment Adviser Representative will review
Client accounts with the Investment Advisory Service regularly on a quarterly basis. The account is reviewed with
regards to the Client’s investment policies and risk tolerance levels. Events that may trigger a special review
would be unusual performance, addition or deletions of Client imposed restrictions, excessive draw-down,
volatility in performance, or buy and sell decisions from the firm or per Client's needs.
Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as
monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in
the accounts, such as receipt of dividends and interest.
Northbrook Financial will not provide written reports to Investment Advisory Clients.
Item 14: Client Referrals and Other
Compensation
We do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our
Clients. Northbrook Financial does not engage with solicitors.
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Northbrook Financial Planning, LLC Form ADV Part 2A May 18, 2026
Page | 19
Item 15: Custody
Northbrook Financial has limited custody of client funds since fees are deducted via a qualified custodian.
Prior to having fees deducted via a qualified custodian, Northbrook Financial will:
i.
ii.
iii.
Send the client an itemized invoice including any formulae used to calculate the fee, the time period
covered by the fee, and the amount of assets under management on which the fee was based.
Possess written authorization from the client to deduct advisory fees from an account held by a qualified
custodian.
Send the qualified custodian written notice of the amount of the fee to be deducted from the client’s
account.
Clients should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that
holds and maintains client investment assets. We urge you to carefully review such statements and compare such
official custodial records to the account statements or reports that we may provide to you. Our statements or
reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation
methodologies of certain securities.
Item 16: Investment Discretion
For those Client accounts where we provide Investment Management Services, we maintain discretion over Client
accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold.
Investment discretion is explained to Clients in detail when an advisory relationship has commenced. At the start
of the advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm
discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory contract
and signed by the Client.
Advisor will have the discretion to facilitate the selection of, and changes to, the Betterment For Advisors
portfolio allocation. Betterment For Advisors provides software tools for advisors to facilitate the purchase and
sale of securities in the Client's accounts, including the amounts of securities to be bought and sold to align with
the Client's goals and risk tolerance, through a series of 101 incremental model portfolio allocations ranging from
0% to 100% in equities.
Clients are able to specify, within reason, any limitations they would like to place on discretionary authority as it
pertains to individual securities and/or sectors that will be traded in their account, by notating these items on the
executed advisory agreement.
Item 17: Voting Client Securities
We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2)
acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s
qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the
Client’s investment assets. If the Client would like our opinion on a particular proxy vote, they may contact us at
the number listed on the cover of this brochure.
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Northbrook Financial Planning, LLC Form ADV Part 2A May 18, 2026
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In most cases, you will receive proxy materials directly from the account custodian. However, in the event we
were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless
you have authorized our firm to contact you by electronic mail, in which case, we would forward you any
electronic solicitation to vote proxies.
Item 18: Financial Information
Registered Investment Advisers are required in this Item to provide you with certain financial information or
disclosures about our financial condition. We have no financial commitment that impairs our ability to meet
contractual and fiduciary commitments to Clients, and we have not been the subject of a bankruptcy proceeding.
We do not have custody of Client funds or securities or require or solicit prepayment of more than $500 in fees
per Client six months in advance.
1340 Smith Avenue, Suite 200 Baltimore, MD 21209 │ www.northbrookfinancial.com
Additional Brochure: NORTHBROOK FINANCIAL WRAP FEE BROCHURE (2026-05-18)
View Document Text
Item 1: Cover Page
Northbrook Financial Planning, LLC
Form ADV Part 2A Appendix 1 – Wrap Fee Program Brochure
1340 Smith Avenue, Suite 200
Baltimore, MD 21209
(410) 941-9709
www.northbrookfinancial.com
Dated May 18, 2026
This Wrap Fee Program Brochure provides information about the qualifications and business
practices of Northbrook Financial Planning, LLC. If you have any questions about the contents
of this Brochure, please contact us at (410) 941-9709. 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.
Northbrook Financial Planning, LLC initially filed for registration as an Investment Advisor with
the SEC on May 18, 2026. Registration of an Investment Advisor does not imply any level of
skill or training. You are encouraged to review both this Brochure and the Brochure Supplements
any of our firm’s associates who advise you for more information on the qualifications of our
firm and our employees.
Additional information about Northbrook Financial Planning, LLC is available on the SEC’s
website at www.advisorinfo.sec.gov. CRD: 309060
1
Item 2: Material Changes
Northbrook Financial Planning, LLC is required to advise you of any material changes to our
Wrap Fee Program Brochure (“Wrap Brochure”) from our last annual update, identify those
changes on the cover page of our Wrap Brochure or on the page immediately following the cover
page, or in a separate communication accompanying our Wrap Brochure. We must state clearly
that we are discussing only material changes since the last annual update of our Wrap Brochure,
and we must provide the date of the last annual update of our Wrap Brochure.
Please note we do not have to provide this information to a client or prospective client who has
not received a previous version of our Wrap Brochure. There has been no material changes since
the last filing of this Wrap Brochure:
2
Item 3: Table of Contents
Contents
Item 1: Cover Page
Form ADV Part 2A Appendix 1 – Wrap Fee Program Brochure
Item 2: Material Changes
Item 3: Table of Contents
Item 4: Services, Fees and Compensation
Item 5: Account Requirements and Types of Clients
Item 6: Portfolio Manager Selection and Evaluation
Item 7: Client Information Provided to Portfolio Manager
Item 8: Client Contact with Portfolio Manager
Item 9: Additional Information
Item 10 Requirements for State-Registered Advisors
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2
3
4
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10
14
14
15
20
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Item 4: Services, Fees and Compensation
Description of Our Services
We offer wrap fee programs as described in this Wrap Fee Program Brochure. Our wrap fee
accounts are managed on an individualized basis according to the client’s investment objectives,
financial goals, risk tolerance, etc.
Types of Advisory Services
We offer the following services:
Investment Management Services
We are in the business of managing individually tailored investment portfolios. Our firm
provides continuous advice to a Client regarding the investment of Client funds based on the
individual needs of the Client. Through personal discussions in which goals and objectives based
on a Client's particular circumstances are established, we develop a Client's personal investment
policy or an investment plan with an asset allocation target and create and manage a portfolio
based on that policy and allocation targets. We will also review and discuss a Client’s prior
investment history, as well as family composition and background.
Account supervision is guided by the stated objectives of the Client (e.g., maximum capital
appreciation, growth, income, or growth, and income), as well as tax considerations. Clients may
impose reasonable restrictions on investing in certain securities, types of securities, or industry
sectors. Fees pertaining to this service are outlined in Item 5 of this brochure.
Schwab’s Brokerage Services In addition to the advisory services, the wrap fee program
includes certain brokerage services of Charles Schwab & Co., Inc. (“Schwab”) a broker-dealer
registered with the Securities and Exchange Commission and a member of FINRA and SIPC. We
are independently owned and operated and not affiliated with Schwab. Schwab will act solely as
a broker-dealer and not as an investment advisor to you. It will have no discretion over your
account and will act solely on instructions it receives from us. Schwab has no responsibility for
our services and undertakes no duty to you to monitor our firm’s management of your account or
other services we provide to you. Schwab will hold your assets in a brokerage account and buy
and sell securities and execute other transactions when we instruct them to. We do not open the
account for you.
Use of Third Party Managers, Outside Managers, or Sub-Advisors (TAMPs)
We offer the use of Third Party Managers, Outside Managers, or Sub-Advisors (TAMPs) for
portfolio management services. We assist Clients in selecting an appropriate allocation model,
completing the Outside Manager’s investor profile questionnaire, interacting with the Outside
Manager and reviewing the Outside Manager. Our review process and analysis of outside
managers is further discussed in Item 8 of this Form ADV Part 2A. Additionally, we will meet
4
with the Client on a periodic basis to discuss changes in their personal or financial situation,
suitability, and any new or revised restrictions to be applied to the account. Fees pertaining to
this service are outlined in Item 5 of this brochure.
Altruist as a Sub-Advisor (CRD#299274)
Northbrook Financial offers investment advisory services through the use of Altruist Financial,
LLC’s proprietary automated investment management platform. We provide clients a customized
portfolio of exchange traded funds (“ETFs”), publicly-traded equities, fixed income securities,
mutual funds, closed end funds (“CEFs”), and currencies (collectively, “Investments”). Altruist
provides Northbrook Financial with technology and related trading and account management
services, and acts as the limited agent of Northbrook Financial for the purposes of implementing
investment advice and directions, including by:
1. Reflecting Northbrooks Financials asset allocations
a. Operating the Allocation to:
i.
Implement Northbrook Financial’s portfolio selections, allocations,
modifications and replacements for client accounts, and
Perform the automatic rebalancing for the client’s accounts; and
ii.
iii. Carrying out the trade order management process via Apex Clearing
Corporation (“Apex”).
Pontera
In cases where the client chooses to have Northbrook Financial advise on assets that are not held
at a qualified custodian in which Northbrook Financial has an advisory relationship. Northbrook
Financial is able to provide investment management services of those held away accounts
through a third party portfolio management provider, Pontera. Such accounts will be studied,
analyzed, asset-allocated, monitored, managed, tactically adjusted and rebalanced when
necessary and periodically reviewed by the Firm in detail on behalf of the Client, taking into
account the Client’s evolving individual circumstances, goals and objectives just as Northbrook
Financial does for assets managed directly at the firm’s recommended custodian.
Access to held away accounts is achieved by the Client giving permission via a provided link
through Pontera for the Firm to make asset allocation changes via the Client’s online login
credentials. These online credentials are never made available to, held or stored by Northbrook
Financial. Access is restricted and the Firm will only have permissions to make changes to the
allocation of funds or other securities in the account and will not at any time be able to adjust,
add to or subtract from investment options, or any other plan policies or fees assessed by the plan
or the fund providers, access the financial assets in the account, make deposits, withdrawals or
distributions.
These assets will be monitored using third party account aggregation software where the account
values and holdings are transmitted and viewed from the account aggregation software. These
5
assets are included in calculating the total assets under management when assessing the annual
advisory fee.
Fees for Wrap Program We charge a single asset-based fee for services covered by the wrap
program. The fees charged for the program are set forth below.
Fees We Pay Schwab In addition to compensating Northbrook for advisory services, the wrap
fee you pay Northbrook allows us to pay for brokerage and execution services provided by
Schwab.
Relative Cost of Wrap Fee Program
A wrap fee is not based directly on the number of transactions in your account. Various factors
influence the relative cost of our wrap fee program to you, including the cost of our investment
advice, custody and brokerage services if you purchased them separately, the types of
investments held in your account, and the frequency, type and size of trades in your account. The
program could cost you more or less than purchasing our investment advice and
custody/brokerage services separately.
Schwab’s Brokerage Services In addition to the advisory services, the wrap fee program
includes certain brokerage services of Charles Schwab & Co., Inc. (“Schwab”) a broker-dealer
registered with the Securities and Exchange Commission and a member of FINRA and SIPC. We
are independently owned and operated and not affiliated with Schwab. Schwab will act solely as
a broker-dealer and not as an investment advisor to you. It will have no discretion over your
account and will act solely on instructions it receives from us [or you]. Schwab has no
responsibility for our services and undertakes no duty to you to monitor our firm’s management
of your account or other services we provide to you. Schwab will hold your assets in a brokerage
account and buy and sell securities and execute other transactions when we [or you] instruct
them to. We do not open the account for you.
Fees and Compensation
Investment Management Services
Our standard advisory fee is based on the market value of the assets under management and is
calculated as follows:
Account Value
Annual Advisory Fee
$0 - $1,000,000
1.00%
$1,000,001 - $2,000,000
0.75%
$2,000,001 and Above
0.50%
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The annual fees are negotiable and are pro-rated and paid in arrears on a monthly or quarterly
basis. The advisory fee is a blended fee and is based on the average daily balance over the
previous billing period. No increase in the annual fee shall be effective without agreement from
the Client by signing a new agreement or amendment to their current advisory agreement.
Advisory fees are directly debited from Client accounts, or the Client may choose to pay by
check. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee
based on the amount of time remaining in the billing period. An account may be terminated with
written notice at least 30 calendar days in advance. Since fees are paid in arrears, no refund will
be needed upon termination of the account.
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Use of Third Party Managers, Outside Managers, or Sub-Advisors (TAMPs)
The standard advisory fee is based on the market value of the account and is calculated as
follows:
Account Value
Annual Advisory Fee
$0 - $1,000,000
1.00%
$1,000,001 - $2,000,000
0.75%
$2,000,001 and Above
0.50%
The annual fees are negotiable and are pro-rated and paid in arrears on a monthly or quarterly
basis, The advisory fee is a blended fee and is based on the average daily balance over the
previous billing period.
When an Outside Manager is used, the Outside Manager will debit the Client’s account for both
the Outside Manager’s fee, and Northbrook Financial’s advisory fee, and will remit Northbrook
Financial’s fee to Northbrook Financial. The Client will designate which account(s) the advisory
fees will be deducted from on the Agreement with Northbrook Financial. Alternatively, the
Client may choose to pay electronic funds transfer or by check. Please note, the above fee
schedule does include the Outside Manager’s fee. No increase in the annual fee shall be effective
without agreement from the Client by signing a new agreement or amendment to their current
advisory agreement.
Accounts initiated or terminated during a calendar quarter will be charged a prorated fee based
on the amount of time remaining in the billing period. An account may be terminated with
written notice at least 30 calendar days in advance. Since fees are paid in arrears, no refund will
be needed upon termination of the account.
Note: lower fees may be available for the same or similar services.
Additional bundled Service Cost Considerations
A wrap fee program allows our clients to pay a specified fee for investment advisory services
and the execution of transactions. The advisory services may include portfolio management and
the fee is not based directly upon transactions in the client’s account. The client’s fee is bundled
with our costs for executing transactions in his or her account(s). This results in a higher
advisory fee. We do not charge our clients higher advisory fees based on their trading activity,
but you should be aware that we may have an incentive to limit our trading activities in your
account(s) because we are charged for executed trades. By participating in a wrap fee program,
you may end up paying more or less than you would through a non-wrap fee program where a
lower advisory fee is charged, but trade execution costs are passed directly through to you by the
executing broker.
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Additional Expenses Not Included in the Wrap Program Fee
Our wrap fee does not include the fees and costs listed below. The fees and costs may apply to
transactions in your account. The fees and costs not included in the wrap fee that you will pay
include:
●
Commissions and other fees charged by broker-dealers other than Schwab for
transactions in your account if we use Schwab’s Prime Brokerage, Step-In, or Trade
Away Services. Because you will pay our wrap fee in addition to any charges paid to
broker - dealers other than Schwab, we have an incentive to execute transactions for your
account through Schwab. However, as discussed in more detail [above / in our Brokerage
Practices description], we consider various factors in our best execution analysis and may
trade at another broker-dealer if we believe we can obtain better execution.
● Fees charged by mutual fund companies, closed-end funds, electronically traded funds,
and other collective investment vehicles, including, but not limited to, sales loads and/or
charges and short-term redemption fees.
● Markups and markdowns, bid-ask spreads, and selling concessions in connection with
transactions Schwab executes as principal. Principal transactions contrast with
transactions in which Schwab acts as your agent in effecting trades. Markups and
markdowns and bid-ask spreads are not separate fees, but are reflected in the net price at
which a trade order is executed.
● Costs imposed by third parties, such as transfer taxes, odd-lot differentials, certificate
delivery fees, reorganization fees, and any other fees required by law. Schwab may also
charge for additional services such as wire transfer fees and fees for alternative
investments.
Compensation
Our investment advisory representatives receive a portion of the advisory fee that you pay us,
either directly as a percentage of your overall fee or as their salary from our firm. In cases where
our investment advisory representatives are paid a percentage of your overall advisory fee, this
may create an incentive to recommend that you participate in a wrap fee program rather than a
non-wrap fee program (where you would pay for trade execution costs) or brokerage account
where commissions are charged. This is because, in some cases, we may stand to earn more
compensation from advisory fees paid to us through a wrap fee program arrangement if your
account is not actively traded.
Item 5: Account Requirements and Types of Clients
We provide financial planning and portfolio management services to individuals, high net-worth
individuals.
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We do not have a minimum account size requirement.
Item 6: Portfolio Manager Selection and Evaluation
Outside Portfolio Managers
We do not hire outside Portfolio Managers.
Northbrook Financial Planning, LLC Portfolio Managers
Our firm and its related persons, Michael Delaney and Elliot Pepper, act as a portfolio managers
for the wrap fee program previously described in this Wrap Fee Program Brochure. This may
create a conflict of interest in that other investment advisory firms may charge the same or lower
fees than our firm for similar services. Our related person portfolio managers are not subject to
the same selection and review as outside portfolio managers that participate in the wrap fee
program.
Advisory Business
See Item 4 of this Wrap Fee Program Brochure for information about our wrap fee advisory
programs.
Individual Tailoring of Advice to Clients
We offer individualized investment advice to clients utilizing our Asset Management and
Comprehensive Portfolio Management services.
The Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of
Securities
We do allow clients to impose reasonable restrictions on investing in certain securities or types of
securities.
Participation in Wrap Fee Programs
Our wrap fee and non-wrap fee accounts are managed on an individualized basis according to the
client’s investment objectives, financial goals, risk tolerance, etc. We do not manage wrap fee
accounts in a different fashion than non-wrap fee accounts.
Performance-based Fees and Side-by-Side Management
We do not charge performance-based fees and do not engage in side-by-side management
Methods of Analysis, Investment Strategies, and Risk of Loss
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Fundamental analysis involves analyzing individual companies and their industry groups, such
as a company’s financial statements, details regarding the company’s product line, the
experience, and expertise of the company’s management, and the outlook for the company’s
industry. The resulting data is used to measure the true value of the company’s stock compared to
the current market value. The risk of fundamental analysis is that the information obtained may
be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the
basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing
fundamental analysis may not result in favorable performance.
Technical analysis involves using chart patterns, momentum, volume, and relative strength in an
effort to pick sectors that may outperform market indices. However, there is no assurance of
accurate forecasts or that trends will develop in the markets we follow. In the past, there have
been periods without discernible trends and similar periods will presumably occur in the future.
Even where major trends develop, outside factors like government intervention could potentially
shorten them.
Furthermore, one limitation of technical analysis is that it requires price movement data, which
can translate into price trends sufficient to dictate a market entry or exit decision. In a trendless
or erratic market, a technical method may fail to identify trends requiring action. In addition,
technical methods may overreact to minor price movements, establishing positions contrary to
overall price trends, which may result in losses. Finally, a technical trading method may
underperform other trading methods when fundamental factors dominate price moves within a
given market.
Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns
and trends based upon business cycles. Economic/business cycles may not be predictable and
may have many fluctuations between long-term expansions and contractions. The lengths of
economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical
analysis is the difficulty in predicting economic trends and consequently the changing value of
securities that would be affected by these changing trends.
Charting analysis involves the gathering and processing of price and volume information for a
particular security. This price and volume information is analyzed using mathematical equations.
The resulting data is then applied to graphing charts, which is used to predict future price
movements based on price patterns and trends. Charts may not accurately predict future price
movements. Current prices of securities may not reflect all information about the security and
day-to-day changes in market prices of securities may follow random patterns and may not be
predictable with any reliable degree of accuracy.
Modern Portfolio Theory
The underlying principles of MPT are:
● Investors are risk averse. The only acceptable risk is that which is adequately
compensated by an expected return. Risk and investment return are related and an
increase in risk requires an increased expected return.
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● Markets are efficient. The same market information is available to all investors at the
same time. The market prices every security fairly based upon this equal availability of
information.
● The design of the portfolio as a whole is more important than the selection of any
particular security. The appropriate allocation of capital among asset classes will have far
more influence on long-term portfolio performance than the selection of individual
securities.
● Investing for the long-term (preferably longer than ten years) becomes critical to
investment success because it allows the long-term characteristics of the asset classes to
surface.
● Increasing diversification of the portfolio with lower correlated asset class positions can
decrease portfolio risk. Correlation is the statistical term for the extent to which two asset
classes move in tandem or opposition to one another.
Use of Outside Managers: We may refer Clients to third-party investment advisers ("outside
managers"). Our analysis of outside managers involves the examination of the experience,
expertise, investment philosophies, and past performance of the outside managers in an attempt
to determine if that manager has demonstrated an ability to invest over a period of time and in
different economic conditions. We monitor the manager's underlying holdings, strategies,
concentrations, and leverage as part of our overall periodic risk assessment. Additionally, as part
of our due diligence process, we survey the manager's compliance and business enterprise risks.
A risk of investing with an outside manager who has been successful in the past is that he or she
may not be able to replicate that success in the future. In addition, as we do not control the
underlying investments in an outside manager's portfolio. There is also a risk that a manager
may deviate from the stated investment mandate or strategy of the portfolio, making it a less
suitable investment for our Clients. Moreover, as we do not control the manager's daily business
and compliance operations, we may be unaware of the lack of internal controls necessary to
prevent business, regulatory or reputational deficiencies.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original
investment which you should be prepared to bear. Many of these risks apply equally to
stocks, bonds, commodities, and any other investment or security. Material risks associated with
our investment strategies are listed below.
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.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work
as intended.
Small and Medium Cap Company Risk: Securities of companies with small and medium
market capitalizations are often more volatile and less liquid than investments in larger
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companies. Small and medium cap companies may face a greater risk of business failure, which
could increase the volatility of the Client’s portfolio.
Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than
other strategies. A high portfolio turnover would result in correspondingly greater brokerage
commission expenses and may result in the distribution of additional capital gains for tax
purposes. These factors may negatively affect the account’s performance.
Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices
may at times be more volatile than at other times. Under certain market conditions, we may be
unable to sell or liquidate investments at prices we consider reasonable or favorable or find
buyers at any price.
Concentration Risk: Certain investment strategies focus on particular asset-classes, industries,
sectors or types of investment. From time to time these strategies may be subject to greater risks
of adverse developments in such areas of focus than a strategy that is more broadly diversified
across a wider variety of investments.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the
value may fall below par value or the principal investment. The opposite is also generally true:
bond prices generally rise when interest rates fall. In general, fixed income securities with longer
maturities are more sensitive to these price changes. Most other investments are also sensitive to
the level and direction of interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of
investments, or the securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar
value of your investments remains the same.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities
may have other risks.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s
bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment
could have an adverse effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest
and repay the amount borrowed either periodically during the life of the security and/or at maturity.
Alternatively, investors can purchase other debt securities, such as zero coupon bonds, which do not pay
current interest, but rather are priced at a discount from their face values and their values accrete over
time to face value at maturity. The market prices of debt securities fluctuate depending on factors such as
interest rates, credit quality, and maturity. In general, market prices of debt securities decline when
interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the
greater its interest rate risk.
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Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market
conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are
also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below
their net asset value; (II) the ETF may employ an investment strategy that utilizes high leverage ratios; or
(IIi) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action
appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit
breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has
no control over the risks taken by the underlying funds in which the Clients invest.
Mutual Funds: When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its
proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will
incur higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may
be affected by losses of an underlying fund and the level of risk arising from the investment practices of
an underlying fund (such as the use of derivatives).
Voting Client Securities
We do not vote client proxies. Therefore, the client maintains exclusive responsibility for: (1) voting
proxies, and (2) acting on corporate actions pertaining to the client’s investment assets. The client shall
instruct the client’s qualified custodian to forward to the client copies of all proxies and shareholder
communications relating to the client’s investment assets. If the client would like our opinion on a
particular proxy vote, they may contact us at the number listed on the cover of this brochure.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event
we were to receive any written or electronic proxy materials, we would forward them directly to you by
mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would
forward you any electronic solicitation to vote proxies.
Item 7: Client Information Provided to Portfolio Manager
We are required to describe the information about you that we communicate to your portfolio
manager(s) and how often or under what circumstances we provide updated information. Our
firm communicates with your portfolio manager(s) on a regular basis as needed (daily, weekly,
monthly, etc.) to ensure your most current investment goals and objectives are understood by
your portfolio manager(s). In most cases, we will communicate such information as part of our
regular investment management duties. Nevertheless, we will also communicate information to
your portfolio manager(s) when you ask us to, when market or economic conditions make it
prudent to do so, etc.
Item 8: Client Contact with Portfolio Manager
Our clients may directly contact their portfolio manager(s) with questions or concerns by calling
the number on this Brochure.
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Item 9: Additional Information
Disciplinary Information
We have determined that our firm and management have no disciplinary information to disclose.
Other Financial Industry Activities and Affiliations
No Northbrook Financial employee is registered, or have an application pending to register, as a
broker-dealer or a registered representative of a broker-dealer.
No Northbrook Financial employee is registered, or have an application pending to register, as a
futures commission merchant, commodity pool operator or a commodity trading advisor.
Northbrook Financial does not have any related parties. As a result, we do not have a relationship
with any related parties.
Northbrook Financial only receives compensation directly from Clients. We do not receive
compensation from any outside source. We do not have any conflicts of interest with any outside
party.
Elliot Pepper is a CPA and Managing Member of Northbrook Tax, LLC, a tax planning and
preparation firm. Mr. Pepper spends approximately 25 hours per week (15 hours per week during
trading hours) on this activity. Michael Delaney is also a Member of Northbrook Tax, LLC. Mr.
Delaney spends approximately 5 hours per week (5 hours per week during trading hours) on this
activity. Advisory Clients of Northbrook Financial Planning, LLC may, but are not required to,
engage Northbrook Tax, LLC, a separate entity, to provide tax services. Clients who do so will
remit fees to Northbrook Financial Planning, LLC and Northbrook Financial Planning, LLC will
remit fees for tax services to Northbrook Tax, LLC.
Recommendations or Selections of Other Investment Advisers
As referenced in Item 4 of this brochure, Northbrook Financial recommends Clients to Outside
Managers to manage their accounts. In the event that we recommend an Outside Manager, please
note that we do not share in their advisory fee. Our fee is separate and in addition to their
compensation (as noted in Item 5) and will be described to you prior to engagement. You are not
obligated, contractually or otherwise, to use the services of any Outside Manager we
recommend. Additionally, Northbrook Financial will only recommend an Outside Manager who
is properly licensed or registered as an investment adviser.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the
best interests of each Client. Our Clients entrust us with their funds and personal information,
which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core
aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm
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also adheres to the Code of Ethics and Professional Responsibility adopted by the CFP® Board
of Standards Inc., and accepts the obligation not only to comply with the mandates and
requirements of all applicable laws and regulations but also to take responsibility to act in an
ethical and professionally responsible manner in all professional services and activities.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance
with each of its specific provisions will not shield associated persons from liability for personal
trading or other conduct that violates a fiduciary duty to advisory Clients. A summary of the
Code of Ethics' Principles is outlined below.
•
Integrity - Associated persons shall offer and provide professional services with integrity.
Objectivity - Associated persons shall be objective in providing professional
•
services to Clients.
Competence - Associated persons shall provide services to Clients competently
•
and maintain the necessary knowledge and skill to continue to do so in those areas in
which they are engaged.
Fairness - Associated persons shall perform professional services in a manner that
•
is fair and reasonable to Clients, principals, partners, and employers, and shall disclose
conflict(s) of interest in providing such services.
•
Confidentiality - Associated persons shall not disclose confidential Client
information without the specific consent of the Client unless in response to proper legal
process, or as required by law.
• Professionalism - Associated persons' conduct in all matter shall reflect the credit
of the profession.
•
Diligence - Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we
require all firm access persons to attest to their understanding of and adherence to the Code of
Ethics at least annually. Our firm will provide a copy of its Code of Ethics to any Client or
prospective Client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflicts of
Interest
Neither our firm, its associates or any related person is authorized to recommend to a Client or
effect a transaction for a Client, involving any security in which our firm or a related person has
a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, etc.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
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Our firm and its “related persons” may buy or sell securities similar to, or different from, those
we recommend to Clients for their accounts. In an effort to reduce or eliminate certain conflicts
of interest involving the firm or personal trading, our policy may require that we restrict or
prohibit associates’ transactions in specific reportable securities transactions. Any exceptions or
trading pre-clearance must be approved by the firm principal in advance of the transaction in an
account, and we maintain the required personal securities transaction records per regulation.
Trading Securities At/Around the Same Time as Client’s Securities
From time to time, our firm or its “related persons” may buy or sell securities for themselves at
or around the same time as clients. This may provide an opportunity for representatives of
Northbrook Financial to buy or sell securities before or after recommending securities to clients
resulting in representatives profiting off the recommendations they provide to clients. Such
transactions may create a conflict of interest; however, Northbrook Financial will never engage
in trading that operates to the client’s disadvantage if representatives of Northbrook Financial
buy or sell securities at or around the same time as clients.
The Custodian and Brokers We Use (Charles Schwab)
The custodian and brokers we use maintain custody of your assets that we manage, although we
may be deemed to have limited custody of your assets due to our ability to withdraw fees from
your account
We recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered
broker-dealer, member SIPC, as the qualified custodian. We are independently owned and
operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account
and buy and sell securities when we instruct them to. While we recommend that you use Schwab
as custodian broker, you will decide whether to do so and will open your account with Schwab
by entering into an account agreement directly with them. We do not open the account for you,
although we may assist you in doing so. Even though your account is maintained at Schwab, we
can still use other brokers to execute trades for your account as described below (see “Your
brokerage and custody costs”).
Your brokerage and custody costs
For our clients’ accounts that Schwab maintains, 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, many
mutual funds and ETFs) may not incur Schwab commissions or transaction fees.
Products and services available to us from Schwab
Schwab Advisor ServicesTM is Schwab’s business serving independent investment advisory
firms like us. They provide our clients and us with access to their institutional brokerage services
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(trading, custody, reporting and related services), many of which are not typically available to
Schwab retail customers. 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 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 may not directly benefit you
Schwab also makes available to us other products and services that benefit us but may not
directly benefit you or your account. These products and services assist us in managing and
administering our clients’ accounts. They include investment research, both Schwab’s own and
that of third parties. We may 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, compliance, legal, and business needs
• Publications and conferences on practice management and business succession do not
require that you maintain your account with Schwab, based on our interest in receiving
Schwab’s services that benefit our business and Schwab’s payment for services for which we
would otherwise have to pay rather than based on your interest in receiving the best value in
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custody services and the most favorable execution of your transactions. This is a potential
conflict of interest. We believe, however, that our selection 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 not
Schwab’s services that benefit only us.
The Custodian and Brokers We Use (Altruist)
For the benefit of no commissions or transaction fees, fully digital account opening, a large
variety of security options and complete integration with software tools to produce better client
outcomes, Northbrook Financial recommends Altruist Financial LLC, an unaffiliated
SEC-registered broker dealer and FINRA/SIPC member, as the introducing broker to Apex
Clearing Corporation, an unaffiliated SEC-registered broker dealer and FINRA/SIPC member, as
the clients' custodian.
Review of Accounts
Michael J. Delaney II, Co-Founder and CCO of Northbrook Financial, will work with Clients to
obtain current information regarding their assets and investment holdings and will review this
information as part of our financial planning services. Northbrook Financial does not provide
specific reports to financial planning Clients, other than financial plans.
Client accounts with the Investment Advisory Service will be reviewed regularly on a quarterly
basis by Michael J. Delaney II, Co-Founder and CCO. The account is reviewed with regards to
the Client’s investment policies and risk tolerance levels. Events that may trigger a special
review would be unusual performance, addition or deletions of Client imposed restrictions,
excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per
Client's needs.
Clients will receive trade confirmations from the broker(s) for each transaction in their accounts
as well as monthly or quarterly statements and annual tax reporting statements from their
custodian showing all activity in the accounts, such as receipt of dividends and interest.
Northbrook Financial will not provide written reports to Investment Advisory Clients.
Client Referrals
We do not receive any economic benefit, directly or indirectly, from any third party for advice
rendered to our clients. Nor do we, directly or indirectly, compensate any person who is not
advisory personnel for client referrals.
Financial Information
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Registered investment advisors are required in this Item to provide you with certain financial
information or disclosures about our financial condition. We have no financial commitment that
impairs our ability to meet contractual and fiduciary commitments to clients, and we have not
been the subject of a bankruptcy proceeding.
Item 10 Requirements for State-Registered Advisors
Material Relationships That Management Persons Have With Issuers of Securities
Northbrook Financial Planning, LLC, nor any management person, has any relationship or
arrangement with issuers of securities.
950 MASS CODE REGS. 12.205(8)(d) 203(A)(a)
The client can obtain the disciplinary history of Northbrook Financial Planning, LLC, or its
representatives from the Division upon request.
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