View Document Text
ITEM 1 - COVER PAGE
Obsidian Personal Planning Solutions, LLC
2099 GAITHER RD., SUITE 110
ROCKVILLE, MD 20850
TELEPHONE: 301-990-4395
FACSIMILE: 301-990-8746
WWW.OBSIDIANPERSONALPLANNINGSOLUTIONS.COM
March 15, 2025
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Obsidian Personal
Planning Solutions, LLC (“Obsidian”). If you have any questions about the contents of this brochure,
please contact us at 301-990-4395. The information in this brochure has not been approved or verified
by the United States Securities and Exchange Commission or by any state securities authority.
Additional information about Obsidian Personal Planning Solutions, LLC is available on the SEC's
website at www.adviserinfo.sec.gov by searching CRD# 168342.
Obsidian Personal Planning Solutions, LLC is a registered investment adviser. Registration with the
United States Securities and Exchange Commission or any state securities authority does not imply a
certain level of skill or training.
ITEM 2 - MATERIAL CHANGES
Form ADV Part 2 requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure,
the adviser is required to notify you and provide you with a description of the material changes.
Since our last annually updated brochure, dated March 25, 2024, we have made the following material
changes:
Item 10: Added in insurance affiliation language
•
If you would like another copy of this Brochure, please download it from the SEC Website as indicated
above, or you may contact our Chief Compliance Officer, Patrick Carroll, at 301-990-4395 or
patrick.carroll@obsidianplanning.com.
We encourage you to read this document in its entirety.
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 2
ITEM 3 - TABLE OF CONTENTS
ITEM 1 - COVER PAGE _____________________________________________________________________ 1
ITEM 2 - MATERIAL CHANGES ______________________________________________________________ 2
ITEM 3 - TABLE OF CONTENTS _____________________________________________________________ 3
ITEM 4 - ADVISORY BUSINESS ______________________________________________________________ 4
ITEM 5 - FEES AND COMPENSATION ________________________________________________________ 8
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT _______________________ 12
ITEM 7 - TYPES OF CLIENTS ______________________________________________________________ 12
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ________________ 12
ITEM 9 - DISCIPLINARY INFORMATION ______________________________________________________ 16
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS _________________________ 16
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING _______________________________________________________________________________ 17
ITEM 12 - BROKERAGE PRACTICES ________________________________________________________ 18
ITEM 13 - REVIEW OF ACCOUNTS __________________________________________________________ 22
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ___________________________________ 22
ITEM 15 - CUSTODY ______________________________________________________________________ 24
ITEM 16 - INVESTMENT DISCRETION _______________________________________________________ 24
ITEM 17 - VOTING CLIENT SECURITIES _____________________________________________________ 25
ITEM 18 - FINANCIAL INFORMATION ________________________________________________________ 25
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 3
ITEM 4 - ADVISORY BUSINESS
DESCRIPTION OF SERVICES AND FEES
Obsidian Personal Planning Solutions, LLC (“Obsidian”) is a registered investment adviser with
a business model built on flexibility (a network of Investment Adviser Representatives ("IARs")) and is
primarily based in Rockville, MD. We are organized as a limited liability company under the laws of the
State of Maryland. We have been providing investment advisory services since 2013. Obsidian Planning
Holdings, LLC. is our principal owner, which is owned by Patrick and Todd Feldman. Patrick Carroll is
our Chief Compliance Officer and can be reached at 301-990-4395. Currently, we offer the following
investment advisory services, which are personalized to each individual client:
• Discretionary
• Non-Discretionary
• Third-Party Money Management
• Legacy Positions
• Financial Planning/Consulting Services
• Retirement Plan Consulting
• Portfolio Management Services
• Wrap Fee Program
We primarily invest in cash, equities, bonds, ETFs, U.S. Government Treasuries, Corporate Bonds,
Municipal Bonds, and Mutual Funds. Where deemed appropriate, we may recommend that our clients
invest in alternative assets, including Environmental, Social, and Governance Strategies (“ESG”).
The following paragraphs describe our services and fees. Please refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services to your
individual needs. As used in this brochure, the words "we", "our" and "us" refer to Obsidian Personal
Planning Solutions, LLC and the words "you", "your" and "client" refer to you as either a client or
prospective client of our firm.
PERSONAL FINANCIAL PLANNING - THE LIFESTYLE PROTECTOR PROCESS™
The Lifestyle Protector Process™ is designed to help you navigate your personal financial plan, step-
by-step. The ultimate goal of this tool is to help protect and grow client’s wealth.
Why Use the Lifestyle Protector Process™?
We created this process because many successful people have financial experience but lack confidence
in their ability to preserve their lifestyle for the future. We ask our clients to consider the following
questions:
• Do you have clear, written financial goals and the financial knowledge you need to manage your
affairs optimally?
• Do you have proper financial and estate plans in place?
• Do you have a clear idea of your financial condition?
• Do you know if you can afford to contribute to your community and/or charities in the future?
• Are your investments appropriate for your needs?
• Do you have money in low-yielding investments?
• Will your children be left paying large amounts of estate tax?
• Do you have enough of the right type of insurance?
• Are you in danger of being taken advantage of by financial product salespeople?
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 4
If you are uncertain about any of the above answers, the Lifestyle Protector Process™ is designed to
help our clients resolve any unresolved questions or lingering doubts about their financial future.
The Lifestyle Protector Process™ is designed to help protect and grow money, maintain a desired
lifestyle, and preserve and enhance a family legacy. Using our four-step process, we work with our clients
every step of the way using our full suite of tools and experience gained over the past 26 years of working
with our clients. We will help clients understand their current situation, both strengths and weaknesses,
and create a powerful vision for their future. We then look at any roadblocks standing in the way, develop
strategies designed to overcome them, and review all of the tools to help our clients achieve their vision.
Our initial consultation is complimentary. You must promptly notify our firm if your financial situation,
goals, objectives, or needs change. You are under no obligation to act on our financial planning
recommendations. Should you choose to act on any of our recommendations, you are not obligated to
implement the financial plan through any of our other investment advisory services.
RETIREMENT PLAN CONSULTING
We offer retirement plan services to plan sponsors and/or plan trustees. These services are focused on
education and communications
to plan participants. Typically, services involve advice and/or
recommendations of investments available in the participant's plan, such as fund selection, investment
options, and educational seminars.
PORTFOLIO MANAGEMENT SERVICES
We offer discretionary and non-discretionary portfolio management services. Through our IARs, the firm
manages individually tailored investment portfolios for clients. We provide continuous advice regarding
the investment of client funds based on the individual needs of the client. The firm conducts ongoing
investment research and investment model development/analysis for individualized client portfolios.
Through personal discussions in which goals and objectives based on a client's particular circumstances
are established by the firm, a client's personal investment policy or individual investment plan is
developed, and a portfolio based on that policy or plan is created and managed. During the data-
gathering process, the firm will typically determine the client’s individual objectives, time horizons, risk
tolerance, net worth, net income, age, tax situation, liquidity needs, and other suitability factors, as
necessary.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow us to determine
the specific securities, and the amount of securities, to be purchased or sold for your account without
your approval prior to each transaction. Discretionary authority is typically granted by the investment
advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit
our discretionary authority (for example, limiting the types of securities that can be purchased for your
account) by providing our firm with your restrictions and guidelines in writing.
Clients have the ability to place reasonable restrictions on the types of investments that may be
purchased in an account, however we retain the right to decline to enter into a management agreement
with any clients whose investment are contrary to the firm’s investment strategies.
In all cases, clients have a direct and beneficial interest in their securities, rather than an undivided
interest in a pool of securities. We do have limited authority to direct the Custodian to deduct our
investment advisory fees from your accounts, but only with the appropriate written authorization from
clients.
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 5
Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically,
these are assets that are ineligible to be custodied at our primary custodian. Clients will engage us to
advise on certain investment products that are not maintained at their primary custodian, such as variable
life insurance, annuity contracts, and assets held in employer sponsored retirement plans and qualified
tuition plans (i.e., 529 plans).
You are advised and are expected to understand that our past performance is not a guarantee of future
results. Certain market and economic risks exist that adversely affect an account’s performance. This
could result in capital losses in your account.
IREBAL
Obsidian Planning Solutions uses software, iRebal, to model and allocate securities to client
accounts. iRebal is utilized in the process of determining position sizing and to allocate block
trades to individual accounts. iRebal provides the dollars/shares of a given security to purchase
based on the size of the account and the percent allocation of that security for the relevant model.
The iRebal software ensures necessary cash is available and prevents accounts from being
overbought. Members of the Obsidian Planning Solutions Portfolio Management team reviews
iRebal orders before execution. Obsidian Planning Solutions uses block trading for instruments
with variable inter day pricing to facilitate best execution and to ensure all clients receive identical
pricing when being allocated the same security on the same day.
SELECTION OF OTHER ADVISERS
As part of our investment advisory services, we may recommend that you use the services of a third-
party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. Investment
advice and trading of securities will only be offered by or through the chosen TPMM. Our firm will not
offer advice on any specific securities or other investments in connection with this service. Prior to
referring clients, our firm will provide initial due diligence on third-party money managers and ongoing
reviews of their management of client accounts. In order to assist in the selection of a TPMM, our firm
will gather client information pertaining to financial situation, investment objectives, and reasonable
restrictions to be imposed upon the management of the account.
Our firm will periodically review third-party money manager reports provided to the client at least
annually. Our firm will contact clients from time to time in order to review their financial situation and
objectives; communicate information to third-party money managers as warranted; and assist the client
in understanding and evaluating the services provided by the TPMM. Clients will be expected to notify
our firm of any changes in their financial situation, investment objectives, or account restrictions that
could affect their financial standing.
Our firm takes actions on behalf of the client to hire or fire money managers used in the implementation
of a client’s investment plan and execution of the Advisory Agreement with our Firm. Therefore, the firm
has the discretionary authority to hire or fire the manager or to allocate assets among managers without
obtaining the Client’s consent.
The services provided by the TPMM include:
Implementation of an asset allocation.
• Assessment of the client's investment needs and objectives.
•
• Delivery of suitable style allocations (e.g., Large Cap, Small Cap, Growth, Value, etc.)
• Facilitation of portfolio transactions.
• Ongoing monitoring of investment vehicles performance.
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 6
• Review of client accounts for adherence to policy guidelines and asset allocation.
• Recommendations for account re-balancing, if and when necessary.
• Reporting of client portfolio performance and progress.
• Engaging selected investment vehicles on behalf of the client
DISCRETIONARY INVESTMENT MANAGEMENT OF ADVISOR VARIABLE ANNUITY
CONTRACTS
Where appropriate, the Firm may also provide advice about any type of legacy position or other
investment held in client portfolios. If appropriate, we can provide recommendations for advisor variable
annuities. Clients can engage us to manage and/or advise on certain investment products that are not
maintained at their primary custodian, such as annuity contracts and assets held in employer sponsored
retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, we direct or recommend
the allocation of client assets among the various investment options available with the product, including
the initial purchase of the advisor variable annuity contract. These assets are generally maintained at
the underwriting insurance company, or the custodian designated by the product’s provider.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
A client or prospect leaving an employer typically has four options regarding an existing retirement plan
(and may engage in a combination of these options): (i) leave the money in the former employer’s plan,
if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are
permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value
(which could, depending upon the client’s age, result in adverse tax consequences). Our Firm may
recommend an investor roll over plan assets to an IRA for which our Firm provides investment advisory
services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a
recommendation that a client or prospective client leave their plan assets with their previous employer
or roll over the assets to a plan sponsored by a new employer will generally result in no compensation
to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets into
an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest,
there are various factors that our Firm will consider before recommending a rollover, including but not
limited to: (i) the investment options available in the plan versus the investment options available in an
IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and
responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets
from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi)
employer stock tax consequences, if any. All rollover recommendations are reviewed by our Firm’s Chief
Compliance Officer and remains available to address any questions that a client or prospective client
has regarding the oversight.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice
to you regarding your retirement plan account or individual retirement account, we are also fiduciaries
within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal
Revenue Code, as applicable, which are laws governing retirement accounts. We have to act in your
best interest and not put our interest ahead of yours. At the same time, the way we make money creates
some conflicts with your interests.
WRAP FEE PROGRAM
We are the sponsor and manager of the Obsidian’s Wrap Program (the “Program”), a wrap fee program
(i.e., an arrangement where brokerage commissions and transaction costs are absorbed by us). The fee
covers transaction costs or commissions resulting from the management of your accounts, however,
most investments trade without transaction fees today, so our payment of these and other incidental
custodial related expenses should not be considered a significant factor in determining the relative value
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 7
of our wrap program. Participants in the Program may pay a higher aggregate fee than if brokerage
services are purchased separately. Additional information about the Program is available in Obsidian’s
Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm’s Form ADV.
TYPES OF INVESTMENTS
We offer advice on all types of investments including any investments we deem appropriate based on
your stated goals and objectives. We may also provide advice on any type of investment held in your
portfolio at the inception of our advisory relationship. You may request that we refrain from investing in
particular securities or certain types of securities. You must provide these restrictions to our firm in
writing.
ASSETS UNDER MANAGEMENT
As of December 31, 2024, our Firm had $407,184,278 in regulatory assets under management, we
provide continuous management services for $341,650,397, which was managed on a discretionary
basis and $65,533,880 on a non-discretionary basis..
ITEM 5 - FEES AND COMPENSATION
PERSONAL FINANCIAL PLANNING - THE LIFESTYLE PROTECTOR PROCESS™
Obsidian Planning Solutions provides financial planning services for clients for a fixed fee, which
generally ranges between $3,400 and $50,000. The fee is not negotiable. The fee is set depending upon
the complexity and scope of the plan, your financial situation, and your objectives. The financial planning
services to be provided consist of specific financial issues as selected in the financial planning
agreement. Fixed fees are payable to the firm with an initial retainer and a monthly retainer thereafter.
Other payable arrangements can be negotiated with the client. We will not require prepayment of a fee
more than six months in advance and in excess of $1,200. Should the engagement last longer than six
months between acceptance of the Financial Planning Agreement and delivery of the financial plan, any
prepaid unearned fees will be promptly returned to you less a pro-rata charge for bona fide financial
planning services rendered to date.
You may terminate your Financial Planning Agreement by providing written notice to our firm. You will
incur a pro-rata charge for services rendered prior to the termination of the agreement. If you have pre-
paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees.
RETIREMENT PLAN CONSULTING
For our retirement plan consulting services, we charge up to 100 basis points (100 basis points equals
1%) of the participant's retirement plan value payable quarterly in arrears based on the average daily
value of the account on the last day of the previous quarter. The fee is negotiable at the firms’ discretion.
You may terminate this service by providing written notice to our firm. You will incur a pro-rata charge
for services rendered prior to the termination of the agreement.
PORTFOLIO MANAGEMENT SERVICES
Our fee for portfolio management services is based on a percentage of the assets we manage. Our
maximum fee is 130 basis points (130 basis points equals 1.3%) of total assets. Our annual portfolio
management fee is billed and payable quarterly in advance based on the average daily value of your
account on the last day of the previous quarter. If the portfolio management agreement is executed at
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 8
any time other than the first day of a calendar quarter, our fees will apply on a pro-rata basis, which
means that the advisory fee is payable in proportion to the number of days in the quarter for which you
are a client. If Client deposits assets (cash and/or securities) with a market value of ten-thousand dollars
($10,000) or more in an account on any given day after the inception of a calendar quarter, the amount
of such deposit shall immediately become subject to an additional pro-rated fee in accordance with the
agreed upon Fee Schedule; Client shall be entitled to a fee rebate calculated in the same manner if
account assets are withdrawn in excess of this amount on any given day. Cash and cash equivalents
and any margin debt balances are included in the calculation of advisory fees, unless otherwise noted
and agreed to in the executed Agreement. Our advisory fee is negotiable, depending on individual client
circumstances.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. For example, we may combine account values for you and your
minor children, joint accounts with your spouse, and other types of related accounts. Combining account
values may increase the asset total, which may result in your paying a reduced advisory fee.
We will deduct our fee directly from your account through the qualified custodian holding your funds and
securities. We will deduct our advisory fee only when you have given our firm written authorization
permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an
account statement to you at least quarterly. These account statements will show all disbursements from
your account. You should review all statements for accuracy.
You may terminate the portfolio management agreement upon 30 days' written notice to our firm. Should
termination occur within the first twelve (12) months, an administrative processing fee may apply. You
will incur a pro-rata charge for services rendered prior to the termination of the portfolio management
agreement, which means you will incur advisory fees only in proportion to the number of days in the
quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you
will receive a prorated refund of those fees.
Upon termination, you are responsible for monitoring the securities in your account, and we will have no
further obligation to act or advise with respect to those assets. In the event of client’s death or disability,
we will continue management of the account until we are notified of client’s death or disability and given
alternative instructions by an authorized party.
SELECTION OF THIRD-PARTY MONEY MANAGERS
We do not charge you a separate fee for the selection of third-party money managers (“TPMM”). We will
share in the advisory fee you pay directly to the TPMM. The advisory fee you pay to the TPMM is
established and payable in accordance with the brochure provided by each TPMM to whom you are
referred. These fees may or may not be negotiable. Our compensation may differ depending upon the
individual agreement we have with each TPMM. As such, a conflict of interest exists where our firm or
persons associated with our firm has an incentive to recommend one TPMM over another TPMM with
whom we have more favorable compensation arrangements or other advisory programs offered by
TPMMs with whom we have less or no compensation arrangements.
You may be required to sign an agreement directly with the recommended TPMM(s). You may terminate
your advisory relationship with the TPMM according to the terms of your agreement with the TPMM. You
should review each MM's brochure for specific information on how you may terminate your advisory
relationship with the TPMM and how you may receive a refund, if applicable. You should contact the
TPMM directly for questions regarding your advisory agreement with the TPMM.
DISCRETIONARY INVESTMENT MANAGEMENT OF VARIABLE ANNUITY CONTRACTS
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 9
We will not charge or receive a direct management fee for the investment, supervision, and management
of the insurance/variable annuity contract(s) and/or sub-accounts for legacy assets. Obsidian and/or
certain related entities may, however, share certain administrative costs and services with our investment
advisor representatives. The Insurance Company and/or any affiliated entities may charge certain fees
and expenses, which may be identified in the prospectus.
For advisor variable annuity contracts recommended by us, the advisory fee will be paid in advance
based upon a percentage of the market value on the last day of the calendar quarter not to exceed 1.3%
annually. The insurance company issuing the variable annuities will charge management expenses and
possibly exchange in addition and separate from the investment advisory fees charged by us. The
product prospectus contains more details about the additional fees that apply.
ADDITIONAL FEES AND EXPENSES
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and Exchange Traded Funds (ETFs). The fees that you pay to our firm for investment
advisory services are separate and distinct from the fees and expenses charged by mutual funds or
exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will
generally include a management fee and other fund expenses.
COMPENSATION FOR THE SALE OF SECURITIES OR OTHER INVESTMENT
PRODUCTS
Persons providing investment advice on behalf of our firm may be registered representatives and/or
investment adviser representatives of Osaic Wealth, Inc. (“Osaic”), a securities broker-dealer, and a
member of the Financial Industry Regulatory Authority and the Securities Investor Protection
Corporation. In their capacity as registered representatives and/or investment adviser representatives,
these persons may receive commission-based compensation in connection with the purchase and sale
of securities. Compensation earned by these persons in their capacities as registered representatives
and/or registered investment adviser representatives is separate and in addition to our advisory fees.
This practice may present a conflict of interest because persons providing investment advice on behalf
of our firm who are registered representatives and/or investment adviser representatives may have an
incentive to effect securities transactions for the purpose of generating commissions rather than solely
based on your needs. When appropriate, we may recommend the purchase of “no-load” funds. You are
under no obligation, contractually or otherwise, to purchase securities products through any person
affiliated with our firm.
Persons providing investment advice on behalf of our firm may be licensed as independent insurance
agents. These persons may earn commission-based compensation for selling insurance products,
including insurance products they sell to you. Insurance commissions earned by these persons are
separate and in addition to our advisory fees. This practice may present a conflict of interest because
persons providing investment advice on behalf of our firm who are insurance agents may have an
incentive to recommend insurance products to you for the purpose of generating commissions rather
than solely based on your needs. You are under no obligation, contractually or otherwise, to purchase
insurance products through any person affiliated with our firm.
IRA ROLLOVER CONSIDERATIONS
As part of our investment advisory services to you, we may recommend that you withdraw the assets
from your employer's retirement plan and roll the assets over to an individual retirement account ("IRA")
that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our
management, we will charge you an asset-based fee as set forth in the agreement you executed with
our firm. This practice presents a conflict of interest because persons providing investment advice on
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 10
our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based
compensation rather than solely based on your needs. You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation
to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options
are available, you should consider the costs and benefits of each.
An employee will typically have four options:
• Leaving the funds in your employer's (former employer's) plan.
• Moving the funds to a new employer’s retirement plan.
• Cashing out and taking a taxable distribution from the plan.
• Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage
you to speak with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points
to consider before you do so:
• Determine whether the investment options in your employer's retirement plan address your needs
or whether you might want to consider other types of investments.
o Employer retirement plans generally have a more limited investment menu than IRAs.
o Employer retirement plans may have unique investment options not available to the public
such as employer securities, or previously closed funds.
• Your current plan may have lower fees than our fees.
o
If you are interested in investing only in mutual funds, you should understand the cost
structure of the share classes available in your employer's retirement plan and how the
costs of those share classes compare with those available in an IRA.
o You should understand the various products and services you might take advantage of at
an IRA provider and the potential costs of those products and services.
• Our strategy may have higher risk than the option(s) provided to you in your plan.
• Your current plan may also offer financial advice.
•
If you keep your assets titled in a 401k or retirement account, you could potentially delay your
required minimum distribution beyond age 70.5.
• Your 401k may offer more liability protection than a rollover IRA; each state may vary.
o Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA
assets have been generally protected from creditors in bankruptcies. However, there can
be some exceptions to the general rules, so you should consult with an attorney if you
are concerned about protecting your retirement plan assets from creditors.
• You may be able to take out a loan on your 401k, but not from an IRA.
•
•
IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
and may also be subject to a 10% early distribution penalty unless they qualify for an exception
such as disability, higher education expenses or the purchase of a home.
If you own company stock in your plan, you may be able to liquidate those shares at a lower
capital gains tax rate.
• Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important that you understand the differences between these types of accounts and to decide
whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 11
adviser representative, or call our main number as listed on the cover page of this brochure.
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
We do not accept performance-based fees or participate in side-by-side management. Performance-
based fees are fees that are based on a share of capital gains or capital appreciation of a client’s
account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-
based fees. Our fees are calculated as described in the Fees and Compensation section above and are
not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your
advisory account.
ITEM 7 - TYPES OF CLIENTS
We offer investment advisory services to individuals, high-net-worth individuals, trusts, partnerships,
retirement plans, and charitable organizations.
In general, we require a minimum of $50,000 to open and maintain a portfolio management account. At
our discretion, we may waive this minimum account size. For example, we may waive the minimum if
you appear to have significant potential for increasing your assets under our management. We may also
combine account values for you and your minor children, joint accounts with your spouse, and other
types of related accounts to meet the stated minimum.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK
OF LOSS
OUR METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
We may use one or more of the following methods of analysis when providing investment advice to you:
TECHNICAL ANALYSIS
Involves studying past price patterns, trends, and interrelationships in the financial markets to
assess risk-adjusted performance and predict the direction of both the overall market and specific
securities.
The risk of market timing based on technical analysis is that our analysis may not accurately detect
anomalies or predict future price movements. Current prices of securities may reflect all information
known 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.
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 and its industry. The resulting data is
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 12
used to measure the true value of the company's stock compared to the current market value.
The risk of fundamental analysis is that 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.
CYCLICAL ANALYSIS
A type of technical analysis that involves evaluating recurring price patterns and trends.
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.
We may use long term purchases, short term purchases, margin transactions, and/or option writing
as investment strategies when managing your account(s). None of these strategies are a
fundamental part of our overall investment strategy, but we may use one or more occasionally
when we determine that they are suitable given your stated investment objectives and tolerance
for risk.
In the event of Selection of Other Advisors, we will not perform quantitative or qualitative analysis
of individual securities. Instead, we will advise you on how to allocate your assets among various
classes of securities or third-party money managers. We primarily rely on investment model
portfolios. We may recommend replacing the MM and/or sub-adviser if there is a significant
deviation in characteristics or performance from the stated strategy and/or benchmark.
TAX CONSIDERATIONS
Our strategies and investments may have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the
management of your assets. Regardless of your account size or any other factors, we strongly
recommend that you consult with a tax professional regarding the investing of your assets.
Moreover, as a result of revised IRS regulations, custodians and broker-dealers will begin reporting the
cost basis of equities acquired in client accounts on or after January 1, 2011. Your custodian will default
to the FIFO (First-In First-Out) accounting method for calculating the cost basis of your investments. You
are responsible for contacting your tax advisor to determine if this accounting method is the right choice
for you. If your tax advisor believes another accounting method is more advantageous, please provide
written notice to our firm immediately and we will alert your account custodian of your individually
selected accounting method. Please note that decisions about cost-basis accounting methods will need
to be made before trades settle, as the cost-basis method cannot be changed after settlement.
RISK OF LOSS
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully identify
market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot
offer any guarantees or promises that your financial goals and objectives will be met. Past performance
is in no way an indication of future performance.
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 13
RECOMMENDATION OF PARTICULAR TYPES OF SECURITIES
As disclosed under the Advisory Business section in this brochure, we recommend all types of
securities and we do not necessarily recommend one particular type of security over another since
each client has different needs and different tolerance for risk. Each type of security has its own
unique set of risks associated with it and it would not be possible to list here all of the specific risks
of every type of investment. Even within the same type of investment, risks can vary widely.
However, in very general terms, the higher the anticipated return of an investment, the higher the
risk of loss associated with that investment.
MUTUAL FUNDS AND ETFS
Mutual funds and exchange traded funds (ETFs) are professionally managed collective investment
systems that pool money from many investors and invest in stocks, bonds, short-term money
market instruments, other mutual funds, other securities or any combination thereof. The fund will
have a manager that trades the fund's investments in accordance with the fund's investment
objective. While mutual funds and ETFs generally provide diversification, risks can be significantly
increased if the fund is concentrated in a particular sector of the market, primarily invests in small
cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or
concentrates in a particular type of security (i.e., equities) rather than balancing the fund with
different types of securities. Exchange traded funds differ from mutual funds since they can be
bought and sold throughout the day like stock and their price can fluctuate throughout the day. The
returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while
some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types
of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be
"closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors
indefinitely whereas "closed end" funds have a fixed number of shares to sell which can limit their
availability to new investors.
We may include mutual funds and exchange traded funds, (“ETFs”) in our investment strategies.
Our policy is to purchase institutional share classes of those mutual funds selected for the client’s
portfolio. The institutional share class generally has the lowest expense ratio. The expense ratio is
the annual fee that all mutual funds or ETFs charge their shareholders. It expresses the percentage
of assets deducted each fiscal year for funds expenses, including 12b-1 fees, management fees,
administrative fees, operating costs, and all other asset-based costs incurred by the fund. Some
fund families offer different classes of the same fund and one share class may have a lower
expense ratio than another share class. These expenses come from client assets which could
impact the client’s account performance. Mutual fund expense ratios are in addition to our fee, and
we do not receive any portion of these charges. If an institutional share class is not available for
the mutual fund selected, the adviser will purchase the least expensive share class available for
the mutual fund. As share classes with lower expense ratios become available, we may use them
in the client’s portfolio, and/or convert the existing mutual fund position to the lower cost share
class. Clients who transfer mutual funds into their accounts with us would bear the expense of any
contingent or deferred sales loads incurred upon selling the product. If a mutual fund has a frequent
trading policy, the policy can limit a client’s transactions in shares of the fund (e.g., for rebalancing,
liquidations, deposits or tax harvesting). All mutual fund expenses and fees are disclosed in the
respective mutual fund prospectus.
NON-TRANSACTION FEE (NTF) MUTUAL FUNDS
When selecting investments for our clients’ portfolios we might choose mutual funds on your
account custodian’s Non-Transaction Fee (NTF) list. This means that your account custodian will
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 14
not charge a transaction fee or commission associated with the purchase or sale of the mutual
fund.
The mutual fund companies that choose to participate in your custodian’s NTF fund program pay
a fee to be included in the NTF program. The fee that a mutual fund company pays to participate
in the program is ultimately borne by the owners of the mutual fund including clients of our Firm.
When we decide whether to choose a fund from your custodian’s NTF list or not, we consider our
expected holding period of the fund, the position size and the expense ratio of the fund versus
alternative funds. Depending on our analysis and future events, NTF funds might not always be in
your best interest.
OTHER RISKS OF LOSS MAY INCLUDE
• Market Risk - Even a long-term investment approach cannot guarantee a profit. Economic,
political, and issuer-specific events will cause the value of securities to rise or fall. Because the
value of investment portfolios will fluctuate, there is the risk that you will lose money and your
investment may be worth more or less upon liquidation.
• Foreign Securities and Currency Risk - Investments in international and emerging-market
securities include exposure to risks such as currency fluctuations, foreign taxes and regulations,
and the potential for illiquid markets and political instability.
• Capitalization Risk - Small-cap and mid-cap companies may be hindered as a result of limited
resources or less diverse products or services Their stocks have historically been more volatile
than the stocks of larger, more established companies.
•
Interest Rate Risk - In a rising rate environment, the value of fixed-income securities generally
declines, and the value of equity securities may be adversely affected.
• Credit Risk - Credit risk is the risk that the issuer of a security may be unable to make interest
payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a
perceived change in an issuer’s financial strength may affect a security’s value and thus, impact
the fund’s performance.
• Securities Lending Risk - Securities lending involves the risk that the fund loses money
because the borrower fails to return the securities in a timely manner or at all. The fund could
also lose money if the value of the collateral provided for loaned securities, or the value of the
investments made with the cash collateral, falls. These events could also trigger adverse tax
consequences for the fund.
• Performance of Underlying Managers - We select the mutual funds and ETFs in the asset
allocation portfolios. However, we depend on the manager of such funds to select individual
investments in accordance with their stated investment strategy.
• Cybersecurity Risk - In addition to the Material Risks listed above, investing involves various
operational and “cybersecurity” risks. These risks include both intentional and unintentional
events at Obsidian or one of its third-party counterparties or service providers, that may result
in a loss or corruption of data, result in the unauthorized release or other misuse of confidential
information, and generally compromise our Firm’s ability to conduct its business. A
cybersecurity breach may also result in a third-party obtaining unauthorized access to our
clients’ information, including social security numbers, home addresses, account numbers,
account balances, and account holdings. We have established business continuity plans and
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 15
risk management systems designed to reduce the risks associated with cybersecurity
breaches. However, there are inherent limitations in these plans and systems, including that
certain risks may not have been identified, in large part because different or unknown threats
may emerge in the future. As such, there is no guarantee that such efforts will succeed,
especially because we do not directly control the cybersecurity systems of our third-party
service providers. There is also a risk that cybersecurity breaches may not be detected.
ITEM 9 - DISCIPLINARY INFORMATION
Obsidian Personal Planning Solutions, LLC has been registered and providing investment advisory
services since 2013. Neither our firm nor any of our management persons has any reportable disciplinary
information.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Persons providing investment advice on behalf of our firm who are registered representatives
and/or investment adviser representatives of Osaic may recommend Osaic to you for securities and
advisory services. For information on our brokerage practices, please refer to the Brokerage Practices
section of this brochure.
We may recommend one or more of our affiliations as described below if appropriate and suitable for
your needs. Our advisory services are separate and distinct from the fees paid to our affiliates for their
respective services. We are affiliated with the following companies through common control and
ownership:
• Obsidian Planning Holding, LLC, holding company that owns entities 2-7 listed below. 80% is
owned by Julie Carroll and 20% by Patrick Carroll
• Obsidian Business Planning Solutions, LLC, a business planning company
• 401(k) Compliance Solution, LLC, a plan sponsor consulting company; analyzes and makes
recommendations on 401k plans
Obsidian Personal Planning Solutions, Inc. a financial services company
• Next Chapter Program, LLC, financial services for individuals who have lost a family member;
owned by Patrick Carroll
• Coordinated Trust Services, LLC, a trust funding service company; Reviews trust funding
• M Group Insurance, LLC, licensed as an insurance agency
• Overture Holdings LLC, an operations management company for marketing, IT, tax reporting and
internal retirement plan. Overture owns 100% of a tax preparation company. There is now
revenue share between the tax preparation company and any of the entities listed above. Patrick
Carroll owns 50% of Overture Holdings, LLC
ARRANGEMENTS WITH AFFILIATED ENTITIES
In the event we refer you to an affiliate of ours, there may be a conflict of interest because we may have
a financial incentive to recommend our affiliate's services. While we believe that compensation charged
by our affiliate is competitive, such compensation may be higher than fees charged by other firms
providing the same or similar services. You are under no obligation to use our affiliate service and may
obtain comparable services and/or lower fees through other firms.
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 16
BROKER-DEALER
Certain IARs of our Firm are registered representatives of Osaic Wealth, Inc. (“Osaic”), a FINRA-
registered broker-dealer and member of SIPC and will be compensated for effecting securities
transactions or providing advisory services. A portion of the time of these IARs is spent in connection
with broker/dealer activities.
As a broker-dealer, Osaic engages in a broad range of activities normally associated with securities
brokerage firms. Pursuant to the investment advice given by our Firm or its IARs, investments in
securities may be recommended for clients. If Osaic is selected as the broker-dealer, Osaic and its
registered representatives, including IARs of our Firm, may receive commissions for executing securities
transactions.
You are advised that if Osaic is selected as the broker-dealer, the transaction charges may be higher or
lower than the charges you may pay if the transactions were executed at other broker/dealers. You
should note, however, that you are under no obligation to purchase securities through IARs of our Firm
or Osaic.
Our Firm may provide advice regarding investment company securities. You should be aware that, in
addition to the advisory fees you pay in connection with any of our Firm’s program, each investment
company also pays its own separate investment advisory fees and other expenses. Such fees and
expenses are disclosed in the mutual fund’s prospectus. In addition, clients should be aware that mutual
funds may be purchased separately, independent of the investment management services of our Firm.
Moreover, you should note that under the rules and regulations of FINRA, Osaic has an obligation to
maintain certain client records and perform other functions regarding certain aspects of the investment
advisory activities of its registered representatives. These obligations require Osaic to coordinate with
and have the cooperation of its registered representatives that operate as, or are otherwise associated
with, investment advisers other than Osaic.
INSURANCE COMPANIES
In their individual capacities, some of our Firm’s IARs are agents for various third-party insurance
companies. As such, these individuals may receive separate yet customary commission compensation
for implementing product transactions on our advisory Clients' behalf. Clients, however, are not obligated
to engage IARs when considering implementing advisory or insurance recommendations. Implementing
any or all recommendations is solely at the Client's discretion.
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
DESCRIPTION OF OUR CODE OF ETHICS
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for persons associated with our firm.
Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary
duties of honesty, good faith, and fair dealing with you. All persons associated with our firm are expected
to adhere strictly to these guidelines. Persons associated with our firm are also required to report any
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 17
violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably
designed to prevent the misuse or dissemination of material, non-public information about you or your
account holdings by persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone
number on the cover page of this brochure.
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
Neither our firm nor any persons associated with our firm has any material financial interest in client
transactions beyond the provision of investment advisory services as disclosed in this brochure.
PERSONAL TRADING PRACTICES
Our firm or persons associated with our firm may buy or sell securities for you at the same time we or
persons associated with our firm buy or sell such securities for our own account. A conflict of interest
exists in such cases because we have the ability to trade ahead of you and potentially receive more
favorable prices than you will receive. To mitigate this conflict of interest, it is our policy that neither our
firm nor persons associated with our firm shall have priority over your account in the purchase or sale of
securities.
ITEM 12 - BROKERAGE PRACTICES
We generally recommend that our clients utilize Charles Schwab & Co., Inc. Advisor Services
("Schwab"), a registered broker-dealer, Member SIPC, as the qualified Custodian. Our Firm is
independently owned and operated and unaffiliated with Schwab. Schwab will hold Client assets in a
brokerage account and buy and sell securities when our Firm instructs them.
While our Firm recommends that Clients use Schwab as a Custodian, Clients must decide whether to
do so and open accounts with Schwab by entering into account agreements directly with them. The
Client opens the accounts with Schwab. The accounts will always be held in the Client's name and never
in our Firm’s.
How Our Firm Selects Custodian-Broker
Our Firm seeks to recommend a Custodian-Broker who will hold Client assets and execute the
transactions on terms that are, overall, most advantageous compared to other available providers and
their services. Our Firm considers a wide range of factors, including, among others:
• Combination of transaction execution and asset custody services (generally without a separate
fee for custody).
• Capability to execute, clear, and settle trades (buy and sell securities for Client accounts).
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payments, etc.).
• The breadth of available investment products (stocks, bonds, mutual funds, exchange-traded
funds [ETFs], etc.).
• Availability of investment research and tools that assist us in making investment decisions.
• Quality of services.
• Competitiveness of the price of those services (commission rates, other fees, etc.) and
willingness to negotiate the prices.
• Reputation, financial strength, and stability.
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 18
• Prior service to our Firm and our other Clients.
• Availability of other products and services that benefit our Firm, as discussed below (see
“Products And Services Available To Us From Schwab”).
Client Brokerage & Custody Costs
For Clients' accounts, Schwab maintains and generally does not charge separately for custody services.
However, Schwab receives compensation by charging ticket charges or other fees on trades it executes
or settling into Clients' Schwab accounts. In addition to commissions, Schwab charges a flat dollar
amount as a "prime broker" or "trade away" fee for each trade that our Firm has executed by a different
broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled)
into a Client’s Schwab account. These fees are in addition to the ticket charges or compensation the
Client pays the executing broker-dealer. Because of this, our Firm has Schwab execute most trades for
Client accounts to minimize trading costs. Our Firm has determined that having Schwab execute most
trades is consistent with our duty to seek the "best execution" of Client trades. Best execution means
the most favorable terms for a transaction based on all relevant factors, including those listed above (see
How Our Firm Selects Custodian-Broker).
Products And Services Available To Us From Schwab
Schwab Advisor Services™ (formerly called Schwab Institutional®) provides independent investment
advisory Firms and Clients with access to its institutional brokerage, 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; others help us manage and grow our business. Schwab’s support services generally
are available on an unsolicited basis and at no charge to our Firm. These are typically considered soft
dollar benefits because there is an incentive to do business with Schwab. Receiving soft dollar benefits
creates a conflict of interest. We have established policies in this regard to mitigate any conflicts of
interest. We believe our selection of Schwab as Custodian-Broker is in the Clients' best interests. Our
Firm will always act in the best interest of our Clients and act as fiduciary in carrying out services to
Clients. The following is a more detailed description of Schwab’s support services:
Services That Benefit Our Clients
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 we might not otherwise have access to or would require a significantly
higher minimum initial investment by our Clients. Schwab’s services described in this paragraph
generally benefit our Clients and their accounts.
Services That May Not Directly Benefit Our Clients
Schwab also makes other products and services available that benefit our Firm but may not directly
benefit our Clients or their accounts. These products and services assist our Firm in managing and
administering our Clients’ accounts. They include investment research, both Schwab’s own and that of
third parties. Our Firm may use this research to service all or a substantial number of our Client's
accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab
also makes available software and other technology that:
• Provides 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.
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 19
• Assist with back-office functions, recordkeeping, and Client reporting.
Services That Generally Benefit Only Us
Schwab also offers other services to help our Firm 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
• Access to employee benefits providers, human capital consultants, and insurance providers
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors
to provide the services to our Firm. Schwab may also discount or waive its fees for some of these
services or pay all or a part of a third party’s fees. Schwab may also provide our Firm with other benefits,
such as occasional business entertainment for our personnel.
Our Interest in Schwab’s Services
• The availability of these services from Schwab benefits our Firm because we do not have to
produce or purchase them. These services are not contingent upon our Firm committing any
specific amount of business to Schwab in trading commissions. We believe our selection of
Schwab as Custodian and Broker is in our Client’s best interests.
• Some of the products, services, and other benefits provided by Schwab benefit our Firm and may
not benefit our Client accounts. Our recommendation or requirement that you place assets in
Schwab's custody may be based, in part, on the benefits Schwab provides to our Firm or our
Agreement to maintain certain Assets Under Management at Schwab and not solely on the
nature, cost, or quality of custody and execution services provided by Schwab.
• Our Firm places trades for our Clients' accounts subject to its duty to seek the best execution
and other fiduciary duties. Schwab's execution quality may be different from other broker-dealers.
• Our Firm does not routinely recommend, request, or require that the Client direct us to execute
the transactions through a specified Custodian. Additionally, our Firm typically does not permit
the Client to direct brokerage. We place trades for Client accounts subject to our duty to seek
the best execution and other fiduciary duties.
We will aggregate trades for ourselves or our associated persons with your trades, providing that the
following conditions are met:
• Our policy for the aggregation of transactions shall be fully disclosed separately to our existing
Clients (if any) and the broker/dealer(s) through which such transactions will be placed.
• We will only aggregate transactions if we believe that aggregation is consistent with our duty to
seek the best execution (which includes the duty to seek the best price) for the Client and is
consistent with the terms of our investment advisory agreement.
• No advisory Client will be favored over any other Client; each Client that participates in an
aggregated order will participate at the average share price for all transactions in a given security
on a given business day, with transaction costs based on each Client's participation in the
transaction.
• Our Firm will prepare a written statement (“Allocation Statement”) specifying the participating
•
Client accounts and how to allocate the order among those Clients.
If the aggregated order is filled in its entirety, it will be allocated among Clients per the allocation
statement; if the order is partially filled, the accounts that did not receive the previous trade's
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 20
positions should be "first in line" to receive the next allocation.
• Notwithstanding the preceding, the order may be allocated on a basis different from that specified
if all Client accounts receive fair and equitable treatment. The reason for the difference in
allocation will be documented and reviewed by our Firm’s Compliance Officer. Our Firm’s books
and records will separately reflect, for each Client account, the orders which are aggregated, and
the securities held by and bought for that account.
• Our Firm will not receive additional compensation or remuneration of any kind because of the
proposed aggregation; and
Individual advice and treatment will be accorded to each advisory Client.
•
Brokerage For Client Referrals
Our Firm does not receive Client referrals from any Custodian or third party in exchange for using that
broker-dealer or third party.
Aggregation & Allocation of Transactions
Our Firm may aggregate transactions if it believes that aggregation is consistent with the duty to seek
the best execution for its Clients and is consistent with the disclosures made to Clients and terms defined
in the Investment Advisory Agreement. No Client will be favored over any other Client. Each account in
an aggregated order will participate at the average share price (per Custodian) for all transactions in that
security on a given business day.
If we do not receive a complete fill for an aggregated order, we will allocate the order on a pro-rata basis.
If we determine that a pro-rata allocation is not appropriate under the particular circumstances, we will
base the allocation on other relevant factors, which may include:
• When only a small percentage of the order is executed, with respect to purchase allocations,
allocations may be given to accounts high in cash.
• Concerning sale allocations, allocations may be given to accounts low in cash.
• We may allocate shares to the account with the smallest order, to the smallest position, or to an
account that is out of line concerning security or sector weightings relative to other portfolios with
similar mandates.
•
•
• We may allocate one account when that account has limitations in its investment guidelines
prohibiting it from purchasing other securities that we expect to produce similar investment
results, and other accounts can purchase that in the block.
If an account reaches an investment guideline limit and cannot participate in an allocation, we
may reallocate shares to other accounts. For example, this may be due to unforeseen changes
in an account's assets after placing an order.
If a pro-rata allocation of a potential execution would result in a de minimis allocation in one or
more account(s), we may exclude the account(s) from the allocation.
• Our Firm will document the reasons for any deviation from a pro-rata allocation.
Trade Errors
Our Firm has implemented procedures designed to prevent trade errors; however, our Firm cannot
always avoid Client trade errors.
Consistent with our Firm's fiduciary duty, it is our Firm’s policy to correct trade errors in a manner that is
in the Client's best interest. In cases where the Client causes the trade error, the Client will be
responsible for any loss resulting from the correction. Depending on the specific circumstances of the
trade error, the Client may not be able to receive any gains generated due to the error correction. In all
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 21
situations where the Client does not cause the trade error, the Client will be made whole, and we would
absorb any loss resulting from the trade error if our Firm caused the error. If the Custodian causes the
error, the Custodian will cover all trade error costs. If an investment error results in a gain when correcting
the trade, the gain will be donated to charity. Our Firm will never benefit or profit from trade errors.
Directed Brokerage
Our Firm does not routinely recommend, request, or require that the Client direct us to execute the
transaction through a specified broker-dealer. Additionally, our Firm typically does not permit the Client
to direct brokerage. Our Firm places trades for Client accounts subject to its duty to seek the best
execution and other fiduciary duties.
ITEM 13 - REVIEW OF ACCOUNTS
FINANCIAL PLANNING REVIEWS
We will review your financial plan annually upon executing an Agreement to ensure the financial
planning services provided to you, and the portfolio mix, are consistent with your stated investment
needs and objectives. Additional reviews may be conducted based on various circumstances, including,
but not limited to:
the review of your financial plan, or
the review of statements you receive from your third-party money manager or account custodian.
• any investment account(s), or
•
•
At your request, we may meet with you and/or your third-party money manager(s) to discuss asset
allocation, but we will not make recommendations regarding specific investments or provide any regular
written reports to you.
PORTFOLIO MANAGEMENT SERVICES
Each Investment Adviser Representative (IAR) is ultimately responsible for reviewing his/her client’s
investment portfolios. IARs will continuously monitor the underlying securities within client accounts as
well as any selected third-party managers/programs and perform at least annual formal account reviews.
Accounts are reviewed for consistency with client investment strategy, asset allocation, risk tolerance
and performance relative to the appropriate benchmark. More frequent reviews may be triggered by
changes in an account holder’s personal, tax or financial status.
Quarterly written performance reports are made available to you electronically and will contain relevant
account and/or market-related information such as an inventory of account holdings and account
performance. You will receive written or electronic trade confirmations and monthly or quarterly
statements from your account custodian(s).
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
ECONOMIC BENEFITS PROVIDED TO THE ADVISORY FIRM FROM EXTERNAL
SOURCES AND CONFLICTS OF INTEREST
As disclosed under Item 12 Brokerage Practices, we participate in the Custodian’s institutional customer
programs, and we may recommend a Custodian to our Clients for custody and brokerage services. There
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 22
is no direct link between our participation in the program and the investment advice we give to our Clients.
However, we receive economic benefits through our participation in the program that is typically not
available to any other independent advisors participating in the program. These benefits include the
following products and services (provided without cost or at a discount):
• Receipt of duplicate Client statements and confirmations.
• Research-related products and tools.
• Consulting services.
• Access to a trading desk serving adviser participants.
• Access to block trading (which provides the ability to aggregate securities transactions for
execution and then allocate the appropriate shares to Client accounts);
• The ability to have advisory fees deducted directly from Client accounts.
• Access to an electronic communications network for Client order entry and account information.
• Access to mutual funds with no transaction fees and certain institutional money Managers.
• Discounts on compliance, marketing, research, technology, and practice management products
or services provided to us by third-party vendors.
Custodians may also have paid for business consulting and professional services received by some of
our IARs. Some of the products and services made available by Custodians through the program may
benefit us but may not benefit your account. These products or services may assist us in managing and
administering Client accounts, including accounts not maintained at our recommended Custodian. Other
services made available by the Custodian are intended to help us manage and further develop our
business enterprise. The benefits our Firm or our IARs receive through participation in the program do
not depend on the amount of brokerage transactions directed to the Custodian. Due to these
arrangements, our Client does not pay more for assets maintained at Schwab. As part of our fiduciary
duties to Clients, we always endeavor to put our Client's interests first. Clients should be aware, however,
that receiving economic benefits from our Firm or our IARs in and of itself creates a conflict of interest
because the cost of these services would otherwise be borne directly by us. These arrangements could
indirectly influence our choice of Custodian for custody and brokerage services. Clients should consider
these conflicts of interest when selecting a Custodian. The products and services provided by the
Custodian, how they benefit us, and the related conflicts of interest are described above.
As disclosed under the Fees and Compensation section in this brochure, persons providing investment
advice on behalf of our firm are licensed insurance agents and are registered representatives
and/or investment adviser representatives with Osaic, a securities broker-dealer, and a member of the
Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. For
information on the conflicts of interest this presents, and how we address these conflicts, please refer to
the Fees and Compensation section.
We do not directly or indirectly use, employ, or compensate non-employee (outside) consultants,
individuals, and/or entities (Promotor) for client referrals.
Our Firm may be asked to recommend a financial professional, such as an attorney, accountant, or
mortgage broker. In such cases, our Firm does not receive any direct compensation in return for any
referrals made to individuals or firms in our professional network. Clients must independently evaluate
these firms or individuals before engaging in business with them and clients have the right to choose
any financial professional to conduct business. Individuals and firms in our financial professional network
may refer clients to our Firm. Again, our Firm does not pay any direct compensation in return for any
referrals made to our Firm. Our Firm does recognize the fiduciary responsibility to place your interests
first and have established policies in this regard to mitigate any conflicts of interest.
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 23
OTHER PROFESSIONALS
Our Firm may refer business to estate planning attorneys, accountants, insurance brokers, and other
professionals. However, we do not receive monetary or other material compensation for referring Clients
to such professionals. We also do not pay any person or firm commissions or other items of material
value for referring Clients to us. If we receive or offer an introduction to a Client, we do not pay or earn
a referral fee, nor are there established quid pro quo arrangements. Each Client can accept or deny such
referral or subsequent services.
ITEM 15 - CUSTODY
We do not have physical custody, as it applies to investment advisors. Custody has been defined by
regulators as having access or control over client funds and/or securities.
DEDUCTION OF ADVISORY FEES
For all accounts, our Firm has the authority to have fees deducted directly from client accounts. Our
Firm has established procedures to ensure all client funds and securities are held at a qualified custodian
in a separate account for each client under that client’s name. Clients, or an independent representative
of the client, will direct, in writing, the establishment of all accounts and therefore are aware of the
qualified custodian’s name, address, and the way the funds or securities are maintained. Finally, account
statements are delivered directly from the qualified custodian to each client, or the client’s independent
representative, at least quarterly. You should carefully review those statements and are urged to
compare the statements against reports received from Obsidian Planning Solutions. When you have
questions about your account statements, you should contact Obsidian Planning Solutions or the
qualified custodian preparing the statement.
Please refer to Item 5 for more information about the deduction of advisor fees.
STANDING LETTERS OF AUTHORIZATION (“SLOA”)
Our Firm is deemed to have custody of clients’ funds or securities when clients have standing
authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) and,
under that SLOA, it authorizes us to designate the amount or timing of transfers with the custodian. The
SEC has set forth a set of standards intended to protect client assets in such situations, which we follow.
We do not have a beneficial interest on any of the accounts we are deemed to have Custody where
SLOAs are on file. In addition, account statements reflecting all activity on the account(s), are delivered
directly from the qualified custodian to each client or the client’s independent representative, at least
quarterly. You should carefully review those statements and are urged to compare the statements
against reports received from us. When you have questions about your account statements, you should
contact us, your Advisor or the qualified custodian preparing the statement.
ITEM 16 - INVESTMENT DISCRETION
For discretionary accounts, prior to engaging us to provide investment advisory services, you will enter
a written Agreement with us granting the Firm the authority to supervise and direct, on an on-going basis,
investments in accordance with the client’s investment objective and guidelines. In addition, you will
need to execute additional documents required by the Custodian to authorize and enable us, in our sole
discretion, without prior consultation with or ratification by you, to purchase, sell, or exchange securities
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 24
in and for your accounts. We are authorized, in our discretion and without prior consultation with you to:
(1) buy, sell, exchange and trade any stocks, bonds or other securities or assets and (2) determine the
amount of securities to be bought or sold, and (3) place orders with the custodian. Any limitations to
such discretionary authority will be communicated to our Firm in writing by you, the client.
The limitations on investment and brokerage discretion held by us for you are:
• For discretionary accounts, we require that we be provided with authority to determine which
securities and the amounts of securities to be bought or sold.
• Any limitations on this discretionary authority shall in writing as indicated on the investment
advisory Agreement, Appendix B. You may change/amend these limitations as required.
In some instances, we may not have discretion. We will discuss all transactions with you prior to
execution or you will be required to make the trades if in an employer sponsored account.
ITEM 17 - VOTING CLIENT SECURITIES
We will not vote proxies on your behalf. You are welcome to vote proxies or designate an independent
third-party at your own discretion. You designate proxy voting authority in the custodial account
documents. You must ensure that proxy materials are sent directly to you or your assigned third party.
We do not take action with respect to any securities or other investments that become the subject of any
legal proceedings, including bankruptcies. Clients can contact our office with questions about a particular
solicitation by phone at 301-990-4395.
Class Action Suits A class action is a procedural device used in litigation to determine the rights of and
remedies, if any, for large numbers of people whose cases involve common questions of law and/or fact.
Class action suits frequently arise against companies that publicly issue securities, including securities
recommended by investment advisors to clients. With respect to class action suits and claims, you (or
your agent) will be responsible for class actions or bankruptcies involving securities purchased for or
held in your account. We do not provide such services and are not obligated to forward copies of class
action notices we may receive to you or your agents.
ITEM 18 - FINANCIAL INFORMATION
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in
advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year.
Finally, we have not been the subject of a bankruptcy petition at any time.
Obsidian Planning Solutions
Form ADV Part 2A | March 2025
Page - 25