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One Day In July LLC
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of One Day In July LLC.
If you have any questions about the contents of this brochure, please contact us at (802) 503-8280 or by
email at: compliance@onedayinjuly.com. The information in this brochure has not been approved or verified
by the United States Securities and Exchange Commission or by any state securities authority.
Additional information about One Day In July LLC, including information regarding the disciplinary
history of One Day In July LLC or its representatives, is also available on the SEC’s website at
www.adviserinfo.sec.gov. One Day In July LLC’s CRD number is: 284335.
77 College St. #3A
Burlington, VT 05401
(802) 503-8280
compliance@onedayinjuly.com
https://www.onedayinjuly.com
UPDATED: February 4, 2026
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Item 2: Material Changes
One Day In July LLC (hereinafter, “ODIJ”) filed an annual updating amendment using the Form
ADV Part 2A on January 30, 2026.
With this amendment, ODIJ included a clarification regarding the environmental investing
service, which focuses on low-carbon investment strategies. This update explains that ODIJ
seeks to construct portfolios with a lower weighted-average carbon intensity for clients that elect
to participate in this service. Please refer to Item 4.B. and Item 8.A. for additional details.
An additional clarification was made to explain that inaccurate or insufficient information
provided to ODIJ about a client’s retirement accounts could lead to incorrect calculations for
required minimum distributions. This could result in the assessment of additional taxes and
penalties by the IRS against the client. Please see Item 4.C. for more information.
Another material change included in this filing is that supervised persons of ODIJ, in addition to
clients and compliance officers, have the authority to terminate an investment advisory contract,
provided that the notification is delivered in writing. Please refer to Item 5.A. for further details.
A fourth material change is that the tranche breakpoint inflation calculations have been changed
to round up to certain defined increments. Please refer to Item 5.A. for additional details.
A fifth material change is that supervised persons of ODIJ can receive compensation for client
referrals in the form of a monetary bonus or increased commission. This compensation does not
result in any additional charge to the client. Please see Item 14.B. for more details.
ODIJ also added a disclosure about highly leveraged funds and cryptocurrency or digital
currency-related assets. ODIJ considers these assets to be high risk and prohibits their purchase in
client Accounts by the firm’s investment personnel. Please see Item 8.A. for more information.
This annual updating amendment follows an interim amendment to ODIJ’s ADV Part 2A that
was filed on September 4, 2025, for the primary purpose of updating the firm’s Chief
Compliance Officer from Jayne Bills to Daniel Cunningham.
The foregoing discusses only material changes since ODIJ’s prior annual updating amendment
of Form ADV Part 2A filed on January 31, 2025.
Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes ........................................................................................................................... 2
Item 3: Table of Contents ........................................................................................................................... 2
Item 4. Advisory Business.......................................................................................................................... 4
A. Description of the Advisory Firm .................................................................................................... 4
B. Types of Advisory Services ............................................................................................................... 4
C. Client Tailored Services and Client Imposed Restrictions ........................................................... 8
D. Wrap Fee Programs ........................................................................................................................... 9
E. Assets under Management ................................................................................................................ 9
Item 5: Fees and Compensation .............................................................................................................. 10
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A. Fee Schedule ..................................................................................................................................... 10
B. Payment of Fees ................................................................................................................................ 14
C. Client Responsibility for Third-Party Fees ................................................................................... 15
D. Prepayment of Fees .......................................................................................................................... 15
E. Outside Compensation for the Sale of Securities to Clients ....................................................... 16
Item 6: Performance-Based Fees and Side-By-Side Management ...................................................... 16
Item 7: Types of Clients ............................................................................................................................ 16
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ................................................ 16
A. Methods of Analysis and Investment Strategies ......................................................................... 16
B. Material Risks Involved ................................................................................................................... 18
C. Risks of Specific Securities Utilized ............................................................................................... 19
Item 9: Disciplinary Information ............................................................................................................ 21
Item 10: Other Financial Industry Activities and Affiliations ............................................................ 21
Item 11: Code of Ethics, Participation or Interest in Client Transactions, Personal Trading, and
Rollovers ..................................................................................................................................................... 21
A. Code of Ethics ................................................................................................................................... 21
B. Personal Trading Practices for Representatives of ODIJ ............................................................ 22
C. Rollover Disclosure .......................................................................................................................... 22
Item 12: Brokerage Practices .................................................................................................................... 22
A. Factors Used to Select Custodians and / or Broker-Dealers ..................................................... 22
1. Research and Other Soft-Dollar Benefits ................................................................................... 23
2. Brokerage for Client Referrals ..................................................................................................... 23
3. Clients Directing Which Broker-Dealer and/or Custodian to Use........................................ 23
B. Aggregating (Block) Trading for Multiple Client Accounts....................................................... 24
Item 13: Review of Accounts ................................................................................................................... 24
Item 14: Client Referrals and Other Compensation ............................................................................. 24
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes
Sales Awards or Other Prizes) ............................................................................................................ 24
B. Compensation to Non – Advisory Personnel for Client Referrals ............................................ 25
Item 15: Custody ....................................................................................................................................... 25
Item 16: Investment Discretion ............................................................................................................... 25
Item 17: Voting Client Securities (Proxy Voting) ................................................................................. 26
Item 18: Financial Information ................................................................................................................ 26
Item 19: Requirements for State Registered Advisors ......................................................................... 26
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Item 4. Advisory Business
A. Description of the Advisory Firm
One Day In July LLC (hereinafter, “ODIJ”) is a limited liability company and SEC-registered
investment advisor. Registration does not imply a certain level of skill or training. The firm was
formed in May of 2016, and the principal owner is Daniel Cunningham. Daniel Cunningham
also serves as the firm’s Chief Compliance Officer.
B. Types of Advisory Services
Investment Advisory Services to Individuals, High Net Worth Individuals, Charitable
Organizations, Corporations or Business Entities, and Pension Plans
ODIJ offers ongoing discretionary investment advisory services based on the financial goals and
circumstances of each client. ODIJ obtains a completed Investment Suitability Questionnaire
from each client that outlines the client’s current situation (income, risk tolerance, and
investment knowledge). ODIJ also gathers information regarding the client’s current
employment status, as it is important for assessing investment suitability. ODIJ then constructs a
plan to aid in the selection of a portfolio that matches each client's specific situation and goals.
The initial plan ODIJ constructs for a client may change over time at ODIJ’s discretion. In
general, though not always, significant changes to a portfolio will be discussed with the client
prior to alteration.
Portfolio management services include, but are not limited to, the following:
Investment strategy
•
• Asset allocation
• Risk tolerance
• Environmental investing
• Personal investment policy
• Asset selection
• Annual portfolio review
• Portfolio rebalancing
ODIJ evaluates the current investments of each client with respect to their risk tolerance levels,
individual goals, objectives, and time horizon. ODIJ assists clients to meet personal financial
goals such as saving for retirement and paying for higher education.
ODIJ also offers its clients an environmental investing service focused on low-carbon investment
strategies. These strategies seek to construct portfolios with a lower weighted-average carbon
intensity and reduced exposure to companies that maintain significant fossil fuel reserves,
relative to broadly diversified traditional equity strategies. To pursue this objective, ODIJ
primarily invests in companies with relatively low carbon footprints that may or may not
engage in the production or sale of carbon-intensive products, such as oil or coal.
Investments are generally, though not exclusively, implemented through environmentally
focused exchange-traded funds (ETFs). In evaluating whether an investment is environmentally
focused, ODIJ utilizes metrics related to carbon intensity and fossil fuel reserves. Based on these
metrics, ODIJ may construct a core equity portfolio for participating clients. Clients may also
elect to include an “impact portfolio” position. This position consists of ETFs or mutual funds
that emphasize environmental objectives and may be associated with higher costs and increased
volatility compared to the client’s core equity portfolio.
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Additional information regarding the metrics used in ODIJ’s environmental investing strategies
and the impact portfolio is provided in Item 8.A. of this brochure under the heading, Investment
Strategies. The terms of the Advisory Fee (as defined in Item 5.A. of this brochure) applicable to
ODIJ’s environmental investing service are identical to such terms for the firm’s other
investment advisory services.
At the outset of its engagement, ODIJ will request discretionary authority from clients to select
securities and execute transactions without permission from the client prior to each transaction.
Risk tolerance levels are documented in the Investment Suitability Questionnaire.
ODIJ seeks to ensure that investment decisions are made in accordance with the fiduciary duties
owed to its clients and without consideration of ODIJ’s economic, investment, or other financial
interests. To meet its fiduciary obligations, ODIJ attempts to avoid, among other things,
investment or trading practices that systematically advantage or disadvantage certain client
portfolios. Accordingly, ODIJ’s policy is to seek fair and equitable allocation of investment
opportunities and transactions among its clients to avoid favoring one client over another over
time. It is also ODIJ’s policy to allocate investment opportunities and transactions it identifies as
being appropriate and prudent among its clients on a fair and equitable basis over time.
ODIJ does not provide trust administration services to its clients. Notwithstanding ODIJ accepts
discretionary authority over Accounts titled in the name of an estate planning trust, ODIJ will
not accept or exercise any authority over the administration of any trust, nor will ODIJ engage in
the interpretation or construction of any trust instrument.
Financial Planning Services
ODIJ representatives provide certain limited financial planning advice to clients in the course of
providing investment advisory services, to the extent that clients request such advice. In such
cases, clients receive planning attention focused on their specific financial and savings goals
within the context of their individual or family circumstances. Often, though not always, the
objectives will include maximizing savings and providing cash flow to investments. Other areas
of focus may include, without limitation, evaluating client resources; identifying financial time
horizons and tolerance for risk; reviewing and considering issues such as needed cash flow,
major purchase decisions, college planning, retirement planning, business exit planning, estate
planning considerations, longevity and elder care considerations; planning charitable gifts, and
the understanding the tax consequences of certain financial decisions. ODIJ provides
implementation strategies to accomplish these objectives.
ODIJ does not charge an additional fee for providing financial planning services nor does ODIJ
provide these services under a separate contract. If ODIJ provides any financial planning
services, they are included within the scope of services provided under the investment advisory
contract and the cost is included within the Advisory Fee. ODIJ recommends that its clients
regularly consult with their tax, accounting, estate planning and insurance advisors prior to and
throughout their engagement of ODIJ with respect to both financial planning strategies and
investment of their assets.
From time to time, ODIJ refers complex financial planning cases to an unaffiliated third-party
financial planner, tax planner, or other unaffiliated third-party professionals (“Third-Party
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Professionals”) to assist clients with recommendations, advice, financial planning strategies
(including tax return preparation, household payment administration, and bill payment), and
other services not directly related to ODIJ’s services. ODIJ does not receive any compensation
for these referrals. Unless otherwise indicated by ODIJ in writing, ODIJ does not perform
specific due diligence regarding Third-Party Professionals and such referrals do not constitute
endorsements by ODIJ of the Third-Party Professional or their services. Referrals to Third-Party
Professionals are made as an accommodation. ODIJ is not acting in a fiduciary capacity when
providing referrals to Third-Party Professionals. Services provided by Third-Party Professionals
are distinct from those provided by ODIJ and typically involve additional terms of service. In
instances where ODIJ maintains a business relationship with a Third-Party Professional, such a
relationship should not influence the referral or the service received by the Third-Party
Professional.
Services Provided to Custodian-Linked and Held-Away Accounts
Clients have the option to engage ODIJ to provide investment advisory services to either
Custodian-Linked or Held-Away Accounts, or both. A “Custodian-Linked Account” is an
account under management with ODIJ (“Account”) that is linked to ODIJ through a qualified
custodian, such as Charles Schwab, for purposes of executing trades in connection with ODIJ’s
investment advisory services. A “Held-Away Account” is an Account held by a custodian that is
not linked to ODIJ through a qualified custodian for purposes of providing investment advisory
services. Held-Away Accounts can include, without limitation, 403(b), 401(a), employer-
sponsored and solo 401(k), 457, SIMPLE IRA, SEP-IRA, and 529 Accounts. It should be noted
that 529 Accounts may be Custodian-Linked or Held-Away, depending upon whether the
Accounts are held by a custodian linked to ODIJ. When clients engage ODIJ to manage
Custodian-Linked Accounts, ODIJ will have automatic access to those Accounts for purposes of
making trades within, and (except with respect to 529 Accounts) deducting the Advisory Fee
from, those Accounts. When clients engage ODIJ to provide services to Held-Away Accounts,
they must grant authorization to ODIJ to access those Accounts through a platform maintained
by a third-party service provider for the purpose of reviewing Accounts, allocating investments,
making securities trades, and performing associated recordkeeping. ODIJ will not accept a
client’s login credentials to access their Held-Away Accounts. Once a client grants ODIJ
authorization to access Held-Away Accounts, ODIJ will not seek additional consents from the
client to effect individual trades. Clients who grant access to ODIJ to Held-Away Accounts do
not do so for purposes of deducting any portion of the Advisory Fee (as defined in Item 5.A.)
nor the Plan Fee (as defined in Item 5.A.). Neither the Advisory Fee nor the Plan Fee (together,
the “Fees”) are deducted from Held-Away Accounts or from 529 Accounts. Please see Item 5.B.
and Item 15 of this brochure for additional information regarding the payment of the Advisory
Fee allocable to Held-Away Accounts and 529 Accounts, as well as Advisory Fee deduction
from Custodian-Linked Accounts other than 529 Accounts.
No Investment Management Advice without Agreement
Unless otherwise specifically agreed to by ODIJ, financial planning is not designed to be specific
to any particular investment account(s). When providing a consolidated financial summary of
accounts to clients, data included may contain information provided by clients about third-party
accounts that ODIJ does not manage or with respect to which ODIJ does not provide investment
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advice. As such, clients should understand that ODIJ does not serve as the investment advisor
on all securities listed in these consolidated financial summaries. ODIJ will not supervise client
assets or provide any recommendations as to investments unless granted authority, in writing,
to manage the particular assets. Investment advisory services provided to clients are governed
by a written investment advisory agreement between ODIJ and each client.
Newsletters, Booklets, Lunch-and-Learns, Webinars, and Other Educational Events
ODIJ publishes informational newsletters at no additional cost to its clients. The newsletters are
circulated electronically to clients via electronic mail every few weeks. ODIJ also publishes a
paper booklet at no additional cost to clients that is mailed quarterly via the United States Postal
Service. ODIJ periodically offers educational webinars and “Lunch-and-Learns” or other
educational in-person events to both existing and prospective clients. Such webinars and in-
person events are generally offered free of charge.
Benefit Plan Consulting
ODIJ provides non-discretionary investment consulting services to employee benefit plans (the
“Plans”) including:
• Pension or other employee benefit plans (including 401(k) plans) governed by the Employee
Retirement Income Security Act of 1974 (ERISA); and
• 403(b) tax-sheltered annuity plans.
ODIJ provides such services to the Plans as a section 3(21) limited scope advisor and not a
section 3(38) co-fiduciary under ERISA. Under this limited scope of service, ODIJ (a) does not
accept liability in the event of a participant lawsuit and (b) does not exercise discretion over the
selection of investment options. Third-party record-keepers and third-party administrators, and
not ODIJ, provide recordkeeping and administration services to the Plans. ODIJ is not
responsible for advising Plan participants with respect to any Required Minimum Distributions
(RMDs) or for facilitating RMDs from any Plan Accounts. In addition, the Plan sponsor or its
designee has final decision-making authority regarding all investment matters.
ODIJ will work with representatives of the Plan sponsor to provide the following investment
consulting services to the Plan:
• Recommending a set of low-fee, diversified investment options for the Plan;
• Determining the course of action to take on behalf of the Plan with respect to the Plan’s
investments; and
• Providing limited education and enrollment assistance to Plan participants (specific and
individualized investment advice is not provided to Plan participants unless they enter into
a separate contract with ODIJ).
ODIJ may present Plan clients with mutual fund model asset allocation portfolios. Each model
portfolio is designed to meet a particular investment goal, such as allocations tailored to the
retirement of a hypothetical Plan participant by a specific date. Plan clients are not obligated to
select from any model asset allocation portfolio offered by ODIJ.
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Under the investment consulting agreement between the Plan and ODIJ, we do not have
discretionary authority or control over the Plan assets nor discretionary authority or control
over administration of the Plan. Advice is provided to the Plan in the form of recommendations
to the trustees. Our role is to serve as a consultant to the Plan. The consulting services provided
are limited to those assets identified on the executed investment consulting agreement between
the Plan and ODIJ.
ODIJ also provides discretionary investment advisory services to Plan participants that enter
into a contract with ODIJ. Details regarding these services can be found above under the
heading, Investment Advisory Services to Individuals, High Net Worth Individuals, Charitable
Organizations, Corporations or Business Entities, and Pension Plans.
Types of Investments
ODIJ generally limits its investment advice to ETFs, corporate bond or treasury bond ETFs,
mutual funds, fixed income securities, equity securities, real estate funds (including Real Estate
Investment Trusts or REITs), individual treasury bonds and treasury inflation-
protected/inflation-linked bonds, corporate bonds, commodities, or non-U.S. securities. ODIJ
primarily recommends a blend of index funds across asset classes to a majority of its clients but
may use other securities as well to help diversify a portfolio when applicable. Due to the fact
that some representatives of ODIJ operate independently, investment advice provided by
representatives may differ from ODIJ’s general investment principles.
Funds and investments are carefully selected based upon their costs, tracking error to
benchmarks, tax implications, breadth of the securities within the fund, assets under
management, and, where clients have selected ODIJ’s environmental investing strategy, the
weighted-average carbon footprint and fossil fuel reserve exposure of various funds’ underlying
holdings, based on available third-party data. For further information regarding the selection of
environmental investments, please refer to information provided above under the heading
Investment Advisory Services to Individuals, High Net Worth Individuals, Charitable
Organizations, Corporations or Business Entities, and Pension Plans (also in Item 4.B. above
this section) and Item 8.A. of this brochure.
While ODIJ generally recommends passively managed, low-cost ETFs or mutual funds, during
the period when a non-Plan client transitions Account(s) to ODIJ, and potentially thereafter,
such Account(s) may contain non-index fund holdings such as individual stocks, bonds, mutual
funds not defined as an index fund, annuities, or other investments. This may be due to client
preference, taxable gain avoidance, or other reasons such as (with respect to annuities) the
inability to trade due to custodian-imposed restrictions. Investments are made subject to client
objectives. Within the context of a client’s investment plan, ODIJ will periodically rebalance the
portfolio to asset class allocation targets, including any contributions and withdrawals. Due to
variances in market conditions, asset allocation guidelines are not necessarily strictly followed.
Between rebalance periods, cash may accumulate in a client’s Account(s) as a result of
dividends, interest payments, or new asset contributions and may remain in cash until the next
rebalance.
C. Client Tailored Services and Client Imposed Restrictions
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ODIJ will tailor a program for each individual client. With respect to Plan clients, ODIJ will
work with Plan trustees or other representatives to recommend a set of low-fee, diversified
investment options. Ultimately, the Plan’s trustees or other representatives will decide whether
to accept or modify the set of investment options ODIJ recommends.
With respect to non-Plan clients, ODIJ will conduct an interview session to get to know the
client’s specific needs and requirements and develop an initial investment plan that ODIJ will
execute on behalf of the client. Each customized investment plan will consider the client’s
personal restrictions, needs, and targets. ODIJ manages portfolios in the context of each client's
financial and other objectives, risk tolerances, and cash flow needs. Clients may impose
restrictions on investing in certain securities or types of securities in accordance with their
values or beliefs. Portfolios do not follow investment plans exactly. Rather, they are structured
using the investment plans as benchmarks and may be modified as client needs or objectives
change over time. Investment plans may also change over time as a result of discussions
between ODIJ and the client without completion of an updated written investment plan or
Investment Suitability Questionnaire.
In the course of providing services to clients who are at or nearing retirement age or clients with
inherited Individual Retirement Accounts (IRAs), ODIJ makes guidance available to clients
regarding Required Minimum Distributions (“RMDs”) from their tax-qualified retirement
Accounts. Any guidance that ODIJ provides with respect to RMDs is only applicable with
respect to IRAs; 401(k), 403(b), 401(a), or 457 accounts; or other qualified Accounts under
management with ODIJ and only for the year or years that they are under management with
ODIJ. ODIJ does not have access to information about accounts not under management, nor to
information about Accounts that are currently under management relating to years or periods
before or after they were under management with ODIJ. Because ODIJ is not a law firm or an
accounting form, clients are urged to speak to their legal and tax advisors about RMDs from all
of their qualified accounts, including accounts that are under management with ODIJ. Where
ODIJ provides guidance regarding RMDs from Account(s) that were under management for
only a portion of a given year, ODIJ must rely upon the client to provide information regarding
the Account(s) for the portion of the year that the Account(s) were not under management.
Inaccurate or insufficient information provided by the client could lead to errors in calculating
RMDs. If a client provides inaccurate or insufficient information to ODIJ about the client’s
retirement accounts, RMDs could be calculated incorrectly and as a result, the IRS could assess
additional taxes and penalties against the client due to insufficient distributions from their
qualified accounts.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative fees. ODIJ
does not participate in any wrap fee programs.
E. Assets under Management
ODIJ has the following assets under management:
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Discretionary Amounts:
Non-discretionary Amounts:
Calculated as of:
12/31/25
$ 1,349,229,936
$ 14,479,000
ODIJ’s non-discretionary assets under management include assets of the Plans for which ODIJ
serves solely as a consultant and does not have discretionary authority or the ability to execute
trades or make any other changes directly within the Plan Accounts.
Item 5: Fees and Compensation
The specific Fee that ODIJ charges each client is established in a client’s written agreement with
ODIJ, subject to inflationary adjustments as further described in this Item 5. The Fees detailed
below, including the minimum Advisory Fee, apply to new clients of ODIJ. Client agreements
entered into prior to the date of this brochure may be governed by fee schedules different from
those that are described in this Item 5.
A. Fee Schedule
Individuals, High Net Worth Individuals, Charitable Organizations, Corporations or Business
Entities, and Pension Plans
The annual fee for individuals, high net worth individuals, charitable organizations,
corporations or business entities, and pension plans (the “Advisory Fee”) that is allocable to
clients’ Custodian-Linked Accounts that are not 529 Accounts is based upon the “tranches,” or
assets under management brackets, described as follows: for assets under management up to
$600,000, the Advisory Fee is 0.75%; for assets under management between $600,001 and
$2,500,000, the annual Advisory Fee is 0.50%; for assets under management between $2,500,001
and $23,600,000, the Advisory Fee is 0.25%; for assets under management between $23,600,001
and $117,800,000, the Advisory Fee is 0.125%; for assets under management over $117,800,000,
the Advisory Fee is negotiable.
With respect to the Custodian-Linked Accounts (other than 529 Accounts), ODIJ charges a
minimum annual Advisory Fee of $1,200, which is billed in 12 equal monthly installments over
the course of a year. This minimum annual Advisory Fee applies only to Custodian-Linked
Accounts (other than 529 Accounts), but it is not in addition to the tranche-based Advisory Fee
detailed in the preceding paragraph. The Advisory Fee for Held-Away and 529 Accounts is
separate and distinct from the Advisory Fee for Custodian-Linked Accounts. The annual
Advisory Fee allocable to clients’ Held-Away Accounts and 529 Accounts is charged at a flat
rate of one-half of one percent (0.50%) of the asset value in those Accounts.
The Advisory Fee for assets under management between $0.00 and $23,600,000.00 is generally
not negotiable. In rare instances, ODIJ may offer a discount to a client with whom we maintain a
relationship or agree to charge an Advisory Fee based upon the aggregate assets under
management with ODIJ owned by members of a single household or family. If a client is the
grantor or trustee of a trust that is also a client, occasionally, ODIJ may calculate the Advisory
Fee charged to the client and the trust as if the assets of each were included in the assets under
management of the other. However, such discounts are highly unusual, and clients should not
assume that members of an immediate family will receive one. Unless granted as a period of
uncharged initial months of service, any such discount usually applies only to the portion of the
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Advisory Fee allocable to Custodian-Linked Accounts and not to any portion of the Advisory
Fee allocable to Held-Away Accounts, unless ODIJ agrees otherwise.
In the event that a representative of ODIJ with whom a client maintains a relationship ceases
providing investment advisory services on behalf of ODIJ, ODIJ will discontinue any Advisory
Fee discounts granted to such client by such representative.
In addition, as a marketing promotion, ODIJ, in its sole discretion, may offer a new client or an
existing client a benefit for transferring (additional) assets to ODIJ for management. This
promotional benefit may be in the form of a cash discount, rebate, or gift card. Such promotional
offers are not considered gifts and are permitted in limited situations, in accordance with special
programs being offered firm-wide.
The client or ODIJ may terminate the investment advisory contract, without penalty, upon
written notice to the other.
In general, there is a combined Account minimum of $60,000, which may be waived by ODIJ in
its discretion. If the combined Account minimum is waived, then the minimum Advisory Fee
may be reduced. ODIJ’s Account minimum is subject to change over time, generally in line with
the inflationary adjustments described below. Any update to the Account minimum will be
disclosed in an amendment to ODIJ’s Form ADV Part 2A.
The tranche breakpoints set forth above shall be adjusted for inflation every three years based
upon the U.S. Department of Labor Bureau of Labor Statistics Consumer Price Index
(“Consumer Price Index”), using the existing tranche breakpoints as starting points. Inflationary
adjustments for tranche breakpoints under $20,000,000 shall be rounded up to the nearest
$100,000, while adjustments to tranche breakpoints between $20,000,000 and $100,000,000 shall
be rounded up to the nearest $1,000,000 and adjustments to tranche breakpoints over
$100,000,000 shall be rounded up to the nearest $5,000,000. The minimum Advisory Fee of
$1,200 per year shall be adjusted for inflation every three years and rounded up to the nearest
$100 based upon the Consumer Price Index. ODIJ made the most recent adjustments to the
tranche breakpoints and Advisory Fee minimums effective as of February 1, 2024, and will make
the next adjustments in 2027. Such adjustments shall not become effective until after their
disclosure on ODIJ’s annual updating amendment to the Form ADV Part 2A filed during the
first quarter of the year in which they will become effective. Certain legacy clients are provided
services under a different fee schedule, which may include a lower minimum Advisory Fee.
Such legacy client fee schedules are generally also subject to the inflationary adjustments
described above. Other than increases resulting from inflationary increases, clients shall be
given thirty (30) days’ prior written notice of any proposed increase in the Advisory Fee. Any
increase in the Advisory Fee that is not related to an inflationary increase shall be accompanied
by an amendment to the investment advisory contract (or execution of a new one) with
signatures from both parties evidencing acceptance of the new fee.
Employee Benefit Plans (401(k) and 403(b) Plans)
The annual fee for the Plans (the “Plan Fee”) is based upon tranche levels and described as
follows: for assets under management up to $600,000, the Plan Fee is 0.75%; for assets under
management between $600,001 and $2,500,000, the annual Plan Fee is 0.50%; for assets under
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management between $2,500,001 and $23,600,000, the Plan Fee is 0.25%; for assets under
management between $23,600,001 and $117,800,000, the Plan Fee is 0.125%; for assets under
management over $117,800,000, the Plan Fee is negotiable. The Plan Fee may be negotiable and
ODIJ may offer a promotional discount to Plan clients who meet certain criteria. There is no
Account minimum size or minimum Plan Fee.
The Plan or ODIJ may terminate the investment consulting agreement, without penalty, upon
written notice to the other. In most cases, if the agreement is terminated prior to the end of a
quarterly billing cycle, ODIJ will not refund a prorated portion of the Plan Fee to the Plan. Please
see below under the heading Advisory Fee and Plan Fee Calculation – In General for additional
information regarding the Plan Fee and Item 5.B. for further information regarding ODIJ’s
billing procedures.
The tranche breakpoints set forth above shall be adjusted for inflation every three years based
upon the Consumer Price Index. Inflationary adjustments for tranche breakpoints under
$20,000,000 shall be rounded up to the nearest $100,000, while adjustments to tranche
breakpoints between $20,000,000 and $100,000,000 shall be rounded up to the nearest $1,000,000
and adjustments to tranche breakpoints over $100,000,000 shall be rounded up to the nearest
$5,000,000. ODIJ made the most recent adjustments to the tranche breakpoints effective as of
January 1, 2024, and will make the next adjustments in 2027. Such adjustments shall not become
effective until after their disclosure on ODIJ’s annual updating amendment to the Form ADV
Part 2A filed during the first quarter of the year in which they will become effective. Certain
legacy Plan clients are subject to fee schedules that differ from the one described above and are
not subject to inflationary adjustments. Other than increases resulting from inflationary
increases, Plan clients shall be given thirty (30) days’ prior written notice of any proposed
increase in the Plan Fee. Any increase in the Plan Fee that is not related to an inflationary
increase shall be accompanied by an amendment to the investment consulting agreement (or
execution of a new one) with signatures from both parties evidencing acceptance of the new
Plan Fee.
Advisory Fee and Plan Fee Calculation – In General
ODIJ calculates the Advisory Fee and Plan Fee against all assets in the Account(s) or Plan
Account(s), unless specifically excluded. Therefore, Advisory Fee and Plan Fee calculations
include cash balances, cash invested in money market funds, short-term investment funds, ETFs,
mutual funds, the entire market value of margined assets and short positions (if any), and all
other investment holdings including, without limitation, any annuities.
For the initial monthly fee deduction of the Advisory Fee allocable to Custodian-Linked
Account(s) (other than 529 Accounts), the Advisory Fee will be charged for the full month
during which the client’s assets are transferred to such Accounts, regardless of the date of such
transfer or the date the client and ODIJ enter into an investment advisory contract. For the initial
quarterly deduction of the Advisory Fee allocable to Held-Away Account(s) and 529 Account(s),
the Advisory Fee will be charged for the full calendar quarter during which the client’s assets
are transferred to such Accounts regardless of the date of such transfer or the date the client and
ODIJ enter into an investment advisory contract.
ADV Part 2A – One Day In July v26-02
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In the event the client or ODIJ terminates the investment advisory contract prior to the end of
the calendar month (with respect to the Advisory Fee allocable to Custodian-Linked Accounts
other than 529 Accounts) or prior to the end of the quarter (with respect to the Advisory Fee
allocable to Held-Away and 529 Accounts), ODIJ does not bill the client for the partial month or
quarter during which it provided investment advisory services. In such cases, the Advisory Fee
that is allocable to such periods is not billed to the client’s Account(s), provided that either the
client or a supervised person of ODIJ notifies the other in writing of such termination. ODIJ will
only consider a client’s contract to be terminated if either the client or a supervised person of
ODIJ notifies the other in writing of such termination.
In general, the Advisory Fee is calculated based upon the dollar amount of the assets in the
Account as of the close of trading on the last day of the applicable billing period. On occasion,
ODIJ may lose access to a Held-Away Account due to technical issues that are not resolved by
the next quarterly billing date. In such cases, ODIJ will charge the client the same dollar amount
with respect to the Held-Away Account as it had charged on the previous quarterly billing date
for services provided during the quarter in which ODIJ lost access to the Held-Away Account.
ODIJ will work with the client to restore access to the affected Held-Away Account. However, if
access is not restored by the end of the following quarterly billing cycle, ODIJ will terminate its
investment advisory services with respect to that Held-Away Account.
Please see Item 5.B. of this brochure under the heading Advisory Fee Charged to Individuals,
High Net Worth Individuals, Charitable Organizations, Corporations or Business Entities, and
Pension Plans for information regarding the timing of payment and other billing terms
applicable to the Advisory Fee.
In general, where permitted by the custodian, the Plan Fee is billed in advance, calculated based
upon the value of assets in Plan Accounts after the close of trading on the last day of the quarter
immediately preceding the date of billing, unless the Plan’s custodian requires ODIJ to bill the
Plan in arrears. In such cases, the Plan Fee is calculated based upon the value of the assets in
Plan Accounts after the close of trading on the last day of the current quarter. Additionally,
certain custodians do not calculate the Plan Fee based upon the value of the assets in Plan
Accounts on the last day of the applicable quarter. Rather, such custodians base the Plan Fee
upon the average daily balance of assets in Plan Accounts during the quarter. Plan clients
should consult their custodian’s terms of service to determine the methodology used by their
custodian to calculate the Plan Fee.
In general, for the initial quarterly billing cycle, the Plan Fee is calculated using the value of the
assets in Plan Accounts on the date the Plan assets are deposited into Custodian-Linked
Accounts and pro-rated through the end of the quarter. Certain custodians of Plan Accounts do
not prorate the Plan Fee for the initial quarterly billing cycle. In such cases, custodians will pay
the Plan Fee for the full quarter to ODIJ. Plan clients should consult their custodian’s terms of
service to determine whether the custodian will prorate the Plan Fee for the initial quarterly
billing cycle.
Please see Item 5.B. of this brochure under the heading Plan Fee Charged to Employee Benefit Plans
(401(k) and 403(b) Plans) for information regarding the timing of payment and other billing terms
applicable to the Plan Fee.
ADV Part 2A – One Day In July v26-02
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B. Payment of Fees
Advisory Fee Charged to Individuals, High Net Worth Individuals, Charitable Organizations,
Corporations or Business Entities, and Pension Plans
Generally, ODIJ’s Advisory Fee is paid monthly in arrears, but ODIJ reserves the right to change
the periodicity of payment from a monthly basis to a quarterly, semi-annual, or annual basis.
Any portion of the Advisory Fee that is allocable to a “Held-Away Account” (defined under
Item 4.B. under the heading Services Provided to Custodian-Linked and Held-Away Accounts) or a
529 Account is paid on a quarterly basis in arrears. ODIJ shall notify a client in writing of any
change to the periodicity of billing of such client’s Account(s) at least ten (10) days in advance of
the date ODIJ’s Advisory Fee is deducted. Notwithstanding the foregoing, the minimum
Advisory Fee is always paid monthly in arrears.
In general, the Advisory Fee will be deducted directly from the Accounts on a pro rata basis,
except with respect to any Held-Away Accounts or 529 Accounts or unless otherwise instructed
by the client.
The portion of the Advisory Fee allocable to any Held-Away Account(s) or 529 Accounts will be
deducted directly from a client’s taxable brokerage account, if such an account is included
among the Accounts. If a taxable brokerage account is not included among the Accounts, the
portion of the Advisory Fee allocable to any Held-Away Account(s), with the exception of 529
Accounts, will be deducted from a client’s IRA, Roth IRA, or SEP-IRA. For 529 Accounts, the
client must have a taxable brokerage Account under management with ODIJ for purposes of
deducting the Advisory Fee.
Except with respect to Held-Away Accounts and 529 Accounts, the Advisory Fee generally will
be deducted within fourteen (14) calendar days of the first day of the month immediately
following the month that the client’s assets were transferred into Custodian-Linked Accounts
and again on or about the same day each month thereafter for as long as the contract remains in
effect.
The Advisory Fee allocable to a client’s Held-Away Account(s) and 529 Account(s) will be
deducted from such Account(s) within thirty (30) calendar days of the first day of the quarter
immediately following the quarter in which the client and ODIJ enter into an investment
advisory contract and again on or about the same day each quarter thereafter for so long as the
contract remains in effect.
Occasionally, ODIJ may deduct the Advisory Fee at a later date due to an internal error.
Notwithstanding any delayed billing of a client’s Account(s), the method used to calculate the
Advisory Fee will remain the same and the amount deducted will not be higher or lower as a
result of any such delay.
Plan Fee Charged to Employee Benefit Plans (401(k) and 403(b) Plans)
The Plan Fee is generally billed on a quarterly basis in advance, but ODIJ reserves the right to
change the periodicity of billing from a quarterly to a monthly, semi-annual, or annual basis.
ODIJ shall notify the Plan client in writing of any change to the periodicity of billing at least ten
(10) days in advance of the date ODIJ’s Fees are billed. For the initial billing period, the portion
ADV Part 2A – One Day In July v26-02
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of the Plan Fee charged to the Plan will be billed within sixty (60) days of the date the Plan assets
are deposited into Custodian-Linked Accounts.
Certain custodians do not permit billing in advance. In such cases, the Plan will be billed
quarterly in arrears at the beginning of the quarter immediately following the quarter in which
ODIJ provided investment consulting services to the Plan.
On the applicable billing date, ODIJ will debit the Plan Fee directly from the Plan Accounts for
which ODIJ provides investment advisory services (“Plan Accounts”) through an Automated
Clearing House (ACH) billing system set up by a third-party record-keeper for the Plan.
Please see Item 5.D. of this brochure under the heading Plan Fee Charged to Employee Benefit Plans
(401(k) and 403(b) Plans) for information regarding prepayment of fees applicable to the Plan Fee.
C. Client Responsibility for Third-Party Fees
Clients are responsible for the payment of all third-party fees (e.g., custodian fees, brokerage
fees, mutual fund fees, transaction fees, or recordkeeping fees). Those fees are separate and
distinct from the Fees charged by ODIJ. Please see Item 12 of this brochure regarding broker-
dealers and custodians.
Many Plan sponsors have contractual arrangements with third-party record-keepers. When
ODIJ enters into an investment consulting agreement with a Plan, it may recommend to the
trustees that the Plan sponsor engage a particular record-keeper for the Plan. Fees for such
services vary and are outlined in the contract between the Plan sponsor and the record-keeper.
The Plan record-keeper provides system access for participants, the Plan sponsor, and ODIJ, and
is also responsible for recording daily transactions, producing participant statements and Plan
sponsor reports, and processing loans and distributions. Third-party record-keepers may engage
affiliates that also provide investment vehicles for 401(k), pension plans, and other retirement
products. These affiliates may receive separate fees for their services or they may charge a
bundled fee for third-party administration, as well as investment management services.
The services ODIJ provides to clients residing or domiciled in certain states may be subject to
sales tax. States’ interpretations of the applicability of sales tax to services such as those
provided by ODIJ are evolving and the amount of sales tax that may actually be imposed has
not yet been determined. Any such costs are not included in the Fees described in Item 5.A. or B.
but will be included as deductions on a client’s Account statement if ODIJ’s investment advisory
services are subject to sales tax. Although state sales tax will be included among the deductions
from a client’s Account, the statement the client receives from the custodian will not separately
identify the amount of the state sales tax.
D. Prepayment of Fees
Advisory Fee Charged to Individuals, High Net Worth Individuals, Charitable Organizations,
Corporations or Business Entities, and Pension Plans
The Advisory Fee is paid in arrears. Therefore, clients in these categories do not prepay the
Advisory Fee and ODIJ does not issue any refunds of the Advisory Fee.
ADV Part 2A – One Day In July v26-02
15
Plan Fee Charged to Employee Benefit Plans (401(k) and 403(b) Plans)
Where permitted by the Plan’s custodian, Plan Fees are collected in advance on a quarterly
basis. Upon termination of the investment consulting agreement, any portion of the Plan Fee
paid in advance by the Plans will not be refunded. Because Plan clients are billed every ninety
(90) days, the prorated amount of Plan Fees collected in advance and forfeited by individual
Plan Accounts upon termination of the agreement will generally be negligible.
Where the custodian of the Plan Accounts does not permit billing in advance, ODIJ will collect
the Plan Fees in arrears on a quarterly basis at the beginning of the quarter following the quarter
in which ODIJ provided investment consulting services to the Plans. In such cases, Plan Fees are
not prepaid and, therefore, ODIJ will not issue any refunds of Plan Fees.
E. Outside Compensation for the Sale of Securities to Clients
Neither ODIJ nor its supervised persons accept any compensation for the sale of 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
ODIJ is compensated based upon a percentage of assets under management. Therefore, as the
amount of assets in an Account increases, so does ODIJ’s Advisory Fee or Plan Fee, as
applicable. Other than being compensated based upon such increases, ODIJ does not accept
performance-based fees or other fees based on a share of capital gains or on capital appreciation
of the assets of a client.
Item 7: Types of Clients
ODIJ generally provides advisory services to the following types of clients:
Individuals
• Corporations or Business Entities
• Employee Benefit Plans such as 401(k) or
403(b) Plans (the “Plans”)
• Pension Plans
•
• High Net Worth Individuals
• Trusts
• Charitable Organizations
Please see Item 5.A. of this brochure for information regarding the minimum Account size
required to obtain ODIJ’s advisory services.
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
With respect to non-Plan clients, ODIJ manages all or a portion of the client portfolio using an
asset allocation strategy. With respect to Plan clients, ODIJ likewise recommends investment
options to Plans based upon an asset allocation strategy. Asset allocation is a top-down
investment strategy that focuses on general movements in the market rather than on
performance of individual securities. Due to changes in market conditions, asset allocation
guidelines are not necessarily strictly followed. Non-Plan clients’ portfolios will be rebalanced at
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a frequency in line with client risk tolerance. Risk-averse clients will be rebalanced more
frequently to manage portfolio volatility better, while clients with a higher risk tolerance will be
rebalanced less frequently.
Investment Strategies
Returns come from client willingness to withstand ups and downs in the market. Investments
are made subject to the objectives of the client, balancing the possibility of return against the
level of risk taken. ODIJ equity allocations generally contain large-cap and small-cap equities,
though allocations may vary depending upon a client’s individual preferences and financial
circumstances. ODIJ fixed income allocations generally contain bonds of various maturities.
ODIJ uses a predominantly long-term investment strategy designed to capture market rates of
both return and risk, but occasionally also uses short-term trading and margin transactions.
ODIJ-managed portfolios, and Plan investment options ODIJ recommends, consist primarily of
passive mutual funds or ETFs. The risks of these broad market indices correlate with the risks of
the global equity and bond markets.
Funds are selected based upon their costs, tax implications, breadth of securities, assets under
management, liquidity, and, where clients have selected ODIJ’s environmental investing
strategy, the weighted-average carbon footprint and fossil fuel reserve exposure of various
funds’ underlying holdings, based on available third-party data.
ODIJ uses two primary metrics to evaluate and select environmentally focused investments:
carbon intensity and fossil fuel reserves. Carbon intensity measures the amount of carbon
dioxide (“CO2”) emissions, expressed in metric tons, relative to a unit of economic activity. In
the case of countries, carbon intensity is commonly measured relative to gross domestic product
(“GDP”).
The fossil fuel reserve metric generally reflects a fund’s weighted-average exposure to
companies that own fossil fuel reserves, based on third-party data. In evaluating potential
environmental investments, ODIJ supplements the firm’s traditional investment criteria of cost,
diversification, and liquidity with an analysis of a fund’s exposure to companies that are
significant carbon emitters or own fossil fuel reserves. ODIJ generally seeks to utilize funds that
have more limited exposure to these companies compared to traditional index funds.
In establishing carbon intensity and fossil fuel reserve metrics, ODIJ relies on data provided by
third-party environmental organizations and academic or industry publications, which may
include, but are not limited to, Our World in Data, the United Nations Framework Convention
on Climate Change, and publications like Energy Research & Social Science and Nature.
Clients investing in our environmentally focused strategy may also elect to include an “impact
portfolio” position within their asset allocation plan. This position consists of ETFs or mutual
funds that invest primarily in companies operating in renewable energy and other
environmentally focused sectors, such as solar and wind. The impact portfolio may provide
more direct exposure to these sectors but typically involves significant concentration in growth-
stage companies, which may result in higher costs and greater performance volatility compared
to the client’s core equity portfolio.
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While ODIJ generally recommends passively managed, low-cost ETFs or mutual funds, during
the period when a client transitions an Account(s) to ODIJ, and from time to time thereafter, the
Account(s) may contain non-index fund holdings. These may be individual stocks, bonds,
mutual funds not defined as an index fund, annuities, or other investments. This may be due to
the client’s preference, desire to maintain existing positions, avoidance of taxable gain
recognition, or other reasons such as (with respect to annuities) the inability to trade due to
custodian-imposed restrictions. Individual Account(s) within a client’s aggregate household
portfolio may have different risk characteristics and may perform differently from the portfolio
as a whole.
In general, ODIJ considers investments in highly leveraged funds and cryptocurrency or digital
currency-related assets to be high risk or highly speculative and prohibits the firm’s investment
personnel from purchasing these types of assets for client Accounts. Cryptocurrency or digital
currency-related assets include, but are not limited to, digital currencies themselves, blockchain
ETFs, and individual stocks of digital currency companies. If a client transfers an Account to
ODIJ with these types of assets, the firm may continue to hold the assets in the Account only if
the client requests as such in writing and the ODIJ advisor obtains approval from ODIJ
compliance personnel to permit the holdings of such assets in the account.
In certain rare circumstances, with approval from the client, ODIJ may short a security for a
client. These trades generally are meant to offset market movements for a period of time.
Investing in securities involves a risk of loss that all clients should be prepared to bear.
B. Material Risks Involved
Asset allocation analysis entails the risk that the rise and fall of certain securities may not react
according to predicted trends. Other factors such as risk tolerance, market timing, portfolio size,
and investment expenses may also affect the portfolio performance. In addition, ODIJ cannot
always allocate among securities in an optimal manner because selling certain securities would
lead to adverse tax consequences.
Generally, ODIJ seeks or recommends, with respect to the Plans, investment strategies that do
not involve significant or unusual risk beyond that of the general domestic and/or international
equity markets, but risks of specific strategies are discussed below. Clients should be aware,
however, that there is a material risk of loss using most investment strategies. ODIJ’s strategies
may have significant tax implications. ODIJ manages portfolios with an awareness of tax
consequences, but long-term wealth compounding is our primary consideration. In all cases,
ODIJ strongly recommends to its clients that they regularly consult with their tax advisors prior
to and throughout their engagement of ODIJ. ODIJ is not responsible for any taxes incurred by
sales of securities, annuities, or insurance products. The final redemption price and basis price
for annuities and insurance products may vary from the amounts stated in the statement
delivered by the insurance carrier.
As discussed elsewhere in this brochure, one of ODIJ’s strategies is discretionary rebalancing of
Accounts. Unfavorable market conditions may coincide by happenstance with the timing of an
Account rebalance, in which case rebalancing losses may compound. Using the other strategies
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discussed below, ODIJ seeks to recover any such losses and to achieve maximum Account value
for our clients, although the firm cannot guarantee full recovery.
Long-term trading is designed to capture market rates of both return and risk. Due to its nature,
the long-term investment strategy can expose clients to various types of risk that will typically
surface at various intervals during the time the client owns the investments. These risks include,
but are not limited to, inflation (purchasing power) risk, interest rate risk, economic risk, market
risk, political, and regulatory risk.
Short-term trading risks include liquidity, economic stability, and inflation, in addition to the
long-term trading risks listed above. Frequent short-term trading, when done, can affect
investment performance, particularly through increased brokerage and other transaction costs
and taxes. Short-term trading generally holds greater risk, and clients should be aware that there
is a material risk of loss using this strategy.
Margin transactions use leverage that is borrowed from a brokerage firm as collateral. The use
of margin transactions generally holds greater risk of capital loss. When losses occur, the value
of the margin account may fall below the brokerage firm’s threshold, thereby triggering a
margin call. This may force the account holder to either allocate more funds to the account or
sell assets in a shorter time frame than desired. Thus, margin transactions can lead to short
selling in the event of a margin call, and so the risks associated with short-term trading may also
apply to margin transactions.
Investing in securities involves a risk of loss that all clients should be prepared to bear.
C. Risks of Specific Securities Utilized
Clients should be aware that there is a material risk of loss using any investment strategy. The
investment types listed below (leaving aside treasury bonds and treasury inflation
protected/inflation linked bonds) are not guaranteed or insured by the Federal Deposit
Insurance Corporation or any other government agency.
Mutual funds are financial vehicles made up of a pool of money collected from many investors
to invest in securities like stocks, bonds, money market instruments, and other assets. Mutual
funds carry the risk of capital loss (“capital loss” means losing the money the client originally
invested) and thus a client may lose money investing in mutual funds. All mutual funds have
costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk)
or stock “equity” nature.
Equity investment generally refers to buying shares of stocks in return for receiving a future
payment of dividends and/or capital gains if the value of the stock increases. The value of
equity securities may fluctuate in response to specific situations for each company, industry
conditions, and the general economic environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount of the
payments can vary. This type of investment can include corporate and government debt
securities, leveraged loans, high-yield and investment grade debt, and structured products, such
as mortgage and other asset-backed securities. Individual bonds may be the best-known type of
fixed income security. In general, the fixed income market is volatile and fixed income securities
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carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect
is usually more pronounced for longer-term securities.) Fixed income securities also carry
inflation risk, liquidity risk (“liquidity risk” means the risk that an investment may not be able to
be sold), call risk (“call risk” means that the issuer of a bond may demand redemption of that
bond at an inopportune time), and credit and default risks (“credit and default risks” refer to the
risks associated with an issuer not being be able to repay part or all of its obligations) for both
issuers and counterparties. The risk of default on treasury bonds and treasury inflation
protected/inflation linked bonds is a corollary to the U.S. Treasury defaulting on its debt
obligations; however, they carry a potential risk of losing share price value. Historically, U.S.
Treasury bonds generally have moved inversely with equities, although there have been
exceptions. There is no guarantee that treasury bonds will move inversely with equities in the
future. Risks of investing in foreign fixed income securities also include the general risk of non-
U.S. investing described below.
Exchange-traded funds (ETFs) are investment funds traded on stock exchanges, similar to
stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a one hundred percent
[100%] loss in the case of a stock holding bankruptcy). Areas of concern include the lack of
transparency in products and increasing complexity, conflicts of interest, and the possibility of
inadequate regulatory compliance with respect to the fund. Specifically, precious metal ETFs
(e.g., gold, silver, or palladium bullion-backed “electronic shares” [not physical metal]) may be
negatively impacted by several unique factors, among them (1) large sales by the official sector
that owns a significant portion of aggregate world holdings in gold and other precious metals,
(2) a significant increase in hedging activities by producers of gold or other precious metals, and
(3) a significant change in the attitude of speculators and investors. Environmental ETFs may
contain significant exposure to certain industries and lack of exposure to others. In addition,
environmental or “Impact” ETFs may have concentrated exposure to growth-stage businesses,
which may result in higher prices and greater performance volatility as compared to other ETFs.
ODIJ does not use inverse, leveraged, or inverse and leveraged ETFs as part of its portfolios.
ETFs have additional risks. Because they are easy to trade, trading risk could result. ODIJ tries
not to trade ETFs frequently to minimize trading risk. Liquidity and shutdown risk could occur
if an ETF shrinks substantially as a fund, making it difficult if not impossible for ODIJ to sell a
position or avoid incurring a tax liability for the investor in the case of shutdown risk.
Authorized participants create liquidity so that ETF funds may function; if they fail in their duty
to create liquidity, the ETF may be adversely affected. If the market price and the net asset value
of the ETF diverge, there may be risk of loss when these values converge. ETF providers may
have conflicts of interest, particularly if they create the index their own ETF tracks.
Index funds refers to mutual funds and ETFs having a portfolio constructed to match or track
the components of a financial market index, such the Standard & Poor’s 500 Index, by tracking
the composition of a standard market index both in terms of the types of stock which constitute
the benchmark index and in the amount that is present in the index. An index fund may
underperform its index because of fees and expenses, trading costs, and tracking error.
Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate
sector, which historically has experienced significant fluctuations and cycles in performance.
Revenues and cash flows may be adversely affected by: changes in local real estate market
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conditions due to changes in national or local economic conditions or changes in local property
market characteristics; competition from other properties offering the same or similar services;
changes in interest rates and in the state of the debt and equity credit markets; the ongoing need
for capital improvements; changes in real estate tax rates and other operating expenses; adverse
changes in governmental rules and fiscal policies; adverse changes in zoning laws; and the
impact of present or future environmental legislation and compliance with environmental laws.
ODIJ generally invests in index funds that own publicly traded REITs. As such, the REITs make
specific investments in a wide range of properties, and the index fund owns portions of many
REITs at the same time.
Commodities are tangible assets used to manufacture and produce goods or services.
Commodity prices are affected by different risk factors, such as disease, storage capacity,
supply, demand, delivery constraints, and weather. Because of those risk factors, even a well-
diversified investment in commodities can be uncertain.
Non-U.S. securities present certain risks such as currency fluctuation, political and economic
change, social unrest, changes in government regulation, differences in accounting, and the
lesser degree of accurate public information available.
Past performance is not indicative of future results. Investing in securities involves a risk of
loss that all clients should be prepared to bear.
Item 9: Disciplinary Information
ODIJ has never been the subject of a criminal or civil action, administrative proceedings, self-
regulatory organization proceedings, or any other disciplinary actions.
Item 10: Other Financial Industry Activities and Affiliations
Neither ODIJ nor its representatives are registered as, or have pending applications to become, a
broker-dealer or a representative of a broker-dealer. Neither ODIJ nor its representatives are
registered as or have pending applications to become either a futures commission merchant,
commodity pool operator, or commodity trading advisor, or an associated person of the
foregoing entities. There are no relationships or arrangements that are material to ODIJ’s
advisory business or to ODIJ’s clients that ODIJ or any of its management persons have with any
related person. ODIJ does not utilize nor select third-party investment advisors. All assets are
managed by ODIJ management, and all advice is rendered by ODIJ advisors.
Item 11: Code of Ethics, Participation or Interest in Client Transactions, Personal
Trading, and Rollovers
A. Code of Ethics
ODIJ has a written Code of Ethics that covers the following areas: prohibited purchases and
sales, insider trading, personal securities transactions, exempted transactions, prohibited
activities, conflicts of interest, gifts and entertainment, confidentiality, service on a board of
directors, compliance procedures, compliance with laws and regulations, procedures and
reporting, certification of compliance, reporting violations, compliance officer duties, training
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and education, recordkeeping, annual review, and sanctions. ODIJ's Code of Ethics is available
free upon request to any client or prospective client.
B. Personal Trading Practices for Representatives of ODIJ
From time to time, representatives of ODIJ may buy or sell securities for themselves at or
around the same time as they buy or sell securities for clients or buy or sell securities for
themselves that they also recommend to clients. ODIJ may recommend that clients buy or sell
securities in which a related person to ODIJ or ODIJ has a material financial interest. This may
provide an opportunity for representatives of ODIJ to buy or sell the same securities before or
after recommending the same securities to clients resulting in representatives profiting from the
same recommendations they provide to clients. Although such transactions have the potential to
create a conflict of interest, it is ODIJ’s policy not to permit transactions that are motivated by, or
result in, an actual conflict of interest. ODIJ personnel will not engage in “front running” client
Accounts. ODIJ will always document any transactions that could be construed as conflicts of
interest and will never engage in trading that operates to the client’s disadvantage when similar
securities are being bought or sold or when representatives of ODIJ buy or sell securities at or
around the same time as clients. ODIJ personnel understand that ODIJ has an affirmative duty
of utmost good faith to act solely in the best interest of its clients.
C. Rollover Disclosure
When ODIJ provides investment advice to clients regarding their retirement plan account or
IRA, ODIJ representatives are fiduciaries within the meaning of ERISA and/or the Internal
Revenue Code (laws governing retirement accounts), as applicable. The way ODIJ makes money
creates some conflicts with client interests, so the firm operates under a special rule that requires
it to act in clients’ best interest and not put its interests ahead of theirs. This special rule requires
ODIJ to give prudent and loyal advice; avoid misleading statements about conflicts of interest,
fees, and investments; follow policies and procedures designed to ensure that its advice is in
clients’ best interest; charge no more than what is reasonable for services; and provide basic
information about the firm’s conflicts of interest. If ODIJ recommends that a client roll over a
retirement plan account or IRA assets into an Account to be managed by ODIJ, such a
recommendation may create a conflict of interest if ODIJ will earn an additional or increased
Advisory Fee on the rolled over assets. No client is under any obligation to roll over retirement
plan assets to an account managed by ODIJ. Clients and prospective clients considering a
rollover from a workplace retirement plan account to an IRA, or from an IRA to another IRA,
are encouraged to consider the advantages and disadvantages of such a rollover, including, but
not limited to, increased or decreased management expenses, transaction expenses and custodial
expenses, and an increase or decrease to the number of available investment options.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker-Dealers
Custodians and/or broker-dealers will be recommended based on their relatively low
transaction fees and access to mutual funds and ETFs. Clients will not necessarily pay the lowest
commission or commission equivalent. ODIJ may also consider the market expertise and
research access provided by the broker-dealer and/or custodian, including but not limited to
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access to written research, oral communication with analysts, admission to research conferences,
and other resources provided by the brokers that may aid in ODIJ's research efforts. ODIJ also
considers the quality of service provided by the custodian and the quality of the custodian’s
digital tools used to help facilitate investment advisory services for the clients. ODIJ does not
charge a premium or commission on transactions, beyond the actual cost imposed by the
broker-dealer and/or custodian.
For each Plan client that expresses an interest in changing custodians, ODIJ will review several
custodians and select the one that provides the highest level of service at the most optimal
pricing for the Plan’s Accounts.
Plan clients who wish to retain ODIJ’s investment consulting services without changing the
Plan’s custodian may do so. In such cases, the Plan’s custodian may or may not be a custodian
ODIJ recommends.
ODIJ does not make custodian or broker-dealer recommendations to individual participants of a
Plan that have not entered into an investment advisory agreement with ODIJ.
For clients other than Plan clients, ODIJ recommends Schwab Institutional, a division of Charles
Schwab & Co., Inc. (“Schwab”) to serve as the custodian and broker-dealer of clients’ investment
Accounts that are not 529 Accounts. ODIJ actively monitors the custodian options available and
may recommend an alternative to Schwab in the future. With respect to clients’ 529 Accounts,
ODIJ recommends my529 (formerly known as the Utah Educational Savings Plan) to serve as
custodian and broker-dealer of those Accounts.
1. Research and Other Soft-Dollar Benefits
While ODIJ has no formal soft dollars program in which soft dollars are received or used to pay
for third-party services, ODIJ may receive research materials published by Schwab in connection
with ODIJ’s recommendation of Schwab as custodian for its clients’ Accounts. These research
materials describe current market trends and updates. ODIJ does not rely on these research
materials in making investment decisions on behalf of its clients, and ODIJ does not have any
incentive to recommend a broker-dealer based on receiving this research. ODIJ’s receipt of this
research will not result in higher commissions charged to the client. In addition, ODIJ receives
certain economic benefits from Schwab Advisor Services, a division of Schwab (“Schwab
Advisor Services”), which are derived from ODIJ’s brokerage recommendation of Schwab. These
benefits are described in further detail under Item 14.A. of this brochure.
ODIJ does not receive any research or soft dollar benefits from my529 in connection with its
recommendation of my529 as a broker-dealer and custodian.
2. Brokerage for Client Referrals
ODIJ receives 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 and/or Custodian to Use
ODIJ will permit clients to direct it to execute transactions through a specified broker-dealer
when the transactions are to occur within clients’ Held-Away Accounts (as defined in Item 4.B.
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of this brochure). Unless a client’s Account is a Held-Away Account, generally ODIJ will not
permit a client to direct brokerage to a custodian other than Schwab.
If a client directs brokerage, this may result in higher commissions, which may result in a
disparity between free and directed accounts, and trades for the client and other-directed
accounts may be executed after trades for free accounts, which may result in less favorable
prices, particularly for illiquid securities or during volatile market conditions. Not all
investment advisors allow their clients to direct brokerage.
B. Aggregating (Block) Trading for Multiple Client Accounts
ODIJ may, but does not always, aggregate or bunch the securities to be purchased or sold for
multiple clients. When trades are not aggregated, this may result in less favorable prices,
particularly for illiquid securities or during volatile market conditions. However, ODIJ primarily
trades in highly liquid ETFs. It is ODIJ’s policy to allocate investment opportunities and
transactions it identifies as being appropriate and prudent among its clients on a fair and
equitable basis over time.
Item 13: Review of Accounts
In addition to annual reviews performed by a client’s ODIJ advisor, all client Accounts for which
ODIJ's investment advisory services are provided on an ongoing basis are reviewed by ODIJ’s
compliance department when the Account is opened or transferred to ODIJ. Accounts are
reviewed within the context of the client’s investment objectives, risk tolerance levels, and
suitability of investment options. More frequent reviews may be triggered by material market,
economic or political events, or changes in a client’s financial situation (such as retirement,
termination of employment, physical move, or inheritance). Each client for whom ODIJ’s
investment advisory services are provided on an ongoing basis will receive a report at least
quarterly detailing the client’s Account, including assets held, asset value, the calculation of
certain fees, and, if the report relates to a Custodian-Linked Account (other than 529 Accounts),
the amount of ODIJ’s Fees. This written report will come from the custodian of the Custodian-
Linked Account or Held-Away Account, as applicable.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered
to Clients (Includes Sales Awards or Other Prizes)
As a benefit for managing its clients’ Accounts at Schwab Advisor Services, ODIJ receives access
to Schwab’s institutional trading and custody services, including services related to execution of
securities transactions, custody, research and analyses, and access to certain funds.
Schwab also makes available to ODIJ other products and services that benefit ODIJ but may not
benefit its clients’ Accounts. These benefits may include educational events and access to
courses for continuing education credits. Other of these products and services assist ODIJ in
managing and administering clients’ Accounts. These include software and other technology
that provide access to client Account data; facilitate trade execution; provide research, pricing
information, and other market data; facilitate payment of ODIJ’s Fees from its clients’ Accounts;
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and assist with back-office training and support functions, recordkeeping, and client reporting.
Schwab Advisor Services also makes available to ODIJ other services intended to help ODIJ
manage and further develop its business enterprise, including professional compliance, legal
and business consulting, and publications and conferences on practice management,
information technology, business succession, employee benefits providers, human capital
consultants, insurance, and marketing. In addition, Schwab may make available, arrange and/or
pay vendors for these types of services rendered to ODIJ by independent third parties. ODIJ is
independently owned and operated and not affiliated with Schwab.
The benefits ODIJ receives from Schwab Advisor Services are derived from ODIJ’s brokerage
recommendation and use of Schwab. Schwab does not charge ODIJ separately for these services.
The benefits do not create a conflict of interest as they are comparable to the benefits ODIJ
would receive from Schwab’s competitors if ODIJ recommended any of those competitors to
serve as the custodian of clients’ Accounts.
B. Compensation to Non–Advisory Personnel for Client Referrals
From time to time, ODIJ provides compensation in the form of a monetary bonus or increased
commission to supervised persons who refer a client to the firm. This compensation is paid from
the Advisory Fee earned by the firm and does not result in any additional charge to the client.
If a supervised person of the firm refers a prospective client to ODIJ, this may create a conflict of
interest as there could be an incentive to grow their assets through risky investments to increase
compensation once they become a client. However, in addition to the firm’s obligation to act in
the client’s best interest in accordance with the fiduciary standard, all ODIJ advisors are
required to follow the guidelines set forth by the client in the investment plan. Furthermore, no
prospective client is under any obligation to sign a contract or to open an Account with ODIJ.
Item 15: Custody
For the investment advisory services ODIJ offers, the custodian of the client’s investment assets
will be agreed to by the client in the Account agreement or other Account opening
documentation. Although ODIJ does not serve as the qualified custodian of any client’s
Account(s), there is one circumstance under which ODIJ will be deemed to have custody of a
client’s assets under applicable securities’ laws.
When ODIJ deducts the Advisory Fee or Plan Fee from a client’s Custodian-Linked Accounts on
a monthly or quarterly basis, ODIJ will be deemed to have limited custody of the client's assets.
In all cases, ODIJ must have a general written authorization from the client to make the
foregoing deductions. Once ODIJ has obtained such authorization from the client, ODIJ will not
seek additional consents each time it deducts Fees. Clients will receive all Account and Plan
Account statements quarterly from the qualified custodian of the Account or Plan Account and
they should carefully review those statements.
Item 16: Investment Discretion
ODIJ provides discretionary investment advisory services to all of its investment advisory
clients except the Plans. The investment advisory contract established with each investment
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advisory client sets forth the discretionary authority for trading. Where investment discretion
has been granted, ODIJ generally manages the client’s Account(s) and makes investment
decisions without consultation with the client as to when the securities are to be bought or sold
for the Account(s), the total amount of the securities to be bought or sold, what securities to buy
or sell, or the price per share. In some instances, ODIJ’s discretionary authority in making these
determinations may be limited by conditions imposed by a client (in investment guidelines or
objectives, or client instructions otherwise provided to ODIJ). Notwithstanding the foregoing
authority, ODIJ does not have authority to withdraw cash, securities, or funds from a client’s
Account without the client’s permission and will never suggest or recommend doing so to a
client. Any such withdrawals must be initiated, approved, and requested by the client.
ODIJ does not accept discretionary authority to manage Plan Accounts and does not have the
ability to effect purchases and sales of securities within Plan Accounts under the investment
consulting agreement with the Plan. See Item 4.B. under the heading Benefit Plan Consulting for
further information about ODIJ’s non-discretionary investment consulting services to the Plans.
Item 17: Voting Client Securities (Proxy Voting)
ODIJ will not ask for, nor accept, voting authority for client securities. Clients will receive
proxies directly from the issuer of the security or the custodian. Clients should direct all proxy
questions to the issuer of the security.
Item 18: Financial Information
ODIJ does not require prepayment of more than $1,200 in Fees per client, six (6) months or more
in advance. Therefore, a balance sheet for ODIJ’s most recently completed fiscal year is not
attached to this brochure. Neither ODIJ nor its management expects that current financial
conditions will render ODIJ unable to meet contractual commitments to clients. ODIJ has never
been the subject of a bankruptcy petition.
Item 19: Requirements for State Registered Advisors
This Item 19 does not apply to ODIJ.
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