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Part 2A of Form ADV: Firm Brochure
ORG Partners, LLC
5001 Spring
Valley Rd, Suite
810W Dallas, TX
75244
August 2025
This brochure provides information about the qualifications and business practices of ORG Partners, LLC.
If you have any questions about the contents of this brochure, please contact our Chief Compliance
Officer, Matthew Reynolds, at matthew.reynolds@orgpag.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 ORG Partners is also available on the SEC’s website at
www.adviserinfo.sec.gov.
References herein to ORG Partners, LLC as a “registered investment adviser” or any reference to being
“registered” does not imply a certain level of skill or training.
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 1 of 24
Item 2
Material Changes
Since our amended filing with the SEC in March 2024, the following material changes have been
made to this brochure:
• ORG Partners has updated Item 10: ORG affiliations include Ascentis Asset Management, LLC (CRD
#318126), Ascentis Wealth Management, LLC (CRD #330923) and Golden State Equity Partners, LLC (CRD
#322879) through common ownership. The Firm’s ownership structure has changed, with Michael
Mansur having the largest individual 0wnership position in Ascentis Operations, LLC, the holding
company of ORG Partners, LLC through a private Irrevocable Trust.
• The Chief Compliance Officer was updated from Justine Kidwell to Matthew Reynolds.
• The firm’s home office was moved to 5001 Spring Valley Rd, 810W, Dallas, TX 75244
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 2 of 24
Table of Contents
Item 3
Contents
Item 1
Cover Page ................................................................................................................................ 1
Item 2 Material Changes ...................................................................................................................... 2
Item 3
Table of Contents ...................................................................................................................... 3
Item 4
Advisory Business...................................................................................................................... 5
A. ORG Partners, LLC .......................................................................................................................... 5
B. Types of Advisory Services Offered ................................................................................................ 5
C.
Tailored Relationships ................................................................................................................... 7
D. Participation in Wrap Fee Programs .............................................................................................. 8
E. Assets Under Management ........................................................................................................... 8
Item 5
Fees and Compensation ............................................................................................................ 8
A. ORG Compensation ....................................................................................................................... 8
B. Billing of Fees ............................................................................................................................... 11
C. Other Fees ................................................................................................................................... 11
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
A. Methods of Analysis and Investment Strategies .......................................................................... 12
B. Risk of Loss ................................................................................................................................... 13
C. Other Fees ................................................................................................................................... 15
Item 9 Disciplinary Information ........................................................................................................... 15
Item 10
Other Financial Industry Activities and Affiliations ............................................................... 16
A. Affiliations.................................................................................................................................... 16
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 16
A. ORG Partners Code of Ethics ........................................................................................................ 16
B. Participation or Interest in Client Transactions ............................................................................ 17
C. Personal Trading .......................................................................................................................... 17
Item 12
Brokerage Practices ............................................................................................................. 17
A. Broker-Dealer Selection ............................................................................................................... 17
B. Trade Errors ................................................................................................................................. 20
C. Order Aggregation, Allocation, and Rotation Practices ................................................................ 20
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 3 of 24
Item 13
Review of Accounts .............................................................................................................. 21
A. Periodic Reviews .......................................................................................................................... 21
Item 14
Client Referrals and Other Compensation ............................................................................ 21
A. Other Compensation ................................................................................................................... 22
B. Referrals ...................................................................................................................................... 24
Item 15
Custody ................................................................................................................................ 24
Item 16
Investment Discretion .......................................................................................................... 24
Item 17
Voting Client Securities ........................................................................................................ 24
Item 18
Financial Information ........................................................................................................... 24
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 4 of 24
Advisory Business
Item 4
A. ORG Partners, LLC
ORG Partners, LLC (“ORG Partners,” “ORG, “or the “Adviser”) is an Indiana limited liability company formed on
January 17, 2021. The Adviser is an investment adviser registered with the Securities and Exchange
Commission (“SEC”) under the Investment Advisers Act of 1940, as amended (the “Investment Advisers
Act”). ORG affiliations include Ascentis Asset Management, LLC (CRD #318126), Ascentis Wealth Management, LLC
(CRD #330923) and Golden State Equity Partners, LLC (CRD #322879) through common ownership. The Firm’s
ownership structure has changed, with Michael Mansur having the largest individual Ownership position in
Ascentis Operations, LLC, the holding company of ORG Partners, LLC through a private Irrevocable Trust.
Our firm’s home office is located at 5001 Spring Valley Rd, 810W, Dallas, TX 75244. Our investment
adviser representatives of the firm are permitted to conduct their business under a “doing business as”
name, otherwise known as a “d/b/a/.” ORG Partners, LLC also conducts business under the following
d/b/a names:
• The Cirque Financial Group
• Constance Wealth Advisors
• Tinker Capital
• Xartis Wealth Advisory Group
• Century Wealth Advisors
• Elias Financial Services
• Benchmark Financial Advisors
B. Types of Advisory Services Offered
Financial Planning
The Adviser’s financial planning process begins with an intensive fact-finding session which helps the
Adviser become familiar with the client’s current financial situation (including among other things,
income taxes, investments, insurance, estate affairs and family circumstances), as well as their personal
goals and priorities for the next several years. Then, working from this comprehensive information, the
Adviser makes specific goal-oriented recommendations. The Adviser’s specific goal-oriented
recommendations are designed to educate and allow a client to coordinate his/her financial affairs more
efficiently, increase cash flow, prudently reduce income taxes, and attempt to improve his/her overall net
worth. Once this has been discussed with the client, the recommendations that the client feels
comfortable with are scheduled for implementation with specific deadlines to be met. The Adviser
continues to assist the client based on an annual review of services in all applicable areas of financial
planning including estate, retirement, cash flow and tax planning.
Investment Consulting
The Adviser works to provide institutional retirement plans and the plan sponsors with diversified
investment options for plan participants to choose from. In addition, as requested by the plan sponsor,
the Adviser shall provide plan participants with general information seminars and/or educational
materials that describe the various investment alternatives available under the plan, information about
investing in general, including information about different types of investments, such as allocation
strategies, and historical returns. Interactive materials designed to help participants identify an
appropriate investment strategy are provided.
Investment Management
We offer discretionary and non-discretionary investment management services. Investment management
services offered by the Adviser are specifically tailored to meet the needs of each client. Prior to
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 5 of 24
delivering investment advisory services, the Adviser will ascertain each client’s specific investment
objective. The Adviser will allocate, or recommend that the client allocate, their investment assets
consistent with the designated investment objective.
Please note: It is always the client’s responsibility to promptly notify the Adviser if there is any change in
their financial situation or investment objective. This notification of change allows the Adviser an
opportunity to review, evaluate, or revise the previous recommendations or services.
Managed Discretionary Assets
If you engage our firm on a discretionary basis, we require you to grant us discretionary authority to
manage your account. Discretionary authorization will allow our Investment Advisor Representatives
(“IAR’s”) to weigh the Client’s objectives with current market conditions and act on a client’s account
without further authorization. ORG Partners has engaged Ascentis Asset Management, LLC, an affiliate,
as the sub-adviser for certain client accounts. As discussed further- in Item 10, ORG Partners, LLC is
affiliated by common ownership with Ascentis Asset Management, LLC. Clients have the authority to
impose reasonable restrictions on any of the Adviser’s investment advisory services at any time, but
restrictions must be delivered to the Adviser in writing and must be signed by the client.
Managed Non-Discretionary Assets
In addition to providing investment management of client assets on a discretionary basis, the Adviser, for
a separate and additional fee, provides certain limited services to clients with respect to “Managed Non-
Discretionary Assets.” These services consist solely of the following:
• The Adviser is available to consult with the client on a semi-annual basis (or more often if
requested by the client) regarding Managed Non-Discretionary Assets. However, the client is
solely responsible for all decisions and consequences on the client’s Managed Non-discretionary
Assets, including decisions on whether to retain or sell all or a portion of the Managed Non-
Discretionary Assets. This responsibility remains solely with the client regardless of whether any
security is reflected on account reports prepared by the Adviser.
• The Adviser is available to service Managed Non-Discretionary Assets, such as setting up and
monitoring regular distributions and special one-time distribution requests.
• The Adviser can process any trades on the Managed Non-Discretionary Assets, but only when
requested to do so by the client. Upon receipt of any client’s request, The Adviser will endeavor,
but cannot guarantee, that any such transaction will be affected on the day received or at any
specific time or price.
Limitations for Non-Discretionary Assets
Clients that engage the Adviser on a non-discretionary investment advisory basis must be willing to accept
that the Adviser cannot affect any account transactions without obtaining prior consent to any such
transaction(s) from the client. Thus, in the event of a market correction during which the client is
unavailable, ORG Partners will be unable to affect any account transactions (as it would for its
discretionary accounts) without first obtaining the client’s consent.
Third-Party Money Mangers
After the Adviser has gathered information about the client’s specific investment objective, the Adviser will
assist the Client in selecting a Third-Party Money Manager (“TPMM”) to deliver an investment model
(“strategy”) or manage a separate account for the Client. IAR’s utilize multiple factors in selecting a
prudent TPMM to recommend to a client, including but not limited to performance, investment objectives,
and fees. These factors are considered in relation to the Client’s specific investment objective to help
determine the suitability of the TPMM. When a Client engages a TPMM we recommend, we do not directly
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 6 of 24
manage that portion of the Client’s portfolio assets and are not involved in selecting the securities to be
bought and sold, or the timing of the same. The day-to-day portfolio management decisions are provided
by the TPMM and then executed by us at the Client’s custodian or executed directly by the TPMM if
managed in a separate account.
In the event that the use of multiple TPMMs is recommended to a client, each TPMM has differing minimum
account requirements as well as a variety of fee ranges. If a client uses a TPMM in a separate account, we
periodically review the Client’s financial situation, objectives, and restrictions; and communicate relevant
information to the TPMM and assist the client in understanding and evaluating the services provided by the
TPMM. Some TPPMs maintain their own separate execution, clearing, and custodial relationships.
If we determine that a selected TPMM is not managing the Client’s portfolio in a manner consistent with
the Client’s IPS and investment objectives, or if the financial situation of the Client changes, we
recommend a new TPPM.
Additional Services
The Adviser is authorized to furnish advice on matters not involving securities, such as:
Insurance Review & Planning Corporate Retirement Plan Guidance
• Retirement Income Planning Withdrawal Rate Analysis
•
• Estate & Charitable Gift Planning
• Business Successions
• Personal Financial Planning
• Education Planning
• Cash Flow & Budgeting
• Employee Benefits & 401(k) Guidance
• Tax Planning
C. Tailored Relationships
At the Adviser, advisory services are tailored to the specific needs of each Client. Prior to providing
advisory services, the Adviser will ascertain each Client’s investment goals and objectives. The Adviser
then allocates and/or recommends that the client allocate investment assets consistent with the
designated investment objective. The client has the authority to, at any time, impose reasonable
restrictions on the Adviser’s services, but restrictions must be delivered to the Adviser in writing and must
be signed by the Client.
In performing services for the Client, the Adviser is not required to verify any information it received from
the client or from the Client’s other professionals and the Adviser is expressly authorized by the Client to
rely on this information. Each client is advised that it remains the Client’s responsibility to promptly notify
the Adviser if there is ever any change in the Client’s financial situation or investment objectives for the
purpose of reviewing, evaluating, or revising the Adviser’s previous recommendations or services to the
Client.
D. Participation in Wrap Fee Programs
The Adviser offers services through both wrap fee programs and non-wrap fee programs. Certain other
fees are not included in the wrap fee and are paid for separately by the client. These fees include
custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall
be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark- ups
and mark-downs, spreads paid to market makers, fees for trades executed away from the custodian, wire
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 7 of 24
transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are
not included within the wrap-fee you are charged by our firm, and the client would be charged these fees
if appliable. Please refer to the Adviser’s Wrap Fee Brochure for additional information.
Generally, we consider wrap fee programs through which investment advisory services and execution of
your transactions are provided for specified fees that are not based directly upon transactions in your
account. Our firm and our investment team do not manage wrap fee accounts differently from other
programs.
E. Assets Under Management
The Adviser Manages a total of $983,937,880 in client assets. $962,359,847 is managed in a discretionary
fashion, and the remainder is managed in a non- discretionary manner.
Item 5 Fees and Compensation
The information below provides an overview of the fees and compensation we generally receive for the
services we provide. Please refer to your agreement with ORG for information about the specific fees to
be imposed with respect to your account and the other terms and conditions that will govern your
relationship with ORG. Our fees are generally negotiable. Fees vary because of negotiations, discussions
and/or factors that include, but are not limited to, the circumstances of the client, the size and
scope of the overall client relationship, client investment guidelines, additional or differing levels of
servicing, or as otherwise agreed with specific clients.
A. ORG Compensation
Financial Planning Fees
ORG Partners offers either hourly or fixed fee arrangements to all clients for its financial planning
services. Fixed fees are computed based upon a good faith estimate of the hours required to perform
services. ORG attempts to maintain parity with hourly and fixed charges while allowing some flexibility in
estimation, considering case complexity and client-specific circumstances. Financial planning fees are
negotiated on an individual basis at the time of the engagement for such services. Factors considered in
determining the fees charged generally include, without limitation, the type of financial planning services
provided such as retirement planning, legacy planning, tax planning, insurance, and special needs
planning. An initial meeting is scheduled with a prospective client at no cost or obligation. The purpose of
the meeting is to inform the prospective client of the types of services the Adviser provides and to
generally discuss what the client desires from such a financial planning relationship. If the prospective
client is interested in exploring the Adviser’s services in more detail, the Adviser will review the
prospective client’s recent income tax returns and make a listing of his/her assets and liabilities. At a
subsequent session, the prospective client is given an idea of the specific value of pursuing this financial
planning process and is quoted a fee for the financial planning services to be provided. The financial
planning fee is quoted on a project basis and covers projected time and expense associated with working
with this client for a twelve-month period. This includes gathering data, developing the written plan,
reviewing the plan with appropriate advisers, discussing the plan with the client, implementation, and
continuing to review, monitor and update the client’s affairs throughout the ensuing twelve months.
The financial planning fee is based upon several factors, including net worth, gross income, complexity of
one’s financial affairs, and the time necessary to meet each individual client’s goals and priorities. Certain
unforeseen expenses could perhaps not be included in the financial planning fee and would be billed
directly.
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 8 of 24
Once the client verbally agrees to the personal financial planning process, the process to develop the
written documents begins. Once the financial plan is completed and the appropriate advisers have
reviewed the plan, a meeting is scheduled to discuss the plan and the specific items to be implemented
with the client. The client takes from this meeting the written plan.
The client will be invoiced for the services provided. Payments are expected within 30 days of the invoice
date through an approved payment method offered by ORG Partners as outlined on the invoice. The
financial planning fee shall be mutually agreed upon in advance by and between the client and ORG. Any
such fee shall be separate from the asset-based investment management fee. The Adviser reserves the
right to waive a portion of or the entire financial planning fee.
The client can terminate the financial planning and/advisory relationship at any time within 10 days’
written notice.
Investment Consulting Fees
The Adviser bases its annual investment consulting fee for retirement plan assets upon a percentage (%)
of the market value of the assets and the specific types of investment consulting services provided. The
Adviser charges an annual fee of up to 2.00% of assets under management. The Adviser can choose to
charge a lower asset-based fee at its sole discretion.
Platform Fees
When a client is invested with the Mercato platform, the Adviser receives compensation in the form of a
fee, this fee is not shared with the advisor.
Investment Management Fees
The Adviser bases its annual investment management fee upon a percentage of assets under
management. The Adviser charges an annual fee of up to 2.00% of assets under management. The
Adviser can choose to charge a lower asset-based fee at its sole discretion.
Fee Schedule
The client agrees to pay the following fees:
• The management fee is in the amount of 200 basis points, at maximum, deducted on a quarterly
basis.
• Platform fees (e.g., Liberty Fi, Envestnet, etc.)
•
Investment management fees payable to third parties. Model portfolio advisors could include
affiliates of ORG.
o ORG Partners can invest client assets in models that are created by affiliates of ORG
Partners and the affiliates could be compensated on models used by ORG Partners
clients.
Fee Calculation Basis
The value used to calculate the investment management fee will be based on the average daily balance
computed at the close of business each trading day or the value of the assets on the last day of the prior
quarter. Your specific billing will be referenced above and is detailed in your investment management
agreement.
Average Daily Balance Billing
The figure used in the fee calculation is the average daily balance of the previous quarter computed at
the close of business each trading day. In computing Average Daily Balance in the account, shares of any
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 9 of 24
mutual funds are valued at their respective net asset value as calculated on the valuation date in
accordance with each fund’s prospectus. The value of stocks, bonds, options, and other securities is the
closing price provided by custodians and/or reputable pricing services. You should not deem valuation,
for fee calculation purposes, as a guarantee with respect to marketability/liquidation value of those
assets.
Last Day of the Previous Quarter Billing
The figure used in the fee calculation is the value of assets on the last day of the previous quarter, as
valued by the custodian.
Payment of Fees
The fees listed above are payable by the client to ORG Partners Quarterly- in advance, based upon the
fee calculation method detailed in the client’s investment management agreement for the previous
quarter.
Third-Party Money Manager Fees
Fees charged by Third-Party Money Managers are often similar to, more, or less than fees assessed by
ORG Partners. The Client will pay any TPMM engaged pursuant to the foregoing fees charged by the
managers, which are separate from and in addition to the Adviser’s fees. Clients referred to a TPMM for
the management of a separate account are directed to the disclosure documents.
Negotiated Fees
The Adviser, in its sole discretion, can reduce its investment management fee based upon certain factors,
like anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, negotiations with client and other considerations.
Other Fees
Clients not participating in a wrap fee program will incur transaction charges for trades executed in their
accounts. These transaction charges are separate from our fees and will generally be disclosed in the
brokerage or custodian agreement in place with respect to your account. Clients can incur certain charges
imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-
lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions. Also, clients will pay the following separately incurred expenses:
charges imposed directly by an investment model, mutual fund, index fund, or ETF, which expenses and
charges are generally disclosed in the fund's prospectus (e.g., fund management fees, distribution fees and
other fund expenses). Clients could be responsible for paying fees charged by sub-advisers, money
managers, Platforms, and/or Platform managers that have been engaged to manage their account as
described in the investment management agreement. Such charges, fees, and commissions are exclusive of,
and in addition to, our fee. ORG, or our affiliate, receives a portion of fees charged by Platforms and for
certain investment models. Item 10 further describes this arrangement, and the conflicts of interest
presented.
This brochure describes our non-wrap fee advisory services; clients utilizing our wrap fee portfolio
management should see the separate Wrap Fee Program Brochure for additional details regarding third
party fees.
Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for
client transactions and determining the reasonableness of their compensation (e.g., commissions).
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 10 of 24
B. Billing of Fees
ORG Partners ’s investment management fees shall be assessed quarterly, in advance, based upon the fee
calculation method detailed in the client’s investment management agreement for the prior quarter. New
accounts will be assessed a prorated fee depending upon the number of days remaining in the quarter.
The Adviser clients must provide their consent in advance to direct debiting of investment management
fees from their custodial account. The Investment Advisory Agreement and the custodial/ clearing
agreement authorize the custodian to debit the client account for the amount of the Adviser’s investment
management fee, and to directly remit that investment management fee to the Adviser in compliance
with regulatory procedures. The Adviser can send each client an itemized fee invoice each quarter –
please see Item 15 for additional information. In the limited event that the Adviser bills the client directly,
payment in full is expected upon presentation of the invoice. In the event an agreement is terminated,
the client will receive a prorated refund for fees paid in advance.
C. Other Fees
Unless clients direct otherwise or an individual client’s circumstances require, the Adviser generally
recommends one of several unaffiliated custodians (e.g., Charles Schwab & Co., Sanders Morris Harris.
etc.) serve as the broker-dealer/custodian for client investment accounts. Broker dealers such as those
listed above can charge brokerage commissions and/or transaction fees for effecting certain securities
transactions. For example, these custodians can charge commissions for individual equity and fixed
income securities transactions, or fees can be charged for certain no-load mutual fund transactions. In
addition to the Adviser’s investment management fee, custodial brokerage commissions and/or
transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases,
charges imposed at the fund level (e.g., management fees and other fund expenses).
Advisor Credit Exchange
ORG Partners participates on the Advisor Credit Exchange platform (“ACx”) presented by the Advisor
Credit Exchange, LLC (“ACE”). The ACx platform is made available by ACE to certain Advisors, and
Participating Lenders and their respective authorized users to enable matching and pre-qualification of
Advisor Clients with Participating Lenders based on Participating Lenders’ credit criteria, along with such
other features and functionality as offered by ACE from time to time. This presents a conflict of interest
because ACE agrees to pay the Advisor a fee for each loan referred through ACx; this arrangement
presents a conflict of interest and gives the Advisor an incentive to recommended participating lenders
based on the compensation received. Clients have the option to search for participating lenders through
other channels not affiliated with us.
Performance-Based Fees and Side-By-Side Management
Item 6
ORG Partners does not advise any client accounts that are subject to performance-based fee
arrangements.
Types of Clients
Item 7
The Adviser predominantly offers its services to individuals, high net worth individuals, pension and
profit-sharing plans and participants, trusts, estates, charitable organizations, corporations, or business
entities.
ORG Partners generally requires an account minimum of $25,000 for investment management services.
When a consolidated client account value in this program falls below $25,000 in value, the minimum
quarterly fee of $100.00 will be charged. ORG Partners Clients with assets at or below the minimum
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 11 of 24
account size can pay a higher percentage rate on their annual advisory fees than the fees paid by clients
with significantly greater assets under management.
The Adviser can reduce or waive its minimum asset requirement based upon certain factors, like
anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, negotiations with client and other considerations.
Other exceptions can apply to employees of the Adviser and their relatives, or relatives of existing
clients.
Methods of Analysis, Investment Strategies and Risk of Loss
Item 8
A. Methods of Analysis and Investment Strategies
The Adviser’s security analysis methods can include fundamental analysis, technical analysis, charting
and cyclical analysis.
The main sources of information for analysis include financial newspapers and magazines, inspections of
corporate activities, research materials prepared by others, corporate rating services, annual reports,
prospectuses, filings with the Securities and Exchange Commission, and company press releases.
Additional research tools and sources of information that the Adviser can use include mutual fund and
stock information provided by unaffiliated third parties (e.g., Morningstar, etc.) and many other reports
located on the Internet using the World Wide Web.
The Adviser is permitted to utilize the following investment strategies when implementing investment
advice given to clients:
Long Term Purchases: (securities held at least a year)
Short Term Purchases: (securities sold within a year)
Trading: (securities sold within thirty (30) days)
•
•
•
• Options (contract for the purchase or sale of a security at a predetermined price during a
specific period of time)
Strategic and Tactical Asset Allocation can be utilized with domestic mutual funds, exchange-traded
funds, or stocks and bonds as the core investments. Global mutual funds, sector funds and specialty
exchange-traded funds can be added as satellite positions. Portfolios can be further diversified among
large, medium, and small sized investments in an effort to control the risk associated with traditional
markets. Investment strategies designed for each client are based upon specific objectives stated by the
client during consultations. Clients can change their specific objectives at any time. Each client executes
an Investment Policy Statement that documents their specific objectives and their desired investment
strategy.
Please Note: Different types of investments involve varying degrees of risk, and it should not be assumed
that future performance of any specific investment or investment strategy recommended or undertaken
by the Adviser will be profitable or equal any specific performance level. Investing in securities involves
risk of loss that clients should be prepared to bear.
B. Risk of Loss
Risk is inherent in any investment in securities and the Adviser does not guarantee any level of return on
a client’s investments. There is no assurance that a client’s investment objectives will be achieved. A
client is subject to certain risks, including, but not limited to, the risks described below. The risks
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 12 of 24
discussed below vary by investment style or strategy. These risks do not always apply to a client. A client
should also review the prospectuses or other disclosure documents for the securities purchased for the
client’s account, as they will contain important information about the risks associated with investing in
such securities.
Investment strategies recommended by the Adviser can be subject to some or all of the following types of
risk:
•
Interest-rate Risk: Fluctuations in interest rates can cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing their
market values to decline.
•
• Market Risk: The price of a security, bond, ETF, or mutual fund can drop in reaction to tangible
and intangible events and conditions. This type of risk is caused by external factors independent
of a security’s particular underlying circumstances. For example, political, economic, and social
conditions trigger market events.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar
next year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against
the currency of the investment’s originating country. This is also referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments could have to be
reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed
income securities.
•
• Business Risk: These risks are associated with a particular industry or a particular company within
an industry. For example, oil-drilling companies depend on finding oil and then refining it, a
lengthy process, before they can generate a profit. They can carry a higher risk of profitability
than an electric company, which generates its income from a steady stream of customers who
buy electricity no matter what the economic environment is like.
Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets
are more liquid if many investors are interested in buying or selling a standardized product. For
example, Treasury Bills are highly liquid, while real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of
profitability, because the company must meet the terms of its obligations in good times and bad.
During periods of financial stress, the inability to meet loan obligations can result in bankruptcy
and/or a declining market value.
• Risks of Investments in ETFs, Mutual Funds, and Other Investment Pools: ORG Partners can
invest client portfolios in ETFs, mutual funds, and other investment pools (“Funds”). Investments
in Funds are generally less risky than investing in individual securities because of their diversified
portfolios; however, these investments are still subject to risks associated with the markets in
which they invest. In addition, Funds’ success will be related to the skills of their managers and
their performance in managing their Funds. Registered Funds are also subject to risks due to
regulatory restrictions applicable to registered investment companies under the Investment
Company Act of 1940, as amended.
• Fixed Income Risks: ORG Partners can invest portions of client assets directly in fixed income
instruments, such as bonds and notes, or invest in Funds that invest in bonds and notes. While
investing in fixed income instruments, either directly or through Funds, is generally less volatile
than investing in stock (equity) markets, fixed income investments nevertheless are subject to
risks. These risks include, without limitation, interest rate risks (risks that changes in interest
rates will devalue the investments), credit risks (risks of default by borrowers), or maturity risk
(risks that bonds or notes will change value from the time of issuance to maturity). ORG Partners
can invest portions of client assets into securities that are rated below investment grade
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 13 of 24
(commonly known as “high yield” or “junk bonds”). Securities which are in the lower-grade
categories generally offer a higher current yield than is offered by higher-grade securities of
similar maturities, but they also generally involve greater risks, such as greater credit risk, greater
market risk and volatility, and greater liquidity concerns. These investments are generally
considered to be speculative based on the issuer’s capacity or incapacity to pay interest and
repay principal.
• Financial Planning Risks: Financial planning is inherently speculative, and ORG Partners makes no
guarantee regarding the success or feasibility of any financial plan. The information forming the
basis of any financial plan will be derived from sources that ORG Partners believes are reliable,
including information provided by the client, and the accuracy of such information is not
guaranteed or independently verified by the Advisor. Certain financial planning services include
educational information regarding the effect of taxes or recommendations with respect to
insurance coverage types and amounts. Clients should understand that this tax and insurance
information is general in nature. Nothing recommended or outlined by ORG Partners should be
used by a client as a substitute for competent legal, accounting, or tax counsel provided by
the client’s personal attorney, accountant, and/or tax advisor. Additionally, ORG Partners strongly
recommends that each client review each area of potential and/or actual insurance coverage
need with the client’s insurance agent to ensure that adequate coverage exists.
• Cybersecurity Risk: As technology becomes more integrated into ORG Partners operations, ORG
Partners will face greater operational risks through breaches in cybersecurity. A breach in
cybersecurity refers to both intentional and unintentional events that cause ORG Partners to lose
proprietary information, suffer data corruption, or lose operational capacity. This in turn could
cause ORG Partners to incur regulatory penalties, reputational damage, additional compliance
costs associated with corrective measures, and/or financial loss. Cybersecurity threats can result
from unauthorized access to ORG Partners’ digital information systems (e.g., through “hacking”
or malicious software coding), but can also result from outside attacks such as denial-of-service
attacks (i.e., efforts to make network services unavailable to intended users). In addition, because
ORG Partners works closely with third-party service providers (e.g., administrators, transfer
agents, and custodians), cybersecurity breaches at such third-party service providers can subject
ORG Partners to many of the same risks associated with direct cybersecurity breaches. The same
is true for cybersecurity breaches at any of the issuers in which ORG Partners invest. While ORG
Partners and their third-party service providers have established information technology and
data security programs and have in place business continuity plans and other systems designed
to prevent losses and mitigate cybersecurity risk, there are inherent limitations in such plans and
systems, including the possibility that certain risks have not been identified or that cyber-attacks
can be highly sophisticated.
• Private Equity (PE) Funds and Private placement Securities Risks are inherently illiquid; they
cannot be easily sold or exchanged for cash without a substantial loss in value. Investors are
usually required to commit their capital for extended periods. Private equity funds typically
charge high fees, including management fees and performance fees (carried interest). These fees
can erode returns, especially if the fund's performance does not meet expectations. Private
Equity funds are subject to higher degrees of risk and are not suitable for all investors. Their
performance is heavily dependent on the skill and experience of the management team. Private
equity funds commonly use leverage (borrowed funds) to enhance returns, which can increase
the potential for significant losses, especially in downturns. In addition, Private Equity
investments often lack transparency. Detailed information about the fund's operations and
investments is not readily available, making it challenging to evaluate the valuations of private
companies.
• Private Placement Securities have similar characteristics and carry risks akin to those of Private
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 14 of 24
Equity Funds. However, Private Placements are typically offered to institutional clients or
accredited investors.
Please Note: In light of these risks of loss and potentially enhanced volatility, clients can direct the
Adviser, in writing at any time, not to employ any or all of the investment strategies recommended by
ORG Partners for their account.
C. Other Fees
Unless clients direct otherwise or an individual client’s circumstances require, the Adviser generally
recommends one of several unaffiliated custodians (e.g., Charles Schwab & Co., Saunder Morris Harris
etc.) serve as the broker-dealer/custodian for client investment accounts. Broker dealers such as those
listed above can charge brokerage commissions and/or transaction fees for effecting certain securities
transactions. For example, these custodians can charge commissions for individual equity and fixed
income securities transactions, or fees can be charged for certain no-load mutual fund transactions. In
addition to the Adviser’s investment management fee, custodial brokerage commissions and/or
transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases,
charges imposed at the fund level (e.g., management fees and other fund expenses).
Disciplinary Information
Item 9
Investment Advisors are required to disclose legal or disciplinary events that are material to a client’s or
prospective client’s evaluation of the Advisor’s business or the integrity of the Advisor’s management.
ORG Partners has no such disclosures to provide.
Other Financial Industry Activities and Affiliation
Item 10
The Adviser is not registered as a securities broker-dealer, futures commission merchant, commodity
pool operator or commodity trading advisor.
Some representatives of the firms are also registered representatives of Broker Dealers. Advisors that are
also registered representatives of a broker dealer can offer securities and receive normal and customary
commissions as a result of securities transactions. Therefore, a conflict of interest would arise as these
commissionable securities sales could create an incentive to recommend products based on the
compensation they would earn and not necessarily be in the best interests of the clients.
Many of the financial professionals at our firm are licensed insurance agents. ORG Partners, at times,
recommends the use of various insurance products where we believe it is in your best interest. You
should be aware that these services pay a commission or other compensation and present a conflict of
interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser.
ORG Partners always seeks to act in the best interest of the client; including the sale of commissionable
products to advisory clients, and we will disclose the commission prior to the sale. You are in no way
required to implement the plan through any representative of ORG Partners in such an individual’s
capacity as an insurance agent.
A. Affiliations
ORG affiliations include Ascentis Asset Management, LLC (CRD #318126), Ascentis Wealth Management, LLC (CRD
#330923) and Golden State Equity Partners, LLC (CRD #322879) through common ownership. The Firm’s ownership
structure has changed, with Michael Mansur having the largest individual 0wnership position in Ascentis
Operations, LLC, the holding company of ORG Partners, LLC through a private Irrevocable Trust.
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 15 of 24
Code of Ethics, Participation or Interest in Client Transactions and Personal
Item 11
Trading
A. ORG Partners Code of Ethics
We have adopted a Code of Ethics pursuant to Advisers Act Rule 204A-1. A basic tenet of our Code of
Ethics is that the interests of clients are always placed first. The Code of Ethics includes standards of
business conduct requiring Access Persons to comply with the federal securities laws and the fiduciary
duties an investment adviser owes to its clients. The Code of Ethics also requires that all Access Persons
comply with ethical restraints relating to clients and their accounts, including restrictions on gifts and
provisions intended to prevent violations of laws prohibiting insider trading.
The goal of our Code of Ethics is to ensure that personal investing activities by our employees are
consistent with our fiduciary duty to its clients. The Code of Ethics includes standards of business conduct
requiring Access Persons to comply with the federal securities laws and the fiduciary duties an investment
adviser owes to its clients. The Code applies to all Access persons that are considered to be supervised by
ORG Partners. Personnel are considered to be Access Persons under the Code including the following:
• Directors, officers, and partners of the Firm (or other persons occupying a similar status or
performing similar functions).
• Employees of the Firm;
• Any other person who provides advice on behalf of the Firm and is subject to the Firm’s
supervision and control.
Our Code of Ethics is available to you upon request. You can obtain a copy of our Code of Ethics by
contacting our Chief Compliance Officer, Justine Kidwell, at justine.kidwell@orgpag.com.
B. Participation or Interest in Client Transactions
ORG Partners and/or its representatives are permitted to engage in securities transactions for their own
accounts, including the same or related securities that are recommended to or owned by clients of the
Adviser. Because Advisors can invest in the same securities as clients, there is a possibility that an Advisor
will benefit from a client’s trading activity in a security held by the Advisor.
C. Personal Trading
To address the potential for conflict of interests, the Adviser has adopted a Code that applies to its
representatives who have access to non-public information relating to advisory client accounts (“Access
Persons”). The Code prohibits Access Persons from using knowledge about advisory client account
transactions to profit personally, directly, or indirectly, by trading in his/her personal accounts. To help
monitor any conflict of interest, all Access Persons are required to submit quarterly personal securities
transactions and annual holdings reports for review by the Chief Compliance Officer.
Brokerage Practices
Item 12
A. Broker-Dealer Selection
We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms
that are overall most advantageous when compared with other available providers and their services. We
consider a wide range of factors, including these:
• Combination of transaction execution services along with asset custody services
(generally without a separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capabilities to facilitate transfers and payments to and from accounts (wire transfers,
check requests, bill payment, etc.)
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 16 of 24
• Breadth of investment products made available (stocks, bonds, mutual funds, exchange
traded funds (ETFs), etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate them
• Reputation, financial strength, and stability of the provider
• Their prior service to us and our other clients
• Availability of other products and services that benefit us
ORG Partners does not maintain custody of your assets that we manage, although we can be deemed to
have custody of your assets if you give us authority to withdraw assets from your account (see Item 14 –
Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a
broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (Schwab), a
registered broker-dealer, member SIPC, as the qualified custodian. We are independently owned and
operated and are not affiliated with Schwab.
We also recommend the brokerage and custodial services of Sanders Morris Harris (“SMH”), member
FINRA/SIPC. SMH is an unaffiliated SEC-registered broker-dealer and FINRA member.
Research and Other Soft Dollar Benefits
Our firm has an arrangement with Charles Schwab & Co., Inc. (“Schwab”), registered broker dealer,
Members SIPC which provides our firm with Schwab “platform” services. The platform services include,
among others, brokerage, custodial, administrative support, record keeping and related services that are
intended to support our firm in conducting business and in serving the best interests of our clients but that
can benefit our firm. However, the receipt of those materials is not tied to the execution of client
transactions. The Adviser seeks to select broker-dealers based upon the broker’s or dealer’s ability to
provide best execution, and the Adviser will not cause clients to pay commissions (or markups or
markdowns) higher than those charged by other broker-dealers for the purpose of obtaining soft dollar
benefits.
Some of the products and services that qualify as “brokerage or research services” under Section 28(e) of
the Securities Exchange Act of 1934 (“Exchange Act”). This is commonly referred to as a “soft dollar”
arrangement.
The Adviser could from time to time receive generic market commentaries, market research, or transition
support from broker-dealer firms.
Brokerage for Client Referrals
We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or
third party.
Your Brokerage and Custody Costs
We recommend the brokerage and custodial services of Schwab Advisor Services division of Charles
Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, to maintain custody of
clients’ assets and to effect trades for their accounts. The final decision to custody assets with Schwab
is at the discretion of our clients, including those accounts under ERISA or IRA rules and regulations, in
which case the client is acting as either the plan sponsor or IRA accountholder. We are independently
owned and operated and not affiliated with Schwab. Schwab provides us with access to its institutional
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 17 of 24
trading and custody services, which are typically not available to Schwab retail investors. These
services generally are available to independent investment advisors on an unsolicited basis, at no
charge to advisors. Schwab’s services include brokerage services that are related to the execution of
securities transactions, custody, research, including that in the form of advice, analyses and reports,
and access to mutual funds and other investments that are otherwise generally available
only to institutional investors or would require a significantly higher minimum initial investment. Our firm
and/or our supervised persons receive benefits.
Schwab also makes available to ORG other products and services that benefit us but on occasion do
not benefit our clients’ accounts. These benefits can include national, regional or ORG specific
educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits
can include occasional business entertainment of personnel of ORG by Schwab Advisor Services
personnel, including meals, invitations to sporting events, including golf tournaments, and other forms
of entertainment, some of which can accompany educational opportunities.
Other of these products and services assist us in managing and administering clients’ accounts. These
include software and other technology (and related technological training) that provide access to client
account data (such as trade confirmations and account statements), facilitate trade execution (and
allocation of aggregated trade orders for multiple client accounts), provide research, pricing information
and other market data, facilitate payment of ORG’s fees from its clients’ accounts, and assist with back-
office training and support functions, recordkeeping, and client reporting. Many of these services
generally, can be used to service all or some substantial number of ORG’s accounts, including accounts
not maintained at Schwab Advisor Services.
Schwab Advisor Services also makes available to ORG other services intended to help ORG manage
and further develop its business enterprise. These services include professional compliance, legal and
business consulting, publications and conferences on practice management, information technology,
business succession, regulatory compliance, employee benefits providers, human capital consultants,
insurance, and marketing. In addition, Schwab makes available, arranges and/or pays vendors for
these types of services rendered to ORG by independent third parties. Schwab Advisor
Services can discount or waive fees they would otherwise charge for some of these services or pay all or a
part of the fees of a third-party providing these services to ORG.
Sanders Morris Harris:
Our firm recommends that clients establish brokerage accounts with the Sanders Morris Harris
(“SMH”), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to effect
trades for their accounts. The final decision to custody assets with SMH is at the discretion of the
client, including those accounts under ERISA or IRA rules and regulations, in which case the client is
acting as either the plan sponsor or IRA accountholder. ORG is independently owned and operated and
not affiliated with SMH. SMH provides ORG with access to trading and custody services, which are
typically not available to SMH retail investors. These services generally are available to independent
investment advisors on an unsolicited basis, at no charge to advisors. SMH’s services include
brokerage services that are related to the execution of securities transactions, custody, research,
including that in the form of advice, analyses and reports, and access to mutual funds and other
investments that are otherwise generally available only to institutional investors or would require a
significantly higher minimum initial investment.
SMH also makes available to ORG other products and services that benefit ORG but do not always
benefit its clients’ accounts. These benefits can include national, regional or ORG specific educational
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 18 of 24
events organized and/or sponsored by SMH. Other potential benefits can include occasional business
entertainment of personnel of ORG by SMH personnel, including meals, invitations to sporting events,
including golf tournaments, and other forms of entertainment, some of which can accompany
educational opportunities.
While, as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients
maintain their assets in accounts at Schwab/SMH can be based in part on the benefit to ORG of the
availability of some of the foregoing products and services and other arrangements and not solely on
the nature, cost or quality of custody and brokerage services provided by Schwab/SMH, which creates
a potential conflict of interest.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other
compensation, such as brokerage services or research. Our affiliate, Ascentis Asset
Management, does have a fee sharing agreement with SMH that allows that entity to receive
a share of the revenue that SMH earns from margin loan spreads and remarketing fees from
money market-sweep products generated by clients referred to SMH. Although ORG does not
receive compensation directly, this fee sharing agreement does benefit our affiliate and as
such creates a conflict when we refer to clients to SMH.
Directed Brokerage
The Adviser will comply with any guidelines and/or limitations reasonably requested by a client relating to
brokerage for the client’s account that are contained in the client’s investment management agreement.
When possible, the Adviser will also observe any non-binding statement of client preferences with
respect to brokerage direction.
If a client directs the Adviser to use a particular broker-dealer for execution of the client’s trade orders (a
“directed brokerage arrangement”), and the Adviser agrees to the arrangement, a client should
understand that the Adviser could be unable to achieve best execution for the client’s transactions. Any
costs related to the directed brokerage arrangement are not included in the Adviser’s fee, and the client
is solely responsible for monitoring, evaluating, and reviewing the arrangement with the directed broker-
dealer and paying any commissions or markups or markdowns or other costs imposed by the directed
broker-dealer. Additionally, the Adviser generally will not aggregate the client’s directed brokerage trade
orders with orders for other clients of the Adviser or include such orders in its trade rotation process.
If the Adviser aggregates a client’s directed brokerage trade orders with trade orders for other clients of
the Adviser, the Adviser can employ the use of “step-outs” to satisfy the client’s directed brokerage
arrangement. A “step-out” occurs when an executing broker executes the trade and then “steps out” the
trade to a clearing broker (which would be the directed broker-dealer in a directed brokerage
arrangement) that confirms and settles the trade. In such a case, a client will bear the costs of any
commissions, markups or markdowns imposed by the executing broker-dealer in addition to the costs of
any commissions, markups or markdowns imposed by the directed broker-dealer.
If a client directs the Adviser to use a particular broker-dealer, and if the particular broker-dealer referred
the client to the Adviser or if the particular broker-deal refers other clients to the Adviser in the future,
the Adviser can benefit from the client’s directed brokerage arrangement. Because of these potential
benefits, the Adviser will have an economic interest in having the client continue the directed brokerage
arrangement. The benefits that the Adviser receives can conflict with the client’s interest in having the
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 19 of 24
Adviser recommend that the client utilize another broker-dealer to execute some or all transactions for
the client’s account.
Before directing the Adviser to use a particular broker-dealer, a client should carefully consider the
possible costs or disadvantages of directed brokerage arrangements.
B. Trade Errors
The Firm nor its Advisors will share in any gains resulting from the trade error. The Custodians Charles
Schwab is in the practice of donating trade error gains to a charity of their choice. Should the trade error
result in a loss, the Firm will charge back the losses to the Advisor.
C. Order Aggregation, Allocation, and Rotation Practices
In order to seek best execution for clients, the Adviser can aggregate contemporaneous buy and sell
orders for the accounts over which it has discretionary authority. This practice of bunching trades
enables the Adviser to obtain more favorable execution, including better pricing and enhanced
investment opportunities, than would otherwise be available if orders were not aggregated. Bunching
transactions cal also assist the Adviser in potentially avoiding an adverse effect on the price of a security
that could result from simultaneously placing a number of separate, successive, or competing, client
orders.
It is within the Adviser’s sole discretion to bunch transactions and its decision is subject to its duty to seek
best execution. The Adviser will aggregate a client’s trade orders only when the Adviser deems it to be
appropriate and in the best interests of the client and permitted by regulatory requirements.
All advisory clients participating in a bunched transaction will receive the same execution price for the
security bought or sold. Average prices can be used when allocating purchases and sales to a client’s
accounts because such securities are be purchased and sold at different prices in a series of bunched
transactions. As a result, the average price received by a client could be higher or lower than the price
the client would have received had the transaction been affected for the client independently from the
bunched transaction. In addition, a client’s transaction costs can vary depending upon, among other
things, the type of security bought or sold, and the commission or markup or markdown charged by the
executing broker-dealer.
The number of securities available in the marketplace, at a particular price at a particular time, on
occasion, will not satisfy the needs of all clients participating in a bunched transaction and can be
insufficient to provide full allocation across all client accounts. To address this possibility, the Adviser has
adopted trade allocation policies and procedures that are designed to make securities allocations to
discretionary client accounts in a manner such that all such clients receive fair and equitable treatment.
If a bunched transaction cannot be executed in full at the same price or time, the securities actually
purchased or sold by the close of each business day will generally be allocated pro rata among the clients
participating in the bunched transaction. Adjustments to this pro rata allocation can be made, at the
discretion of the Adviser, to take into consideration account specific investment restrictions, undesirable
position size, account portfolio weightings, client tax status, client cash positions and client preferences.
Adjustments can also be made to avoid a nominal allocation to client accounts.
When the Adviser is not able to aggregate trades, the Adviser generally uses a trade rotation process that
is designed to be fair and equitable to its clients.
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 20 of 24
Item 13
Review of Accounts
A. Periodic Reviews
IARs are required to conduct quarterly reviews of client statements to ensure 1) the statement is
alignment with the Investor Advisory Agreement and agreed contractual fee schedule, 2) the clients’
accounts are in line with their investment objectives, appropriately positioned based on market
conditions, and investment policies, if applicable. On an annual basis, ORG monitors client accounts to
ensure IARs are adhering to the requirements noted above. ORG does not provide written reports to
clients, however, IARs can create consolidated-performance statements. It is important to note the
custodian’s statements supersede any reports generated by your IAR.
We can review client accounts more frequently than described above. Among the factors that will
trigger an off-cycle review include major market or economic events, the client’s life events, or requests
by the client.
Investment Consulting clients receive reviews of their pension plans for the duration of the pension
consulting service. We also provide ongoing services to Consulting clients where we meet with such
clients upon their request to discuss updates to their plans, changes in their circumstances, etc.
Retirement and Pension Consulting clients do not receive written or verbal updated reports regarding
their pension plans unless they choose to contract with us for ongoing Pension Consulting services.
Financial Planning clients do not receive reviews of their written plans unless they take action to schedule
a financial consultation with us. We do not provide ongoing services to financial planning clients, but are
willing to meet with such clients upon their request to discuss updates to their plans, changes in their
circumstances, etc. Financial Planning clients do not receive written or verbal updated reports regarding
their financial plans unless they separately contract with us for a post-financial plan meeting or update to
their initial written financial plan.
Client Referrals and Other Compensation
Item 14
A. Other Compensation
Charles Schwab & Co., Inc.
As stated above, we recommend that clients establish brokerage accounts with the Schwab Advisor
Services division of Charles Schwab & Co., Inc. (“Schwab”), to maintain custody of clients’ assets and to
effect trades for their accounts. The final decision to custody assets with Schwab is at the discretion of
our clients, including those accounts under ERISA or IRA rules and regulations, in which case the client is
acting as either the plan sponsor or IRA accountholder. Schwab provides us with access to its institutional
trading and custody services, which are typically not available to Schwab retail investors.
These services generally are available to independent investment advisors on an unsolicited basis, at no
charge to advisors. Schwab’s services include brokerage services that are related to the execution of
securities transactions, custody, research, including that in the form of advice, analyses and reports, and
access to mutual funds and other investments that are otherwise generally available only to institutional
investors or would require a significantly higher minimum initial investment.
Schwab also makes available to ORG other products and services that benefit us but on occasion do not
benefit our clients’ accounts. These benefits can include national, regional or ORG specific educational
events organized and/or sponsored by Schwab Advisor Services. Other potential benefits can include
occasional business entertainment of personnel of ORG by Schwab Advisor Services personnel, including
meals, invitations to sporting events, including golf tournaments, and other forms of entertainment,
some of which can accompany educational opportunities.
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 21 of 24
Other of these products and services assist us in managing and administering clients’ accounts. These
include software and other technology (and related technological training) that provide access to client
account data (such as trade confirmations and account statements), facilitate trade execution (and
allocation of aggregated trade orders for multiple client accounts), provide research, pricing information
and other market data, facilitate payment of ORG’s fees from its clients’ accounts, and assist with back
office training and support functions, recordkeeping and client reporting. Many of these services
generally can be used to service all or some substantial number of ORG’s accounts, including accounts
not maintained at Schwab Advisor Services.
Schwab Advisor Services also makes available to ORG other services intended to help ORG manage and
further develop its business enterprise. These services can include professional compliance, legal and
business consulting, publications and conferences on practice management, information technology,
business succession, regulatory compliance, employee benefits providers, human capital consultants,
insurance, and marketing. In addition, Schwab can make available, arrange and/or pay vendors for these
types of services rendered to ORG by independent third parties. Schwab Advisor Services can reserve the
right to discount or waive fees it would otherwise charge for some of these services or pay all or a part of
the fees of a third- party providing these services to ORG.
While, as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients
maintain their assets in accounts at Schwab can be based in part on the benefit to ORG of the availability
of some of the foregoing products and services and other arrangements and not solely on the nature,
cost or quality of custody and brokerage services provided by Schwab, which creates a potential conflict
of interest.
Sanders Morris Harris
As stated above, we recommend that clients establish brokerage accounts with Sanders Morris Harris.
(“SMH”), a registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to affect
trades for their accounts. The final decision to custody assets with SMH is at the discretion of our clients,
including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as
either the plan sponsor or IRA accountholder. We are independently owned and operated and not
affiliated with SMH. SMH provides us with access to its trading and custody services, which are typically
not available to retail investors. These services generally are available to independent investment
advisors on an unsolicited basis, at no charge to advisors. SMH’s services include brokerage services that
are related to the execution of securities transactions, custody, research, including that in the form of
advice, analyses and reports, and access to mutual funds and other investments that are otherwise
generally available only to institutional investors or would require a significantly higher minimum initial
investment.
SMH also makes available to ORG other products and services that benefit us but on occasion do not
benefit our clients’ accounts. These benefits can include national, regional or ORG specific educational
events organized and/or sponsored by SMH Services. Other potential benefits can include occasional
business entertainment of personnel of ORG by SMH, including meals, invitations to sporting events,
including golf tournaments, and other forms of entertainment, some of which can accompany
educational opportunities.
Other of these products and services assist us in managing and administering clients’ accounts. These
include software and other technology (and related technological training) that provide access to client
account data (such as trade confirmations and account statements), facilitate trade execution (and
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 22 of 24
allocation of aggregated trade orders for multiple client accounts), provide research, pricing information
and other market data, facilitate payment of ORG’s fees from its clients’ accounts, and assist with back
office training and support functions, recordkeeping and client reporting. Many of these services
generally can be used to service all or some substantial number of ORG’s accounts, including accounts
not maintained at SMH.
SMH also makes available to ORG other services intended to help ORG manage and further develop its
business enterprise. These services can include professional compliance, legal and business consulting,
publications and conferences on practice management, information technology, business succession,
regulatory compliance, employee benefits providers, human capital consultants, insurance, and
marketing. In addition, SMH can make available, arrange and/or pay vendors for these types of services
rendered to ORG by independent third parties. SMH reserves the right to discount or waive fees it
would otherwise charge for some of these services or pay all or a part of the fees of a third- party
providing these services to ORG.
While, as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients
maintain their assets in accounts at SMH can be based in part on the benefit to ORG of the availability of
some of the foregoing products and services and other arrangements and not solely on the nature, cost
or quality of custody and brokerage services provided by SMH, which creates a potential conflict of
interest.
Platforms
Client accounts are generally managed via third-party investment management platforms (“Platforms”).
Platforms are paid a fee based on the amount of client assets on the Platform (“Platform Fee”). ORG, or
our affiliates, receives a portion of the Platform Fee. The Platform Fee is higher as a result of our receipt
of a portion of the Platform Fee and clients are able to access Platforms through other investment
advisers at a lower fee. Clients can be responsible for paying the Platform Fee as described in the
investment management agreement. Clients should review the investment management agreement to
determine if they are responsible for paying the Platform Fee. This fee is in addition to the compensation
we receive for our advisory services described in Item 5. Fees reduce returns over time. This creates a
conflict of interest as we have an incentive to recommend Platforms based on our receipt of a portion of
the Platform Fee rather than the best interests of the client. We have reviewed and periodically review
Platforms that we recommend and believe that the use of such Platforms is in the best interest of clients.
As of the date of this Brochure, we utilize Envestnet and Liberty Fi as Platforms.
Advisor Credit Exchange Platform (“ACx”)
ORG Partners participates on the Advisor Credit Exchange platform (“ACx”) presented by the Advisor
Credit Exchange, LLC (“ACE”). The ACx platform is made available by ACE to certain Advisors, and
Participating Lenders and their respective authorized users to enable matching and pre-qualification of
Advisor Clients with Participating Lenders based on Participating Lenders’ credit criteria, along with such
other features and functionality as are be offered by ACE from time to time. This presents a conflict of
interest because ACE agrees to pay the Advisor a fee for each loan referred through ACx; this
arrangement presents a conflict of interest and gives the Advisor an incentive to recommended
participating lenders based on the compensation received. Clients have the option to search for
participating lenders through other channels not affiliated with us.
B. Referrals
ORG Partners can provides compensation to individuals who refer clients in some instances. When
applicable, the compensation paid is a percentage of the client’s fee payments or the value of the client’s
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 23 of 24
account. The amount of compensation will vary, with the specific level determined based upon
consideration of various factors. ORG Partners can pay these fees to unaffiliated solicitors with which they
have entered into a written agreement.
Custody
Item 15
Pursuant to Rule 206(4)-2 under the Advisers Act, because we can directly deduct advisory fees from
client accounts as part of our billing process, we are deemed to have limited custody of client funds. The
qualified custodian you hold your assets with maintains actual custody of your assets. You will receive
account statements directly from the custodian at least Quarterly. They will be sent to the email or postal
mailing address you provided to the custodian. You should carefully review those statements promptly
when you receive them.
Investment Discretion
Item 16
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to an
executed investment advisory client agreement. By granting investment discretion, we are authorized to
execute securities transactions including the selection and amount of securities to be purchased or sold
for your account(s) without obtaining your consent or approval prior to each transaction. Limitations can
be imposed by the client in the form of specific constraints on any of these areas of discretion with our
firm's written acknowledgment.
If a client enters into non-discretionary arrangements with ORG, we will obtain your approval prior to the
execution of any transactions for your account(s). Clients have an unrestricted right to decline to
implement any advice provided by our firm on a non-discretionary basis.
Voting Client Securities
Item 17
We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to
our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in
the future. Clients can call, write, or email us to discuss questions they have about particular proxy votes
or other solicitations.
Financial Information
Item 18
ORG Partners does not require the prepayment of more than $1,200 in fees and for more than six months
in advance, does not take custody of client funds or securities and does not have a financial condition that
is likely to impair our ability to meet our commitments to our clients.
Form ADV Part 2 Brochure
You can obtain a current copy of the Form CRS at http://www.orgpag.com.
Page 24 of 24