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Item 1: Cover Page
Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure
September 2025
Pacific Sun Financial Wrap Program
Sponsored by:
Pacific Sun Financial Corp.
10940 Wilshire Blvd
Suite 1450
Los Angeles, CA 9002
www.PacSunFinancial.com
Firm Contact:
Mitchell Fisher
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Pacific Sun
Financial Corp. If clients have any questions about the contents of this brochure, please contact us at
(949) 716-8646. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any State Securities Authority. Additional
information about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by
searching CRD #284286.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Pacific Sun Financial Corp. is required to notify clients of any information that has changed since the
last annual update of the Wrap Brochure (“Wrap Brochure”) that may be important to them. Clients
can request a full copy of our Wrap Brochure or contact us with any questions that they may have
about the changes.
Since our last annual amendment filed on 11/12/2024, our firm does not have any material
change(s) to report.
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Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................................. 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Services, Fees & Compensation .......................................................................................................................... 4
Item 5: Account Requirements & Types of Clients .................................................................................................... 6
Item 6: Portfolio Manager Selection & Evaluation ..................................................................................................... 6
Item 7: Client Information Provided to Portfolio Manager(s) .............................................................................. 9
Item 8: Client Contact with Portfolio Manager(s) ...................................................................................................... 9
Item 9: Additional Information .......................................................................................................................................... 9
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Pacific Sun Financial Corp.
Item 4: Services, Fees & Compensation
A. Description of our services, including the types of portfolio management services, provided
under each program. Our firm must indicate the wrap fee charged for each program, or, if fees
vary according to a schedule, provide such schedule. Further, our firm is required to indicate
whether fees are negotiable and identify the portion of the total fee, or range of fees, paid to
portfolio managers.
Our firm is dedicated to providing clients with a wide array of investment advisory services. Our
firm is a corporation formed under the laws of the State of California and has been in business as
an investment adviser since 2016. Our firm is wholly owned by Mitchell Fisher. Our firm managed
$290,000,000 on a discretionary basis as of June 30th, 2025.
Our firm sponsors and offers a wrap fee program. Our firm manages assets for many different
types of clients to help meet their financial goals while remaining sensitive to risk tolerance and
time horizons. As a fiduciary it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing the client. Our firm has established a service-oriented advisory
practice with open lines of communication. Working with clients to understand their investment
objectives while educating them about our process, facilitates the kind of working relationship
we value.
Our recommended custodian, Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction
fees for U.S. listed equities and exchange traded funds. Since we pay the transaction fees charged
by the custodian to clients participating in our wrap fee program, our firm’s expenses have
decreased. This presents a conflict of interest because we are incentivized to recommend equities
and exchange traded funds over other types of securities in order to reduce our costs.
(i) Wrap Asset Management:
As part of our Wrap Asset Management service, a portfolio is created, consisting of individual
stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and
private securities or investments. The client’s individual investment strategy is tailored to their
specific needs and may include some or all of the previously mentioned securities. Portfolios will
be designed to meet a particular investment goal, determined to be suitable to the client’s
circumstances. Once the appropriate portfolio has been determined, portfolios are continuously
and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs,
stated goals and objectives.
Fee Schedule:
Assets Under Management
$0 to $999,999.99
$1,000,000 - $4,999,999.99
Over $5,000,000
Annual Percentage of Assets Charge
1.25%
1.00%
0.75%
Fees to be assessed will be outlined in the advisory agreement to be signed by the client.
Annualized fees are billed on a pro-rata basis monthly in arrears based on the value of the
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account(s) on the last day of the month. Fees are negotiable. Our firm bills on cash unless
indicated otherwise in writing. In rare cases, our firm will agree to directly invoice. Fees will
be deducted from client account(s). As part of this process, clients understand the following:
a) The client’s independent custodian sends statements at least quarterly showing the
market values for each security included in the Assets and all account disbursements,
including the amount of the advisory fees paid to our firm.
b) Clients will provide authorization permitting our firm to be directly paid by these
terms. Our firm will send an invoice directly to the custodian.
c) If our firm sends a copy of our invoice to the client, it will include a disclosure urging
the client to compare the information provided in our statement with those from the
qualified custodian.
Termination and Refunds
Either party may terminate the advisory agreement signed with our firm for the Wrap Asset
Management service by providing the other party with written or electronic notice at any
time. Upon notice of termination, pro-rata advisory fees for services rendered to the point of
termination will be charged.
B. Explanation that a wrap fee program may cost clients more or less than purchasing such services
separately and description of the factors that bear upon the relative cost of the program, such as
the cost of the services if provided separately and the trading activity in client account(s).
Our firm sponsors and offers a wrap fee program, which allows clients to pay a single fee for
investment advisory services and associated custodial transaction costs. Transaction fees will be
paid by our firm based on a percentage of the dollar amount of assets in the account(s) or via
individual transaction charges. Because our firm absorbs client transaction fees, an incentive
exists to limit trading activities in client accounts.
C. Description of any fees that clients may pay in addition to a wrap fee, and description of the
circumstances under which clients may pay these fees, including, if applicable, mutual fund
expenses and mark-ups, mark-downs, or spreads paid to market makers.
In addition to our advisory fees above, clients may also pay holdings charges imposed by the
chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund,
or exchange traded fund, which shall be disclosed in the fund’s prospectus (e.g., fund
management fees and other types of fees), distribution fees, surrender charges, variable annuity
fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads paid to market
makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes
on brokerage accounts and securities transactions. Our firm does not receive a portion of these
fees.
D. If someone recommending a wrap fee program to you, receives compensation as a result of your
participation in the program, our firm must disclose this fact. Further, our firm is required to
explain, if applicable, that the amount of the compensation may be more than what the person
would receive if you participated in our other wrap fee program or paid separately for investment
advice, brokerage and other services. Finally, our firm must explain that someone recommending
a wrap fee program may have a financial incentive to recommend the wrap fee program over
other programs or services.
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Pacific Sun Financial Corp.
Our firm does not recommend or offer the wrap program services of other providers.
Item 5: Account Requirements & Types of Clients
Our firm has the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension and Profit Sharing Plans;
• Corporations, Limited Liability Companies and/or Other Business Types
Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
us.
Item 6: Portfolio Manager Selection & Evaluation
A. Description of how our firm selects and reviews portfolio managers, our basis for recommending
or selecting portfolio managers for particular clients, and our criteria for replacing or
recommending the replacement of portfolio managers for the program and for particular clients.
Our firm does not utilize outside portfolio managers. All accounts are managed by our in-house
licensed investment adviser representatives (“IARs”) of our firm. Prior to becoming licensed with
our firm, each IAR’s industry experience, licensure, outside business activities, client complaints
(if any), disciplinary or regulatory history (if any) and financial well-being will be reviewed. Each
IAR will then have a Form U4 and ADV Part 2B on file with our firm.
1) Standards used to calculate portfolio manager performance, such as industry standards or
standards used solely by our firm.
Performance returns of wrap portfolios are reviewed at least quarterly. The nature of these
reviews is to learn whether client accounts are in line with their investment objectives and
appropriately positioned based on market conditions. If these standards fall below the client
objectives, our firm will discuss the review with the portfolio manager for proactive action to
realign the investment strategy.
2) Indication of whether our firm reviews, or whether any third-party reviews, performance
information to determine or verify its accuracy or its compliance with presentation
standards. If so, a brief description of the nature of the review and the name of any third party
conducting the review is required.
Our firm reviews performance information in order to verify its accuracy. Please see Item
6A(1) for more information.
B. Disclosure of whether our firm or any related persons act as a portfolio manager for a wrap fee
program described in the wrap fee program brochure. Our firm must explain the conflicts of
interest faced because of this arrangement and describe how these conflicts of interests are
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addressed. Further, our firm must disclose whether related person portfolio managers are
subject to the same selection and review as the other portfolio managers that participate in the
wrap fee program. If they are not, our firm must describe how related person portfolio managers
are selected and reviewed.
Our firm’s IARs act as portfolio manager(s) for this wrap fee program. A conflict may arise in that
other investment advisory firms may charge the same or lower fees than our firm for similar
services. IARs are subject to individual licensing requirements as imposed by state securities
boards. Our firm confirms or updates each IAR’s Form U4 on an annual basis. IAR supervision is
conducted by our Chief Compliance Officer.
C. If our firm, or any of our supervised persons covered under or investment adviser registration,
act as a portfolio manager for a wrap fee program described in the wrap fee program brochure,
our firm must respond to Items 4.B, 4.C, 4.D (Advisory Business), 6 (Performance-Based Fees and
Side-By-Side Management), 8.A (Methods of Analysis, Investment Strategies and Risk of Loss)
and 17 (Voting Client Securities) of Part 2A of Form ADV (Firm Brochure).
Our firm and IARs act as portfolio manager(s) for this wrap fee program.
(1) Advisory Business:
Information about our wrap fee services can be found in Item 4 of this brochure.
(2) Individual Tailoring of Advice to Clients:
Our firm offers individualized investment advice to our Wrap Asset Management clients.
(3) Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of
Securities:
Each Wrap Asset Management client has the opportunity to place reasonable restrictions on the
types of investments to be held in the portfolio. Restrictions on investments in certain securities
or types of securities may not be possible due to the level of difficulty this would entail in
managing the account.
(4) Participation in Wrap Fee Programs.
Our firm only offers wrap fee accounts to our clients, which are managed on an individualized
basis according to the client’s investment objectives, financial goals, risk tolerance, etc.
(5) Performance-Based Fees & Side-By-Side Management.
Our firm does not charge performance-based fees.
(6) Methods of Analysis, Investment Strategies & Risk of Loss
Description of the Methods of Analysis and Investment Strategies Used In Formulating
Investment Advice or Managing Assets
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We attempt to measure the intrinsic value of a security by looking at economic and financial
factors (including the overall economy, industry conditions, and the financial condition and
management of the company itself) to determine if the company is underpriced (indicating it
may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental
analysis does not attempt to anticipate market movements. This presents a potential risk, as
the price of a security can move up or down along with the overall market regardless of the
economic and financial factors considered in evaluating the stock.
The following investment strategies are used managing client accounts, provided that such
strategies are appropriate to the needs of the client and consistent with the client's
investment objectives, risk tolerance, and time horizons, among other considerations:
Long-Term Purchases:
When utilizing this strategy, we may purchase securities with the idea of holding them for a
relatively long time (typically held for at least one year). A risk in a long-term purchase
strategy is that by holding the security for this length of time, we may not take advantage of
short-term gains that could be profitable to a client. Moreover, if our predictions are
incorrect, a security may decline sharply in value before we make the decision to sell.
Typically, we employ this sub-strategy when we believe the securities to be well valued;
and/or we want exposure to a particular asset class over time, regardless of the current
projection for this class. The potential risks associated with this investment strategy could
involve a lower than expected return, for many years in a row. Lower-than-expected returns
that last for a long time and/or that are severe in nature would have the impact of
dramatically lowering the ending value of your portfolio, and thus could significantly impede
your ability to meet financial goals.
Short-Term Purchases:
When utilizing this strategy, we may also purchase securities with the idea of selling them
within a relatively short time (typically one year or less). We do this in an attempt to take
advantage of conditions that we believe will soon result in a price swing in the securities we
purchase. The potential risk associated with this investment strategy could be associated
with the currency or exchange rate. Currency or exchange rate risk is a form of risk that arises
from the change in price of one currency against another. The constant fluctuations in the
foreign currency in which an investment is denominated vis-à-vis one's home currency may
add risk to the value of a security. Currency risk is greater for shorter term investments,
which do not have time to level off like longer term foreign investments.
Please Note: Investing in securities involves risk of loss that clients should be prepared to
bear. While the stock market may increase and the account(s) could enjoy a gain, it is also
possible that the stock market may decrease, and the account(s) could suffer a loss. It is
important that clients understand the risks associated with investing in the stock market, are
appropriately diversified in investments, and ask any questions.
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(7) Voting Client Securities
(i) If our firm has, or will accept, proxy authority to vote client securities, a description of
our voting policies and procedures, including those adopted pursuant to SEC Rule 206(4)-
6, must be provided.
Our firm does not accept the proxy authority to vote client securities. Clients will receive
proxies or other solicitations directly from their custodian or a transfer agent. In the event
that proxies are sent to our firm, our firm will forward them to the appropriate client and
ask the party who sent them to mail them directly to the client in the future. Clients may
call, write or email us to discuss questions they may have about particular proxy votes or
other solicitations.
Item 7: Client Information Provided to Portfolio Manager(s)
All accounts are managed by our in-house licensed IARs. Our IARs manage the client’s account(s) or
portfolio(s) and will be privy to the client’s investment goals and objectives, risk tolerance,
restrictions placed on the management of the account(s) or portfolio(s) and relevant client notes
taken by our firm. Please see our firm’s Privacy Policy for more information on how our firm utilizes
client information.
Item 8: Client Contact with Portfolio Manager(s)
Clients are always encouraged to directly contact their portfolio manager(s) with any questions or
concerns about their portfolios or other matters.
Item 9: Additional Information
A. Our firm is required to respond to: 1. Item 9 (Disciplinary Information); and 2. Item 10 (Other
Financial Industry Activities and Affiliations) of Part 2A of Form ADV.
There are no legal or disciplinary events that are material to the evaluation of our advisory
business or the integrity of our management.
Mitchell Fisher is licensed to provide annuity and insurance products. He may offer products and
receive normal and customary compensation as a result of these transactions. A conflict of
interest may exist as an incentive to recommend products based on the compensation earned. To
mitigate this potential conflict, our firm will act in accordance with the highest ethical standards
and in the client’s best interest.
Our representative, Ryan Fisher, is a licensed attorney in the State of California. Legal services
are not provided through our firm. Clients that require legal services may be referred to Ryan J.
Fisher, a Professional Corporation which is a separate and independent from Pacific Sun
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Financial Corp. Clients are under no obligation to engage Ryan J. Fisher, A Professional
Corporation for any services and may utilize an attorney of their choice. Our firm will not receive
any compensation for these referrals.
B. Our firm is required to respond to: 1. Items 11 (Code of Ethics or Interest in Client Transactions
and Personal Trading); 2. Item 13 (Review of Accounts); 3. Item 14 (Client Referrals and Other
Compensation); and 4. Item 18 (Financial Information) of Part 2A of Form ADV, as applicable to
our wrap fee clients.
1. Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
Brief description of our Code of Ethics adopted pursuant to SEC rule 204A-1 and offer to provide
a copy of our Code of Ethics to any client or prospective client upon request.
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all
material facts and to act solely in the best interest of each of our clients at all times. Our fiduciary
duty is the underlying principle for our firm’s Code of Ethics, which includes procedures for personal
securities transaction and insider trading. Our firm requires all representatives to conduct business
with the highest level of ethical standards and to comply with all federal and state securities laws at
all times. Upon employment with our firm, and at least annually thereafter, all representatives of our
firm will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our
firm and representatives must conduct business in an honest, ethical, and fair manner and avoid all
circumstances that might negatively affect or appear to affect our duty of complete loyalty to all
clients. This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a
potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly
upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried
out in a way that does not endanger the interest of any client. At the same time, our firm also believes
that if investment goals are similar for clients and for our representatives, it is logical, and even
desirable, that there be common ownership of some securities.
In order to prevent conflicts of interest, our firm has established procedures for transactions effected
by our representatives for their personal accounts1. In order to monitor compliance with our
personal trading policy, our firm has pre-clearance requirements and a quarterly securities
transaction reporting system for all of our representatives.
a) If our firm or a related person recommends to clients, or buys or sells for client accounts,
securities in which our firm or a related person has a material financial interest (excluding
an interest as a shareholder of an SEC-registered, open-end investment company), our firm
must describe our practice and discuss the conflicts of interest it presents.
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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Neither our firm nor a related person recommends, buys or sells for client accounts, securities
in which our firm or a related person has a material financial interest without prior disclosure
to the client.
b) If our firm or a related person invests in the same securities (or related securities, e.g.,
warrants, options or futures) that our firm or a related person recommends to clients, our
firm is required to describe our practice and discuss the conflicts of interest this presents and
generally the conflicts that arise in connection with personal trading are addressed.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons
will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics,
a copy of which is available upon request.
c) If our firm or a related person recommends securities to clients, or buys or sells securities for
client accounts, at or about the same time that you or a related person buys or sells the same
securities for our firm’s (or the related person's own) account, our firm is required to
describe our practice and discuss the conflicts of interest it presents. Our firm is also required
to describe generally how conflicts that arise are addressed.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same
time they buy or sell the same securities for client accounts. In order to minimize this conflict of
interest, our related persons will place client interests ahead of their own interests and adhere
to our firm’s Code of Ethics, a copy of which is available upon request. Further, our related
persons will refrain from buying or selling the same securities prior to buying or selling for our
clients in the same day. If related persons’ accounts are included in a block trade, our related
persons will always trade personal accounts last.
2. Review of Accounts
a) Review of client accounts, along with a description of the frequency and nature of our review,
and the titles of our employees who conduct the review
Our management personnel or financial advisors reviews accounts on at least an annual basis
for our Wrap Asset Management clients. The nature of these reviews is to learn whether
clients’ accounts are in line with their investment objectives, appropriately positioned based
on market conditions, and investment policies, if applicable.
b) Review of client accounts on other than a periodic basis, along with a description of the
factors that trigger a review.
Our firm may review client accounts more frequently than described above. Among the
factors which may trigger an off-cycle review are major market or economic events, the
client’s life events, requests by the client, etc.
c) Description of the content and indication of the frequency of written or verbal regular reports
provided to clients regarding their accounts.
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Our firm does not provide written reports to clients, unless asked to do so. Verbal reports to
clients take place on at least an annual basis when our Wrap Asset Management clients are
contacted.
3. Client Referrals & Other Compensation
a) If someone who is not a client provides an economic benefit to our firm for providing
investment advice or other advisory services to our clients, our firm must generally describe
the arrangement. For purposes of this Item, economic benefits include any sales awards or
other prizes.
Pacific Sun Financial Corp. (“PSFC”) may recommend that clients establish brokerage
accounts with the 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 the Advisor’s 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. PSFC is
independently owned and operated and not affiliated with Schwab. Schwab provides PSFC
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 them so long as a total of at least $10 million
of the advisor’s clients’ assets are maintained in accounts at Schwab Advisor Services.
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.
For PSFC client accounts maintained in its custody, Schwab generally does not charge
separately for custody services but is compensated by account holders through commissions
or other transaction-related or asset-based fees for securities trades that are executed
through Schwab or that settle into Schwab accounts.
Schwab also makes available to PSFC other products and services that benefit PSFC but may
not benefit its clients’ accounts. These benefits may include national, regional or PSFC specific
educational events organized and/or sponsored by Schwab Advisor Services. Other potential
benefits may include occasional business entertainment of personnel of PSFC by Schwab
Advisor Services personnel, including meals, invitations to sporting events, including golf
tournaments, and other forms of entertainment, some of which may accompany educational
opportunities. Other of these products and services assist PSFC 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 PSFC’s fees from its clients’ accounts, and assist with back-office training
and support functions, recordkeeping and client reporting. Many of these services generally
may be used to service all or some substantial number of PSFC’s accounts, including accounts
not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to
PSFC other services intended to help PSFC manage and further develop its business
enterprise. These services may include professional compliance, legal and business
consulting, publications and conferences on practice management, information technology,
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business succession, regulatory compliance, 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 PSFC by independent third
parties. Schwab Advisor Services may 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 PSFC. While, as a fiduciary, PSFC endeavors to act in its clients’ best interests, PSFC’s
recommendation/requirement that clients maintain their assets in accounts at Schwab may
be based in part on the benefit to PSFC 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 may create a potential conflict of interest.
Product Sponsors
Representatives of our firm will occasionally accept travel expense reimbursement provided
by product sponsors in order to attend their educational events. The reimbursement is not
directly dependent upon the recommendation of any specific product. Although we may be
incentivized to recommend products from product sponsors that reimburse our travel, our
representatives will always adhere to their fiduciary duty in recommending appropriate
investments for our clients.
b) If our firm or a related person directly or indirectly compensates any person who is not our
employee for client referrals, our firm is required to describe the arrangement and the
compensation.
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not
provide cash or non-cash compensation directly or indirectly to unaffiliated persons for the
referral of prospective clients to our firm.
4. Financial Information
Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
• Our firm does not take custody of client funds or securities.
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
Our firm has never been the subject of a bankruptcy proceeding.
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