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BluePrint Wealth Management, LLC
d/b/a
Parady Wealth Management
3602 Kiessel Road
The Villages, FL 32163
Telephone: (352) 674-3911
March 31, 2026
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of BluePrint Wealth
Management, LLC. If you have any questions about the contents of this brochure, contact us at (352)
674-3911. 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 BluePrint Wealth Management, LLC is available on the SEC's website at
www.adviserinfo.sec.gov. Click on the "Investment Adviser Search" link and then search for
"Investment Adviser Firm" using the firm's IARD ("CRD") number, which is 169997.
BluePrint Wealth Management, LLC is a registered investment adviser. Registration with the United
States Securities and Exchange Commission or any state securities authority does not imply a certain
level of skill or training.
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Item 2 Summary of Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure,
the adviser is required to notify you and provide you with a description of the material changes.
Since the filing of our last annual updating amendment, dated February 26, 2025, we have the
following material changes to report:
• We updated Item 4 to reflect that the firm is an indirect wholly-owned subsidiary of Brown &
Brown, Inc., a publicly traded company. In August 2025, RSC Topco, Inc., the holding company
for our parent company, was acquired by Brown & Brown, Inc., a diversified insurance
brokerage and risk management services firm.
• We updated Item 5 to reflect the firm's current standard rate for investment management
services.
Our firm may at any time update this document and either send a copy of its updated brochure or
provide a summary of material changes to its brochure and an offer to send an electronic or hard copy
form of the updated brochure. Clients are also able to download this brochure from the SEC's website
at www.adviserinfo.sec.gov or may contact our firm at (352) 674-3911 to request a copy at any time.
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Item 3 Table of Contents
Item 1 Cover Page
Item 2 Summary of Material Changes
Item 3 Table of Contents
Item 4 Advisory Business
Item 5 Fees and Compensation
Item 6 Performance-Based Fees and Side-By-Side Management
Item 7 Types of Clients
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16 Investment Discretion
Item 17 Voting Client Securities
Item 18 Financial Information
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Item 4 Advisory Business
Description of Firm
BluePrint Wealth Management, LLC is a Florida domiciled limited liability company formed in
December of 2013. Our original registration as an investment adviser occurred in May of 2014, with the
State of Florida, and has since transitioned to an SEC registration during January of 2022. We operate
under the trade name Parady Wealth Management. RSC Insurance Brokerage, Inc. is the principal
owner of the firm, which is an indirect wholly-owned subsidiary of Brown & Brown, Inc, a publicly
traded company.
The following paragraphs describe our services and fees. Parady Wealth Management has several
financial services industry affiliates or related parties that are described in further detail under the
Other Financial Industry Activities and Affiliates section of this brochure (see Item 10). Since our
investment strategies and advice are based on each client's specific financial situation, the investment
advice we provide to you may be different or conflicting with the advice we give to other clients
regarding the same security or investment.
Refer to the description of each investment advisory service listed below for information on how we
tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our,"
"firm", and "us" refer to Parady Wealth Management and the words "you," "your," and "client" refer to
you as either a client or prospective client of our firm.
Parady Wealth Management offers the following advisory services:
Investment Management Services
•
• Selection of Other Advisers
Investment Management Services
During or prior to our first meeting, we will provide you with certain disclosures and request information
from you. A financial professional of our firm will hold one or more discussions with you and conduct an
analysis to determine how best to tailor our investment services to your financial needs, goals,
holdings, etc. Depending on the scope of the engagement, you may be asked to provide copies of the
following documents early in the process:
Information on current retirement plans and other benefits provided by an employer;
Insurance policies, including information about riders, loans, and amendments;
• Statements reflecting current investments in retirement and non-retirement accounts;
• Stock options and stock purchase plan agreements;
•
• Current financial specifics including W-2s, 1099s, K-1 statements, etc.;
• Wills, codicils, and trusts;
•
• Mortgage information;
• Tax returns (current and prior years);
• Divorce decree or separation agreement; and
• Employment or other business agreements.
It is important that we are provided with an adequate level of information and supporting
documentation throughout the term of the engagement, and that it is accurate. Our firm may, but is not
obligated to, verify the information that has been provided to us which will then be used in the advisory
process.
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Our review will include a client's investment objectives, time horizon, liquidity needs, tolerance for risk
and other factors necessary to form the basis for our investment recommendations to you (herein
referred to as "investment parameters"). Clients will complete a statement of investment selection or
other suitability forms ("Risk Profile Questionnaire" or "RPQ") to assist us with this process.
We offer discretionary investment management services. Our investment advice is tailored to meet our
clients' needs and investment parameters. We utilize model portfolios that are designed for investors
with varying degrees of risk tolerance and investment objectives for taxable and non-taxable accounts.
The model portfolios are rebalanced on a monthly, quarterly, or as needed basis.
If you participate in our discretionary investment management services, we require you to grant our
firm discretionary authority to manage your account. Discretionary authorization will allow us to
determine the specific securities, and the amount of securities, to be purchased or sold for your
account without your approval prior to each transaction. Discretionary authority is typically granted by
the investment advisory agreement you sign with our firm and the appropriate trading authorization
forms. You may request reasonable restrictions to limit our discretionary authority, as described above,
by providing our firm with your restrictions and guidelines in writing. The acceptance of restrictions and
guidelines is subject to the firm's discretion.
We have entered into a sub-advisory relationship with CreativeOne Wealth Management, LLC
("CreativeOne"), an unaffiliated SEC registered investment adviser, to provide back office, billing, and
trading support through their platform. In addition, CreativeOne manages the model portfolios we
recommend. CreativeOne charges a platform fee for these services. Refer to the Fees and
Compensation section below for additional information regarding the platform fee. CreativeOne also
serves as an independent marketing organization for our affiliated insurance agency, Parady Financial
Group, LLC, providing product education for the sale of fixed and indexed annuity products. Please
see the Other Financial Industry Activities and Affiliations section for more information about
CreativeOne's services and certain conflicts of interest.
Furthermore, certain investment adviser representatives of the firm are licensed insurance agents
and/or certified public accountants (CPAs) and offer insurance products and tax preparation services in
their individual capacity or through one or more affiliated companies. These services are offered under
a separate agreement and will not be within the scope of advisory services offered by Parady Wealth
Management. Please see the Other Financial Industry Activities and Affiliations section (Item 10) for
additional information.
In limited circumstances, our firm acts as a named fiduciary for certain qualified retirement plans, such
as self-employed 401k plans. Refer to the ERISA Rider in the advisory agreement for important
disclosures and additional information. In providing services to ERISA covered plans, our firm does not
provide any advisory services with respect to the following types of assets: employer securities, real
estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded
securities or assets, other illiquid investments, or brokerage window programs (collectively, "Excluded
Assets").
Selection of Other Advisers
As discussed above, we generally select or recommend the services of CreativeOne to manage all, or
a portion of, your investment portfolio. After gathering information about your investment parameters,
we select or recommend that you engage one or more model portfolios available on CreativeOne's
platform. Factors that we take into consideration when making our recommendation(s) include, but are
not limited to, the following: CreativeOne's performance, methods of analysis, fees, your financial
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needs, investment goals, risk tolerance, and investment objectives. Additionally, we retain
discretionary authority to change model portfolio strategies based on your investment parameters and
to hire and fire CreativeOne without your prior approval.
CreativeOne will invest on behalf of a client account in accordance with the strategies set forth in their
own disclosure documents which will be provided to you by our firm prior to employing their strategies.
CreativeOne typically assumes discretionary authority over the account and will manage the selected
model portfolio(s). Rebalancing of the asset allocation models will occur as necessary. Account
rebalancing is accomplished by buying and selling shares of stocks, mutual funds, or exchange-traded
funds to reach target allocations.
At least annually thereafter, a review will be performed to determine whether CreativeOne's model
portfolio(s) remains an appropriate fit based on your investment parameters.
Rollover Recommendations
If a client desires to conduct an account rollover from their employer-sponsored plan or we recommend
the rollover, after an analysis of the client's situation and their retirement plan documents, we consider
the following relevant factors, among others:
• Are there alternatives to the employer plan rollover, including leaving the money in an
employer's retirement plan (if permitted)?
• What are the fees and expenses associated with both the employer's plan and the rollover IRA?
• Does the employer currently pay for some or all the plan's administrative expenses?
• What are the different levels of services and investments available under the employer plan and
the rollover IRA?
Is the rollover appropriate notwithstanding any additional costs?
• What are the long-term impacts if there are increased costs?
•
• What is the impact of economically significant investment features such as surrender schedules
and indexed annuity cap and participation rates (such as in an employer sponsored 403(b) plan
account)?
For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02")
where applicable, we are providing the following acknowledgment to you. When we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the
Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we
make money creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's
provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
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We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Types of Investments
We primarily offer advice on equity securities (stocks), exchange traded funds (ETFs), mutual funds,
municipal and corporate bonds, and cash instruments. We also recommend fixed and indexed
annuities and life and health insurance products through affiliated entities. Additionally, we will advise
you on various types of investments based on your stated goals and objectives.
Assets Under Management
As of January 16, 2026, our firm had $145,725,885 in discretionary assets under management. We do
not manage assets on a non-discretionary basis.
Item 5 Fees and Compensation
Investment Management Services
Parady Wealth Management charges its investment management services clients an advisory fee that
is based on a percentage of the market value of the assets that we manage. We do not assess
account opening or administrative "set-up" fees.
If the advisory agreement is executed at any time other than the first day of the month, our fees will
apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of
days in the month for which you are a client.
Our asset-based fee is charged monthly, in arrears, based on the market value of the assets in the
account on the last calendar day of the month (see Fee Calculation Methodology below). We charge
an annualized asset-based fee of 0.50% or 50 basis points. Cash and money market balances are
excluded from the advisory fee calculation except for cash or money market balances included in
model portfolios or other cash management strategies. Deposits and withdrawals that occur during the
month are pro-rated for all inflow/outflows greater than $10,000. Advisory fees may be amended from
time to time upon 30-days prior written notice to you.
As mentioned under the Advisory Business section above, CreativeOne charges a platform fee to
manage the model portfolios and provide back office, billing, and trading support through their platform.
CreativeOne's platform fee is 0.15% or 15 basis points and is calculated and billed monthly in arrears,
using the same methodology as Parady Wealth Management's investment management fee.
CreativeOne's fee (0.15% or 15 basis points), although separate, is added to the Parady investment
management fee (0.35% or 35 basis points) for billing purposes. CreativeOne will invoice Parady
Wealth Management accordingly.
Fee Calculation Methodology: (month-end market value x annual fee %) / (12 months)
For example, an account under our management with account assets valued at $500,000 on the last
day of the calendar month would be assessed an advisory fee of $145.84 and a platform fee of $62.50
for a total monthly fee of $208.34. Formula: ($500,000 x 0.50%) / (12) = $208.34
Terms of service, fees charged, etc., will be stated in the firm's advisory agreement with each client.
Our published fees are generally non-negotiable. There are very limited circumstances in which our
advisory fee will be negotiable. For example, we could negotiate a lower fee for a cash management
strategy.
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By signing the firm's advisory agreement, as well as the custodian account opening documents, the
client will be authorizing the withdrawal of our investment management advisory fees and platform fees
from their account. All fees will be noted on the account statement provided by the custodian of record.
The withdrawal of these fees will be accomplished by the selected custodian, not by our firm, and the
custodian will remit our fee directly to our firm.
Selection of Other Advisers
We have entered into a sub-advisory relationship with CreativeOne. CreativeOne charges a platform
fee for the services provided which are calculated and billed as described above.
Termination of Services
Either party may terminate the advisory agreement upon written notice. Parady Wealth Management
will not be responsible for investment allocation, advice, or transactional services (except for limited
closing transactions) after it receives a termination notice. It will also be necessary that we inform the
custodian of record and CreativeOne that the relationship between the firm and the client has been
terminated.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds to their shareholders. These fees will generally include a management fee and other fund
expenses. Fees charged by issuers are detailed in prospectuses or product descriptions and the client
is encouraged to read these documents before investing.
Any transactional or service fees (sometimes termed brokerage fees), individual retirement account
fees, qualified retirement plan fees, custodian account termination fees, or wire transfer fees will be
borne by the client per the custodian of record's separate fee schedule. We do not share in any portion
of the transaction charges or service fees imposed by the broker-dealer or custodian. To fully
understand the total cost you will incur, you should review all the fees charged by mutual funds,
exchange traded funds, our firm, and others. For information on our brokerage practices, refer to
the Brokerage Practices section of this brochure (Item 12).
Compensation for the Sale of Securities or Other Investment Products
We are affiliated with Parady Financial Group, LLC through common control and ownership, a licensed
insurance agency. Financial professionals, providing investment advice on behalf of our firm, are
licensed insurance agents and offer insurance products (i.e., fixed or indexed annuities and life
insurance policies, etc.) through Parady Financial Group, LLC. Parady Financial Group, LLC and our
financial professionals (in their capacity as agents of Parady Financial Group, LLC) will earn
commission-based compensation, and other forms of compensation, for selling insurance products
including insurance products they sell to you. Annuities can have high fees, including commissions,
distribution or administrative fees, surrender charges, mortality expenses, rider fees, expense ratios,
redemption fees and contingent deferred sales charges. In general, fees will depend on the annuity
type and will be higher the more complex the annuity and the longer the contract. Fees charged by the
insurance company are detailed in the annuity contract and/or risk disclosure documents and we
encourage clients to read these documents before investing. For more information on insurance
product sales, refer to the Other Financial Industry Activities and Affiliations section of this brochure
(Item 10).
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Certain of our financial professionals that provide investment advice on behalf of our firm, are also
accountants or CPAs and offer accounting services and tax preparation services. These services are
offered by the financial professional either in their individual capacities (i.e., as a CPA) or through the
financial professional's affiliated entity. Insurance commissions and fees for accounting services or tax
preparation services earned by the financial professional are separate and in addition to our advisory
fees.
These practices present a conflict of interest because financial professionals, providing investment
advice on behalf of our firm who are insurance agents or accountants/CPAs, and our affiliated entities,
who offer these products and services, have a financial incentive to recommend insurance products or
accounting/tax preparation services to you for the purpose of generating commissions or additional
compensation, respectively, rather than solely based on your best interest. You are under no
obligation, contractually or otherwise, to purchase insurance products or other services through
any financial professional affiliated with our firm.
Our advisory firm and its financial professionals take their responsibilities seriously and only intend to
recommend investments, insurance, accounting, and investment advisory services that we believe
appropriate for each client. Please refer to the Other Financial Industry Activities and Affiliations
section (Items 10) and the Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading section (Item 11) of this brochure, in addition to the financial professional's brochure
supplement, (Part 2B - Items 2 and 4) for additional details.
Item 6 Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or participate in side-by-side management. Our firm's
advisory fees will not be based on a share of capital gains or capital appreciation (growth) of a client's
account or any portion of managed funds also known as performance-based fees. Our fees will also
not be based on side-by-side management, which refers to a firm simultaneously managing accounts
that pay performance-based fees (such as a hedge fund) and those that do not.
Item 7 Types of Clients
Parady Wealth Management provides investment advisory services to individuals, high net worth
individuals, and charitable organizations. We encourage prospective clients of all economic levels to
inquire about our services and do not impose minimum income, minimum asset, or similar eligibility
requirements.
Clients will be informed in advance of any minimum account requirements imposed by recommended
sub-advisers. The firm may waive or reduce certain fees based on individual circumstances, special
arrangements, or pre-existing relationships. The firm also reserves the right to terminate an advisory
relationship if an account falls below a level that, in the firm's judgment, is no longer practical to
manage effectively.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Our Methods of Analysis and Investment Strategies
We primarily recommend model portfolios managed by a sub-adviser.
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Model Portfolios
We will not perform quantitative or qualitative analysis of individual securities when we recommend a
model portfolio managed by a sub-adviser. Instead, we will advise you on how to allocate your assets
among various strategies. We may replace or recommend replacing a model portfolio if there is a
significant deviation in characteristics or performance from the stated strategy and/or benchmark.
We recognize that each client's needs, goals, and tolerance for risk are different, subsequently,
portfolio strategies and underlying investment vehicles will vary based on the client's requirements.
The following strategies sample the general types of strategists that may be suggested. It is common
to find a broad range of mutual funds and ETFs as the primary investment vehicle, however, individual
equities and fixed income instruments (stocks and bonds) can be included when appropriate.
Passive Management
Passive management involves investing in a portfolio intended to mirror the returns and risk
characteristics of a broad-market index (e.g., S&P 500, NASDAQ 100, etc.). Various approaches are
employed to achieve this result with varying levels of success. With passive strategies, two primary
factors for consideration are the strategies' success with replicating benchmark risk and return profiles
and the cost associated with employing the strategy. Investors more concerned with excessive fees
than excess or risk-managed returns will generally prefer to invest through these types of strategies.
Tax Conscious Investing
Depending on client circumstances and the type of account in question, tax-conscious investment
strategies may be utilized to reduce the impact of taxes on the client's portfolio. Types of investment
strategies which could satisfy this objective include low turnover portfolios such as long-term active
investment management focusing on growth or qualified dividend income, passive/indexing strategies,
municipal bond portfolios, and tax-focused active investment management strategies.
Cash Management; Cash Position Risk
In managing the cash maintained in your account, we utilize the exclusive cash vehicle (money market
fund) made available by the custodian. There may be other cash management options away from the
custodian available to you with higher yields or safer underlying investments. From time to time, a
client's portfolio may hold a significant portion of its assets in cash or cash equivalents for varying
periods. This may occur for a number of reasons, including, but not limited to, pending investment of
new contributions, awaiting suitable investment opportunities consistent with the client's investment
strategy, defensive positioning in response to market conditions, anticipated liquidity needs, or portfolio
rebalancing. While holding cash or cash equivalents may help preserve capital and provide liquidity, it
also presents certain risks. During periods in which a portfolio maintains elevated cash positions, the
portfolio may not participate, or may participate to a lesser extent, in market gains. Cash and cash
equivalents generally earn lower returns than equity or fixed income investments over the long term,
and the purchasing power of cash holdings may be eroded by inflation. As a result, maintaining
substantial cash positions for extended periods could negatively impact a client's overall portfolio
performance and the ability to achieve long-term investment objectives. Clients should be aware that
there is no guarantee that the decision to hold assets in cash, whether for defensive purposes or
otherwise, will prove beneficial, and the opportunity cost of holding cash rather than remaining invested
may be significant.
Sub-Advisers
We will not perform quantitative or qualitative analysis of individual securities when we recommend a
sub-adviser. Instead, we will advise you on how to allocate your assets among various classes of
securities or model portfolios managed by the sub-adviser. We may replace or recommend replacing a
sub-adviser or model portfolio if there is a significant deviation in characteristics or performance from
the stated strategy and/or benchmark.
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As previously noted in the Advisory Business section, our investment strategies and advice may vary
depending upon each client's specific financial situation. As such, we determine investments and
allocations based upon your predefined investment parameters. Your restrictions and guidelines may
affect the composition of your portfolio. It is important that you notify us immediately with respect
to any material changes to your financial circumstances, including for example, a change in
your current or expected income level, tax circumstances, or employment status.
Tax Considerations
Our strategies and investments can have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the
management of your assets. Regardless of your account size or any other factors, we strongly
recommend that you consult with a tax professional regarding the investing of your assets.
Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your
custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis
of your investments. You are responsible for contacting your tax advisor to determine if this accounting
method is the right choice for you. If your tax advisor believes another accounting method is more
advantageous, provide written notice to our firm immediately and we will alert your account custodian
of your individually selected accounting method. Decisions about cost basis accounting methods will
need to be made before trades settle, as the cost basis method cannot be changed after settlement.
Recommendation of Particular Types of Securities
We recommend various model portfolio strategies which generally consist of mutual fund and ETFs.
We do not primarily recommend one particular type of security over another since each client has
different needs and different tolerance for risk. Each type of security has its own unique set of risks
associated with it and it would not be possible to list here all of the specific risks of every type of
investment. Even within the same type of investment, risks can vary widely. However, in very general
terms, the higher the anticipated return of an investment, the higher the risk of loss associated with the
investment. A description of the types of securities we may recommend to you and some of their
inherent risks are provided below.
Risk of Loss
Our firm believes its strategies and investment recommendations are designed to produce the
appropriate potential return for the given level of risk; however, there is no guarantee that an
investment objective will be achieved. Past performance is not necessarily indicative of future results.
Investing in securities involves risk of loss that clients should be prepared to bear. When evaluating
risk, financial loss may be viewed differently by each client and may depend on many different risks,
each of which may affect the probability and magnitude of any potential losses. While the following list
is not exhaustive, we provide examples of such risk in the following paragraphs, and we believe it is
important that our clients review and consider each prior to investing.
Annuities
Annuities are a product for those who may have the ability to pay a premium now and want to
guarantee they receive certain monthly payments or a return on investment later in the future.
Annuities are contracts issued by a life insurance company designed to meet requirements or other
long-term goals. Annuities can have high fees, including surrender charges, administrative fees, and
rider fees. You may face penalties and fees if you withdraw money early, especially during the
surrender period. If the insurance company becomes insolvent, you may not be able to recover all of
your funds. As described in Item 10, most of Parady Wealth Management's financial professionals are
licensed insurance agents and often recommend or include annuities as part of the client's asset
allocation.
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• Fixed annuities – pay a set interest rate for a specified period, regardless of how the stock
market performs. While fixed annuities offer principal protection and predictable returns, the
guaranteed rate may not keep pace with inflation, potentially eroding purchasing power over
time. Fixed annuities typically impose surrender charge schedules, and early withdrawals
beyond any permitted penalty-free amount may result in significant penalties. Fixed annuities
may also carry administrative fees, mortality expense risk charges, and commission fees.
Interest rates are set by the insurance carrier and, upon expiration of an initial guarantee
period, may be reset at the carrier's discretion, subject to a contractual minimum rate that may
be lower than the initial rate. All guarantees under the contract are subject to the claims-paying
ability and financial strength of the issuing insurance company.
• Equity indexed annuities – these are complex insurance products that credit interest based, in
part, on the performance of a specified market index (e.g., the S&P 500). While indexed
annuities generally provide downside protection through a guaranteed minimum interest rate or
"floor," they limit upside potential through participation rates, rate caps, and/or spreads that are
set by the insurance carrier and may be reset periodically at the carrier's discretion. These
features, combined with the product's crediting methodology, can make it difficult to predict
returns, and actual interest credited may be significantly less than the total return of the
referenced index. Indexed annuities typically impose surrender charge schedules that can
extend for many years, and accessing funds beyond any permitted penalty-free withdrawal
amount during the surrender period can result in significant charges. Optional riders (e.g.,
guaranteed lifetime withdrawal benefits) are available for an additional fee that reduces the
annuity's overall return. All guarantees under the contract are subject to the claims-paying
ability and financial strength of the issuing insurance company. Compensation tied to fixed
indexed annuities primarily consists of upfront commissions paid by the insurance company to
the agent or broker. These commissions are not deducted directly from the premium amount
invested, but rather are built into the product's structure.
Equity (Stock) Risk
Common stocks are susceptible to general stock market fluctuations and to volatile increases or
decreases in value as market confidence in and perceptions of their issuers change. If an investor held
common stock or common stock equivalents of any given issuer, they may be exposed to greater risk
than if they held preferred stocks and debt obligations of the issuer.
Preferred stocks can be affected by interest rate and liquidity risks (described in adjacent paragraphs).
Also note that their dividend payment is not guaranteed; some are subject to a call provision, meaning
the issuer can redeem its preferred shares on demand, and usually when interest rates have fallen.
Exchange Traded Funds and Mutual Fund Risks
The risk of owning exchange traded funds ("ETFs") and mutual funds reflect their underlying securities
(e.g., stocks, bonds, commodities, etc.). These forms of securities typically carry additional expenses
based on their share of operating expenses and certain brokerage fees, which may result in the
potential duplication of certain fees. Certain ETFs and indexed funds have the potential to be affected
by "active risk;" a deviation from its stated index (e.g., S&P 500).
The liquidity of the underlying stocks in the index can affect "ETF liquidity." Liquidity risk can result from
an insufficient number of Active Participants performing their duties as intermediaries and liquidity
providers in the ETF market. "Spread risk" may also occur, which is the difference between the bid and
the ask price of a security. Due to the fact that ETF transactions are priced throughout the day and are
traded on the exchanges like stocks, widening spreads may occur and have impact on certain
portfolios or transactions. As with any security, if the ETF "fails," the investor may lose their gains and
invested principal.
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While many ETFs and index mutual funds are known for their potential tax-efficiency and higher
"qualified dividend income" (QDI) percentages, there are asset classes within these investment
vehicles or holding periods within that may not benefit. Shorter holding periods, as well as commodities
and currencies (that may be a holding within an ETF or mutual fund), may be considered "non-
qualified" under certain tax code provisions. A holding's QDI will be considered when tax-efficiency is
an important aspect of the client's portfolio. We do not recommend leveraged or inverse ETFs.
Some mutual funds are sold through brokerage firms and assess a commission ("load) in addition to
their underlying fees earlier noted, while others are offered through investment advisers, retirement
plans and other institutions. "No load" funds are also available to the public through brokerage firms,
and they usually incur trading (brokerage) fees. If a client chooses to purchase a mutual fund through a
broker/dealer on their own, they should consider the trading fees, internal operating costs, as well as
potential commissions they may pay through that executing firm. Our firm is not a broker/dealer, nor
are we or our staff associated with a broker/dealer, and (per Items 5 and 10) is not compensated by a
"loaded" fund.
Fixed Income Risks
Various forms of fixed income instruments, such as bonds, money market or bond funds may be
affected by various forms of risk, including:
- During periods of falling interest rates, issuers of callable bonds may call (redeem)
• Call Risk
securities with higher coupons or interest rates before their maturity dates. The owner of the
bond would then lose any potential price appreciation above the bond's call price and would be
forced to reinvest the unanticipated proceeds at lower interest rates, resulting in a decline in the
owner's income. Call risk is generally low for short-term bond funds, moderate for intermediate-
term bond funds, high for long-term bond funds, and high for high-yield bonds.
- The potential risk that an issuer would be unable to pay scheduled interest or
• Credit Risk
repay principal at maturity, sometimes referred to as "default risk." Credit risk may also occur
when an issuer's ability to make payments of principal and interest when due is interrupted.
Bondholders are creditors of an issuer and have priority to assets before equity holders (e.g.,
stockholders) when receiving a payout from liquidation or restructuring. When defaults occur
due to bankruptcy, the type of bond held will determine seniority of payment.
•
Interest Rate Risk
- The risk that the value of the fixed income holding will decrease because of
an increase in interest rates. The longer the maturity of the bond, the more sensitive its value is
to changes in interest rates. Bond prices and interest rate changes are inversely correlated.
- The prepayment risk is the premature return of principal on a fixed-income
• Prepayment Risk
security. When principal is returned early on a security, future interest payments will not be paid
on that part of the principal. The owner of the security would lose any price appreciation above
the principal and forced to reinvest the unanticipated proceeds possibly at lower interest rates,
resulting in a decline of dividends, income, and returns. The risk of prepayment is most
prevalent in fixed-income securities such as callable bonds and mortgage-backed securities.
- With declining interest rates, investors may have to reinvest interest
• Reinvestment Risk
income or principal at a lower rate.
• State Government and Municipal Securities Risk
- State government and municipal securities
are subject to various risks based on factors such as economic and regulatory developments,
changes or proposed changes in the federal and state tax structure, deregulation, court rulings
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and other factors. Repayment of state and municipal securities depends on the ability of the
issuer or project backing such securities to generate taxes or revenues. There is also a risk the
interest on an otherwise tax- exempt municipal security may be subject to federal income tax.
Unfavorable developments in any economic sector may have far-reaching ramifications on the
overall state and/or municipal market.
• United States Government Securities Risk
- US government securities are subject to varying
interest rates and inflation risks. Not all US government securities are backed by the full faith
and credit of the US government. Certain securities issued by agencies and instrumentalities of
the US government are only insured or guaranteed by the issuing agency or instrumentality,
which must rely on its own resources to repay the debt. As a result, there is risk these entities
will default on a financial obligation.
Horizon and Longevity Risk
The risk that your investment horizon is shortened because of an unforeseen event, for example, the
loss of your job. This may force you to sell investments that you were expecting to hold for the long
term. If you must sell at a time that the markets are down, you may lose money. Longevity Risk is the
risk of outliving your savings. This risk is particularly relevant for people who are retired, or are nearing
retirement.
Inflation Risk and Interest Rate Risk
Security prices and portfolio returns will likely vary in response to changes in inflation and interest
rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing
power of a client's future interest payments and principal. Inflation also generally leads to higher
interest rates which may cause the value of many types of fixed income investments to decline.
Liquidity Risk
Liquidity risk is the inability to readily buy or sell an investment for a price close to the true underlying
value of the asset due to a lack of buyers or sellers. There are times when there is no trading
volume/market depth to support a security's current price. As such, the true value of the bond (for
example) may not be supported by the current price. Conversely, when trading volume is high, there is
also a risk of not being able to purchase a particular issue at the desired price.
Market Risk
Market risk, also called systematic risk, is that part of a security's risk that is common to all securities of
the same general class (stocks and bonds) and thus cannot be eliminated by diversification. In cases
where markets are under extreme duress, many securities lose their ability to provide diversification
benefits.
Money Market Funds
A money market fund is managed to maintain a stable net asset value (NAV) of $1 per share, the value
of the fund may fluctuate, and the investor could lose money (termed "breaking the buck"). Money
market funds are a type of mutual fund investing in high-quality, short-term debt securities, pays
dividends that generally reflect short-term interest rates and seeks to maintain a stable NAV per share
(typically $1). An investment in a money market mutual fund is typically not insured or guaranteed by
the Federal Deposit Insurance Corporation, National Credit Union Association, or any other
government agency.
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Item 9 Disciplinary Information
We are required to disclose the facts of any legal or disciplinary events that are material to a client's
evaluation of our advisory business or the integrity of our management. We do not have any required
disclosures under this item.
Item 10 Other Financial Industry Activities and Affiliations
Arrangements with Affiliated Entities
The following companies are either under common control and ownership of our advisory firm through
RSC Insurance Brokerage, Inc. and/or are owned and/or controlled by financial professionals of our
firms:
• Parady Financial Group, LLC - a licensed insurance agency that provides insurance planning to
its clients using fixed and indexed annuities and life insurance products;
• Parady Tax Solutions, LLC - provides income tax preparation and planning; and
• Kathleen Laseter CPA, LLC - provides income tax preparation and accounting services.
Financial professionals of our advisory firm are licensed to sell fixed and/or indexed life insurance and
annuity products. In their capacities as licensed insurance agents of one or more of our affiliated
insurance agencies, they recommend to clients or prospective clients the purchase of certain
insurance products. These individuals will receive compensation for the sale of those products. The
recommendation and sale of insurance products by our financial professionals, in their capacities as
insurance agents of one or more of our affiliates, presents a conflict of interest because those financial
professionals and our affiliated insurance agencies will receive insurance commissions or other
compensation for selling you products. Clients are under no obligation to purchase insurance products
through our advisory representatives and may do so through any insurance agent or insurance agency
they choose.
Insurance Product Sales
As mentioned above, our firm is affiliated with a licensed insurance agency, Parady Financial Group,
LLC. It is common for our financial professionals to recommend clients utilize insurance products (for
example, a fixed index annuity) as part of the client's overall asset allocation in lieu of separately
managed accounts or assets classes (such as cash or fixed income). You should be aware that there
are a number of conflicts of interest that are present when associates of our advisory firm recommend
you utilize insurance products in this nature.
You will generally work with your financial professionals in both their capacity as an investment adviser
representative (IAR) of Parady Wealth Management, as well as in their capacity as an insurance
agent. As such, your Parady Wealth Management financial professional, in his or her capacity as an
IAR may recommend that you purchase insurance products (fixed and/or indexed life insurance and
annuity products), and then in his or her capacity as an insurance agent assist you in implementing the
recommendations by selling you those same products. When acting as an insurance agent, in
exchange for selling you those products, the financial professional will typically be paid a commission.
This recommendation that a client purchase an insurance product through them as an insurance agent
presents a conflict of interest, as the financial professional will be incentivized to recommend products
that generate commissions for him or her rather than those that are solely in your best interests.
Furthermore, commissions vary by product, and each individual product often has different commission
rates, incentivizing the financial professional to recommend products that pay higher commissions over
the products that make the most sense for you.
15
In addition, insurance products also have different payment schedules depending on the nature of the
product, and the timing of the payments likely differ from that of the advisory options offered by Parady
Wealth Management. This timing difference has the potential to create a conflict of interest since some
financial professionals have the incentive to recommend an insurance product that pays commissions
now, instead of recommending that you invest the assets in your advisory account, which will generate
asset-based fees for the firm over a relatively longer period.
Parady Financial Group, LLC utilizes the services of CreativeOne, a third-party insurance marketing
organization ("IMO") who provide education on the different products that are available. The purpose of
the IMO is to assist us in finding the insurance product that best fits the client's situation. This
relationship between CreativeOne and Parady Financial Group, LLC creates a financial incentive for us
to select and retain CreativeOne as a sub-adviser over other potentially qualified sub-advisers that do
not provide these additional benefits to our affiliated entities. In other words, our recommendation of
CreativeOne as a sub-adviser may not be based solely on CreativeOne's qualifications or ability to
serve your best interest, but may also be influenced by the broader financial benefits that the
CreativeOne relationship provides to our affiliated insurance business.
In addition, each of the individual insurance carriers that our financial professionals work with also
separately provide incentive-based bonuses or awards in exchange for sales-related production over
specific periods of time, which is a conflict of interest. They also provide indirect compensation by
providing marketing assistance, business development tools, technology, back office/operations
support, business succession planning, business conferences, and incentive trips. These incentive
programs do not directly affect fees paid by the client. Although some of these services can benefit a
client, other services obtained by our IARs such as marketing assistance, business development, and
incentive trips, will not benefit an existing client and presents a conflict of interest. At times, our
financial professionals receive expense reimbursement for travel and/or marketing expenses from
distributors of investment and/or insurance products. Travel expense reimbursements are a result of
attendance at due diligence and/or investment training events hosted by product sponsors. Marketing
expense reimbursements are the result of informal expense sharing arrangements in which product
sponsors will underwrite costs incurred for marketing, such as client appreciation events, advertising,
publishing, and seminar expenses. Although receipt of these travel and marketing expense
reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements
are made by those sponsors for which sales have been made or for which it is anticipated sales will be
made. These services, benefits, and compensation create a conflict of interest because they create an
incentive for the financial professional to recommend certain products and investments to benefit the
financial professional rather than the best interest of clients.
We have taken a number of steps to manage these types of conflict of interests. We attempt to
mitigate these sales-related conflicts by always basing investment decisions on the individual needs of
clients. As a fiduciary, we expect and require that each investment adviser representative only
recommend insurance and annuities when in the best interest of the client. Finally, you should be
aware that there are other insurance products that are offered by other insurance agents other than
those recommended by our financial professionals.
You are under no obligation, contractually or otherwise, to purchase insurance products or other
services through any associate affiliated with Parady Wealth Management or implement any insurance
or annuity transactions through Parady Financial Group.
Selection of Other Advisers
We generally recommend that you use a sub-adviser based on your investment parameters and goals.
We will not receive separate direct compensation from the sub-adviser for recommending that you use
their services. However, in the instance of CreativeOne, we receive an indirect economic benefit from
16
the platform fee as we would otherwise have to pay for the back office services separately.
Additionally, we have other business relationships with CreativeOne through our affiliated insurance
agency, Parady Financial Group, LLC, which uses CreativeOne as an independent marketing
organization (IMO), as disclosed in more detail above.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for persons associated with our
firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our
fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm
are expected to adhere strictly to these guidelines. Persons associated with our firm are also required
to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies
reasonably designed to prevent the misuse or dissemination of material, nonpublic information about
you or your account holdings by persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the
telephone number on the cover page of this brochure.
Participation or Interest in Client Transactions
Neither our firm nor any persons associated with our firm have a material financial interest in any
securities recommended to clients.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we recommend to
you or securities in which you are already invested. A conflict of interest exists in such cases because
we have the ability to trade ahead of you and potentially receive more favorable prices than you will
receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons associated
with our firm shall have priority over your account in the purchase or sale of securities. However,
persons associated with our firm are permitted to participate in aggregated trades with client accounts
as described below.
Aggregated Trading
Our firm or persons associated with our firm buy or sell securities for you at the same time we or
persons associated with our firm buy or sell such securities for our own account. We may also combine
our orders to purchase securities with your orders to purchase securities ("aggregated trading"). Refer
to the Brokerage Practices section in this brochure for information on our aggregated trading practices.
Item 12 Brokerage Practices
We recommend the brokerage and custodial services of National Financial Services LLC and Fidelity
Brokerage Services LLC (together with affiliates, "Fidelity"), Members NYSE and SIPC, for investment
management accounts. Your assets must be maintained in an account at a "qualified custodian,"
generally a broker-dealer or bank. In recognition of the value of the services Fidelity provides, you may
pay higher commissions and/or trading costs than those that may be available elsewhere. Our
recommendation of Fidelity as the custodian for our client accounts is based on many factors, including
the level of services provided, the custodian's financial stability, and the cost of services provided by
the custodian to our clients, which includes the yield on cash sweep choices, commissions, custody
fees and other fees or expenses.
17
We seek to use a custodian who will hold client assets and execute transactions on terms that are
overall advantageous when compared to other available providers and their services. Our firm
considers a wide range of factors, including, among others, 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 an account)
• capabilities to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• breadth of investment products made available (stocks, bonds, mutual 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, and
•
•
• availability of other products and services that benefit us, as discussed below.
Accounts served by a third-party manager are to be maintained at one or more custodians that have
been selected by the respective third-party investment manager and they will be disclosed in the third-
party manager's disclosure documents and account opening forms.
Research and Other Soft Dollar Benefits
We do not have any soft dollar arrangements.
Fidelity Institutional
We participate in the institutional adviser program offered by Fidelity Institutional. While we
recommend that our clients use Fidelity as their custodian, the client must decide whether to do so,
and will open the account by entering into an account agreement directly with Fidelity. We do not open
accounts for clients, but we will assist our clients in doing so. If you do not wish to place your assets
with Fidelity, then we cannot manage your account. Not all advisers require their clients to direct
brokerage. Please see the directed brokerage section below for additional information.
Fidelity charges our firm a separate asset-based fee for custody services provided to client's accounts
as described in this section. However, alternative investments incur a separate fee that is not included
in the asset-based fee we pay to Fidelity. If applicable, you will be charged an annual custody fee of
$250 per position for alternative investments. Fidelity is compensated by charging you commissions or
other fees on trades that it executes or that settle into your Fidelity account. Certain trades (for
example, many mutual funds and ETFs) may not incur Fidelity commissions or transaction fees.
Fidelity is also compensated by earning interest on the uninvested cash in your account in Fidelity's
cash and core sweep vehicles.
Fidelity's commission rates applicable to our client accounts were negotiated based on the condition
that our clients collectively maintain a minimum asset level in accounts at Fidelity. This commitment
benefits you because the overall commission rates you pay are lower than they would be otherwise. In
addition to commissions, Fidelity charges you a flat dollar amount as a "prime broker" or "trade away"
fee, on non-international trade-aways, for each trade that we have executed by a different broker-
dealer but where the securities bought or the funds from the securities sold are deposited (settled) into
your Fidelity account. International trade-aways fees are not included in the flat fee arrangement.
These fees are in addition to the commissions or other compensation you pay the executing broker-
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dealer. Because of this, in order to minimize your trading costs, we have Fidelity execute most trades
for your account. The following is a breakdown of the negotiated commissions for the
routine transactions that you pay to Fidelity:
Security Type
Commission Range per
Transaction*
Equities
$0 - $4.95
ETFs
$0 - $4.95
Mutual Funds
$0 - $30.00
Fixed Income
$0 - $2.50 per bond
Trade Away Fee
$20.00
$100.00
Alternatives
*Premiums apply for international trades, accounts not enrolled in eDelivery, and certain manual and/or block
trades via trading desk. Non-routine transactions can have a different fee schedule than what is published above.
Minimums apply to certain transaction types. Please contact Parady Wealth Management or Fidelity for
questions or additional information on commissions or other transaction fees.
Fidelity provides us with access to its institutional brokerage—trading, custody, reporting and related
services—many of which are not typically available directly to a "retail investor." They also directly or
indirectly make available various support services to our advisory firm. Some of those services help us
manage or administer our clients' accounts, while others help us manage and grow our business.
These support services are generally available to us on an unsolicited basis (we do not have to
request them) and at no charge to us as long as we keep a certain level of our clients' assets in
accounts at Fidelity. If we have less than $25,000,000 of client assets at Fidelity, they charge our firm a
quarterly service fee of $2,500 that we pay from our operating account. Our custodian's institutional
brokerage services include access to a broad range of investment products, execution of securities
transactions, and custody of client assets. The investment products available through Fidelity include
some to which we might not otherwise have access or that would require a significantly higher
minimum initial investment by our clients, such as those services described in previous paragraphs
that generally benefit our clients. Note that we are not compensated for trade routing/order flow, nor
are we paid commissions on such trades. We do not receive interest on an account's cash balance.
Fidelity makes available to our firm, directly or indirectly, other products and services that benefit us
but do not directly benefit each of our clients' accounts. These products and services assist us in
managing and administering our clients' accounts. They include investment research, both from the
custodian's own and that of third parties. We use this research to service all or some substantial
number of our clients' accounts. In addition to investment research, they also make available software
and other technology that:
• provides access to client account data (such as duplicate trade confirmations and account
statements);
facilitates trade execution and allocates aggregated trade orders for multiple client accounts;
facilitates payment of our fees from our clients' accounts; and
•
• provides pricing and other market data;
•
• assists with back-office functions, recordkeeping, and client reporting.
Fidelity also directly or indirectly provide other services intended to help us manage and further
develop our business enterprise, such as:
19
technology, compliance, legal, and business consulting;
• educational conferences and events;
•
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants and business insurance
providers.
Fidelity provides some of these services itself. In other cases, they arrange for third-party providers to
offer those services to us. They also discount or waive their fees for some of these services or pay all
or a part of a third party's fees. They also provide us with other benefits such as occasional business
entertainment for our personnel. Certain tools, discounts and services, made available directly or
indirectly by Fidelity, benefit our advisory firm but do not directly benefit each client account. The
availability of these services benefits our firm because we do not have to produce or purchase them as
long as clients maintain assets in accounts at our preferred custodian. There is a conflict of interest
since our firm has an incentive to select or recommend Fidelity as a custodian based on our firm's
interest in receiving these benefits rather than the client's interests in receiving favorable trade
execution.
It is important to mention that the benefit received by our firm through participation in any custodian's
program does not depend on the amount of brokerage transactions directed to that custodian, and our
selection of a custodian is primarily supported by the scope, quality, and cost of services provided as a
whole, not just those services that benefit only our advisory firm. Further, we will act in the best interest
of our clients regardless of the custodian we may recommend. Our firm conducts periodic
assessments of any recommended service provider which generally involves a review of the range and
quality of services, reasonableness of fees, among other items, in comparison to industry peers.
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.
Directed Brokerage
We routinely require that you direct our firm to execute transactions through Fidelity. As such, we may
be unable to achieve the most favorable execution of your transactions (i.e., greater spreads or less
favorable net prices, etc.) and you may pay higher brokerage commissions or other transaction costs
than you might otherwise pay through another broker-dealer that offers the same types of services. Not
all advisers require their clients to direct brokerage.
Aggregating Securities Transactions
Trade aggregation involves the purchase or sale of the same security for several clients/accounts at
approximately the same time. Aggregated orders are completed to obtain better execution, negotiate
favorable transaction rates, or to allocate equitably among multiple client accounts should there be
differences in prices, brokerage commissions or other transactional costs that might otherwise be
unobtainable through separately placed orders.
However, transactions for each client generally will be effected independently, unless we decide to
purchase or sell the same securities for several clients at approximately the same time. We may, but
are not obligated to, aggregate orders for advisory accounts we manage. We will then distribute a
portion of the shares to participating accounts in a fair and equitable manner. Generally, participating
accounts will pay a fixed transaction cost regardless of the number of shares transacted. In certain
cases, each participating account pays an average price per share for all transactions and pays a
proportionate share of all transaction costs on any given day. In the event an order is only partially
20
filled, the shares will be allocated to participating accounts in a fair and equitable manner, typically on a
pro-rata basis. Accounts owned by our firm or persons associated with our firm may participate in
aggregated trading with your accounts; however, they will not be given preferential treatment.
Non-Aggregated Securities Transactions
From time to time, we change investment allocations after we have reviewed the client's portfolio and
financial situation during our annual meeting with specific clients. We typically meet with different
clients at different times of the year. When this occurs we may not aggregate orders, or only aggregate
the orders for clients who we met with on or about the same time.
Note: When trade aggregation is not allowed or infeasible and necessitates individual transactions
(e.g., withdrawal or liquidation requests, odd-lot trades, etc.), an account may potentially be assessed
higher costs or less favorable prices than those where aggregation has occurred.
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position
it should have been in had the trading error not occurred. Depending on the circumstances, corrective
actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account.
Mutual Fund Share Classes
Mutual funds are sold with different share classes, which carry different cost structures. Each available
share class is described in the mutual fund's prospectus. When we purchase, or recommend the
purchase of, mutual funds for a client, we select the share class that is deemed to be in the client's
best interest, taking into consideration the availability of advisory, institutional or retirement plan share
classes, initial and ongoing share class costs, transaction costs (if any), tax implications, cost basis
and other factors. We also review the mutual funds held in accounts that come under our management
to determine whether a more beneficial share class is available, considering cost, tax implications, and
the impact of contingent or deferred sales charges.
Item 13 Review of Accounts
Scheduled Reviews
Your investment adviser representative will monitor your accounts on an ongoing basis and will
conduct account reviews at least annually, to ensure the advisory services provided to you are
consistent with your investment needs and objectives. Additional reviews may be conducted based on
various circumstances, including, but not limited to:
• contributions and withdrawals;
• year-end tax planning;
• market moving events;
• security specific events; and/or
• changes in your risk/return objectives.
For accounts managed by a sub-adviser, a review will be performed at least annually to determine
whether the selected sub-adviser remains an appropriate fit based on your investment parameters. We
will communicate information to the sub-adviser as warranted and will assist the client in understanding
and evaluating the services provided by the sub-adviser.
Interim Reviews
Clients should contact our firm for additional reviews when they anticipate or have experienced
21
changes in their financial situation (i.e., changes in employment, an inheritance, the birth of a new
child, etc.), or if they prefer to change requirements involving their investment allocation. Interim
reviews are conducted by the account's investment adviser representative.
Client Reports
Our clients receive account statements sent directly from custodians, mutual fund companies, transfer
agents or brokerage companies where their investments are held. We urge all clients to carefully
review these account statements for accuracy and clarity, and to ask questions when something is not
clear.
Item 14 Client Referrals and Other Compensation
As disclosed under the Fees and Compensation (Item 5) and Other Financial Industry Activities and
Affiliations sections (Items 10) in this brochure, financial professionals providing investment advice on
behalf of our firm are licensed insurance agents and/or certified public accountants (CPAs) and offer
insurance products and tax preparation services in their individual capacity or through one or more
affiliated companies. For information on the conflicts of interest this presents, and how we address
these conflicts, refer to the Other Financial Industry Activities and Affiliations section.
If we receive or offer an introduction to a client, we do not pay or earn a referral fee, nor are there
established quid pro quo arrangements. Each client retains the right to accept or deny such referral or
subsequent services.
Our clients are generally referrals from one or more of our affiliates. While we do not pay referral fees
to our affiliates or share our revenues with our affiliates as a result of the referrals we receive, the
referral process presents a conflict of interest because each referral can result in additional revenue to
our overall corporate organization. We strive to act in the best interests of each client and only
recommend our services to prospective clients when we believe our services would benefit those
prospective clients. Prospective clients are not required to retain us for investment advisory services
and may do business with the investment advisory firm of their choosing.
On occasion, we refer our clients to one of our affiliates for insurance or tax services. Parady Wealth
Management is not compensated in any way for those referrals. At no time will there be tying
between business practices and/or services; a condition where a client or prospective client would be
required to accept one product or service which is conditional upon the selection of a second,
distinctive tied product or service. Please refer to the Fees and Compensation section (Item 5) for
additional disclosures related to financial professionals and their insurance agent and accounting/CPA
capacities.
We do not receive compensation from any third-party, outside of the Selection of Other Advisers (see
Items 4, 5, & 10), in connection with providing investment advice to you nor do we compensate any
individual or firm for client referrals.
Refer to the Brokerage Practices section above (Item 12) for disclosures on research and other
benefits we receive resulting from our relationship with your account custodian.
Item 15 Custody
The assets of your account will be held by an independent qualified custodian—a bank, broker-dealer,
or other qualified custodian. We do not have physical custody of any of your funds and/or securities;
however, we will directly debit your account(s) for the payment of our advisory fees, which causes our
firm to have limited custody over your funds or securities. Your custodian of record provides
22
investment account transaction confirmations and account statements, which include debits and
credits and any advisory fees for the relevant period. Custodian statements are provided directly to our
clients on at least a quarterly basis.
Our clients are reminded that if they receive a report from any source that contains investment
performance information, they are urged to carefully review and compare their account statements
received from their custodian of record to evaluate that report's accuracy.
Accounts are not to be maintained by our firm or any associate of our firm. In keeping with this policy
involving our clients' funds or securities, our firm:
•
restricts the firm or an associate from serving as trustee or having general power of attorney
over a client account (unless it is an immediate family member);
• does not accept or forward client securities (i.e., stock certificates) erroneously delivered to our
firm;
• prohibits the firm or an associate from having the client's bank or investment account access
information (i.e., passwords and user identification);
• does not currently accept standing letters of authority to third-parties (SLOAs);
• will not collect advance fees of $1,200 or more for services that are to be performed six months
or more into the future; and
• prohibits an associate from having authority to directly withdraw securities or cash assets from
a client account.
In the event our firm accepts SLOAs in the future, we have adopted policies and procedures to comply
with the requirements of the SEC's Investment Adviser Association No-Action Letter ("NAL"), dated
February 2017. Compliance with the conditions, as outlined in the NAL, allows an investment adviser
to exercise limited custody over your funds or securities pursuant to an SLOA without complying with
the requirement to obtain a surprise examination pursuant to Rule 206(4)-2 under the Investment
Advisers Act of 1940.
Item 16 Investment Discretion
Management Services
Investment
Before we can buy or sell securities on your behalf, you must first sign our discretionary management
agreement and the appropriate trading authorization forms.
You may grant our firm discretion over 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. You may
specify investment objectives, guidelines, and/or impose certain conditions or investment parameters
for your account(s). For example, you may specify that the investment in any particular stock or
industry should not exceed specified percentages of the value of the portfolio and/or restrictions or
prohibitions of transactions in the securities of a specific industry or security. Refer to the Advisory
Business section in this brochure for more information on our discretionary management services.
Selection of Other Advisers
By signing our discretionary management agreement, you grant our firm the authority to engage the
services of a sub-adviser to manage all or a portion of your assets on a discretionary basis. We
assume the discretionary authority to hire and fire any sub-adviser without your prior approval. In
certain situations, you might be required to sign an agreement directly with the recommended sub-
adviser that describes their limited account authority, as well as the sub-adviser's custodian of record
account opening documents that include the appropriate trading authorization forms.
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Item 17 Voting Client Securities
Account holders of record periodically receive proxies or other similar solicitations sent directly from
their custodian or transfer agent. If we receive a duplicate copy, note that we do not forward these or
any correspondence relating to the voting of clients' securities, class action litigation, or other corporate
actions.
Our firm does not vote proxies on behalf of clients. We do not offer specific guidance on how to vote
proxies, nor will we offer our position involving a claim or potential claim in any bankruptcy proceeding,
class action securities litigation or other litigation or proceeding relating to securities held at any time in
a client account, including, without limitation, to file proofs of claim or other documents related to such
proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving
client assets. We will answer limited questions via a scheduled meeting with respect to what a proxy
voting request or other corporate matter may be and how to reach the issuer or their legal
representative.
Investment management services clients should review the sub-adviser's Form ADV Part 2A to
determine that investment manager's proxy voting policies. Otherwise, each account holder will
maintain responsibility for directing the manner in which proxies solicited by issuers of securities that
are beneficially owned shall be voted, as well as making all other elections relative to mergers,
acquisitions, tender offers or other legal matters or events pertaining to holdings.
Clients should consider contacting the issuer or their legal counsel involving specific questions they
may have with respect to a particular proxy solicitation or corporate action.
Item 18 Financial Information
Parady Wealth Management has not filed for bankruptcy petition at any time over the past ten years.
Additionally, our firm does not have a financial condition or impairment that would prevent us from
meeting our contractual commitments to clients.
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