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Form ADV Part 2A – Firm Brochure
Item 1: Cover Page
March 2026
Petix & Botte Financial
7777 Alvarado Road – Suite 520
La Mesa, CA 91942
www.petixbotte.com
Firm Contact:
Andrew Williams
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Petix & Botte
Company doing business as Petix & Botte Financial. If you have any questions about the contents of
this brochure, please contact us by telephone at (619) 698-6500 or email andrew@petixbotte.com.
The information in this brochure has not been approved or verified by the United States Securities
and Exchange Commission or by any State Securities Authority.
Additional information about Petix & Botte Financial also is available on the SEC’s website at
www.adviserinfo.sec.gov by searching CRD # 170020.
Please note that the use of the term “registered investment adviser” and description of Petix & Botte
Financial and/or our associates as “registered” does not imply a certain level of skill or training. You
are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who
advise you for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Petix & Botte Financial is required to advise you of any material changes to the Firm Brochure
(“Brochure”) from our last annual update.
Since our last annual amendment filed on 03/27/2025, we do not have any material changes to
disclose.
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Petix & Botte Financial
Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................................. 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Advisory Business.................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................. 7
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 9
Item 7: Types Of Clients & Account Requirements .................................................................................................... 9
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 9
Item 9: Disciplinary Information .................................................................................................................................... 11
Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 11
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............. 12
Item 12: Brokerage Practices ........................................................................................................................................... 13
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 15
Item 14: Client Referrals & Other Compensation ..................................................................................................... 16
Item 15: Custody .................................................................................................................................................................... 16
Item 16: Investment Discretion ....................................................................................................................................... 17
Item 17: Voting Client Securities ..................................................................................................................................... 17
Item 18: Financial Information ........................................................................................................................................ 17
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Petix & Botte Financial
Item 4: Advisory Business
We are dedicated to providing individuals and other types of clients with a wide array of investment
advisory services. Our firm is a corporation formed in the State of California. Our firm has been in
business as an investment adviser since 2014 and is owned by Andrew Williams and Vickie Petix.
Description of the Types of Advisory Services We Offer
Asset Management:
We emphasize continuous and regular account supervision. As part of our asset management service,
we generally create a portfolio, consisting of individual stocks or 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. Each portfolio will be initially designed to meet a particular investment goal,
which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been
determined, we review the portfolio periodically and if necessary, rebalance the portfolio based upon
the client’s individual needs, stated goals and objectives. Each client has the opportunity to place
reasonable restrictions on the types of investments to be held in the portfolio.
Financial Planning & Consulting:
We provide a variety of financial planning and consulting services to individuals, families and other
clients regarding the management of their financial resources based upon an analysis of the client’s
current situation, goals, and objectives. Generally, such financial planning services will involve
preparing a financial plan or rendering a financial consultation for clients based on the client’s
financial goals and objectives. This planning or consulting may encompass one or more of the
following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning,
Education Planning, Corporate and Personal Tax Planning, Corporate Structure, Real Estate Analysis,
Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal
Financial Planning.
Our written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. For example,
recommendations may be made that the clients begin or revise investment programs, create or revise
wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or
establish education or charitable giving programs. It should also be noted that we refer clients to an
accountant, attorney or other specialist, as necessary for non-advisory related services. For written
financial planning engagements, we provide our clients with a written summary of their financial
situation, observations, and recommendations. For financial consulting engagements, we usually do
not provide our clients with a written summary of our observations and recommendations as the
process is less formal than our planning service. Plans or consultations are typically completed within
six (6) months of the client signing a contract with us, assuming that all the information and
documents we request from the client are provided to us promptly. Implementation of the
recommendations will be at the discretion of the client.
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LPL Financial Sponsored Advisory Programs:
Our firm may provide advisory services through certain programs sponsored by LPL Financial
(“LPL”), a registered investment adviser and broker-dealer. Below is a brief description of each LPL
advisory program available to our firm. For more information regarding the LPL programs, including
more information on the advisory services and fees that apply, the types of investments available in
the programs and the potential conflicts of interest presented by the programs please see the LPL
Financial Form ADV Part 2 or the applicable program’s Appendix 1 (Wrap Fee Program Brochure)
and the applicable client agreement.
Optimum Market Portfolios Program (OMP)
OMP offers clients the ability to participate in a professionally managed asset allocation program
using Optimum Funds Class I shares. Under OMP, client will authorize LPL on a discretionary basis
to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Advisor
will assist the client in determining the suitability of OMP for the client and assist the client in setting
an appropriate investment objective. Advisor will have discretion to select a mutual fund asset
allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have
discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL
will also have authority to rebalance the account.
Model Wealth Portfolios Program (MWP)
MWP offers clients a professionally managed mutual fund asset allocation program. We will obtain
the necessary financial data from the client, assist the client in determining the suitability of the MWP
program and assist the client in setting an appropriate investment objective. The Advisor will initiate
the steps necessary to open an MWP account and have discretion to select a model portfolio designed
by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s
Research Department is responsible for selecting the mutual funds within a model portfolio and for
making changes to the mutual funds selected.
The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds
(including in certain circumstances exchange traded funds) and to liquidate previously purchased
securities. The client will also authorize LPL to effect rebalancing for MWP accounts.
The MWP program makes available model portfolios designed by strategists other than LPL’s
Research Department. The Advisor will have discretion to choose among the available models
designed by LPL and outside strategists.
Manager Access Select Program (MAS)
Manager Access Select provides clients access to the investment advisory services of professional
portfolio management firms for the individual management of client accounts. Advisor will assist
client in identifying a third party portfolio manager (Portfolio Manager) from a list of Portfolio
Managers made available by LPL. The Portfolio Manager manages client’s assets on a discretionary
basis. Advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection
process.
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Guided Wealth Portfolios Program (GWP)
Guided Wealth Portfolios is a centrally managed, algorithm-based investment program which is
made available to users and clients through a web-based, interactive account management portal.
Investment recommendations to buy and sell exchange-traded funds and open-end mutual funds are
generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of
FutureAdvisor, Inc. (“FutureAdvisor”), based upon model portfolios constructed by LPL Financial and
selected for the account. Communications concerning GWP are intended to occur primarily through
electronic means, although we will be available to discuss investment strategies, objectives or the
account in general in person or over the phone.
A preview of the Program (the “Educational Tool”) is provided for a period of up to 45 days to help
users determine whether they would like to become advisory clients and receive ongoing financial
advice from LPL Financial, FutureAdvisor and our firm by enrolling in the advisory service (the
“Managed Service”). The Educational Tool and Managed Service are described in more detail in the
GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of
LPL Financial, FutureAdvisor or our firm, do not enter into an advisory agreement with LPL Financial,
FutureAdvisor or our firm, do not receive ongoing investment advice or supervisions of their assets,
and do not receive any trading services.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Asset Management service.
Additionally, we offer general investment advice to clients utilizing our Financial Planning &
Consulting service.
Each 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. Restrictions would
be limited to our Asset Management service. We do not manage assets through our Financial Planning
and Consulting service.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of 12/31/2025, we managed $411,940,000 on a discretionary basis.
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Item 5: Fees & Compensation
How We Are Compensated for Our Advisory Services
Asset Management:
Assets Under Management
$0 to $250,000
Above $250,000
Annual Percentage of Assets Charge
0.85% - 2.00%
0.25% - 1.50%
Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of
your account on the last day of the previous quarter. The ultimate fee we charge is based on the scope
and complexity of the engagement and will be listed in Schedule A of the advisory agreement. Our
firm bills on cash and cash equivalents unless indicated otherwise in writing. LPL will make quarterly
adjustments for deposits and withdrawals in client accounts. Fees will generally be automatically
deducted from your managed account*. As part of this process, you understand and acknowledge the
following:
a) LPL Financial as the custodian sends statements at least quarterly to clients showing all
disbursements for their account, including the amount of the advisory fees paid to our
firm.
b) The client has provided authorization permitting fees to be directly paid by these terms.
c) LPL Financial calculates the advisory fees and deducts them from the Client’s account.
*In rare cases, we will agree to directly bill clients.
Financial Planning & Consulting:
We charge an hourly or flat fee for our Financial Planning & Consulting services. The total estimated
fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of our
engagement with you. Our hourly fee is $250 and flat fees generally range from $500 to $3,000.
We do not require a retainer of the ultimate financial planning or consulting fee we charge you. The
fee is due to us within thirty (30) days of your financial plan being delivered or consultation rendered
to you.
LPL Sponsored Programs:
The maximum fees for the LPL sponsored advisory programs are as follows:
LPL Sponsored Advisory Program
(a) Optimum Market Portfolios Program (OMP)
(b) Model Wealth Portfolios Program (MWP)
(c) Manager Access Select Program (MAS)
(d) Guided Wealth Portfolios Program (GWP)
Annual Percentage of Assets Charge
2.50%
2.50%
2.50%
0.35%
The fees for LPL’s Financial Sponsored Advisory Programs are billed on a pro-rata annualized basis
quarterly in advance based on the value of your account on the last day of the previous quarter. LPL
serves as program sponsor, investment adviser, and broker-dealer for the LPL advisory programs. Our
firm and LPL may share in the account fee and other fees associated with program accounts.
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Petix & Botte Financial
Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of
your account on the last day of the previous quarter. Management fees will be deducted from the
client’s managed account, upon a signed Account Application Form. The ultimate management fee is
indicated on the Account Application Form. Our firm does not have the authority to instruct LPL
Financial to change or deduct fees without written client consent. LPL Financial sends a quarterly
statement showing all fees deducted from the clients accounts.
The MWP account fee consists of an LPL Financial program fee, a strategist fee (if applicable) and an
advisor fee of up to 2.00%. Accounts remaining under the legacy fee structure may be charged one
aggregate account fee, for which the maximum account fee is 2.50%. See the MWP program brochure
for more information.
GWP Managed Service clients are charged an account fee consisting of an LPL Financial program fee
of 0.35% and an advisor fee of up to 1.00%. In the future, a strategist fee may apply. However, LPL
Research currently serves as the sole portfolio strategist and does not charge a fee for its services.
FutureAdvisor is compensated directly by LPL Financial for its services, including the Algorithm and
related software, through an annual sub-advisory fee (tiered based on assets under management by
FutureAdvisor, at a rate ranging from 0.10% to 0.17%). As each asset tier is reached, LPL Financial’s
share of the compensation shall increase and clients will not benefit from such asset tiers.
GWP Educational Tool provides access to sample recommendations at no charge to users. However,
if users decide to implement sample recommendations by executing trades, they will be charged fees,
commissions, or expenses by the applicable broker or adviser, as well as underlying investment fees
and expenses.
Other Fees:
Clients will incur transaction charges for trades executed in their accounts. These transaction fees
are separate from our fees and will be disclosed by the firm that the trades are executed through. LPL
Financial offers a trading platform with select exchange traded funds (“ETFs”) that do not charge
transaction fees. The no-transaction-fee ETF trading platform is available to clients participating in
LPL Financial’s Strategic Wealth Management (“SWM”) program. Clients will be subject to
transaction fees charged by LPL Financial for ETFs not included in LPL Financial’s platform and for
other types of securities. The limited number of ETFs available on LPL Financial’s no-transaction fee
platform may have higher overall expenses than other types of securities and ETFs not included in
the platform. Other major custodians have eliminated transaction fees for all ETFs and U.S. listed
equities, so clients may pay more for investing in the same securities at LPL Financial.
Also, clients will pay the following separately incurred expenses, which we do not receive any part
of: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be
disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses).
Refunds Following Termination
Either party may terminate the signed Asset Management agreement by providing written notice to
the other party at any time. Upon notice of termination, LPL will process a pro-rate refund of any
unearned portion of the advisory fees charged in advance at the beginning of the quarter.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For the purpose of calculating refunds, all
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Petix & Botte Financial
work performed by us up to the point of termination shall be calculated at the hourly fee currently in
effect. Clients will receive a pro-rata refund of any unearned fees based on the time and effort
expended by our firm.
Commissionable Securities Sales
In order to sell securities for a commission, our supervised persons are registered representatives of
LPL. Our supervised persons may accept compensation for the sale of securities or other investment
products, including distribution or service (“trail”) fees from the sale of mutual funds. You should be
aware that the practice of accepting commissions for the sale of securities:
1. Presents a conflict of interest and gives our firm and/or our supervised persons an incentive to
recommend investment products based on the compensation received, rather than on your
needs. We generally address commissionable sales conflicts that arise when explaining to clients
that commissionable securities sales creates an incentive to recommend products based on the
compensation we and/or our supervised persons may earn and/or when recommending
commissionable mutual funds, explaining that “no-load” funds are also available.
2. In no way prohibits you from purchasing investment products recommended by us through other
brokers or agents which are not affiliated with us.
Item 6: Performance-Based Fees & Side-By-Side Management
We do not accept performance-based fees.
Item 7: Types Of Clients & Account Requirements
We have the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations; and
• Corporations, Limited Liability Companies and/or Other Business Types.
We do not have any requirements for opening and maintaining accounts or otherwise engaging us.
However, LPL Financial has the following account requirements for their sponsored advisory
programs:
• A minimum account value of $15,000 is required for OMP.
• A minimum account value of $25,000 is required for MWP.
• A minimum account value of $100,000 is required for MAS, however, in certain instances, the
minimum account size may be lower or higher.
• A minimum account value of $5,000 is required for GWP.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
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Fundamental Analysis. 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.
Technical Analysis. We analyze past market movements and apply that analysis to the present in an
attempt to recognize recurring patterns of investor behavior and potentially predict future price
movement. Technical analysis does not consider the underlying financial condition of a company.
This presents a risk in that a poorly-managed or financially unsound company may underperform
regardless of market movement.
Cyclical Analysis. In this type of technical analysis, we measure the movements of a particular stock
against the overall market in an attempt to predict the price movement of the security.
Investment Strategies We Use
We use the following strategies in 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 a year). A risk in a long-term
purchase strategy is that by holding the security for this length of time, we may not take advantages
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
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.
Depending on a client’s investment objectives, financial circumstances, time horizon, asset allocation,
and tax considerations, we may also utilize tax loss harvesting and trading to minimize tax exposure.
When utilizing a tax loss harvesting strategy, we sell securities that have declined in value in order
to offset gains from other investments.
Margin Transactions: Our firm may purchase securities for your portfolio with money borrowed
from your brokerage account. This allows you to purchase more stock than you would be able to with
your available cash and allows us to purchase securities without selling other holdings. Margin
accounts and transactions are risky and not necessarily appropriate for every client.
The potential risks associated with these transactions are (1) You can lose more funds than are
deposited into the margin account; (2) the forced sale of securities or other assets in your account;
(3) the sale of securities or other assets without contacting you; (4) you may not be entitled to choose
which securities or other assets in your account(s) are liquidated or sold to meet a margin call; and
(5) custodians charge interest on margin balances which will reduce your returns over time.
Structured Products: Structured products are designed to facilitate highly customized risk-return
objectives. While structured products come in many different forms, they typically consist of a debt
security that is structured to make interest and principal payments based upon various assets, rates
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Petix & Botte Financial
or formulas. Many structured products include an embedded derivative component. Structured
products may be structured in the form of a security, in which case these products may receive
benefits provided under federal securities law, or they may be cast as derivatives, in which case they
are offered in the over-the-counter market and are subject to no regulation.
Investing in structured products includes significant risks, including valuation, lack of liquidity, price,
credit and market risks. The relative lack of liquidity is due to the highly customized nature of the
investment and the fact that the full extent of returns from the complex performance features is often
not realized until maturity. Another risk with structured products is the credit quality of the issuer.
Although the cash flows are derived from other sources, the products themselves are legally
considered to be the issuing financial institution's liabilities. The vast majority of structured products
are from high-investment-grade issuers only. Also, there is a lack of pricing transparency. There is no
uniform standard for pricing, making it harder to compare the net-of-pricing attractiveness of
alternative structured product offerings than it is, for instance, to compare the net expense ratios of
different mutual funds or commissions among broker-dealers.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and your account(s) could enjoy a gain, it is also possible that the stock market
may decrease and your account(s) could suffer a loss. It is important that you understand the risks
associated with investing in the stock market, are appropriately diversified in your investments, and
ask us any questions you may have.
Description of Material, Significant or Unusual Risks
We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we
try to achieve the highest return on our client’s cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to Asset
Management, as applicable.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
LPL Financial:
Representatives of our firm are financial advisors of LPL Financial, member FINRA/SIPC, and
licensed insurance agents. They may offer products and receive normal and customary commissions
as a result of these transactions. A conflict of interest may arise as these commissionable securities
sales may create an incentive to recommend products based on the compensation they may earn.
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Selection of LPL Financial’s Advisory Sponsored Programs:
Our firm receives compensation as a result of a client’s participation in an LPL Financial program.
Depending on, among other things, the type and size of the account, type of securities held in the
account, changes in its value over time, the ability to negotiate fees or commissions, the historical or
expected size or number of transactions, and the number and range of supplementary advisory and
client-related services provided to the client, the amount of this compensation may be more or less
than what we would receive if the client participated in other programs, whether through LPL
Financial or another sponsor, or paid separately for investment advice, brokerage and other services.
The account fee may be higher than the fees charged by other investment advisors for similar
services. For instance, FutureAdvisor offers direct-to-consumer services similar to GWP. Therefore,
clients could generally pay a lower advisory fee for algorithm-driven, automated investment advisory
services through FutureAdvisor or other robo providers. However, clients using such direct robo
services will forgo opportunities to utilize LPL Financial-constructed model portfolios or to work
directly with a financial advisor.
Clients should consider the level and complexity of the advisory services to be provided when
negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with our firm.
With regard to accounts utilizing third-party portfolio managers under aggregate, all-in-one account
fee structures (including MAS and the legacy MWP fee structure), because the portion of the account
fee retained by us varies depending on the portfolio strategist fee associated with a portfolio, we have
a financial incentive to select one portfolio instead of another portfolio.
Please refer to the relevant LPL Financial Form ADV program brochure for a more detailed discussion
of conflicts of interest.
Tax & Financial Services Co., Inc.:
Representatives of our firm are also tax preparers for Tax & Financial Services Co., Inc., a tax
preparation company. Such services are independent of our financial planning and investment
advisory services and are governed under a separate engagement agreement. Clients are under no
obligation to utilize such services.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions & Personal Trading
We recognize that the personal investment transactions of members and employees of our firm demand
the application of a high Code of Ethics and require that all such transactions be carried out in a way that
does not endanger the interest of any client. At the same time, we believe that if investment goals are
similar for clients and for members and employees of our firm, it is logical and even desirable that there
be common ownership of some securities.
Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-
clearing procedure) with respect to transactions effected by our members, officers and employees for
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Petix & Botte Financial
their personal accounts1. In order to monitor compliance with our personal trading policy, we have a
quarterly securities transaction reporting system for all of our associates.
Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An
investment adviser is considered a fiduciary. 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. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core
underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities
Transactions Policies and Procedures. We require all of our supervised persons 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 or affiliation and at least annually thereafter, all supervised persons will sign an
acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our
firm and supervised persons 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. However, 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.
Neither our firm nor 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.
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.
Related persons of our firm may 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 within 24 hours prior to buying or selling for our clients. If related persons’ accounts
are included in a block trade, our related persons will always trade personal accounts last.
Item 12: Brokerage Practices
We seek to recommend a custodian/broker who will hold your assets and execute transactions on
terms that are overall most advantageous when compared to other available providers and their
services. We consider a wide range of factors, including, among others, these:
• Ability to maintain the confidentiality of trading intentions
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Liquidity of the securities traded
• Willingness to commit capital
• Ability to place trades in difficult market environments
• Research services provided
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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• Ability to provide investment ideas
• Execution facilitation services provided
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
With this in consideration, our firm has an arrangement with LPL Financial. LPL Financial offers
independent investment advisers non-soft dollar services which include custody of securities, trade
execution, clearance and settlement of transactions. We receive non-soft-dollar services such as
research and administrative functions including portfolio pricing, account statement generation and fee
calculations, which are intended to support our firm in conducting business and in serving the best
interests of our clients. These services do not incentivize us to recommend LPL Financial. Our
recommendation of LPL Financial to our clients is based on our clients’ interests in receiving best
execution and the level of competitive, professional services LPL Financial provides. Our firm does not
receive client brokerage commissions (or markups or markdowns) to obtain research or other
products or services. Neither our firm receive brokerage commissions for client referrals. We do not
allow client-directed brokerage, as trades in our clients’ accounts are executed through LPL Financial,
a qualified custodian and broker-dealer; neither do we direct client transactions to LPL Financial in
return for soft-dollar benefits.
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, we will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
We perform investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when we believe that to
do so will be in the best interest of the effected accounts. When such concurrent authorizations occur,
the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, we attempt to allocate trade executions in the most equitable manner
possible, taking into consideration client objectives, current asset allocation and availability of funds
using price averaging, proration and consistently non-arbitrary methods of allocation.
Transactions for each client account 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, combine or "batch" such orders to obtain “best execution”, to negotiate more favorable
commission rates, to allocate fairly among the clients’ differences in prices and commissions or other
transaction costs that might have been obtained had such orders been placed independently. Under this
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Petix & Botte Financial
procedure, transactions will be averaged as to price and will be allocated among our clients in
proportion to the purchase and sale orders placed for each client account on any given day. To the extent
that we determine to aggregate client orders for the purchase or sale of securities, including securities
in which our principals (and/or associated persons) may invest, we shall generally do so in accordance
with the parameters set forth in SEC No-Action Letter, SMC Capital, Inc. We shall not receive any
additional compensation or remuneration as a result of the aggregation. When referring clients to
dealers, we will only refer clients to dealers registered in states where the clients reside.
If requested, we will arrange for the execution of securities brokerage transactions for the account
through broker-dealers that we reasonably believe will provide "best execution". In seeking “best
execution”, the determinative factor is not the lowest possible commission cost, but whether the
transaction represents the best qualitative execution. We also take into consideration the full range
of a broker-dealer's services including execution capability, commission rates, and responsiveness.
Although we will seek competitive commission rates, it may not necessarily obtain the lowest
possible commission rates for account transactions. Over-the-Counter (OTC) securities transactions
for our clients are generally effected based on two (2) separate broker-dealers: (1) a “dealer” or
“principal” acting as market-maker; and (2) the executing broker-dealer that acts in an agency
capacity for the client’s account. Dealers executing principal transactions typically include a mark-
up/down, which is included in the offer or bid price of the securities purchased or sold. In addition
to the dealer mark-up/down, the client may also incur the transaction fee imposed by the executing
broker-dealer. We do not receive any portion of the dealer mark-up/down or the executing broker-
dealer transaction fee.
Item 13: Review of Accounts or Financial Plans
We review accounts on a periodic basis for our clients subscribing to our Asset Management service.
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. We do not provide written reports to clients, unless asked to do so. Verbal reports to
clients take place on at least an annual basis when we contact clients who subscribe to our Asset
Management service. Only our Financial Advisors will conduct reviews of client accounts.
We 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.
Financial Planning & Consulting clients will receive reviews of their written plans upon completion
to discuss the summary of recommendations. We do not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning & Consulting clients do not receive
written or verbal updated reports regarding their financial plans unless they separately contract with
us for a post-financial plan meeting or update to their initial written financial plan.
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Petix & Botte Financial
Item 14: Client Referrals & Other Compensation
LPL Financial
We may receive from LPL Financial, without cost and/or at a discount support services and/or
products, to assist us to better monitor and service client accounts maintained at such institutions.
Included within the support services we may receive investment-related research, pricing
information and market data, software and other technology that provide access to client account
data, compliance and/or practice management-related publications, discounted or gratis consulting
services, discounted and/or gratis attendance at conferences, meetings, and other educational
and/or social events, marketing support, computer hardware and/or software and/or other
products used by us to assist us in our investment advisory business operations. Our clients do not
pay more for investment transactions effected and/or assets maintained at LPL Financial as result of
this arrangement. There is no commitment made by us to LPL Financial or any other institution as a
result of the above arrangement.
Unaffiliated Investment Companies & Mutual Funds
We may occasionally co-sponsor educational seminars or receive marketing support from
unaffiliated investment companies or mutual funds. Our clients do not pay more for investment
transactions effected and/or assets maintained as result of this arrangement. There is no
commitment made by us to any other institution as a result of this arrangement.
Referral Fees
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 testimonials or
endorsements (which include client referrals).
Item 15: Custody
Deduction of Advisory Fees
All of our clients receive at least quarterly account statements directly from their custodians. Upon
opening an account with a qualified custodian on a client's behalf, we promptly notify the client in
writing of the qualified custodian's contact information. If we decide to also send account statements
to clients, such notice and account statements include a legend that recommends that the client
compare the account statements received from the qualified custodian with those received from our
firm.
Third Party Money Movement
The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under
the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody
Rule as well as clarified that an adviser who has the power to disburse client funds to a third party
under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has
adopted the following safeguards in conjunction with our custodian, LPL Financial:
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Petix & Botte Financial
• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
We encourage our clients to raise any questions with us about the custody, safety or security of their
assets. The custodians we do business with will send you account statements listing your account
balance(s), transaction history and any fee debits or other fees taken out of your account.
Item 16: Investment Discretion
Our firm only manages accounts where we have discretionary authority. Such authority shall be
granted through the executed investment advisory client agreement. By granting investment
discretion, we are authorized to execute securities transactions, which securities are bought and sold,
the total amount to be bought and sold, and the costs at which the transactions will be effected.
Limitations may be imposed by the client in the form of specific constraints on any of these areas of
discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies
or other solicitations directly from their custodian or a transfer agent. In the event that proxies are
sent to our firm, we will forward them on to you and ask the party who sent them to mail them
directly to you in the future. Clients may call, write or email us to discuss questions they may have
about particular proxy votes or other solicitations.
Item 18: Financial Information
We are not required to provide financial information in this Brochure because:
• We do not require the prepayment of more than $1,200 in fees and six or more months in
advance.
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Petix & Botte Financial
• We do not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
• We have never been the subject of a bankruptcy proceeding.
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Petix & Botte Financial