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Item 1
Cover Page
Pollock Planning Associates, Inc.
ADV Part 2A, Firm Brochure
Dated: February 12, 2026
Contact: Steven Pollock, Chief Compliance Officer
61 Villa Nova Drive
Asheville, NC 28804
www.pollockplanning.com
This Brochure provides information about the qualifications and business practices of Pollock
Planning Associates, Inc. If you have any questions about the contents of this brochure, please
contact us at 856-266-2276 or spollock15@gmail.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 Pollock Planning Associates, Inc. is also available on the SEC’s website
at www.adviserinfo.sec.gov.
References herein to Pollock Planning Associates, Inc. as a “registered investment adviser” or any
reference to being “registered” does not imply a certain level of skill or training.
Item 2
Material Changes
There have been no material changes made to this Brochure since Pollock Planning Associates’ last Annual
Amendment filing made on January 17, 2025.
Pollock Planning Associates’ Chief Compliance Officer, Steven Pollock, remains available to address any
questions that an existing or prospective client may have regarding this Brochure.
Item 3
Table of Contents
Item 1 Cover Page .................................................................................................................................... 1
Item 2 Material Changes .......................................................................................................................... 2
Item 3
Table of Contents .......................................................................................................................... 2
Item 4 Advisory Business ........................................................................................................................ 3
Fees and Compensation ................................................................................................................ 8
Item 5
Performance-Based Fees and Side-by-Side Management .......................................................... 10
Item 6
Item 7
Types of Clients .......................................................................................................................... 10
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 10
Item 9 Disciplinary Information ............................................................................................................ 12
Item 10 Other Financial Industry Activities and Affiliations .................................................................. 12
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.............. 13
Item 12 Brokerage Practices .................................................................................................................... 14
Item 13 Review of Accounts .................................................................................................................... 16
Item 14 Client Referrals and Other Compensation .................................................................................. 16
Item 15 Custody ....................................................................................................................................... 16
Investment Discretion ................................................................................................................. 17
Item 16
Item 17 Voting Client Securities .............................................................................................................. 17
Item 18 Financial Information ................................................................................................................. 17
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Item 4
Advisory Business
A. Pollock Planning Associates, Inc. (“Pollock Planning”) is a corporation formed in October
1985 under the law of the State of New Jersey. Pollock Planning became registered as an
investment adviser registered with the Securities and Exchange Commission on May 30,
1986. Pollock Planning is solely owned by Steven Leonard Pollock and he is also the firm’s
President.
B. As discussed below, Pollock Planning offers to its clients (primarily high net worth
individuals) investment advisory services on a discretionary basis and financial planning
services.
INVESTMENT MANAGEMENT SERVICES
Pollock Planning provides discretionary investment management services on a fee-only
basis as discussed at Item 5 below. We also offer to provide all clients with financial
planning services. Pollock Planning’s services include investment management services,
and, to the extent specifically requested by the client, financial planning and consulting
services. In the event that the client requires extraordinary planning or consultation services
(to be determined in the sole discretion of Pollock Planning), the firm may determine to
charge for those additional services, the dollar amount of which will be agreed to between
Pollock Planning and the client. Clients and prospective clients should review the
disclosure under the heading “Limitations of Financial Planning and Non-Investment
Consulting/Implementation Services” for more information about our planning and
consulting services. To commence the investment advisory process, Pollock Planning will
ascertain each client’s investment objective(s) and then allocate the client’s assets
consistent with the client’s designated investment objective(s). Once allocated, Pollock
Planning provides ongoing supervision of the account(s).
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
Pollock Planning may also provide financial planning and related consulting services
regarding matters such as tax and estate planning, insurance, etc. on a stand-alone basis per
the terms and conditions of a separate written agreement and fee, the fee for which shall
generally be based upon the individual providing the service and the scope of the services
to be provided. Prior to engaging Pollock Planning to provide planning or consulting
services, clients are generally required to enter into a Financial Planning and Consulting
Agreement with Pollock Planning setting forth the terms and conditions of the engagement
(including termination), describing the scope of the services to be provided, and the portion
of the fee that is due from the client prior to Pollock Planning commencing services.
If requested by the client, Pollock Planning may recommend the services of other
professionals for implementation purposes (i.e. attorneys, accountants, insurance agents).
The client is under no obligation to engage the services of any recommended professional.
The client retains absolute discretion over all implementation decisions and is free to accept
or reject any recommendation from Pollock Planning. If the client engages any
recommended professional, and a dispute arises, the client agrees to seek recourse
exclusively from the engaged professional. It remains the client’s responsibility to
promptly notify Pollock Planning if there is ever any change in their financial situation or
investment objectives so that Pollock Planning can review, and if necessary, revise its
previous recommendations.
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MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. To the extent requested by the client, Pollock Planning will generally provide
financial planning and related consulting services regarding matters such as tax and estate
planning, insurance, etc. Pollock Planning will generally provide such consulting services
inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon
assets under management, extraordinary matters, special projects, stand-alone planning
engagements, etc. for which Firm may charge a separate or additional fee). Pollock
Planning believes that it is important for the client to address financial planning issues on
an ongoing basis. Pollock Planning’s advisory fee, as set forth at Item 5 below, will remain
the same regardless of whether or not the client determines to address financial planning
issues with Pollock Planning. Pollock Planning does not serve as an attorney, accountant,
or insurance agent, and no portion of our services should be construed as same.
Accordingly, Pollock Planning does not prepare legal documents or tax returns, nor does
it offer or sell insurance products. To the extent requested by a client, we may recommend
the services of other professionals for non-investment implementation purpose (i.e.,
attorneys, accountants, insurance, etc.). The client is not under any obligation to engage
any such professional(s). The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from Pollock
Planning and/or its representatives. If the client engages any professional (i.e., attorney,
accountant, insurance agent, etc.), recommended or otherwise, and a dispute arises
thereafter relative to such engagement, the engaged professional shall remain exclusively
responsible for resolving any such dispute with the client. At all times, the engaged licensed
professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not Pollock Planning,
shall be responsible for the quality and competency of the services provided.
Retirement Rollovers. A client or prospective client leaving an employer typically has
four options regarding an existing retirement plan (and may engage in a combination of
these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over
the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii)
roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value
(which could, depending upon the client’s age, result in adverse tax consequences). If
Pollock Planning recommends that a client roll over their retirement plan assets into an
account to be managed by Pollock Planning, such a recommendation creates a conflict of
interest if Pollock Planning will earn a new (or increase its current) compensation as a
result of the rollover. If Pollock Planning provides a recommendation as to whether a client
should engage in a rollover or not, Pollock Planning is acting as a fiduciary 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. No client is
under any obligation to roll over retirement plan assets to an account managed by Pollock
Planning. Pollock Planning’s Chief Compliance Officer, Steven Pollock, remains available
to address any questions that a client or prospective client may have regarding the conflict
of interest presented by such rollover recommendation.
Use of Mutual Funds and Exchange Traded Funds. Pollock Planning utilizes mutual
funds and exchange traded funds for its client portfolios. In addition to Pollock Planning’s
investment advisory fee described below, and transaction and/or custodial fees discussed
below, clients will also incur, relative to all mutual fund and exchange traded fund
purchases, charges imposed at the fund level (e.g. management fees and other fund
expenses).
Please Note-Use of DFA Mutual Funds: Pollock Planning utilizes the mutual
funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally
only available through registered investment advisers approved by DFA. Thus, if
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the client was to terminate Pollock Planning’s services, and transition to another
adviser who has not been approved by DFA to utilize DFA funds, restrictions
regarding additional purchases of, or reallocation among other DFA funds, will
generally apply. ANY QUESTIONS: Pollock Planning’s Chief Compliance
Officer, Steven Pollock, remains available to address any questions that a client or
prospective client may have regarding the above.
Custodian Charges-Additional Fees. As discussed below at Item 12 below, when
requested to recommend a broker-dealer/custodian for client accounts, Pollock Planning
generally recommends that Schwab serve as the broker-dealer/custodian for client
investment management assets. Broker-dealers such as Schwab charge brokerage
commissions, transaction, and/or other type fees for effecting certain types of securities
transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and
mark-downs charged for fixed income transactions, etc.). The types of securities for which
transaction fees, commissions, and/or other type fees (as well as the amount of those fees)
shall differ depending upon the broker-dealer/custodian. While certain custodians,
including Schwab, generally (with the potential exception for large orders) do not currently
charge fees on individual equity transactions (including ETFs), others do. Please Note:
there can be no assurance that Schwab will not change their transaction fee pricing in the
future. The above fees/charges are in addition to Pollock Planning’s investment advisory
fee at Item 5 below. Pollock Planning does not receive any portion of these fees/charges.
ANY QUESTIONS: Pollock Planning’s Chief Compliance Officer, Steven Pollock,
remains available to address any questions that a client or prospective client may have
regarding the above.
Cash Positions. Pollock Planning continues to treat cash as an asset class. As such, unless
determined to the contrary by Pollock Planning, all cash positions (money markets, etc.)
shall continue to be included as part of assets under management for purposes of
calculating Pollock Planning’s advisory fee. At any specific point in time, depending upon
perceived or anticipated market conditions/events (there being no guarantee that such
anticipated market conditions/events will occur), Pollock Planning may maintain cash
positions for defensive purposes. In addition, while assets are maintained in cash, such
amounts could miss market advances. Depending upon current yields, at any point in time,
Pollock Planning’s advisory fee could exceed the interest paid by the client’s money market
fund. ANY QUESTIONS: Pollock Planning’s Chief Compliance Officer, Steven Pollock,
remains available to address any questions that a client or prospective client may have
regarding the above fee billing practice.
Cash Sweep Accounts. Account custodians generally require that cash proceeds from
account transactions or cash deposits be swept into and/or initially maintained in the
custodian’s sweep account. The yield on the sweep account is generally lower than those
available in money market accounts. To help mitigate this issue, Pollock Planning shall
generally purchase a higher yielding money market fund available on the custodian’s
platform with cash proceeds or deposits, unless Pollock Planning reasonably anticipates
that it will utilize the cash proceeds during the subsequent 30-day period to purchase
additional investments for the client’s account. Exceptions and/or modifications can and
will occur with respect to all or a portion of the cash balances for various reasons, including,
but not limited to, the amount of dispersion between the sweep account and a money market
fund, an indication from the client of an imminent need for such cash, or the client has a
demonstrated history of writing checks from the account. ANY QUESTIONS: Pollock
Planning’s Chief Compliance Officer, Steven Pollock, remains available to address any
questions that a client or prospective client may have regarding the above.
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Other Assets. A client may:
• hold securities that were purchased at the request of the client or acquired prior
to the client’s engagement of Pollock Planning. Generally, with potential
exceptions, Pollock Planning does not/would not recommend nor follow such
securities, and absent mitigating tax consequences or client direction to the
contrary, would prefer to liquidate such securities. Please Note: If/when
liquidated, it should not be assumed that the replacement securities purchased by
Pollock Planning will outperform the liquidated positions. To the contrary,
different types of investments involve varying degrees of risk, and there can be
no assurance that future performance of any specific investment or investment
strategy (including the investments and/or investment strategies recommended or
undertaken by Pollock Planning) will be profitable or equal any specific
performance level(s)In addition, there may be other securities and/or accounts
owned by the client for which Pollock Planning does not maintain custodian
access and/or trading authority; and,
• hold other securities and/or own accounts for which Pollock Planning does not
maintain custodian access and/or trading authority.
When agreed
Corresponding Services/Fees:
to by Pollock Planning, Pollock
Planning shall: (1) remain available to discuss these securities/accounts on an ongoing
basis at the request of the client; (2) monitor these securities/accounts on a regular
basis, including, where applicable, rebalancing with client consent;(3) shall generally
consider these securities as part of the client’s overall asset allocation; and, (4) report on
such securities/accounts as part of regular reports that may be provided by Pollock
Planning; and, (5) include the market value of all such securities for purposes of
calculating advisory fee.
ESG: We don’t have or recommend a strategy:
Please Note: Socially Responsible (ESG) Investing Limitations. Socially Responsible
Investing involves the incorporation of Environmental, Social and Governance (“ESG”)
considerations into the investment due diligence process. ESG investing incorporates a set
of criteria/factors used in evaluating potential investments: Environmental (i.e., considers
how a company safeguards the environment); Social (i.e., the manner in which a company
manages relationships with its employees, customers, and the communities in which it
operates); and Governance (i.e., company management considerations). The number of
companies that meet an acceptable ESG mandate can be limited when compared to those
that do not, and could underperform broad market indices. Investors must accept these
limitations, including potential for underperformance. As with any type of investment
(including any investment and/or investment strategies recommended and/or undertaken
by Pollock Planning), there can be no assurance that investment in ESG securities or funds
will be profitable, or prove successful. Pollock Planning does not maintain or advocate an
ESG investment strategy, but will seek to employ ESG if directed by a client to do so. If
implemented, Pollock Planning shall rely upon the assessments undertaken by the
unaffiliated mutual fund, exchange traded fund or separate account manager to determine
that the fund’s or portfolio’s underlying company securities meet a socially responsible
mandate.
Portfolio Activity. Pollock Planning has a fiduciary duty to provide services consistent
with the client’s best interest. Pollock Planning will review client portfolios on an ongoing
basis to determine if any changes are necessary based upon various factors, including, but
not limited to, investment performance, market conditions, fund manager tenure, style drift,
account additions/withdrawals, and/or a change in the client’s investment objective. Based
upon these factors, there may be extended periods of time when Pollock Planning
determines that changes to a client’s portfolio are unnecessary. Clients remain subject to
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the fees described in Item 5 below during periods of portfolio inactivity. Of course, as
indicated below, there can be no assurance that investment decisions made by the Pollock
Planning will be profitable or equal any specific performance level(s).
ByAllAccounts. Pollock Planning may provide, via ByAllAccounts and for no additional
fee, periodic comprehensive reporting services, which can incorporate all of the client’s
investment assets including those investment assets that are not part of the assets managed
by Pollock Planning (the “Excluded Assets”). Unless agreed to otherwise, the client
and/or his/her/its other advisors that maintain trading authority, and not Pollock
Planning, shall be exclusively responsible for the investment performance of the
Excluded Assets. Unless also agreed to otherwise, Pollock Planning does not provide
investment management, monitoring or implementation services for the Excluded Assets.
If the Pollock Planning is asked to make a recommendation as to any Excluded Assets, the
client is under absolutely no obligation to accept the recommendation, and Pollock
Planning shall not be responsible for any implementation error (timing, trading, etc.)
relative to the Excluded Assets. The client can engage Pollock Planning to provide
investment management services for the Excluded Assets pursuant to the terms and
conditions of the Investment Advisory Agreement between Pollock Planning and the client.
Cybersecurity Risk. The information technology systems and networks that Pollock
Planning and its third-party service providers use to provide services to Pollock Planning’s
clients employ various controls that are designed to prevent cybersecurity incidents
stemming from intentional or unintentional actions that could cause significant
interruptions in Pollock Planning’s operations and/or result in the unauthorized acquisition
or use of clients’ confidential or non-public personal information. Clients and Pollock
Planning are nonetheless subject to the risk of cybersecurity incidents that could ultimately
cause them to incur financial losses and/or other adverse consequences. Although the
Pollock Planning has established processes to reduce the risk of cybersecurity incidents,
there is no guarantee that these efforts will always be successful, especially considering
that the Pollock Planning does not control the cybersecurity measures and policies
employed by third-party service providers, issuers of securities, broker-dealers, qualified
custodians, governmental and other regulatory authorities, exchanges and other financial
market operators and providers.
Privacy. Pollock Planning maintains policies and procedures designed to help protect the
confidentiality and security of client nonpublic personal information (“NPPI”). NPPI
includes, but is not limited to, social security numbers, credit or debit card numbers, state
identification card numbers, driver’s license number and account numbers. Pollock
Planning maintains administrative, technical, and physical safeguards designed to protect
such information from unauthorized access, use, loss, or destruction. These safeguards
include controls relating to data access, information security, and incident response, and
are reviewed to address changes in risk and business. Client information may be disclosed
in response to regulatory requests, legal obligations, or as otherwise permitted by law, and
any such disclosure is made in accordance with applicable privacy and confidentiality
requirements.
Pollock Planning may engage non-affiliated service providers in connection with providing
advisory services, and such providers may have access to client NPPI, as necessary, to
perform their functions. Pollock Planning confirms that service providers maintain
safeguards designed to protect client information from unauthorized access or use and
provide notice to Pollock Planning in the event of a cybersecurity incident involving client
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information maintained by the service provider. While Pollock Planning maintains policies
and procedures designed to protect client information, such measures cannot eliminate all
risk. Pollock Planning will notify clients in the event of a data breach involving their NPPI
as may be required by applicable state and federal laws.
Client Obligations. In performing its services, Pollock Planning will not be required to
verify any information received from the client or from the client’s other designated
professionals and is expressly authorized to rely on that information. Moreover, each client
is advised that it remains their responsibility to promptly notify Pollock Planning if there
is ever any change in their financial situation or investment objectives for the purpose of
reviewing/evaluating/revising our previous recommendations and/or services.
Disclosure Statement. A copy of Pollock Planning’s written Brochure as set forth on Part
2A of Form ADV and Form CRS (Client Relationship Summary) shall be provided to each
client prior to, or contemporaneously with, the execution of an agreement between the
client and Pollock Planning.
C. Pollock Planning provides investment advisory services specific to the needs of each client.
Prior to providing investment advisory services, an investment adviser representative will
ascertain each client’s investment objectives and select an appropriate investment strategy.
Pollock Planning then invests the client’s assets consistent with the client’s designated
investment strategy. The client may, at any time, impose reasonable restrictions, in writing,
on Pollock Planning’s services.
D. Pollock Planning does not participate in a wrap fee program.
E. As of December 31, 2025 Pollock, Planning had $164,514,113 in assets under management
on a discretionary basis.
Item 5
Fees and Compensation
A.
INVESTMENT MANAGEMENT SERVICES
Pollock Planning’s annual investment advisory fee can be either a fixed-fee, retainer basis
or as a percentage of assets under management.
If the client’s fee is based on a percentage of assets under management, the schedule is
typically as follows:
Annual Fee Schedule:
Market Value of Assets
Initial $499,999
Next $500,000 to $999,999
Over $1,000,000
% of Assets
1.00%
0.75%
0.50%
While we provide the fee schedule above as an estimate of our asset-based fees, we
generally price our advisory services based upon various objective and subjective factors.
Pollock Planning in its discretion, may charge a lesser investment advisory fee, charge a
8
flat fee, waive its fee entirely, or charge fee on a different interval, based upon certain
criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar
amount of assets to be managed, related accounts, account composition, complexity of the
engagement, anticipated services to be rendered, grandfathered fee schedules, employees
and family members, courtesy accounts, competition, negotiations with client, etc.). As a
result, similarly situated clients could pay diverse fees, and the services to be provided by
Pollock Planning to any particular client could be available from other advisers at lower
fees. All clients and prospective clients should be guided accordingly. ANY
QUESTIONS: Pollock Planning’s Chief Compliance Officer, Steven Pollock, remains
available to address any questions regarding advisory fees.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
To the extent specifically requested by a client, Pollock Planning may determine to provide
financial planning and/or consulting services (including investment and non-investment
related matters, including estate planning, insurance planning, etc.) on a stand-alone fee
basis. Pollock Planning’s planning and consulting services are typically offered on a flat
fee basis generally ranging between $4,000 and $20,000.
B. Pollock Planning’s advisory fees are deducted from the client’s custodial account. Both
Pollock Planning's Investment Advisory Agreement and the custodial/clearing agreement
authorize the custodian to debit the account for the amount of Pollock Planning's
investment advisory fee and to directly remit that management fee to Pollock Planning in
compliance with regulatory procedures. In the limited event that Pollock Planning bills the
client directly, payment is due upon receipt of Pollock Planning’s invoice.
C. As discussed below, unless the client directs otherwise or an individual client’s
circumstances require, Pollock Planning generally recommends that Charles Schwab &
Co. (“Schwab”) serve as the broker-dealer/custodian for client accounts. Schwab charges
brokerage commissions, transaction, and/or other type fees for effecting certain types of
securities transactions (i.e., including transaction fees for certain mutual funds, and mark-
ups and mark-downs charged for fixed income transactions, etc.). The types of securities
for which transaction fees, commissions, and/or other type fees (as well as the amount of
those fees) shall differ depending upon the broker-dealer/custodian (while certain
custodians do not currently charge fees on individual equity transactions [including ETFs],
others do). In addition to Pollock Planning’s investment management fee, brokerage
commissions and transaction fees, clients will also incur, relative to all mutual fund and
exchange traded fund purchases, charges imposed at the fund level (e.g. management fees
and other fund expenses).
D. Pollock Planning's annual investment advisory fee shall be prorated and paid quarterly, in
advance, based upon the market value of the assets on the last business day of the previous
quarter. Pollock Planning’s policy is to treat intra-quarter account additions and
withdrawals equally. Pollock Planning does not charge for intra-quarter additions or
withdrawals unless indicated to the contrary on Pollock Planning’s Investment Advisory
Agreement executed by the client. Pollock Planning generally requires a $3,000 minimum
annual fee for investment advisory services. Pollock Planning, in its sole discretion, may
reduce or waive its minimum annual fee requirement. In the event that the client is subject
to an annual minimum fee, the client could pay a higher percentage fee than referenced
above.
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The Investment Advisory Agreement between Pollock Planning and the client will continue
in effect until terminated by either party by written notice in accordance with the terms of
the Investment Advisory Agreement. Upon termination, Pollock Planning shall refund the
pro-rated portion of the advanced advisory fee paid based upon the number of days
remaining in the billing quarter.
E. Neither Pollock Planning, nor its representatives, accepts compensation from the sale of
securities or other investment products.
Item 6
Performance-Based Fees and Side-by-Side Management
Neither Pollock Planning nor any supervised person of Pollock Planning is a party to any
performance or incentive-related compensation arrangements with its clients.
Item 7
Types of Clients
Pollock Planning offers to its clients (individuals, trusts, and estates, etc.) investment
advisory services on a discretionary basis.
Clients and prospective clients should review Item 5 for information about the firm’s
minimum annual fee requirements. Pollock Planning in its discretion, may charge a lesser
investment advisory fee, charge a flat fee, waive its fee entirely, or charge fee on a different
interval, based upon certain criteria (i.e. anticipated future earning capacity, anticipated
future additional assets, dollar amount of assets to be managed, related accounts, account
composition, complexity of the engagement, anticipated services to be rendered,
grandfathered fee schedules, employees and family members, courtesy accounts,
competition, negotiations with client, etc.). Please Note: As result of the above, similarly
situated clients could pay different fees. In addition, similar advisory services may be
available from other investment advisers for similar or lower fees. ANY QUESTIONS:
Pollock Planning’s Chief Compliance Officer, Steven Pollock, remains available to address
any questions that a client or prospective client may have regarding advisory fees.
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
A. Pollock Planning may utilize the following methods of security analysis:
• Fundamental - (analysis performed on historical and present data, with the goal of
making financial forecasts)
• Technical – (analysis performed on historical and present data, focusing on price
and trade volume, to forecast the direction of prices)
• Cyclical – (analysis performed on historical relationships between price and
market trends, to forecast the direction of prices)
Pollock Planning may utilize the following investment strategies when implementing
investment advice given to clients:
• Long Term Purchases (securities held at least a year)
• Short Term Purchases (securities sold within a year)
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Different types of investments involve varying degrees of risk, and it should not be
assumed that future performance of any specific investment or investment strategy,
including the investments and strategies recommended or undertaken by Pollock Planning
will be profitable or equal any specific performance levels.
B. Pollock Planning’s methods of analysis and investment strategies do not present any
significant or unusual risks.
However, every method of analysis has its own inherent risks. To perform an accurate
market analysis Pollock Planning must have access to current/new market information.
Pollock Planning has no control over the dissemination rate of market information;
therefore, unbeknownst to Pollock Planning, certain analyses may be compiled with
outdated market information, severely limiting the value of Pollock Planning’s analysis.
Furthermore, an accurate market analysis can only produce a forecast of the direction of
market values. There can be no assurances that a forecasted change in market value will
materialize into actionable and/or profitable investment opportunities.
Pollock Planning’s primary investment strategies - Long Term Purchases and Short Term
Purchases - are fundamental investment strategies. However, every investment strategy has
its own inherent risks and limitations. For example, longer term investment strategies
require a longer investment time period to allow for the strategy to potentially develop.
Shorter term investment strategies require a shorter investment time period to potentially
develop but, as a result of more frequent trading, may incur higher transactional costs when
compared to a longer term investment strategy.
Pollock Planning’s strategies involve it reviewing client portfolios on a periodic basis to
determine if any changes are necessary. Pollock Planning considers various factors, which
may include, investment performance, portfolio drift, market changes, tax consequences,
and changes in a client’s investment objective. Based on these reviews, there may be
extended periods of time when Pollock Planning determines that changes to a client’s
portfolio are not necessary. However, Pollock Planning will continue to earn its fees
outlined in Item 5 regardless of the level of trading in a client’s account. Clients are
responsible for determining whether a relationship with Pollock Planning remains
appropriate for them in light of their individual situation.
Pollock Planning’s investment strategies may involve above-average portfolio turnover
and accounts subject to income taxation could be subject to tax consequences as a result of
Pollock Planning’s investment strategies. Clients may impose reasonable restrictions on
Pollock Planning, in writing, should they wish to avoid or reduce their tax liabilities.
C. Currently, Pollock Planning primarily allocates client investment assets among various
individual equity (stocks) and fixed income securities, mutual funds and/or exchange
traded funds on a discretionary basis in accordance with the client’s designated investment
objectives.
The following provides a short description of some of the underlying risks associated with
investing in these types of securities:
Mutual Fund Risk. Mutual funds are operated by investment companies that raise money
from shareholders and invests it in stocks, bonds, and/or other types of securities. Each
fund will have a manager that trades the fund’s investments in accordance with the fund’s
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investment objective. Mutual funds charge a separate management fee for their services,
so the returns on mutual funds are reduced by the costs to manage the funds. While mutual
funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market. Mutual funds that are sold through brokers
are called load funds, and those sold to investors directly from the fund companies are
called no-load funds. Mutual funds come in many varieties. Some invest aggressively for
capital appreciation, while others are conservative and are designed to generate income for
shareholders. In addition, the client’s overall portfolio may be affected by losses of an
underlying fund and the level of risk arising from the investment practices of an underlying
fund (such as the use of derivatives).
Exchange Traded Fund Risk. ETFs are marketable securities that are designed to track,
before fees and expenses, the performance or returns of a relevant index, commodity, bonds
or basket of assets, like an index fund. Unlike mutual funds, ETFs trade like common stock
on a stock exchange. ETFs experience price changes throughout the day as they are bought
and sold. In addition to the general risks of investing, there are specific risks to consider
with respect to an investment in ETFs, including, but not limited to: (i) the price of an ETF
may or may not fluctuate with the price of the underlying securities that make up the fund;
(ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii)
trading of an ETF’s shares may be halted if the listing exchange’s officials deem such
action appropriate, the shares are de-listed from the exchange, or the activation of market-
wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading
generally.
Item 9
Disciplinary Information
Pollock Planning has not been the subject of any disciplinary actions.
Item 10
Other Financial Industry Activities and Affiliations
A. Neither Pollock Planning, nor its representatives, are registered or have an application
pending to register, as a broker-dealer or a registered representative of a broker-dealer.
B. Neither Pollock Planning, nor its representatives, are registered or have an application
pending to register, as a futures commission merchant, commodity pool operator, a
commodity trading advisor, or a representative of the foregoing.
C. As a fiduciary, Pollock Planning has certain legal obligations, including the obligation to
act in a client’s best interest. Pollock Planning maintains a Business Continuity and
Succession Plan and seeks to avoid a disruption of service to clients in the event of an
unforeseen loss of key personnel, due to disability or death. To that end, Pollock Planning
entered into a succession agreement with JFS Wealth Advisors, LLC (CRD: 145051 / SEC:
801-68333) in 2017 which is currently in effect. Pollock Planning can provide additional
information to any current or prospective client upon request by contacting Steven Pollock,
President at 856-266-2276 or spollock15@gmail.com.
D. Pollock Planning does not receive, directly or indirectly, compensation from investment
advisors that it recommends or selects for its clients.
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Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. Pollock Planning maintains an investment policy relative to personal securities
transactions. This investment policy is part of Pollock Planning’s overall Code of Ethics,
which serves to establish a standard of business conduct for all of Pollock Planning’s
representatives that is based upon fundamental principles of openness, integrity, honesty
and trust, a copy of which is available upon request.
Pollock Planning also maintains and enforces written policies reasonably designed to
prevent the misuse of material non-public information by Pollock Planning or any person
associated with Pollock Planning.
B. Neither Pollock Planning nor any related person of Pollock Planning recommends, buys,
or sells for client accounts, securities in which Pollock Planning or any related person of
Pollock Planning has a material financial interest.
C. Pollock Planning and/or representatives of Pollock Planning may buy or sell securities that
are also recommended to clients. This practice may create a situation where Pollock
Planning and/or representatives of the firm are in a position to materially benefit from the
sale or purchase of those securities. Therefore, this situation creates a potential conflict of
interest. Practices such as “scalping” (i.e., a practice whereby the owner of shares of a
security recommends that security for investment and then immediately sells it at a profit
upon the rise in the market price which follows the recommendation) could take place if
Pollock Planning did not have adequate policies in place to detect such activities. In
addition, this requirement can help detect insider trading, “front-running” (i.e., personal
trades executed prior to those of Pollock Planning’s clients) and other potentially abusive
practices.
Pollock Planning has a personal securities transaction policy in place to monitor the
personal securities transactions and securities holdings of each of Pollock Planning’s
“Access Persons”. Pollock Planning’s securities transaction policy requires that an Access
Person of Pollock Planning must provide the Chief Compliance Officer or his/her designee
with a written report of their current securities holdings within ten (10) days after becoming
an Access Person. Additionally, each Access Person must provide the Chief Compliance
Officer or his/her designee with a written report of the Access Person’s current securities
holdings at least once each twelve (12) month period thereafter on a date Pollock Planning
selects; provided, however that at any time that Pollock Planning has only one Access
Person, he or she shall not be required to submit any securities report described above.
D. Pollock Planning and/or representatives of Pollock Planning may buy or sell securities, at
or around the same time as those securities are recommended to clients. This practice
creates a situation where Pollock Planning and/or representatives of the firm are in a
position to materially benefit from the sale or purchase of those securities. Therefore, this
situation creates a potential conflict of interest. As indicated above in Item 11.C, Pollock
Planning has a personal securities transaction policy in place to monitor the personal
securities transaction and securities holdings of each of Pollock Planning’s Access Persons.
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Item 12
Brokerage Practices
A. In the event that the client requests that Pollock Planning recommend a broker-
dealer/custodian for execution and/or custodial services (exclusive of those clients that may
direct Pollock Planning to use a specific broker-dealer/custodian), Pollock Planning
generally recommends that investment management accounts be maintained at Schwab.
Prior to engaging Pollock Planning to provide investment management services, the client
will be required to enter into a formal Investment Advisory Agreement with Pollock
Planning setting forth the terms and conditions under which Pollock Planning shall manage
the client's assets, and a separate custodial/clearing agreement with each designated broker-
dealer/custodian.
Factors that Pollock Planning considers in recommending Schwab (or any other broker-
dealer/custodian to clients) include historical relationship with Pollock Planning, financial
strength, reputation, execution capabilities, pricing, research, and service. Broker-dealers
such as Schwab can charge transaction fees for effecting certain securities transactions (See
Item 4 above). To the extent that a transaction fee will be payable by the client to Schwab,
the transaction fee shall be in addition to Pollock Planning’s investment advisory fee
referenced in Item 5 above.
transaction
rates, and
To the extent that a transaction fee is payable, Pollock Planning shall have a duty to obtain
best execution for such transaction. However, that does not mean that the client will not
pay a transaction fee that is higher than another qualified broker-dealer might charge to
effect the same transaction where Pollock Planning determines, in good faith, that the
transaction fee is reasonable. In seeking best execution, the determinative factor is not the
lowest possible cost, but whether the transaction represents the best qualitative execution,
taking into consideration the full range of a broker-dealer’s services, including the value of
research provided, execution capability,
responsiveness.
Accordingly, although Pollock Planning will seek competitive rates, it may not necessarily
obtain the lowest possible rates for client account transactions.
1. Research and Additional Benefits.
Although not a material consideration when determining whether to recommend
that a client utilize the services of a particular broker-dealer/custodian, Pollock
Planning can receive from Schwab (or another broker-dealer/custodian,
investment manager, platform sponsor, mutual fund sponsor, or vendor) without
cost (and/or at a discount) support services and/or products, certain of which assist
Pollock Planning to better monitor and service client accounts maintained at such
institutions. Included within the support services that can be obtained by Pollock
Planning can be 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-including client
events, computer hardware and/or software and/or other products used by Pollock
Planning in furtherance of its investment advisory business operations.
Pollock Planning’s clients do not pay more for investment transactions effected or
assets maintained at Schwab or other broker-dealers and custodians because of
these arrangements. There is no corresponding commitment made by Pollock
Planning to Schwab, or any other any entity, to invest any specific amount or
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percentage of client assets in any specific mutual funds, securities or other
investment products as result of the above arrangement.
Pollock Planning’s Chief Compliance Officer, Steven Pollock, remains available
to address any questions that a client or prospective client may have regarding the
above arrangement and any the conflicts of interest this arrangement creates.
2. Pollock Planning does not receive referrals from broker-dealers.
3. Pollock Planning recommends that its clients utilize the brokerage and custodial
services provided by Schwab. The Firm generally does not accept directed
brokerage arrangements (but could make exceptions). A directed brokerage
arrangement arises when a client requires that account transactions be effected
through a specific broker-dealer/custodian, other than one generally recommended
by Pollock Planning (i.e., Schwab). In such client directed arrangements, the client
will negotiate terms and arrangements for their account with that broker-dealer,
and Pollock Planning will not seek better execution services or prices from other
broker-dealers or be able to "batch" the client's transactions for execution through
other broker-dealers with orders for other accounts managed by Pollock Planning.
As a result, client may pay higher commissions or other transaction costs or greater
spreads, or receive less favorable net prices, on transactions for the account than
would otherwise be the case.
the client's accounts
through a specific broker-dealer,
In the event that the client directs Pollock Planning to effect securities transactions
the client
for
correspondingly acknowledges that such direction may cause the accounts to incur
higher commissions or transaction costs than the accounts would otherwise incur
had the client determined to effect account transactions through alternative
clearing arrangements that may be available through Pollock Planning. Higher
transaction costs adversely impact account performance. Transactions for directed
accounts will generally be executed following the execution of portfolio
transactions for non-directed accounts.
B. Transactions for each client account generally will be effected independently unless
Pollock Planning decides to purchase or sell the same securities for several clients at
approximately the same time. Pollock Planning may (but is not obligated to) combine or
“batch” such orders for individual equity transactions (including ETFs) with the intention
to obtain better price execution, to negotiate more favorable commission rates, or to
allocate more equitably among Pollock Planning’s clients differences in prices and
commissions or other transaction costs that might have occurred had such orders been
placed independently. Under this procedure, transactions will be averaged as to price and
will be allocated among clients in proportion to the purchase and sale orders placed for
each client account on any given day. In the event that Pollock Planning becomes aware
that a firm employee seeks to trade in the same security on the same day, the employee
transaction will either be included in the “batch” transaction or transacted after all
discretionary client transactions have been completed. Pollock Planning will not receive
any additional compensation as a result of its order aggregation.
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Item 13
Review of Accounts
A. For those clients to whom Pollock Planning provides investment supervisory services,
account reviews are conducted on a periodic basis by Pollock Planning's Principal. All
investment supervisory clients are advised that it remains their responsibility to advise
Pollock Planning of any changes in their investment objectives and financial situation. All
clients (in person or via telephone) are encouraged to review financial planning issues (to
the extent applicable), investment objectives and account performance with Pollock
Planning on an annual basis.
B. Pollock Planning may conduct account reviews on an other than periodic basis upon the
occurrence of a triggering event, such as a change in client investment objectives and/or
financial situation, market corrections and client request.
C. Clients are provided, at least quarterly, with written transaction confirmation notices and
regular written summary account statements directly from the broker-dealer/custodian
and/or program sponsor for the client accounts. Pollock Planning may also provide a
written periodic report summarizing account activity and performance.
Item 14
Client Referrals and Other Compensation
A. As referenced in Item 12.A.1 above, Pollock Planning may receive an indirect economic
benefit from Schwab. Pollock Planning may receive free or discounted support services or
products from Schwab. Pollock Planning’s clients do not pay more for investment
transactions effected and/or assets maintained at Schwab (or any other institution) as result
of this arrangement. There is no corresponding commitment made by Pollock Planning to
Schwab, or to any other entity, to invest any specific amount or percentage of client assets
in any specific mutual funds, securities or other investment products as the result of the
above arrangement
B. Pollock Planning does not have any new referral relationships where it compensates others
for client referrals.
Item 15
Custody
Pollock Planning shall have the ability to have its advisory fee for each client debited by
the custodian on a quarterly basis. Clients are provided, at least quarterly, with written
transaction confirmation notices and regular written summary account statements directly
from the broker-dealer/custodian and/or program sponsor for the client accounts. Pollock
Planning may also provide a written periodic report summarizing account activity and
performance.
To the extent that Pollock Planning provides clients with periodic account statements or
reports, the client is urged to compare any statement or report provided by Pollock Planning
with the account statements received from the account custodian. The account custodian
does not verify the accuracy of Pollock Planning’s advisory fee calculation.
In addition, certain clients have established asset transfer authorizations that permit the
qualified custodian to rely upon instructions from Pollock Planning to transfer client funds
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or securities to third parties. These arrangements are disclosed at Item 9 of Part 1 of Form
ADV. However, in accordance with the guidance provided in the SEC’s February 21, 2017
Investment Adviser Association No-Action Letter, the affected accounts are not subject to
an annual surprise CPA examination.
Item 16
Investment Discretion
The client can engage Pollock Planning to provide investment advisory services on a
discretionary basis. Prior to Pollock Planning assuming discretionary authority over a
client’s account, client shall be required to execute an Investment Advisory Agreement
with Pollock Planning setting forth the terms and conditions under which Pollock Planning
shall manage the client's assets, and a separate custodial/clearing agreement with each
designated broker-dealer/custodian..
Clients who engage Pollock Planning on a discretionary basis may, at any time, impose
restrictions, in writing, on Pollock Planning’s discretionary authority (e.g., limit the
types/amounts of particular securities purchased for their account, exclude the ability to
purchase securities with an inverse relationship to the market).
Item 17
Voting Client Securities
A. Pollock Planning does not vote client proxies. Clients maintain exclusive responsibility
for: (1) directing the manner in which proxies solicited by issuers of securities beneficially
owned by the client shall be voted, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the
client’s investment assets.
B. Clients will receive their proxies or other solicitations directly from their custodian. Clients
may contact Pollock Planning to discuss any questions they may have with a particular
solicitation.
Item 18
Financial Information
A. Pollock Planning does not solicit fees of more than $1,200 per client, six months or more
in advance.
B. Pollock Planning is unaware of any financial condition that is reasonably likely to impair
its ability to meet its contractual commitments relating to its discretionary authority over
certain client accounts.
C. Pollock Planning has not been the subject of a bankruptcy petition.
ANY QUESTIONS: Pollock Planning’s Chief Compliance Officer, Steven Pollock, remains available to
address any questions that a client or prospective client may have regarding the above disclosures and
arrangements.
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