Overview
Assets Under Management: $197 million
Headquarters: VICTOR, NY
High-Net-Worth Clients: 82
Average Client Assets: $2 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (PAG DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENT)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.25% |
| $1,000,001 | $3,000,000 | 1.00% |
| $3,000,001 | and above | 0.75% |
Minimum Annual Fee: $1,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $47,500 | 0.95% |
| $10 million | $85,000 | 0.85% |
| $50 million | $385,000 | 0.77% |
| $100 million | $760,000 | 0.76% |
Clients
Number of High-Net-Worth Clients: 82
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 74.71
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 859
Discretionary Accounts: 859
Regulatory Filings
CRD Number: 310720
Last Filing Date: 2024-09-26 00:00:00
Website: https://prosperityadv.com
Form ADV Documents
Primary Brochure: PAG DISCLOSURE BROCHURE AND BROCHURE SUPPLEMENT (2025-07-14)
View Document Text
Prosperity Advisory Group LLC
Form ADV Part 2A – Disclosure Brochure
Effective: July 14, 2025
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Prosperity Advisory Group LLC (“PAG” or the “Advisor”). If you have any questions about the content of
this Disclosure Brochure, please contact the Advisor at (585) 381-5900.
PAG is a Registered Investment Advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure
Brochure provides information about PAG to assist you in determining whether to retain the Advisor.
Additional information about PAG and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310720.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of PAG.
PAG believes that communication and transparency are the foundation of its relationship with Clients and will
continually strive to provide you with complete and accurate information at all times. PAG encourages all current
and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment filing on
3/5/2024:
• The Advisor is now licensed as an insurance agency. Please see Item 5 and Item 10 for additional
information.
• The Advisor has updated their Advisory Services to offer Cash Flow Consulting. Please see Item 4 and
Item 5 for additional information.
• Advisory Persons are no longer licensed as registered representatives with a Broker-Dealer.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure
Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310720. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (585) 381-5900.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents .................................................................................................................................... 3
Item 4 – Advisory Services ................................................................................................................................... 4
A. Firm Information ............................................................................................................................................................. 4
B. Advisory Services Offered .............................................................................................................................................. 4
C. Client Account Management .......................................................................................................................................... 6
D. Wrap Fee Programs ....................................................................................................................................................... 6
E. Assets Under Management ............................................................................................................................................ 6
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services ............................................................................................................................................. 6
B. Fee Billing ....................................................................................................................................................................... 7
C. Other Fees and Expenses ............................................................................................................................................. 8
D. Advance Payment of Fees and Termination .................................................................................................................. 8
E. Compensation for Sales of Securities ............................................................................................................................ 9
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9
Item 7 – Types of Clients ....................................................................................................................................... 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 9
A. Methods of Analysis ....................................................................................................................................................... 9
B. 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 .............. 12
A. Code of Ethics .............................................................................................................................................................. 12
B. Personal Trading with Material Interest ........................................................................................................................ 12
C. Personal Trading in Same Securities as Clients .......................................................................................................... 12
D. Personal Trading at Same Time as Client ................................................................................................................... 13
Item 12 – Brokerage Practices ............................................................................................................................ 13
A. Recommendation of Custodian[s] ................................................................................................................................ 13
B. Aggregating and Allocating Trades .............................................................................................................................. 13
Item 13 – Review of Accounts ............................................................................................................................ 14
A. Frequency of Reviews .................................................................................................................................................. 14
B. Causes for Reviews ..................................................................................................................................................... 14
C. Review Reports ............................................................................................................................................................ 14
Item 14 – Client Referrals and Other Compensation ........................................................................................ 14
A. Compensation Received by PAG ................................................................................................................................. 14
B. Compensation for Client Referrals ............................................................................................................................... 14
Item 15 – Custody ................................................................................................................................................ 14
Item 16 – Investment Discretion ......................................................................................................................... 15
Item 17 – Voting Client Securities ...................................................................................................................... 15
Item 18 – Financial Information .......................................................................................................................... 15
Appendix 1 – Wrap Fee Program Brochure ...................................................................................................... 16
Form ADV Part 2B – Brochure Supplement ...................................................................................................... 23
Privacy Policy ...................................................................................................................................................... 30
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 3
Item 4 – Advisory Services
A. Firm Information
Prosperity Advisory Group LLC (“PAG” or the “Advisor”) is a Registered Investment Advisor with the U.S. Securities
and Exchange Commission (“SEC”). The Advisor was organized as a Limited Liability Company (“LLC”) under the
laws of the State of New York in August 2020 and became a Registered Investment Advisor in October 2020. PAG
is owned and operated by John Harnish (Principal and Chief Compliance Officer). This Disclosure Brochure
provides information regarding the qualifications, business practices, and the advisory services provided by PAG.
B. Advisory Services Offered
PAG offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and
retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. PAG's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
PAG provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related advisory
services. PAG works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. PAG will then construct an investment
portfolio, consisting of diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s
investment goals. The Advisor may also utilize individual stocks, individual bonds and/or fee-based variable
annuities to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s
legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified
between the Advisor and the Client.
PAG’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. PAG will
construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types
of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
PAG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. PAG may recommend, on occasion, redistributing investment allocations to diversify the portfolio. PAG
may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend
employing cash positions as a possible hedge against market movement. PAG may recommend selling positions
for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure
to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change
in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the
Client’s risk tolerance.
At no time will PAG accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 4
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
Participant Account Management – As part of the Advisor’s Investment Management Services, when appropriate,
the Advisor will use a third party platform to facilitate management of held away assets such as defined contribution
plan participant accounts, with discretion. The platform allows the Advisor to avoid being considered to have
custody of Client funds since the Advisor does not have direct access to Client log-in credentials to affect trades.
The Advisor is not affiliated with the platform in any way and does not receive compensation from them for using
their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once
Client account(s) is connected to the platform, the Advisor will review the current account allocations. When
deemed necessary, the Advisor will rebalance the account considering client investment goals and risk tolerance,
and changes in allocations will take into account current economic and market trends. The goal is to improve
account performance over time, minimize loss during difficult markets, and manage internal fees that harm account
performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed
necessary.
Financial Planning Services
PAG will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written
financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on
their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or
rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or
consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
PAG may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation.
For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial
situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide
a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming
all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Cash Flow Consulting – The Advisor also offers financial planning services specific to cash flow consulting.
Retirement Plan Advisory Services
PAG provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company
(the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in
meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs
of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
•
Investment Policy Statement (“IPS”) Design and Monitoring
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 5
Investment Oversight Services (ERISA 3(21))
•
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
These services are provided by PAG serving in the capacity as a fiduciary under the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is
provided with a written description of PAG’s fiduciary status, the specific services to be rendered and all direct and
indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging PAG to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – PAG, in connection with the Client, will develop a strategy that seeks
to achieve the Client’s goals and objectives.
• Asset Allocation – PAG will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – PAG will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
•
Investment Management and Supervision – PAG will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
PAG includes securities transaction fees and custody fees together with its investment advisory fee. Including these
fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor sponsors the PAG Wrap Fee
Program solely as a supplemental disclosure regarding the combination of fees. The Advisor customizes its
investment management services for its Clients and does not provide different services for Clients in the Wrap Fee
Program. Depending on the level of trading or the security selection required for the Client’s account[s], the costs
for securities transaction fees borne by the Advisor may vary. Held-away assets are excluded from the PAG Wrap
Fee Program. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this
Disclosure Brochure.
E. Assets Under Management
As of December 31, 2024, PAG manages $207,423,491 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more
written agreements with the Advisor.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid quarterly, advance of each calendar quarter, pursuant to the terms of the
investment advisory agreement. Investment advisory fees are based on the market value of assets under
management at the end of the prior calendar quarter. Investment advisory fees are based on the following schedule:
Annual Rate (%)
Assets Under Management ($)
Up to $1,000,000
$1,000,001 to $3,000,000
1.25%
1.00%
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 6
0.75%
Over $3,000,000
*The Advisor imposes a minimum fee of $1,000 for Investment Management Services
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
PAG will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s
valuations to ensure accurate billing.
Financial Planning Services
Initial Financial Plan Development - The Initial financial plan development is a one-time engagement offered for a
fixed fee ranging up to $3,000. Fees may be negotiable based on the on the nature and complexity of the services to
be provided and the overall relationship with the Advisor.
Ongoing Annual Review – Ongoing financial planning reviews are charged a fixed fee of $500 per year. Fees may be
negotiable based on the on the nature and complexity of the services to be provided and the overall relationship with
the Advisor.
Cash Flow Consulting
PAG offers cash flow consulting services on an hourly basis. Hourly fees range from $100 to $300 per hour. Fees may
be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the
Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these
services.
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 0.50% and are billed
quarterly in advance of each calendar quarter pursuant to the terms of the retirement plan advisory agreement.
Retirement plan advisory fees are based on the market value of assets under management at the end of the prior
calendar quarter. Fees may be negotiable depending on the size and complexity of the Plan.
B. Fee Billing
Investment Management Services
Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the
Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from
the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the
quarterly rate (annual rate divided by 4) to the total assets under management with PAG at the end of the prior
quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the
investment advisory fee. Clients are urged to also review brokerage statements from the Custodian, as the Custodian
does not perform verification of fees. Clients provide written authorization permitting advisory fees to be deducted by
PAG to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and
separate account forms provided by the Custodian.
Financial Planning Services
Financial planning fees for the initial financial plan development may be invoiced up to fifty percent (50%) of the
expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion
of the agreed upon deliverable[s]. Financial planning fees for the ongoing annual review are billed quarterly in
advance of each calendar quarter.
Cash Flow Consulting
Cash flow consulting fees for the initial financial plan development may be invoiced up to fifty percent (50%) of the
expected total fee upon execution of the cash flow consulting agreement. The balance shall be invoiced upon
completion of the agreed upon deliverable[s].
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 7
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the
Plan, depending on the terms of the retirement plan advisory agreement.
C. Other Fees and Expenses
PAG includes securities transaction fees as part of its overall investment advisory fee through the PAG Wrap Fee
Program. Securities transaction fees for Client-directed trades may be charged back to the Client. Please see Item
4.D. above as well as Appendix 1 – Wrap Fee Program Brochure.
Clients may incur certain fees or charges imposed by third parties, other than PAG, in connection with investments
made on behalf of the Client’s account[s]. The Advisor has negotiated a fixed rate with its recommended Custodian
for securities transaction fees, which is based on assets under management in the Client’s account[s]. Certain
accounts may be excluded from this fixed rate arrangement. The Advisor's recommended Custodian may not
charge securities transaction fees for ETF and equity trades in certain Client account[s], provided that the account
meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian often charges
for mutual funds and other types of investments. The Advisor, in its fiduciary duty, will select the investments most
appropriate for the Client’s investment portfolio[s], regardless of securities transaction costs.
In addition, all fees paid to PAG for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in
each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds,
other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible
distribution fee. A Client may be able to invest in these products directly, without the services of PAG, but would not
receive the services provided by PAG which are designed, among other things, to assist the Client in determining
which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the
Client should review both the fees charged by the fund[s] and the fees charged by PAG to fully understand the total
fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Investment Management Services
PAG may be compensated for its investment management services in advance of the quarter in which services are
rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written
notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business
days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges
for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the
Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective
date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-
transferable without the Client’s prior consent.
Financial Planning Services
PAG requires an advance deposit as described above. Either party may terminate the financial planning agreement,
at any time, by providing advance written notice to the other party. The Client may also terminate the financial
planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the
five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and
such fees will be due and payable by the Client. Upon termination, the Client shall be billed for the percentage of the
engagement scope completed by the Advisor and the Advisor will refund any unearned, prepaid planning fees from
the effective date of termination. The Client’s financial planning agreement with the Advisor is non-transferable without
the Client’s prior consent.
Cash Flow Consulting
Either party may terminate the Cash Flow Consulting agreement, at any time, by providing advance written notice to
the other party. The Client may also terminate the Cash Flow Consulting agreement within five (5) business days of
signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona
fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 8
termination, the Client shall be billed for any unpaid hours completed by the Advisor. The Client’s Cash Flow
Consulting agreement with the Advisor is non-transferable without the Client’s prior consent.
Retirement Plan Advisory Services
PAG is compensated for its retirement plan services at the beginning of the quarter before services are rendered.
Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice
to the other party. The Client shall be responsible for retirement plan advisory fees up to and including the effective
date of termination. Upon termination, the Advisor will refund any unearned, prepaid retirement plan advisory fees
from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with
the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Certain individuals are licensed as independent insurance professionals through PAG. As an independent
insurance professional, individuals will earn commission-based compensation for selling insurance products,
including insurance products sold to Clients. Insurance commissions earned by individuals are separate and in
addition to advisory fees charged by PAG. This practice presents a conflict of interest as an individual, who is also
an insurance agent, has an incentive to recommend insurance products to Clients. However, Clients are under no
obligation, contractually or otherwise, to purchase insurance products through any individual affiliated with the
Advisor. Please see Item 10 below.
Item 6 – Performance-Based Fees and Side-By-Side Management
PAG does not charge performance-based fees for its investment advisory services. The fees charged by PAG are
as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any
Client. PAG does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund
or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
PAG offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and
retirement plans. PAG generally does not impose a minimum relationship size. However, the Advisor imposes a
minimum annual fee of $1,000. This fee may be waived at the sole discretion of the Advisor.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
PAG’s overall investment strategy, based on the demographics of its Client base, is to manage accounts to protect
and grow the Client’s assets and provide income during retirement. To accomplish this, PAG primarily employs a
tactical asset allocation investment strategy to manage client portfolios. PAG meets with Clients to get a clear
understanding of their investment goals and the amount of risk they are willing to take to attain these goals. Based
on this information and the current market conditions, the Advisor develops a target asset allocation. In developing
the targets, the Advisor will set a higher (overweight) allocation target to sectors that are anticipated to outperform
others and a lower (underweight) allocation target to sectors that are anticipated to under-perform. As market
conditions change, the asset allocation targets will be reviewed and updated as appropriate. In addition, asset
allocation targets are updated if there is a change in the Client’s investment objective.
PAG also employs a fundamental analysis method in developing investment strategies for its Clients. Fundamental
analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally
of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets
are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value
discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does
not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the
fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 9
economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the
Advisor’s review process are included below in Item 13 – Review of Accounts.
As noted above, PAG generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. PAG will typically hold all or a portion of a security for more than a year, but may hold for shorter
periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, PAG may also buy
and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals
of the security, sector or asset class.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account[s]. The
Advisor uses screening tools and research reports, as well as conducts due diligence with analysts, portfolio
managers and strategists with money management firms. This information is used to determine which investments
are best suited for the Client. The Advisor may utilize one or more the following general securities publications and
research materials to assist with its process:
Investment News Daily
Investment Advisor
Journal of Financial Planners
• Morningstar Principia Mutual Fund Advanced
• Value Line Investment Survey
•
• Barron’s
•
•
• Financial Planning
• Financial Advisor
• Profiles Plus
• Continuing Education Programs
•
Internet sources
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. PAG will assist Clients in determining an appropriate strategy
based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will
meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction
process. Following are some of the risks associated with the Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
Prosperity Advisory Group LLC
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Phone: (585) 381-5900 * Fax: (585) 381-0478
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ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk
based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-
ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may
dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased
or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon
rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than
was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that
exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk
associated with purchasing a debt instrument which includes the possibility of the company defaulting on its
repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the
company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity
Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same
price as a mutual fund purchased later that same day.
Tactical Asset Allocation
There is risk associated with any investment strategy, including tactical asset allocation. The Client must be aware
of the following risks associated with a tactical asset allocation strategy:
• There is no guarantee that the use of this strategy will provide a higher performance than the use of other
investment strategies.
• This strategy relies on an accurate reading of market conditions and the future direction of the market.
There is no guarantee that the anticipated asset allocation targets will outperform other sectors.
• Clients may be exposed to tax consequences due to capital gains/losses from the sale of securities to
rebalance accounts. Some of the capital gains could be short-term, which are taxed at a higher rate.
• Fund companies may place restrictions on an account for violating a Fund’s short-term trading policy. While
this is possible, PAG seeks to avoid processing trades in Client’s accounts that would subject the Client to
short-term trading fees or account restrictions.
Variable Annuity Risk
A variable annuity is a form of insurance where the seller or issuer (typically an insurance company) makes a series
of future payments to a buyer (annuitant) in exchange for the immediate payment of a lump sum (single-payment
annuity) or a series of regular payments (regular-payment annuity). The payment stream from the issuer to the
annuitant has an unknown duration based principally upon the date of death of the annuitant. At this point, the
contract will terminate, and the remainder of the funds accumulated forfeited unless there are other annuitants or
beneficiaries in the contract. Annuities can be purchased to provide an income during retirement. Unlike fixed
annuities that make payments in fixed amounts or in amounts that increase by a fixed percentage, variable
annuities, pay amounts that vary according to the performance of a specified set of investments, typically bond and
equity mutual funds. Variable annuities may impose a variety of fees and expenses such as mortality and expense
risk charges; administrative fees; underlying fund expenses; and charges for special features, all of which can
reduce the return. Earnings in a variable annuity do not provide all the tax advantages of 401(k)s and other before-
tax retirement plans. Once the investor starts withdrawing money from their variable annuity, earnings are taxed at
the ordinary income rate, rather than at the lower capital gains rates applied to other non-tax-deferred vehicles
which are held for more than one year. Proceeds of most variable annuities do not receive a “step-up” in cost basis
when the owner dies like stocks, bonds and mutual funds do.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 11
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
Item 9 – Disciplinary Information
On June 6, 2022, John Harnish d/b/a KM Advisory Services, entered a settlement with the U.S. Securities and
Exchange Commission (SEC) surrounding historical practices of recommending to advisory Clients certain mutual
funds that paid 12b-1 fees and charged commissions. Without admitting or denying the SEC’s findings, John
Harnish, d/b/a KM Advisory Services, agreed to (1) cease and desist from committing or causing any violations and
any future violations of Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 promulgated thereunder,
(2) a censure, and (3) pay disgorgement of $220,097.30, prejudgment interest of $5,549.69, and a civil monetary
penalty of $75,000. A copy of the Order is available at https://www.sec.gov/litigation/admin/2022/34-95047.pdf.
The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310720.
Item 10 – Other Financial Industry Activities and Affiliations
Insurance Agency
The Advisor serves as a licensed insurance agency, and as such, may offer insurance products on a commission
basis. The Advisor shall generally introduce the Client to an unaffiliated insurance agency to manage the insurance
process. The Advisor shall receive a portion of the insurance commission earned by the unaffiliated insurance
agency. No client shall be under any obligation to purchase any insurance products from the Advisor or such
introduced insurance agency. The recommendation by an Advisory Person that a Client purchase an insurance
product presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend
insurance products based on commissions to be received, rather than based on a particular Client’s need. Clients
are reminded that they remain free to purchase insurance products through other insurance agencies.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
PAG has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each
Client. This Code applies to all persons associated with PAG (“Supervised Persons”). The Code was developed to
provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. PAG and
its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of
PAG’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general
principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of
interest. To request a copy of the Code, please contact the Advisor at (585) 381-5900.
B. Personal Trading with Material Interest
PAG allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. PAG does not act as principal in any transactions. In addition, the Advisor does not
act as the general partner of a fund, or advise an investment company. PAG does not have a material interest in
any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
PAG allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 12
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by PAG requiring reporting of personal securities trades by its Supervised Persons for review by the Chief
Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect
the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While PAG allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no
time will PAG, or any Supervised Person of PAG, transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
PAG does not have discretionary authority to select the broker-dealer/custodian for custody and execution services.
The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and
authorize PAG to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further,
PAG does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade
basis.
Where PAG does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to
Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will
not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by PAG.
However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged.
PAG may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions
charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s
offices.
PAG will generally recommend that Clients establish their account[s] at Fidelity Clearing & Custody Solutions and
related entities of Fidelity Investments, Inc. (collectively “Fidelity”), Fidelity is a FINRA-registered broker-dealer and
member SIPC and will serve as the Client’s “qualified custodian”. PAG maintains an institutional relationship with
Fidelity, whereby the Advisor receives economic benefits from Fidelity. Please see Item 14 below.
Following are additional details regarding the brokerage practices of the Advisor:
• Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research
and other services. PAG does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see
Item 14 below.
• Brokerage Referrals - PAG does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
• Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where PAG will place trades
within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are
traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e.,
trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts
(i.e., purchase of a security into one Client account from another Client’s account[s]). PAG will not be
obligated to select competitive bids on securities transactions and does not have an obligation to seek the
lowest available transaction costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. PAG will execute its transactions through the Custodian as
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 13
authorized by the Client. PAG may aggregate orders in a block trade or trades when securities are purchased or
sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be
executed in full at the same price or time, the securities actually purchased or sold by the close of each business
day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This
must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Mr. Harnish. Formal reviews are
generally conducted at least annually or more frequently depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result
of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify PAG if changes occur in the Client’s
personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be
triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the
Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also
provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by PAG
Participation in Institutional Advisor Platform
PAG has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s].
Access to the Fidelity platform is provided at no charge to the Advisor. The Advisor receives access to software and
related support without cost because the Advisor renders investment management services to Clients that maintain
assets at Fidelity. The software and related systems support may benefit the Advisor, but not its Clients directly. In
fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should
be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these
benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar
software, systems support, or services.
The following benefits are also received from Fidelity: financing services, receipt of duplicate Client confirmations
and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants;
access to block trading which provides the ability to aggregate securities transactions and then allocate the
appropriate shares to Client accounts; and access to an electronic communication network for Client order entry
and account information.
B. Compensation for Client Referrals
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
Item 15 – Custody
PAG does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below:
Prosperity Advisory Group LLC
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Phone: (585) 381-5900 * Fax: (585) 381-0478
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Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of
advisory fees, all Clients for whom PAG exercises discretionary authority must hold their assets with a "qualified
custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and
must instruct PAG to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to
review statements provided by the Custodian and compare to any reports provided by PAG to ensure accuracy, as
the Custodian does not perform this review.
Money Movement Authorization - For instances where Clients authorize PAG to move funds between their
accounts, PAG and the Custodian have implemented safeguards to ensure that all money movement activities are
conducted strictly in accordance with the Client’s documented instructions.
Item 16 – Investment Discretion
PAG generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by PAG.
Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will
be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to
such authority. All discretionary trades made by PAG will be in accordance with each Client's investment objectives
and goals.
Item 17 – Voting Client Securities
PAG does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from
the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the
sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither PAG, nor its management, have any adverse financial situations that would reasonably impair the ability of
PAG to meet all obligations to its Clients. Neither PAG, nor any of its Advisory Persons, have been subject to a
bankruptcy or financial compromise. PAG is not required to deliver a balance sheet along with this Disclosure
Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months
or more in the future.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
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Prosperity Advisory Group LLC
Form ADV Part 2A – Appendix 1
(“Wrap Fee Program Brochure”)
Effective: July 14, 2025
This Form ADV2A – Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and
business practices for Prosperity Advisory Group LLC (“PAG” or the “Advisor”) services when offering services
pursuant to a wrap fee program. This Wrap Fee Program Brochure shall always be accompanied by the PAG
Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did not
receive the complete PAG Disclosure Brochure or you have any questions about the content of this Wrap Fee
Program Brochure or the PAG Disclosure Brochure, please contact the Advisor at (585) 381-5900.
PAG is a Registered Investment Advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Wrap Fee Program Brochure provides information about PAG to assist Clients in determining whether to retain the
Advisor.
Additional information about PAG and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310720.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
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Item 2 – Material Changes
This Wrap Fee Program Brochure provides information about a variety of topics relating to an Advisor’s business
practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses wrap fee programs
offering by the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment filing on
3/5/2024:
• The Advisor is now licensed as an insurance agency. Please see Item 9 for additional information.
• Advisory Persons are no longer licensed as registered representatives with a Broker-Dealer.
Future Changes
From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business
practices, changes in regulations or routine annual updates as required by the securities regulators. This complete
Wrap Fee Brochure (along with the complete PAG Disclosure Brochure) or a Summary of Material Changes shall
be provided to you annually and if a material change occurs in the business practices of PAG.
You may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm
name or CRD# 165516. You may also request a copy of this Disclosure Brochure at any time, by contacting the
Advisor at (585) 381-5900.
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................. 16
Item 2 – Material Changes ................................................................................................................................... 17
Item 3 – Table of Contents .................................................................................................................................. 17
Item 4 – Services Fees and Compensation ....................................................................................................... 18
Item 5 – Account Requirements and Types of Clients ..................................................................................... 19
Item 6 – Portfolio Manager Selection and Evaluation ...................................................................................... 19
Item 7 – Client Information Provided to Portfolio Managers ........................................................................... 20
Item 8 – Client Contact with Portfolio Managers .............................................................................................. 20
Item 9 – Additional Information .......................................................................................................................... 20
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 17
Item 4 – Services Fees and Compensation
A. Services
Prosperity Advisory Group LLC (“PAG” or the “Advisor”) provides customized investment advisory services for its
Clients. This Wrap Fee Program Brochure is provided as a supplement to the PAG Disclosure Brochure (Form ADV
2A). This Wrap Fee Program Brochure is provided along with the complete Disclosure Brochure to provide full
details of the business practices and fees when selecting PAG as your investment advisor.
As part of the investment advisory fees noted in Item 5 of the Disclosure Brochure, PAG includes securities
transaction fees and custody fees as part of its overall investment advisory fee through this Wrap Fee Program.
Securities regulations often refer to this combined fee structure as a “Wrap Fee Program”.
When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual
retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement
Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing
retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to
a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or
recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to
another IRA, or from one type of account to another account (e.g. commission-based account to fee-based
account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its
current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account
to an account managed by the Advisor.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of
Covered Costs into a single “bundled” investment advisory fee. This Wrap Fee Program Brochure references back
to the PAG Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please note,
held-away assets are excluded from the PAG Wrap Fee Program. Please see Item 4 – Advisory Services of the
Disclosure Brochure for details on PAG’s investment philosophy and related services.
B. Program Costs
Advisory services provided by PAG are offered in a wrap fee structure whereby securities transaction fees are
included together with investment advisory fees into a single, combined fee. The Advisor does not have a higher
fee schedule for Clients offered this Wrap Fee Program. Please see Item 5 – Fees and Compensation of the
Disclosure Brochure for complete details on fees.
C. Fees
Investment advisory fees are paid quarterly, advance of each calendar quarter, pursuant to the terms of the
investment advisory agreement. Investment advisory fees are based on the market value of assets under
management at the end of the prior calendar quarter. Investment advisory fees are based on the following schedule:
Annual Rate (%)
1.25%
1.00%
0.75%
Assets Under Management ($)
Up to $1,000,000
$1,000,001 to $3,000,000
Over $3,000,000
*The Advisor imposes a minimum fee of $1,000 for Investment Management Services
The investment advisory fee in the first quarter of service is prorated from the inception date of the Client’s account[s]
to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take
into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed
by PAG will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s
valuation to ensure accurate billing.
Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of
the Client’s account[s]. Under this Wrap Fee Program, PAG includes securities transactions costs as part of its overall
investment advisory fee. The Advisor has negotiated a fixed rate with its recommended Custodian for securities
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
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Page 18
transaction fees, which is based on assets under management in the Client’s account[s]. Certain accounts may be
excluded from this fixed rate arrangement. In such instances, the Advisor may utilize certain investments that the
Custodian provides with no-transaction fee (“NTF Investments”). Advisory Persons of the Advisor, in their fiduciary
duty, will always seek the most appropriate investments for inclusion in a Client’s portfolio. As such, the Advisor has
an incentive to utilize NTF Investments to limit the overall cost to the Advisor. The Advisor will only place Client
assets into a Wrap Free Program when it is believed to be in the Client’s best interest. The Advisor, in its fiduciary
duty, will select the investments most appropriate for the Client’s investment portfolio[s], regardless of securities
transaction costs.
In addition, all fees paid to PAG for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in
each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds,
other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible
distribution fee. A Client may be able to invest in these products directly, without the services of PAG, but would not
receive the services provided by PAG which are designed, among other things, to assist the Client in determining
which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the
Client should review both the fees charged by the fund[s] and the fees charged by PAG to fully understand the total
fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure Brochure (included with this
Wrap Fee Program Brochure).
D. Compensation
PAG is the sponsor and portfolio manager of this Wrap Fee Program. PAG receives investment advisory fees paid
by Clients for participating in the Wrap Fee Program and pays the Covered Costs associated with the management
of the Client’s account[s].
Item 5 – Account Requirements and Types of Clients
PAG offers investment advisory services to individuals, high net worth individuals, trusts, estates, and businesses.
PAG generally does not impose a minimum relationship size.
Item 6 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
PAG serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Related Persons
PAG personnel serve as portfolio managers for this Wrap Fee Program. PAG does not serve as a portfolio
manager for any third-party wrap fee programs.
Performance-Based Fees
PAG does not charge performance-based fees.
Supervised Persons
Advisory Persons serve as portfolio managers for all accounts, including the services described in this Wrap Fee
Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure Brochure.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Brochure) for details on the research and
analysis methods employed by the Advisor.
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. PAG will assist Clients in determining an appropriate strategy
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 19
based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will
meet their investment goals.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account[s]. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on
investment risks.
Proxy Voting
PAG does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from
the Custodian. Further, the Advisor does not participate in any legal proceedings involving investments held in
Client accounts. The Advisor will assist in answering questions relating to proxies and other matters, however, the
Client retains the sole responsibility for decisions, voting and related activities. The Custodian will send these
materials directly to the Client. If the Client instead directs these documents to the Advisor’s attention, the Client is
advised that the Advisor will not be responsible to take action on proxies and legal proceedings.
Item 7 – Client Information Provided to Portfolio Managers
PAG is the sponsor and sole portfolio manager for the Wrap Fee Program. The Advisor does not share Client
information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program.
Please also see the PAG Privacy Policy (included after this Wrap Fee Program Brochure).
Item 8 – Client Contact with Portfolio Managers
PAG is a full-service investment management advisory firm. Clients always have direct access to the Advisory
Persons at PAG.
Item 9 – Additional Information
A. Disciplinary Information and Other Financial Industry Activities and Affiliations
On June 6, 2022, John Harnish d/b/a KM Advisory Services, entered a settlement with the U.S. Securities and
Exchange Commission (SEC) surrounding historical practices of recommending to advisory Clients certain mutual
funds that paid 12b-1 fees and charged commissions. Without admitting or denying the SEC’s findings, John
Harnish, d/b/a KM Advisory Services, agreed to (1) cease and desist from committing or causing any violations and
any future violations of Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 promulgated thereunder,
(2) a censure, and (3) pay disgorgement of $220,097.30, prejudgment interest of $5,549.69, and a civil monetary
penalty of $75,000. A copy of the Order is available at https://www.sec.gov/litigation/admin/2022/34-95047.pdf.
The backgrounds of the Advisor and its Advisor Persons are available on the Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310720.
Please see Item 9 of the PAG Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure
Supplement for additional information on how to research the background of the Advisor and its Advisory Persons.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 20
Other Financial Activities and Affiliations
Insurance Agency – As noted in Item 10 of the Disclosure Brochure, the Advisor serves as a licensed insurance
agency, and as such, may offer insurance products on a commission basis. The Advisor shall generally introduce
the Client to an unaffiliated insurance agency to manage the insurance process. The Advisor shall receive a portion
of the insurance commission earned by the unaffiliated insurance agency. No client shall be under any obligation to
purchase any insurance products from the Advisor or such introduced insurance agency. The recommendation by
an Advisory Person that a Client purchase an insurance product presents a conflict of interest, as the receipt of
commissions may provide an incentive to recommend insurance products based on commissions to be received,
rather than based on a particular Client’s need. Clients are reminded that they remain free to purchase insurance
products through other insurance agencies.
Please see Items 10 and 14 of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee
Brochure).
B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information
PAG has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of Ethics
applies to all persons subject to PAG’s compliance program (our “Supervised Persons”). Complete details on the
PAG Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and
Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure).
Review of Accounts
Securities in Client accounts are monitored on a regular and continuous basis by Mr. Harnish. Formal reviews are
generally conducted at least annually or more frequently depending on the needs of the Client. Details of the review
policies and practices are provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure.
Other Compensation
Institutional Advisor Platform (Fidelity) - PAG has established an institutional relationship with Fidelity to assist the
Advisor in managing Client account[s]. Access to the Fidelity platform is provided at no charge to the Advisor. The
Advisor receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Fidelity. The software and related systems support may
benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to
put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a
Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this
Custodian over one that does not furnish similar software, systems support, or services.
The following benefits are also received from Fidelity: financing services, receipt of duplicate Client confirmations
and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants;
access to block trading which provides the ability to aggregate securities transactions and then allocate the
appropriate shares to Client accounts; and access to an electronic communication network for Client order entry
and account information.
Please see Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this
Wrap Fee Brochure) for details on additional compensation that may be received by PAG or its Advisory Persons.
Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Brochure) provides details on any
outside business activities and the associated compensation.
Compensation for Client Referrals
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
Financial Information
Neither PAG, nor its management has any adverse financial situations that would reasonably impair the ability of
PAG to meet all obligations to its Clients. Neither PAG, nor any of its Advisory Persons, has been subject to a
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 21
bankruptcy or financial compromise. PAG is not required to deliver a balance sheet along with this Disclosure
Brochure, as the firm does not collect advance fees of $1,200 or more for services to be performed six months or
more in advance. Please see Item 18 of the Form ADV Part 2A – Disclosure Brochure.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 22
Form ADV Part 2B – Brochure Supplement
for
John P. Harnish, CFP®
Principal and Chief Compliance Officer
Effective: July 14, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of John
P. Harnish, CFP® (CRD# 4813106) in addition to the information contained in the Prosperity Advisory Group LLC
(“PAG” or the “Advisor”, CRD# 310720) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the PAG Disclosure Brochure or this Brochure
Supplement, please contact us at (585) 381-5900.
Additional information about Mr. Harnish is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4813106.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 23
Item 2 – Educational Background and Business Experience
John P. Harnish, CFP®, born in 1975, is dedicated to advising Clients of PAG as the Principal and Chief
Compliance Officer. Mr. Harnish attended classes at St. Bonaventure University. Mr. Harnish also earned his
Certified Financial PlannerTM designation at the College for Financial Planning in 2007. Additional information
regarding Mr. Harnish’s employment history is included below.
Employment History:
09/2020 to Present
07/2004 to 07/2025
03/2020 to 08/2021
03/2020 to 08/2021
01/2004 to 3/2020
04/2002 to 03/2020
Principal and Chief Compliance Officer, Prosperity Advisory Group LLC
Registered Representative, Cadaret, Grant & Co., Inc.
Owner, Investment Advisor Representative and Chief Compliance Officer,
KM Advisory Services
CEO and President, KM Investment Services
Investment Advisor Representative and Chief Compliance Officer,
KM Advisory Services
Client Service Coordinator/Financial Advisor/Director of Financial Planning,
KM Investment Services
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner™ Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to
hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 87,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP Board’s studies have determined as necessary for the competent and professional delivery
of financial planning services. CFP Board’s financial planning subject areas include insurance planning and
risk management, employee benefits planning, investment planning, income tax planning, retirement
planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real-world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in order
to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of their
clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP®.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 24
Item 3 – Disciplinary Information
On June 6, 2022, John Harnish d/b/a KM Advisory Services, entered a settlement with the U.S. Securities and
Exchange Commission (SEC) surrounding historical practices of recommending to advisory Clients certain mutual
funds that paid 12b-1 fees and charged commissions. Without admitting or denying the SEC’s findings, John
Harnish, d/b/a KM Advisory Services, agreed to (1) cease and desist from committing or causing any violations and
any future violations of Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 promulgated thereunder,
(2) a censure, and (3) pay disgorgement of $220,097.30, prejudgment interest of $5,549.69, and a civil monetary
penalty of $75,000. A copy of the Order is available at https://www.sec.gov/litigation/admin/2022/34-95047.pdf.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices.
In regard to the above SEC settlement, the Certified Planner Board of Standards issued a Public Censure against
Mr. Harnish in August of 2023. As with the SEC settlement, this was related to activity with KM Advisory Services
from 2016 to 2020. Please view disciplinary information on the CFP Board Website at www.cfp.net/verify.
PAG encourages you to independently view the background of Mr. Harnish on the Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4813106.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Harnish is a licensed insurance professional. Implementations of insurance recommendations are separate and
apart from Mr. Harnish’s role with PAG. As an insurance professional, Mr. Harnish will receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr.
Harnish is not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Harnish or the Advisor. Mr. Harnish spends approximately 10% of his time per month in this capacity.
Notary Public - State of New York
Mr. Harnish is also a notary public licensed in the State of New York.
Item 5 – Additional Compensation
Mr. Harnish has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Harnish serves as its Principal and Chief Compliance Officer and Director of PAG. Mr. Harnish can be reached
at (585) 381-5900.
PAG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of PAG. Further, PAG is subject to regulatory oversight by various
agencies. These agencies require registration by PAG and its Supervised Persons. As a registered entity, PAG is
subject to examinations by regulators, which may be announced or unannounced. PAG is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 25
Form ADV Part 2B – Brochure Supplement
for
Alyssa V. Girod
Director of Client Service
Effective: July 14, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Alyssa V. Girod (CRD# 7032448) in addition to the information contained in the Prosperity Advisory Group LLC
(“PAG” or the “Advisor”, CRD# 310720) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the PAG Disclosure Brochure or this Brochure
Supplement, please contact us at (585) 381-5900.
Additional information about Ms. Girod is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 7032448.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 26
Item 2 – Educational Background and Business Experience
Alyssa V. Girod, born in 1995, is dedicated to advising Clients of PAG as the Director of Client Service. Ms. Girod
earned a Master of Science in Management from Keuka College in 2017. Ms. Girod also earned a Bachelor of
Science from Kueka College in 2016. Additional information regarding Ms. Girod’s employment history is included
below.
Employment History:
Director of Client Service, Prosperity Advisory Group LLC
Food/Bar Attendant, Ravenwood Golf Club
Client Service Coordinator, KM Investment Services, Inc.
Management Trainee, EverGreen Federal Credit Union
Store Cashier, Peebles
07/2021 to Present
5/2022 to 6/2022
10/2018 to 7/2021
5/2018 to 9/2018
9/2017 to 6/2018
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Girod. Ms. Girod has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Ms. Girod.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Ms. Girod.
However, we do encourage you to independently view the background of Ms. Girod on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
7032448.
Item 4 – Other Business Activities
Ms. Girod is dedicated to the investment advisory activities of PAG’s Clients. Ms. Girod does not have any other
business activities.
Item 5 – Additional Compensation
Ms. Girod is dedicated to the investment advisory activities of PAG’s Clients. Ms. Girod does not receive any
additional forms of compensation.
Item 6 – Supervision
Ms. Girod serves as the Director of Client Service of PAG and is supervised by John Harnish, the Chief Compliance
Officer. Mr. Harnish can be reached at (585) 381-5900.
PAG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of PAG. Further, PAG is subject to regulatory oversight by various
agencies. These agencies require registration by PAG and its Supervised Persons. As a registered entity, PAG is
subject to examinations by regulators, which may be announced or unannounced. PAG is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 27
Form ADV Part 2B – Brochure Supplement
for
Martha E. Jesse
Director of Operations
Effective: July 14, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Martha E. Jesse (CRD# 7595175) in addition to the information contained in the Prosperity Advisory Group LLC
(“PAG” or the “Advisor”, CRD# 310720) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the PAG Disclosure Brochure or this Brochure
Supplement, please contact us at (585) 381-5900.
Additional information about Mrs. Jesse is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 7595175.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 28
Item 2 – Educational Background and Business Experience
Martha E. Jesse, born in 1984, is dedicated to advising Clients of PAG as a Director of Operations. Mrs. Jesse
earned a Bachelor of Arts in Sociology from St. John Fisher College in 2007. Mrs. Jesse also earned an Associate
Degree from Monroe Community College in 2005. Additional information regarding Mrs. Jesse’s employment
history is included below.
Employment History:
Director of Operations, Prosperity Advisory Group LLC
Homemaker, N/A
07/2022 to Present
7/2009 to 7/2022
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mrs. Jesse. Mrs. Jesse has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mrs. Jesse.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mrs. Jesse.
However, we do encourage you to independently view the background of Mrs. Jesse on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
7595175.
Item 4 – Other Business Activities
Mrs. Jesse is dedicated to the investment advisory activities of PAG’s Clients. Mrs. Jesse does not have any other
business activities.
Item 5 – Additional Compensation
Mrs. Jesse is dedicated to the investment advisory activities of PAG’s Clients. Mrs. Jesse does not receive any
additional forms of compensation.
Item 6 – Supervision
Mrs. Jesse serves as a Director of Operations of PAG and is supervised by John Harnish, the Chief Compliance
Officer. Mr. Harnish can be reached at (585) 381-5900.
PAG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of PAG. Further, PAG is subject to regulatory oversight by various
agencies. These agencies require registration by PAG and its Supervised Persons. As a registered entity, PAG is
subject to examinations by regulators, which may be announced or unannounced. PAG is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 29
Privacy Policy
Effective: July 14, 2025
Our Commitment to You
Prosperity Advisory Group LLC (“PAG” or the “Advisor”) is committed to safeguarding the use of personal
information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as
described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. PAG (also referred to as "we", "our" and "us”)
protects the security and confidentiality of the personal information we have and implements controls to ensure that
such information is used for proper business purposes in connection with the management or servicing of our
relationship with you.
PAG does not sell your non-public personal information to anyone. Nor do we provide such information to others
except for discrete and reasonable business purposes in connection with the servicing and management of our
relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number
Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Income Tax Information
Insurance Information
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect
Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 30
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
No
Not Shared
Yes
Yes
No
Not Shared
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
PAG does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where PAG or the
Client has a formal agreement with the financial institution. We will only
share information for purposes of servicing your accounts, not for
marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
PAG does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
us at (585) 381-5900.
Prosperity Advisory Group LLC
50 Square Drive, Suite 220, Victor, NY 14564
Phone: (585) 381-5900 * Fax: (585) 381-0478
https://prosperityadv.com
Page 31