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Part 2A of Form ADV:
Firm Brochure
Providence Financial and Insurance Services, Inc.
6320 Canoga Avenue, Suite 600
Woodland Hills, CA 91367
Telephone: 800-256-3513
www.providencefinancialinc.com
March 2026
____________________________________________________________________________________
This Brochure provides information about the qualifications and investment advisory business practices of
Anthony A. Saccaro, ChFC, J.D., President of Providence Financial and Insurance Services, Inc. If you
have any questions about the contents of this Brochure, please contact Anthony A. Saccaro at 818-887-
6443. The information in this Brochure has not been approved or verified by the United States Securities
and Exchange Commission (SEC) or by any state securities authority.
Additional information about Anthony A. Saccaro, President of Providence Financial and Insurance
Services, Inc. is also available on the Internet at www.adviserinfo.sec.gov. You can view the information
on this website by searching for the investment adviser firm name or by searching for the firm CRD
number 141988.
*Registration as an investment advisor does not imply a certain level of skill or training.
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Item 2 – Material Changes
The Firm Brochure is used to provide our clients with a summary of new and/or updated information. We
will inform you of the revision(s) based on the nature of the updated information.
Providence Financial and Insurance Services, Inc. has no material changes to this Disclosure Brochure
since our last annual amendment was filed in March 2025.
Consistent with the rules, we will ensure that you receive a summary of any material changes to this and
subsequent Brochures within 120 days of the close of our business’ fiscal year. Furthermore, we will
provide you with other interim disclosures about material changes, as necessary.
Item 3 – Table of Contents
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Item 2 – Material Changes ........................................................................................................................ 2
Item 3 – Table of Contents ....................................................................................................................... 2
Item 4 – Advisory Business ...................................................................................................................... 4
General Description of Primary Advisory Services ........................................................................... 5
Limits Advice to Certain Types of Investments .................................................................................. 8
Item 5 – Fees and Compensation............................................................................................................ 9
Financial Planning/Consulting Services ............................................................................................ 11
Third-Party Money Managers ................................................................................................................. 11
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 11
Item 7 – Types of Clients ........................................................................................................................ 12
Minimum Investment Amounts Required .......................................................................................... 12
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 12
Methods of Analysis ................................................................................................................................. 12
Investment Strategies .......................................................................................................................... 13
Use of Primary Method of Analysis or Strategy ............................................................................... 13
Risk of Loss ........................................................................................................................................... 13
Item 9 – Disciplinary Information............................................................................................................ 14
Item 10 – Other Financial Industry Activities and Affiliations............................................................. 14
Insurance Activities .............................................................................................................................. 14
Third-Party Money Managers ................................................................................................................. 14
Legal Services .......................................................................................................................................... 15
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading .................. 15
Item 12 – Brokerage Practices ............................................................................................................... 16
Trade Errors .......................................................................................................................................... 18
Aggregation of Client Orders-Block Trading Policy......................................................................... 18
Item 13 – Review of Accounts ................................................................................................................ 18
Review Process .................................................................................................................................... 19
Report Process ..................................................................................................................................... 19
Item 14 – Client Referrals and Other Compensation .......................................................................... 19
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Additional Compensation .................................................................................................................... 19
Item 15 – Custody .................................................................................................................................... 20
Item 16 – Investment Discretion ............................................................................................................ 20
Item 17 – Voting Client Securities.......................................................................................................... 21
Item 18 – Financial Information .............................................................................................................. 21
Item 19 – Privacy Policy ......................................................................................................................... 21
Item 4 – Advisory Business
Anthony A. Saccaro, ChFC, J.D., President of Providence Financial and Insurance Services, Inc.
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(Providence and/or the Firm) is a registered investment advisor and is an S Corporation formed under the
laws of the state of California. Furthermore, Anthony A. Saccaro is an attorney licensed to practice in
California.
• Providence Financial and Insurance Services, Inc. was initially approved as a registered
investment advisor in March 2008.
• Anthony A. Saccaro, President and 100% owner of Providence Financial and Insurance Services,
Inc.
General Description of Primary Advisory Services
Providence provides clients with a broad range of investment management and insurance services,
comprehensive estate and financial planning, and consulting services (including non-investment related
matters). The following briefly outlines the primary advisory services provided by the Firm. A more
detailed description of our services is provided in Item 5 – Fees and Compensation allowing clients and
prospective clients an opportunity to review our description of services and description of fees in a side-
by-side manner.
Financial Planning & Consulting Services – Providence provides investment advisory services in the
form of financial planning and consulting services. Financial planning and consulting services involves the
active management of client accounts with a focus on a client’s overall financial situation. For Providence,
financial planning and consulting consists of guiding individuals as they determine and set their long-term
financial goals, through investments, tax planning, asset allocation, risk management, retirement
planning, and other areas. Furthermore, Anthony A. Saccaro, in his capacity as an attorney, offers legal
advice in the area of estate planning for which he is qualified to offer such advice. The role of a financial
planner is to find ways to assist the client in understanding their overall financial situation and financial
objectives.
Investment Management Services – We provide advisory services in the form of Investment
Management Services. Investment Management Services involve providing clients with continuous and
on-going supervision over client accounts. This includes monitoring a client’s account and directing
trades, when necessary. Providence places trades on a discretionary basis without the direct consent of
the client.
Although we utilize certain preferred brokerage and custodial platforms and require their use for standard
brokerage accounts, including but not limited to individual accounts, joint accounts, IRA accounts and
trust or corporate accounts, we can also manage and monitor accounts not held on a brokerage platform
we recommend. Through an arrangement with Pontera Solutions Inc. (formerly known as “FeeX, Inc.”),
an unaffiliated third-party, we are able to gain access to your accounts not held at one of our primary
brokerage platforms using the Pontera Order Management System software, to facilitate discretionary
investment management of and execute trade orders for retirement plan participant accounts (often
referred to as a participant’s 401k account). If you choose to grant Pontera Solutions Inc. access to these
accounts, we can regularly review the investment options in the accounts, monitor them, rebalance and
trade them to implement investment strategies the same way we do for your other accounts, if any, under
our management.
If you engage us to provide services for your retirement plan participant account(s) you will need to share
your retirement plan participant account login credentials directly with Pontera Solutions Inc. Advisor is
able to avoid being classified as having custody of the retirement plan participant accounts since we do
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not have direct access to your log-in credentials stored by Pontera Solutions, Inc. and have limited
authority to place only investment trades within such accounts.
While Pontera Solutions Inc. asserts that it has implemented cybersecurity measures to protect your
information, it is important to recognize the inherent risks of sharing your account credentials. It is crucial
to acknowledge that no cybersecurity system is impervious to risk. In the event of a cybersecurity breach
involving Pontera Solutions Inc., there is a possibility that your retirement plan participant account
credentials could be exposed.
Moreover, the sharing of login details with a third party, such as Pontera Solutions Inc., may contravene
the terms-of-use of the online platform associated with your retirement plan participant account(s)
potentially leading to service providers associated with those accounts disclaiming liability to you for any
unauthorized transactions. This is a critical consideration as it might limit your recourse in the event of
unauthorized access to your account. We recommend that you check the terms-of-use of the specific
online platform(s) associated with your retirement plan participant account(s) with respect to this issue.
In light of these considerations, Pontera Solutions Inc. posted a "Client Cyber Protection Pledge," which is
available for review at https://pontera.com/client-protection-pledge . We strongly advise you to review this
pledge along with the Subscription Agreement, Terms & Conditions, and Privacy Policy of Pontera
Advisors Solutions, Inc. to understand the scope of their actual contractual obligations. Furthermore, it is
essential to consult with your legal counsel to assess the risks associated with this arrangement and the
enforceability of Pontera's pledge in protecting your interests. You are under no obligation to retain us to
manage your retirement plan participant account(s).
Referral of Third-Party Money Managers - Providence offers advisory services by referring clients to a
third-party money manager, Sound Income Strategies, LLC, (SIS), which offers asset management and
other investment advisory services. SIS is responsible for continuously monitoring client accounts and
making trades in client accounts on a discretionary basis when they deem necessary.
Under this program, we assist you with identifying your risk tolerance and investment objectives. We then
instruct SIS to invest according to your stated investment objectives and risk tolerance. You must
authorize SIS, who provide your designated account(s) with asset management services, to have trading
authority which you will do through a limited power of attorney.
We are available to answer questions that you may have regarding your account and act as the
communication conduit between you and SIS. SIS may take discretionary authority to determine the
securities to be purchased and sold for your account. However, Providence also has full trading authority.
After reviewing the performance of various third-party investment advisory firms, including various factors
such as the overall fee that they charge us or our clients, Providence has selected SIS as the single third-
party money manager which we recommend to our clients. Therefore, Providence has a conflict of
interest in that it will only recommend SIS as its sole third-party money manager. In addition, in 2023 the
firm’s President, Anthony Saccaro, made a personal investment in Sound Income Group the parent
company of SIS. This small ownership interest further enhances the level of conflict of interest in having
SIS as the sole third-party investment advisors utilized by the firm.
Clients are advised that there may be other third-party managed programs not recommended by our firm,
that may be more suitable for the client and that may be more or less costly than arrangements
recommended by our firm. No guarantees can be made that a client’s financial goals or objectives will be
achieved by SIS. Further, no guarantees of performance can ever be offered by our firm (Please refer to
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more details.)
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Retirement Plan Rollover Recommendations - When Providence provides investment advice about
your retirement plan account or individual retirement account (“IRA”) including whether to maintain
investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the
retirement plan account to a IRA or make a distribution from the retirement plan account, we
acknowledge that Providence 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. The way Providence makes money creates conflicts with your interests so
Providence operates under a special rule that requires Providence to act in your best interest and not put
our interest ahead of you.
Under this special rule’s provisions, Providence must as a fiduciary to a retirement plan account or IRA
under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (give
prudent advice);
• Never put the financial interests of Providence ahead of you when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Providence gives advice that is in
your best interest;
• Charge no more than is reasonable for the services of Providence; and
• Give Client basic information about conflicts of interest.
To the extent we recommend you roll over your account from a current retirement plan account to an
individual retirement account managed by Providence, please know that Providence and we have a
conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over your account at the
retirement plan to an IRA managed by Providence. We will earn fewer investment advisory fees if you do
not roll over the funds in the retirement plan to an IRA managed by Providence.
Thus, our investment adviser representatives have an economic incentive to recommend a rollover of
funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that
you open an IRA account to be managed by our firm can be based on our economic incentive and not
based exclusively on whether or not moving the IRA to our management program is in your overall best
interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard
whereby our investment adviser representatives will (i) provide investment advice to a retirement plan
participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status
described below, (ii) not recommend investments which result in Providence receiving unreasonable
compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose
compensation received by Providence and our supervised persons and any material conflicts of interest
related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making
any materially misleading statements regarding such rollover.
When providing advice to a retirement plan account or IRA, we will act with the care, skill, prudence, and
diligence under the circumstances then prevailing that a prudent person acting in a like capacity and
familiar with such matters would use in the conduct of an enterprise of a like character and with like aims,
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based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without
regard to the financial or other interests of Providence or our affiliated personnel.
Limits Advice to Certain Types of Investments
We provide investment advice concerning, but not limited to, the following types of investments:
• Exchange-listed securities (i.e., stocks)
• Securities traded over-the-counter
• Foreign issues
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States government securities
• Options contracts on securities
• Options contracts on commodities
• Interests in partnerships investing in real estate
• Interests in partnerships investing in oil and gas interests
The Firm does not provide advice on futures contracts on tangibles or intangibles.
When providing Investment Management Services, Providence typically constructs each client’s account
holdings using income producing investments (individual bonds, unit investment trusts, real estate
investment trusts, etc.), along with exchange traded funds (ETFs), mutual funds, and equities, to build
diversified portfolios. It is not the Firm’s typical investment strategy to attempt to time the market, but
Providence may increase cash holdings modestly as deemed appropriate, based on a client’s risk
tolerance and the Firm’s analysis and expectations regarding market behavior. Providence may modify
our investment strategy to accommodate special situations such as low basis stock, stock options, and
legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer
to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.)
Tailor Advisory Services to Individual Needs of Clients
Our services are always provided based on the individual needs of each client. For example, a client is
given the ability to impose restrictions on the accounts we manage on behalf of the client, including
specific investment selections and sectors. Providence works with each client on a one-on-one basis
through interviews and questionnaires to determine the client’s investment objectives and suitability
information.
Client Assets Managed by Providence
As of February 12, 2026, the amount of client assets managed by Providence totaled; $215,020,611. All
accounts are managed on a discretionary basis.
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Item 5 – Fees and Compensation
In addition to the information provided in Item 4 – Advisory Business, this section provides details
regarding our advisory services, fees and compensation arrangements.
Investment Management Services
The client may engage Providence to design an investment portfolio and provide ongoing corresponding
investment management services on a fee-only basis. Unless the client directs otherwise, we will
generally recommend investment management accounts be established with Charles Schwab and Co.
Member FINRA/SIPC/NFA.
We provide an additional service for accounts not directly held with Schwab, but where we do have
discretion, and may leverage an Order Management System to implement tax-efficient asset location and
opportunistic rebalancing strategies on behalf of the client. These are primarily employer sponsored
retirement accounts (i.e. 401(k), 403B etc.), HSA’s, and other assets we do not custody. We regularly
review the available investment options in these accounts, monitor them, and rebalance and implement
our strategies in the same way we do other accounts, though using different tools, as necessary.
Advisory recommendations are based on the client’s financial situation at the time the services are
provided and are based on financial information disclosed by the client to us. You are advised that certain
assumptions may be made with respect to interest and inflation rates and the use of past trends and
performance of the market and economy. Past performance is in no way an indication of future
performance. As the client’s financial situation, goals, objectives, or needs change, the client must notify
us promptly.
Our fees for investment management services generally range between 1.25% and 1.50% of the invested
assets and are charged as follows:
Assets Under Management Maximum Annual Advisory Fee
$0-$250,000
$2500 flat fee
$250,000-$1,000,000
1.50%
$1,000,001+
1.25%
Our fees are subject to negotiation and charged on a pro-rata (annual) basis monthly in arrears based on
the average daily market value of the account during the most recent calendar month. Our fees are
negotiable based on factors such as the client’s financial situation and circumstances, the amount of
assets under management, and the overall complexity of the services provided.
Clients may receive the same or comparable services from other financial advisors at a lower fee.
Prior to Providence providing investment management services, the client will be required to enter into a
formal Investment Advisory Agreement with us setting forth the terms and conditions under which the
Firm will manage the client's assets, and a separate custodial/clearing/management agreement with the
account custodian. Our Investment Advisory Agreement and the custodial/clearing/ management
agreement may authorize the account custodian to debit the client account in the amount of the
Providence investment advisory fee and to directly remit the management fee to the Firm in accordance
with applicable state and/or regulatory procedures. The applicable procedures require that Providence to
provide clients with a fee notification contemporaneously with any fees being deducted from the account.
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The fee notification expressly states the amount of fees for the month, the manner in which the fees are
deducted, any adjustments to the fees, as well as an explanation regarding any adjustments. The
account custodian provides client statements, at least quarterly, showing all disbursements for the
account including the amount of the advisory fee deducted directly from the account. The exception for
this is directly-managed held-away accounts, such as 401(k)’s and other employer sponsored retirement
plans. As it is impossible to directly debit the fees from these accounts, those fees will be assigned to the
client’s other pre-tax or taxable accounts on a pro-rata basis. If the client does not have a pre-tax or
taxable account, they will be required to establish one in order to use this service. If we only manage your
held-away assets for part of a quarter, the charge will be prorated. Furthermore, although the fee for this
service will be charged according to the fee schedule above, the fee for directly-managed held-away
accounts will be based on the value of the account on the last day of the quarter and will be deducted
quarterly in arrears.
Advice offered by Providence may involve investments in mutual and/or money market funds, unit
investment trusts, real estate investment trusts, variable annuities, and/or the use of third-party money
managers who also charge a separate fee. Clients are hereby advised that all fees paid to the Firm for
investment advisory services are separate and distinct from the fees and expenses charged by these
funds (described in each fund’s prospectus) to their shareholders. These fees may include, but are not
limited to, a management fee, upfront sales charges, and other fund expenses. In addition, transaction
charges may apply when purchasing or selling securities. Providence does not share in any portion of the
brokerage fees/transaction charges imposed by the custodian holding the client funds or securities. You
should review all fees charged by mutual and/or money market funds, Providence and others to fully
understand the total amount of fees to be paid by the client.
In performing its services, Providence is not required to verify any information received from the client or
from the client’s other professionals and may rely on the information provided in servicing the client
account. The client is free to accept or reject any recommendation made by us. Moreover, each client is
advised that it is the client’s responsibility to promptly notify Providence regarding any change in the
client’s financial situation or investment objectives for the purpose of reviewing/evaluating/revising the
Firm’s previous recommendations and/or services. Our clients are advised to promptly notify us if there
are ever any changes in their financial situation or investment objectives, or if they wish to impose any
reasonable restrictions upon Providence’s management services.
The Providence written disclosure statement is provided to each client prior to, or contemporaneously
with, the execution of the Investment Advisory Agreement. Any client who has not received a copy of our
written disclosure statement at least forty-eight (48) hours prior to executing the initial Investment
Advisory Agreement is allowed five (5) business days subsequent to executing the agreement to
terminate the Firm’s services without penalty.
The Investment Advisory Agreement may be cancelled at any time, by either party, for any reason upon
receipt of written notice. Upon termination of any account, any prepaid, unearned fees are promptly be
refunded, and any earned, unpaid fees are due and payable.
Neither the Firm nor the client may assign the Investment Advisory Agreement without the prior written
consent of the other party. Transactions that do not result in a change of actual control or management of
Providence will not be considered an assignment.
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Financial Planning/Consulting Services
We provide investment and financial planning advice to clients through consultations. We provide an
initial consultation with no fee and no obligation. If it is determined that we can assist a prospective client
in a particular area, the Firm will then develop a proposal for the prospective client. If the proposal
involves the utilization of products in which there is a commission payable, then, in most circumstances,
we are willing to accept the commissions as full compensation for our consultation services but only with
regards to the products that pay the commission.
Providence provides financial planning advice to clients that often involves the use of fixed and/or indexed
products and/or life insurance. We also attempt to identify estate-planning deficiencies and either
recommend solutions or refer clients to an appropriate professional (e.g., elder law attorney, CPA) who
can further discuss the details of these deficiencies along with possible solutions.
As a customary part of the Firm’s financial planning/consulting process, Providence sometimes
recommends clients purchase one or more fixed and/or indexed products including, but not limited to,
annuities and/or life insurance.
Third-Party Money Managers
A complete description of the third-party money manager’s services, fee schedules and account
minimums will be disclosed in the third-party money manager’s disclosure brochure which will be provided
to you prior to or at the time an agreement for services is executed and the account is established.
The asset management fees charged under the Third-Party Money Manager program may vary and may
be negotiable based upon the type of client, the services requested, the complexity of the client's
situation, the composition of the client's account, other advisory services provided and the relationship of
the client. The exact fees and other terms will be outlined in the agreement between you and Providence.
All fees are calculated, billed to the custodian and collected by Providence. We will be responsible for
delivering the third-party manager their portion of the asset management fees collected.
Third-party managers generally have account minimum requirements that will vary among third-party
money managers. Account minimums are generally higher on fixed income accounts than for equity-
based accounts.
Under this program, you may incur additional charges including but not limited to, mutual fund sales
loads, 12b-1 fees and surrender charges and IRA and qualified retirement plan fees.
We have a conflict of interest by only offering SIS as the sole third-party money managers as they have
agreed to charge us lower fees or pay a portion of their advisory fee to us and have met the conditions of
our due diligence review. There may be other third-party money managers that may be more suitable for
you or that may be more or less costly. No guarantees can be made that your financial goals or objectives
will be achieved. Further, no guarantees of performance can be offered.
Item 6 – Performance-Based Fees and Side-By-Side Management
Providence does not charge or accept performance-based fees. Performance-based fees are fees based
on a share of capital gains on or capital appreciation of the assets held within a client’s account.
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Item 7 – Types of Clients
We generally provide investment advice to the following types of clients:
Individuals
•
• Pension and profit-sharing plans
• Trusts, estates, or charitable organizations
• Corporations or business entities other than those listed above
Minimum Investment Amounts Required
Although we reserve the right make an exception, there is a minimum investment amount of $250,000
required for establishing an account managed by Providence. Prior to engaging us to provide investment
advisory services, the client is required to enter into an Investment Advisory Agreement with the Firm
setting forth the terms and conditions of the engagement, describing the scope of the services to be
provided, and the portion of any fee that is due from the client prior to us commencing services.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Providence uses the following methods of analysis in formulating investment advice:
Charting – This is a set of techniques used in technical analysis in which charts are used to plot price
movements, volume, settlement prices, open interest, and other indicators, in order to anticipate future
price movements. Users of these techniques, called chartists, believe that past trends in these indicators
can be used to extrapolate future trends.
Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic value by
examining related economic, financial and other qualitative and quantitative factors. Fundamental
analysts attempt to study everything that can affect the security's value, including macroeconomic factors
(like the overall economy and industry conditions) and individually specific factors (like the financial
condition and management of companies). The end goal of performing fundamental analysis is to
produce a value that an investor can compare with the security's current price in hopes of figuring out
what sort of position to take with that security (underpriced = buy, overpriced = sell or short). This method
of security analysis is considered to be the opposite of technical analysis. Fundamental analysis is about
using real data to evaluate a security's value. Although most analysts use fundamental analysis to value
stocks, this method of valuation can be used for just about any type of security.
Technical – This is a method of evaluating securities by analyzing statistics generated by market activity,
such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value,
but instead use charts and other tools to identify patterns that can suggest future activity. Technical
analysts believe that the historical performance of stocks and markets are indications of future
performance.
Cyclical – This is a method of analyzing the investments sensitive to business cycles and whose
performance is strongly tied to the overall economy. For example, cyclical companies tend to make
products or provide services that are in lower demand during downturns in the economy and higher
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demand during upswings. Examples include the automobile, steel, and housing industries. The stock
price of a cyclical company will often rise just before an economic upturn begins, and fall just before a
downturn begins. Investors in cyclical stocks try to make the largest gains by buying the stock at the
bottom of a business cycle, just before a turnaround begins.
Investment Strategies
Providence uses the following investment strategies when managing client assets and/or providing
investment advice:
Long term purchases. Investments held at least a year.
Short term purchases. Investments sold within a year.
Trading. Investments sold within thirty (30) days.
Use of Primary Method of Analysis or Strategy
Our primary method of analysis or strategy is buy and hold. Some of the risks involved with using this
method include the potential fluctuation of a security’s value even if it is a fixed income security or non-
equity.
Our primary strategy involves infrequent trading of securities. The infrequent trading of securities may
have a positive or negative impact on investment performance.
Risk of Loss
Past performance is not indicative of future results. Therefore, you should never assume that future
performance of any specific investment or investment strategy will be profitable. Investing in securities
(including stocks, mutual funds, and bonds) involves risk of loss. Depending on the different types of
investments there may be varying degrees of risk. Clients and prospective clients should be prepared to
bear investment loss including loss of original principal.
Because of the inherent risk of loss associated with investing, Providence is unable to represent,
guarantee, or even imply that our services and methods of analysis can or will predict future results,
successfully identify market tops or bottoms, or insulate you from losses due to market corrections or
declines. There are certain additional risks associated when investing in securities through the Firm’s
investment management program.
Market Risk: Either the stock market as a whole, or the value of an individual company, goes down
resulting in a decrease in the value of client investments. This is also referred to as systemic risk.
Equity (Stock): Market Risk Common stocks are susceptible to general stock market fluctuations and to
volatile increases and decreases in value as market confidence in and perceptions of their issuers
change. If you held common stock, or common stock equivalents, of any given issuer, you would
generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer.
Company Risk: When investing in stock positions, there is always a certain level of company or industry
specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be
reduced through appropriate diversification. There is the risk that the company will perform poorly or have
its value reduced based on factors specific to the company or its industry. For example, if a company’s
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employees go on strike or the company receives unfavorable media attention for its actions, the value of
the company may be reduced.
Fixed Income Risk: When investing in bonds, there is the risk an issuer will default on the bond and be
unable to make payments. In addition, individuals who depend on set amounts of periodically paid income
face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular
payments susceptible to the similar inflation risk.
ETF and Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional expenses
based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential
duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of
owning the underlying securities the ETF or mutual fund holds. Clients will also incur brokerage costs
when purchasing ETFs.
Management Risk: Your investment with my firm varies with the success and failure of our investment
strategies, research, analysis and determination of portfolio securities. If the Firm’s investment strategies
do not produce the expected returns, the value of the investment will decrease.
Item 9 – Disciplinary Information
Providence is required to disclose any legal or disciplinary events material to a client's or prospective
client's evaluation of our advisory business or the integrity of our management. The Firm and its
employees have not been involved in legal or disciplinary events related to past investment clients.
Item 10 – Other Financial Industry Activities and Affiliations
Providence is not an affiliated entity to any of the following institutions (1) broker/dealer, municipal
securities dealer, government securities dealer or broker, (2) futures commission merchant, commodity
pool operator or commodity trading adviser, (3) investment company or other pooled investment vehicle
(including a mutual fund, closed-end investment company, unit investment trust, private investment
company or hedge fund, and offshore fund), (4) other investment adviser (5) financial planning firm, (6)
banking or thrift institution, (7) accounting firm, (8) insurance company or agency, (9) pension consultant,
(10) real estate broker or dealer, or (11) sponsor or syndicator of limited partnerships. However,
Providence is an affiliated entity with Anthony Saccaro Law, A Professional Legal Corporation.
Insurance Activities
While our primary business involves providing investment and financial planning advice, Providence
employs staff who are licensed as independent insurance agents through various insurance companies.
You are never obligated or required to purchase insurance products through agents affiliated with the
Firm. However, based on your financial review staff may recommend a product through a third party to
assist in achieving your financial goals and objectives.
Third-Party Money Managers
Providence has developed a program, previously described in Item 5 of this disclosure brochure,
designed to allow us to recommend and select third-party money managers for you. We have selected
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Sound Income Strategies, LLC as the sole third-party manager. We may pay the third-party money
manager on your behalf or the third-party money manager may pay us a portion of the fees you are
charged. Please refer to Items 4 and 5 for full details regarding the programs, fees, conflicts of interest
and materials arrangements when Providence selects other investment advisers.
Legal Services
Anthony A. Saccaro, the President of Providence, is an attorney and founder/president of Anthony
Saccaro Law, A Professional Legal Corporation, and is duly licensed in the State of California. On
occasion, he may provide legal advice or services to clients on matters both related and unrelated to
advisory services. When acting in this capacity, he will be compensated on an hourly or fee basis for legal
services.
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
Code of Ethics Summary
All investment advisers are required to establish, maintain and enforce a Code of Ethics. Providence has
established a Code of Ethics which applies to all of the Firm’s associated persons. An investment adviser
is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full
disclosure of all material facts and to act solely in the best interest of each of our clients at all times.
Providence has a fiduciary duty to all clients. This fiduciary duty is considered the core underlying
principle for the Firm’s Code of Ethics which also covers our Insider Trading and Personal Securities
Transactions Policies and Procedures. Providence requires all of our supervised persons to conduct
business with the highest level of ethical standards and to comply with all federal and state securities
laws at all times.
Upon employment, affiliation or when policy changes occur, all supervised persons sign an
acknowledgement that they have read, understand and agree to comply with the Firm’s Code of Ethics.
Providence has the responsibility to affirm your interests are placed ahead of the interests of the Firm’s
supervised persons’ own investment interests. Full disclosure of all material facts and potential conflicts of
interest are provided to you prior to any services being conducted. Providence and our supervised
persons must conduct business in an honest, ethical and fair manner, avoiding all circumstances that
might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is
provided to give you a summary of our Code of Ethics. However, if you wish to review the Firm’s Code of
Ethics in its entirety, contact Anthony Saccaro at www.providencefinancialinc.com or call 800-256-3513.
Providence has established the following restrictions in order to ensure its fiduciary responsibilities:
We emphasize the unrestricted right of the client to specify investment objectives, guidelines,
and/or conditions on the overall management of their account
Associated persons or their immediate family members will not buy or sell securities for their
personal portfolio(s) where their decision is derived in whole or in part, by reason of the
associated person’s employment, unless the information is also available to the investing
public on reasonable inquiry. Providence associated persons shall not place their personal
investment interest(s) ahead of the Firm’s clients.
In general, the Firm and its associated persons may not purchase and sell securities being
considered for, or held by client accounts, without pre-clearance approval by the Providence
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Chief Compliance Officer (CCO). Moreover, if the security is a thinly traded security (with
average daily volume below 100,000 shares per day) investment personnel may be subject to
a blackout period from trading in such securities.
Providence or individuals associated with the Firm may buy or sell for their personal accounts
investment products identical to those recommended to clients. It is our express policy that
no person employed by Providence may enter an order to purchase or sell any security prior
to a transaction(s) being implemented for an advisory account (in accordance with standard
front running guidelines), and therefore, preventing such associated persons from benefiting
through transactions placed on behalf of advisory accounts.
Providence or individuals associated with the Firm may not participate in private placements
or initial public offerings (IPOs) without pre-clearance from the CCO.
The Firm and its associated persons shall act in accordance with all applicable federal and
state regulations governing registered investment advisory practices. Failure to observe the
restrictions may lead to disciplinary actions and/or termination.
Records will be maintained regarding all securities bought or sold by the Firm, associated
persons and if applicable, related entities. The CCO shall periodically review these records in
accordance with the Firm’s policy and procedures.
Associated persons failing to observe the noted restrictions may be subject to disciplinary
actions and/or termination.
Affiliated Person Insurance/Annuity Activity Conflict
As referenced in Item 10 – Other Financial Industry Activities and Affiliations associated person of
Providence are independent licensed as insurance agents. When acting in this capacity our associated
persons are able to receive a fixed up front commission of up to 10% on the sale of annuity products.
Clients are never obligated or required to purchase insurance products through agents affiliated with the
Providence.
Affiliate and Employee Personal Securities Transactions Disclosure
Providence and/or associated persons with the Firm may buy or sell for their personal account(s)
investment products identical to those recommended to clients. It is the expressed policy of Providence
that no person employed by the Firm may purchase or sell any security prior to a transaction(s) being
implemented for an advisory account (in accordance with standard front running guidelines), and
therefore, preventing such associated persons from benefiting through transactions placed on behalf of
advisory accounts. Providence may utilize batched orders to carry out this policy.
Item 12 – Brokerage Practices
You are under no obligation to act on our financial planning recommendations. If Providence assists with
the implementation of any recommendations, we are responsible to ensure you receive the best
execution pricing available at the time. The Firm acknowledges that we may utilize various non-affiliated
financial institutions for the execution of securities transactions and to custody assets. In certain cases,
we may recommend that clients execute transactions through non-affiliated broker-dealers. Providence
does not earn any commissions from unaffiliated broker-dealers. In any event, clients are under no
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obligation to act upon our recommendations and if a client elects to act on any of our recommendations,
the client is under no obligation to execute the transaction through the Firm, or any of the recommended
unaffiliated broker-dealers.
Providence actively recommends, and in some cases requires, that clients establish brokerage accounts
with the Schwab Institutional division of Charles Schwab & Company, Inc. (“Schwab”), a FINRA-
registered broker-dealer, Member SIPC, to maintain custody of clients’ assets and to effect trades for their
accounts.
Although Providence recommends clients establish accounts at Schwab, it is the client’s decision to
custody assets with Schwab. Providence is independently owned and operated and not affiliated with
Schwab. Providence can recommend additional unaffiliated broker-dealers to affect fixed income
transactions.
Schwab provides Providence with access to its institutional trading and custody services, which are
typically not available to Schwab retail investors. These services generally are available to independent
investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million
of the advisor’s clients’ assets are maintained at Schwab Institutional. These services are not contingent
upon Providence committing to Schwab any specific amount of business (assets in custody or trading
commissions). Schwab’s brokerage services include the execution of securities transactions, custody,
research, and access to mutual funds and other investments that are otherwise generally available only to
institutional investors or would require significantly higher minimum initial investment.
Schwab Institutional also makes available to Providence other products are services that benefit
Providence but may not directly benefit clients’ accounts. Many of these products and services can be
used to service all or some substantial number of Providence’ accounts, including accounts not
maintained Schwab.
Schwab’s products and services that assist Providence in managing and administering clients’ accounts
include software and other technology that (i) provides access to client account data (such as trade
confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders
for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of
Providence’ fees from some of its accounts; and (v) assist with back-office functions, recordkeeping and
client reporting.
Schwab Institutional also offers other services intended to help Providence manage and further develop
its business enterprise. These services include: (i) compliance, legal and business consulting; (ii)
publications and conferences on practice management and business succession; and (iii) access to
employee benefits providers, human capital consultants and insurance providers. Schwab Institutional will
discount or waive fees it would otherwise charge for some of these services or pay all or part of the fees
of a third-party providing these services to Providence. Schwab Institutional will also provide other
benefits such as educational events or occasional business entertainment of Providence personnel. While
as a fiduciary, Providence endeavors to act in its clients’ best interests, Providence’ recommendation that
clients maintain their assets in accounts at Schwab will take into account availability of some of the
foregoing products and services and other arrangements not solely on the nature of cost or quality of
custody and brokerage services provided by Schwab, which creates a conflict of interest.
Although we utilize our preferred brokerage platforms and require their use for standard brokerage
accounts, including but not limited to individual accounts, joint accounts, IRA accounts and trust or
corporate accounts, we can also manage and monitor accounts not held at platform we recommend.
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Through an arrangement with Pontera Solutions Inc., we are able to gain access to your accounts not
held at one of our primary brokerage platforms using the Pontera Order Management System.
The Pontera Order Management System is a third-party software platform which allows us to access and
trade the account. Clients receive a link from Pontera allowing them to connect an account(s) to the
platform.
These are typically, but not limited to, 401(k) and similar retirement-plan participant accounts. If you
choose to grant Pontera Solutions Inc. access to these accounts, we can regularly review the investment
options in the accounts, monitor them, rebalance and trade them to implement investment strategies the
same way we do for accounts under our management.
Trade Errors
We have implemented procedures designed to prevent trade errors; however, trade errors in client
accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade
errors in a manner that is in the best interest of the client. In cases where the client causes the trade
error, the client is responsible for any loss resulting from the correction. Depending on the specific
circumstances of the trade error, the client may not be able to receive any gains generated as a result of
the error correction. In all situations where the client does not cause the trade error, the client will be
made whole and any loss resulting from the trade error is absorbed by us if it is determined the error was
caused by the Firm. If the error is caused by the broker-dealer, the broker-dealer will be responsible for
handling the trade error. If an investment gain results from the correcting trade, the gain will remain in the
client’s account unless the same error involved other client account(s) which should also receive the
gains and it is not permissible for all clients to retain the gain. We may also confer with a client to
determine if the client should forego the gain (e.g., due to tax reasons).
Providence will never benefit or profit from trade errors.
Aggregation of Client Orders-Block Trading Policy
We may elect to purchase or sell the same securities for several clients at approximately the same time.
This process is referred to as aggregating orders, batch trading, or block trading and may be used by the
Firm when we believe such action may prove advantageous to clients. If and when we aggregate client
orders, the allocation of securities among client accounts is conducted on a fair and equitable basis.
Typically, the process of aggregating client orders is done in order to achieve better execution, to
negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis
in order to avoid differences in prices and transaction fees or other transaction costs that might be
obtained when orders are placed independently. Under this procedure, transactions will be averaged as
to price and are allocated among our clients in proportion to the purchase and sale orders placed for each
client account on any given day. If and when Providence initiates an aggregate regarding client orders for
the purchase or sale of securities, including securities in which we may invest, the Firm will do so in
accordance with the parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. Neither
Providence nor our associated persons receive any additional compensation or remuneration as a result
of aggregating trades.
Item 13 – Review of Accounts
Investment Supervisory Services
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Review Process
Client accounts are continually monitored. Accounts are reviewed in the context of each client's stated
investment objectives and guidelines. More frequent reviews may be triggered by material changes in
variables such as the client's individual circumstances, or the market, political or economic environment.
These accounts are reviewed by a properly licensed Investment Advisor Representative affiliated with
Providence.
Report Process
Clients receive transaction confirmations and statements at least quarterly from their account custodians.
Collectively, these reports list client’s account holdings, transactions and fees paid to Providence.
Upon the client’s request, the Firm provides applicable reports summarizing performance.
Item 14 – Client Referrals and Other Compensation
Additional Compensation
Providence is independently owned and operated and not affiliated with Schwab. Schwab and other firms
may also make available to us other products and services that may benefit the Firm, but which may not
benefit clients. These types of services will help us in managing and administering your accounts. These
include software and other technology that provide access to client account data (i.e., trade confirmations
and account statements); facilitate trade executions; provide research, pricing information, and other
market data. In addition, back-office functions including but not limited to facilitating fee payments from
the Firm’s client accounts; and assisting with record-keeping, and client reporting. Many of these services
may be used to service all or a substantial number of our accounts.
The only form of other compensation received from advisory services is the fees charged for providing
investment advisory services as described in Item 5 Fees and Compensation of this Brochure. The Firm
receives no other form of compensation in connection with providing investment advice.
SmartVestor™ Program
Providence Financial and Insurance Services has entered into an agreement with Ramsey Solutions™ to
receive referrals generated from Dave Ramsey’s radio shows, online marketing and other events. We
also receive marketing support and business consulting from Ramsey Solutions™. The formal agreement
is known as the SmartVestor™ Advertising Agreement. Through this agreement, we are able to advertise
through Ramsey Solutions™ both online and locally.
This is a paid arrangement whereby we have agreed to pay Ramsey Solutions™ a monthly fee for the
service and to be listed as a qualified investing professional in the Los Angeles, California and
surrounding areas. Individuals that contact Ramsey Solutions™ either directly or online will receive a list
of financial service providers in the individual’s area that have been approved by Ramsey Solutions™ for
the SmartVestor Program. The individual will receive the list and can view each referred company’s
information and will then decide to contact the selected financial service provider.
Ramsey Solutions™ does not proactively call or speak to individuals about Providence Financial And
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Insurance Services, but if an individual contacts Ramsey Solutions™ for a recommended financial
provider in the Los Angeles, California markets, the individual will be given Providence Financial and
Insurance Services’ name and contact information. At that time, Ramsey Solutions™ will provide the
individual a Solicitor Disclosure Statement (detailing among other things, the fee we pay to Ramsey
Solutions™) along with a copy of our Form ADV Part 2 brochure.
Providence Financial and Insurance Services is given the individual’s name and contact information that
they provide and that have expressed interest in hearing from a qualified investing professional.
Providence Financial and Insurance Services will attempt to contact them directly to answer any question
they have and if necessary, schedule an appointment with an Investment Advisor Representative.
Our payment to Ramsey Solutions™ is not based on the number of referrals provided and not based on
the number of new clients attained. We simply pay a set monthly account fee and set advertisement fee
for the service. The fee does not go up or down based on the number of referrals.
Individuals referred to Providence Financial and Insurance Services by Ramsey Solutions™ are not
required or obligated in any way to work with Providence Financial and Insurance Services. The selection
of an investment adviser is important and should not be based solely on marketing or referrals, including
referrals from Dave Ramsey. Individuals that find us through Dave Ramsey are free to work with any
investment adviser or financial professional of their own choosing.
Item 15 – Custody
Custody, as it applies to investment advisors, is defined by regulators as having access or control over
client funds and/or securities. In other words, custody is not limited to physically holding client funds and
securities. If an investment advisor has the ability to access or control client funds or securities, the
investment advisor is deemed to have custody and must ensure proper procedures are implemented.
Providence is deemed to have custody of client funds and securities because the Firm is given the
authority to deduct fees directly from client accounts. However, this is the only form of custody the Firm
maintains. It should be noted that authorization to trade in client accounts is not deemed by regulators to
be custody.
For accounts in which Providence is deemed to have custody, the Firm has established procedures to
ensure all client funds and securities are held at a qualified custodian in a separate account for each
client under the specific client’s name. Clients or an independent representative of the client will direct, in
writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name,
address and the manner in which the funds or securities are maintained. Finally, account statements are
delivered directly from the qualified custodian to each client, or the client’s independent representative, at
least quarterly. Clients should carefully review those statements and are encouraged to compare the
statements against reports received from Providence. When clients have questions concerning their
account statements, they should contact us or the qualified custodian preparing the statement.
Item 16 – Investment Discretion
When providing investment management services, Providence maintains trading authorization over your
Account and can provide management services on a discretionary basis. When discretionary authority is
granted, we will have the authority to determine the type of securities, the amount of securities that can
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be bought or sold, the broker or dealer to be used and the commission rates paid for your portfolio without
obtaining your consent for each transaction. However, it is the Firm policy to consult with you prior to
making significant changes in the account even when discretionary trading authority is granted.
Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing
of buying or selling an investment and the price at which the investment is bought or sold. If your
accounts are managed on a non-discretionary basis, you need to know that if we are not able to reach
you or you are slow to respond to our request, it can have an adverse impact on the timing of trade
implementations and we may not achieve the optimal trading price.
You will have the ability to place reasonable restrictions on the types of investments that may be
purchased in your account. You may also place reasonable limitations on the discretionary power granted
to the Firm as an attachment to Investment Adviser Agreement. The attachment must signed by all
parties and specifically set forth the requested limitations.
Item 17 – Voting Client Securities
Providence does not vote proxies on behalf of your account. It is the client’s responsibility to vote all
proxies for securities held in client accounts that are managed by the Firm. You will receive proxies
directly from your account custodian or transfer agent and such documents are not delivered by
Providence.
We do not offer any consulting assistance regarding proxy issues to clients.
Item 18 – Financial Information
Under no circumstances does Providence require or solicit payment of fees in excess of $500 per client
more than six months in advance of services rendered. Therefore, we are not required to include a
financial statement as part of this Brochure. The Firm has not been the subject of a bankruptcy petition at
any time during the past ten years.
Item 19 – Privacy Policy
In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain
financial institutions, such as investment advisor firms, to protect the privacy of customer information. In
situations where a financial institution does disclose customer information to non-affiliated third parties,
other than permitted or required by law, customers must be given the opportunity to opt out or prevent
such disclosure. Providence does not share or disclose customer information to non-affiliated third parties
except as permitted or required by law.
Providence is committed to safeguarding the confidential information of its clients. Providence holds all
personal information provided by clients in the strictest confidence and it is the objective of Providence to
protect the privacy of all clients. Except as permitted or required by law, Providence does not share
confidential information about clients with non-affiliated parties. In the event that there were to be a
change in this policy, Providence will provide clients with written notice and clients will be provided an
opportunity to direct Providence as to whether such disclosure is permissible.
To conduct regular business, Providence may collect personal information from sources such as:
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•
•
•
Information reported by the client on applications or other forms the client provides to Providence
Information about the client’s transactions implemented by Providence or others
Information developed as part of financial plans, analyses or investment advisory services
To administer, manage, service and provide related services for client accounts, it is necessary for
Providence to provide access to customer information within the firm and to non-affiliated companies, with
whom Providence has entered into agreements. To provide the utmost service, Providence may disclose
the information below regarding customers and former customers, as necessary, to companies to perform
certain services on Providence’s behalf.
•
•
•
•
Information Providence receives from the client on applications (name, Social Security number,
address, assets, etc.)
Information about the client’s transactions with Providence or others (account information,
payment history, parties to transactions, etc.)
Information concerning investment advisory account transactions
Information about a client’s financial products and services transaction with Providence
Since Providence shares non-public information solely to service client accounts, Providence does not
disclose any non-public personal information about Providence’s customers or former customers to
anyone, except as permitted by law. However, Providence may also provide customer information outside
of the firm as required by law, such as to government entities, consumer reporting agencies or other third
parties in response to subpoenas. In the event that Providence has a change to its customer privacy
policy that would allow it to disclose non-public information not covered under applicable law, Providence
will allow its clients the opportunity to opt out of such disclosure.
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