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PROVIDER FINANCIAL, INC.
WRAP PROGRAM BROCHURE
(APPENDIX 1 TO FIRM BROCHURE)
December 3, 2025
Mailing Address:
3091 East 98th St., Suite 200
Indianapolis, IN 46280
Phone: (317) 706-0890
Email: Robert.malmquist@provider-financial.com
Web Site: www.provider-financial.com
This wrap fee program brochure provides information about the qualifications and business
practices of Provider Financial, Inc. If you have any questions about the contents of this
brochure, please contact Robert L. Malmquist at (317) 706-0890. The information in this
brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority.
Additional information about Provider Financial, Inc. is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a
CRD number. The CRD number for the Firm is 168964.
ITEM 2 - MATERIAL CHANGES
We have no material changes to report since our last annual update to this firm brochure, which
was on March 5, 2025.
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ITEM 3 - TABLE OF CONTENTS
Item 2. Material Changes .............................................................................................................2
Item 3. Table of Contents .............................................................................................................3
Item 4. Services, Fees and Compensation ...................................................................................4
Item 5. Account Requirements and Types of Clients ................................................................6
Item 6. Portfolio Manager Selection and Evaluation .................................................................6
Item 7. Client Information Provided to Portfolio Managers ....................................................9
Item 8. Client Contact with Portfolio Managers ........................................................................9
Item 9. Additional Information ...................................................................................................9
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ITEM 4 - SERVICES, FEES AND COMPENSATION
SERVICES
We offer ongoing portfolio management services on a wrap account basis. Our management
services are based on the individual goals, objectives, time horizon, and risk tolerance of each
client. We evaluate the current investments of each client with respect to their risk tolerance
levels and time horizon. Clients may impose restrictions on investing in certain securities or
groups of securities by indicating in the written advisory agreement with Advisor.
We will request discretionary authority from clients in order to select securities and execute
transactions without permission from the client prior to each transaction. The client authorizes us
to have discretion by signing an advisory agreement.
The assets we manage are held at LPL Financial (“LPL”) on their SWM platform. LPL sponsors
our wrap program. LPL also acts as executing broker/dealer for transactions placed in program
accounts and provides other administrative services as described throughout this Brochure.
FEES
Fees for wrap accounts are calculated and billed quarterly in advance using the annualized rates
below.
Custodian Reported
Value of Account
$100,000 to $250,000
$250,001 to $500,000
$500,001 to $750,000
$750,001 to $1,250,000
$1,250,001 to $1,750,000
$1,750,001 to $3,000,000
$3,000,001 to $5,000,000
Over $5,000,000
Management
Fee
2.05%
1.75%
1.60%
1.40%
1.30%
1.15%
1.00%
Negotiable
The pro-rated first quarter’s management fee will be calculated on the Account’s initial value as
reported by the Account’s custodian. Thereafter, the management fee will be calculated on the
Account’s previous quarter-end value as reported by the Account’s custodian.
In a wrap account, clients pay a single annual advisory fee for advisory services and execution of
transactions. Clients do not pay brokerage commissions, markups or transaction charges for
execution of transactions in addition to the advisory fee. However, please see the following
disclosures regarding the conflicts of interest associated with a wrap-fee program.
Conflict of Interest Disclosure
Although clients do not pay a transaction charge for transactions in a SWM account, clients
should be aware that we pay LPL transaction charges for those transactions. The transaction
charges paid by us vary based on the type of transaction (e.g., mutual fund, equity or ETF) and
for mutual funds based on whether or not the mutual fund pays 12b-1 fees and/or recordkeeping
fees to LPL. Transaction charges paid by us for equities and ETFs are $7. For mutual funds, the
transaction charges range from $0 to $26.50 depending on whether they pay a recordkeeping
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and/or revenue sharing fee to LPL (Full Participating Fund versus Non-Participating Fund).
Because we pay the transaction charges in SWM accounts, there is a conflict of interest in cases
where the mutual fund is offered at both $0 and $26.50. Clients should understand that the cost
to us of transaction charges may be a factor that our considers when deciding which securities to
select and how frequently to place transactions in an SWM account. We attempt to mitigate this
conflict of interest by placing the clients’ interest ahead of our own through our fiduciary duty
and by implementing policies and procedures designed to address the conflict.
Other Types of Fees and Charges
Program accounts will incur additional fees and charges from parties other than us as noted
below. These fees and charges are in addition to the advisory fee paid to us. We do not share in
any portion of these third-party fees.
LPL, as the custodian and broker-dealer providing brokerage and execution services on program
accounts, will impose certain fees and charges. LPL notifies clients of these charges at account
opening and makes available a list of these fees and charges on its website at www.lpl.com. LPL
will deduct these fees and charges directly from the client’s program account.
There are other fees and charges that are imposed by other third parties that apply to investments
in program accounts. Some of these fees and charges are described below.
•
If a client’s assets are invested in mutual funds or other pooled investment products, clients
should be aware that there will be two layers of advisory fees and expenses for those assets.
Client will pay an advisory fee to the fund manager and other expenses as a shareholder of
the fund. Client will also pay us the advisory fee with respect to those assets. Most of the
mutual funds available in the program may be purchased directly. Therefore, clients could
generally avoid the second layer of fees by not using our management services and by
making their own investment decisions.
• Certain mutual funds impose fees and charges such as contingent deferred sales charges,
early redemption fees and charges for frequent trading. These charges apply if the client
transfers into or purchases such a fund with the applicable charges in a program account.
• Although only no-load and load-waived mutual funds can be purchased in a program
account, client should understand that some mutual funds pay asset-based sales charges or
service fees (e.g., 12b-1 fees) to the custodian with respect to account holdings.
•
If client holds a variable annuity as part of an account, there are mortality, expense and
administrative charges, fees for additional riders on the contract and charges for excessive
transfers within a calendar year imposed by the variable annuity sponsor.
Further information regarding fees assessed by a mutual fund, or variable annuity is available in
the appropriate prospectus, which is available upon request from us or from the product sponsor
directly.
Other Important Considerations
• The advisory fee is an ongoing wrap fee for investment advisory services, the execution of
transactions and other administrative and custodial services. The advisory fee may cost the
client more than purchasing the program services separately, for example, paying an advisory
fee plus commissions for each transaction in the account. Factors that bear upon the cost of
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the account in relation to the cost of the same services purchased separately include the type
and size of the account, historical and or expected size or number of trades for the account,
and number and range of supplementary advisory and client-related services provided to the
client.
• The advisory fee costs the client more than if assets were held in a traditional brokerage
account. In a brokerage account, a client is charged a commission for each transaction, but
the representative has no duty to provide ongoing advice with respect to the account. If the
client plans to follow a buy and hold strategy for the account or does not wish to purchase
ongoing investment advice or management services, the client should consider opening a
brokerage account rather than a program account.
• When we recommend the program to the client, we receive compensation because of the
client’s participation in the program. This compensation includes the advisory fee and other
compensation, such as bonuses, awards or other things of value offered by LPL to us or our
associated persons. The amount of this compensation is more than what we would receive if
the client participated in other LPL programs, programs of other investment advisors or paid
separately for investment advice, brokerage and other client services. Therefore, we have a
financial incentive to recommend a program account over other programs and services.
• The investment products available to be purchased in the program can be purchased by
clients outside of a program account, through broker-dealers or other investment firms not
affiliated with us.
Termination of Portfolio Management Services
A client may terminate the Investment Management Agreement for any reason at any time and,
within the first five (5) business days after signing the contract, without any cost or penalty.
Thereafter, the contract may be terminated at any time by giving ten (10) days written notice. To
cancel the Agreement, the client must notify firm in writing at to Provider Financial, Inc., 3091
East 98th St., Suite 200, Indianapolis, IN 46280 and return any materials received to that date.
Because we charge in advance, any client that terminates their contract within a quarter will
receive a prorated refund of fees that is based on the amount of time elapsed during the
termination quarter. For example, if a client cancels on 45 days in to a 90 day quarter, the client
will receive a refund of 50% of the fees. (45 days divided by 90 days equal 50 percent.) Please
note the prorated refund may be adjusted for additional deposits and withdrawals to the advisory
account within the termination quarter.
ITEM 5 - ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
We offer our services to individuals, high net worth individuals and corporations or other
business entities. We do not require a minimum account size to become a client.
ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION
In our wrap program, we do not select, review or recommend other investment advisors or
portfolio managers. We, through our associated persons, are responsible for the investment
advice and management offered to clients. For more information about associated person
managing the account, client should refer to the Brochure Supplement (ADV Part 2B) for the
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associated person, which client should have received along with this Brochure at the time client
opened the account.
LPL performs certain administrative services for us, including generation of quarterly (or
monthly, if requested) statements and performance reports for program accounts. The client will
receive an individual quarterly (or monthly, if requested) statement and performance report that
provides performance information on a time-weighted basis. The performance reports are
intended to inform clients as to how their investments have performed for a period, both on an
absolute basis and compared to leading investment indices.
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
When we manage a client’s portfolio, we use the following types of analysis:
Fundamental analysis is a technique that attempts to determine a security’s value by focusing on
underlying factors that affect a company's actual business and its future prospects. The analysis
is performed on historical and present data. On a broader scope, one can perform fundamental
analysis on industries or the economy as a whole. The term refers to the analysis of the economic
well-being of a financial entity as opposed to only its price movements. The risk associated with
fundamental analysis is that despite that appearance that a security is undervalued, it may not rise
in value as predicted.
Technical Analysis 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. The risk associated with technical analysis is that there is no broad
consensus among technical traders on the best method of identifying future price movements.
Tactical Asset Allocation is an active management portfolio strategy that rebalances the
percentage of assets held in various categories in order to take advantage of market pricing
anomalies or strong market sectors. This strategy is designed to allow portfolio managers to
create extra value by taking advantage of certain situations in the marketplace. It is as a
moderately active strategy because portfolio managers return to the portfolio's original strategic
asset mix when desired short-term profits are achieved.
Our analysis of securities and advice relating thereto may be based upon information obtained
from financial newspapers and magazines, research materials prepared by others, corporate
ratings services, and annual reports, prospectuses and filings made with the Securities and
Exchange Commission. We also utilize computer models for performance analysis, asset
allocation and risk management.
It is important to note that no methodology or investment strategy is guaranteed to be successful
or profitable. It is also important that you understand the concept and risks inherent in
exchanging an investment from one position to another. Some investment decisions result in
profit and others in losses. Our firm and your representative cannot guarantee that the objectives
of any investment program will be achieved. Furthermore, it is important that you understand
that the exchange of shares of one mutual fund for shares of another mutual fund is treated as a
sale for federal income tax purposes, and that capital gains or losses may be realized unless you
are eligible for tax deferral under a qualified retirement plan.
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All investments bear different types and degrees of risk and investing in securities involves risk
of loss that clients should be prepared to bear. While we use investment strategies that are
designed to provide appropriate investment diversification, some investments have significantly
greater risks than others. Obtaining higher rates of return on investments entails accepting higher
levels of risk. Recommended investment strategies seek to balance risks and rewards to achieve
investment objectives. A client needs to ask questions about risks he/she does not understand,
we would be pleased to discuss them.
The account investment management is determined by the stated investment objectives of the
client (i.e., current income, balanced, growth and income, growth and maximum growth). Your
representative is responsible for developing and determining the investment strategies that will
be used when managing your accounts. This strategy is based on your individual financial
situation, goals, and objectives. Your representative is responsible for monitoring your portfolios
and, when appropriate, reallocating the portfolios based on changing market conditions, changes
in your individual circumstances, or other factors. If the account is managed on a non-
discretionary basis, your representative will consult you prior to reallocating securities in the
account. Reallocations are implemented in discretionary accounts without prior notice to clients.
If your individual situation changes, you should notify your representative, who will assist you in
revising the current portfolio and/or prepare an updated client profile so that he/she can
determine if a different model portfolio would be appropriate to your new situation. You may
also directly contact the third-party advisor managing the account.
We use several types of securities in client portfolios including, but not limited to, mutual funds,
exchange traded funds, stocks, money market funds.
An investment could lose money over short or even long periods. A client should expect his/her
account value and returns to fluctuate within a wide range, like the fluctuations of the overall
stock and bond markets. A client’s account performance could be hurt by:
• Stock market risk: The chance that stock prices overall will decline. Stock markets tend
to move in cycles, with periods of rising stock prices and periods of falling stock prices.
• Interest rate risk: The chance that bond prices overall will decline because of rising
interest rates.
• Manager risk: The chance that the proportions allocated to the various securities will
cause the client’s account to underperform relevant to benchmarks or other accounts with
a similar investment objective.
• International investing risk: Investing in the securities of non-U.S. companies involves
special risks not typically associated with investing in U.S. companies. Foreign securities
tend to be more volatile and less liquid than investments in U.S. securities, and may lose
value because of adverse political, social or economic developments overseas or due to
changes in the exchange rates between foreign currencies and the U.S. dollar. In addition,
foreign investments are subject to settlement practices, as well as regulatory and financial
reporting standards, that differ from those of the U.S.
• Liquidity risk: One common risk associated with private placements and REITs is a
relative lack of liquidity due to the highly customized nature of the investment.
Moreover, the full extent of returns is often not realized until maturity. Because of this,
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these products tend to be more of a buy-and-hold investment decision rather than a means
of getting in and out of a position with speed and efficiency.
• Credit risk: This is the risk that an issuer of a bond could suffer an adverse change in
financial condition that results in a payment default, security downgrade, or inability to
meet a financial obligation.
• Inflation Risk: This is the risk that inflation will undermine the performance of your
investment and/or the future purchasing power of your assets.
VOTING CLIENT SECURITIES
We do not accept authority to vote client securities. Clients retain the right to vote all proxies that
are solicited for securities held in the account. Clients will receive proxies or other solicitations
from the custodian of assets. If clients have questions regarding the solicitation, they should
contact us or the contact person that the issuer identifies in the proxy materials. In addition, we
do not accept authority to take action with respect to legal proceedings relating to securities held
in the account.
ITEM 7 - CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS
In our wrap program, we are responsible for account management; there is no separate portfolio
manager involved. We obtain the necessary financial data from the client and assist the client in
setting an appropriate investment objective for the account. We obtain this information by having
the client complete an advisory agreement and other documentation. Clients are encouraged to
contact us if there have been any changes in the client’s financial situation or investment
objectives or if they wish to impose any reasonable restrictions on the management of the
account or reasonably modify existing restrictions. Client should be aware that the investment
objective selected for the program is an overall objective for the entire account and may be
inconsistent with a particular holding and the account’s performance at any time. Client should
further be aware that achievement of the stated investment objective is a long-term goal for the
account.
ITEM 8 - CLIENT CONTACT WITH PORTFOLIO MANAGERS
Client should contact us at any time with questions regarding program account.
ITEM 9 - ADDITIONAL INFORMATION
DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events within the past 10-years that would be material to your evaluation of us or the
integrity of our management.
We have no information applicable to this Item because we have not been the subject of any
administrative, civil, criminal or regulatory proceedings.
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Our owner, Robert L. Malmquist, is also licensed as a registered representative of LPL Financial
Corporation (“LPL”), a full-service broker/dealer and member FINRA/SIPC. As a registered
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representative, Mr. Malmquist can affect securities transactions and he receives separate
compensation for effecting any securities transactions. Mr. Malmquist spends the majority of his
time involved these activities.
This presents a conflict of interest when the client elects to implement Mr. Malmquist’s
recommendations and selects him to execute those transactions. In this case, Mr. Malmquist
receives both fees as advisor representative and commissions as registered representative or
insurance agents. As a registered representative, he receives compensation from the sale of
mutual funds, 12(b)-1 distribution fees, variable annuity sales commissions or trail commissions.
The 12(b)-1 distribution fees, sales charges and other fee arrangements will be disclosed upon
the client’s request and are typically described in the applicable fund and/or annuity prospectus.
Any fees or other compensation received by Mr. Malmquist in his separate capacity as registered
representative will be received to the extent permitted by applicable law.
Because of these compensation arrangements, a conflict of interest exists in connection with Mr.
Malmquist recommending particular investments for a client’s account. Clients have sole
discretion whether to implement any or all of Mr. Malmquist’s recommendations. In addition,
clients are free to select any broker/dealer they wish to implement recommendations.
Mr. Malmquist is also a licensed independent insurance agent (Life and Health Licensed). As
such, he can affect insurance transactions and receives separate compensation for effecting any
insurance transactions. With the ability to work as a client’s insurance agent and investment
adviser representative, this is a conflict of interest because each service pays a separate fee or
commission. However, Mr. Malmquist attempts to mitigate any conflicts of interest to the best
of his ability by placing the client’s interests ahead of his own and through the implementation of
policies and procedures that address the conflict. Also, clients are never obligated to purchase
recommended insurance products through Mr. Malmquist.
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING
Our Approach to Conflicts of Interest
Conflicts of interest that arise while providing investment management services are described
throughout this brochure, as are some of our policies and procedures designed to address specific
conflicts of interest, such as our Code of Ethics and personal trading practices.
We have a compliance program in place that is intended to identify, mitigate and, in some
instances, prevent actual and potential conflicts of interest, ensure compliance with legal and
regulatory requirements and ensure compliance with client investment guidelines and
restrictions. Our compliance program includes written policies and procedures that we believe
are reasonably designed to prevent violations of applicable law and regulations.
Code of Ethics
According to the Investment Advisers Act of 1940, an investment advisor is considered a
fiduciary and has a fiduciary duty to clients. The applicant has established a Code of Ethics to
comply with the requirements of Section 204(A)-1 of the Investment Advisors Act of 1940 that
reflects fiduciary obligations and those of its supervised persons and requires compliance with
federal and state securities laws. Our Code of Ethics covers all individuals that are classified as
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“supervised persons”. All employees, officers, directors and investment advisor representatives
are classified as supervised persons. We require our supervised persons to consistently act in
their client’s best interests in all advisory activities. We impose certain requirements on its
affiliates and supervised persons to ensure that they meet the firm’s fiduciary responsibilities to
our clients. The standard of conduct required is higher than ordinarily required and encountered
in commercial business.
This section is only intended to provide current and potential clients with a description of the
applicant Code of Ethics. If you wish to review the Code of Ethics in its entirety, you may
request a copy in writing. Your request will be provided promptly.
Participation or Interest in Client Transactions
LPL, our broker/dealer may execute securities transactions on our behalf or on behalf of your
representative. We, LPL and/or your representative can receive advisory fees and broker/dealer
commissions for the sale of securities placed under our management. The receipt of
compensation from a variety of sources is a conflict of interest. We encourage you to review this
ADV closely and discuss any potential conflicts of interest with your representative.
We will process brokerage security transactions through LPL so long as we determine that
executing the transactions through our broker/dealer fulfills our duty of best execution. We
consider certain factors when selecting a broker/dealer and determining the reasonableness of
commissions. Please refer to the section titled “Brokerage Practices” for more information.
Policy Regarding Engaging in Agency Cross Transactions in Advisory Accounts
It is our policy to prohibit representatives from engaging in agency cross transactions where
representatives act as brokers for both the buy and sell of a single security between two different
clients for which the representatives receive compensation in the form of an agency commission
or principal mark-up for the trades. Should we adopt a different policy in this area, we will
observe all rules and regulations in accordance with the disclosure and consent requirements of
Section 206(3) of the Advisers Act. Additionally, we are aware that such transactions can only
occur if we can ensure that we meet our duty of best execution for the client.
Policy Regarding Engaging in Principal Trading Involving Advisory Accounts
We do not permit principal transactions to be effected in advisory accounts. LPL does not make
a market in securities. LPL may engage in riskless principal transactions for certain fixed
income securities. A riskless principal transaction is a trade in which a broker or dealer, receives
an order to buy or sell a security and purchases the security in a simultaneous offsetting
transaction. Potential conflicts of interest exist between your interests, our interests and LPL.
Current federal securities regulations do not require that firms when trading as a principal
disclose their mark-ups on riskless principal transactions. Mark-ups may vary by security.
Personal Trading
We and our representatives will recommend a buy, sell, or hold a position in securities identical
to the securities recommended to you, at or about the same time that they or a related person
buys or sells the same securities for their own or a related person’s account. It is our policy that
no supervised person will put his/her interest before your interests. Our firm and our
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representatives cannot trade ahead of any client or trade in a way that would cause the supervised
person to obtain a better price than the price a client would obtain.
Our Pre-Clearance and Restricted Securities Policy
Due to our affiliation with other investment companies, investment advisors, and broker dealers,
LPL, on our behalf, maintains a Restricted and Pre-Clearance Equity List, which may limit our
firm and the representative's ability to transact in certain equities on your behalf in a
discretionary advisory program. Your representative may not be able to place certain transactions
or may experience delays in submitting certain transactions on your behalf based on any pre-
clearance or pre-approval requirements implemented by the firm. You may receive a worse price
than what you might receive if you placed the transaction through another investment advisor
representative not affiliated with LPL and not subject to any trading restrictions. These trading
restrictions are subject to change without notice.
REVIEW OF ACCOUNTS
Frequency of Account Reviews
Our owner, Robert Malmquist, reviews the positions on a continuous basis. Mr. Malmquist will
also meet (either in person or by telephone) with a client on a quarterly, semi-annual or annual
basis as requested by the client.
Review Triggers
The calendar is the triggering factor. Factors triggering an account review may include material
market, economic or political events, and changes in your financial or personal situation or
performance of the account in general.
Reports and Account Statements
The client will receive quarterly (or monthly, if requested) statements and performance reports
from their account’s custodian. We urge you to carefully review such statements.
To the extent you receive performance reports from your representative, we urge you to compare
performance reports received with account statements received from the custodian. Inquiries or
concerns regarding the account, including performance reports, should be directed to the
investment advisor firm at the phone number listed on the account statement. Each representative
then decides whether to provide these reports to his or her clients. Performance information
provided by your representative is believed to be accurate but cannot be guaranteed. Your
representative may or may not include variable annuity account position information within
performance reports. Neither our firm nor your representative can guarantee the accuracy of
fund values, securities and other information obtained from third parties.
CLIENT REFERRALS AND OTHER COMPENSATION
We do not pay for client referrals or use solicitors.
Our representatives are incentivized to join and remain affiliated with our current broker/dealer,
LPL, through compensation arrangements that include bonuses, enhanced pay-outs, forgivable
loans and/or business transition loans. The receipt of such compensation is financial incentive
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and conflict of interest. We encourage you to review this ADV closely and discuss any conflicts
of interest with your representative.
Additionally, our owner, Mr. Malmquist, participates in LPL’s Club Program, which is a
performance-based incentive program based on advisory fee revenue plus gross dealer
concession. Qualifying advisers receive airfare and hotel accommodations for LPL’s annual
conference. This creates a financial incentive to use and recommend LPL’s services. Mr.
Malmquist attempts to mitigate any conflicts of interest to the best of his ability by placing the
client’s interests ahead of his own and through the implementation of policies and procedures
that address the conflict.
FINANCIAL INFORMATION
We do not have any financial impairment that will preclude us from meeting our contractual
commitments to you. We do not serve as a custodian for your funds or securities. At no time will
fees of more than $1200 be charged six or more months in advance by our firm or your
representative. We have established policies and procedures designed to prevent the collection
of fees greater than $1200 six or more months in advance. As such, a balance sheet is not
required to be provided to you at this time.
CUSTODY
LPL is the qualified custodian and maintains custody of client funds and securities in a separate
account for each client under the client’s name. LPL as a qualified custodian sends account
statements showing all transactions, positions, and all deposits and withdrawals of principal and
income. LPL sends account statements monthly when the account has had activity or quarterly if
there has been no activity. Clients should carefully review those account statements.
Although most securities available in program accounts are custodied at LPL, there are certain
securities managed as part of the account that are held at third parties, and not at LPL. For
example, variable annuities, hedge funds and managed futures are often held directly with the
investment sponsor. For those outside positions, client will receive confirmations and statements
directly from the investment sponsor.
For outside positions not custodied at LPL, LPL may receive information (e.g., number of shares
held and market value) from the investment sponsor and display that information on statements
and reports prepared by LPL. Such information also may be used to calculate performance in
performance reports prepared by LPL. Although we believe that the information provided by
LPL is accurate, we recommend that clients refer to the statements and reports received directly
from the investment sponsor and compare them with the information provided in any statements
or reports from LPL. The statements and reports provided by LPL with respect to outside
positions should not replace the statements and reports received directly from the investment
sponsor.
BROKERAGE PRACTICES
In our wrap program, we require that clients direct LPL as the sole and exclusive broker-dealer
to execute transactions in the account. LPL sponsors our wrap program. Because our associated
persons are licensed with LPL, this presents a conflict of interest. Clients should understand that
not all advisors require their clients to direct brokerage. By directing brokerage to LPL, clients
may be unable to achieve the most favorable execution of client transactions. Therefore, directed
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brokerage may cost clients more money. Because we receive benefits from LPL, we have a
financial incentive to use their brokerage and custodian services. We attempt to mitigate any
conflicts of interest to the best of our ability by placing the client’s interests ahead of our own
and through the implementation of policies and procedures that address the conflict.
We may receive support services and/or products from LPL, which assist us to better monitor
and service program accounts maintained at LPL. These support services and/or products may
be received without cost, at a discount, and/or at another negotiated rate, and may include the
following:
investment-related research
•
• pricing information and market data
• software and other technology that provide access to client account data
• compliance and/or practice management-related publications
• consulting services
• attendance at conferences, meetings, and other educational and/or social events
• marketing support
• computer hardware and/or software
• other products used by us in furtherance of our investment advisory business operations
Clients do not pay more for services as a result of this arrangement. There is no corresponding
commitment made by us to LPL or any other entity to invest any specific amount or percentage
of client assets in any specific securities as a result of the arrangement.
We often aggregate transactions in equity and fixed income securities for a client with other
clients to improve the quality of execution. When transactions are so aggregated, the actual
prices applicable to the aggregated transactions will be averaged, and the client account will be
deemed to have purchased or sold its proportionate share of the securities involved at the average
price obtained. We sometimes determine not to aggregate transactions, for example, based on
the size of the trades, the number of client accounts, the timing of the trades, the liquidity of the
securities and the discretionary or non-discretionary nature of the trades. If we do not aggregate
orders, some clients purchasing securities around the same time may receive a less favorable
price than other clients. This means that this practice of not aggregating may cost clients more
money.
Provider Financial, Inc.
Page 14
Appendix 1 – 12/3/2025