Overview
- Headquarters
- Cupertino, CA
- Total Firm Assets
- $77 million
- Average High-Net-Worth Client Portfolio Size
- $1.6 million
Fee Structure
Primary Fee Schedule (ADV PART 2A AND PART 2A APPENDIX 1)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.25% |
| $500,001 | $1,000,000 | 1.00% |
| $1,000,001 | $2,500,000 | 0.90% |
| $2,500,001 | $5,000,000 | 0.80% |
| $5,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,250 | 1.12% |
| $5 million | $44,750 | 0.90% |
| $10 million | $69,750 | 0.70% |
| $50 million | $269,750 | 0.54% |
| $100 million | $519,750 | 0.52% |
Clients
- High-Net-Worth Share of Firm Assets
- 76.95%
- Number of High-Net-Worth Clients
- 37
- Total Client Accounts
- 179
- Discretionary Accounts
- 179
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 117378
Additional Brochure: ADV PART 2A AND PART 2A APPENDIX 1 (2026-05-19)
View Document Text
Item 1 - Cover Page
Part 2A of Form ADV: Firm Brochure
Pruneyard Financial Group, Inc.
22801 Longdown Road Cupertino, CA 95014
May 19th, 2026
Telephone: 408 377 4444
Email: service@pruneyardfinancial.com
Web Address: https://pruneyardfinancial.com
This brochure provides information about the qualifications and business practices of Pruneyard
Financial Group, Inc., a registered investment adviser. 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. Registration with the SEC or with any state securities authority does not imply a certain level
of skill or training.
If you have any questions about the contents of this brochure, please contact us at the telephone
number or email address listed above. Additional information about Pruneyard Financial Group, Inc. is
available on the SEC's website at adviserinfo.sec.gov. You can search this site by a unique identifying
number, known as a CRD number. Our firm's CRD number is 117378.
Page 1 of 32
Item 2 - Material Changes
Pruneyard Financial Group, Inc. will ensure that clients receive a summary of any material changes to
this and subsequent disclosure brochures within 120 days after the Firm’s fiscal year end, December 31.
This means that if there were any material changes over the past year, clients will receive a summary of
those changes no later than April 30 of the following year. At that time, Pruneyard Financial Group, Inc.
will also offer a copy of its most current disclosure brochure and may also provide other ongoing
disclosure information about material changes as necessary.
Clients and prospective clients can always receive the most current disclosure brochure for Pruneyard
Financial Group, Inc.at any time by contacting the Firm.
Since our filing dated 04/24/2025, we have the following changes to report:
Item 4: We are switching from SEC to State registration.
Item 4: We are no longer offering pension consulting services.
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Item 3 - Table of Contents
Item 1 - Cover Page ........................................................................................................................................ 1
Item 2 - Material Changes ............................................................................................................................. 2
Item 3 - Table of Contents ............................................................................................................................ 3
Item 4 - Advisory Business ............................................................................................................................ 4
Item 5 - Fees and Compensation .................................................................................................................. 4
Item 6 - Performance-Based Fees and Side-By-Side Management .............................................................. 6
Item 7 - Types of Clients ................................................................................................................................ 6
Item 8 - Methods of Analysis, Strategies and Risk of Loss ............................................................................ 6
Item 9 - Disciplinary Information .................................................................................................................. 9
Item 10 - Other Financial Industry Activities and Affiliations ....................................................................... 9
Item 11 - Code of Ethics and Personal Trading ........................................................................................... 10
Item 12 - Brokerage Practices ..................................................................................................................... 11
Item 13 - Review of Accounts ..................................................................................................................... 14
Item 14 - Client Referrals and Other Compensation .................................................................................. 14
Item 15 - Custody ........................................................................................................................................ 14
Item 16 - Investment Discretion ................................................................................................................. 15
Item 17 - Voting Client Securities................................................................................................................ 16
Item 18 - Financial Information .................................................................................................................. 16
Item 19: Requirements For State Registered Advisers ............................................................................... 16
Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure ................................................................ 18
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Item 4 - Advisory Business
Pruneyard Financial Group, Inc. (“PFG”) is an investment adviser registered with the state of California,
with its principal office located in Cupertino, California. The Firm has been in business since November
2001. The principal owner and Chief Compliance Officer is John D. Masegian
Portfolio Management
Our firm provides discretionary portfolio management to individuals, families, and small business (e.g.,
investment advice, portfolio management, and financial planning) through the PFG Money Management
Program (the "Program"), a wrap fee program managed and sponsored by PFG Please refer to our Form
ADV, Part 2A, Appendix 1: Wrap Fee Program Brochure for further information.
Financial Planning
In connection with portfolio management services we may address broader financial topics such as
retirement planning, cash flow considerations, and general financial goals. For example,
recommendations may be made that the client begin or revise investment programs, revise wills or
trusts, obtain, or revise insurance coverage, commence, or alter retirement savings, or establish
education or charitable giving programs. These discussions are incorporated into the investment
management process and are not offered as a separate or standalone financial planning service. The
Firm does not prepare or deliver comprehensive written financial plans and does not charge a separate
fee for financial planning services. The Firm does not receive compensation from the sale of securities,
insurance, real estate, or other products in connection with these services. Implementation of any
recommendation is at the discretion of the client. If the client elects to act on our recommendations, the
client is under no obligation to affect the transaction through us.
Services Tailored to Clients’ Needs
Services are provided based on a client ’s specific needs within the scope of the services provided as
discussed above. The client may provide impose restrictions on investing. A review of the information
provided by the client regarding the client’s current financial situation, goals, and risk tolerances will be
performed and advice will be provided that is in line with available information.
Regulatory Assets Under Management
As of 12/31/2025, we managed $77,025,743 of client assets on a discretionary basis.
Item 5 - Fees and Compensation
This section details the fees and compensation we receive for our services. Lower fees for comparable
services may be available from other sources.
Fee Schedule
Portfolio Management Fees
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The Firm’s advisory services are offered primarily through a wrap fee program. Clients participating in
the wrap fee program pay a single asset-based fee (the “wrap fee”) for investment advisory services.
The wrap fee is calculated as a percentage of assets under management not to exceed 1.25%.
Clients may either agree to a single annual billing rate based on a percentage of AUM, or a tiered fee
based on total household AUM. Our tiered fee rates are as follows
Rate Tier
Annual Fee Monthly Rate
Total Household Assets Under
Management*
1
$0.00 - $499,999.99
1.25%
0.10%
2
$500,000 - $999,999.99
1.00%
0.08%
3
$1,000,000 - $2,499,999.99
0.90%
0.08%
4
$2,500,000 - $4,999,999.99
0.80%
0.07%
5
$5,000,000 +
0.50%
0.04%
Our Tiered Pricing is graduated. For example, for a sample $1,000,000 account:
For that portion of the client’s account(s) up to $499,999.99, PFG will charge an annual fee of
1.25%, resulting in an annual fee of $6,250 on the first $500,000; plus
For that portion of the client’s account(s) exceeding $500,000 but not exceeding $1,000,000, the
Adviser will charge an annual fee of 1.00%, resulting in an annual fee of $5,000 on the portion
between $500,000 and $1,000,000.
This would result in a total annual fee of $11,250 on the sample $1,000,000 account.
Our advisory fees are negotiated and agreed upon prior to our onboarding a client. Client facts,
circumstances and needs are considered in determining the fee schedule, including the complexity of
the client, assets to be placed under advisement, related accounts, and account composition and
reports, among other factors. The specific fee schedule is identified in each contract between our firm
and the client. The client should be aware that lower fees for comparable services may be available from
other sources.
Clients should be aware that the wrap fee may be higher than the aggregate cost of paying for advisory
services and transaction costs separately, depending on the level of trading activity in the account.
Additional details regarding the Program, including the services provided and the fees and expenses
covered by the wrap fee, are described in the Firm’s Form ADV Part 2A Appendix 1 (Wrap Fee Program
Brochure), which clients are encouraged to review carefully.
Clients may terminate our services via written notice to the firm. You will incur a pro rata charge for
services rendered prior to the termination of the agreement, which means you will incur advisory fees
only in proportion to the number of days in the month during which you are a client.
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Payment of Fees
Program fees are charged monthly in arrears. If management begins after the start of a month, Program
fees will be prorated accordingly. When authorized by the client, fees will be debited from the account in
accordance with the terms set forth in the Investment Management Services Agreement. See Item 15
for more information on direct fee deduction.
Other types of fees or expenses
The wrap fee is designed to cover most costs associated with the Program, including our investment
management (e.g., investment advice, portfolio management and financial planning), administrative
expenses (e.g., custodial fees), and brokerage costs (to the extent trades are conducted through Schwab
or Fidelity). The Program fees do not include expenses of mutual funds and electronically traded funds
such as fund management fees charged to each fund's investors.
Prepayment of Fees
PFG does not collect fees in advance.
Outside Compensation For the Sale of Securities to Clients
Neither PFG nor its supervised persons accept any compensation for the sale of investment products,
including asset-based sales charges or service fees from the sale of mutual funds.
Item 6 - Performance-Based Fees and Side-By-Side Management
PFG does not charge performance-based fees or utilize side-by-side management.
Item 7 - Types of Clients
PFG provides advisory services to the following types of clients:
Individuals (other than high net worth individuals)
High net worth individuals
Corporations or small businesses
The Firm does not require a minimum account size
Item 8 - Methods of Analysis, Strategies and Risk of Loss
Methods of Analysis and associated risks
We use the following methods of analysis in formulating our investment strategies:
Charting. In this type of technical analysis, we review charts of market and security activity to better
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identify when the market is moving up or down and to predict how long the trend may last and when
that trend might reverse.
Technical Analysis. We analyze past market movements and apply that analysis to the present to better
recognize recurring patterns of investor behavior and potentially predict future price movement.
Technical analysis does not consider the underlying financial condition of a company. This presents a risk
that a poorly managed or financially unsound company may underperform regardless of market
movement.
Risks. The risk of market timing based on technical analysis is that charts might not accurately
predict future price movements. Current prices of securities may reflect all information known
about the security and day to day changes in market prices of securities may follow random
patterns and may not be predictable with any reliable degree of accuracy.
Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic
and financial factors (including the overall economy, industry conditions, and the financial condition and
management of the company itself) to determine if the company is underpriced (indicating it may be a
good time to buy) or overpriced (indicating it may be time to sell).
Risks. Fundamental analysis does not attempt to anticipate market movements. This presents a
potential risk, as the price of a security can move up or down along with the overall market
regardless of the economic and financial factors considered in evaluating the stock.
Quantitative Analysis. We use mathematical models to better obtain more accurate measurements of a
company's quantifiable data, such as the value of share price or earnings per share and predict changes
to that data.
Risks. A risk in using quantitative analysis is that the models used may be based on assumptions
that prove to be incorrect.
Qualitative Analysis. We subjectively evaluate non-quantifiable factors such as quality of management,
labor relations, and strength of research and development factors not readily subject to measurement
and predict changes to share price based on that data.
Risks. A risk is using qualitative analysis is that our subjective judgment may prove incorrect.
Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager of the
mutual fund or ETF to better determine if that manager has demonstrated an ability to invest over a
period and in different economic conditions. We also look at the underlying assets in a mutual fund or
ETF to better determine if there is a significant overlap in the underlying investments held in other
fund(s) in the client's portfolio. We also monitor the funds or ETFs to better determine if they are
continuing to follow their stated investment strategy.
Risks. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful may not be
able to replicate that success in the future. In addition, as we do not control the underlying
investments in a fund or ETF, managers of different funds held by the client may purchase the
same security, increasing the risk to the client if that security were to fall in value. There is also a
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risk that a manager may deviate from the stated investment mandate or strategy of the fund or
ETF, which could make the holding(s) less suitable for the client's portfolio.
Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies
whose securities we purchase and sell, the rating agencies that review these securities, and other publicly
available sources of information about these securities, are providing accurate and unbiased data. While
we are alert to indications that data may be incorrect, there is always a risk that our analysis may be
compromised by inaccurate or misleading information.
Investment Strategies
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Long-term purchases. We purchase securities with the idea of holding them in the client's account for a
year or longer. We typically employ this strategy when:
We believe the securities to be currently undervalued, and/or
We want exposure to a particular asset class over time, regardless of the current projection for
this class.
Risks. A risk in a long-term purchase strategy is that by holding the security for this length of time,
we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our
predictions are incorrect, a security may decline sharply in value before we make the decision to
sell.
Short-term purchases. When utilizing this strategy, we purchase securities with the idea of selling them
within a relatively short time (typically less than a year). We do this to better take advantage of
conditions that we believe will soon result in a price swing in the securities we purchase.
Risks. Risks include liquidity, economic stability, and inflation, in addition to the long- term
trading risks listed above. Frequent trading can affect investment performance, particularly
through increased brokerage and other transaction costs and taxes.
Options writing. We may use options as an investment strategy. An option is a contract that gives the
buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price
on or before a certain date. An option, just like a stock or bond, is a security. An option is also a
derivative because it derives its value from an underlying asset.
The two types of options we utilize are calls and puts:
A call gives us the right to buy an asset at a certain price within a specific period. We will buy a
call if we have determined that the stock will increase substantially before the option expires.
A put gives us the holder the right to sell an asset at a certain price within a specific period. We
will buy a put if we have determined that the price of the stock will fall before the option
expires.
We will use options to speculate on the possibility of a sharp price swing. We will also use options to
"hedge" a purchase of the underlying security; in other words, we will use an option purchase to limit
the potential upside and downside of a security we have purchased for your portfolio.
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We use "covered calls", in which we sell an option on security you own. In this strategy, you receive a
fee for making the option available, and the person purchasing the option has the right to buy the
security from you at an agreed-upon price.
We use a "spread strategy", in which we purchase two or more option contracts (for example, a call option
that you buy and a call option that you sell) for the same underlying security. This effectively puts you on
both sides of the market, but with the ability to vary price, time, and other factors.
Risks. Options are complex securities that involve risks and are not suitable for everyone. Option
trading can be speculative in nature and carry substantial risk of loss. It is generally
recommended that you only invest in options with risk capital. A relatively small market
movement will have a proportionately larger impact, which may work for or against the
investor. The placing of certain orders, which are intended to limit losses to certain amounts,
may not be effective because market conditions may make it impossible to execute such orders.
Selling ("writing" or "granting") an option generally entails considerably greater risk than
purchasing options. Although the premium received by the seller is fixed, the seller may sustain
a loss well in excess of that amount. The seller will also be exposed to the risk of the purchaser
exercising the option and the seller will be obliged either to settle the option in cash or to
acquire or deliver the underlying investment. If the option is "covered" by the seller holding a
corresponding position in the underlying investment or a future on another option, the risk may
be reduced.
Risk of Loss
Clients should understand that investing in any securities, including mutual funds, involves a risk of loss
of both income and principal that clients should be prepared to bear.
Item 9 - Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's or prospective
client's evaluation of our advisory business or the integrity of our management.
Our firm and our management personnel have no reportable disciplinary events to disclose.
Item 10 - Other Financial Industry Activities and Affiliations
PFG is not registered, nor does it have an application pending to register as a broker-dealer, futures
commission merchant, commodity pool operator, or commodity trading advisor. Furthermore, no PFG
control person is registered or has a pending application to become registered as, or licensed with, any
such foregoing entity.
Pruneyard Financial Group, Inc. is registered separately with the State of California as an accountancy
corporation, with services incidental to conduct of its advisory business. Accordingly, management
personnel and other employees, in their separate capacities as accountants or associates, may also
provide tax planning and preparation services to advisory clients for separate yet customary
compensation. Advisory clients are not under any obligation to engage the firm or these individuals for
Page 9 of 32
accounting services. PFG’s accounting services do not include the authority to sign checks or otherwise
disburse funds on any of our advisory client's behalf. PFG does not have signatory authority of client
accounts.
John D. Masegian, CPA, anticipates dedicating approximately 20% of his time to providing accounting
and tax planning and preparation services in his capacity as the firm's Tax Partner, for which he will
receive separate yet customary compensation. Mr. Masegian does not have signatory authority of client
accounts.
PFG does not recommend or select other investment advisers for clients.
CCR § 260.238 (k) provides that failing to disclose to a client in writing before entering or renewing an
advisory agreement with that client any material conflicts of interest regarding the investment adviser,
its representatives or any of its employees, which could be reasonably expected to impair the rendering
of unbiased and objective advice does not promote ''fair, equitable or ethical principles''. PFG and its
management persons have reasonably disclosed all material conflicts of interest.
Item 11 - Code of Ethics and Personal Trading
Code of Ethics
Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that
we require of our employees, including compliance with applicable federal securities laws. PFG and our
personnel owe a duty of loyalty, fairness, and good faith towards our clients, and have an obligation to
adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide
the Code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions
reports as well as initial and annual securities holdings reports that must be submitted by the firm's
access persons.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request
a copy by email sent to service@pruneyardfinancial.com, or by calling us at 408 377 4444.
Recommendations Involving Material Financial Interests
PFG does not recommend that clients buy or sell any security in which a related person to PFG or PFG
has a material financial interest.
Personal Trading and Conflicts of Interest
Our firm and/or individuals associated with our firm may buy or sell for their personal account(s)
securities identical to or different from those recommended to our clients. However, no person
employed by our firm may purchase or sell any security prior to a transaction being implemented for an
advisory account, thereby preventing such employees from benefiting from transactions placed on
behalf of advisory accounts.
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We aggregate our employee trades with client transactions where possible and when compliant with our
duty to seek best execution for our clients. In these instances, participating clients will receive an
average share price and transaction costs will be shared equally and on a pro-rata basis. In instances
where there is a partial fill of a particular batched order, we will allocate all purchases pro- rata, with
each account paying the average price. Our employee accounts will be included in the pro-rata
allocation. Our Code of Ethics also requires prior approval of any acquisition of securities in a limited
offering (e.g., private placement) or an initial public offering. Furthermore, our personnel are reminded
that the use of material non- public information in a personal or professional capacity (i.e., insider
trading, professional networks) is prohibited and will result in disciplinary action.
Item 12 - Brokerage Practices
As disclosed in Item 4, our portfolio management services are provided through a wrap-fee program
sponsored and managed by PFG We do not maintain custody of your assets that we manage but are
deemed to have custody of your assets if you give us authority to withdraw assets from your account
e.g., our fee (see Item 15— Custody). Therefore, your assets must be maintained in an account at a
“qualified custodian,” usually a broker- dealer. We require our wrap-fee program clients use either
Fidelity Investments (Fidelity) and/or Charles Schwab & Co., Inc. (Schwab), registered broker- dealers,
members SIPC, as an account’s qualified custodian.
Fidelity or Schwab will hold your assets in a brokerage account and buy and sell securities when we
instruct them to do so. While we require that you use Fidelity or Schwab as custodian/broker, you will
decide whether to do so and will open your account with Fidelity or Schwab by entering into an account
agreement directly with them. We do not open an account for you, although we may assist you in doing
so. Even though your account is maintained at Fidelity or Schwab, we can still use other brokers to
execute trades for your account as described below (see “Your brokerage and custody costs”)
How we select brokers/custodians
We use custodians/brokers that will hold your assets and execute transactions. When considering
whether the terms that the custodian provides are, overall, most advantageous to you when compared
with other available providers and their services, we consider a wide range of factors, including:
• Combination of transaction execution services and asset custody services (generally without a
separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds,
etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate the prices
• Reputation, financial strength, security, and stability
• Prior service to us and our clients
• Availability of other products and services that benefit us, as discussed below (see “Products
and services available to us from our custodians”).
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Your brokerage and trading costs.
Schwab and Fidelity each offer services to independent investment advisers which include, among
others, custody of securities, trade execution, clearance, and settlement of transactions. There is no
direct link between our firm's participation in the programs and the investment advice we give to our
clients, although we receive economic benefits through our participation in the programs that are
typically not available to Schwab or Fidelity retail investors.
The fee paid to us by our clients participating in the wrap-fee program covers administrative expenses,
custody charges, and most transaction fees incurred by PFG as a participant in the institutional customer
programs offered by Fidelity and Schwab.
For our clients’ accounts that Schwab or Fidelity maintain, each custodian generally does not charge you
separately for custody services but is compensated by charging you commissions or other fees on trades
that it executes or that settle into your account. Certain trades (for example, many mutual funds, and
U.S. exchange- listed equities and ETFs) may not incur commissions or transaction fees. Schwab is also
compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features
Program.
Where we choose to execute a trade with different broker-dealer but where the securities bought or the
funds from the securities sold are deposited (settled) into your account, Schwab or Fidelity usually
charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade. These fees are
in addition to the commissions or other compensation you pay the executing broker-dealer. Because of
this, to minimize your trading costs, we have Schwab or Fidelity execute most trades for your account.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that
broker provides execution quality comparable to other brokers or dealers. Although we are not required
to execute all trade through Schwab or Fidelity, we have determined that having Schwab or Fidelity
execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution
means the most favorable terms for a transaction based on all relevant factors, including those listed
above (see “How we select brokers/ custodians”). By using another broker or dealer you may pay lower
transaction costs.
Products and services available to us from the custodians:
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours.
Fidelity also has a similar business unit. They provide us and our clients with access to their institutional
brokerage services (trading, custody, reporting, and related services), many of which are not typically
available to retail customers. However, certain retail investors may be able to get institutional brokerage
services from Schwab or Fidelity without going through our firm. Schwab and Fidelity also make
available various support services. Some of those services help us manage or administer our clients’
accounts, while others help us manage and grow our business. Schwab and Fidelity’s support services
are generally available at no charge to us. Following is a more detailed description of the support
services:
Services that benefit you:
Schwab and Fidelity’s institutional brokerage services include access to a broad range of investment
products, execution of securities transactions, and custody of client assets. The investment products
available through Schwab and Fidelity include some to which we might not otherwise have access or
that would require a significantly higher minimum initial investment by our clients. Schwab and Fidelity’s
services described in this paragraph generally benefit you and your account.
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Services that do not directly benefit you:
Schwab and Fidelity also make available to us other products and services that benefit us but do not
directly benefit you or your account. These products and services assist us in managing and
administering our clients’ accounts and operating our firm. They include investment research, both
Schwab and Fidelity’s own and that of third parties. We use this research to service all or a substantial
number of our clients’ accounts, including accounts not maintained at Schwab or Fidelity. In addition to
investment research, Schwab and Fidelity also makes available software and other technology that:
• Provides access to client account data (such as duplicate trade confirmations and account
statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, record keeping, and client reporting
Services that generally benefit only us:
• Educational conferences and events
• Consulting on technology and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing consulting and support
The availability of these services from Schwab and Fidelity benefits us because we do not have to
produce or purchase them. We don’t have to pay for the services and are not contingent upon us
committing any specific amount of business to either Schwab or Fidelity in trading commissions or
assets in custody. The fact that we receive these benefits from Schwab and Fidelity is an incentive for us
to custody with Schwab and Fidelity rather than making such decision based exclusively on your interest
in receiving the best value in custody services and the most favorable execution of your transactions.
This is a conflict of interest. We believe, however, that taken in the aggregate, our use of Schwab and
Fidelity as our preferred custodians and brokers is in the best interests of our clients. Our selection is
primarily supported by the scope, quality, and price of Schwab and Fidelity’s services (see “How we
select brokers/custodians”) and not the services that benefit only us.
PFG is independently operated and owned and is not affiliated with either Schwab or Fidelity. Additional
information regarding the PFG Wrap Fee Program is provided in our Form ADV, Part 2A, Appendix 1:
Wrap Fee Program Brochure.
Order Aggregation
PFG will aggregate trades into blocks where possible and when advantageous to clients. This allocation
process permits the trading of aggregate blocks of securities composed of assets from multiple client
accounts and generally allows us to execute equity trades in a timely, equitable manner, at an average
share price.
Key components of our block trading policy and procedures are as follows:
• No client or account will be favored over another.
•
If the order cannot be executed in full at the same price or time, the securities purchased or sold by
the close of each business day must be allocated pro rata among the participating client accounts.
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• Transactions for any client account may not be aggregated for execution if the practice is prohibited
or inconsistent with the client's advisory agreement with us or firm policy.
•
Brokerage for Client Referrals
PFG does not receive client referrals from a broker-dealer or third-party in exchange for recommending
the use of a specific broker-dealer for brokerage services.
Directed Brokerage
As discussed above, PFG will generally require clients to direct the Firm to execute transactions through
a specified broker-dealer. Not all investment advisers require their clients to direct brokerage. Directing
brokerage may prevent clients from achieving most favorable execution and could cost clients more
money
Item 13 - Review of Accounts
Client accounts are reviewed at least quarterly by the CCO, John Masesigan, with regard to their
investment policies and risk tolerance levels.
Reviews may be triggered by material market, economic or political events, or by changes in client's
financial situations (such as retirement, termination of employment, physical move, or inheritance).
Clients will receive a statement, at least quarterly, detailing the client’s account, including assets held,
asset value, and calculation of fees. This statement will come from the custodian.
PFG does not prepare or deliver comprehensive written financial plans. To the extent financial planning
topics are discussed (e.g., retirement projections, cash flow considerations, or general financial goals),
these discussions are reviewed and updated periodically as part of the Firm’s ongoing portfolio
management services, typically in connection with regular client meetings or upon changes in a client’s
financial circumstances.
Item 14 - Client Referrals and Other Compensation
It is PFG's policy not to engage solicitors or to pay related or non-related persons to refer potential clients
to our firm.
It is PFG's policy not to accept or allow our related persons to accept any form of compensation,
including cash, sales awards, or other prizes, from a non-client in conjunction with the advisory services
we provide to our clients. PFG does not have any soft-dollar arrangements and does not receive any
commissions or other revenue from outside asset managers or brokerage firms.
Item 15 - Custody
We previously disclosed in Item 5 that under securities regulations, we are deemed to have custody of
your assets when you authorize us to instruct the custodian to deduct our advisory fees directly from
your account. The Firm has adopted the following safeguard procedures:
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1. We possess written authorization from the client to deduct advisory fees from an account held
by a qualified custodian;
2. We send the qualified custodian a written invoice detailing the fee amount to be deducted from
the client account; and,
3. We send the client an invoice or statement itemizing the fee. Itemization includes the formula
used to calculate the fee, the value of the assets under management on which the fee is based,
and the time period covered by the fee. This may be included with the client’s quarterly
performance report.
Certain clients have also granted the firm authorization to disburse funds to a third party under a
standing letter of instruction. The SEC issued a no-action letter (“Letter”) with respect to the Rule
206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter
provided guidance on the Custody Rule as well as clarified that an adviser who has the power to
disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have
custody. As such, our firm has adopted the following safeguards in conjunction with our custodian:
1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s
signature, the third party’s name, and either the third party’s address or the third party’s
account number at a custodian to which the transfer should be directed.
2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form
or separately, to direct transfers to the third party either on a specified schedule or from time to
time.
3. The client’s qualified custodian performs appropriate verification of the instruction, such as a
signature review or other method to verify the client’s authorization, and provides a transfer of
funds notice to the client promptly after each transfer.
4. The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
5. The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the client’s
instruction.
6. The investment adviser maintains records showing that the third party is not a related party of
the investment adviser or located at the same address as the investment adviser.
7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
The custodian maintains actual custody of your assets. You will receive brokerage account statements
directly from the custodian at least quarterly. They will be sent to the email or postal mailing address you
provided to the custodian. You should carefully review your brokerage account statements promptly
when you receive them.
We urge you to compare the brokerage account statements with the periodic portfolio reports you will
receive from us. Reports issued by our firm include a reminder to compare the account statements
received from the qualified custodian with those received from our firm. Clients are encouraged to
contact us with any questions or concerns about the report within 30 days of receipt.
Item 16 - Investment Discretion
Clients participating in our wrap fee Program give us discretionary authority over buying and selling
decisions in their accounts. Program clients may limit, change, or amend this authority by presenting us
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signed written instructions. However, PFG and its Principals reserve the right to reject the instructions
and end the engagement. Please refer to the Form ADV, Part 2A, Appendix 1 Wrap Fee Program
Brochure for more comprehensive information regarding the Program.
Item 17 - Voting Client Securities
We do not vote proxies on behalf of clients. Our policy is for clients to maintain exclusive responsibility
for (1) directing the way proxies solicited by issuers of securities beneficially owned by the client shall be
voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy
proceedings or other type events pertaining to the client’s investment assets. Clients are contractually
responsible for instructing each custodian to forward directly to them copies of all proxies and
shareholder communications relating to their investments.
Should a client fail to provide such instructions to the custodian, or the instructions are disregarded
causing proxy and/or shareholder materials to be delivered to our firm, while we will not vote the
proxies on the client’s behalf, we will forward the materials to the client and request that the client
promptly instruct the custodian to deliver all future proxy and shareholder materials directly to the
client. Thereafter, PFG will destroy, and not vote on, any proxies we subsequently receive. However, we
may provide clients with assistance regarding proxy issues if they contact us with questions.
Item 18 - Financial Information
As an advisory firm that maintains discretionary authority for client accounts, we are also required to
disclose any financial condition that is reasonable likely to impair our ability to meet our contractual
obligations.
• We have no such financial circumstances to report.
• Under no circumstances do we require or solicit payment of fees of more than $500 per client more
than six months in advance of services rendered. Therefore, we are not required to include a
financial statement.
• We have not been the subject of a bankruptcy petition at any time during the past ten years.
Item 19: Requirements For State Registered Advisers
A.
Formal Education and Business Background of Principal Officer
John Masegian is the sole owner, Managing Member, and Chief Compliance Officer of Pruneyard
Financial Group. For additional information about John Masegian, please see his Form ADV Part 2B.
B.
Other Business Activities
Additional information regarding John Masegian’s outside business activities can be found in his Form
ADV Part 2B.
C.
Performance-Based Fees
Neither the Firm nor John Masegian are compensated for Advisory Services with performance-based
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fees. See Item 5 (Fees and Compensation) of this brochure for further information on the Firm’s advisory
fees.
D.
Disciplinary Information
John Masegian has not been the subject of any legal or disciplinary actions by courts, regulatory
agencies, self-regulatory organizations, or professional societies.
E.
Material Relationships with Issuers of Securities
John Masegian does not maintain any relationships or arrangements with any issuer of securities.
Page 17 of 32
Item 1 - Cover Page
Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure
PFG Money Management Program
Pruneyard Financial Group, Inc.
22801 Longdown Road
Cupertino, California 95014
Telephone: 408 377 4444
Email: service@pruneyardfinancial.com
Web Address: https://pruneyardfinancial.com
May 19th, 2026
This brochure provides information about the qualifications and business practices of Pruneyard
Financial Group, Inc., a registered investment adviser. 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. Registration with the SEC or with any state securities authority does not imply a certain level of
skill or training.
If you have any questions about the contents of this brochure, please contact us at the telephone
number or email address listed above. Additional information about Pruneyard Financial Group, Inc. is
available on the SEC's website at adviserinfo.sec.gov. You can search this site by a unique identifying
number, known as a CRD number. Our firm's CRD number is 117378.
Page 18 of 32
Item 2 - Material Changes
Pruneyard Financial Group, Inc. is required to advise you of any material changes to our brochures and
disclosure documents from our last annual update, identify those changes on the cover page of our
brochure or on the page immediately following the cover page, or in a separate communication
accompanying our brochure.
Item 4: We are switching from SEC to State registration.
Since our filing dated 03/17/2025, we have the following changes to report:
•
Page 19 of 32
Item 3 - Table of Contents
Item 1 - Cover Page ................................................................................................................................. 18
Item 2 - Material Changes ....................................................................................................................... 19
Item 3 - Table of Contents ...................................................................................................................... 20
Item 4 - Services, Fees, and Compensation ............................................................................................ 21
Item 5 - Account Requirements and Types of Clients ............................................................................. 24
Item 6 - Portfolio Manager Selection and Evaluation ............................................................................. 25
Item 7 - Client Information Provided to Portfolio Managers .................................................................. 29
Item 8 - Client Contact with Portfolio Managers .................................................................................... 29
Item 9 - Additional Information .............................................................................................................. 30
Item 10 - Requirements for State-Registered Advisers .......................................................................... 32
Page 20 of 32
Item 4 - Services, Fees, and Compensation
Pruneyard Financial Group, Inc. (“PFG”) is an investment adviser registered with the state of California,
with its principal office located in Cupertino, California. The Firm has been in business since November
2001.The principal owner and Chief Compliance Officer is John D. Masegian.
Portfolio Management
This brochure is specific to describing the services, fees, and other necessary information clients
should consider prior to becoming a portfolio management client of PFG. PFG provides discretionary
portfolio management services (i.e., separately managed accounts) through a wrap fee program, the
PFG Money Management Program (the "Program"). PFG is the sponsor and investment manager of
the Program.
Separately Managed Accounts
Through personal discussions, our advisors determine the investor’s financial goals, expectations, time
horizon, risk tolerance, and liquidity requirements. The advisor may also review and discuss an investor’s
prior investment experience, as well as family situation and background.
When an investor decides to participate in the Program and become a client, a separately managed
account is opened whereby the advisor can exercise their discretion to make investment decisions on
the client’s behalf, including when to buy or sell securities, based on the prior discussions, and selected
financial objective for the account (i.e., growth, income, balanced).
To encourage advisor-client communication and to remind clients to keep us informed of changes in
their financial situation, we send quarterly written reports with reminders to each participating client
requesting any updated information regarding changes in the client's financial situation and investment
objectives.
Types of Securities: Pruneyard Financial Group, Inc. portfolio managers have established three absolute
criteria governing the types of securities that can be included in a client's managed portfolio:
1. The security must be traded on a U.S. exchange.
2. The security must be valued in U.S. dollars.
3. The security must be liquid, able to be bought or sold during market hours.
Because some types of investments involve certain additional degrees of risk, they will only be used
when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and
suitability. Clients may also impose reasonable restrictions on investing in certain securities, types of
securities, or industry sectors.
The following types of securities are most often utilized in our client portfolios:
Mutual Funds
No-load
Load-Waived
Target Date
Fixed-Income
Corporate Bonds
U.S. Treasuries
Mortgage-backed
Municipal Bonds
Equities
Listed/OTC
Preferred
ADRs
ETFs
Other
Closed End Funds
REITs
Certificates of Deposit
Structured Products
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Financial Planning
In connection with portfolio management services we may address broader financial topics such as
retirement planning, cash flow considerations, and general financial goals. For example,
recommendations may be made that the client begin or revise investment programs, revise wills or
trusts, obtain, or revise insurance coverage, commence, or alter retirement savings, or establish
education or charitable giving programs. These discussions are incorporated into the investment
management process and are not offered as a separate or standalone financial planning service. The
Firm does not prepare or deliver comprehensive written financial plans and does not charge a separate
fee for financial planning services. The Firm does not receive compensation from the sale of securities,
insurance, real estate, or other products in connection with these services. Implementation of any
recommendation is at the discretion of the client. If the client elects to act on our recommendations, the
client is under no obligation to affect the transaction through us.
Advisory Fees
Clients pay an asset-based fee that covers the services provided by PFG including administrative
expenses, custody charges and most transactions fees incurred by our firm as an institutional customer of
Fidelity Investments (Fidelity) and/or Charles Schwab & Co., Inc. (Schwab), registered broker-dealers,
members SIPC, as an account’s qualified custodian.
The maximum annual fee for our services in the Program is 1.25% on all account assets under
management. Clients may either agree to a single annual billing rate based on a percentage of AUM, or a
tiered fee based on total household AUM. Our tiered fee rates are as follows
Rate Tier
Annual Fee Monthly Rate
Total Household Assets Under
Management*
1
$0.00 - $499,999.99
1.25%
0.10%
2
$500,000 - $999,999.99
1.00%
0.08%
3
$1,000,000 - $2,499,999.99
0.90%
0.08%
4
$2,500,000 - $4,999,999.99
0.80%
0.07%
5
$5,000,000 +
0.50%
0.04%
Our Tiered Pricing is graduated. For example, for a sample $1,000,000 account:
For that portion of the client’s account(s) up to $499,999.99, PFG will charge an annual fee of
1.25%, resulting in an annual fee of $6,250 on the first $500,000; plus
For that portion of the client’s account(s) exceeding $500,000 but not exceeding $1,000,000, the
Adviser will charge an annual fee of 1.00%, resulting in an annual fee of $5,000 on the portion
between $500,000 and $1,000,000.
This would result in a total annual fee of $11,250 on the sample $1,000,000 account.
How are Fees Charged? Program fees are charged monthly in arrears. If management begins after the
start of a month, Program fees will be prorated accordingly. When authorized by the client, fees will be
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debited from the account in accordance with the terms set forth in the Investment Management
Services Agreement.
What services are covered by the Program fees? The Program fees pay for our investment management
(e.g., investment advice, portfolio management and financial planning), administrative expenses (e.g.,
custodial fees), and brokerage costs (to the extent trades are conducted through Schwab or Fidelity).
What services are not covered by the Program fees? The Program fees do not include expenses of mutual
funds and electronically traded funds such as fund management fees charged to each fund's investors.
Fees are Negotiated. The Program fees set forth in this Wrap Fee Program Brochure are the maximum
annual rates for each Program. Fees are negotiated and may differ from client to client based on several
factors, including the type and size of the account, and the selected investment objective, among other
possible criteria. The actual rates agreed upon between the client and our firm with respect to a Program
account are set forth in the related client agreement.
Other Fees and Expenses. Clients may incur charges for other account services including, but not limited
to, annual account maintenance fees, wire transfer fees, trade-away fees, mark-ups, mark-downs,
spreads, interest charges on margin or collateralized loans, exchange fees, and fees for transfers of
securities or closing of accounts.
Additional Information about Program fees. Under the Program, the participant receives investment
advisory services, the execution of securities brokerage transactions, custody, and reporting services for a
single specified Program fee. Clients are cautioned that depending on the level of fees charged by the
executing broker-dealer, and the amount of portfolio activity in the clients' account, the value of the
services provided under this Program may exceed the total cost of such services had they been provided
separately. In addition, the Program Fee may be higher or lower than that charged by other sponsors of
comparable wrap fee programs. In addition, a disparity in wrap fees may exist between the wrap fees
charged to other clients depending on the minimum account requirements and advisory fees in effect at
the time the clients began the advisory relationships.
Compensation for Client Participation. Neither PFG, nor any representatives of PFG receive any
additional compensation beyond advisory fees for the participation of client’s in the wrap fee program.
General Information
Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either
party, for any reason upon receipt of written notice. Upon termination of any account, any prepaid,
unearned fees will be promptly refunded.
Mutual Fund Fees: Fees paid to our firm for investment advisory services are separate and distinct from
the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and
expenses are described in each fund's prospectus. These fees will generally include a management fee,
other fund expenses, and a possible distribution fee (e.g., a 12b-1 fee). If the fund also imposes sales
charges, a client may pay an initial or deferred sales charge.
Under no circumstances will Pruneyard Financial Group, Inc. or its supervised persons accept or receive
12b-1 fees, commissions on trades, or any similar fee, in connection with recommending, purchasing, or
holding 12b-1 fee paying share classes for its advisory clients when a lower-cost share class or no
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transaction fee (NTF) class of the same fund is available to those clients at the time of selection.
A client could invest in a mutual fund directly, without our services. In that case, the client would not
receive the services provided by our firm which are designed, among other things, to assist the client in
determining which mutual fund or funds are most appropriate to each client's financial condition and
objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully
understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services
being provided.
Exchange-Traded Funds. Shares of ETFs held in client accounts are bought and sold on an exchange and
not, like mutual funds, directly from the fund itself. The price of ETF shares fluctuates in accordance with
changes in the net asset value (NAV) per share, as well as in response to market supply and demand.
Accordingly, ETF shares may trade at a price which differs from NAV per share of the ETF.
Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are subject to
Pruneyard Financial Group, Inc.'s minimum account requirements and advisory fees in effect at the time
the client enters the advisory relationship. Therefore, our firm's minimum account requirements will
differ among clients.
Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available
from other registered (or unregistered) investment advisers for similar or lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees more than
$500 more than six months in advance of services rendered.
Item 5 - Account Requirements and Types of Clients
Minimum Account Requirements
No minimum account size is required to participate in this program, however accounts of $100,000 or
less are likely to be invested primarily in mutual funds and exchange traded funds whereas accounts
over $100,000 may include individual securities, like stocks and/or bonds.
As a condition for program participation, clients are required to custody their assets with Schwab and/or
Fidelity. The fee paid by our clients participating in the program covers administrative expenses, custody
charges and most transactions fees incurred by our firm as a participant in the institutional customer
programs offered by Schwab and Fidelity. As such, we reserve the right to decline acceptance of any
client account for which the client directs the use of a broker dealer or custodian other than Schwab or
Fidelity
Custody
Schwab and Fidelity each offers services to independent investment advisers which include, among
others, custody of securities, trade execution, clearing, and settlement of transactions. There is no direct
link between our firm's participation in the programs and the investment advice we give to our clients,
although we receive economic benefits through our participation in the programs that are typically not
available to Schwab or Fidelity retail investors.
These benefits include the following products and services (provided without cost or at a discount):
duplicate client statements and confirmations; research related products and tools; consulting services;
access to a trading desk serving adviser participants; access to block trading (which provides the ability
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to aggregate securities transactions for execution and then allocate the appropriate shares to client
accounts); the ability to have advisory fees deducted directly from client accounts; access to an
electronic communications network for client order entry and account information; access to mutual
funds with no transaction fees and to certain Institutional money managers; and discounts on
compliance, marketing, research, technology, and practice management products or services provided to
our firm by third party vendors. Schwab and Fidelity may also pay for business consulting and
professional services received by our related persons.
Some of the products and services made available by Schwab and Fidelity through the program may
benefit PFG but may not benefit our client accounts. These products or services may assist us in
managing and administering client accounts, including accounts not maintained at Schwab or Fidelity.
Other services made available by Schwab and Fidelity are intended to help us manage and further
develop our business enterprise. The benefits received by our firm through participation in the
programs do not depend on the amount of brokerage transactions directed to Schwab or Fidelity.
Clients should be aware, however, that the receipt of economic benefits by our firm or related persons in
and of itself creates a potential conflict of interest and may indirectly influence our recommendation of
Schwab or Fidelity for custody and brokerage services. We examined this potential conflict of interest
with Schwab and Fidelity and determined that maintaining the two custodial relationships is in the best
interests of our clients and satisfies our client obligations, including our duty to seek best execution.
Trade Execution and Aggregation
PFG will aggregate trades into blocks whenever possible and when advantageous to clients. This
allocation process permits the trading of aggregate blocks of securities composed of assets from
multiple client accounts and generally allows us to execute equity trades in a timely, equitable manner,
at an average share price. Key components of our block trading policy and procedures are as follows:
1. No client or account will be favored over another.
2.
If the order cannot be executed in full at the same price or time, the securities purchased or sold
by the close of each business day must be allocated pro rata among the participating client
accounts.
3. Transactions for any client account may not be aggregated for execution if the practice is
prohibited by or inconsistent with the client's advisory agreement, or firm policy.
Types of Clients
We provide advisory and portfolio management services to the following types of clients:
Individuals (other than high net worth individuals)
High net worth individuals
Corporations or small business
Item 6 - Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
As previously disclosed, all participating clients' assets are managed by advisory personnel of our firm.
These individuals must possess, in minimum, a college degree and/or appropriate business experience
and all required licenses. Please refer to Item 4 for detailed disclosures regarding the portfolio
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management services we provide to program clients.
Portfolio Performance Reporting
Pruneyard Financial Group, Inc. publishes and distributes a quarterly report for each client that includes
information relevant to their portfolio, such as a portfolio’s asset allocation, investment performance,
unrealized gain/loss, and billing summary. Performance is presented as the time weighted rate of return
(TWR) for an account, net of fees. The S&P 500 Composite Index and Bloomberg Aggregate Bond Index
are displayed alongside the account performance values for discussion purposes.
Affiliated Portfolio Managers
As previously disclosed, all client assets in this program are managed by our portfolio managers. Please
refer to Item 4 for a detailed description of PFG Money Management Program's services and fees.
Performance-Based Fees
PFG does not charge performance-based fees.
Methods of Analysis and associated risks
We use the following methods of analysis in formulating our investment strategies:
Charting. In this type of technical analysis, we review charts of market and security activity to better
identify when the market is moving up or down and to predict how long the trend may last and when
that trend might reverse.
Technical Analysis. We analyze past market movements and apply that analysis to the present to better
recognize recurring patterns of investor behavior and potentially predict future price movement.
Technical analysis does not consider the underlying financial condition of a company. This presents a risk
that a poorly managed or financially unsound company may underperform regardless of market
movement.
Risks. The risk of market timing based on technical analysis is that charts might not accurately
predict future price movements. Current prices of securities may reflect all information known
about the security and day to day changes in market prices of securities may follow random
patterns and may not be predictable with any reliable degree of accuracy.
Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic
and financial factors (including the overall economy, industry conditions, and the financial condition and
management of the company itself) to determine if the company is underpriced (indicating it may be a
good time to buy) or overpriced (indicating it may be time to sell).
Risks. Fundamental analysis does not attempt to anticipate market movements. This presents a
potential risk, as the price of a security can move up or down along with the overall market
regardless of the economic and financial factors considered in evaluating the stock.
Quantitative Analysis. We use mathematical models to better obtain more accurate measurements of a
company's quantifiable data, such as the value of share price or earnings per share and predict changes
to that data.
Risks. A risk in using quantitative analysis is that the models used may be based on assumptions
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that prove to be incorrect.
Qualitative Analysis. We subjectively evaluate non-quantifiable factors such as quality of management,
labor relations, and strength of research and development factors not readily subject to measurement
and predict changes to share price based on that data.
Risks. A risk is using qualitative analysis is that our subjective judgment may prove incorrect.
Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager of the
mutual fund or ETF to better determine if that manager has demonstrated an ability to invest over a
period and in different economic conditions. We also look at the underlying assets in a mutual fund or
ETF to better determine if there is a significant overlap in the underlying investments held in other
fund(s) in the client's portfolio. We also monitor the funds or ETFs to better determine if they are
continuing to follow their stated investment strategy.
Risks. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful may not be
able to replicate that success in the future. In addition, as we do not control the underlying
investments in a fund or ETF, managers of different funds held by the client may purchase the
same security, increasing the risk to the client if that security were to fall in value. There is also a
risk that a manager may deviate from the stated investment mandate or strategy of the fund or
ETF, which could make the holding(s) less suitable for the client's portfolio.
Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies
whose securities we purchase and sell, the rating agencies that review these securities, and other publicly
available sources of information about these securities, are providing accurate and unbiased data. While
we are alert to indications that data may be incorrect, there is always a risk that our analysis may be
compromised by inaccurate or misleading information.
Investment Strategies
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Long-term purchases. We purchase securities with the idea of holding them in the client's account for a
year or longer. We typically employ this strategy when:
We believe the securities to be currently undervalued, and/or
We want exposure to a particular asset class over time, regardless of the current projection for
this class.
Risks. A risk in a long-term purchase strategy is that by holding the security for this length of time,
we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our
predictions are incorrect, a security may decline sharply in value before we make the decision to
sell.
Short-term purchases. When utilizing this strategy, we purchase securities with the idea of selling them
within a relatively short time (typically less than a year). We do this to better take advantage of
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conditions that we believe will soon result in a price swing in the securities we purchase.
Risks. Risks include liquidity, economic stability, and inflation, in addition to the long- term
trading risks listed above. Frequent trading can affect investment performance, particularly
through increased brokerage and other transaction costs and taxes.
Options writing. We may use options as an investment strategy. An option is a contract that gives the
buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price
on or before a certain date. An option, just like a stock or bond, is a security. An option is also a
derivative because it derives its value from an underlying asset.
The two types of options we utilize are calls and puts:
A call gives us the right to buy an asset at a certain price within a specific period. We will buy a
call if we have determined that the stock will increase substantially before the option expires.
A put gives us the holder the right to sell an asset at a certain price within a specific period. We
will buy a put if we have determined that the price of the stock will fall before the option
expires.
We will use options to speculate on the possibility of a sharp price swing. We will also use options to
"hedge" a purchase of the underlying security; in other words, we will use an option purchase to limit
the potential upside and downside of a security we have purchased for your portfolio.
We use "covered calls", in which we sell an option on security you own. In this strategy, you receive a
fee for making the option available, and the person purchasing the option has the right to buy the
security from you at an agreed-upon price.
We use a "spread strategy", in which we purchase two or more option contracts (for example, a call option
that you buy and a call option that you sell) for the same underlying security. This effectively puts you on
both sides of the market, but with the ability to vary price, time, and other factors.
Risks. Options are complex securities that involve risks and are not suitable for everyone. Option
trading can be speculative in nature and carry substantial risk of loss. It is generally
recommended that you only invest in options with risk capital. A relatively small market
movement will have a proportionately larger impact, which may work for or against the
investor. The placing of certain orders, which are intended to limit losses to certain amounts,
may not be effective because market conditions may make it impossible to execute such orders.
Selling ("writing" or "granting") an option generally entails considerably greater risk than
purchasing options. Although the premium received by the seller is fixed, the seller may sustain
a loss well in excess of that amount. The seller will also be exposed to the risk of the purchaser
exercising the option and the seller will be obliged either to settle the option in cash or to
acquire or deliver the underlying investment. If the option is "covered" by the seller holding a
corresponding position in the underlying investment or a future on another option, the risk may
be reduced.
Risk of Loss
Clients should understand that investing in any securities, including mutual funds, involves a risk of loss
Page 28 of 32
of both income and principal that clients should be prepared to bear.
Voting Client Securities
As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our firm may
provide investment advisory services relative to client investment assets, clients maintain exclusive
responsibility for: (1) directing the way proxies solicited by issuers of securities beneficially owned by the
client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers,
bankruptcy proceedings or other type events pertaining to the client's investment assets. Clients are
responsible for instructing each custodian of the assets to forward to the client copies of all proxies and
shareholder communications relating to the client's investment assets.
Should a client fail to provide such instructions to the custodian, or the instructions are disregarded
causing proxy and/or shareholder materials to be delivered to our firm, while we will not vote the proxies
on the client’s behalf, we will forward the materials to the client and request that the client promptly
instruct the custodian to deliver all future proxy and shareholder materials directly to the client.
Thereafter, we will destroy, and not vote, any proxies we subsequently receive. However, we may
provide clients with assistance regarding proxy issues if they contact us with questions.
Item 7 - Client Information Provided to Portfolio Managers
Individuals affiliated with our firm are responsible for developing an initial financial profile of the
prospective client. Prior to opening an account, we assist in determining a participant's profile for the
Program by obtaining from the participant appropriate information (i.e., investment objectives, risk
tolerance, time horizon, and any reasonable restrictions the client wishes to impose upon the
management of the account). The initial investment strategy is jointly determined based on an
assessment of the information provided by the client.
While we provide the client with periodic reminders, it remains the client's responsibility to advise us
of any changes to the information previously provided that might impact the ongoing suitability of any
prior determined investment strategies and/or objectives. We will promptly communicate any
reported changes to the client's portfolio manager.
A Pruneyard Financial Group, Inc.'s representative will directly contact each wrap fee program client at
least annually to verify that there has been no change in the client's financial circumstances and/or
investment objectives and determine whether the client wishes to impose any reasonable restrictions
on the management of their assets. Any such changes or requests are communicated in writing to the
client's portfolio manager, who is responsible for implementing appropriate adjustments to the client's
portfolio.
Item 8 - Client Contact with Portfolio Managers
Pruneyard Financial Group Inc.'s portfolio managers are reasonably available to consult with clients
regarding the status of their accounts. We encourage the managers to make themselves available as time
permits for our clients to discuss investment philosophy, objectives and to answer client questions.
Page 29 of 32
Item 9 - Additional Information
Review of Accounts
Client accounts are reviewed at least quarterly by the CCO, John Masesigan, with regard to their
investment policies and risk tolerance levels.
Reviews may be triggered by material market, economic or political events, or by changes in client's
financial situations (such as retirement, termination of employment, physical move, or inheritance).
Clients will receive a statement, at least quarterly, detailing the client’s account, including assets held,
asset value, and calculation of fees. This statement will come from the custodian.
The Firm does not prepare or deliver comprehensive written financial plans. To the extent financial
planning topics are discussed (e.g., retirement projections, cash flow considerations, or general financial
goals), these discussions are reviewed and updated periodically as part of the Firm’s ongoing portfolio
management services, typically in connection with regular client meetings or upon changes in a client’s
financial circumstances.
Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's or prospective
client's evaluation of our advisory business or the integrity of our management.
Our firm and our management personnel have no reportable disciplinary events to disclose.
Other Financial Industry Activities and Affiliations
PFG is not registered, nor does it have an application pending to register as a broker-dealer, futures
commission merchant, commodity pool operator, or commodity trading advisor. Furthermore, no
Pruneyard Financial Group, Inc. control person is registered or has a pending application to become
registered as, or licensed with, any such foregoing entity.
PFG is registered separately with the State of California as an accountancy corporation, with
services incidental to conduct of its advisory business. Accordingly, management personnel and
other employees, in their separate capacities as accountants or associates, may also provide tax
planning and preparation services to advisory clients for separate yet customary compensation. Advisory
clients are not under any obligation to engage the firm or these individuals for accounting services. PFG
does not have signatory authority of client accounts.
Our accounting services do not include the authority to sign checks or otherwise disburse funds on any
of our advisory clients’ behalf.
John D. Masegian anticipates dedicating approximately 20% of his time engaged in providing accounting
and tax planning and preparation services in his capacity as a CPA, for which he will receive separate yet
customary compensation. Mr. Masegian does not have signatory authority of client accounts.
PFG does not recommend or select other investment advisers for clients.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
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Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that
we require of our employees, including compliance with applicable federal securities laws.
Pruneyard Financial Group, Inc. and our personnel owe a duty of loyalty, fairness, and good faith
towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of
Ethics but to the general principles that guide the Code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions
reports as well as initial and annual securities holdings reports that must be submitted by the firm's
access persons.
Our firm and/or individuals associated with our firm may buy or sell for their personal account(s)
securities identical to or different from those recommended to our clients. However, no person
employed by our firm may purchase or sell any security prior to a transaction being implemented for an
advisory account, thereby preventing such employees from benefiting from transactions placed on behalf
of advisory accounts.
We will aggregate our employee trades with client transactions where possible and when compliant
with our duty to seek the best execution for our clients. In these instances, participating clients will
receive an average share price and transaction costs will be shared equally and on a pro-rata basis.
In instances where there is a partial fill of a particular batched order, we will allocate all purchases pro-
rata, with each account paying the average price. Our employee accounts will be included in
the pro-rata allocation.
Our Code of Ethics also requires prior approval of any acquisition of securities in a limited offering (e.g.,
private placement) or an initial public offering. Furthermore, our personnel are reminded that the use of
material non-public information in a personal or professional capacity (i.e., insider trading, professional
networks) is prohibited and will result in disciplinary action.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request
a copy by email sent to service@pruneyardfinancial.com, or by calling us at 408 377 4444.
Client Referrals and Other Compensation
It is Pruneyard Financial Group, Inc.'s policy not to engage solicitors or to pay related or non-related
persons for referring potential clients to our firm or allow our related persons to accept any form of
compensation, including cash, sales awards, or other prizes, from a non-client in conjunction with the
advisory services we provide to our clients.
Financial Information
As an advisory firm that maintains discretionary authority for client accounts, we are required to
disclose any financial condition that is reasonable likely to impair our ability to meet our contractual
obligations. We have no additional financial circumstances to report.
Under no circumstances do we require or solicit payment of fees of more than $500 per client more
than six months in advance of services rendered. Therefore, we are not required to include a financial
statement. We have not been the subject of a bankruptcy petition at any time during the past ten years.
Recommendations Involving Material Financial Interests
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PFG does not recommend that clients buy or sell any security in which a related person to PFG or PFG has
a material financial interest.
Item 10 - Requirements for State-Registered Advisers
Pruneyard Financial Group and its management person do not have any relationship or arrangement with
any issuer of Securities.
Page 32 of 32
Additional Brochure: ADV PART 2B (2026-05-19)
View Document Text
Item 1 Cover Page
SUP ER V I S E D P E R S O N B R O CH U R E
F O R M A D V P A R T 2 B
John D. Masegian
Office Address:
22801 Longwood Road
Cupertino, CA 95014
Tel: (408) 377-4444
Email: service@pruneyardfinancial.com
Website: https://pruneyardfinanical.com
DATE: May 19, 2026
.
This brochure supplement provides information about John D. Masegian and supplements the Pruneyard
Financial Group, Inc. brochure. You should have received a copy of that brochure. Please contact John D.
Masegian if you did not receive the brochure or if you have any questions about the contents of this
supplement.
Additional information about John D. Masegian (CRD #4782088) is available on the SEC’s website at
www.adviserinfo.sec.gov.
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer – John D. Masegian
Year of birth: 1975
Item 2 - Educational Background and Business Experience
Educational Background:
San Jose State University; Bachelor of Science: Accounting; Graduated 2003
Business Experience:
Pruneyard Financial Group, Inc., President/Treasurer/Investment Advisor
Representative; 06/2002 – Present
Pruneyard Financial Group, Inc, Certified Public Accountant
09/2004 – Present
Professional Designation:
Certified Public Accountant (CPA):
CPAs are licensed and regulated by their state boards of accountancy. While state laws
and regulations vary, the education, experience and testing requirements for licensure as
a CPA generally include minimum college education (150 credit hours with at least a
baccalaureate degree and a concentration in accounting), minimum experience levels
(most states require at least one year of experience providing services that involve the
use of accounting, attest, compilation, management advisory, financial advisory, tax or
consulting skills, all of which must be achieved under the supervision of or verification by
a CPA), and successful passage of the Uniform CPA Examination.
In order to maintain a CPA license, states generally require the completion of 40 hours of
continuing professional education (CPE) each year (or 80 hours over a two-year period
or 120 hours over a three-year period). Additionally, all American Institute of Certified
Public Accountants (AICPA) members are required to follow a rigorous Code of
Professional Conduct which requires that they act with integrity, objectivity, due care,
competence, fully disclose any conflicts of interest (and obtain client consent if a conflict
exists), maintain client confidentiality, disclose to the client any commission or referral
fees, and serve the public interest when providing financial services.
In addition to the Code of Professional Conduct, AICPA members who provide personal
financial planning services are required to follow the Statement on Standards in Personal
Financial Planning Services (SSPFPS).
Item 3 - Disciplinary Information
John D. Masegian has not been the subject of any legal or disciplinary actions by courts, regulatory
agencies, self-regulatory organizations, or professional societies.
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Item 4 - Other Business Activities
Managing Member, John D. Masegian is part owner of Modest Engine LLC. This limited liability
company was formed for the purpose of leasing the office property from which the Firm conducts
its business. Mr. Masegian spends approximately 1 hour per month on this activity.
John D. Masegian is licensed as a Certified Public Accountant and may provide accounting and tax
services through Pruneyard Financial Group, Inc., which is registered separately with the State of
California as an accountancy corporation. Advisory clients are not under any obligation to engage the
firm or Mr. Masegian for accounting services. Mr. Masegian dedicates approximately 20% of his time
to providing accounting and tax planning and preparation services in his capacity as the firm's Tax
Partner, for which he receives separate yet customary compensation.
Item 5 - Additional Compensation
John D. Masegian does not receive any economic benefit from any person, company, or
organization, other than Pruneyard Financial Group, Inc in exchange for providing clients
advisory services through Pruneyard Financial Group, Inc.
Item 6 - Supervision
Since John D. Masegian is the sole owner and Chief Compliance Officer of Pruneyard Financial
Group, Inc., he is solely responsible for all supervision and formulation and monitoring of
investment advice offered to Clients. He will adhere to the policies and procedures described in
the firm’s Compliance Manual. He can be reached at:
• Tel: (408) 377-4444
• Email: service@pruneyardfinancial.com
Item 7 – Requirements for State Registered Advisers
A. John D. Masegian has NOT been involved in any of the events listed below.
1. An award or otherwise being found liable in an arbitration claim alleging damages involving
any of the following:
a) an investment or an investment-related business or activity;
b) fraud, false statement(s), or omissions;
c) theft, embezzlement, or other wrongful taking of property;
d) bribery, forgery, counterfeiting, or extortion; or
e) dishonest, unfair, or unethical practices.
2. An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding involving any of the following:
a) an investment or an investment-related business or activity;
b) fraud, false statement(s), or omissions;
c) theft, embezzlement, or other wrongful taking of property;
d) bribery, forgery, counterfeiting, or extortion; or
e) dishonest, unfair, or unethical practices.
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B. John D. Masegian has NOT been the subject of a bankruptcy petition in the past ten years.
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