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Quad City Investment Advisors, LLC
d/b/a: Quad City Investment Center
3551 7th Street
Moline, IL 61265
Telephone: 563-388-5436
Website: www.qcbt.com
March 24, 2026
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Quad City
Investment Center. If you have any questions about the contents of this brochure, contact us at 563-
388-5436. 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 Quad City Investment Center is available on the SEC's website at
www.adviserinfo.sec.gov.
Quad City Investment Center is a registered investment adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain level of
skill or training.
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Item 2 Summary of Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure,
the adviser is required to notify you and provide you with a description of the material changes.
Since the filing of our last annual updating amendment dated March 14, 2025, we have no material
changes to report.
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Item 3 Table of Contents
Item 1 Cover Page
Item 2 Summary of Material Changes
Item 3 Table of Contents
Item 4 Advisory Business
Item 5 Fees and Compensation
Item 6 Performance-Based Fees and Side-By-Side Management
Item 7 Types of Clients
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16 Investment Discretion
Item 17 Voting Client Securities
Item 18 Financial Information
Item 19 Requirements for State-Registered Advisers
Item 20 Additional Information
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Item 4 Advisory Business
Description of Firm
Quad City Investment Advisors, LLC d/b/a Quad City Investment Center is an SEC registered
investment adviser primarily based in Moline, Illinois. We are organized as a limited liability company
("LLC") under the laws of the State of Illinois. We have been providing investment advisory services
since the acquisition of CMG Investment Advisors, L.L.C. in 2008.
We are a wholly owned subsidiary of Quad City Bank & Trust Company and indirectly owned by QCR
Holdings, Inc., the parent company of Quad City Bank and Trust Company.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we," "our," and "us" refer to Quad City Investment Center
("QCIC") and the words "you," "your," and "client" refer to you as either a client or prospective client of
our firm.
Portfolio Management Services
We offer discretionary portfolio management services. Our investment advice is tailored to meet our
clients' needs and investment objectives. If you retain our firm for portfolio management services, we
will meet with you to determine your investment objectives, risk tolerance, and other relevant
information at the beginning of our advisory relationship. We will use the information we gather to
develop a strategy that enables our firm to give you continuous and focused investment advice and/or
to make investments on your behalf. As part of our portfolio management services, we may customize
an investment portfolio for you according to your risk tolerance and investing objectives. We may also
invest your assets according to one or more model portfolios developed by our firm. Once we construct
an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance
on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and
in your financial circumstances.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow us to determine
the specific securities, and the amount of securities, to be purchased or sold for your account without
your approval prior to each transaction. Discretionary authority is typically granted by the investment
advisory agreement you sign with our firm. You may limit our discretionary authority (for example,
limiting the types of securities that can be purchased or sold for your account) by providing our firm
with your restrictions and guidelines in writing.
As referenced above, we may invest your assets according to one or more model portfolios developed
by our firm. These models are designed for investors with varying degrees of risk tolerance ranging
from a more aggressive investment strategy to a more conservative investment approach. Clients
whose assets are invested in model portfolios may not set restrictions on the specific holdings or
allocations within the model, nor the types of securities that can be purchased in the model.
Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in
their account. In such cases, this may prevent a client from investing in certain models that are
managed by our firm.
In our sole discretion, we may offer complimentary financial planning to certain portfolio management
clients.
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Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based upon the
needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these
services may include an existing plan review and analysis, plan-level advice regarding fund selection
and investment options, education services to plan participants, investment performance monitoring,
and/or ongoing consulting. These pension consulting services will generally be non-discretionary and
advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor
or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational
seminars to plan participants on such topics as: diversification, asset allocation, risk tolerance, and
time horizon
Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually
negotiated basis. All services, whether discussed above or customized for the plan based upon
requirements from the plan fiduciaries (which may include additional plan-level or participant-level
services) shall be detailed in a written agreement and be consistent with the parameters set forth in the
plan documents.
Selection of Other Advisers
As part of our investment advisory services, we may recommend that you use the services of a third
party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. After
gathering information about your financial situation and objectives, we will recommend that you engage
a specific TPMM or investment program. Factors that we take into consideration when making our
recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of
analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We
will periodically monitor the TPMM(s)' performance to ensure its management and investment style
remains aligned with your investment goals and objectives.
LPL Financial Sponsored Advisory Programs
We may provide advisory services through certain programs sponsored by LPL Financial LLC ("LPL"),
a registered investment advisor and broker-dealer. Below is a brief description of each LPL advisory
program available to QCIC. For more information regarding the LPL programs, including more
information on the advisory services and fees that apply, the types of investments available in the
programs and the potential conflicts of interest presented by the programs please see the program
account packet (which includes the account agreement and LPL Form ADV program brochure) and the
Form ADV, Part 2A of LPL or the applicable program.
Model Wealth Portfolios Program (MWP)
MWP offers clients a professionally managed mutual fund asset allocation program. QCIC will obtain
the necessary financial data from the client, assist the client in determining the suitability of the MWP
program and assist the client in setting an appropriate investment objective. QCIC will initiate the steps
necessary to open an MWP account and have discretion to select a model portfolio designed by LPL's
Research Department consistent with the client's stated investment objective. LPL's Research
Department or third-party portfolio strategists are responsible for selecting the mutual funds or ETFs
within a model portfolio and for making changes to the mutual funds or ETFs selected.
The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and
ETFs and to liquidate previously purchased securities. The client will also authorize LPL to effect
rebalancing for MWP accounts.
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MWP requires a minimum asset value for a program account to be managed. The minimums vary
depending on the portfolio(s) selected and the account's allocation amongst portfolios. The lowest
minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is permitted.
Guided Wealth Portfolios (GWP)
GWP offers clients the ability to participate in a centrally managed, algorithm-based investment
program, which is made available to users and clients through a web-based, interactive account
management portal ("Investor Portal"). Investment recommendations to buy and sell exchange-traded
funds and open-end mutual funds are generated through proprietary, automated, computer algorithms
(collectively, the "Algorithm") of FutureAdvisor, Inc. ("FutureAdvisor"), based upon model portfolios
constructed by LPL and selected for the account as described below (such model portfolio selected for
the account, the "Model Portfolio"). Communications concerning GWP are intended to occur primarily
through electronic means (including but not limited to, through email communications or through the
Investor Portal), although QCIC will be available to discuss investment strategies, objectives or the
account in general in person or via telephone.
A preview of the Program (the "Educational Tool") is provided for a period of up to forty-five (45) days
to help users determine whether they would like to become advisory clients and receive ongoing
financial advice from LPL, FutureAdvisor and QCIC by enrolling in the advisory service (the "Managed
Service"). The Educational Tool and Managed Service are described in more detail below and in the
GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of
LPL, FutureAdvisor or QCIC, do not enter into an advisory agreement with LPL, FutureAdvisor or
QCIC, do not receive ongoing investment advice or supervisions of their assets, and do not receive
any trading services.
A minimum account value of $5,000 is required to enroll in the Managed Service.
Features of the Educational Tool
Users of the Educational Tool (each, a "user") agree to a terms of use ("Terms of Use") and complete
an investor profile. An investment objective ("Investment Objective") and Model Portfolio is assigned to
each user based upon factors in the investor profile, including risk tolerance and the number of years
remaining until the age of retirement (such time being referred to herein as the "Retirement Age"). (See
description in "Features of the Managed Service" below for information regarding the design of the
Model Portfolios.) Based on the Investment Objective and Model Portfolio, the Educational Tool
generates sample analysis, advice and investment recommendations ("Sample Recommendations").
The Educational Tool provides Sample Recommendations that may assist users in determining
whether to utilize the Managed Service. Access to the Educational Tool is generally limited to a period
of forty-five (45) days. The Educational Tool is intended to be used for educational and informational
purposes only. The Educational Tool does not provide comprehensive financial planning and is not
intended to constitute legal, financial or tax advice. There may be other relevant factors and financial
considerations (e.g., debt load or financial obligations) that LPL, FutureAdvisor and QCIC do not take
into consideration in formulating any Sample Recommendations provided. The Sample
Recommendations made are meant solely as a sample of the types of recommendations available
through the Managed Service. LPL, FutureAdvisor and QCIC are not responsible for any actions taken
with respect to the Sample Recommendations, and users are solely responsible for making their own
investment decisions. The Educational Tool is only one of many tools that users may use as part of a
comprehensive investment analysis process. Users should not rely on the Educational Tool as the sole
basis for investment decisions.
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Although LPL is an investment adviser and broker-dealer registered with the SEC and a member of the
Financial Industry Regulatory Authority, and FutureAdvisor is an investment adviser registered with the
SEC, in providing access to the Educational Tool, LPL, FutureAdvisor and QCIC do not intend to
establish an advisory relationship, or in the case of LPL, a brokerage relationship, with users of the
Educational Tool. Users are not charged an advisory fee or any other fee or expense to use the
Educational Tool. The scope of any investment advisory relationship with LPL, FutureAdvisor and
QCIC begins when users enroll in the Managed Service. The output that users receive by using the
Educational Tool, including the Sample Recommendations, may differ materially from the advice users
would receive as an advisory client of LPL, FutureAdvisor and QCIC.
Neither LPL, FutureAdvisor, nor QCIC provides ongoing investment management or trading services
for assets of users of the Educational Tool, makes any determination as to whether the website
through which the Program is accessed or the Educational Tool is appropriate for any user, can access
any assets in any accounts users aggregate in the Educational Tool, places any trades on behalf of
users of the Educational Tool, or provides ongoing supervision of assets of users of the Educational
Tool. The Sample Recommendations provided are intended as an informational preview of the
Managed Service, and the Sample Recommendations are being provided to demonstrate the types of
analysis, advice and recommendations provided by the Managed Service.
Features of the Managed Service
Investors participating in the Managed Service ("clients" and each, a "client") complete an account
application (the "Account Application") and enter into an account agreement (the "Account
Agreement") with LPL, QCIC and FutureAdvisor. As part of the account opening process, clients are
responsible for providing complete and accurate information regarding, among other things, their age,
risk tolerance, and investment horizon (collectively, "Client Profile"). LPL, QCIC, and FutureAdvisor rely
on the information in the Client Profile in order to provide services under the Program, including but not
limited to, determination of suitability of the Program for clients and an appropriate Investment
Objective and Model Portfolio for clients. The Model Portfolios have been designed and are maintained
by LPL or, in the future, a third-party investment strategist (as applicable, the "Portfolio Strategist") and
shall include a list of securities holdings, relative weightings and a list of potential replacement
securities for tax harvesting purposes. FutureAdvisor, Advisor and clients cannot access, change or
customize the Model Portfolios. Only one Model Portfolio is permitted per account. Based upon a
client's risk tolerance as indicted in the Client Profile, the client is assigned an investment allocation
track (currently Fixed Income Tilt, Balance Tilt or Equity Tilt), the purpose of which is to slowly rotate
the client's equity allocation to fixed income over time. LPL Research created these tracks using
academic research on optimal retirement allocations, the industry averages as calculated by
Morningstar for the target date fund universe, and input from FutureAdvisor.
Within the applicable allocation track and based upon a client's chosen Retirement Age in the Client
Profile, the client will be assigned a Model Portfolio and one of five of LPL's standard investment
objectives:
•
•
Income with capital preservation. Designed as a longer term accumulation account, this
investment objective is considered generally the most conservative. Emphasis is placed on
generation of current income with minimal risk of capital loss. Lowering the risk generally
means lowering the potential income and overall return.
Income with moderate growth. This investment objective emphasizes generation of current
income with a secondary focus on moderate capital growth.
• Growth with income. This investment objective emphasizes modest capital growth with some
focus on generation of current income.
• Growth. This investment objective emphasizes achieving high long-term growth and capital
appreciation. There is little focus on generation of current income.
• Aggressive growth. This investment objective emphasizes aggressive growth and maximum
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capital appreciation, with no focus on generation of current income. This objective has a very
high level of risk and is for investors with a longer timer horizon.
Both the client and QCIC are required to review and approve the initial Investment Objective. As a
client approaches the Retirement Age, the Algorithm will automatically adjust the client's asset
allocation. Any change to the Investment Objective directed by a client due to changes in the Client's
risk tolerance and/or Retirement Age will require written approval from the client and QCIC before
implementation. Failure to approve the change in Investment Objective may result in a client remaining
in a Model Portfolio that is no longer aligned with the applicable Client Profile. The Investment
Objective selected for the account is an overall objective for the entire account and may be
inconsistent with a particular holding and the account's performance at any time and may be
inconsistent with other asset allocations suggested to client by LPL, QCIC or FutureAdvisor prior to
client entering into the Account Agreement. Achievement of the stated investment objective is a long-
term goal for the account, and asset withdrawals may impair the achievement of client's investment
objectives. A Client Profile that includes a conservative risk tolerance over a long-term investment
horizon may result in the selection of an Investment Objective that is riskier than would be selected
over a shorter-term investment horizon. Clients should contact QCIC if they believe the Investment
Objective does not appropriately reflect the Client Profile, such as their risk tolerance.
By executing the Account Agreement, clients authorize LPL and FutureAdvisor to have discretion to
buy and sell only exchange-traded funds ("ETFs") and open-end mutual funds ("Mutual Funds")
(collectively, "Program Securities") according to the Model Portfolio selected and, subject to certain
limitations described in the Account Agreement, hold or liquidate previously purchased non-model
securities that are transferred into the account ("Legacy Securities"). In order to be transferred into an
account, Legacy Securities must be Mutual Funds with which LPL has a full or partial selling
agreement, ETFs or individual U.S. listed stocks. Securities that are not Program Securities included
within the Model Portfolio will not be purchased for an account, and FutureAdvisor, in its sole
discretion, will determine whether to hold or sell Legacy Securities, generally, but not solely, with the
goal of optimizing tax impacts for accounts that are subject to tax. Additional Legacy Securities will not
be purchased for the account. Clients may not impose restrictions on liquidating any Legacy Securities
for any reason. Clients should not transfer in Legacy Securities that they are not willing to have
liquidated at the discretion of FutureAdvisor.
In addition, uninvested cash may be invested in money market funds, the Multi-Bank Insured Cash
Account ("ICA") or the Deposit Cash Account ("DCA"), as applicable, as described in the Account
Agreement. Dividends paid by the Program Securities in the account will be contributed to the cash
allocation and ultimately reinvested into the account based on the Model Portfolio once the tolerance
within cash allocation is surpassed. Pursuant to the Account Agreement, FutureAdvisor is authorized
to perform tax harvesting when deemed acceptable by the Algorithm. LPL, Advisor and clients cannot
alter trades made for tax harvesting purposes. In order to permit trading in a tax-efficient manner, the
Account Agreement also grants FutureAdvisor the authority to select specific tax lots when liquidating
securities within the account. Although the Algorithm attempts to achieve tax efficiencies, by doing so a
client's portfolio may not directly align with Model Portfolio. As a result, a client may receive advice that
differs from the advice received by accounts using the same Model Portfolio, and the client's account
may perform differently than other accounts using the same Model Portfolio.
During the term of the Account Agreement, FutureAdvisor will perform a daily review of the account to
determine if rebalancing is appropriate based on tolerance thresholds established by LPL and/or
FutureAdvisor. At each rebalancing review, the account will be rebalanced if at least one of the
account positions is outside such thresholds, subject to a minimum transaction amount established by
LPL and/or FutureAdvisor. In addition, LPL and/or FutureAdvisor may review the account for
rebalancing in the event that the Portfolio Strategist changes a Model Portfolio. FutureAdvisor may
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delay placing rebalancing transactions for non-qualified accounts by a number of days, to be
determined by FutureAdvisor, in an attempt to limit short-term tax treatment for any position being sold.
In addition, trading in the account at any given time is also subject to certain conditions, including but
not limited to, conditions related to trade size, compliance tests, the target cash allocation and
allocation tolerances. LPL, Advisor and clients can alter the rebalancing frequency.
Selection of FutureAdvisor as Third-Party Robo Advisor
Under QCIC's agreement with LPL, QCIC was provided the opportunity to offer GWP, which utilizes
FutureAdvisor's Algorithm as described herein, to prospective clients. QCIC is not otherwise affiliated
with FutureAdvisor. FutureAdvisor is compensated directly by LPL for its services, including the
Algorithm and related software, through an annual sub-advisory fee (tiered based on assets under
management by FutureAdvisor, at a rate ranging from 0.10% to 0.17%). As each asset tier is reached,
LPL's share of the compensation shall increase and clients will not benefit from such asset tiers. No
additional fee is charged for FutureAdvisor's services.
QCIC believes that certain clients will benefit from GWP's advisor-enhanced advisory services,
particularly due to the relatively low minimum account balance and the combination of a digital advice
solution with access to an advisor. Unlike direct-to-consumer robo platforms, QCIC is responsible on
an ongoing basis as investment advisor and fiduciary for the client relationship, including for
recommending the program for the client; providing ongoing monitoring of the program, the
performance of the account, the services of LPL and FutureAdvisor; determining initial and ongoing
suitability of the program for the client; reviewing clients' suggested portfolio allocations; reviewing and
approving any change in Investment Objective due to changes clients make to their Client Profile;
answering questions regarding the program, assisting with paperwork and administrative and
operational details for the account; and being available to clients to discuss investment strategies,
changes in financial circumstances, objectives or the account in general in person or via telephone.
QCIC can also recommend other suitable investment programs if clients have savings goals or
investment needs for which GWP is not the optimal solution.
Wrap Fee Program(s)
We are a portfolio manager and a sponsor of a wrap fee program, which is a type of investment
program that provides clients with access to several money managers or mutual fund asset allocation
models for a single fee that includes administrative fees, management fees, and commissions. If you
participate in our wrap fee program, you will pay our firm a single fee, which includes our money
management fees, certain transaction costs, and custodial and administrative costs. We receive a
portion of the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee
program may be higher or lower than you might incur by separately purchasing the types of securities
available in the program.
Transactions for your account must be executed by LPL Financial, LLC, a securities broker-dealer and
a member of the Financial Industry Regulatory Authority and the Securities Investor Protection
Corporation. To compare the cost of the wrap fee program with non-wrap fee portfolio management
services, you should consider the frequency of trading activity associated with our investment
strategies and the brokerage commissions charged by or other broker-dealers, and the advisory fees
charged by investment advisers. For more information concerning the Wrap Fee Program,
see Appendix 1 to this Brochure.
Additionally, we may recommend the wrap fee programs sponsored by other Advisors.
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Types of Investments
We primarily offer advice on mutual funds, exchange traded funds (ETFs), and index
funds. Additionally, we may advise you on various types of investments based on your stated goals
and objectives. We may also provide advice on any type of investment held in your portfolio at the
inception of our advisory relationship.
Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional
disclosures on this topic.
Assets Under Management
As of December 31, 2025, we provide continuous management services for $407,964,628 in client
assets on a discretionary basis.
Item 5 Fees and Compensation
Portfolio Management Services
Our annual fee for portfolio management services varies between 0.60% and 1.35% depending upon
the market value of your assets under our management, the type and complexity of the asset
management services provided, as well as the level of administration requested either directly or
assumed by the client.
Our annual portfolio management fee is billed and payable, quarterly in advance, based on the
balance at end of billing period.
If the portfolio management agreement is executed at any time other than the first day of a calendar
quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in
proportion to the number of days in the quarter for which you are a client. Our advisory fee is
negotiable, depending on individual client circumstances.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. For example, we may combine account values for you and
your minor children, joint accounts with your spouse, and other types of related accounts. Combining
account values may increase the asset total, which may result in your paying a reduced advisory fee.
We will send you an invoice for the payment of our advisory fee, or we will deduct our fee directly from
your account through the qualified custodian holding your funds and securities. We will deduct our
advisory fee only when you have given our firm written authorization permitting the fees to be paid
directly from your account. Further, the qualified custodian will deliver an account statement to you at
least quarterly. These account statements will show all disbursements from your account. You should
review all statements for accuracy.
We encourage you to reconcile our invoices with the statement(s) you receive from the qualified
custodian. If you find any inconsistent information between our invoice and the statement(s) you
receive from the qualified custodian call our main office number located on the cover page of this
brochure.
You may terminate the portfolio management agreement upon 30 days written notice. You will incur a
pro rata charge for services rendered prior to the termination of the portfolio management agreement,
which means you will incur advisory fees only in proportion to the number of days in the quarter for
which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive
a prorated refund of those fees.
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Pension Consulting Services
Our advisory fees for these customized services will be negotiated with the plan sponsor or named
fiduciary on a case-by-case basis.
Either party to the pension consulting agreement may terminate the agreement upon written notice to
the other party in accordance with the terms of the agreement for services. The pension consulting
fees will be prorated for the quarter in which the termination notice is given and any unearned fees will
be refunded to the client.
Selection of Other Advisers
Advisory fees charged by TPMMs are separate and apart from our advisory fees. Assets managed by
TPMMs will be included in calculating our advisory fee, which is based on the fee range set forth in
the Portfolio Management Services section in this brochure. Advisory fees that you pay to the TPMM
are established and payable in accordance with the brochure provided by each TPMM to whom you
are referred. These fees may or may not be negotiable. You should review the recommended TPMM's
brochure and take into consideration the TPMM's fees along with our fees to determine the total
amount of fees associated with this program.
You may be required to sign an agreement directly with the recommended TPMM(s). You may
terminate your advisory relationship with the TPMM according to the terms of your agreement with the
TPMM. You should review each TPMM's brochure for specific information on how you may terminate
your advisory relationship with the TPMM and how you may receive a refund, if applicable. You should
contact the TPMM directly for questions regarding your advisory agreement with the TPMM.
Fees for LPL Advisory Programs
The account fee charged to the client for each LPL advisory program is negotiable, subject to the
following maximum account fees:
MWP 1.35%*
GWP 1.35%**
*The MWP account fee consists of an LPL program fee, a strategist fee (if applicable) and an advisor
fee of up to 1.35%. See the MWP program brochure for more information.
**GWP Managed Service clients are charged an account fee consisting of an LPL program fee of
0.35% and an advisor fee of up to 1.00%. In the future, a strategist fee may apply. However, LPL
Research currently serves as the sole portfolio strategist and does not charge a fee for its services.
FutureAdvisor is compensated directly by LPL for its services, including the Algorithm and related
software, through an annual sub-advisory fee (tiered based on assets under management by
FutureAdvisor, at a rate ranging from 0.10% to 0.17%). As each asset tier is reached, LPL's share of
the compensation shall increase and clients will not benefit from such asset tiers.
GWP Educational Tool provides access to sample recommendations at no charge to users. However,
if users decide to implement sample recommendations by executing trades, they will be charged fees,
commissions, or expenses by the applicable broker or adviser, as well as underlying investment fees
and expenses. Account fees are payable quarterly in advance.
Excluding GWP, LPL serves as program sponsor, investment advisor and broker-dealer for the LPL
advisory programs. In the Managed Service of GWP, LPL is appointed by each client as custodian of
account assets and broker-dealer with respect to processing securities transactions for the accounts.
In general, FutureAdvisor, in its capacity as investment advisor, will submit transactions through LPL;
however, FutureAdvisor may choose to execute transactions through a broker-dealer other than LPL,
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subject to its duty to seek to achieve best execution. When securities transactions are effected through
LPL, there are no brokerage commissions charged to the account. If FutureAdvisor chooses to execute
a transaction through a broker-dealer other than LPL, the execution price may include a commission or
fee imposed by the executing broker-dealer. In evaluating whether to execute a trade through a broker-
dealer other than LPL, Future Advisor will consider the fact that the account will not be charged a
commission if the transaction is effected through LPL.
QCIC and LPL may share in the account fee and other fees associated with program accounts.
Associated persons of QCIC may also be registered representatives of LPL.
Potential Conflicts of Interest
QCIC receives compensation as a result of a client's participation in an LPL program. Depending on,
among other things, the type and size of the account, type of securities held in the account, changes in
its value over time, the ability to negotiate fees or commissions, the historical or expected size or
number of transactions, and the number and range of supplementary advisory and client-related
services provided to the client, the amount of this compensation may be more or less than what the
QCIC would receive if the client participated in other programs, whether through LPL or another
sponsor, or paid separately for investment advice, brokerage and other services.
The account fee may be higher than the fees charged by other investment advisors for similar
services. For instance, FutureAdvisor offers direct-to-consumer services similar to GWP. Therefore,
clients could generally pay a lower advisory fee for algorithm-driven, automated ("robo") investment
advisory services through FutureAdvisor or other robo providers. However, clients using such direct
robo services will forgo opportunities to utilize LPL-constructed model portfolios or to work directly with
a financial advisor.
Clients should consider the level and complexity of the advisory services to be provided when
negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with QCIC.
With regard to accounts utilizing third-party portfolio managers under aggregate, all-in-one account fee
structures (including MAS, PWP and the legacy MWP fee structure), because the portion of the
account fee retained by QCIC varies depending on the portfolio strategist fee associated with a
portfolio, QCIC has a financial incentive to select one portfolio instead of another portfolio.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds (described in each fund's prospectus) to their shareholders. These fees will generally
include a management fee and other fund expenses. You may also incur transaction charges and/or
brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by
the broker-dealer or custodian through whom your account transactions are executed. We do not
share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or
custodian. To fully understand the total cost you will incur, you should review all the fees charged by
mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices,
refer to the Brokerage Practices section of this brochure.
Compensation for the Sale of Securities or Other Investment Products
Persons providing investment advice on behalf of our firm are also registered representatives with LPL
Financial, LLC ("LPL"), a securities broker-dealer, and a member of the Financial Industry Regulatory
Authority and the Securities Investor Protection Corporation. In their capacity as registered
representatives for LPL, these persons receive compensation in connection with the purchase and sale
of securities or other investment products, including asset-based sales charges, service fees or 12b-1
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fees, for the sale or holding, of mutual funds. Compensation earned by these persons in their
capacities as registered representatives is separate and in addition to our advisory fees. This practice
presents a conflict of interest because persons providing investment advice to advisory clients - who
are registered representatives have an incentive to recommend investment products based on the
compensation received rather than solely based on your needs.
While persons providing investment advice to advisory clients on behalf of our firm can select or
recommend mutual fund investments in share classes that pay 12b-1 fees, it is our policy that these
persons do not select or recommend share classes that pay 12b-1 fees for your advisory
account. However, sometimes we have to recommend an A-Share, but the 12b-1 fee is passed
through to the client in these instances. Thus, we will not receive a 12b-1 fee and an advisory fee on
the same asset. In the event that we inadvertently receive a 12b-1 fee on an advisory account, we will
rebate the 12b-1 fee to your advisory account. However, it is important to note that these persons,
when acting in their separate capacities as registered representatives, can select or recommend, and
in many instances will select or recommend, that your brokerage account purchase mutual fund
investments in share classes that pay 12b-1 fees when clients are eligible to purchase share classes of
the same funds that do not pay such fees and are less expensive. This presents a conflict of interest.
You are under no obligation, contractually or otherwise, to purchase securities products through any
person affiliated with our firm who receives compensation described above.
Persons providing investment advice on behalf of our firm are licensed as independent insurance
agents of LPL. These persons will earn commission-based compensation for selling insurance
products, including insurance products they sell to you. Insurance commissions earned by these
persons are separate and in addition to our advisory fees. This practice presents a conflict of interest
because persons providing investment advice who are insurance agents have a financial incentive to
recommend insurance products to you. You are under no obligation, contractually or otherwise, to
purchase insurance products through any person affiliated with our firm.
Past Due Accounts and Termination of Agreement
We reserve the right to stop work on any account that is more than 90 days overdue.
Item 6 Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or participate in side-by-side management. Performance-
based fees are fees that are based on a share of a capital gains or capital appreciation of a client's
account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-
based fees. Our fees are calculated as described in the Fees and Compensation section above, and
are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in
your advisory account.
Item 7 Types of Clients
We offer investment advisory services to individuals, high net worth individuals, pension and profit
sharing plans, charitable organizations, corporations and other business entities.
In general, we do not require a minimum dollar amount to open and maintain an advisory account;
however, we have the right to terminate your Account if it falls below a minimum size which, in our sole
opinion, is too small to manage effectively. Additionally, certain third-party advisory programs may
impose a minimum asset value to participate in their program.
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Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Our Methods of Analysis and Investment Strategies
We may use one or more of the following methods of analysis or investment strategies when providing
investment advice to you:
Technical Analysis - involves studying past price patterns, trends and interrelationships in the
financial markets to assess risk-adjusted performance and predict the direction of both the overall
market and specific securities.
Risk: The risk of market timing based on technical analysis is that our analysis may not accurately
detect anomalies or 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 - involves analyzing individual companies and their industry groups, such as a
company's financial statements, details regarding the company's product line, the experience and
expertise of the company's management, and the outlook for the company and its industry. The
resulting data is used to measure the true value of the company's stock compared to the current
market value.
Risk: The risk of fundamental analysis is that information obtained may be incorrect and the
analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's
value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not
result in favorable performance.
Modern Portfolio Theory - a theory of investment which attempts to maximize portfolio expected
return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected
return, by carefully diversifying the proportions of various assets.
Risk: Market risk is that part of a security's risk that is common to all securities of the same
general class (stocks and bonds) and thus cannot be eliminated by diversification.
Long-Term Purchases - securities purchased with the expectation that the value of those securities
will grow over a relatively long period of time, generally greater than one year.
Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in
the long-term which may not be the case. There is also the risk that the segment of the market
that you are invested in or perhaps just your particular investment will go down over time even if
the overall financial markets advance. Purchasing investments long-term may create an
opportunity cost - "locking-up" assets that may be better utilized in the short-term in other
investments.
Our investment strategies and advice may vary depending upon each client's specific financial
situation. As such, we determine investments and allocations based upon your predefined objectives,
risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors.
Your restrictions and guidelines may affect the composition of your portfolio. It is important that you
notify us immediately with respect to any material changes to your financial circumstances,
including for example, a change in your current or expected income level, tax circumstances, or
employment status.
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Tax Considerations
Our strategies and investments may have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the
management of your assets. Regardless of your account size or any other factors, we strongly
recommend that you consult with a tax professional regarding the investing of your assets.
Your custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost
basis of your investments. You are responsible for contacting your tax advisor to determine if this
accounting method is the right choice for you. If your tax advisor believes another accounting method
is more advantageous, provide written notice to our firm immediately and we will alert your account
custodian of your individually selected accounting method. Decisions about cost basis accounting
methods will need to be made before trades settle, as the cost basis method cannot be changed after
settlement.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate clients from losses due to market corrections or declines.
We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past
performance is in no way an indication of future performance.
Other Risk Considerations
When evaluating risk, financial loss may be viewed differently by each client and may depend on many
different risks, each of which may affect the probability and magnitude of any potential loses. The
following risks may not be all-inclusive, but should be considered carefully by a prospective client
before retaining our services.
Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high
volatility or lack of active liquid markets. You may receive a lower price or it may not be possible to sell
the investment at all.
Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and
sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair
or erase the value of an issuer's securities held by a client.
Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to
changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and
may reduce the purchasing power of a client's future interest payments and principal. Inflation also
generally leads to higher interest rates which may cause the value of many types of fixed income
investments to decline.
Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an
unforeseen event, for example, the loss of your job. This may force you to sell investments that you
were expecting to hold for the long term. If you must sell at a time that the markets are down, you may
lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for
people who are retired, or are nearing retirement.
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Recommendation of Particular Types of Securities
We primarily recommend mutual funds, exchange traded funds ("ETFs"), and index funds. However,
we may advise on other types of investments as appropriate for you since each client has different
needs and different tolerance for risk. Each type of security has its own unique set of risks associated
with it and it would not be possible to list here all of the specific risks of every type of investment. Even
within the same type of investment, risks can vary widely. However, in very general terms, the higher
the anticipated return of an investment, the higher the risk of loss associated with the investment.
Mutual Funds and Exchange Traded Funds: Mutual funds and exchange traded funds ("ETF") are
professionally managed collective investment systems that pool money from many investors and invest
in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any
combination thereof. The fund will have a manager that trades the fund's investments in accordance
with the fund's investment objective. While mutual funds and ETFs generally provide diversification,
risks can be significantly increased if the fund is concentrated in a particular sector of the market,
primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a
significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing
the fund with different types of securities. ETFs differ from mutual funds since they can be bought and
sold throughout the day like stock and their price can fluctuate throughout the day. The returns on
mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual
funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds
do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open
end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas
"closed end" funds have a fixed number of shares to sell which can limit their availability to new
investors.
ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to
cause the ETF's performance to match that of the its Underlying Index or other benchmark, which may
negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track
the performance of their Underlying Indices or benchmarks on a daily basis, mathematical
compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an
ETF may not have investment exposure to all of the securities included in its Underlying Index, or its
weighting of investment exposure to such securities may vary from that of the Underlying Index. Some
ETFs may invest in securities or financial instruments that are not included in the Underlying Index, but
which are expected to yield similar performance.
Bonds: Corporate debt securities (or "bonds") are typically safer investments than equity securities,
but their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be "called" prior to
maturity. When a bond is called, it may not be possible to replace it with a bond of equal character
paying the same rate of return.
Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as
"equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the
company issuing it. However, stock prices can be affected by many other factors including, but not
limited to the class of stock (for example, preferred or common); the health of the market sector of the
issuing company; and, the overall health of the economy. In general, larger, better established
companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the
mere size of an issuer is not, by itself, an indicator of the safety of the investment.
Money Market Funds: A money market fund is technically a security. The fund managers attempt to
keep the share price constant at $1/share. However, there is no guarantee that the share price will stay
at $1/share. If the share price goes down, you can lose some or all of your principal. The U.S.
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Securities and Exchange Commission ("SEC") notes that "While investor losses in money market
funds have been rare, they are possible." In return for this risk, you should earn a greater return on
your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured
savings account (money market funds are not FDIC insured). Next, money market fund rates are
variable. In other words, you do not know how much you will earn on your investment next month. The
rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes
down and you earn less than you expected to earn, you may end up needing more cash. A final risk
you are taking with money market funds has to do with inflation. Because money market funds are
considered to be safer than other investments like stocks, long-term average returns on money market
funds tends to be less than long term average returns on riskier investments. Over long periods of
time, inflation can eat away at your returns.
Certificates of Deposit: Certificates of deposit are generally the safest type of investment since they
are insured by the federal government up to a certain amount. However, because the returns are
generally very low, it is possible for inflation to outpace the return. Likewise, U.S. government
securities are backed by the full faith and credit of the U.S. government but it is also possible for the
rate of inflation to exceed the returns.
Municipal Securities: Municipal securities, while generally thought of as safe, can have significant
risks associated with them including, but not limited to: the credit worthiness of the governmental entity
that issues the bond; the stability of the revenue stream that is used to pay the interest to the
bondholders; when the bond is due to mature; and, whether or not the bond can be "called" prior to
maturity. When a bond is called, it may not be possible to replace it with a bond of equal character
paying the same amount of interest or yield to maturity.
Real Estate Investment Trust: A real estate investment trust ("REIT") is a corporate entity which
invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate
income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock
exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually
pay dividends out of funds from operations, so cash flow has to be strong or the REIT must either dip
into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After 2012,
the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts
periodically. The credit markets are no longer frozen, but banks are demanding, and getting, harsher
terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay
debt, which will lead to additional dilution of the stockholders. Fluctuations in the real estate market can
affect the REIT's value and dividends.
Item 9 Disciplinary Information
We are required to disclose the facts of any legal or disciplinary events that are material to a client's
evaluation of our advisory business or the integrity of our management. We do not have any required
disclosures under this item.
Item 10 Other Financial Industry Activities and Affiliations
Registrations with Broker-Dealer
Persons providing investment advice on behalf of our firm are registered representatives with LPL a
securities broker-dealer, and a member of the Financial Industry Regulatory Authority and the
Securities Investor Protection Corporation. See the Fees and Compensation section in this brochure
for more information on the compensation received by registered representatives who are affiliated
with our firm.
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Arrangements with Affiliated Entities
We are affiliated with Quad City Bank and Trust Company through common control and ownership. We
will recommend that you use the services of our affiliate if appropriate for your needs. Our advisory
services are separate and distinct from the compensation paid to our affiliate for their services.
Referral arrangements with an affiliated entity present a conflict of interest for us because we may
have a direct or indirect financial incentive to recommend an affiliated firm's services. While we believe
that compensation charged by our affiliate is competitive, such compensation may be higher than fees
charged by other banks providing the same or similar services. You are under no obligation to use the
services of any affiliate or third-party that we may recommend, and you may obtain comparable
services and/or lower fees through other firms.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for persons associated with our
firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our
fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm
are expected to adhere strictly to these guidelines. Persons associated with our firm are also required
to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies
reasonably designed to prevent the misuse or dissemination of material, non-public information about
you or your account holdings by persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the
telephone number on the cover page of this brochure.
Participation or Interest in Client Transactions
Neither our firm nor any persons associated with our firm has any material financial interest in client
transactions beyond the provision of investment advisory services as disclosed in this brochure.
Personal Trading Practices
Our firm or persons associated with our firm may not buy or sell the same securities that we
recommend to you or securities in which you are already invested. A conflict of interest exists in such
cases because we would have the ability to trade ahead of you and potentially receive more favorable
prices than you will receive. To mitigate this conflict of interest, it is our policy that neither our firm nor
persons associated with our firm shall have priority over your account in the purchase or sale of
securities.
Block Trading
Our firm or persons associated with our firm may not buy or sell securities for you at the same time we
or persons associated with our firm buy or sell such securities for our own account. We do not combine
our orders or any other client's orders to purchase securities with your orders to purchase securities
("block trading"). Refer to the Brokerage Practices section in this brochure for more information on our
block trading practices. All purchases and sales are done at an account level for each individual client.
A conflict of interest exists in such cases because we would have the ability to trade ahead of you and
potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, it is
our policy that neither our firm nor persons associated with our firm shall have priority over your
account in the purchase or sale of securities.
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Item 12 Brokerage Practices
While we maintain relationships with several custodians and/or broker-dealers, we primarily
recommend the brokerage and custodial services of LPL Financial, LLC, (the "Custodian"). Your
assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or
bank. In recognition of the value of the services the Custodian provides, you may pay higher
commissions and/or trading costs than those that may be available elsewhere.
We seek to recommend a custodian/broker that will hold your assets and execute transactions on
terms that are, overall, the most favorable compared to other available providers and their services.
We consider various factors, including:
• Capability to buy and sell securities for your account itself or to facilitate such services.
• The likelihood that your trades will be executed.
• Availability of investment research and tools.
• Overall quality of services.
• Competitiveness of price.
• Reputation, financial strength, and stability.
• Existing relationship with our firm and our other clients.
Research and Other Soft Dollar Benefits
We do not have any soft dollar arrangements.
Economic Benefits
As a registered investment adviser, we have access to the institutional platform of your account
custodian. As such, we will also have access to research products and services from your account
custodian and/or other brokerage firm. These products may include financial publications, information
about particular companies and industries, research software, and other products or services that
provide lawful and appropriate assistance to our firm in the performance of our investment decision-
making responsibilities. Such research products and services are provided to all investment advisers
that utilize the institutional services platforms of these firms, and are not considered to be paid for with
soft dollars. However, you should be aware that the commissions charged by a particular broker for a
particular transaction or set of transactions may be greater than the amounts another broker who did
not provide research services or products might charge.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation,
such as brokerage services or research.
Directed Brokerage
We routinely require that you direct our firm to execute transactions through LPL Financial. As such,
we may be unable to achieve the most favorable execution of your transactions and you may pay
higher brokerage commissions than you might otherwise pay through another broker-dealer that offers
the same types of services. Not all advisers require their clients to direct brokerage.
Persons providing investment advice on behalf of our firm who are registered representatives of LPL
Financial, LLC ("LPL") would normally be required to recommend LPL to you for brokerage services.
These individuals are subject to applicable industry rules that restrict them from conducting securities
transactions away from LPL unless LPL provides the representatives with written authorization to do
so, which LPL has done in this case. Therefore, although these individuals would generally be limited
to conducting securities transactions through LPL, in this instance, as noted above, they may
recommend the brokerage services of other brokers. It may be the case that these other brokers
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charge higher transaction costs and/or custodial fees than another broker charges for the same types
of services. However, if transactions were executed though LPL these individuals (in their separate
capacities as registered representatives of LPL) could earn commission-based compensation as a
result of placing the recommended securities transactions through LPL. This practice would present a
conflict of interest because these registered representatives would have an incentive to effect
securities transactions for the purpose of generating commissions rather than solely based on your
needs. You may utilize the broker-dealer of your choice and have no obligation to purchase or sell
securities through such broker as we recommend. However, if you do not use the recommended
broker we may not be able to accept your account. See the Fees and Compensation section in this
brochure for more information on the compensation received by registered representatives who are
affiliated with our firm.
Block Trades
We do not combine multiple orders for shares of the same securities purchased for advisory accounts
we manage (this practice is commonly referred to as "block trading") because we primarily invest in
mutual funds which do not trade in blocks.
Item 13 Review of Accounts
Your invest adviser representative will monitor your accounts on an ongoing basis and will conduct
account reviews at least at least annually, to ensure the advisory services provided to you are
consistent with your investment needs and objectives. Additional reviews may be conducted based on
various circumstances, including, but not limited to: contributions and withdrawals, year-end tax
planning, market moving events, security specific events, and/or changes in your risk/return objectives.
The individuals conducting reviews may vary from time to time, as personnel join or leave our firm.
We will not provide you with regular written reports. You will receive trade confirmations and monthly or
quarterly statements from your account custodian(s).
Item 14 Client Referrals and Other Compensation
As disclosed under the Fees and Compensation section in this brochure, persons providing investment
advice on behalf of our firm are licensed insurance agents, and are registered representatives with
LPL, a securities broker-dealer, and a member of the Financial Industry Regulatory Authority and the
Securities Investor Protection Corporation. For information on the conflicts of interest this presents,
and how we address these conflicts, refer to the Fees and Compensation section.
Client Referrals
We may directly compensate non-employee (outside) consultants, individuals, and/or entities
(Solicitors) for client referrals. In order to receive a cash referral fee from our firm, Solicitors must
comply with the requirements of the jurisdictions in which they operate. If you were referred to our firm
by a Solicitor, you should have received a disclosure from the Solicitor at the time of the referral. If you
become a client, the Solicitor that referred you to our firm will receive a one-time referral fee, based on
a percentage of the advisory fee you pay our firm in first quarter for which you are a client. You will not
pay additional fees because of this referral arrangement. Referral fees paid to a Solicitor are
contingent upon your entering into an advisory agreement with our firm. Therefore, a Solicitor has a
financial incentive to recommend our firm to you for advisory services. This creates a conflict of
interest; however, you are not obligated to retain our firm for advisory services. Comparable services
and/or lower fees may be available through other firms.
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Solicitors that refer business to more than one investment adviser may have a financial incentive to
recommend advisers with more favorable compensation arrangements. We request that our Solicitors
disclose to you whether multiple referral relationships exist and that comparable services may be
available from other advisers for lower fees and/or where the Solicitor's compensation is less
favorable.
Item 15 Custody
As paying agent for our firm, your independent custodian will directly debit your account(s) for the
payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our
firm to exercise limited custody over your funds or securities. We do not have physical custody of any
of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or
other qualified custodian. You will receive account statements from the qualified custodian(s) holding
your funds and securities at least quarterly. The account statements from your custodian(s) will
indicate the amount of our advisory fees deducted from your account(s) each billing period. You should
carefully review account statements for accuracy.
We will also provide statements to you reflecting the amount of the advisory fee deducted from your
account. You should compare our statements with the statements from your account custodian(s) to
reconcile the information reflected on each statement. If you have a question regarding your account
statement, or if you did not receive a statement from your custodian, contact us immediately at the
telephone number on the cover page of this brochure.
Item 16 Investment Discretion
Before we can buy or sell securities on your behalf, you must first sign our discretionary management
agreement and the appropriate trading authorization forms.
You may grant our firm discretion over the selection and amount of securities to be purchased or sold
for your account(s) without obtaining your consent or approval prior to each transaction. You may
specify investment objectives, guidelines, and/or impose certain conditions or investment parameters
for your account(s). For example, you may specify that the investment in any particular stock or
industry should not exceed specified percentages of the value of the portfolio and/or restrictions or
prohibitions of transactions in the securities of a specific industry or security. Refer to the Advisory
Business section in this brochure for more information on our discretionary management services.
Item 17 Voting Client Securities
We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice
regarding corporate actions and the exercise of your proxy voting rights. If you own shares of
applicable securities, you are responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the
event we were to receive any written or electronic proxy materials, we would forward them directly to
you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we
would forward any electronic solicitations to vote proxies.
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Item 18 Financial Information
Our firm does not have any financial condition or impairment that would prevent us from meeting our
contractual commitments to you. We do not take physical custody of client funds or securities, or serve
as trustee or signatory for client accounts, and, we do not require the prepayment of more than $1,200
in fees six or more months in advance. Therefore, we are not required to include a financial statement
with this brochure.
We have not filed a bankruptcy petition at any time in the past ten years.
Item 19 Requirements for State-Registered Advisers
We are a federally registered investment adviser; therefore, we are not required to respond to this
item.
Item 20 Additional Information
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position
it should have been in had the trading error not occurred. Depending on the circumstances, corrective
actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you
are eligible to participate in class action settlements or litigation nor do we initiate or participate in
litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or
negligence by issuers of securities held by you.
IRA Rollover Considerations
As part of our investment advisory services to you, we cannot make a recommendation concerning
your employer's retirement plan or other qualified retirement account. However, we can provide you
with educational information. If you elect to roll the assets to an IRA that is subject to our management,
we will charge you an asset based fee as described above under Item 5. You are under no obligation,
contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you
are under no obligation to have the assets in an IRA managed by our firm.
It is important for you to understand, many employers permit former employees to keep their retirement
assets in their company plan. Also, current employees can sometimes move assets out of their
company plan before they retire or change jobs. In determining whether to complete the rollover to an
IRA, and to the extent the following options are available, you should consider the costs and benefits
of:
1. Leaving the funds in your employer's (former employer's) plan.
2. Moving the funds to a new employer's retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage
you to speak with your CPA and/or tax attorney.
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If you are considering rolling over your retirement funds to an IRA for us to manage here are a few
points to consider before you do so:
1. Determine whether the investment options in your employer's retirement plan address your
needs or whether you might want to consider other types of investments.
a. Employer retirement plans generally have a more limited investment menu than IRAs.
b. Employer retirement plans may have unique investment options not available to the
public such as employer securities, or previously closed funds.
2. Your current plan may have lower fees than our fees.
a. If you are interested in investing only in mutual funds, you should understand the cost
structure of the share classes available in your employer's retirement plan and how the
costs of those share classes compare with those available in an IRA.
b. You should understand the various products and services you might take advantage of
at an IRA provider and the potential costs of those products and services.
3. Our strategy may have higher risk than the option(s) provided to you in your plan.
4. Your current plan may also offer financial advice.
5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your
required minimum distribution beyond age 73.
6. Your 401k may offer more liability protection than a rollover IRA; each state may vary.
a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA
assets have been generally protected from creditors in bankruptcies. However, there
can be some exceptions to the general rules so you should consult with an attorney if
you are concerned about protecting your retirement plan assets from creditors.
7. You may be able to take out a loan on your 401k, but not from an IRA.
8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
and may also be subject to a 10% early distribution penalty unless they qualify for an exception
such as disability, higher education expenses or the purchase of a home.
9. If you own company stock in your plan, you may be able to liquidate those shares at a lower
capital gains tax rate.
10.Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important that you understand the differences between these types of accounts and to decide
whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment
adviser representative, or call our main number as listed on the cover page of this brochure.
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