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Shared Vision Wealth Group, LLC
This brochure provides information about Shared Vision Wealth Group LLC (“Shared Vision” “Advisor” or “Firm”)
qualifications and business practices. If you have any questions about the contents of this brochure, please contact us
at 760-349-1750 or by email at mailto:info@sharedvisionwealth.com. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission (SEC) or by any State Securities Authority.
Additional information about Shared Vision is also available at the SEC’s website https://adviserinfo.sec.gov/ (select
“investment adviser firm” and type in our firm name). Results will provide you both Part 1 and 2 of our Form ADV.
We are a registered investment advisory firm. Our registration does not imply any level of skill or training. The oral and
written communications we provide to you, including this brochure, are for you to evaluate us. Please use this
information as factors in your decision to hire us or to continue our business relationship.
ITEM 1 – COVER PAGE ADV PART 2 A
February 23, 2026
CRD #:325000
1902 Wright Place, Suite 200
Carlsbad, CA 92008
info@sharedvisionwealth.com
760-349-1750
ITEM 2– MATERIAL CHANGES
This brochure dated February 23, 2026 has been prepared by Shared Vision Wealth Group to meet SEC requirements. It has
changed materially since our last annual update document in the following ways:
ITEM 5 –FEES AND COMPENSATION
(Added language)
Trust Accounts in excess of $1 million with professional Trustees are eligible for a discounted fee schedule
ITEM 3 –TABLE OF CONTENTS
Item 1 – Cover Page ADV Part 2 A ................................................................................................................................................... 1
Item 2 – Material Changes ............................................................................................................................................................. 2
Item 3 – Table of Contents ............................................................................................................................................................. 3
Item 4 – Advisory Business ............................................................................................................................................................. 4
Item 5 – Fees and Compensation ................................................................................................................................................... 8
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................................................. 11
Item 7 – Types of Clients .............................................................................................................................................................. 11
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................................................... 11
Item 9 – Disciplinary Information .................................................................................................................................................. 14
Item 10 – Other Financial Industry Activities and Affiliations ........................................................................................................ 14
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................................................... 15
Item 12 – Brokerage Practices ....................................................................................................................................................... 16
Item 13 – Review of Accounts ...................................................................................................................................................... 18
Item 14 – Client Referrals and Other Compensation ...................................................................................................................... 19
Item 15 – Custody ........................................................................................................................................................................ 19
Item 16 – Investment Discretion .................................................................................................................................................. 20
Item 17 – Voting Client Securities .................................................................................................................................................. 20
Item 18 – Financial Information ................................................................................................................................................... 20
ITEM 4– ADVISORY BUSINESS
4a: Firm Description
Shared Vision Wealth Group (Shared Vision) was established in 2022 by Bradley Sayre, Carolina Ortiz, and Bryan Theall.
Shared Vision became registered as an investment advisor with the Securities and Exchange Commission in 2023. Our
main office is located in Carlsbad, California.
4a1: Principal Member
Bradley Sayre, Managing Member/Chief Compliance Officer: Mr. Sayre may be contacted by email at
mailto:info@sharedvisionwealth.com or by telephone at (760) 349-1750.
4b: Types of Advisory Services
Shared Vision offers a variety of investment advisory services to our clients with discretionary and non- discretionary
authority. Shared Vision’s services include investment management, financial planning and consulting services. Prior to
providing advisory services, clients are required to enter into a written agreement with Shared Vision.
When we provide investment advice to you regarding your retirement plan account or individual retirement account,
we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal
Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some
conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put
our interests ahead of yours. As fiduciaries we are obligated to do the following:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Investment Management Services
We work with our clients to identify their investment goals and objectives as well as risk tolerance in order to create an
initial portfolio allocation designed to complement their clients’ financial goals and objectives. We may create a
portfolio, consisting of, but not limited to no-load funds and/or load-waived funds, exchange traded funds, individual
stocks or bonds and certificates of deposit.
Each portfolio will be initially designed to meet a particular investment goal which Shared Vision has determined to be
suitable to our client’s circumstances. Once the appropriate portfolio has been determined, we will review the portfolio
and rebalance the account based upon our client’s individual needs, stated goals and objectives. Shared Vision’s
strategy, generally, will be to seek to meet client investment objectives while providing clients with access to personal
advisory services. Shared Vision may also provide advice about any type of legacy position or other investment held in
client portfolios.
Shared Vision owes the client a fiduciary duty to put the client’s interest first which includes, but is not limited to, a duty
of care, of loyalty, and utmost good faith. Your portfolio is customized based on your investment objectives. You may
make requests or make suggestions in writing regarding the investments made in your portfolio. Restrictions on trading
which, in our opinion, are not in your best interest cannot be honored and if forced may result in the termination of our
agreement.
In cases where we are not given discretion, we must receive permission from the client to make any trades on a non-
discretionary basis. In non-discretionary accounts, you have the right to decide whether to act upon Shared Vision
recommendations. If you elect to act on any of the recommendations, you have the right to effect the transaction
through a professional unaffiliated with Shared Vision.
Occasionally our firm utilizes the sub-advisory services of a Third-Party Money Manager (“manager”) for the
management of client accounts. Sub-advisors are utilized by Shared Vision to offer funds to clients managed to a specific
investment objective. The client will not engage the subadvisor directly; the client’s advisory relationship remains with
Shared Vision as set forth in the client’s Investment Advisory Agreement. Our firm will not offer advice on any specific
securities or other investments in connection with this service. Prior to utilizing sub-advisors for our clients, our firm will
provide initial due diligence on managers and ongoing reviews of their management of client accounts. In order to assist
in the selection of a manager, our firm will gather client information pertaining to financial situation, investment
objectives, and reasonable restrictions to be imposed upon the management of the account.
Our firm will periodically review manager reports provided to the client at least annually. Our firm will contact clients
from time to time in order to review their financial situation and objectives; communicate information to managers as
warranted; and, assist the client in understanding and evaluating the services provided by the managers.
Clients will be expected to notify our firm of any changes in their financial situation, investment objectives, or account
restrictions that could affect their financial standing.
Our firm takes actions on behalf of the client to hire or fire managers used in the implementation of a client’s investment
plan and execution of the Advisory Agreement with our Firm. Therefore, the firm has the discretionary authority to hire
or fire the manager or to allocate assets among managers without obtaining the Client’s consent.
Clients should carefully review the disclosure documents of managers for a full description of the services offered,
investments, and strategies used.
Financial Planning & Consulting Services
Shared Vision offers financial planning and consulting services in conjunction with our investment management
services. Standard Financial Planning and consulting services are complimentary for clients that have investment
management services. With respect to estate planning and tax planning, our role will be that of a coordinator between
you and your designated professional(s). Standard Financial Planning does not include the delivery of a formal written
financial plan.
We also provide stand-alone financial planning or consulting services in three areas:
Full Service Financial Planning – Includes tax planning, estate guidance, and a formal written financial plan.
Tax Planning – As part of the consulting services, Shared Vision may not provide you with tax advice. However, Shared
Vision may provide education and assist you in implementing various strategies to help maximize the tax efficiency of
your portfolio such as: advice on tax gain-loss harvesting, timing of purchases and sells, selection of investment type,
asset location, Roth conversions, types of retirement plans individuals and business owners may use to help reduce or
defer tax liability, education on how charitable donations may qualify for tax deduction, etc. With your permission and
at your direction, Shared Vision can also communicate information and coordinate strategy with your existing tax
advisor(s) or other qualified tax advisor(s) as needed. In addition, Shared Vision can coordinate with your investment
account custodian(s) to assist with strategy implementation as directed.
Estate Planning Guidance – As part of the consulting services, Shared Vision may not provide legal advice and Shared
Vision does not draft legal documents. However, Shared Vision may provide education on strategies to assist you with
your estate and legacy goals such as: Multi-generational planning, asset protection, tax efficiency, gifting, charity, etc.
With your permission and at your direction, Shared Vision can also communicate information and coordinate strategy
with your existing legal advisor(s) or other qualified legal advisor(s) as needed. In addition, Shared Vision can coordinate
with your investment account custodian(s) to assist with strategy implementation as directed.
Asset Management clients with assets under management of more than $1 million are eligible to receive the services
above without additional fees.
Retirement Plan Advisory Services
The Retirement Plan Advisory Services we offer help employer plan sponsors to establish, monitor and review their
company’s retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment
selection and monitoring plan structure and participant education. Our firm provides its advisory services as an
investment advisor as defined under Section 3(21) and Section 3(38) of the Employee Retirement Income Security Act
of 1974, as amended (“ERISA”). We offer investment management of 401(k) accounts, profit sharing plans and defined
contribution plans on a Plan level by managing the investment line-up making changes as necessary. Our firm will
establish the plan’s needs and objectives through an initial meeting to collect data, review plan information and assist
in developing or updating the plan’s provision. Ongoing services may include recommendations regarding the selection
and review of unaffiliated mutual funds that, in the Firm’s judgment, are suitable for plan assets to be invested. We
periodically review the investment options selected and make recommendations to keep or replace plans investment
options as appropriate.
For employer-sponsored retirement plans, we provide advisory services as an investment advisor as defined under
Section 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
When serving as an ERISA 3(38) investment manager, the plan sponsor is relieved of all fiduciary responsibility for the
investment decisions made by our firm. We are the discretionary investment manager in accordance with the terms of
a separate ERISA 3(38) Investment Management Agreement between our firm and the plan sponsor. Our investment
management is limited in that it has the discretion solely to replace funds in plan fund lineups and initiate the transfer
of existing balances to the replacements without prior approval from the client.
Additionally, our firm offers Retirement Plan Consulting Services to our Plan Sponsors. Our Firm may assist the Plan
Sponsor by acting as a service provider liaison, providing participant enrollment meetings, and assisting with participant
education. While the primary clients for these services will be pension, profit sharing and 401(k) plans, we offer these
services, where appropriate, to individuals and trusts and organizations. Pension Consulting Services are comprised of
four distinct services. Clients may choose to use any or all of these services.
•
SELECTION OF INVESTMENT VEHICLES - We assist plan sponsors in constructing appropriate asset allocation
models. We will then review various mutual funds (both index and managed) to determine which investments
are appropriate. The number of investments to be recommended will be determined by the client.
•
• MONITORING OF INVESTMENT PERFORMANCE - We monitor client investments continually, based on the
procedures and timing intervals detailed in the Investment Policy Statement. Although our firm is not involved
in any way in the purchase or sale of these investments, we supervise the client's portfolio and will make
recommendations to the client as market factors and the client's needs dictate.
PARTICIPANT ENROLLMENT - We will assist Plan Sponsor in enrolling Plan participants in the Plan, including
conducting an agreed upon number of enrollment meetings. As part of such meetings, we will provide
participants with information about the Plan, which may include information on the benefits of Plan
participation, the benefits of increasing Plan contributions, the impact of preretirement withdrawals on
retirement income, the terms of the Plan, and the operation of the Plan.
•
PLAN EDUCATION - We will assist participant education, which may include preparation of education materials
and/or conducting investment education seminars and meeting for Plan Participants. Such meetings may be on
a group and/or individual basis. Such meetings shall not include specific investment advice about investment
options under the Plan as being appropriate for a particular participant but may include the use of education
investment models.
Plan participants have the ability to exercise control over the assets in their account, and we have no authority
or discretion to direct the investment of assets of any participant’s account under the Retirement Plan
Consulting services offered by our firm.
• ADDITIONAL INFORMATION CONCERNING PENSION & RETIREMENT PLAN CONSULTING- All pension
consulting services shall be in compliance with applicable State rules and statutes and/or the Investment
Advisers Act of 1940, rules and regulations thereunder regulating the services provided by this Agreement. This
section applies to an Account that is a pension or other employee benefit plan (a “Plan”) governed by the
Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the Account is part of a Plan and
we accept appointments to provide advisory services to such Account, Advisor acknowledges that it is a
fiduciary within the meaning of Section 3(21) of ERISA (but only with respect to the provision of services
described in section 1 of this agreement). Client represents that (i) Advisor’s appointment and services are
consistent with the Plan documents, (ii) Client has furnished Advisor true and complete copies of all documents
establishing and governing the Plan and evidencing your authority to retain Advisor. Client further represents
that he will promptly furnish Advisor with any amendments to the Plan, and Client agrees that, if any
amendment affects our rights or obligations, such amendment will be binding on Advisor only with our prior
written consent. If ERISA or other applicable law requires bonding with respect to the assets in the account,
Client will obtain and maintain at his/her/its expense bonding that satisfies this requirement and covers Advisor
and any of our affiliates.
As an investment advisor registered under the Securities Act of California and other applicable federal and state
securities laws, Shared Vision owes the client a fiduciary duty to put the client’s interest first which includes, but is not
limited to, a duty of care, of loyalty, to act in accordance with plan documents, and utmost good faith.
4c: Client Tailored Relationships and Restrictions
Shared Vision owes the client a fiduciary duty to put the client’s interest first which includes, but is not limited to, a
duty of care, of loyalty, and utmost good faith. Your portfolio is customized based on your investment objectives. You
may make requests or make suggestions regarding the investments made in your portfolio. Restrictions on trading
which, in our opinion, are not in your best interest cannot be honored and if forced may result in the termination of
our agreement.
You are under no obligation to act upon Shared Vision’s or associated person's recommendations.
4e: Assets under Management (AUM)
Shared Vision as of December 31, 2025 has $ 326,289,796 in discretionary assets under management and $ 9,565,403 in non-
discretionary assets under management for a total of $335,855,199 assets under management.
ITEM 5 –FEES AND COMPENSATION
5a, b, c & d: Fee Schedules, Payments & Options
Investment Management
ASSETS UNDER MANAGEMENT
ANNUAL FEE (%)
First $500,000
0.95%
Next $500,000
0.85%
Next $3,000,000
0.75%
Next $6,000,000
0.60%
Next $10,000,000 and above
0.40%
Fees are negotiable. Fees may lower based on several factors, including:
Size of the relationship – Larger accounts may receive more favorable pricing.
•
• Accounts within the same household will be combined under a signed householding form for a reduced
fee unless the client instructs otherwise.
Loyal long-term clients may retain legacy pricing from their original agreements
•
Trust Accounts in excess of $1 million with professional Trustees are eligible for a discounted fee schedule
Our employees and their family related accounts are charged a reduced fee for services.
For purposes of determining value, securities and other instruments traded on a market for which actual transaction
prices are publicly reported are valued at the last reported sale price on the principal market in which they are traded.
If the investments are not managed assets, they are not included in Shared Vision’s fee calculation.
Compensation for our services will be calculated in accordance with what is set in the client agreement. We may modify
the terms of any agreement by written changes submitted to the client for signature. Changes will not become effective
until after the client has agreed to the change in writing. While we strive to maintain competitive fees, the same or
similar services may be available from other firms at higher or lower fees.
Shared Vision requires written authorization from the client to deduct advisory fees from an account held by a qualified
custodian. Shared Vision fees are paid from your account by the custodian when we submit an invoice to them. At the
same time Shared Vision sends the qualified custodian written notice of the amount of the fee to be deducted from the
client’s account, in all instances, Shared Vision will send the client a written invoice including the fee, the formula used
to calculate the fee, the fee calculation itself, the time period covered by the fee and, if applicable, the amount of assets
under management on which the fee was based. The invoice will contain the name of the custodian on the invoice. We
strongly urge you to compare our invoices with the fees listed in the custodian account statements.
Invoicing includes any fee arrangement with third-party investment advisers, if the third-party adviser sends invoice
information, which includes Shared Vision’s advisory fee, and if the third-party adviser sends the invoice information
directly to the client on behalf of Shared Vision. If any invoice information relating to Shared Vision’s advisory fees is
missing, Shared Vision will provide the missing information.
Shared Vision fees are paid quarterly in advance or arrears as indicated in your investment advisory agreement based on the
value as of the last business day of the prior quarter, with payment due within 10 days from the date of the invoice. Our
fee is determined by taking the percentage rate we charge, divided by four, times the market value of the account. The
Market value is the sum of the values of all managed assets in the account, not adjusted by any margin debit.
In cases where there are partial fees at the commencement or termination of our agreement, they will be billed or
refunded on a pro-rated basis contingent on the number of days the account was open. Quarterly fee adjustments for
additional assets received into the account during a quarter or for partial withdrawals will also be provided on the above
pro rata basis. If there is insufficient cash in your account to pay your fees, securities in your portfolio may be sold to
pay our fee.
In addition to our fees, there may be custodial, mutual fund, 12b-1 fees or similar third-party management fees and
charges. See 5c: Third Party Fees below.
Sub-Advised Programs.
As discussed in Item 4 above, there are occasions where an independent Third-Party Money Manager (“manager”) acts
as a sub-adviser to our firm. In those circumstances, the manager manages the assets based upon the parameters
provided by our firm. The client will not engage the subadvisor directly; the client’s advisory relationship remains with
Shared Vision as set forth in the client’s Investment Advisory Agreement. Sub Advisors charge separate fees for the
services provided. A separate fee is charged by Shared Vision for portfolio monitoring, oversight and ongoing due
diligence on the manager. See Item 4 for other services provided by Shared Vision when utilizing subadvisors.
The total advisory fee may be collected from the custodian by our firm. Alternatively, the manager fee may be collected
separately from the custodian. The total fee will include our firm’s portion of the investment advisory fee as well as the
manager’s fee. Fee charged by the managers range from 0.2% to 1.00%. Clients may be able to go to the sub- adviser
directly for advisory services.
Shared Vision may at any time terminate the relationship with a manager that manages your assets. Shared Vision will
notify you of instances where we have terminated a relationship with any manager you are investing with. Shared Vision
will not conduct on-going supervisory reviews of the manager following such termination.
Factors involved in the termination of a manager may include a failure to adhere to their stated management style or
your objectives, a material change in the professional staff of the manager, unexplained poor performance, unexplained
inconsistency of account performance, or our decision to no longer include the manager on our list of approved
managers.
Information regarding the services and strategies provided by managers can be found in the specific manager’s ADV
2A. Clients are encouraged to carefully review each manager’s ADV 2A disclosure brochure for service level, fee, conflict
of interest, and professional background information applicable to each sub-advisor.
Financial Planning & Consulting Fees
Standard Financial Planning and consulting services are complimentary for clients that have investment management services.
Full Financial Planning and consulting services are complimentary for clients with more than $1 million of assets under
management. Full Financial Planning and consulting services are also available for a fixed fee. Services performed on a fixed fee
basis are paid as set forth in our agreement with you. Depending on the size and scope of the project, we may request fees up
front, a partial retainer or to be paid in full upon completion. All invoices are due within ten (10) days of invoice.
Retirement Plan Advisory Services
Fees for portfolio monitoring, retirement plan ERISA planning and consulting services depend on the types of services
that serve the client. We typically use our standard fee schedule. Fees are negotiable depending on the size of the plan
and services rendered. Fees are paid quarterly in advance or arrears as designated in our agreement with you. Fees
billed in advance are based on the value of the assets in the account as of the last business day of the prior quarter.
Fees billed in arrears are based on the value of assets in the account as of the end of the billing cycle on the last business
day of the quarter. For Plans where our fee is billed to the custodian, the fee is deducted directly from the participant
accounts. Written authorization permitting us to be paid directly from the custodial account is outlined in the
Agreement. Our maximum investment advisory fee is 1%, or we may negotiate a lower advisory fee. The specific
advisory fees are set forth in your Investment Advisory Agreement.
Shared Vision does not take receipt of more than $1200 in fees per client six (6) months or more in advance.
Lower fees for comparable services may be available from other sources. If a conflict exists between the interests of the
Advisor or its associated persons and the interest of the client, the client always has the right to decide whether to act
on any of the recommendations made by Shared Vision and if you elect to act on any of the recommendations, you
have the right to effect the transactions through a professional unaffiliated with Shared Vision. Our fiduciary obligation
is to always act and recommend in the client’s best interest.
5b: Account Requirements and Types of Clients.
Shared Vision caters primarily to affluent individuals and their retirement accounts, family offices and family investment
vehicles who seek an approach to capital appreciation by investing in established stocks, exchange-traded funds, mutual
funds and fixed income. Shared Vision investment programs are also suitable for institutional investors such as pension
and profit-sharing plans, trust, estates and/or charitable organizations and corporations. While there is no account
minimum, Shared Vision may decline to accept accounts smaller than $500,000.
5c: Third Party Fees
You are responsible for the payment of all third-party fees (i.e. custodian fees, mutual fund fees, 12b-1 fees, transaction
fees, etc.). Those fees are also separate and distinct from the fees we charge. Shared Vision does the best we can to
minimize all fees and transaction costs.
All brokerage commissions, stock transfer fees, 12b-1 fees and other similar charges incurred in connection with
transactions for the account will be paid out of the assets in the account and are in addition to the investment
management fees paid to us. While we take measures to ensure the fees charged are accurate, it is your responsibility
to ensure the amount of fee charged is correct. In addition to invoices and reports sent by us, you will receive statements
directly from the custodian or mutual funds or other investments you hold. We strongly urge you to compare our
invoices and reports to custodian statements for accuracy.
5.d: Termination
The investment advisory contract may be terminated by the client within five (5) business days of signing the contract
without incurring any advisory fees or penalty. Ongoing, Shared Vision or our clients can terminate our agreement upon
receipt of written notice to the other party.
When an agreement is terminated, we will refund any pre-paid, unearned fees based on the number of days remaining
in the quarter after termination. Refunds will be made within 30 days of the effective date of termination.
You will be responsible for paying all fees including full quarterly custodial administrative fees, account closure fees,
mutual fund fees and all trading costs due to the termination. If there is insufficient cash in the account, the liquidation
of some securities may be used to pay the fees. Prior to termination of the agreement, we can provide a good-faith
estimate of these fees.
5e: Other Investment Compensation
Shared Vision does not accept commission for the sale of securities or other 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
Shared Vision does not charge advisory fees on the performance of funds or securities in your account.
ITEM 7 – TYPES OF CLIENTS
Shared Vision generally provides asset management and financial planning services to the following types of clients:
Pension and Profit-Sharing Plans
Trusts
Estates
High-Net-Worth Individuals
Charitable Organizations
Churches
Corporations
Individuals
Minimum Account Size: Shared Vision does not have an account minimum.
ITEM 8–METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
8a: Analysis
In determining the recommendations to give to you, we first gather and consider information regarding several factors
including our client’s:
Current financial situation;
Investment goals and objectives;
Current and long-term needs;
Tolerance and appetite for risk; and
Level of investment knowledge.
•
•
•
•
•
Shared Vision uses multiple sources of information to obtain analysis and strategies. They include sources such as
financial newspapers, financial magazines, research prepared by others, corporate rating services, prospectuses,
company press releases, annual reports and filings with the SEC.
Shared Vision’s methods of analysis include Fundamental analysis, Modern portfolio theory and Cyclical Analysis.
Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or
the analysis of management or competitive advantages.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given
amount of portfolio risk or equivalently minimize risk for a given level of expected return, each by carefully choosing
the proportions of various assets.
Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security.
8b: Investment Strategies
Asset Allocation
Shared Vision recommends a mix of asset classes for your portfolio based on an assessment of your long- term financial
objectives. Where appropriate, we will recommend an allocation to high-quality, short-term and intermediate term
bonds (within a broadly diversified index or asset class mutual fund) to reduce overall portfolio risk, generate a more
predictable cash flow (interest income), facilitate portfolio rebalancing, and provide a hedge against inflation.
If your objective is a higher annual expected return and you are willing to accept a higher degree of risk, we
will recommend a portfolio with greater weighting to stocks in general and small company and value stocks specifically
(using index or asset class mutual funds). Recommended stock allocations will generally be globally diversified among
the U.S., foreign developed markets, and emerging markets. In certain circumstances, we may include traded REITs in
limited percentages. Our recommended asset allocation is not influenced by current market conditions. This asset
allocation is altered only when your long-term investment objectives have changed.
Asset Allocation is based on the principle that different assets perform differently in different market and economic
conditions. It is difficult to predict how any particular asset class will perform in any given year.
Diversification is a strategy for managing risk. Diversification does not ensure a profit or protect against a loss in a
declining market. Asset Allocation is unlikely to generate the greatest returns since not all of the asset classes will do
equally well.
Rebalancing
Asset allocations for your portfolio will change as financial markets rise and fall and the specific assets of different parts
of your portfolio change. This creates the opportunity to selectively rebalance your portfolio in order to bring asset
class percentages back to your policy targets. Asset classes that have risen beyond predetermined limits are
sold by an amount that brings the allocation back in line with policy targets, and those that have fallen in value are
purchased in the same way. This is a method of buying low and selling high that is not based on trying to predict the
direction of markets or asset returns.
This rebalancing has the effect of enhancing portfolio returns while maintaining the agreed-upon risk. In order to limit
rebalancing transactions and the costs associated with buying and selling mutual funds through the chosen custodian,
Shared Vision has pre-determined ranges in which allocations may vary and at which rebalancing is initiated.
Specific Investments
We generally select ETFs, mutual funds or similar securities, we may at times select individual securities or build
individual stock portfolios for our clients. In these cases, Shared Vision examines each securities’ management, financial
condition, and market position and ensures that any purchases of individual securities work towards the client’s
portfolio goals, investment horizons and exposure to risk. Individual stocks present potential risks as prices of individual
securities can move up or down due to general economic conditions, industry specific conditions, government
regulations or corporate management, among other factors.
8c: Risk of Loss
All investments include a risk of loss that clients should be prepared to bear. Performance of any investment is not
guaranteed. We use our best efforts and expertise to manage your assets. However, we cannot guarantee any level of
performance or that you will not experience financial loss.
Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived
value. The risk assumed is that the market will fail to reach expectations of perceived value.
Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same
expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated
by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The
exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on
individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second
portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio
exists which has better expected returns.
Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide
performance. The risks with this strategy are two-fold: 1) the markets do not always repeat cyclical patterns; and 2) if
too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit.
Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed
below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or
any other government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual
funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature
(lower risk) or stock “equity” nature.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in
ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of
concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility
of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic
shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large
sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals,
(2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in
the attitude of speculators and investors.
Equity investments generally refers to buying shares of stocks in return for receiving a future payment of dividends
and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to
specific situations for each company, industry conditions and the general economic environment.
Options strategies are complex investments and entail risks that vary with the type of options strategy employed.
Buying Options:
When you buy an option, you pay a premium for the right to buy or sell an underlying asset (like a stock, commodity,
or currency) at a specific price (strike price) before a certain date (expiration date). The risk in buying an option is that
if the underlying asset doesn't move in the direction you anticipated or if it doesn't move enough, you could lose the
premium you paid for the option. In other words, if the option expires out of the money (meaning the underlying asset's
price did not reach the strike price before the expiration date), the buyer loses their premium.
Selling Options:
When you sell an option, you receive a premium from the buyer in exchange for the obligation to buy or sell an
underlying asset at a specific price before a certain date. The risk in selling an option is that if the underlying asset
moves in the opposite direction of what you anticipated, you could lose more money than the premium you received.
In other words, if the option expires in the money (meaning the underlying asset's price reaches the strike price before
the expiration date), the seller could be obligated to buy or sell the underlying asset at a loss.
In summary, the risks of buying or selling options involve potential losses if the underlying asset does not move in the
anticipated direction or if it moves too much in the opposite direction.
Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This
type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment
grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds
may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income
securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually
more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and
credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation
linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of
losing share price value, albeit rather minimal.
ITEM 9– DISCIPLINARY INFORMATION
9a: Civil or Criminal Actions
Shared Vision and its managers have never been found guilty, convicted or pleaded no contest to a criminal or civil action
in a domestic, foreign or military court.
9b: Administrative Enforcement Proceedings
Shared Vision and its managers have never been found by the SEC, any other state or federal agency or any foreign
regulatory agency to have caused loss of the ability of an investment-related business to do business or been sanctioned,
barred or limited in investment-related activities.9c: Self-Regulatory Organization Enforcement Proceedings Shared Vision
and its managers have never been found by a self-regulatory agency to have caused loss of the ability of an investment-
related business to do business. Additionally, Shared Vision and its managers have never been found in violation of self-
regulatory agency rules such that they were barred, suspended, limited in advisory functions or fined.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
10a: Broker Dealers and Registered Representatives
Shared Vision is not registered as a broker-dealer, and our employees are not registered representatives of any broker-
dealer.
10b: Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor
Neither Shared Vision nor our employees hold any of the above registrations.10c: Registration Relationships Material to this
Advisory Business and Possible Conflicts of Interests.
The principal business of Shared Vision is that of a registered investment advisor and provider of financial planning
services. Shared Vision does not accept commission for the sale of securities or other investment products, including
asset-based sales charges or service fees from the sale of mutual funds. Shared Vision will disclose any material conflict of
interest relating to Shared Vision, our representatives, or any of our associates which could reasonably be expected to impair
the rendering of unbiased and objective advice.
10d: Selection of Other Advisors and How this Advisor is Compensated for those Selections
Shared Vision is not paid for the selection of other advisors, asset managers or portfolio managers.
Shared Vision may enter directly into sub-advisory relationships with independent registered investment advisory firms
(“sub-advisors”) on behalf of its clients as part of our discretionary services. We do not receive any additional
compensation for selecting a sub-advisor. Prior to entering into a relationship, Shared Vision performs a due diligence
review of the sub-advisor. This review includes, but is not limited to, the review of regulatory filings, investment
offerings, and the performance of the strategies considered.
When a strategy offered through a sub-advisor is appropriate for a client of Shared Vision, the client will be given the
sub-advisor’s Form ADV Part 2A, Privacy Notice, and any other information that may be relevant or informative to the
client.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING
11a: Code of Ethics Description
We have adopted a Code of Ethics to which all investment advisor representatives and employees are bound to adhere.
The key component of our Code of Ethics states that Shared Vision and its investment advisor representatives and
employees shall always:
Act with integrity, competence, dignity, and ethics when dealing with the public, clients, prospects, employers,
and employees.
Exercise its authority and responsibility for the benefit and interest of its clients first and to refrain from having
outside interests that conflict with the interests of its clients. Shared Vision must avoid any circumstances that
might adversely affect or appear to affect its duty of complete loyalty to its clients.
Refrain from disclosing any nonpublic personal information about a client to any nonaffiliated third-party
unless the client expressly gives permission to Shared Vision to do so. All client information will otherwise
be treated as confidential.
Maintain the physical security of nonpublic information, including information stored on computers.
This Code of Ethics is in place to guide the personal conduct of our team and embodies our fiduciary duties and
responsibilities to you and sets forth our practice of supervising the personal securities transactions of employees with
prior or concurrent access to client trade information. A copy of the Shared Vision Code of Ethics is available, free of
charge, upon request.11b, c & d: Participation or Interest in Client Transactions.
Shared Vision, or its employees, may buy and sell some of the same securities for our own accounts that we buy and sell
for our clients. We will always buy or sell from our clients’ accounts before we buy or sell from our accounts. In some
cases, Shared Vision, or its employees, may buy or sell securities for our own accounts and not for clients’ accounts, as it
may not meet the objectives or plans for the client. There are possible conflicts of interest, which our Code of Ethics
addresses. We will always evaluate our activity from the point of view of our clients to ensure that any and all required
disclosures are made. For example, we will disclose anything that would cause you to be unfairly influenced to make
any decision regarding actions or inactions in your account.
Shared Vision does not buy or sell between Shared Vision, our employees or our clients’ accounts.
Shared Vision always tries to get the best price for the client. Shared Vision has in place internal controls and processes
to allow contemporaneous trading (submitting Shared Vision or employee orders at the same time as client orders) in
block or aggregate trades. In other cases, except in the case of unaffiliated mutual funds, we will always trade individual
securities in a client account before we trade Shared Vision or employee accounts.
Shared Vision does not recommend securities to advisory clients nor buy or sell securities for advisory client accounts
in which Shared Vision or a related person has a material financial interest.
ITEM 12– BROKERAGE PRACTICES
12a: Selecting Brokerage Firms
The Custodian and Brokers We Use
Shared Vision does not maintain custody of your assets that we manage. Your assets must be maintained in an account
at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co.,
Inc. (Schwab) or Fidelity Investments, both FINRA-registered broker-dealers, and members of SIPC, as qualified
custodians. Shared Vision is independently owned and operated and not affiliated with Schwab or Fidelity. Both Schwab
and Fidelity will hold your assets in a brokerage account and buy and sell securities when instructed to do so. While we
recommend that you use Schwab or Fidelity as custodian/broker, you will decide whether to do so and open your
account with Schwab or Fidelity by entering into an account agreement directly with them. If you do not wish to place
your assets with Schwab or Fidelity, then we cannot manage your account. Even though your account is maintained at
Schwab or Fidelity, we can still use other brokers to execute trades for your account, as described under Your Custody
and Brokerage Costs below. Shared Vision does not receive any client referrals from Schwab or Fidelity.
How We Select Brokers/Custodians
We seek to select a custodian/broker who will hold your assets and execute transactions on terms that are overall
most advantageous when compared to other available providers and their services. We consider a wide range of factors,
including, among others, these:
o
o
o
combination of transaction execution services along with asset custody services (generally without a
separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for your account)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill
payment, etc.)
o breadth of investment products made available (stocks, bonds, mutual funds, exchange traded funds (ETFs),
etc.)
availability of investment research and tools that assist us in making investment decisions
o
o quality of services
o
competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and
willingness to negotiate them
o
o
reputation, financial strength and stability of the provider their prior service to us and our other clients
availability of other products and services that benefit us, as discussed below (see “Products and Services
Available to Us from Custodians”)
To avoid creating a possible conflict of interest in recommending broker-dealers, we have established the following
restrictions in order to ensure our fiduciary responsibilities:
1. Shared Vision adheres to our Code of Ethics as outlined in Item 11 above.
2. If Shared Vision receives separate compensation for transactions, we will fully disclose them.
3. Shared Vision emphasizes the unrestricted right of you to select and choose your own broker or
dealer.
4. Shared Vision will always act in accordance with all applicable federal and state regulations
governing registered investment advisory practices.
Your Custody and Brokerage Costs
For our clients’ accounts it maintains, our custodians generally do 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 custodial
account. For some accounts, our custodians may charge you a percentage of the dollar amount of assets in the account
in lieu of commissions. Our custodian’s rates may be determined by committing a certain value of assets at the
custodian. This commitment benefits you because the overall rates you pay are lower than they would be if we had
not made the commitment. You may also be charged a flat dollar amount as a “prime Broker” or “trade away” fee for
each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the
securities sold are deposited (settled) into your custodial account. These fees are in addition to the commissions or
other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we
have the custodian execute most trades for your account.
Products and Services Available to Us from Schwab1 (for clients with Schwab accounts)1.
Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment
advisory firms like us. They provide us and our clients with access to its institutional brokerage – trading, custody,
reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also
makes 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. Here is a more detailed description of Schwab’s support services:
2
Services that Benefit You. Schwab’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 include some to which we might not otherwise have access or that would require a significantly higher minimum
initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account.
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
Services that May Not Directly Benefit You. Schwab also makes available to us other products and services that benefit
us but may not directly benefit you or your account. These products and services assist us in managing and administering
our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this
research to service all or some substantial number of our clients’ accounts, including accounts not maintained at
Schwab. In addition to investment research, Schwab also makes available software and other technology that:
o provide access to client account data (such as duplicate trade confirmations and account statements);
o
o provide pricing and other market data;
1 1 For clients with Fidelity accounts similar services are also provided to us by Fidelity Institutional® which is a division of Fidelity
Investments which offers clearing and custody services, investment and technology products and solutions, brokerage and trading
services, and a range of insights, expertise to financial intermediary firms and institutions.
facilitate payment of our fees from our clients’ accounts; and
assist with back-office functions, recordkeeping and client reporting.
access to employee benefits providers, human capital consultants and insurance providers.
technology, compliance, legal, and business consulting;
o
o
o
o educational conferences and events
o publications and conferences on practice management and business succession; and
o
o
Services that Generally Benefit Only Us. Schwab also offers other services intended to help us manage and further develop our
business enterprise. These services include:
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the
services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third-
party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our
personnel.
We endeavor at all times to put the interests of our clients first. You should be aware, however, that the receipt of the
types of benefits discussed above can create a potential conflict of interest by influencing our choice of a broker- dealer.
12.b: Sales Aggregation
Shared Vision is authorized to aggregate purchases and sales and other transactions made for your account with
purchases and sales and other transactions in the same or similar securities or instruments for other clients of ours.
When we aggregate transactions, the actual prices applicable to the aggregated transactions will be averaged, and the
account will be deemed to have purchased or sold its proportionate share of the securities or instruments involved at
the average price obtained. Stock exchange regulations may in certain instances prevent the executing broker-dealer
from delivering to the account a confirmation slip with respect to its participation in the aggregated transaction and, in
such event, we will advise you in writing of any purchase or disposition of instruments for the account with respect to
any such aggregated transaction. We will direct that confirmations of any transactions effected for the account will be
sent, in conformity with applicable law, to you.
ITEM 13 – REVIEW OF ACCOUNTS
13a: Periodic Reviews
Accounts are managed and reviewed by Bradley Sayre, CCO or his designee. The frequency of reviews is determined
based on your investment objectives, but no less than annually. Accounts are reviewed to determine if the positions,
transactions and strategies are consistent with the Client’s stated investment objective(s) and whether any rebalancing
or adjustments may be necessary.
Depending on the type of financial planning service requested, we may meet on a regular basis with you to discuss any
potential changes to your financial plan.
13b: Review Triggers
More frequent reviews are triggered by a change in your investment objectives; tax considerations; large deposits or
withdrawals; large sales or purchases; loss of confidence in corporate management; or, changes in economic climate.
13c: Regular Reports
All investment advisory clients receive reports as needed, but no less than annually, on representative investments
recommended specifically by Shared Vision. Reports are generated through ORION based on custodian data. Orion is a
provider of integrated, web-based portfolio rebalancing, performance reporting and customer relationship management
software for independent advisors. Performance Reporting reports may contain such items as: Performance Review,
Summary by Account, Asset Allocation, Security Performance, Realized Gains/Losses, Holdings, and Transactions that
occurred during the period. Custodian data is provided to Orion directly and reports are generated only using the
custodian data.
Investment advisory clients also receive standard account statements from the custodian of their accounts on at least
a quarterly basis.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
14a: Economic Benefits Provided by Third Parties for Advice Rendered to Clients
We receive an economic benefit from Schwab in the form of the support products and services it makes available to us
and other independent investment advisors that have their clients maintain accounts at Schwab. We receive similar
benefits from Fidelity. These products and services, how they benefit us, and the related conflicts of interest are
described above (see Item 12 – Brokerage Practices). The availability to us of Schwab’s and Fidelity’s products and
services is not based on us giving particular investment advice, such as buying particular securities for our clients.
Shared Vision does not receive economic benefits from third parties for the advice we render to our clients. As disclosed
in Item 12 above, broker-dealers may provide services, tools or other non-financial benefits to us as a benefit for using
the broker-dealer’s services. However, we endeavor at all times to put the interests of our clients first. You should be
aware, however, that the receipt of benefits can create a potential conflict of interest by influencing our choice of a
broker-dealer.
14b: Compensation to Non‐Advisory Personnel for Client Referrals
Shared Vision has an arrangement with Willow Network, Inc. (“Willow”), a lead generation company, under which
Willow provides potential client leads. Shared Vision Investment Advisor Representatives pay Willow a flat fee for the
opportunity to receive leads. Willow is not compensated based on the number of leads that result in advisory services
or based on the amount of assets placed under management by referred clients. This lead generation arrangement does
not impact the fees that clients pay for advisory services, and clients are not charged any additional fees as a result of
this referral arrangement.
ITEM 15 – CUSTODY
Shared Vision clients’ accounts are held by a qualified custodian, as designated by the client in writing, and other than
to withdraw advisory fees, Shared Vision shall have no liability to the client for any loss or other harm to any property
in the account. This includes harm to any property in the account resulting from the insolvency of the custodian or any
unauthorized acts of the agents or employees of the custodian and whether or not the full amount or such loss is covered
by the Securities Investor Protection Corporation (“SIPC”) or any other insurance which may be carried by the custodian.
The client understands that SIPC provides only limited protection for the loss of property held by a broker-dealer.
Shared Vision owes the client a fiduciary duty to put the client’s interest first which includes, but is not limited to, a duty
of care, of loyalty, and utmost good faith.
Custodial statements will include fees charged by Shared Vision. At the same time, we invoice the custodian, in all
instances, Shared Vision will send the client a written invoice, including the fee, the formula used to calculate the fee,
the fee calculation itself, the time period covered by the fee, and, if applicable, the amount of assets under management
on which the fee was based. Also, Shared Vision will include the name of the custodian(s) on your fee invoice. Shared
Vision will send these to the client concurrently with the request for payment or payment of Shared Vision advisory fees.
We urge the client to compare this information with the fees listed in the account statement.
ITEM 16 – INVESTMENT DISCRETION
Shared Vision asks our clients to give us discretionary authority to execute transactions without our client’s prior
approval. These transactions may include the purchase and selling of securities, arranging payments or generally acting
on behalf of our clients in most matters necessary to the handling of the account. This includes the buying or selling of
securities, the rebalancing and selection of portfolios, the selection of portfolio managers or subadvisors or the
disbursement of funds to the client as requested or arranged. Discretionary authority is granted once an election is
made on the Investment Advisory Agreement and the agreement is signed by the client. In cases where we are not
given discretion, we must receive permission from the client to make any trades on a non-discretionary basis.
You may make requests or make suggestions regarding the investments made in your portfolio. Restrictions on trading
which, in our opinion, are not in your best interest cannot be honored and if forced may result in the termination
of our agreement.
ITEM 17 – VOTING CLIENT SECURITIES
The clients of Shared Vision retain the authority to proxy vote. You should ensure that proxy ballots are mailed directly
to you by selecting this option on your custodial application forms. You are welcome to delegate said proxy voting
authority to a third-party representative (non-advisory personnel) by filing the appropriate custodial form. Shared Vision
will not accept authority to vote client proxies. This policy is set forth in Shared Vision’s standard advisory agreements.
Proxy material will be sent from the transfer agent and in rare cases could come from Schwab or Fidelity.
Should Shared Vision inadvertently receive proxy information for a security held in clients' accounts, it would
immediately forward such information on to clients but will not take any further action with respect to the voting of such
proxy. Upon termination of the advisory relationship, Shared Vision will make a good faith and reasonable attempt to
forward proxy information inadvertently received on behalf of clients to the forwarding address provided by clients.
Clients may contact Shared Vision for advice or information about a particular proxy vote; however, Shared Vision shall
not be deemed to have proxy voting authority solely as a result of providing such advice to clients.
ITEM 18 – FINANCIAL INFORMATION
18a: Balance Sheet
Shared Vision does not solicit prepayment of more than $1200 in fees per client six (6) months or more in
advance.
18b: Financial Conditions
Shared Vision has no financial issues that could impair our ability to carry out our fiduciary duty to our clients.
18c: Bankruptcy Petition
Shared Vision has never been the subject of a bankruptcy petition.