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F O R M A D V P A R T 2 A
D I S C L O S U R E B R O C H U R E
Shum Financial Group, Inc.
Office Address:
2205 Harbor Bay Parkway
Alameda, CA 94502
Tel: 510-748-7462
Fax: 510-769-4990
cliff@shumfinancial.com
F E B R U A R Y 2 3 ,
2 0 2 6
This brochure provides information about the qualifications and business practices of Shum
Financial Group, Inc. Being registered as a registered investment adviser does not imply a certain
level of skill or training. If you have any questions about the contents of this brochure, please
contact us at 510-748-7462. 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 Shum Financial Group, Inc. (CRD #285426) is available on the SEC’s
website at www.adviserinfo.sec.gov
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Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
Since the last filing of this brochure on February 12, 2025, the following has been changed:
•
Item 4 has been updated with the firm’s most recent assets under management
calculation.
• The firm address has been updated.
Full Brochure Available
This Firm Brochure being delivered is the complete brochure for the Firm.
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Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes ......................................................................................................................... 2
Annual Update ....................................................................................................................................................... 2
Material Changes since the Last Update ....................................................................................................... 2
Full Brochure Available ...................................................................................................................................... 2
Item 3: Table of Contents ......................................................................................................................... 3
Item 4: Advisory Business ....................................................................................................................... 6
Firm Description ................................................................................................................................................... 6
Types of Advisory Services ............................................................................................................................... 6
Client Tailored Services and Client Imposed Restrictions..................................................................... 9
Wrap Fee Programs ........................................................................................................................................... 10
Client Assets under Management ................................................................................................................. 10
Item 5: Fees and Compensation .......................................................................................................... 10
Method of Compensation and Fee Schedule ............................................................................................. 10
Client Payment of Fees ...................................................................................................................................... 12
Additional Client Fees Charged ..................................................................................................................... 12
Prepayment of Client Fees ............................................................................................................................... 13
External Compensation for the Sale of Securities to Clients ............................................................... 13
Item 6: Performance-Based Fees and Side-by-Side Management ........................................... 13
Sharing of Capital Gains.................................................................................................................................... 13
Item 7: Types of Clients ......................................................................................................................... 13
Description ............................................................................................................................................................ 13
Account Minimums ............................................................................................................................................ 13
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................... 13
Methods of Analysis ........................................................................................................................................... 13
Investment Strategy ........................................................................................................................................... 14
Security Specific Material Risks ..................................................................................................................... 14
Item 9: Disciplinary Information ....................................................................................................... 15
Criminal or Civil Actions .................................................................................................................................. 15
Administrative Enforcement Proceedings ................................................................................................ 15
Self-Regulatory Organization Enforcement Proceedings .................................................................... 16
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Item 10: Other Financial Industry Activities and Affiliations ................................................... 16
Broker-Dealer or Representative Registration ........................................................................................ 16
Futures or Commodity Registration ............................................................................................................ 16
Material Relationships Maintained by this Advisory Business and Conflicts of Interest . 16
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest . 16
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading ..................................................................................................................................... 16
Code of Ethics Description .............................................................................................................................. 16
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest ................................................................................................................................................................... 17
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest ................................................................................................................................................................... 17
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest ........................................................................................................ 17
Item 12: Brokerage Practices .............................................................................................................. 18
Factors Used to Select Broker-Dealers for Client Transactions ......................................................... 18
Aggregating Securities Transactions for Client Accounts .................................................................... 20
Item 13: Review of Accounts ............................................................................................................... 20
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved ................................................................................................................................................. 20
Review of Client Accounts on Non-Periodic Basis .................................................................................. 20
Content of Client Provided Reports and Frequency .............................................................................. 20
Item 14: Client Referrals and Other Compensation ..................................................................... 20
Economic benefits provided to the Advisory Firm from External Sources and Conflicts of
Interest ................................................................................................................................................................... 20
Advisory Firm Payments for Client Referrals .......................................................................................... 21
Item 15: Custody ...................................................................................................................................... 21
Account Statements ........................................................................................................................................... 21
Item 16: Investment Discretion .......................................................................................................... 21
Discretionary Authority for Trading ........................................................................................................... 21
Item 17: Voting Client Securities ........................................................................................................ 22
Proxy Votes ........................................................................................................................................................... 22
Item 18: Financial Information .......................................................................................................... 22
Balance Sheet ....................................................................................................................................................... 22
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients ................................................................................................................................... 22
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Bankruptcy Petitions during the Past Ten Years .................................................................................... 22
Brochure Supplement (Part 2B of Form ADV) ............................................................................... 24
Supervised Person Brochure .......................................................................................................................... 24
Principal Executive Officer - Cliff Wing-Yin Shum, CFP® .................................................................... 24
Item 2 Educational Background and Business Experience ................................................................. 24
Professional Certifications .............................................................................................................................. 24
Item 3 Disciplinary Information .................................................................................................................... 25
Item 4 Other Business Activities ................................................................................................................... 25
Item 5 Performance Based Fee Description .............................................................................................. 25
Item 6 Supervision ............................................................................................................................................. 26
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Item 4: Advisory Business
Firm Description
Shum Financial Group, Inc. (“SFG”) was founded in September 2016 and became registered
as an investment adviser in January of 2017. Cliff Shum is 98.567% owner.
SFG is a fee based investment management firm. Investment advisor representative, Mr. Shum,
sells insurance as a sole proprietor. SFG does not act as a custodian of client assets.
An evaluation of each client's initial situation is provided to the client, often in the form of a net
worth statement, risk analysis or similar document. Periodic reviews are also communicated to
provide reminders of the specific courses of action that need to be taken. More frequent
reviews occur but are not necessarily communicated to the client unless immediate changes
are recommended.
If a conflict of interest exists between the interests of the investment advisor and the
interests of the client, the client is under no obligation to act upon the investment advisor’s
recommendation. If the client elects to act on any of the recommendations, the client is under
no obligation to effect the transaction through SFG.
Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are
engaged directly by the client on an as-needed basis and may charge fees of their own. Under
CCR Section 260.238(k), SFG, its representatives or any of its employees will disclose to the
clients all material conflicts of interest.
Types of Advisory Services
SFG provides investment supervisory services, also known as asset management services
through consultations and financial planning services.
ASSET MANAGEMENT
SFG offers discretionary and non-discretionary direct asset management services to advisory
clients. SFG will offer clients ongoing portfolio management services through determining
individual investment goals, time horizons, objectives, and risk tolerance.
Investment
strategies, investment selection, asset allocation, portfolio monitoring and the overall investment
program will be based on the above factors.
Discretionary
When the client provides SFG discretionary authority the client will sign a limited trading
authorization or equivalent. SFG will have the authority to execute transactions in the
account without seeking client approval on each transaction.
Non-discretionary
When the client elects to use SFG on a non-discretionary basis, SFG will determine the
securities to be bought or sold and the amount of the securities to be bought or sold.
However, SFG will obtain prior client approval on each and every transaction before
executing any transactions.
Envestnet
SFG offers discretionary direct asset management services to advisory clients utilizing
Envestnet’s wrap program described in detail in their appendix. The wrap program provides
access to the portfolios on the Envestnet platform. SFG will offer clients ongoing portfolio
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management services through determining individual investment goals, time horizons,
objectives, and risk tolerance. Investment strategies, investment selection, assets allocation,
portfolio monitoring and the overall investment program will be based on the above factors.
The client will authorize SFG discretionary authority to execute selected investment program
transactions as stated within the Investment Advisory Agreement.
ERISA PLAN SERVICES
SFG provides service to qualified retirement plans including 401(k) plans, 403(b) plans, pension
and profit sharing plans, cash balance plans, and deferred compensation plans. SFG may act as
either a 3(21) or 3(38) advisor:
Limited Scope ERISA 3(21) Fiduciary. SFG may serve as a limited scope ERISA 3(21) fiduciary
that can advise, help and assist plan sponsors with their investment decisions on a non-
discretionary basis. As an investment advisor SFG has a fiduciary duty to act in the best interest
of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan,
though using SFG can help the plan sponsor delegate liability by following a diligent process.
1. Fiduciary Services are:
• Provide non-discretionary investment advice to the Client about asset classes and
investment alternatives available for the Plan in accordance with the Plan’s investment
policies and objectives. Client will make the final decision regarding the initial selection,
retention, removal and addition of investment options. SFG acknowledges that it is a
fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan. Client shall have the
ultimate responsibility and authority to establish such policies and objectives and to
adopt and amend the IPS.
• Provide non-discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance
to the guidelines set forth in the IPS and make recommendations to maintain, remove or
replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the
investment
recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and
the investment alternatives available to them under the Plan. Client understands SFG’s
assistance in education of the Plan participants shall be consistent with and within the
scope of the Department of Labor’s definition of investment education (Department of
Labor Interpretive Bulletin 96-1). As such, SFG is not providing fiduciary advice as
defined by ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide
investment advice concerning the prudence of any investment option or combination of
investment options for a particular participant or beneficiary under the Plan.
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• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by the
employees.
SFG may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between Advisor and Client.
3. SFG has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar
vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to SFG on the ERISA Agreement.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
3(38) Investment Manager. SFG may also act as an ERISA 3(38) Investment Manager in which
it has discretionary management and control of a given retirement plan’s assets. SFG would then
become solely responsible and liable for the selection, monitoring and replacement of the plan’s
investment options.
1. Fiduciary Services are:
• SFG has discretionary authority and will make the final decision regarding the initial
selection, retention, removal and addition of investment options in accordance with the
Plan’s investment policies and objectives.
• Assist the Client with the selection of a broad range of investment options consistent with
ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection
of a qualified default investment alternative for participants who are automatically
enrolled in the Plan or who have otherwise failed to make investment elections. The
Client retains the sole responsibility to provide all notices to the Plan participants
required under ERISA Section 404(c) (5).
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the
investment alternatives available to them under the Plan. Client understands the SFG’s
assistance in education of the Plan participants shall be consistent with and within the
scope of the Department of Labor’s definition of investment education (Department of
Labor Interpretive Bulletin 96-1). As such, the SFG is not providing fiduciary advice as
defined by ERISA to the Plan participants. SFG will not provide investment advice
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concerning the prudence of any investment option or combination of investment options
for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by the
employees.
SFG may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between SFG and Client.
1. SFG has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar
vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to the Adviser on the ERISA
Agreement.
FINANCIAL PLANNING AND CONSULTING
If financial planning services are applicable, the client will compensate SFG on an hourly or
fixed fee basis described in detail under “Fees and Compensation” section of this brochure.
Services include but are not limited to a thorough review of all applicable topics including Estate
Planning, Qualified Plans, Retirement Income, Social Security, College Planning, Investments,
Taxes, and Insurance. If a conflict of interest exists between the interests of the investment
advisor and the interests of the client, the client is under no obligation to act upon the
investment advisor’s recommendation. If the client elects to act on any of the recommendations,
the client is under no obligation to effect the transaction through SFG. Financial plans will be
completed and delivered inside of thirty (30) days.
VARIABLE ANNUITY AND VARIABLE LIFE MANAGEMENT
SFG offers discretionary direct asset management services to advisory clients on their
variable annuities and variable life products. SFG will work with individuals to assemble an
appropriate portfolio of investment options as provided through the insurance company that
services variable annuity investment. SFG will not receive commissions for the sale of annuities.
The accounts will be monitored on an annual basis.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each client are documented in our client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities.
Agreements may not be assigned without written client consent.
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Wrap Fee Programs
SFG does not sponsor any wrap fee programs. SFG may utilize third party money managers
that have wrap fee programs.
Client Assets under Management
SFG has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$321,953,763
$0
Date Calculated:
12/31/2025
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
SFG bases its fees on a percentage of assets under management, a fixed fee, and on an hourly
basis.
ASSET MANAGEMENT
SFG offers discretionary and non-discretionary asset management services to advisory clients.
SFG charges an annual investment advisory fee based on the total assets under management
as noted in the fee schedule below. SFG’s annual advisory fees are as follows:
Account Value
$0.00 - $500,000
$500,001 - $1,000,000
$1,000,001 - $2,000,000
$2,000,001 - $3,000,000
$3,000,001 - $5,000,000
$5,000,001 and Over
SFG Annual Fee
1.00%
0.95%
0.90%
0.85%
0.80%
0.75%
Quarterly Fee
0.25%
0.2375%
0.225%
0.2125%
0.20%
0.1875%
The annual fee may be negotiable. Accounts within the same household may be combined for a
reduced fee. Fees are billed quarterly in advance based on the amount of assets managed as
of the last business day of the previous quarter. If margin is utilized, the fees will be billed based
on the gross asset value of the account. Initial fees for partial quarters are pro-rated. Quarterly
advisory fees deducted from the clients' account by the custodian will be reflected in a provided
fee invoice as fees are withdrawn. Lower fees for comparable services may be available from
other sources. Clients may terminate their account within five (5) business days of signing the
Investment Advisory Agreement for a full refund. Clients may terminate advisory services with
thirty (30) days written notice. For accounts closed mid-quarter, the client will be entitled to
a pro rata refund for the days service was not provided in the final quarter. Client shall be
given thirty (30) days prior written notice of any increase in fees, and client will acknowledge,
in writing, any agreement of increase in said fees.
Envestnet
The fees charged by SFG are in addition to the fees charged by Envestnet, any other
investment advisor, and the custodian.
For clients utilizing the Envestnet platform, fees for SFG will be based on assets under
management as follows:
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Assets Under M anagement
Quarterly Fee (in advance)
Annual Fee
Up to $1,000,000
.75%
.188%
$1,000,001 to $2,000,000
.70%
.175%
.65%
.1625%
$2,000,001 to $3,000,000
$3,000,001 and Over
.60%
.150%
The annual Fee may be negotiable. Accounts within the same household may be combined
for a reduced fee. Fees are billed quarterly in advance. Envestnet’s billing services calculates
the fees for Envestnet, SFG, the custody fee, and the manager fee. Monthly prorates are run to
capture additional deposits or withdrawals and intra quarter account opening and closings. Fees
collected by Envestnet from the client account will be distributed to the appropriate parties
for payment. Lower fees for comparable services may be available from other sources. Clients
may terminate their account within five business days of signing the Investment Advisory
Agreement with no obligation. Clients may terminate advisory services with thirty (30) days
written notice. Client will be entitled to a pro rata refund for the days service was not provided
in the final quarter. Client shall be given thirty (30) days prior written notice of any increase
in fees.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed 1%.
Fees may be charged quarterly or monthly in arrears or in advance based on the assets as
calculated by the custodian or record keeper of the Included Assets (without adjustments for
anticipated withdrawals by Plan participants or other anticipated or scheduled transfers or
distribution of assets) on the last business day of the previous
quarter or month. If the services to be provided start any time other than the first day of a quarter
or month, the fee will be prorated based on the number of days remaining in the quarter or
month. If this Agreement is terminated prior to the end of the fee period, SFG shall be entitled
to a prorated fee based on the number of days during the fee period services were provided
or client will be due a prorated refund of fees for days services were not provided in the billing
cycle.
The fee schedule, which includes compensation of SFG for the services is described in detail
in Schedule A of the ERISA Plan Agreement. The Plan is obligated to pay the fees, however the
Plan Sponsor may elect to pay the fees. Client may elect to be billed directly or have fees
deducted from Plan Assets. SFG does not reasonably expect to receive any additional
compensation, directly or indirectly, for its services under this Agreement. If additional
compensation is received, SFG will disclose this compensation, the services rendered, and
the payer of compensation. SFG will offset the compensation against the fees agreed upon
under this Agreement.
FINANCIAL PLANNING and CONSULTING
SFG charges either an hourly fee or a fixed fee for financial planning. Prior to the planning process
the client will be provided an estimated plan fee. Pricing will be according to the degree of
complexity associated with each client’s situation. The services include but are not limited to
a thorough review of all applicable topics including Estate Planning, Qualified Plans, Retirement
Income, Social Security, College Planning, Investments, Taxes, and Insurance. Client will pay
50% of the estimated fee at time of engagement and the remaining 50% upon completion of
the plan. Services are completed and delivered inside of thirty (30) days dependent upon
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timely client delivery of required documentation. Client may cancel within five (5) business
days of signing Agreement for a full refund. If the client cancels after five (5) business days, SFG
will charge a pro-rata fee based on any work that has been completed. The client may be
entitled to a refund depending on the amount of work that has been completed.
FIXED FEES
Financial planning and consulting services are offered based on a flat fee ranging from
$2,500-$10,000 depending on complexity associated with each client’s situation.
HOURLY FEES
Financial planning and consulting services are offered based on an hourly fee of
$500 per hour.
VARIABLE ANNUITY AND VARIABLE LIFE MANAGEMENT
Fees for portfolios managed by SFG for Variable Annuities and Variable Life are based on a
percentage of Assets Under Management as follows:
Account Value
$0.00 - $500,000
$500,001 - $1,000,000
$1,000,001 - $2,000,000
$2,000,001 - $3,000,000
$3,000,001 - $5,000,000
$5,000,001 and Over
SFG Annual Fee
1.00%
0.95%
0.90%
0.85%
0.80%
0.75%
Quarterly Fee
0.25%
0.2375%
0.225%
0.2125%
0.20%
0.1875%
SFG fees are billed quarterly in advance based on the amount of assets managed as of the close
of business on the last business day of the previous quarter. Quarterly advisory fees will be paid
in the following ways:
a) deducting from client’s account For clients under age of 59 ½
b) deducted from a client’s account held with SFG
c) payable within 10 days of invoice presentation
Client Payment of Fees
Lower fees for comparable services may be available from other sources. Clients may terminate
their account within five business days of signing the Investment Advisory Agreement for a full
refund. Clients may terminate advisory services with thirty (30) days written notice. Clients will
be entitled to a pro rata refund for the days service that was provided in the final quarter. Client
shall be given thirty (30) days prior written notice of any increase in fees, and client will
acknowledge, in writing, any agreement of increase in said fees.
Investment management fees are billed quarterly in advance, meaning we bill you before the
three-month period has started. Payment in full is expected upon invoice presentation. Fees
are usually deducted from a designated client account to facilitate billing. The client must
consent in advance to direct debiting of their investment account.
Fees for financial plans are due 50% at the time of engagement and 50% upon completion of the
plan.
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
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equities, and exchange-traded funds. These charges may include Mutual Fund transactions
fees, postage and handling, margin interest, and miscellaneous fees (fee levied to recover costs
associated with fees assessed by self-regulatory organizations).
The selection of the security is more important than the nominal fee that the custodian charges
to buy or sell the security.
SFG, in its sole discretion may charge a lesser investment advisory fee based upon certain criteria
(e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated
future additional assets, dollar amounts of assets to be managed, related accounts, account
composition, negotiations with clients, etc.).
When utilizing subadvisors, those subadvisors will charge an additional fee for their services.
For more details on the brokerage practices, see Item 12 of this brochure.
Prepayment of Client Fees
Investment management fees are billed quarterly in advance. If the client cancels after five
(5) days, any unearned fees will be refunded to the client.
Fees for ERISA 3(21) and/or 3(38) services may be billed in advance.
External Compensation for the Sale of Securities to Clients
SFG does not receive any external compensation for the sale of securities to clients.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
SFG does not use a performance-based fee structure because of the conflict of interest.
Performance based compensation may create an incentive for the adviser to recommend an
investment that may carry a higher degree of risk to the client.
Item 7: Types of Clients
Description
SFG primarily provides investment advice to individuals, high net worth, businesses, and
charitable organizations. Client relationships vary in scope and length of service.
Account Minimums
SFG does require an account minimum of $1,000,000 to open an account, accounts below the
stated minimums may be accepted on an individual basis at the discretion of SFG. Some
TPMs may require an account minimum, this will be disclosed in the TPM’s Form ADV 2.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Investing in securities involves risk of loss that clients should be prepared to bear. Past
performance is not a guarantee of future returns. Security analysis methods will include
fundamental analysis.
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Fundamental analysis involves evaluating a stock using real data such as company revenues,
earnings, return on equity, and profits margins to determine underlying value and potential
growth.
for economic value and
When creating a financial plan, SFG utilizes fundamental analysis to provide review of
insurance policies
income replacement. The main sources of
information include Morningstar, Standard & Poor’s, and client documents such as tax returns
and insurance policies.
In developing a financial plan for a client, SFG’s analysis may include cash flow analysis,
investment planning, risk management, tax planning and estate planning. Based on the
information gathered, a detailed strategy is tailored to the client’s specific situation.
The main sources of information include Morningstar, Standard & Poor’s, financial newspapers
and magazines, annual reports, prospectuses, and filings with the Securities and Exchange
Commission.
Investment Strategy
The investment strategy for a specific client is based upon the objectives stated by the client
during consultations. The client may change these objectives at any time. Each client executes
an Investment Policy Statement or Risk Tolerance that documents their objectives and their
desired investment strategy.
Other strategies may include long-term purchases, short-term purchases, trading, and option
writing (including covered options, uncovered options or spreading strategies).
Security Specific Material Risks
All investment programs have certain risks that are borne by the investor. Fundamental
analysis may involve interest rate risk, market risk, business risk, and financial risk. Risks
involved in technical analysis are inflation risk, reinvestment risk, and market risk. Cyclical
analysis involves inflation risk, market risk, and currency risk.
Our investment approach constantly keeps the risk of loss in mind. Investors face the
following investment risks and should discuss these risks with SFG:
• Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate.
less attractive,
For example, when interest rates rise, yields on existing bonds become
causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For example,
political, economic and social conditions may trigger market events.
• Inflation Risk: When any type of inflation is present, a dollar today will buy more than a
dollar next year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar
against the currency of the investment’s originating country. This is also referred to as
exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to
be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates
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to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding oil
and then refining it, a lengthy process, before they can generate a profit. They carry a
higher risk of profitability than an electric company which generates its income from a
steady stream of customers who buy electricity no matter what the economic
environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally,
assets are more liquid if many traders are interested in a standardized product. For
example, Treasury Bills are highly liquid, while real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk
of profitability, because the company must meet the terms of its obligations in good
times and bad. During periods of financial stress, the inability to meet loan obligations
may result in bankruptcy and/or a declining market value.
• Long-term purchases: Long-term investments are those vehicles purchased with
the
intention of being held for more than one year. Typically, the expectation of the
investment is to increase in value so that it can eventually be sold for a profit. In addition,
there may be an expectation for the investment to provide income. One of the biggest
risks associated with long-term investments is volatility, the fluctuations in the financial
markets that can cause investments to lose value.
• Short-term purchases: Short-term investments are typically held for one year or
less.
Generally, there is not a high expectation for a return or an increase in value. Typically,
short-term investments are purchased for the relatively greater degree of principal
protection they are designed to provide. Short-term investment vehicles may be subject
to purchasing power risk — the risk that your investment’s return will not keep up with
inflation.
• Trading risk: Investing involves risk, including possible loss of principal. There is no
assurance that the investment objective of any fund or investment will be achieved.
• Options Trading: The risks involved with trading options are that they are very time
sensitive investments. An options contract is generally a few months. The buyer of an
option could lose his or her entire investment even with a correct prediction about the
direction and magnitude of a particular price change if the price change does not occur
in the relevant time period (i.e., before the option expires). Additionally, options are less
tangible than some other investments. An option is a “book-entry” only investment
without a paper certificate of ownership.
Item 9: Disciplinary Information
Criminal or Civil Actions
The firm and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
The firm and its management have not been involved in administrative enforcement
proceedings.
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Self-Regulatory Organization Enforcement Proceedings
The firm and its management have not been involved in legal or disciplinary events related
to past or present investment clients.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Neither SFG nor its employees are registered with a broker dealer.
Futures or Commodity Registration
Neither SFG nor its employees are registered or has an application pending to register as a
futures commission merchant, commodity pool operator, or a commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
President, Cliff Shum is also a licensed insurance agent and sells insurance products as a sole
proprietor. Less than 1% of Mr. Shum’s time is spent in his insurance practice. From time to
time, he will offer clients products and/or services in this capacity.
This represents a conflict of interest because it gives an incentive to recommend products and
services based on the commission received. This conflict is mitigated by disclosures,
procedures, and the firm’s Fiduciary obligation. Clients have the option to purchase these
products or services through another insurance agent of their choosing.
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
SFG may also utilize the services of a Sub-advisor to manage Clients’ investment portfolios.
Sub-advisors will maintain the models or investment strategies agreed upon between Sub-
advisor and SFG. Sub-advisors execute all trades on behalf of SFG in Client accounts. SFG will
be responsible for the overall direct relationship with the Client. SFG retains the authority to
terminate the Sub-advisor relationship at SFG’s discretion.
In addition to the authority granted to SFG under the Agreement, Client will grant SFG full
discretionary authority and authorizes SFG to select and appoint one or more independent
investment advisors (“Advisors”) to provide investment advisory services to Client without
prior consultation with or the prior consent of Client. Such Advisors shall have all of the same
authority relating to the management of Client’s investment accounts as is granted to SFG in the
Agreement. In addition, at SFG’s discretion, SFG may grant such Advisors full authority to
further delegate such discretionary investment authority to additional Advisors.
This practice represents a conflict of interest as SFG may select Sub-advisors who charge a
lower fee for their services than other Sub-advisors. This conflict is mitigated by disclosures,
procedures, and by the fact that SFG has a fiduciary duty to place the best interest of the
Client first and will adhere to their code of ethics.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
The employees of SFG have committed to a Code of Ethics (“Code”). The purpose of our Code
is to set forth standards of conduct expected of SFG employees and addresses conflicts that may
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arise. The Code defines acceptable behavior for employees of SFG. The Code reflects SFG and
its supervised persons’ responsibility to act in the best interest of their client.
One area which the Code addresses is when employees buy or sell securities for their
personal accounts and how to mitigate any conflict of interest with our clients. We do not allow
any employees to use non-public material information for their personal profit or to use internal
research for their personal benefit in conflict with the benefit to our clients.
SFG’s policy prohibits any person from acting upon or otherwise misusing non-public or inside
information. No advisory representative or other employee, officer or director of SFG may
recommend any transaction in a security or its derivative to advisory clients or engage in
personal securities transactions for a security or its derivatives if the advisory representative
possesses material, non-public information regarding the security.
SFG’s Code is based on the guiding principle that the interests of the client are the top
priority. SFG’s officers, directors, advisors, and other employees have a fiduciary duty to the
clients and must diligently perform that duty to maintain the trust and confidence of the clients.
When a conflict arises, it is SFG’s obligation to put the client’s interests over the interests of
either employees or the company.
The Code applies to “access” persons. “Access” persons are employees who have access to non-
public information regarding any clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in making
securities recommendations to clients, or who have access to such recommendations that are
non-public.
SFG will provide a copy of the Code of Ethics to any client or prospective client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest
SFG and its employees do not recommend to clients, securities in which we have a material
financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
SFG and its employees may buy or sell securities that are also held by clients. In order to mitigate
conflicts of interest such as front running, employees are required to disclose all reportable
securities transactions as well as provide SFG with copies of their brokerage statements.
The Chief Compliance Officer of SFG is Cliff Shum. He reviews all employee trades quarterly.
The personal trading reviews ensure that the personal trading of employees does not affect
the markets and that clients of the firm receive preferential treatment over employee
transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest
SFG does not maintain a firm proprietary trading account and does not have a material
financial interest in any securities being recommended and therefore no conflicts of
interest
exist. However, employees may buy or sell securities at the same time they buy or sell securities
for clients. In order to mitigate conflicts of interest such as front running, employees are
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required to disclose all reportable securities transactions as well as provide SFG with copies of
their brokerage statements.
The Chief Compliance Officer of SFG is Cliff Shum. He reviews all employee trades each quarter.
The personal trading reviews ensure that the personal trading of employees does not affect
the markets and that clients of the firm receive preferential treatment over employee
transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
SFG may recommend the use of a particular broker-dealer or may utilize a broker-dealer of the
client's choosing. SFG will select appropriate brokers based on a number of factors including but
not limited to their relatively low transaction fees and reporting ability. SFG relies on its broker
to provide its execution services at the best prices available. Lower fees for comparable services
may be available from other sources. Clients pay for any and all custodial fees in addition to the
advisory fee charged by SFG.
SFG may recommend that Clients establish brokerage accounts with the Schwab Advisor Services
division of Charles Schwab & Co., Inc.1 ("Schwab"), a FINRA2 registered broker-dealer and SIPC3
member, to maintain custody of Clients’ assets and to effect trades for their accounts. SFG is
independently owned and operated and not affiliated with Schwab. SFG has evaluated Schwab
and believes that it will provide our Clients with a blend of execution services, commission costs
and professionalism that will assist our firm in meeting our fiduciary obligations to Clients.
Schwab provides SFG with access to its institutional trading and custody services, which are
typically not available to Schwab retail investors. These services generally are available to
independent investment advisers on an unsolicited basis, at no charge to them so long as a total
of at least $10 million of the adviser’s Clients’ assets are maintained in accounts at Charles Schwab
& Co. These services are not contingent upon our firm committing to Schwab any specific amount
of business (assets in custody or trading commissions). Schwab’s brokerage services include the
execution of securities transactions, custody, research, and access to mutual funds and other
investments that are otherwise generally available only to institutional investors or would
require a significantly higher minimum initial investment.
For our Client accounts maintained in its custody, Schwab generally does not charge separately
for custody services but is compensated by account holders through commissions and other
transaction-related or asset-based fees for securities trades that are executed through Schwab or
that settle into Schwab accounts.
Charles Schwab & Co. also makes available to SFG other products and services that benefit SFG
but may not directly benefit our Clients’ accounts. Many of these products and services may be
used to service all or some substantial number of our Client accounts, including accounts not
maintained at Schwab.
1 For information regarding Schwab, please refer to their website: https://www.schwab.com/.
2 FINRA is the largest independent regulator for all securities firms doing business in the United States. For more
information, please refer to FINRA’s website: http://www.finra.org/.
3 For information regarding SIPC, please refer to their website: http://www.sipc.org/.
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Schwab’s products and services that assist SFG in managing and administering our Clients’
accounts include software and other technology that:
• provide access to Client account data (such as trade confirmations and account
•
statements);
facilitate trade execution and allocate aggregated trade orders for multiple Client
accounts;
facilitate payment of our fees from Clients’ accounts; and
• provide research, pricing and other market data;
•
• assist with back-office functions, recordkeeping and Client reporting.
Charles Schwab & Co. also offers other services intended to help us manage and further develop
our business enterprise. These services may include:
• compliance, legal and business consulting;
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants and insurance
providers.
Schwab may make available, arrange and/or pay third-party vendors for the types of services
rendered to SFG. Charles Schwab & Co. may discount or waive fees it would otherwise charge for
some of these services or pay all or a part of the fees of a third-party providing these services to
our firm. Charles Schwab & Co. may also provide other benefits such as educational events or
occasional business entertainment of our personnel. In evaluating whether to recommend or
require that Clients custody their assets at Schwab, we may take into account the availability of
some of the foregoing products and services and other arrangements as part of the total mix of
factors we consider and not solely on the nature, cost or quality of custody and brokerage services
provided by Schwab, which may create a potential conflict of interest.
SFG reserves the right to decline acceptance of any Client account for which the Client directs the
use of a broker other than Schwab if we believe that this choice would hinder our fiduciary duty
to the Client and/or our ability to service the account. In directing the use of Schwab (or any
other broker), it should be understood that SFG will not have authority to negotiate commissions
or to necessarily obtain volume discounts, and best execution may not be achieved. In addition,
a disparity in commission charges may exist between the commissions charged to the Client and
those charged to other Clients (who may direct the use of another broker other than Schwab).
Clients should note that, while SFG has a reasonable belief that Schwab is able to obtain best
execution and competitive prices, our firm will not independently seek best execution price
capability through other brokers.
• Directed Brokerage
SFG does not allow directed brokerage.
• Best Execution
Investment advisors who manage or supervise client portfolios have a fiduciary
obligation of best execution. The determination of what may constitute best
execution and price in the execution of a securities transaction by a broker involves
a number of considerations and is subjective. Factors affecting brokerage selection
include the overall direct net economic result to the portfolios, the efficiency with
which the transaction is effected, the ability to effect the transaction where a large
block is involved, the operational facilities of the broker-dealer, the value of an
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ongoing relationship with such broker and the financial strength and stability of the
broker. The firm does not receive any portion of the trading fees.
• Soft Dollar Arrangements
The Securities and Exchange Commission defines soft dollar practices as
arrangement under which products or services other than execution services are
obtained by an Advisor from or through a broker-dealer in exchange for directing
client transactions to the broker-dealer. As permitted by Section 28(e) of the
Securities Exchange Act of 1934, if an Advisor receives economic benefits as a result
of commissions generated from securities transactions by the broker-dealer from
the accounts of an Advisor. These benefits include both proprietary research from
the broker and other research written by third parties.
SFG does not receive soft dollar benefits.
Aggregating Securities Transactions for Client Accounts
When SFG is authorized in its discretion to aggregate purchases and sales and other
transactions made for the account with purchases and sales and transactions in the same
securities for other Clients of SFG. All Clients participating in the aggregated order shall receive
an average share price with all other transaction costs shared on a pro-rated basis.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed quarterly by Investment Advisor Representatives of SFG.
Account reviews are performed more frequently when market conditions dictate.
Review of Client Accounts on Non-Periodic Basis
Other conditions that may trigger a review of clients’ accounts are changes in the tax laws, new
investment information, and changes in a client's own situation.
Content of Client Provided Reports and Frequency
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by the Advisor’s custodian. Client receives confirmations of each
transaction in account from Custodian and an additional statement during any month in which
a transaction occurs.
Under financial planning services, the client will receive a one-time written financial plan.
Item 14: Client Referrals and Other Compensation
Economic benefits provided to the Advisory Firm from External Sources and Conflicts
of Interest
As disclosed under Item 12 above, SFG receives an economic benefit from Schwab in the form of
the support products and services it makes available to SFG and other independent investment
advisors that have their Clients maintain accounts at Schwab. These products and services, how
they benefit SFG, and the related conflicts of interest are described above (see Item 12 –
Brokerage Practices). The availability to SFG of Schwab’s products and services is not based on
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SFG giving particular investment advice, such as buying particular securities for our Clients.
Advisory Firm Payments for Client Referrals
SFG does not compensate for client referrals.
Item 15: Custody
Account Statements
SFG is deemed to have constructive custody because advisory fees are directly deducted from
Client’s account by the custodian on behalf of SFG and due to its third party money movement
authority.
SFG and its qualified custodian meet the following seven (7) conditions in order to avoid
maintaining full custody:
1. The Client provides an instruction to the qualified custodian, in writing, that includes the
Client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
2. The Client authorizes SFG, in writing, either on the qualified custodian’s form or
separately, to direct transfers to the third party either on a specified schedule or from
time to time.
3. The Client’s qualified custodian performs appropriate verification of the instruction, such
as a signature review or other method to verify the Client’s authorization and provides a
transfer of funds notice to the Client promptly after each transfer.
4. The Client has the ability to terminate or change the instruction to the Client’s qualified
custodian.
5. SFG has no authority or ability to designate or change the identity of the third party, the
address, or any other information about the third party contained in the Client’s
instruction.
6. SFG maintains records showing that the third party is not a related party of SFG or located
at the same address as SFG.
7. The Client’s qualified custodian sends the Client, in writing, an initial notice confirming
the instruction and an annual notice reconfirming the instruction.
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at their address of record at least quarterly. Clients are
urged to compare the account statements received directly from their custodians to the
performance report statements prepared by SFG.
Item 16: Investment Discretion
Discretionary Authority for Trading
SFG may require discretionary authority to manage securities accounts on behalf of Clients. SFG
has the authority to determine, without obtaining specific Client consent, the securities to be
bought or sold, and the amount of the securities to be bought or sold. If applicable, Client will
authorize SFG discretionary authority to execute selected investment program transactions as
stated within the Investment Advisory Agreement.
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SFG allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy
Statement or similar document. Such restrictions could include only allowing purchases of
socially conscious investments. These restrictions must be provided to SFG in writing.
The Client approves the custodian to be used and the commission rates paid to the custodian.
SFG does not receive any portion of the transaction fees or commissions paid by the Client to
the custodian.
Item 17: Voting Client Securities
Proxy Votes
SFG does not vote proxies on securities. Clients are expected to vote their own proxies. The
client will receive their proxies directly from the custodian of their account or from a transfer
agent.
When assistance on voting proxies is requested, SFG will provide recommendations to the client.
If a conflict of interest exists, it will be disclosed to the client.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because SFG does not serve as a custodian for
client funds or securities and SFG does not require prepayment of fees of more than
$1,200 per client and six (6) months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
SFG has no condition that is reasonably likely to impair our ability to meet contractual
commitments to our clients.
Bankruptcy Petitions during the Past Ten Years
Neither SFG nor its management has had any bankruptcy petitions in the last ten years.
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Item 1 Cover Page
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Cliff Wing-Yin Shum, CFP®
Shum Financial Group, Inc.
Office Address:
2205 Harbor Bay Parkway
Alameda, CA 94502
Tel: 510-748-7462
Fax: 510-769-4990
Email: cliff@shumfinancial.com
This brochure supplement provides information about Cliff Shum and supplements the
Shum Financial Group, Inc.’s brochure. You should have received a copy of that brochure.
Please contact Cliff Shum if you did not receive the brochure or if you have any questions
about the contents of this supplement.
F E B R U A R Y 2 3 ,
2 0 2 6
Additional information about Cliff Shum (CRD #2973780) is available on the SEC’s
website at www.adviserinfo.sec.gov.
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Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer - Cliff Wing-Yin Shum, CFP®
• Year of birth: 1973
Item 2 Educational Background and Business Experience
Educational Background:
• University of California - Irvine; Bachelor of Arts in Economics; 1996
Business Experience:
• Shum Financial Group, Inc.; President/Investment Advisor Representative; 12/2016 –
Present
• Cliff Shum, Sole Proprietor; Insurance Agent; 07/2013 - Present
• Girard Securities,
Inc.
dba
Shum Financial
Group; Registered
Representative/Investment Advisor Representative; 06/2013 – 04/2017
• Edward Jones Investments; Registered Representative/Investment Advisor
Representative; 01/2007 – 06/2013
• Financial Network Investment Corp.; Registered Representative/Manager of OSJ
Supervision; 04/2005 – 01/2007
• Edward Jones Investments; Field Supervision Director; 10/2002 – 03/2005
• American Express Financial Advisors; Registered Representative/Investment Advisor
Representative;11/1997 – 10/2002
• IDS Life Insurance Company; Insurance Agent; 11/1997 – 10/2002
• Cellular Express; District Manager; 08/1996 – 11/1997
Professional Certifications
Employees have earned certifications and credentials that are required to be explained in
further detail.
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame
design) marks (collectively, the “CFP® marks”) are professional certification marks granted
in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP® certification. It is recognized in the United States and
a number of other countries for its (1) high standard of professional education; (2) stringent
code of conduct and standards of practice; and (3) ethical requirements that govern
professional engagements with clients. Currently, more than 62,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the
following requirements:
• Education – Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board’s studies have determined as necessary
for the competent and professional delivery of financial planning services and attain a
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Shum Financial Group, Inc.
Bachelor’s Degree from a regionally accredited United States college or university (or
its equivalent from a foreign university). CFP Board’s financial planning subject areas
include insurance planning and risk management, employee benefits planning,
investment planning, income tax planning, retirement planning, and estate planning;
• Examination – Pass
the comprehensive CFP® Certification Examination. The
examination, administered in 10 hours over a two-day period, includes case studies and
client scenarios designed to test one’s ability to correctly diagnose financial planning
issues and apply one’s knowledge of financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of
documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and
ethics requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two
years, including two hours on the Code of Ethics and other parts of the Standards of
Professional Conduct, to maintain competence and keep up with developments in the
financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The
Standards prominently require that CFP® professionals provide financial planning
services at a fiduciary standard of care. This means CFP® professionals must provide
financial planning services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may
be subject to CFP Board’s enforcement process, which could result in suspension or
permanent revocation of their CFP® certification.
Item 3 Disciplinary Information
Criminal or Civil Action: None to report.
Administrative Proceeding: None to report.
Self-Regulatory Proceeding: None to report.
Item 4 Other Business Activities
President, Cliff Shum, is also a licensed insurance agent as a sole proprietor. Less than 1% of
Mr. Shum’s time is spent in his insurance practice. From time to time he will offer clients
products and/or services in this capacity.
This represents a conflict of interest because it gives an incentive to recommend products and
services based on the commission received. This conflict is mitigated by the fact that Mr.
Shum has a fiduciary responsibility to place the best interest of the client first and the clients
are not required to purchase any products or services. Clients have the option to purchase
these products or services through another insurance agent of their choosing.
Item 5 Performance Based Fee Description
Mr. Shum receives additional compensation in his capacity as an insurance agent, but he does
not receive any performance based fees.
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Item 6 Supervision
Since Mr. Shum is the sole owner of Shum Financial Group, Inc., he is solely responsible for
all supervision and formulation and monitoring of investment advice offered to clients. He
will adhere to the policies and procedures as described in the firm’s Compliance Manual.
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