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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
September 05, 2025
Snider Financial Group
12505 Bel-Red Rd. Suite 200
Bellevue, Washington 98005
www.SniderFinancialGroup.com
Firm Contact:
Heather Bush
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Snider
Retirement Strategies, Inc. dba Snider Financial Group. If clients have any questions about the
contents of this brochure, please contact us at 425-453-7080 or heather@sniderfinancialgroup.com.
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 our
firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD # 117392.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Snider Financial Group is required to make clients aware of information that has changed since the
last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can
then determine whether to review the brochure in its entirety or to contact us with questions about
the changes.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual
amendment filing on 3/20/2025:
- The Advisor now serves as the General Partner and Investment Manager to a Private Fund.
Please see Items 4, 5, 6, 7, 10, and 14 for more details.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our
business practices, changes in regulations or routine annual updates as required by the securities
regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided
to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name
or our CRD# 117392. You may also request a copy of this Disclosure Brochure at any time, by
contacting the Advisor at (425) 453-7080.
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Snider Financial Group
Item 3: Table of Contents
Item 3: Table of Contents............................................................................................................................. 3
Item 4: Advisory Business ........................................................................................................................... 4
Item 5: Fees & Compensation...................................................................................................................... 8
Item 6: Performance-Based Fees & Side-By-Side Management ............................................................. 11
Item 7: Types of Clients & Account Requirements .................................................................................. 11
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ...................................................... 12
Item 9: Disciplinary Information .............................................................................................................. 14
Item 10: Other Financial Industry Activities & Affiliations .................................................................... 14
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ........... 15
Item 12: Brokerage Practices .................................................................................................................... 16
Item 13: Review of Accounts or Financial Plans...................................................................................... 18
Item 14: Client Referrals & Other Compensation .................................................................................... 19
Item 15: Custody ........................................................................................................................................ 19
Item 16: Investment Discretion ................................................................................................................ 20
Item 17: Voting Client Securities .............................................................................................................. 20
Item 18: Financial Information ................................................................................................................. 20
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Snider Financial Group
Item 4: Advisory Business
Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a corporation formed under the laws of the State of
Washington in 2001 and has been registered as an investment adviser since 2008. Our firm is wholly
owned by Monte Snider.
Snider Financial Group provides personalized confidential financial planning and investment
management to
individuals, pension and profit-sharing plans, trusts, estates, charitable
organizations, and small businesses. Advice is provided through consultation with the client and
might include determination of financial objectives, identification of financial problems, cash flow
management, tax planning, insurance review, investment management, education funding,
retirement planning, and estate planning.
Investment advice is an integral part of financial planning. In addition, Snider Financial Group advises
clients regarding cash flow, college planning, retirement planning, tax planning and estate planning.
Investment advice is provided, with the advisor making the final decision on investment selection on
discretionary accounts and the client giving the final permission on the recommendations for non-
discretionary accounts. Snider Financial Group does not act as a custodian of client assets. The client
always maintains control of assets. Snider Financial Group places trades for clients under a limited
power of attorney.
Types of Advisory Services Offered
Financial Planning & Consulting:
A financial plan is designed to help the client with all aspects of financial planning without ongoing
investment management after the financial plan is completed. The financial plan might include, but
is not limited to: a net worth statement; a cash flow statement; a review of investment accounts,
including reviewing asset allocation and providing repositioning recommendations; strategic tax
planning; a review of retirement accounts and plans including recommendations; a review of
insurance policies and recommendations for changes, if necessary; one or more retirement
scenarios; estate planning review and recommendations; and education planning with funding
recommendations.
Detailed investment advice and specific recommendations are provided as part of a financial plan.
Implementation of the recommendations is at the discretion of the client. Snider Financial Group may
recommend that clients execute their financial plans through a broker-dealer, however, the Client is
free to implement their plan through broker-dealers or insurance companies of their choice.
Investment Management:
Most clients choose to have our firm manage their assets in order to obtain ongoing in-depth advice
and life planning. All aspects of the client’s financial affairs are reviewed. Realistic and measurable
goals are set and objectives to reach those goals are defined. As goals and objectives change over
time, suggestions are made and implemented on an ongoing basis in discretionary accounts and
changes are recommended and approved by the client in non-discretionary accounts.
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Snider Financial Group
Our Investment Management service includes cash flow management; insurance review; investment
management (including performance reporting); education planning; retirement planning; estate
planning; and tax preparation, as well as the implementation of recommendations within each area.
We use a third-party platform to facilitate management of held away assets such as defined
contribution plan participant accounts, with discretion. The platform allows us to avoid being
considered to have custody of Client funds since we do not have direct access to Client log-in
credentials to affect trades. We are not affiliated with the platform in any way and receive no
compensation from them for using their platform. A link will be provided to the Client allowing them
to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser
will review the current account allocations. When deemed necessary, Adviser will rebalance the
account considering client investment goals and risk tolerance, and any change in allocations will
consider current economic and market trends. The goal is to improve account performance over time,
minimize loss during difficult markets, and manage internal fees that harm account performance.
Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed
necessary. The Advisor may retain other types of investments from the Client’s legacy portfolio due
to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between
the Advisor and the Client.
Our firm utilizes the sub-advisory services of a third-party investment advisory firm or individual
advisor to aid in the implementation of an investment portfolio designed by our firm. Before selecting
a firm or individual, our firm will ensure that the chosen party is properly licensed or registered. Our
firm will not offer advice on any specific securities or other investments in connection with this
service. We will provide initial due diligence on third party money managers and ongoing reviews of
their management of client accounts. In order to assist in the selection of a third-party money
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 third party money 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 third party money managers as warranted; and assist
the client in understanding and evaluating the services provided by the third-party money manager.
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.
Legal Service Fee Coverage – The Advisor will pay for a portion of CPA and Estate Attorney Fees for
clients with greater than $5,000,000 in assets under management with the Advisor.
For clients with greater than $5,000,000 in assets under management with the Advisor, the Advisor
will cover Client-incurred CPA and Estate Attorney fees up to a value of 5% of the revenue that the
Advisor receives from the Client in advisory fees.
For clients with greater than $10,000,000 in assets under management with the Advisor, the Advisor
will cover Client-incurred CPA and Estate Attorney fees up to a value of 10% of the revenue that the
Advisor receives from the Client in advisory fees.
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Snider Financial Group
LPL Financial Sponsored Advisory Programs:
Our firm may provide advisory services through certain programs sponsored by LPL Financial
Corporation (“LPL”), a registered investment advisor and broker-dealer. Below is a brief description
of each LPL advisory program available to our firm. For more information regarding the LPL
programs, including more information on the advisory services and fees that apply, the types of
investments available in the programs and the potential conflicts of interest presented by the
programs please see the LPL Financial Form ADV Part 2 and the applicable client agreement.
• Manager Access Select (MAS)
Manager Access Select is a separate account platform available through LPL Financial that
offers high-net-worth investors the ability to access a variety of institutional portfolio
managers at significantly lower account minimums. This enables clients to enjoy a higher
level of specialization and service through the ownership of individual securities. You can
choose from a broad range of portfolio managers and multiple investment styles including
equity, fixed income, asset classes, mutual funds, ETFs, and specialty strategies. The client
will authorize LPL to act on a discretionary basis to purchase and sell securities and to
liquidate previously purchased securities. The client will also authorize LPL to effect
rebalancing for MAS accounts.
• Optimum Market Portfolios Program (OMP)
OMP offers clients the ability to participate in a professionally managed asset allocation
program using Optimum Funds Class I shares. Under OMP, client will authorize LPL on a
discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives
chosen by the client. Advisor will assist the client in determining the suitability of OMP for
the client and assist the client in setting an appropriate investment objective. Advisor will
have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent
with the client’s investment objective. LPL will have discretion to purchase and sell Optimum
Funds pursuant to the portfolio selected for the client. LPL will also have authority to
rebalance the account. A minimum account value of $15,000 is required for OMP.
• Model Wealth Portfolios Program (MWP)
MWP offers clients a professionally managed mutual fund asset allocation program. Snider
Financial Group will obtain the necessary financial data from the client, assist the client in
determining the suitability of the MWP program and assist the client in setting an appropriate
investment objective. The Advisor will initiate the steps necessary to open an MWP account
and have discretion to select a model portfolio designed by LPL’s Research Department
consistent with the client’s stated investment objective. LPL’s Research Department is
responsible for selecting the mutual funds within a model portfolio and for making changes
to the mutual funds selected. The client will authorize LPL to act on a discretionary basis to
purchase and sell mutual funds (including in certain circumstances exchange traded funds)
and to liquidate previously purchased securities. The client will also authorize LPL to effect
rebalancing for MWP accounts. The MWP program does make available model portfolios
designed by strategists other than LPL’s Research Department. Such models are made
available, and the Advisor will have discretion to choose among the available models
designed by LPL and outside strategists. A minimum account value of $100,000 is required
for MWP.
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Snider Financial Group
• Strategic Wealth Management (SWM)
SWM is a comprehensive, open-architecture, fee-based investment platform designed to help
deliver highly customized advice and exceptional service. The platform provides a foundation
to help you develop successful client relationships by thoroughly understanding your clients’
long-term financial goals and offering solutions to achieve them. With this platform, multiple
investments can be wrapped in one account with one consolidated statement for the client.
Snider Financial Group has the fiduciary responsibility on the account, and also selects,
recommends, and makes changes to these accounts on a discretionary basis. The client will
authorize Snider Financial Group to act on a discretionary basis to purchase and sell
securities and to liquidate previously purchased securities. The client will also authorize
Snider Financial Group to effect rebalancing for SWM accounts.
Private Fund Advisor Services:
The Advisor serves as the general partner and investment manager to the Razor Fund, LP, a pooled
investment vehicle (“Razor Fund” or the “Fund”). These services are detailed in the offering
documents for the Fund, which include as applicable, operating agreements, private placement
memorandum and/or term sheets, subscription agreements, separate disclosure documents, and all
amendments thereto (“Offering Documents”).
The Advisor manages the Fund based on the investment objectives, policies and guidelines as set
forth in the respective Offering Documents and not in accordance with the individual needs or
objectives of any particular investor therein. Each prospective investor interested in investing in the
Fund is required to complete a subscription agreement in which the prospective investor attests as
to whether or not such prospective investor meets the qualifications to invest in the Fund and further
acknowledges and accepts the various risk factors associated with such an investment.
In general, investors in the Fund are not permitted to impose restrictions or limitations. However,
the Advisor may enter into side letter agreements with one or more investors that may alter, modify,
or change the terms of interest held by investors. Certain types of side letters create a conflict of
interest between the Advisor and the investors in the Fund, and/or between investors themselves.
For more detailed information on investment objectives, policies and guidelines, please refer to
the respective Fund’s Offering Documents.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Investment Management clients. General
investment advice will be offered to our Financial Planning & Consulting clients. Each Investment
Management client has the opportunity to place reasonable restrictions on the types of investments to
be held in the portfolio. Restrictions on investments in certain securities or types of securities may not
be possible due to the level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not manage or place Client assets into a wrap fee program. Investment management
services are provided directly by Snider Financial Group. However, SFG has approximately 10 – 15
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Snider Financial Group
legacy clients in SWM II accounts, but SFG no longer offers SWM II accounts. The advisory fee charged
to Advisory Clients participating in SWM II program will include the transaction fees charged by the LPL
Financial for securities transactions.
Regulatory Assets Under Management
As of December 31, 2024 our firm manages $500,674,906 in Client assets, all of which is managed on
a discretionary basis. Clients may request more current information at any time by contacting the
Advisor.
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Financial Planning & Consulting:
An hourly fee that can range up to $500 per hour for an Advisor and up to $150 per hour for an
Associate Advisor or Paraplanner (depending on the complexity of the client’s situation) is charged
by Snider Financial Group for financial planning and consulting services. The total estimated fee, as
well as the ultimate fee charged, is based on the scope and complexity of our engagement with the
client. Before commencing financial planning services, we will provide an estimate of the
approximate hours needed to complete the requested financial planning services. If we anticipate
exceeding the estimated amount of hours, your Investment Advisor Representative will contact you
to receive authorization to provide additional services. Upon presentment of the invoice to you,
Snider Financial Group will deduct the hourly fees due against any retainer balance you may have
and you will be responsible to immediately pay Snider Financial Group any outstanding balance of
hourly fees due.
The Wealth Management System has a one-time fee for the financial plan equal to 20 basis points
(0.20%) of the client’s total assets. New and existing clients who transfer assets to Snider Financial
Group for advisory services within six (6) months of the delivery of the financial plan shall receive a
reduced fee of 10 basis points (0.10%) of the client’s total assets under management. The fee for the
financial plan as stated herein is subject to a minimum Three Thousand Five Hundred and No/100
Dollars ($3,500.00) fee. Adjustments to the fee for the financial plan for clients who transfer assets
to SFG for advisory services within six (6) months of the delivery of the financial plan will be credited
to the client’s Snider Financial Group account within two (2) weeks of such transfer.
Investment Management:
The annual Investment Management fee is based on a percentage of the assets according to the
following schedule in addition to the fee required for the respective underlying manager for each
account if applicable:
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Snider Financial Group
Flat Fee Schedule
Assets Under Management
to $ 749,999
to $ 999,999
to $ 1,999,999
to $ 4,999,999
to $ 9,999,999
$ 200,000
$ 750,000
$ 1,000,0000
$ 2,000,000
$ 5,000,000
$ 10,000,000+
Annual %
1.50%
1.25%
1.00%
0.90%
0.75%
0.60%
A minimum of $200,000 is required or an annualized fee of 1.75% of assets under management
will be assessed.
The fee to be assessed to each account will be detailed in the client’s signed advisory agreement, LPL
Account Application or LPL Tiered Fee Authorization form. Our firm bills on cash or cash equivalents,
unless otherwise agreed to in writing. Fees are billed on a pro-rata basis quarterly in advance based
on the value of the account(s) on the last day of the previous quarter. Fees are negotiable and will be
deducted from the account(s). Please note that fees will be adjusted for deposits and withdrawals
made during the quarter. If accounts are opened during the quarter, the pro-rata advisory fees will
be deducted during the next regularly scheduled billing cycle. All securities held in accounts managed
by SFG will be independently valued by the Custodian. The Advisor will conduct periodic reviews of
the Custodian’s valuation to ensure accurate billing. In rare cases, our firm will agree to direct bill
clients. As part of this process, Clients understand the following:
a) The client’s custodian sends statements at least quarterly, showing all disbursements for each
account, including the amount of the advisory fees paid to our firm.
b) Clients provide authorization permitting the custodian to deduct these fees.
c) The custodian calculates the advisory fees for all fee schedules and deducts them from the
client’s account.
The maximum annual fee charged to clients utilizing Third Party Managers will not exceed the
maximum fee published above for this service. Our firm will debit fees for this service as laid out in
the executed advisory agreement between the client and our firm. This fee shall be in addition to any
fees assessed by the chosen third party money manager. The third-party money managers we
recommend will not directly charge you a higher fee than they would have charged without us
introducing you to them. Third party money managers establish and maintain their own separate
billing processes over which we have no control. They will directly bill you and describe how this
works in their separate written disclosure documents.
LPL Sponsored Advisory Programs:
The account fee charged to the client for each LPL advisory program is negotiable, subject to the
following maximum account fees:
Advisory Program
Manager Access Select
Optimum Market Portfolio
Annual Percentage of Assets Charged
Up to 3.00%
Up to 2.50%
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Snider Financial Group
Model Wealth Portfolios Program
Strategic Wealth Management
Up to 2.50%
Up to 3.00%
LPL has a separate billing process which we have no control over. In general, they will directly bill
you and describe how this works in their separate written disclosure documents.
Private Fund Advisor Services:
Razor Fund L.P. does not pay the Advisor an ongoing management fee. However, the Advisor will
charge a performance-based fee of a 20.0% profit allocation (the “Profit Allocation”), once each
investors contingent loss account has been reduced to 0, as outlined in Item 6 below. This fee is
allocated at the close of each calendar month. For more detailed information on the fees and
compensation received by the Advisor and its affiliates, please refer to the Fund’s Offering
Documents.
Other Types of Fees & Expenses
Clients in legacy SWM II accounts will not incur transaction costs for trades by their chosen custodian.
All other clients will incur transaction charges for trades executed in their accounts. These
transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen
custodian. LPL Financial offers a trading platform with select exchange traded funds (“ETFs”) that do
not charge transaction fees. The no-transaction-fee ETF trading platform is available to clients
participating in LPL Financials’ Strategic Wealth Management (“SWM”) and Strategic Asset
Management (“SAM”) programs. Clients will be subject to transaction fees charged by LPL Financial
for ETFs not included in LPL Financials’ platform and for other types of securities. The limited
number of ETFs available on LPL Financials’ no-transaction fee platform may have higher overall
expenses than other types of securities and ETFs not included in the platform. Other major custodians
have eliminated transaction fees for all ETFs and U.S. listed equities, so clients may pay more for
investing in the same securities at LPL Financial.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges,
mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified
retirement plan fees, and other fund expenses), mark-ups and mark-downs, spreads paid to market
makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on
brokerage accounts and securities transactions. Our firm does not receive a portion of these fees.
Clients may incur certain fees or charges imposed by third parties in connection with investments
made on behalf of the Client’s account[s].
Termination & Refunds
Either party may terminate the signed advisory agreement at any time. Upon receipt of your notice
of termination, LPL will process a pro-rate refund of the unearned portion of the advisory fees
charged in advance at the beginning of the quarter.
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Snider Financial Group
The financial planning services terminate upon either party providing the other party with written
notice of termination. In the event that you terminate the financial planning services at any time
prior to presentment of the written plan by providing notice to us:
• For financial planning services performed by SFG under an hourly arrangement, you will pay
SFG for any hourly fees incurred at the rates described above.
• For financial planning services performed by SFG under a fixed fee arrangement, you will pay
SFG a pro-rated fixed fee equivalent to the percentage of work completed by SFG as
determined by SFG.
• For financial planning services provided on an Asset Based fee option you will be responsible
for a pro-rated amount for the asset-based fee based upon the level of services provided.
Snider Financial Group reserves the right to terminate any financial planning engagement where a
client has willfully concealed or has refused to provide pertinent information about financial
situations when necessary and appropriate, in Snider Financial Group’s judgment, to providing
proper financial advice. Any unused portion of fees collected in advance will be refunded within 30
days.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
As disclosed in Item 5 above, for assets invested in the Razor Fund L.P. the Advisor will be entitled to
a 20.0% profit allocation (the “Profit Allocation”), once each investors contingent loss account has
been reduced to 0, as outlined in the Offering Documents. This fee is generally allocated at the close
of each calendar month. The calculation of this performance-based fee is disclosed in the Fund’s
Offering Documents. Investors should understand that the receipt of performance-based fees creates
a conflict of interest as Razor Fund L.P. has the potential to receive higher compensation.
Performance-based fees create an incentive for the Advisor to make investments that are riskier or
more speculative than might otherwise be the case in the absence of such arrangement. Additionally,
the Advisor is incentivized to favor and devote more time and effort to managing investments when
there is a potential for receipt of performance-based compensation. The Advisor seeks to mitigate
these conflicts through disclosures in this Disclosure Brochure; additional disclosures in the
applicable Offering Documents, as well as through the Advisor’s Code of Ethics and policies and
procedures contained in the Compliance Manual.
Item 7: Types of Clients & Account Requirements
Our firm generally provides investment advice to individuals, high-net-worth individuals, pension
and profit-sharing plans, trusts, estates, or pooled investment vehicles.
Our requirements for opening and maintaining accounts or otherwise engaging us:
• Our firm requires an initial minimum account balance of $200,000 for our Investment
Management service. This may be negotiable at the Advisor’s discretion.
• Accounts of less than $200,000 may be set up when the client and the advisor anticipate the
client will add additional funds to the accounts bringing the total to $200,000 within a period
of 6 months. Other exceptions will apply to employees of Snider Financial Group and their
relatives, or relatives of existing clients.
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Snider Financial Group
• Please refer to Item 5 for our minimum fee requirements pertaining to our Financial Planning
& Consulting service.
Private Fund Advisor Services
Generally, the investors in the Razor Fund L.P. meet the definition of “accredited investor” as defined
in the Securities Act of 1933 and “qualified client” as defined in the Advisers Act. The various
requirements for investing in a Fund, including the minimum investment size, are set forth in each
Fund’s Offering Documents. The Advisor has the ability, in its sole discretion, to permit commitments
below the minimum amounts set forth in the Offering Documents.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
Security analysis methods might include charting, fundamental analysis, technical analysis, and
cyclical analysis.
The main sources of information include financial newspapers and magazines, research materials
prepared by others, timing services, annual reports, prospectuses, filings with the Securities and
Exchange Commission, and company press releases.
Other sources of information that Snider Financial Group might use include Morningstar, Forbes,
Smart Money, Bloomberg Business Week, The Economist, Investment Advisor, Financial Advisor,
Investment News, BlackRock Research, LPL Research, and the World Wide Web.
Investment Strategies We Use
The primary investment strategy used on client accounts is strategic asset allocation with a tactical
overlay. This means that we use managed funds, ETFs, and/or individual securities to compliment
the portfolio. Portfolio diversification is achieved by using traditional as well as alternative asset
classes. Portfolios are globally diversified to control the risk associated with traditional markets.
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.
Other strategies might at your request include long-term purchases, short-term purchases, trading,
short sales, margin transactions, and option writing (including covered options, uncovered options
or spreading strategies).
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease, and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, are appropriately diversified in investments, and ask
any questions.
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Snider Financial Group
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate.
For example, when interest rates rise, yields on existing bonds become less attractive, 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 not buy as much as
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 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.
• Margin Transactions: If you request, we can help you establish your account to allow for
margin transactions. Margin allows you to purchase investments for your portfolio with
money borrowed from your custodian and secured by the investments in your brokerage
account. This allows you to purchase more stock than you would be able to with your
available cash and allows us to purchase stock without selling other holdings. Therefore, your
exposure to market volatility increases. In a declining market your account could experience
greater losses.
• Mutual Fund Risks: The performance of mutual funds is subject to market risk, including the
possible loss of principal. The price of the mutual funds will fluctuate with the value of the
underlying securities that make up the funds. The price of a mutual fund is typically set daily
therefore a mutual fund purchased at one point in the day will typically have the same price
as a mutual fund purchased later that same day.
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Snider Financial Group
• Private Pooled Investment Vehicles: The Advisor recommends that certain clients invest
in privately placed pooled investment vehicles (e.g., hedge funds, private equity funds, etc.).
The managers of these vehicles have broad discretion in selecting the investments. There are
few limitations on the types of securities or other financial instruments that may be trade and
no requirement to diversify. Hedge funds may trade on margin or otherwise leverage
positions, thereby potentially increasing the risk to the vehicle. In addition, because the
vehicles are not registered as investment companies, they are much less regulated than
investment companies. There are numerous other risks in investing in these securities.
Clients should consult each fund’s private placement memorandum and/or other documents
explaining such risks prior to investing.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to our Investment
Management service, as applicable.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are insurance agents/brokers. They offer insurance products and receive
customary fees as a result of insurance sales. A conflict of interest exists as these insurance sales
create an incentive to recommend products based on the compensation adviser and/or our
supervised persons may earn. To mitigate this potential conflict, our firm will act in the client’s best
interest.
Monte Snider is the owner of FinTax Partners, LLC. FinTax Partners, LLC provides income tax
preparation and accounting services. These services are independent of our firm’s advisory services
and are governed under a separate engagement agreement. Clients have the option of engaging
FinTax Partners, LLC for tax preparation or accounting services, though they are under no obligation
to do so.
General Partner to Private Fund
Snider Financial Group also serves as the general partner to the Razor Fund. As such, Snider Financial
Group has an incentive to recommend investments in the Fund as owners will benefit financially in
their individual capacity through the receipt of additional revenue. The conflict is mitigated by an
internal policy mandating that the Advisor will not charge a separate investment advisory fee for the
management of the assets placed in the Private Funds. Additionally, there is no requirement for the
Advisor to recommend the Private Funds to Clients, nor are Clients obligated to invest into Private
Funds.
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Snider Financial Group
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal
Trading
Code of Ethics
The employees of Snider Financial Group have committed to a Code of Ethics that is available for review
by clients and prospective clients upon request. The firm will provide a copy of the Code of Ethics to any
client or prospective client upon request.
Participation or Interest in Client Transactions
Snider Financial Group and its employees may buy or sell securities that are also held by clients.
Employees may not knowingly trade their own securities ahead of client trades on any given day prior
to executing a client trade. Employees comply with the provisions of the LPL Financial compliance rules
where all securities trading takes place and as Snider Financial Group is required to trade these
securities through LPL Financial no best execution review is performed or attempted.
Trades occurring in accounts managed by a third party is not know in advance by anyone at Snider
Financial Group therefore it would be highly unlikely that Snider Financial Group employees would be
able to trade ahead of their clients in these scenarios.
Personal Trading
Our firm recognizes that the personal investment transactions of our representatives demand the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
our representatives for their personal accounts. In order to monitor compliance with our personal
trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which
our firm or a related person has a material financial interest without prior disclosure to the client.
Related persons of our firm may buy or sell securities and other investments that are also recommended
to clients. In order to minimize this conflict of interest, our related persons will place client interests
ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon
request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities prior to buying or selling for our clients in the same day unless included in
a block trade.
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Snider Financial Group
Item 12: Brokerage Practices
Selecting a Brokerage Firm
Our firm does not maintain custody of client assets. Client assets must be maintained by a qualified
custodian. Our firm seeks to recommend a custodian who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. Clients are not obligated to use the recommended Custodian and will
not incur any extra fee or cost from the Advisor associated with using a custodian not recommended
by SFG. The factors considered, among others, are these:
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
• Quality of services
With this in consideration, our firm has an arrangement with LPL Financial (“LPL”), a qualified custodian
from whom our firm is independently owned and operated. LPL offers services to independent
investment advisers which includes custody of securities, trade execution, clearance and settlement
of transactions. LPL enables us to obtain many no-load mutual funds without transaction charges and
other no-load funds at nominal transaction charges. LPL does not charge client accounts separately for
custodial services. Client accounts will be charged transaction fees, commissions or other fees on trades
that are executed or settle into the client’s custodial account. Transaction fees are negotiated with LPL
and are generally discounted from customary retail commission rates. This benefits clients because
the overall fee paid is often lower than would be otherwise.
LPL may make certain research and brokerage services available at no additional cost to our firm.
Research products and services provided by LPL may include: research reports on recommendations or
other information about particular companies or industries; economic surveys, data and analyses;
financial publications; portfolio evaluation services; financial database software and services;
computerized news and pricing services; quotation equipment for use in running software used in
investment decision-making; and other products or services that provide lawful and appropriate
assistance by LPL to our firm in the performance of our investment decision-making responsibilities.
The aforementioned research and brokerage services qualify for the safe harbor exemption defined in
Section 28(e) of the Securities Exchange Act of 1934.
LPL does not make client brokerage commissions generated by client transactions available for our
firm’s use. The aforementioned research and brokerage services are used by our firm to manage
accounts for which our firm has investment discretion. Without this arrangement, our firm might be
compelled to purchase the same or similar services at our own expense.
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Snider Financial Group
As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of
our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm
or our related persons creates a potential conflict of interest and may indirectly influence our firm’s
choice of LPL as a custodial recommendation. Our firm examined this potential conflict of interest when
our firm chose to recommend LPL and have determined that the recommendation is in the best interest
of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution.
Our clients may pay a transaction fee or commission to LPL that is higher than another qualified
broker dealer might charge to affect the same transaction where our firm determines in good faith
that the commission is reasonable in relation to the value of the brokerage and research services
provided to the client as a whole.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
As discussed previously, certain associated persons of our firm are registered representatives of LPL
Financial. As a result of this relationship, LPL Financial may have access to certain confidential
information (e.g., financial information, investment objectives, transactions and holdings) about
SFG’s clients, even if the client does not establish any account through LPL. If you would like a copy
of the LPL Financial privacy policy, please contact Monte Snider.
Soft Dollars
Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will
generally be used to service all of our clients but not necessarily all at any one particular time.
Client Brokerage Commissions
LPL does not make client brokerage commissions generated by client transactions available for our
firm’s use.
Client Transactions in Return for Soft Dollars
Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar
benefits.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
Neither our firm nor any of our firm’s representatives have discretionary authority in making the
determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale
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Snider Financial Group
of securities are placed for execution, and the commission rates at which such securities transactions
are affected. Our firm routinely recommends that clients direct us to execute through a specified
broker-dealer. Our firm recommends the use of LPL. Each client will be required to establish their
account(s) with LPL if not already done. Please note that not all advisers have this requirement.
Client-Directed Brokerage
Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to
achieve the most favorable execution of client transactions. Client directed brokerage may cost
clients more money. For example, in a directed brokerage account, clients may pay higher brokerage
commissions because our firm may not be able to aggregate orders to reduce transaction costs, or
clients may receive less favorable prices.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when our firm believes
that to do so will be in the best interest of the effected accounts. When such concurrent authorizations
occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In order to mitigate front running and preferential treatment, employee trades are executed
last unless included in a block trade.
Item 13: Review of Accounts or Financial Plans
Our Chief Compliance Officer, Heather Bush, reviews accounts on at least an annual basis for our
Investment Management clients. The nature of these reviews is to learn whether client accounts are
in line with their investment objectives, appropriately positioned based on market conditions, and
investment policies, if applicable. Our firm does not provide written reports to clients, unless asked
to do so. Verbal reports to clients take place on at least an annual basis when our Investment
Management clients are contacted.
Our firm may review client accounts more frequently than described above. Among the factors which
may trigger an off-cycle review are major market or economic events, the client’s life events, requests
by the client, etc.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or update to their initial written financial plan.
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Snider Financial Group
Item 14: Client Referrals & Other Compensation
LPL Financial
Our firm may receive from LPL or a mutual fund company, without cost and/or at a discount non-
soft-dollar support services and/or products, to assist us to better monitor and service client
accounts maintained at such institutions. Included within the support services our firm may receive
investment-related research, pricing information and market data, software and other technology
that provide access to client account data, compliance and/or practice management-related
publications, discounted or gratis consulting services, discounted and/or gratis attendance at
conferences, meetings, and other educational and/or social events, marketing support, computer
hardware and/or software and/or other products used by us to assist us in our investment advisory
business operations. Our clients do not pay more for investment transactions effected and/or assets
maintained at LPL as result of this arrangement. There is no commitment made by us to LPL or any
other institution as a result of the above arrangement.
Compensation for Client Referrals
Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein
"Promoter") and receive, directly or indirectly, compensation for the Client referral. In
such instances, the Advisor will compensate the Promoter a fee in accordance with Rule 206(4)-1 of
the Advisers Act and any corresponding state securities requirements. Any such compensation shall
be paid solely from the investment advisory fees earned by the Advisor, and shall not result in any
additional charge to the Client.
Item 15: Custody
The Advisor is considered to have custody under the following circumstances and is consequently
required to undergo an annual surprise examination:
Private Fund Advisor Services - The Advisor is the investment manager and general partner to the
Private Funds. As such, the Advisor is deemed to have the ability to manage the cash and securities
within the Private Funds. The Advisor complies with Rule 206(4)-2(b) by having each Fund audited
at least annually by a PCAOB-organized and inspected accountant, and distributes audited financial
statements, which are prepared in accordance with generally accepted accounting principles, to
limited partners within 120 days of the end of the fiscal year of the Private Funds.
Additionally, The Advisor is considered to have custody under the following limited circumstances.
However, specific safeguards have been implemented to ensure that the associated Clients and
accounts are exempt from an annual surprise examination.
Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the
deduction of advisory fees, all Clients for whom SFG exercises discretionary authority must hold their
assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to
safeguard their funds and securities and must instruct SFG to utilize that Custodian for securities
transactions on their behalf. Clients are encouraged to review statements provided by the Custodian
and compare to any reports provided by SFG to ensure accuracy, as the Custodian does not perform
this review.
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Snider Financial Group
Money Movement Authorization - For instances where Clients authorize SFG to move funds between
their accounts, SFG and the Custodian have implemented safeguards to ensure that all money
movement activities are conducted strictly in accordance with the Client’s documented instructions.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, our firm is
authorized to execute securities transactions, determine which securities are bought and sold, and
the total amount to be bought and sold. Limitations may be imposed by the client in the form of
specific constraints on any of these areas of discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write or email us to discuss questions
they may have about particular proxy votes or other solicitations.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
• Our firm does not take custody of client funds or securities.
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
• Our firm has never been the subject of a bankruptcy proceeding.
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Snider Financial Group