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Item 1 Cover Page for Part 2A of Form ADV - Firm Brochure
Dated: March 30, 2025
21515 Hawthorne Blvd, Suite 200 Torrance, CA 90503
2700 Patriot Blvd. #250 Glenview, IL 60026
9611 N US HWY 1 #332 Sebastian, FL 32958
Phone: 310-792-4189 Fax: 310-792-4189
www.southbayfinancialpartners.com
This brochure provides information about the qualifications and business practices of
South Bay Financial Partners Group, Inc d/b/a South Bay Financial Partners. If you
have any questions about the contents of this brochure, please contact us at 310-792-
4189 and/or info@southbayfinanicalpartners.com. Please know that the information in
this brochure is always accessible on our website, southbayfinancialpartners.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 South Bay Financial Partners also is available on the
SEC’s website at www.advisorinfo.sec.gov.
Being a Registered Investment Advisor (RIA) does not imply a certain level of skill or
training.
As a CFP® certificant, South Bay Financial Partners acknowledges its responsibility to
adhere to the standards established in the CFP® Board’s Standards of Professional
Conduct, including the duty of care of a fiduciary, as defined by the CFP® Board. If
Client believes that South Bay Financial Partners has violated the Standards, Client
may file a complaint online with the CFP® Board at www.cfp.net/complaint. Company
also has a more stringent Code of Ethics that all employees adhere to. A copy of this
Code of Ethics is provided upon request.
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Item 2 Material Changes
Item 1 Date updated.
Item 4 The Number of clients and AUM on 12/31/2024 was updated. Editing for clarity.
Item 5 Minimum fees and editing for clarity. Added Tax Preparation Services.
Item 13 Account review updated to indicate a more frequent review of accounts.
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Item 3 Table of Contents
Item 1 Cover Page for Part 2A of Form ADV - Firm Brochure ........................................... 1
Item 2 Material Changes ................................................................................................... 2
Item 3 Table of Contents ................................................................................................... 3
Item 4 Advisory Business .................................................................................................. 6
A.
Investment Advisory Services ................................................................................. 6
B. Financial Planning ................................................................................................... 7
C. Financial Coaching and Therapy ............................................................................ 7
D. Publication of Periodicals or Newsletters ................................................................ 8
E. Educational Seminars/Workshops .......................................................................... 8
F. Online Environment – Your Amazing Financial Life (YAFL) .................................... 8
Item 5 Fees and Compensation ......................................................................................... 8
A. Your Amazing Financial Life ................................................................................... 9
B. Fresh Start Program ............................................................................................... 9
C. Ongoing Financial Planning Service Plans ............................................................. 9
D. Financial Coaching ............................................................................................... 11
E. Standalone Investment Advisory Services ............................................................ 11
F. Tax Preparation Services ..................................................................................... 11
G. When are fees calculated ..................................................................................... 11
H. Other Types of Fees and Expenses ...................................................................... 12
I. Marketing Activities ............................................................................................... 13
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Item 6 Performance-Based Fees and Side-By-Side Management .................................. 13
Item 7 Types of Clients .................................................................................................... 13
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss .............................. 13
Item 9 Disciplinary Information ........................................................................................ 15
Item 10 Other Financial Industry Activities and Affiliations ............................................... 15
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ............................................................................................................................ 16
A. Code of Ethics Description .................................................................................... 16
B.
Investment Recommendations Involving a Material Financial Interest and Conflicts
of Interest ............................................................................................................. 17
C. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts
of Interest ............................................................................................................. 17
D. Trading Securities At/Around the Same Time as Client’s Securities ..................... 17
Item 12 Brokerage Practices ........................................................................................... 17
A. How We Select Brokers/Custodians ........................................................................ 18
E. Services that Benefit Client. .................................................................................. 19
F. Services that May Not Directly Benefit Client. ....................................................... 19
G. Services that Generally Benefit Only Advisor. ....................................................... 20
H. Our Interest in Custodian’s Services ..................................................................... 20
Item 13 Review of Accounts ............................................................................................ 21
Item 14 Client Referrals and Other Compensation .......................................................... 21
Item 15 Custody .............................................................................................................. 22
Item 16 Investment Discretion ......................................................................................... 22
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Item 17 Voting Client Securities ....................................................................................... 22
Item 18 Financial Information .......................................................................................... 22
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Item 4 Advisory Business
South Bay Financial Partners (Advisor) provides custom financial planning, financial
therapy, investment advice, and tax preparation services. We provide an integrated
service that facilitates all aspects of Client’s financial life including matters relating to
their small business, interfacing with Client’s other professional Advisors, and family
members with matters relating to finances.
We specialize in a myriad of areas, including multi-generational family financial
planning, later life transitions and financial coaching for young adults. Each Client is
evaluated individually, and advice is solely based on their needs and goals. We do not
sell financial products, nor do we receive commissions or fees for products that we
recommend. All Advisor income is paid as a salary with no compensation for selling
products or acquiring clients.
Client should be aware that, in general, the interests of the Advisor may not be the
same as the interests of the Client. Clients are under no obligation to act on Advisor’s
recommendations. If Client elects to act on any of the recommendations, Client is under
no obligation to affect the transaction through Advisor.
Advisor has $ 109,420,847.90 of non-discretionary assets and 47 Clients under
management as of December 31, 2024.
Advisor has been incorporated in the State of California since December 18, 2014 and
is wholly owned by Tara T. Unverzagt and Robert M. Unverzagt. Tara has been a
financial Advisor since 1992. Robert is not involved in the day-to-day operation of the
firm.
A. Investment Advisory Services
Advisor manages portfolios that trade primarily in individual domestic stocks and
investment grade bonds. Advisor invests in exchange traded funds (ETFs), mutual
funds, lower grade bonds, and international securities.
Client’s needs and risk preferences are established to determine portfolio design with
the aim of meeting financial goals and objectives. Advisor and Client will review goals,
objectives, and risk levels at least annually.
Client can provide restrictions on investments including types of securities to select,
particular securities or industries that they do or do not want to invest in, or other
parameters.
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While Advisor does not open brokerage accounts, Client can request assistance.
B. Financial Planning
Advisor provides a variety of financial planning services to Client which, depending on
complexity, can include:
• Full financial plan that includes analysis of current financial situation based on
information provided by Client, analyzing beliefs and behaviors that affect financial
decisions, determining financial goals, analyzing risk management (including insurance
and investment risk), developing a plan to meet goals, estate plan analysis.
• Monitoring and executing plan and goals. Including assistance to family at the death of
a Client.
• Any portion of the financial plan may be completed independently.
• Plans to achieve goals can include planning for college, retirement, debt reduction,
major purchase, or life change (e.g. getting married, changing jobs or careers, financial
independence, transitioning into retirement homes, assisted care and memory care
facilities, and death of a loved one), among others.
• Charitable giving, planning and execution.
• Small business planning including cash flow, strategic planning, benefits, and tax
planning.
• Tax preparation and planning.
C. Financial Coaching and Therapy
Hourly one-on-one sessions are available as support to Client executing their own
financial plan, investments, and tax preparation and planning. The information provided
is general in nature and allows Client to make decisions for themselves. Advisor does
not open accounts, execute trades, or decide what custodian the Client should use, etc.
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D. Publication of Periodicals or Newsletters
Advisor will periodically publish a blog entry on the company website email. The
information is general in nature and is not meant to represent financial or tax advice.
Each person’s financial situation is unique, and advice needs to be customized to their
particular situation. The information is meant to be a starting point in determining
potential financial needs to be addressed.
Advisor may publish other newsletters written by the company or purchased from a third
party. Newsletters may be distributed on paper or electronically. No specific information
about performance, past or expected, or particular securities will be discussed except
for publicly known facts such as prices and benchmark performance such as the S&P
500 Index and Dow Jones Industrial Average. Hypothetical information may be used for
educational purposes only and will be noted that it is not intended to predict results or
outcomes.
E. Educational Seminars/Workshops
Advisor will conduct workshops and on demand courses. They are open to the public,
on various topics of financial planning, investments, and tax preparation. These are
general in nature and are not meant to represent financial or tax advice for a specific
person. No specific information about performance, past or expected, or particular
securities will be discussed except for publicly known facts such as prices and
benchmark performance such as the S&P 500 Index and Dow Jones Industrial Average.
F. Online Environment – Your Amazing Financial Life (YAFL)
Advisor provides a service that allows individuals access to financial planning, financial
coaching, financial therapy, investment, and tax information. There are courses and
workshops available for educational purposes only. YAFL members can ask questions
and Advisor may refer them to resources publicly available in addition to providing
general answers that provide choices or a framework to consider when making financial
decisions.
Advisor does not participate in a wrap fee program.
Item 5 Fees and Compensation
Please note, unless a Client has received the firm’s Form ADV - Firm Brochure (this
document) at least 48 hours prior to signing the Client contract, the Client contract may
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be terminated by the Client within five (5) business days of signing the contract without
incurring any advisory fees. How we are paid depends on the type of advisory service
we are performing. Please review the fee and compensation information below.
A. Your Amazing Financial Life
Membership to Your Amazing Financial Life (YAFL) is free.
In addition, workshops, courses and classes, like the Women’s Investing Network, are
available to all members and range from free to $500 each. In the event of cancellation
by the member, fees are fully refundable up to seven (7) days prior to the
commencement of the workshop or class.
Fees are paid automatically via a credit card or ACH, as chosen by each member.
B. Fresh Start Program
The Fresh Start Program is designed as a service that new Clients experience. In this
program, we work with Clients to create an achievable plan built around their beliefs,
behaviors, life intentions, and goals. Delivered in six steps, we begin with a Discovery
meeting, that costs between $400-$600. The Discovery meeting is approximately 90
minutes covering Client’s beliefs, behaviors, and current financial situation to determine
where they are and how they got to their current financial situation. Client receives a net
worth statement, KMSI and Wealth Builder survey results, and a report summarizing
their current situation and action items they could take. If mutually decided to move
forward, we begin our financial planning process to develop a comprehensive plan that
will be delivered after the sixth step is completed. Fees for the entire program range
from $2,200 - $12,000. Discounts are available.
Current clients may go through the Fresh Start program during life transitions. There is no
additional cost to current clients for the Fresh Start program.
C. Ongoing Financial Planning Service Plans
Ongoing recurring clients are provided with investment advice, as well as tax preparation,
tax planning, reviewing risk and insurance/benefits, reviewing estate plans including
coordinating with Client’s attorney, cash flow management, and financial therapy, ie.
sessions to facilitate financial decisions.
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Fees for Ongoing Financial Planning will be calculated as follows:
2% of AGI (Adjusted Gross Income from most recently available tax return), less capital
gains + .45% of assets under management + .2% of held away assets under
advisement + $150 per Schedule C + $300 per Schedule E + $500 for administrative
overhead.
Examples:
(cid:120)
(cid:120)
(cid:120)
(cid:120)
If Client has $100,000 of investments at Brokerage, the fee is $450 per year for
the Assets Under Management portion of the fee.
If Client has $100,000 in a 401k at another brokerage that Advisor advises, the
fee would be $200 per year for the assets “held away” portion of the fee.
If the Client has $100,000 in income (as defined above), the fee would be $2,000
per year for the financial planning fee.
If the Client had $100,000 at Brokerage, a $100,000 401k under advisement, and
$100,000 employee wages, the total fee would be $3,150 per year billed $787.50
per quarter or $262.50 per month.
The minimum total fee is $810 quarterly or $270 monthly. Fees charged to Clients are
the only fees that the Advisor receives. There are no other fees, commissions, bonuses,
etc. received by Advisor. Discounts are available.
Trusts that require their own tax returns are charged 0.55% of assets under
management plus a $500 administration fee. Services include tax preparation and
planning, as well as cash flow management.
Examples:
A $1,000,000 trust held with a client, as listed previously, would pay $5,500 per year or
$1,375 per quarter.
A $1,000,000 trust held by a client that has no other services with Advisor would have
an additional $500 administration fee for a total of $6,000 per year or $1,500 per
quarter.
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D. Financial Coaching
Client executing their own financial plan, tax preparation, and investing can request
support and review of their plan for $165 per hour for basic topics. Complex topics that
require advanced knowledge are charged at a rate of $440 per hour. Client can have
special monthly packages for specific projects. These monthly subscriptions may
include access to financial planning and investment software tools. These support
services are executed during the meeting only. No preparation work is typically done
by Advisor before the meeting or follow-up after the meeting. Advisor also does not
proactively contact Client when laws or the economy change in a meaningful way. It is
the Client’s responsibility to monitor these and engage Advisor.
E. Standalone Investment Advisory Services
Our stand-alone investment advisory fee is based on the market value of the assets and
is calculated as follows:
The fee is calculated by applying the account value as of the last day of the previous
quarter.
Examples:
An account valued at $2,000,000 would pay 0.60% for an annual fee of $12,000 plus
$500 administration fee: $12,500 per year or $3,125 quarterly.
The minimum annual fee for Standalone Investment Advisory Services is $1,500. Fees
charged to Clients are the only fees that the Advisor receives. There are no other fees,
commissions, bonuses, etc. received by Advisor. Discounts are available.
Standalone investment services are not available to new clients.
F. Tax Preparation Services
Advisor offers tax preparation services to recurring clients. This is included in their fee.
Advisor offers tax preparation services to currently engage Clients that are not recurring
clients at an extra fee calculated based on the Client tax situation.
G. When are fees calculated
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For current Client, in the third quarter of each year, fees are updated based on income
from Client’s most recent available tax returns and March 31st investment account
balances calculated in our investment analysis software, Morningstar Office or Black
Diamond. New contracts are expected to be signed by the end of June. New fees take
effect on July 1st (beginning of the 3rd quarter) and are billed on September 30th (end
of the 3rd quarter).
New Client fees are based on the most recent available tax return and account
balances from the end of the most recent month according to statements provided by
Client.
Upon request, fees can be paid monthly through ACH.
H. Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related
costs and expenses which may be incurred by the Client. Client may incur certain
charges imposed by custodians, brokers, and other third parties such as custodial fees,
deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic
fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Mutual fund and exchange-traded funds also charge internal management fees, which
are disclosed in a fund’s prospectus. Such charges, fees, and commissions are
exclusive of and in addition to our fee, and we shall not receive any portion of these
commissions, fees, and costs.
Assets and Income are reassessed at least annually to ensure accuracy and
reasonableness of fees charged in comparison to services rendered. Should the fee
change because of the reassessment, a new advisory contract will be executed.
Fees for our services are billed directly from Client’s investment accounts or ACH on a
quarterly or monthly basis, billed in arrears. For one-time services, credit cards may be
allowed. The service may be terminated with 30 days written notice. Upon termination
of any agreement, the quarterly fee will be prorated based on days of service rendered
during that quarter. Since fees are paid in arrears, no refund will be needed upon
termination of the account.
In the case that Client fees are not paid 30 days after their due date, a late fee of $250
will be assessed and an additional $50 per week after the first 30 days. If fees are late
due to issues with our billing software or anything not involving the Client, then these
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fees will not be charged. Fees are due on the last business day of the quarter in which
they are billed or the last business day of the month for those who are paying monthly.
Item 12 further describes the factors that we consider in selecting or recommending
broker-dealers for Client’s transactions and determining the reasonableness of their
compensations (e.g., commissions).
We do not accept compensation for the sale of securities or other investment products,
including asset-based sales charges or service fees from the sale of mutual funds.
I. Marketing Activities
We occasionally provide token thank you gifts to people who provide testimonials. We
sometimes provide hypothetical examples for educational purposes.
Item 6 Performance-Based Fees and Side-By-Side Management
Advisor does not charge performance-based fees.
Item 7 Types of Clients
Advisor provides investment advice to high-net-worth individuals and families,
individuals, families, small businesses, freelancers, churches, trusts, pension plans, and
pooled income funds. Clients represent all age groups, working, retired, and
multigenerational families. There are no minimum asset or income requirements.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
We primarily invest in high quality stocks, investment grade bonds and cash. We may
also invest in mutual funds, ETFs, investment grade corporate bonds, U.S. Government
bonds, and Municipal bonds in particular situations. We do not invest in options or
derivatives.
Each Client’s current situation, goals, and risk tolerance are used to determine specific
investments to meet the goals with an acceptable risk level. We may invest in securities
that employees of the Advisor are also personally invested in. We always make
recommendations with solely the Client’s best interest in mind. Advisor will review each
employee’s personal trading activity at least quarterly to ensure no conflicts of interest
arise.
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Investments are researched using a variety of research tools that analyze past
performance and future projections. In addition, economic, industry, and other external
factors are evaluated to determine the effect on investments.
Asset allocation is determined based on Client’s goals and risk tolerance and is updated
based on economic and investment environment changes.
Risk is minimized using asset allocation, diversification, and high-quality investments.
Aggressive investments will be utilized if it fits the Client’s goals and risk tolerance.
Our investment philosophy is to buy and hold long-term. We aim to select stocks in
companies in which the Client wants to have ownership. We aim to buy investments at
a low price and sell at a high price. Advisor buys bonds with the expectation to hold
them to maturity or bond mutual funds when appropriate. We do not recommend
securities that are not publicly traded or investments that do not have publicly published
data.
Investing in securities involves risks and investments may experience a loss to Client.
• Market Risk: The prices of securities held by Clients may decline due to certain
events including economic, political, and social changes domestically or globally.
Financial changes, such as those described below, affect the overall market. And
market sentiment to the market in general or a particular stock affects each stock price.
• Inflation Risk: Inflation reduces the value of goods. If investments do not increase by
at least the value of inflation, the funds invested will lose value over time.
• Interest-Rate Risk: Fluctuations in interest rates cause investment prices to fluctuate.
Typically, as interest rates go up, prices of fixed income securities go down.
• Currency Risk: The change in foreign currency relative to US dollars affects
companies that are headquartered internationally, as well as domestic companies that
have large parts of their business abroad.
• Reinvestment Risk: Future proceeds from investments may have to be reinvested at
a time when the market prices are high and/or interest rates are low. This affects
securities with maturity dates.
• Liquidity Risk: The ability to readily convert an investment into cash. The more
buyers available every day, the higher the liquidity. US bonds are very liquid while real
estate and private partnerships are not.
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• Management Risk: Advisor’s investment approach may not produce expected results.
If Advisor assumptions regarding performance of asset classes or specific securities are
incorrect, the overall portfolio will perform below expectations.
• Equity Risk: Stocks are generally more volatile than other securities. Specific
securities will be more or less volatile than the market as a whole. While stocks typically
perform well over the long-term, within any given timeframe, they may fail to produce
expected results.
• Fixed Income Risk: Issuers of fixed income securities may not be able to make
interest and/or principal payments when due. Issuers are rated to identify the likelihood
of defaulting. Higher rated issuers typically pay less interest while lower rated issuers
have to pay higher interest to make up for higher risk. These ratings can change which
affects the price of the security.
• Mutual Fund/ETFs Risk: Since mutual funds and ETFs are made up of underlying
securities, they carry the same risks as described above. They can have additional risks
if they hold derivatives (such as options). Mutual funds also have management risk that
the managers of the fund will not invest to achieve expected results. ETFs may trade at
a market price that is above or below the net asset value.
Clients should know that all investments carry a risk ranging from the variability of
market values to the possibility of permanent loss of capital.
Item 9 Disciplinary Information
We have no reportable disciplinary events to disclose.
Item 10 Other Financial Industry Activities and Affiliations
Tara Unverzagt is a Registered Tax Preparer in the State of California and an IRS
Annual Filing Season Program Participant. Jessica Robertson is a Certified Public
Accountant. Tax preparation is integrated into South Bay Financial Partners’ business
for recurring Clients. We may charge an additional fee for tax preparation and planning.
South Bay Financial Partners has not registered, nor has an application pending to
register, as a broker-dealer or a registered representative of a broker-dealer. South Bay
Financial Partners is not registered, nor has an application pending to register, as
futures commission merchant, commodity pool operator, a commodity trading Advisor,
or an associated person of the foregoing entities.
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No payment is made or received for referrals of Clients from or to other investment
Advisors.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely
in the best interests of each Client. Our Clients entrust us with their funds and personal
information, which in turn places a high standard on our conduct and integrity. Our
fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis
of all of our dealings. The firm also adheres to the Code of Ethics and Professional
Responsibility adopted by the CFP® Board of Standards Inc. and accepts the obligation
not only to comply with the mandates and requirements of all applicable laws and
regulations but also to take responsibility to act in an ethical and professionally
responsible manner in all professional services and activities.
A. Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal
compliance with each of its specific provisions will not shield associated persons from
liability for personal trading or other conduct that violates a fiduciary duty to advisory
Clients. A summary of the Code of Ethics’ Principles is outlined below.
(cid:120)
Integrity - Associated persons shall offer and provide professional services with
integrity.
(cid:120) Objectivity - Associated persons shall be objective in providing professional
services to Clients.
(cid:120) Competence - Associated persons shall provide services to Clients competently
and maintain the necessary knowledge and skill to continue to do so in those
areas in which they are engaged.
(cid:120) Fairness - Associated persons shall perform professional services in a manner
that is fair and reasonable to Clients, principals, partners, and employers, and
shall disclose conflict(s) of interest in providing such services.
(cid:120) Confidentiality - Associated persons shall not disclose confidential Client
information without the specific consent of the Client unless in response to proper
legal process, or as required by law.
(cid:120) Professionalism - Associated persons’ conduct in all matters shall reflect the
credit of the profession.
(cid:120) Diligence - Associated persons shall act diligently in providing professional
services.
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We periodically review and amend our Code of Ethics to ensure that it remains current,
and we require all firm access persons to attest to their understanding of and adherence
to the Code of Ethics at least annually. Our firm will provide a copy of its Code of Ethics
to any Client or prospective Client upon request.
B. Investment Recommendations Involving a Material Financial Interest and
Conflicts of Interest
Neither our firm, its associates or any related person is authorized to recommend to a
Client or effect a transaction for a Client, involving any security in which our firm or a
related person has a material financial interest, such as in the capacity as an
underwriter, adviser to the issuer, etc.
C. Advisory Firm Purchase of Same Securities Recommended to Clients and
Conflicts of Interest
Our firm and its “related persons” may buy or sell securities similar to, or different from,
those we recommend to Clients for their accounts. In an effort to reduce or eliminate
certain conflicts of interest involving the firm or personal trading, our policy may require
that we restrict or prohibit associates’ transactions in specific reportable securities
transactions. The firm principal must approve any exceptions or trading pre-clearance in
advance of the transaction in an account, and we maintain the required personal
securities transaction records per regulation.
D. Trading Securities At/Around the Same Time as Client’s Securities
From time to time, our firm or its “related persons” may buy or sell securities for
themselves at or around the same time as Clients.
Item 12 Brokerage Practices
Advisor does not maintain custody of Client assets on which we advise, although we
may be deemed to have custody of Client assets given authority to withdraw assets
from the account. Client assets must be maintained in an account at a “qualified
custodian,” generally a broker-dealer or bank. We recommend that Client use Charles
Schwab & Co, (BROKER), registered broker-dealers, members of SIPC, as the qualified
custodian. We are independently owned and operated and are not affiliated with the
above-mentioned BROKER. BROKER will hold assets in a brokerage account and buy
and sell securities when instructed. While we recommend that Client use BROKER as
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Client’s custodian/broker, Client will decide whether to do so. Client will open an
account with BROKER by entering into an account agreement directly with them. We do
not open the account for Client, although we may assist in doing so. Even though Client
account is maintained at BROKER, Client can still use other brokers to execute trades
for Client account as described below (see “Your brokerage and custody costs”).
A. How We Select Brokers/Custodians
We seek to recommend a custodian/broker that will hold your assets and execute
transactions on terms that are, overall, most advantageous when compared with other
available providers and their services. We consider a wide range of factors, including:
• Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers,
check requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-
traded funds [ETFs], etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest
rates, other fees, etc.) and willingness to negotiate the prices
• Reputation, financial strength, and stability
• Prior service to us and our other Clients
• Availability of other products and services that benefit us, as discussed below (see
“products and services available to us from BROKER”)
For Client's accounts that BROKER maintains, BROKER generally does not charge
separately for custody services but is compensated by charging Client commissions or
other fees on trades that they execute or that settle into BROKER account. In addition
to commissions, BROKER charges Client a flat dollar amount as a “prime broker” or
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“trade away” fee for each trade that we have executed by different broker-dealer but
where the securities bought or the funds from the securities sold are deposited (settled)
into your BROKER account. These fees are in addition to the commissions or other
compensation you pay the executing broker-dealer. Because of this, in order to
minimize Client trading costs, Advisor has BROKER execute most trades for Client
account. We have determined that having BROKER execute most trades is consistent
with our duty to seek “best execution” of trades. Best execution means the most
favorable terms for a transaction based on all relevant factors, including those listed
above (see “How We Select Brokers/Custodians.”).
BROKER serves independent investment advisory firms like us. They provide us and
our Clients with access to its institutional brokerage services (trading, custody,
reporting, and related services), many of which are not typically available to retail
customers. BROKER also makes available various support services. Some of those
services help us manage or administer our Client’s accounts; while others help us
manage and grow our business. BROKER’s support services are generally available on
an unsolicited basis (i.e., we don’t have to request them) and at no charge to us.
Following is a more detailed description of BROKER’s support services:
E. Services that Benefit Client.
BROKER’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client assets.
The investment products available through BROKER include some to which we might
not otherwise have access or that would require a significantly higher minimum initial
investment by Clients. BROKER’s services described in this paragraph generally benefit
Client and Client’s account.
F. Services that May Not Directly Benefit Client.
BROKER also makes available to us other products and services that benefit Advisor
but may not directly benefit Client. These products and services assist us in managing
and administering Client’s accounts. They include investment research, both BROKER’s
own and that of third parties. We may use this research to service all or a substantial
number of our Client’s accounts, including accounts not maintained at BROKER. In
addition to investment research, BROKER also makes available software and other
technology that:
• Provide access to Client account data (such as duplicate trade confirmations and
account statements)
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• Provide pricing and other market data
• Facilitate payment of Advisor fees from Client’s accounts
• Assist with back-office functions, recordkeeping, and Client reporting
G. Services that Generally Benefit Only Advisor.
Schwab also offers other services intended to help Advisor manage and further develop
our business enterprise. These services include:
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, pension plan
consultants, and insurance providers.
BROKER may provide some of these services itself. In other cases, it will arrange for
third-party vendors to provide the services to Advisor. BROKER may also discount or
waive its fees for some of these services or pay all or a part of a third party’s fees.
BROKER may also provide us with other benefits, such as occasional business
entertainment for our personnel.
H. Our Interest in Custodian’s Services
The availability of these services from BROKER benefits Advisor because Advisor did
not have to produce or purchase them. Advisor does not have to pay for BROKER’s
services. These services are not contingent upon Advisor committing any specific
amount of business to BROKER in trading commissions or assets in custody. Advisor
may have an incentive to recommend that Client maintain account with BROKER,
based on Advisor interest in receiving BROKER’s services that benefit Advisor’s
business rather than based on Client’s interest in receiving the best value in custody
services and the most favorable execution of Client’s transactions. This is a potential
conflict of interest. Advisor believes, however, that the selection of BROKER is in the
best interests of Clients. Advisor selection is primarily supported by the scope, quality,
and price of BROKER services (see “How We Select Brokers/Custodians”) and not
BROKER’s services that benefit only Advisor. Also, services and products provided by
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BROKER reduce the cost to Advisor of maintaining Client’s account and therefore
reduce Client’s overall fees.
Item 13 Review of Accounts
Client accounts are reviewed weekly by Advisor. In-depth investment reviews occur at
least annually. Transactions in the Client’s account will be reported by BROKER.
Item 14 Client Referrals and Other Compensation
As disclosed under Item 12, above, Advisor participates in BROKER institutional
customer program and Advisor may recommend BROKER to Clients for custody and
brokerage services. There is no direct link between Advisor’s participation in the
program and the investment advice it gives to its Clients, although Advisor receives
economic benefits through its participation in the program that are typically not available
to BROKER retail investors. These benefits include the following products and services
(provided without cost or at a discount): receipt of duplicate Client statements and
confirmations; research-related products and tools; consulting services; access to a
trading desk serving Advisor participants; the ability to have advisory fees deducted
directly from Client accounts; access to an electronic communications network for Client
order entry and account information; access to mutual funds with no transaction fees
and to certain institutional money managers; and discounts on compliance, marketing,
research, technology, and practice management products or services provided to
Advisor by third party vendors.
BROKER may also have paid for business consulting and professional services
received by Advisor’s related persons. Some of the products and services made
available by BROKER through the program may benefit Advisor but may not benefit its
Client accounts. These products or services may assist Advisor in managing and
administering Client accounts, including accounts not maintained at BROKER.
Other services made available by BROKER are intended to help Advisor manage and
further develop its business enterprise. The benefits received by Advisor or its
personnel through participation in the program do not depend on the number of
brokerage transactions directed to BROKER.
As part of its fiduciary duties to Clients, Advisor endeavors always to put the interests of
its Clients first. Clients should be aware, however, that the receipt of economic benefits
by Advisor or its related persons in and of itself creates a potential conflict of interest
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and may indirectly influence the Advisor’s choice of BROKER for custody and
brokerage services.
Item 15 Custody
Advisor will obtain previous written authorization from Client to deduct advisory fees
from the account held with BROKER. BROKER will send statements, at least quarterly,
to Client showing all disbursements for the investment account, including the amount of
the advisory fees. Each time a fee is directly deducted from Client account, Advisor
concurrently sends BROKER an invoice of the amount of the fee to be deducted from
Client’s account; and sends Client an invoice or statement itemizing the fee. BROKER
maintains actual custody of Client’s assets. They will be sent to the email or postal
mailing address Client provided to BROKER. Client should carefully review those
statements promptly when received. Advisor also urges Client to compare BROKER’s
account statements with the periodic portfolio reports Client will receive from Advisor.
Item 16 Investment Discretion
Advisor does have the ability to make trades in accounts at BROKER, but the
relationship with Client’s account is non-discretionary in that Client approves all
transactions prior to execution. Client approves BROKER used and the commission
rates paid to BROKER. Advisor does not receive any portion of the transaction fees or
commissions that Client pays to the custodian. Advisor does not have discretion over
accounts held away from BROKER. Client is responsible for all trades made.
Item 17 Voting Client Securities
We do not have authority to vote proxies for Client’s securities.
Item 18 Financial Information
Advisor has no financial impairment to report that would affect its ability to provide
service to Client. Advisor has never been the subject of a bankruptcy petition at any
time. Advisor does not require or solicit prepayment of more than $500 in fees from
Client, six months or more in advance for investment services.
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