Overview
- Headquarters
- El Dorado Hills, CA
- Average Client Assets
- $2.7 million
- Minimum Account Size
- $100,000
- SEC CRD Number
- 306217
Fee Structure
Primary Fee Schedule (FORM ADV - STATHEROS FINANCIAL SOLUTIONS INC.)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.20% |
| $500,001 | $1,000,000 | 1.10% |
| $1,000,001 | $2,500,000 | 0.80% |
| $2,500,001 | $5,000,000 | 0.65% |
| $5,000,001 | $10,000,000 | 0.40% |
| $10,000,001 | $15,000,000 | 0.25% |
| $15,000,001 | and above | 0.10% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,500 | 1.15% |
| $5 million | $39,750 | 0.80% |
| $10 million | $59,750 | 0.60% |
| $50 million | $107,250 | 0.21% |
| $100 million | $157,250 | 0.16% |
Clients
- HNW Share of Firm Assets
- 47.45%
- Total Client Accounts
- 1,430
- Discretionary Accounts
- 1,430
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Regulatory Filings
Primary Brochure: FORM ADV - STATHEROS FINANCIAL SOLUTIONS INC. (2026-03-20)
View Document Text
Statherόs Financial Solutions, Inc.
2026
Form ADV Part 2A
Firm Brochure
(Part 2A of Form ADV)
Statherόs Financial Solutions, Inc.
1107 Investment Blvd., Ste. 135
El Dorado Hills CA 95762
2107 N 1st Street, Ste. 415
San Jose CA 95131
Phone: (916) 932-1219
Phone: (408) 871-1590
Fax: (866) 294-7650
Fax: (866) 294-7650
WEBSITE: WWW.STATHEROSFINANCIAL.COM
EMAIL: kelly@statherosfinancial.com
This brochure provides information about the qualifications and business practices of Statherόs
Financial Solutions, Inc. If you have any questions about the contents of this brochure, please
contact us at: (916) 932-1219, or by email at: compliance@statherosfinancial.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 Statherόs Financial Solutions, Inc. is available on the SEC’s website
at www.adviserinfo.sec.gov
March 2026
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2026
Form ADV Part 2A
Item 2: Material Changes
Amending Update
This is the firm’s amended Form ADV filing, but the Material Changes section of this brochure will be
updated whenever material changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
No material changes since the last update
Full Brochure Available
Whenever you would like to receive a printed copy of our Firm Brochure, please contact us by telephone at:
(916) 932-1219 or by email at: compliance@statherosfinancial.com
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Form ADV Part 2A
Item 3: Table of Contents
ITEM 2: MATERIAL CHANGES ......................................................................................................................... 2
AMENDING UPDATE ..................................................................................................................................................... 2
MATERIAL CHANGES SINCE THE LAST UPDATE ............................................................................................................ 2
FULL BROCHURE AVAILABLE ....................................................................................................................................... 2
ITEM 3: TABLE OF CONTENTS ........................................................................................................................ 3
ITEM 4: ADVISORY BUSINESS ........................................................................................................................... 5
FIRM DESCRIPTION ....................................................................................................................................................... 5
Principal Owners .................................................................................................................................................... 5
TYPES OF ADVISORY SERVICES .................................................................................................................................... 5
INVESTMENT ADVISORY AGREEMENT .......................................................................................................................... 6
FULL-SERVICE ADMINISTRATIVE SERVICES AGREEMENT ............................................................................................ 6
RETIREMENT PLAN SERVICES AGREEMENT .................................................................................................................. 6
OTHER SERVICES AGREEMENTS ................................................................................................................................... 6
ASSET MANAGEMENT .................................................................................................................................................. 6
TERMINATION OF AGREEMENT ..................................................................................................................................... 7
ITEM 5: FEES AND COMPENSATION .............................................................................................................. 7
INVESTMENT ADVISORY SERVICES ............................................................................................................................... 7
CUSTODIAN SERVICES .................................................................................................................................................. 8
FULL-SERVICE ADMINISTRATIVE SERVICES ................................................................................................................. 9
RETIREMENT PLAN ADVISORY SERVICES ..................................................................................................................... 9
FINANCIAL PLANNING SERVICES ................................................................................................................................ 10
OTHER FEES ............................................................................................................................................................... 10
FEE BILLING ............................................................................................................................................................... 10
ITEM 6: PERFORMANCE FEES ....................................................................................................................... 10
CONFLICT OF INTEREST BETWEEN DIFFERENT FEE STRUCTURES ............................................................................... 10
ITEM 7: TYPES OF CLIENTS ........................................................................................................................... 11
DESCRIPTION .............................................................................................................................................................. 11
ACCOUNT MINIMUMS ................................................................................................................................................. 11
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ......................... 11
METHODS OF ANALYSIS ............................................................................................................................................. 11
INVESTMENT STRATEGIES .......................................................................................................................................... 11
MARKET, SECURITY AND REGULATORY RISKS........................................................................................................... 11
Market Risks: ....................................................................................................................................................... 11
Regulatory Risks: ................................................................................................................................................. 13
Security Specific Risks: ........................................................................................................................................ 14
ITEM 9: DISCIPLINARY INFORMATION ...................................................................................................... 14
LEGAL AND DISCIPLINARY ......................................................................................................................................... 14
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ........................................ 14
AFFILIATIONS ............................................................................................................................................................. 14
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ITEM 11: CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL
TRADING ............................................................................................................................................................. 14
CODE OF ETHICS ......................................................................................................................................................... 14
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS ........................................................................................... 15
PERSONAL TRADING ................................................................................................................................................... 15
ITEM 12: BROKERAGE PRACTICES .............................................................................................................. 15
BROKERAGE SELECTION AND SOFT DOLLARS ............................................................................................................ 15
ORDER AGGREGATION ............................................................................................................................................... 15
DIRECTING BROKERAGE FOR CLIENT REFERRALS ...................................................................................................... 15
ITEM 13: REVIEW OF ACCOUNTS ................................................................................................................. 16
PERIODIC REVIEWS ..................................................................................................................................................... 16
REVIEW TRIGGERS...................................................................................................................................................... 16
REGULAR REPORTS .................................................................................................................................................... 16
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ............................................................... 16
INCOMING CLIENT REFERRALS ................................................................................................................................... 16
ITEM 15: CUSTODY ........................................................................................................................................... 16
CUSTODY POLICY ....................................................................................................................................................... 16
ACCOUNT STATEMENTS ............................................................................................................................................. 17
PERFORMANCE REPORTS ............................................................................................................................................ 17
ITEM 16: DISCRETIONARY AUTHORITY FOR TRADING ......................................................................... 17
WEALTH MANAGEMENT CLIENTS: ............................................................................................................................. 17
RETIREMENT PLAN CLIENTS: ...................................................................................................................................... 17
ITEM 17: VOTING CLIENT SECURITIES....................................................................................................... 17
PROXY VOTES ............................................................................................................................................................ 17
ITEM 18: FINANCIAL INFORMATION ........................................................................................................... 17
FINANCIAL CONDITION ............................................................................................................................................... 17
BUSINESS CONTINUITY PLAN ........................................................................................................................ 18
GENERAL .................................................................................................................................................................... 18
DISASTERS .................................................................................................................................................................. 18
ALTERNATE OFFICES .................................................................................................................................................. 18
SUMMARY OF BUSINESS CONTINUITY PLAN ............................................................................................................... 18
INFORMATION SECURITY PROGRAM .......................................................................................................... 18
INFORMATION SECURITY ............................................................................................................................................ 18
PRIVACY PRACTICES .................................................................................................................................................. 18
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Form ADV Part 2A
Item 4: Advisory Business
Firm Description
Statherόs Financial Solutions, Inc., (“the Advisor”) was founded in 2019 and is an SEC registered investment
advisor.
Statherόs Financial Solutions, Inc. is succeeding to the business of a registered investment adviser due to a
change in the ownership structure of our predecessor investment advisory firm, PGR Solutions, LLC.
The Advisor provides personalized 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 may 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. In additions to investment management the Advisor provides administrative
and portfolio support services to other third-party investment managers and/or registered representatives of
broker dealers and also provides retirement plan advisory and consulting services to qualified retirement plan
sponsors.
The Advisor is a fee-only investment management firm and does not sell securities on a commission basis.
However, there may be some associated persons who are in other fields where they receive commissions as
compensation. In addition, some associates may serve at the pleasure of their client as a trustee, board
member, or in a similar capacity. All such relationships are fully disclosed and subject to the review of
management.
The firm is not affiliated with entities that sell financial products or securities.
Investment advice is provided, with the client making the final decision on investment selection. The Advisor
does not act as a custodian of client assets and the client always maintains asset control.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on
an as-needed basis. Any conflicts of interest arising out of the Advisor or its associated persons are disclosed
in this brochure.
Principal Owners
Jake Parsons 88% stockholder, Kelly Roemers 10% stockholder, other 2% stockholder
Types of Advisory Services
The Advisor provides investment supervisory services, also known as asset management services and
manages investment Advisory accounts not involving investment supervisory services. On more than an
occasional basis, the Advisor furnishes advice to clients on matters not involving securities, such as financial
planning matters, investment management administration, retirement plan consulting and administrative
services and actuarial services. The Advisor does not offer wrap fee programs.
As of December 31, 2025, Statherόs Financial Solutions, Inc. manages approximately $926,170,170 in
discretionary assets for approximately 629 households.
Types of Agreements
The following agreements define the typical client relationships. Agreements may not be assigned without
client consent.
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Form ADV Part 2A
Investment Advisory Agreement
Advisor provides investment advice and management to individually managed accounts. Advisor acts on a
discretionary or non-discretionary basis, per the clients’ requests, with respect to these accounts and client
assets are deposited in a qualified custodian account. The Advisor uses its own managed model allocations
or will customize portfolio allocations for each client. The allocations for each client are primarily achieved
through the use of mutual funds and/or exchange-traded funds (ETFs). In certain cases, allocations may also
incorporate the use of institutional class index variable life/annuity products through a non-affiliated third-
party firm that sponsors institutional index variable annuity products. In determining whether to recommend
these annuities, or any investment product, the Adviser that will consider whether the particular product meets
the client’s investment objectives and risk tolerances, among other factors.
The scope of work and fee for an Advisory Service Agreement is provided to the client in writing prior to the
start of the relationship.
Full-Service Administrative Services Agreement
The Advisor provides administrative and portfolio support services to clients of other third-party investment
managers and/or registered representatives of broker dealers. These services may include access to managed
models as well as the ability to customize allocations using the underlying funds for the third party to
determine an appropriate allocation for their clients. Additional, back office services include but are not
limited to documentation, reporting, account setup, client transaction processing, fee processing, file
maintenance, and other administrative services.
Retirement Plan Services Agreement
The Advisor provides retirement plan advisory services to qualified retirement plan sponsors. These
Advisory services generally include employee education and enrollment meetings and investment
management and discretionary advisory services to the Plan Sponsor and/or its employees in accordance with
the Plans’ Investment Policy Statements. Additional services include but are not limited to file maintenance,
and access to model allocations.
Other Services Agreements
Advisor may do general financial planning work for investment advisory clients. Such work is preliminary
to and generally compensated solely by the fees for investment supervisory services. Financial planning may
be the only service provided to the client and does not require that the client use or purchase the investment
advisory services offered by the Advisor. There is an inherent conflict of interest for the Advisor whenever
a financial plan recommends use of professional investment management services. The Advisor or its
associated persons may receive compensation as a result of the recommendation for the provision of
investment management services. The client is under no obligation to accept any of the recommendations of
the Advisor or use the services of the Advisor in particular.
Additionally, Advisor may provide actuarial consulting work for non-investment advisory clients. Such work
is billed on an hourly basis directly to the client at $300/hr. The Advisor at its sole discretion may elect to
charge a different fee for this service or waive the fee entirely. The Advisor does not make any representation
that these services are offered at the lowest available cost and the client may be able to obtain the same
products or services at a lower cost from other providers.
Asset Management
Assets are invested primarily in no-load or low-load mutual funds, usually through Qualified Custodians
(“Custodians”) and/or fund companies. Fund companies charge each fund shareholder an investment
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management fee that is disclosed in the fund prospectus. Custodians may charge a transaction fee for the
purchase of some funds.
Stocks and bonds transferred to Advisor will be sold through a brokerage account as needed, usually as an
accommodation or when transacting legacy securities. The brokerage firm charges a fee for stock and bond
trades.
The Advisor does not receive any compensation, in any form, from fund companies.
Initial public offerings (IPOs) are not available through the Advisor.
Termination of Agreement
The client may terminate immediately Advisor's investment management services within five (5) days of
signing the agreement and will not be charged a fee provided no assets have transferred to the account. After
then, the investment management agreement may be terminated at any time by mutual consent of the parties,
or without such consent, by either party giving to the other party written notice of termination concurrent with
or in advance of the termination date. If the agreement is terminated, client will only be charged a pro-rated
fee up through the date assets are transferred out of the account managed by Advisor.
The third-party investment management services may be terminated by either party with written or verbal
notice concurrent with or in advance of the effective termination date. Prepaid investment management fees,
if any, will be returned to the third party.
The retirement plan consulting and administrative services may be terminated by either party with written
notice 30 days prior to the effective termination date.
The Advisor reserves the right to stop work on any account that is more than 30 days overdue. In addition,
the Advisor 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 the Advisor’s judgment, to providing proper financial advice.
Item 5: Fees and Compensation
Investment Advisory Services
The Advisor bases its fees on a percentage of assets under management and in some rare instances may charge
hourly for actuarial consulting work for non-investment Advisory clients. Although the Advisory Service
Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client
is at the client’s discretion. The client or the investment manager may terminate an Agreement by written
notice to the other party. At termination, fees will be billed on a pro rata basis for the portion of the quarter
completed. The portfolio value at the completion of the prior full billing quarter is used as the basis for the
fee computation, adjusted for the number of days during the billing quarter prior to termination.
Fees for investment Advisory accounts are payable quarterly in arrears and are calculated based on the
average daily account balance during the quarter. These fees are tiered in that the stated fee is applied to each
portion of the client’s average daily balance. The maximum percentage annual fee charged on each tier is
based on the following schedule:
Annualized Investment Advisory Fees
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Account Value From
Account Value To
Annual Percentage Fee
$0
$499,999
Not to Exceed 1.20%
The next $500,000
$999,999
Not to Exceed 1.10%
The next $1,500,000
$2,499,999
Not to Exceed 0.80%
The next $2,500,000
$4,999,999
Not to Exceed 0.65%
The next $5,000,000
$9,999,999
Not to Exceed 0.40%
The next $5,000,000
$14,999,999
Not to Exceed 0.25%
Amount over $15,000,000
Not to Exceed 0.10%
The Advisor at its sole discretion may elect to charge a client a fee different from the above schedule. The
Advisor may and does provide investment management services to persons related to the Advisor at no
management fee.
The Advisor relies primarily on mutual funds in clients’ portfolios. Clients may be charged for the services
by the providers/managers of these products in addition to the management fee paid to The Advisor. The
fees and expenses charged by the product providers are separate and distinct from the management fee
charged by The Advisor. These fees and expenses are described in each mutual fund’s or underlying annuity
fund’s prospectus. These fees will generally include a management fee, other fund expenses and a possible
distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no
initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay
an initial or deferred sales charge. A client could invest in a mutual fund without the services of The Advisor.
Accordingly, the client should review both the fees charged by the funds and the applicable program fee
charged by The Advisor to fully understand the total amount of fees to be paid by the client and to thereby
evaluate the Advisory services being provided. Similar to other securities held in the client’s account, the
Adviser may also charge a management fee on the variable annuity assets.
The client may terminate immediately Advisor's services within five (5) days of signing the agreement and
will not be charged a fee. After then, the investment management agreement may be terminated at any time
by mutual consent of the parties, or without such consent, by either party giving to the other party written
notice of termination. If the agreement is terminated, any unused portion of any prepaid management fees
will be returned to the client.
Custodian Services
Statherόs has selected Charles Schwab & Co., Inc. (“Schwab”) as primary custodian for our clients’
accounts. By using Schwab as primary custodian, Statherόs has access to a wide range of products and
services that help us serve our clients, including:
• Full range of investment products and trading services
• Technology and service support
• Wide array of investment account types including retirement accounts, charitable giving, and
education accounts
Custodian fees may be asset based or transaction based and depend on the clients’ wishes and any obvious
advantage that one pricing program can provide over the other. Clients will be informed at the time the
account is opened as to which pricing structure they will fall under. Statherόs does not receive any portion
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Form ADV Part 2A
of the custodian’s fee. Statherόs does not make any representation that these services are at the lowest cost
available and clients may be able to obtain these services at a more favorable rate from other providers.
Full-Service Administrative Services
Statherόs offers Full-Service Administration services to third party unaffiliated investment advisors and
broker-dealers. The firms that utilize Administration services receive access to model portfolios managed by
Advisor as well as administrative support as a solution to their back-office and trading needs. These services
may have been offered in the past under other names but the fees did not exceed those shown below.
The benefit to the firms is that it allows them to focus their efforts on building their business and servicing
clients. The firms’ clients sign Advisor’s administrative service agreement but are not considered clients of
Advisor for purposes of calculating AUM unless clients invest in the Advisor’s managed model portfolios.
For accounts opened through the Full-Service Administration program, Advisor collects the administrative
service fees as follows:
Annualized Full-Service Administrative Services Fees
Account Value From
Account Value To
Annual Percentage Fee
$0
$499,999
Not to Exceed 0.38%
The next $500,000
$999,999
Not to Exceed 0.32%
The next $1,500,000
$2,499,999
Not to Exceed 0.26%
The next $2,500,000
$4,999,999
Not to Exceed 0.20%
Amount over $5,000,000
Not to Exceed 0.14%
These fees are tiered in that the stated fee is applied to each portion of the client’s average daily balance. The
above annual fees are charged quarterly in arrears. The Advisor at its sole discretion may elect to charge a
fee different from the above schedule or waive the fee entirely. The Advisor does not make any representation
that these services are at the lowest cost available and the third-party advisors and their clients may be able
to obtain those services at a more favorable rate from other providers. Any prepaid administrative fees will
be returned to the third party.
Retirement Plan Advisory Services
Advisory Fees for Retirement Plan accounts are payable quarterly in arrears and are calculated based on the
account balance on the last day of each quarter. The maximum percentage annual fee charged on each tier is
based on the following schedule:
Annualized Retirement Plan Advisory Fees
Account Value From
$0
Account Value To
$999,999
$2,499,999
$4,999,999
$9,999,999
$19,999,999
The next $1,500,000
The next $2,500,000
The next $5,000,000
The next $10,000,000
Amounts over $20,000,000
Annual Percentage Fee
Not to Exceed 0.80%
(minimum annual fee $1000)
Not to Exceed 0.65%
Not to Exceed 0.50%
Not to Exceed 0.35%
Not to Exceed 0.25%
Not to Exceed 0.10%
These fees are tiered in that the stated fee is applied to each portion of the client’s average daily balance.
The above annual fees are charged quarterly in arrears.
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Additional fees for ancillary services on Retirement Plans may be charged on an hourly basis at a rate between
$100 and $300 per hour and will be quoted in advance of the work. Examples of ancillary services include,
but are not limited to, IRS/Department of Labor audit support or specialized plan consulting.
When evaluating these services, the client should consider the total annual cost of asset-based Advisory fees
when comparing services elsewhere. The Advisor does not make any representation that these services are
at the lowest cost available and the third-party advisors and their clients may be able to obtain those services
at a more favorable rate from other providers
Financial Planning Services
Clients that do not have an investment advisory agreement with the Adviser may engage the Adviser to
perform financial planning services. The Adviser may charge a fixed fee for each engagement which is
calculated based on the complexity and intricacy of a client’s financial situation and planning needs. As such,
a fee can total in the range from $1,800 - $10,000. Financial planning may be the only service provided to
the client and does not require that the client use or purchase the investment advisory services offered by the
Advisor.
Other Fees
In addition to the management fee paid to the Advisor, clients may be charged for the services by the
providers/managers of investment products. The Advisor, from time to time, may select or recommend
investments with fees that are separately charged by the product providers and are separate and distinct from
the management fee charged by the Advisor. These fees will generally include a management fee, other fund
expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios
so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected,
a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity
or investment partnership directly, without the services of the Advisor. Accordingly, the client should review
both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand
the total amount of fees to be paid by the client.
Investment Advisory clients are required to use a custodian recommended by the Advisor. The fees charged
by the custodian are provided to clients prior to signing an agreement and are in addition to fees charged by
Advisor. The Advisor does not make any representation that these products and services are offered at the
lowest available cost and the client may be able to obtain the same products or services at a lower cost from
other providers.
Fee Billing
Investment management fees are billed quarterly, in arrears meaning that we invoice you after the three-
month billing period has ended. The billing, or Fee Statement, is either included in the statement sent to you
directly from the custodian or plan recordkeeper, or is made available separately by Advisor through an online
portal depending on the type of service received. Payment in full is expected upon invoice presentation. Fees
are deducted from the client account to facilitate billing as authorized by the investment management
agreement.
Item 6: Performance Fees
Fees are not based on a share of the capital gains or capital appreciation of managed securities. The Advisor
does not use a performance-based fee structure.
Conflict of Interest Between Different Fee Structures
The Advisor offers several different services detailed in this brochure that compensate the Advisor differently
depending on the service selected. There is a conflict of interest for the Advisor and its associated personnel
to recommend the services that offer a higher level of compensation to the Firm through either higher
management fees or reduced administrative expenses. The Advisor mitigates this conflict through its
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Form ADV Part 2A
procedures to review client accounts relative to the client or investors personal financial situation to ensure
the investment management service provided is appropriate. Further, the Advisor is committed to its
obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and
its associated persons fulfill their fiduciary duty to clients or investors.
Item 7: Types of Clients
Description
The Advisor generally provides investment advice to individuals, pension and profit-sharing plans, trusts,
estates, or charitable organizations and corporations, and business entities. Client relationships vary in scope
and length of service.
Account Minimums
The Advisor generally prefers a $100,000 minimum investment to open an account. Advisor may accept a
smaller amount at its sole discretion.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods may include fundamental analysis and cyclical analysis. The main sources of
information include financial newspapers and magazines, research materials prepared by others, corporate
rating services, annual reports, prospectuses and filings with the Securities and Exchange Commission.
The Advisor also makes use of a proprietary technology in the allocation of assets within a client’s account
called Portfolio Builder. Portfolio Builder includes twelve (12) basic allocations that are tailored to differing
account tax-status levels of financial need and risk tolerance. Investment Advisor Representatives may select
one of those twelve (12) or further modify the allocation based on the specific needs of each client. Portfolio
Builder also reflects suggested mutual funds to fill the client allocations and provides modeled historical
performance information based on the client’s specific allocation.
Investment Strategies
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. Each client executes a Risk Tolerance Questionnaire and interview
with their Advisor representative that documents their objectives and their desired investment strategy. The
Advisor’s strategies do not involve frequent trading. The Advisor generally uses a long-term purchases
strategy meaning securities held at least a year.
Market, Security and Regulatory Risks
Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts
of interest. All investment programs have certain risks that are borne by the investor which are described
below:
Market Risks:
Competition: The securities industry and the varied strategies and techniques to be engaged in by the Advisor are extremely
competitive and each involves a degree of risk. The Advisor will compete with firms, including many of the
larger securities and investment banking firms, which have substantially greater financial resources and research
staff.
Statherόs Financial Solutions, Inc.’s Investment Activities: The Advisors’ investment activities involve a
significant degree of risk. The performance of any investment is subject to numerous factors which are neither
within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political,
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Form ADV Part 2A
competitive, technological and other conditions (including acts of terrorism and war) that may affect
investments in general or specific industries or companies. The securities markets may be volatile, which may
adversely affect the ability of the Advisor to realize profits. Additionally, specific investments under the
Advisors’ strategy may require significant time to realize the expected return and may experience a pricing
correction in a faster-than-expected time, subjecting the Advisor to reinvestment risk. Likewise, the investment
strategy of the Advisor is partially dependent on its ability to correctly identify and assess technology’s impact
on a company’s business. As a result of the nature of the Advisors’ investing activities, it is possible that its
financial performance may fluctuate substantially over time and from period to period.
Material Non-Public Information: By reason of their responsibilities in connection with other activities of
the advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire
confidential or material non-public information or be restricted from initiating transactions in certain securities.
The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not
be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment
that it otherwise might have sold.
Accuracy of Public Information: The Advisor selects investments, in part, on the basis of information and
data filed by issuers with various government regulators or made directly available to the Advisor by the issuers
or through sources other than the issuers. Although the Advisor evaluates all such information and data and
sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the
Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data,
and in some cases, complete and accurate information is not available. Investments may not perform as expected
if information is inaccurate.
Volatility of Currency Prices: The profitability of the Advisors’ portfolios depends, in part, upon the Advisor
correctly assessing the future price movements of currencies. However, price movements of currencies are
difficult to predict accurately because they are influenced by, among other things, changing supply and demand
relationships; governmental, trade, fiscal, monetary and exchange control programs and policies; national and
international political and economic events; and changes in interest rates. Governments from time to time
intervene in certain markets in order to influence prices directly. The Advisor cannot guarantee that it will be
successful in accurately predicting currency price and interest rate movements.
Market or Interest Rate Risk: The price of most fixed income securities moves in the opposite direction of
the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the
Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact
on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity
date, an increase in interest rates could result in a loss to the Advisor.
Investments in Non-U.S. Investments: From time to time, the Advisor may invest and trade a portion of its
assets in non-U.S. securities and other assets (through mutual funds of foreign securities and otherwise), which
will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting
from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such
risks may include:
• Political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism,
withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations on the use or
transfer of portfolio assets.
• Enforcing legal rights in some foreign countries is difficult, costly and slow, and there are sometimes special
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Form ADV Part 2A
problems enforcing claims against foreign governments.
• Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor may
directly hold foreign currencies and purchase and sell foreign currencies through forward exchange
contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of
dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the
strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s investments
to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the
currency markets, causing a decline in value or liquidity of the Advisor’s foreign currency holdings. If the
Advisor enters into forward foreign currency exchange contracts for hedging purposes, it may lose the
benefits of advantageous changes in exchange rates. On the other hand, if the Advisor enters forward
contracts for the purpose of increasing return, it may sustain losses.
• Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely
supervised by the government than in the United States. Foreign countries often lack uniform accounting,
auditing and financial reporting standards, and there may be less public information about the operations of
issuers in such markets.
Risk of Default or Bankruptcy of Third Parties: The Advisor may engage in transactions in securities,
commodities, other financial instruments and other assets that involve counterparties. Under certain conditions,
the Advisor could suffer losses if counterparty to a transaction were to default or if the market for certain
securities, commodities, other financial instruments and/or other assets were to become illiquid. In addition, the
Advisor could suffer losses if there were a default or bankruptcy by certain other third parties, including
brokerage firms and banks with which the Advisor does business, or to which securities, commodities, other
financial instruments and/or other assets have been entrusted for custodial purposes. For example, if the
Advisor’s prime broker and custodian were to become insolvent or file for bankruptcy, the Advisor could suffer
firm.
significant
losses
with
respect
to
any
securities
held
by
such
Regulatory Risks:
Strategy Restrictions: Certain institutions may be restricted from directly utilizing investment strategies of the
type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult
their own Advisors, counsel and accountants to determine what restrictions may apply and whether an
investment in the Advisor is appropriate.
Trading Limitations: For all securities, instruments and/or assets listed on an exchange, including options
listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain
circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and
subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate
positions and thereby expose the Advisor to potential losses.
Tax Risk: The tax aspects of an investment in the Advisor are complicated and each investor should have them
reviewed by professional advisors familiar with such investor’s personal tax situation and with the tax laws and
regulations applicable to the investor and private investment vehicles as applicable.
Conflicts of Interest: In the administration of client accounts, portfolios and financial reporting, the Advisor
faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates
these conflicts through its Code of Ethics which provides that the client’s interest is always held above that
of the Firm and its associated persons.
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Form ADV Part 2A
Supervision of Trading Operations: The Advisor’s, with assistance from its brokerage and clearing firms,
intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and
client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise
inappropriate trading activity may occur in portfolio accounts.
Security Specific Risks:
Depending on the nature of the investment management service selected by a client and the securities used to
implement the investment strategy, clients will be exposed to risks that are specific to the securities in their
particular investment portfolio.
Currency: 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
Limited Liquidity of Interests: An investment in a partnership usually involves substantial restrictions on
liquidity and its interests are not freely transferable. There is no market for the interests the Advisor and no
market should be expected to develop. Additionally, transfers are usually subject to the consent of the general
partner at the general partner’s sole discretion.
Item 9: Disciplinary Information
Legal and Disciplinary
The firm and its employees have not been involved in legal or disciplinary events related to past or present
investment clients.
Item 10: Other Financial Industry Activities and Affiliations
Affiliations
The Advisor has material relationships with certain broker dealers and investment advisors that use the
Advisor’s administrative investment management services to augment their own investment management
services as previously described under Administrative Investment Management Services and Retirement Plan
Services
The Advisor's associates are CPAs and licensed real estate agents/brokers. Client’s use of the accountancy
services or real estate services of investment advisor representatives is not required and the Advisor does not
represent these services are available at the lowest cost. A conflict of interest exists in that the associates will
devote time to these other business activities as needed which are separate and distinct from the Advisor’s
investment management services. However, this conflict is mitigated by the Advisor ensuring that it and its
associated persons fulfill the fiduciary responsibility to the client and that at no time are the clients
compromised by the outside activities.
Item 11: Code of Ethics, Participation in Client Transactions and Personal Trading
Code of Ethics
The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons.
The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary
obligations to clients and applicable securities laws, and specific requirements relating to, among other things,
personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires
supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s
Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised
persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each
supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must
acknowledge in writing having received the materials. Annually, each supervised person must certify that he
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Form ADV Part 2A
or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy
of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor.
Participation or Interest in Client Transactions
Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers and employees may
invest personally in securities of the same classes as are purchased for clients and may own securities of the
issuers whose securities are subsequently purchased for clients. Given that the Advisor almost exclusively
only purchases mutual funds for client portfolios, it is an uncommon occurrence for individual securities to
be purchased for client portfolios. However, if an issue is purchased or sold for clients and any of the Advisor,
managers, members, officers and employees on the same day purchase or sell the same security, either the
clients and the Advisor, managers, members, officers or employees shall receive or pay the same price or the
clients shall receive a more favorable price. The Advisor and its managers, members, officers and employee
may also buy or sell specific securities for their own accounts based on personal investment considerations,
which the Advisor does not deem appropriate to buy or sell for clients.
Personal Trading
The Chief Compliance Officer of The Advisor is Kelly Roemers. She reviews all employee trades each
quarter (except for her own trading activity that is reviewed by another principal or officer of the Firm). The
personal trading reviews ensure that the personal trading of employees does not affect the markets, and that
clients of the firm receive preferential treatment.
Item 12: Brokerage Practices
Brokerage Selection and Soft Dollars
The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid
without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified
custodians and for trade execution.
In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible
but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest
available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the
client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the
broker which are included in the commission rate. It is the policy and practice of the Advisor to strive for the
best price and execution for costs and discounts which are competitive in relation to the value of the
transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended.
Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount
of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e),
and the Advisor makes no warranty or representation regarding compensation paid on transactions. In
negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation
of brokerage firms and the brokerage and research services provided by such brokers, although the client may
not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The
Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio
securities.
Order Aggregation
The nature of the clients and/or trading activity on behalf of client accounts are such that trade aggregation
does not garner any client benefit (in regards to mutual fund or exchange traded funds for example).
Directing Brokerage for Client Referrals
The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as
consideration for selecting or recommending brokers for client accounts.
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Form ADV Part 2A
Item 13: Review of Accounts
Periodic Reviews
Account reviews are performed periodically by the Advisor representatives. They are instructed to consider
the client's current security positions and the likelihood that the performance of each security will contribute
to the investment objectives of the client.
Review Triggers
Accounts are reviewed at least bi-annually or more frequently when market conditions dictate. Other
conditions that may trigger a review are changes in the tax laws, new investment information, and changes in
a client's financial or personal situation.
Regular Reports
Clients receive statements of account positions no less than quarterly from the custodian of the account. In
addition, the Advisor provides quarterly performance reports to wealth management clients that access their
online portal.
Item 14: Client Referrals and Other Compensation
Incoming Client Referrals
The Advisor makes cash payments to the introducing broker-dealer, investment Advisory firm or qualified
solicitor for client referrals provided that each such solicitor will provide all prospective clients with a copy
of the Advisor's Form ADV Part 2 and a separate written disclosure document which fully informs the client
regarding the nature of the relationship between the solicitor and the Advisor and any fees to be paid
thereunder. With this option, the Advisor does not have discretion to determine, without obtaining specific
client consent, the securities to be bought or sold as well as the amount of securities to be bought or sold but
the Advisor may still direct the selection of an independent custodian and the placement of all mutual fund
transactions. In exchange for each referral, the Advisor may pay a referral fee to the solicitor. Such fees are
negotiable at the discretion of the Advisor and paid on a quarterly basis after collection from the Advisor.
Collection times can vary anywhere from 1-3 months after quarter end. The Advisor will only recognize this
option when the client has submitted to the Advisor a signed copy of the solicitor's separate written disclosure.
The Advisor’s use of a solicitor does not increase the management fee paid by any client.
Item 15: Custody
Custody Policy
The Advisor does not accept or permit the Firm or its associated persons from acting as trustee, provide bill
paying service, have password access to control account activity or any other form of controlling client assets.
All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian
and transferred to the custodian by the end of the next business day.
In certain cases, and at the client’s request, the Advisor allows the use of a standing letters of authorization
(“SLOA”) that permits, with certain limitations the third-party transfer of money between their accounts.
Based on the No-Action Letter submitted by the Investment Adviser Association dated February 21, 2017,
the SEC indicates that an adviser generally has custody where a client grants the adviser power in a
standing letter of authorization (“SLOA”) to conduct third party transfers. The No-Action Letter further
states that an Adviser is exempt from the annual surprise audit requirement if it complies with the seven
stated conditions of the letter that are intended to protect client assets in such situations. The Advisor meets
the seven conditions the SEC has set forth and is therefore not subject to an annual surprise audit.
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Form ADV Part 2A
Account Statements
All assets are held at qualified custodians and the custodians provide account statements not less than
quarterly to clients at their address of record. Clients should carefully review such statements for any
discrepancies or inaccuracies.
Performance Reports
Utilizing the Orion Report Builder platform, the Advisor provides quarterly performance reports for most
wealth management clients that access their online portal. All performance reports are based on security
valuations provided directly from Qualified Custodians.
Item 16: Discretionary Authority for Trading
Wealth Management Clients:
The Advisor receives discretionary authority from the client to select the securities to be bought or sold as
well as the brokerage firms that will execute the trades (with transaction fees), without obtaining consent from
the client before transactions take place. In all cases, however, such discretion is to be exercised in a manner
consistent with the stated investment objectives for the particular client account. Discretionary authority is
conveyed to the Advisor at the outset of an advisory relationship by the client’s execution of; (1) a brokerage
application with the selected third-party custodian, and (2) a formal investment management agreement with
the Adviser.
The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the
custodian on any trades.
Retirement Plan Clients:
The Advisor has designed and manages six model portfolios for use by its retirement plan clients. Advisor
has discretion over the models and can make changes to the underlying funds and allocation percentages
without obtaining consent from the client.
The client retains discretion to select the custodian to be used. The Advisor does not receive any portion of
the transaction fees or commissions paid by the client to the custodian for any trades.
Item 17: Voting Client Securities
Proxy Votes
The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The
client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give
any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions
of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps
the authority and responsibility for the voting of any proxies for securities held in plan accounts. Also, the
Advisor cannot give any advice or take action with respect to the voting of these proxies. The Advisor
promptly passes along any proxy voting information to the clients or their representatives.
Item 18: Financial Information
Financial Condition
The Advisor does not have any financial impairment that will preclude the firm from meeting contractual
commitments to clients and the Advisor meets all net capital requirements that it may be subject to. The
Advisor has not been the subject of a bankruptcy petition in the last 10 years.
The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or
securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in
advance.
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Form ADV Part 2A
Business Continuity Plan
General
The Advisor has a Business Continuity Plan in place that provides detailed steps to mitigate and recover from
the loss of office space, communications, services or key people.
Disasters
The Business Continuity Plan covers natural disasters such as earthquakes, snow storms, hurricanes, tornados,
and flooding. The Plan covers man-made disasters such as loss of electrical power, loss of water pressure,
fire, bomb threat, nuclear emergency, chemical event, biological event, T-1-communications line outage,
Internet outage, railway accident and aircraft accident. Electronic files are backed up daily and archived
offsite.
Alternate Offices
Alternate offices are identified to support ongoing operations in the event the main office is unavailable. It
is our intention to contact all clients within five days of a disaster that dictates moving our office to an alternate
location.
Summary of Business Continuity Plan
A summary of the business continuity plan is available on the Advisor’s website or upon request to the
Advisor’s Chief Compliance Officer.
Information Security Program
Information Security
The Advisor maintains an information security program to reduce the risk that your personal and confidential
information may be breached.
Privacy Practices
Below is a summary of the Advisor’s Privacy Policy regarding client personal information. A complete
version of the Privacy Policy is contained in your client Advisory agreement and may be obtained by
contacting the Compliance Officer of the Advisor.
Statherόs Financial Solutions, Inc.:
1. Collects non-public personal information about its clients from the following sources:
a. Information received from clients on applications or other forms;
b. Information about clients’ transactions with the Advisor, its affiliates and others;
c. Information received from our correspondent clearing broker with respect to client accounts;
d. Medical information submitted as part of an insurance application for a traditional life or
variable life policy; and
e. Information received from service bureaus or other third parties.
2. The Advisor will not share such information with any affiliated or nonaffiliated third party except:
a. When necessary to complete a transaction in a customer account, such as with the clearing
firm or account custodians;
b. When required to maintain or service a customer account;
c. To resolve customer disputes or inquiries;
d. With persons acting in a fiduciary or representative capacity on behalf of the customer;
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Form ADV Part 2A
e. With rating agencies, persons assessing compliance with industry standards, or to the
attorneys, accountants and auditors of the firm;
In connection with a sale or merger of the Advisor’s business;
f.
g. To protect against or prevent actual or potential fraud, identity theft, unauthorized
transactions, claims or other liability;
h. To comply with federal, state or local laws, rules and other applicable legal requirements;
i.
j.
In connection with a written agreement to provide investment management or advisory
services when the information is released for the sole purpose of providing the products or
services covered by the agreement;
In any circumstances with the customer’s instruction or consent.
3. Restricts access to confidential client information to individuals who are authorized to have access to
confidential client information and need to know that information to provide services to clients.
4. Maintains physical, electronic and procedural security measures that comply with applicable state
and federal regulations to safeguard confidential client information.
19
Additional Brochure: FORM ADV TAMP - STATHEROS FINANCIAL SOLUTIONS INC. (2026-03-20)
View Document Text
Statherόs Financial Solutions, Inc.
2026
Form ADV Part 2A
Firm Brochure
(Part 2A of Form ADV)
Statherόs Financial Solutions, Inc.
1107 Investment Blvd., Ste. 135
El Dorado Hills CA 95762
2107 N 1st Street, Ste. 415
San Jose CA 95131
Phone: (916) 932-1219
Phone: (408) 871-1590
Fax: (866) 294-7650
Fax: (866) 294-7650
WEBSITE: WWW.STATHEROSFINANCIAL.COM
EMAIL: kelly@statherosfinancial.com
This brochure provides information about the qualifications and business practices of Statherόs
Financial Solutions, Inc. If you have any questions about the contents of this brochure, please
contact us at: (916) 932-1219, or by email at: compliance@statherosfinancial.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 Statherόs Financial Solutions, Inc. is available on the SEC’s website
at www.adviserinfo.sec.gov
March 2026
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Statherόs Financial Solutions, Inc.
2026
Form ADV Part 2A
Item 2: Material Changes
Annual Update
This is the firm’s amended Form ADV filing, but the Material Changes section of this brochure will be
updated annually when material changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
None since last update
Full Brochure Available
Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by telephone
at: (916) 932-1219 or by email at: clientsvcs@statherosfinancial.com
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Statherόs Financial Solutions, Inc.
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Form ADV Part 2A
Item 3: Table of Contents
ITEM 2: MATERIAL CHANGES ......................................................................................................................... 2
ANNUAL UPDATE ......................................................................................................................................................... 2
MATERIAL CHANGES SINCE THE LAST UPDATE ............................................................................................................ 2
FULL BROCHURE AVAILABLE ....................................................................................................................................... 2
ITEM 3: TABLE OF CONTENTS ........................................................................................................................ 3
ITEM 4: ADVISORY BUSINESS ........................................................................................................................... 5
FIRM DESCRIPTION ....................................................................................................................................................... 5
Principal Owners .................................................................................................................................................... 5
TYPES OF ADVISORY SERVICES .................................................................................................................................... 5
RETIREMENT PLAN SERVICES AGREEMENT .................................................................................................................. 6
ASSET MANAGEMENT .................................................................................................................................................. 6
TERMINATION OF AGREEMENT ..................................................................................................................................... 6
ITEM 5: FEES AND COMPENSATION .............................................................................................................. 7
FULL-SERVICE ADMINISTRATIVE SERVICES ................................................................................................................. 7
RETIREMENT PLAN ADVISORY SERVICES ..................................................................................................................... 7
OTHER FEES ................................................................................................................................................................. 8
FEE BILLING ................................................................................................................................................................. 8
ITEM 6: PERFORMANCE FEES ......................................................................................................................... 9
CONFLICT OF INTEREST BETWEEN DIFFERENT FEE STRUCTURES ................................................................................. 9
ITEM 7: TYPES OF CLIENTS ............................................................................................................................. 9
DESCRIPTION ................................................................................................................................................................ 9
ACCOUNT MINIMUMS ................................................................................................................................................... 9
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ........................... 9
METHODS OF ANALYSIS ............................................................................................................................................... 9
INVESTMENT STRATEGIES ............................................................................................................................................ 9
MARKET, SECURITY AND REGULATORY RISKS............................................................................................................. 9
Market Risks: ......................................................................................................................................................... 9
Regulatory Risks: ................................................................................................................................................. 11
Security Specific Risks: ........................................................................................................................................ 12
ITEM 9: DISCIPLINARY INFORMATION ...................................................................................................... 12
LEGAL AND DISCIPLINARY ......................................................................................................................................... 12
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ........................................ 12
AFFILIATIONS ............................................................................................................................................................. 12
ITEM 11: CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL
TRADING ............................................................................................................................................................. 13
CODE OF ETHICS ......................................................................................................................................................... 13
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS ........................................................................................... 13
PERSONAL TRADING ................................................................................................................................................... 13
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Form ADV Part 2A
ITEM 12: BROKERAGE PRACTICES .............................................................................................................. 13
BROKERAGE SELECTION AND SOFT DOLLARS ............................................................................................................ 13
ORDER AGGREGATION ............................................................................................................................................... 14
DIRECTING BROKERAGE FOR CLIENT REFERRALS ...................................................................................................... 14
ITEM 13: REVIEW OF ACCOUNTS ................................................................................................................. 14
PERIODIC REVIEWS ..................................................................................................................................................... 14
REVIEW TRIGGERS...................................................................................................................................................... 14
REGULAR REPORTS .................................................................................................................................................... 14
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ............................................................... 14
INCOMING CLIENT REFERRALS ................................................................................................................................... 14
ITEM 15: CUSTODY ........................................................................................................................................... 14
CUSTODY POLICY ....................................................................................................................................................... 14
ACCOUNT STATEMENTS ............................................................................................................................................. 15
PERFORMANCE REPORTS ............................................................................................................................................ 15
ITEM 16: DISCRETIONARY AUTHORITY FOR TRADING ......................................................................... 15
WEALTH MANAGEMENT CLIENTS: ............................................................................................................................. 15
RETIREMENT PLAN CLIENTS: ...................................................................................................................................... 15
ITEM 17: VOTING CLIENT SECURITIES....................................................................................................... 15
PROXY VOTES ............................................................................................................................................................ 15
ITEM 18: FINANCIAL INFORMATION ........................................................................................................... 16
FINANCIAL CONDITION ............................................................................................................................................... 16
BUSINESS CONTINUITY PLAN ........................................................................................................................ 16
GENERAL .................................................................................................................................................................... 16
DISASTERS .................................................................................................................................................................. 16
ALTERNATE OFFICES .................................................................................................................................................. 16
SUMMARY OF BUSINESS CONTINUITY PLAN ............................................................................................................... 16
INFORMATION SECURITY PROGRAM .......................................................................................................... 16
INFORMATION SECURITY ............................................................................................................................................ 16
PRIVACY PRACTICES .................................................................................................................................................. 16
4
Statherόs Financial Solutions, Inc.
2026
Form ADV Part 2A
Item 4: Advisory Business
Firm Description
Statherόs Financial Solutions, Inc., (“the Advisor”) was founded in 2019 and is an SEC registered investment
advisor.
Statherόs Financial Solutions, Inc. is succeeding to the business of a registered investment adviser due to a
change in the ownership structure of our predecessor investment advisory firm, PGR Solutions, LLC.
The Advisor provides personalized investment management and financial planning to individuals, pension
and profit-sharing plans, trusts, estates, charitable organizations and small businesses. Advice is provided
through consultation with the client and may 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. In additions to investment management the
Advisor provides administrative and portfolio support services to other third-party investment managers
and/or registered representatives of broker dealers and also provides retirement plan advisory and consulting
services to qualified retirement plan sponsors.
The Advisor is a fee-only investment management firm and does not sell securities on a commission basis.
However, there may be some associated persons who are in other fields where they receive commissions as
compensation. In addition, some associates may serve at the pleasure of their client as a trustee, board
member, or in a similar capacity. All such relationships are fully disclosed and subject to the review of
management.
The firm is not affiliated with entities that sell financial products or securities.
Investment advice is provided, with the client making the final decision on investment selection. The Advisor
does not act as a custodian of client assets and the client always maintains asset control.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on
an as-needed basis. Any conflicts of interest arising out of the Advisor or its associated persons are disclosed
in this brochure.
Principal Owners
Jake Parsons 88% stockholder, Kelly Roemers 10% stockholder, other 2% stockholder
Types of Advisory Services
The Advisor provides investment supervisory services, also known as asset management services and
manages investment Advisory accounts not involving investment supervisory services. On more than an
occasional basis, the Advisor furnishes advice to clients on matters not involving securities, such as financial
planning matters, investment management administration, retirement plan consulting and administrative
services and actuarial services. The Advisor does not offer wrap fee programs.
As of December 31, 2025, Statherόs Financial Solutions, Inc. manages approximately $926,170,170 in
discretionary assets for approximately 617 households.
Types of Agreements
The following agreements define the typical client relationships. Agreements may not be assigned without
client consent.
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Statherόs Financial Solutions, Inc.
2026
Form ADV Part 2A
Retirement Plan Services Agreement
The Advisor provides retirement plan advisory services to qualified retirement plan sponsors. These
Advisory services generally include employee education and enrollment meetings and investment
management and discretionary advisory services to the Plan Sponsor and/or its employees in accordance with
the Plans’ Investment Policy Statements. Additional services include but are not limited to file maintenance,
and access to model allocations.
Asset Management
Assets are invested primarily in no-load or low-load mutual funds and exchange traded funds (“ETFs"),
usually through Qualified Custodians (“Custodians”) and/or fund companies. Fund companies charge each
fund shareholder an investment management fee that is disclosed in the fund prospectus. Custodians may
charge a transaction fee for the purchase of some funds.
Stocks and bonds transferred to Advisor will be sold through a brokerage account as needed, usually as an
accommodation or when transacting legacy securities. The brokerage firm charges a fee for stock and bond
trades.
The Advisor does not receive any compensation, in any form, from fund companies.
Initial public offerings (IPOs) are not available through the Advisor.
Termination of Agreement
The client may terminate immediately Advisor's investment management services within five (5) days of
signing the agreement and will not be charged a fee provided no assets have transferred to the account. After
then, the investment management agreement may be terminated at any time by mutual consent of the parties,
or without such consent, by either party giving to the other party written notice of termination concurrent with
or in advance of the termination date. If the agreement is terminated, client will only be charged a pro-rated
fee up through the date assets are transferred out of the account managed by Advisor.
The third-party investment management services may be terminated by either party with written or verbal
notice concurrent with or in advance of the effective termination date. Prepaid investment management fees,
if any, will be returned to the third party.
The retirement plan consulting and administrative services may be terminated by either party with written
notice 30 days prior to the effective termination date.
The Advisor reserves the right to stop work on any account that is more than 30 days overdue. In addition,
the Advisor 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 the Advisor’s judgment, to providing proper financial advice.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement
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Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way we make money creates some conflicts with your interests, so we
operate under a special rule that requires us to act in your best interest and not put our interest
ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give
prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Item 5: Fees and Compensation
Full-Service Administrative Services
Statherόs offers Full-Service Administration services to third party unaffiliated investment advisors and
broker-dealers. The firms that utilize Administration services receive access to model portfolios managed by
Advisor as well as administrative support as a solution to their back-office and trading needs. These services
may have been offered in the past under other names but the fees did not exceed those shown below.
The benefit to the firms is that it allows them to focus their efforts on building their business and servicing
clients. The firms’ clients sign Advisor’s administrative service agreement but are not considered clients of
Advisor for purposes of calculating AUM unless clients invest in the Advisor’s managed model portfolios.
For accounts opened through the Full-Service Administration program, Advisor collects the administrative
service fees as follows:
Annualized Full-Service Administrative Services Fees
Account Value From
Account Value To
Annual Percentage Fee
$0
$499,999
Not to Exceed 0.38%
The next $500,000
$999,999
Not to Exceed 0.36%
Over $1,000,000
Not to Exceed 0.26%
These fees are tiered in that the stated fee is applied to each portion of the client’s average daily balance. The
above annual fees are charged quarterly in arrears. The Advisor at its sole discretion may elect to charge a
fee different from the above schedule or waive the fee entirely. The Advisor does not make any representation
that these services are at the lowest cost available and the third-party advisors and their clients may be able
to obtain those services at a more favorable rate from other providers. Any prepaid administrative fees will
be returned to the third party.
Retirement Plan Advisory Services
Advisory Fees for Retirement Plan accounts are payable quarterly in arrears and are calculated based on the
account balance on the last day of each quarter. The maximum percentage annual fee charged on each tier is
based on the following schedule:
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Annualized Retirement Plan Advisory Fees
Account Value From
$0
Account Value To
$999,999
$2,499,999
$4,999,999
$9,999,999
$19,999,999
The next $1,000,000
The next $2,500,000
The next $5,000,000
The next $10,000,000
Amounts over $20,000,000
Annual Percentage Fee
Not to Exceed 0.80%
(minimum annual fee $1000)
Not to Exceed 0.65%
Not to Exceed 0.50%
Not to Exceed 0.35%
Not to Exceed 0.25%
Not to Exceed 0.10%
These fees are tiered in that the stated fee is applied to each portion of the client’s average daily balance.
The above annual fees are charged quarterly in arrears.
Additional fees for ancillary services on Retirement Plans may be charged on an hourly basis at a rate between
$100 and $300 per hour and will be quoted in advance of the work. Examples of ancillary services include,
but are not limited to, IRS/Department of Labor audit support or specialized plan consulting.
When evaluating these services, the client should consider the total annual cost of asset-based Advisory fees
when comparing services elsewhere. The Advisor does not make any representation that these services are
at the lowest cost available and the third-party advisors and their clients may be able to obtain those services
at a more favorable rate from other providers.
Other Fees
In addition to the management fee paid to the Advisor, clients may be charged for the services by the
providers/managers of investment products. The Advisor, from time to time, may select or recommend
investments with fees that are separately charged by the product providers and are separate and distinct from
the management fee charged by the Advisor. These fees will generally include a management fee, other fund
expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios
so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected,
a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity
or investment partnership directly, without the services of the Advisor. Accordingly, the client should review
both the fees charged by the funds and the applicable program fee charged by the Advisor to fully understand
the total amount of fees to be paid by the client.
Investment Advisory clients are required to use a custodian recommended by the Advisor. The fees charged
by the custodian are provided to clients prior to signing an agreement and are in addition to fees charged by
Advisor. The Advisor does not make any representation that these products and services are offered at the
lowest available cost and the client may be able to obtain the same products or services at a lower cost from
other providers.
Fee Billing
Investment management fees are billed quarterly, in arrears meaning that we invoice you after the three-
month billing period has ended. The billing, or Fee Statement, is either included in the statement sent to you
directly from the custodian or plan recordkeeper or is made available separately by Advisor through an online
portal depending on the type of service received. Payment in full is expected upon invoice presentation. Fees
are deducted from the client account to facilitate billing as authorized by the investment management
agreement.
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Item 6: Performance Fees
Fees are not based on a share of the capital gains or capital appreciation of managed securities. The Advisor
does not use a performance-based fee structure.
Conflict of Interest Between Different Fee Structures
The Advisor offers several different services detailed in this brochure that compensate the Advisor differently
depending on the service selected. There is a conflict of interest for the Advisor and its associated personnel
to recommend the services that offer a higher level of compensation to the Firm through either higher
management fees or reduced administrative expenses. The Advisor mitigates this conflict through its
procedures to review client accounts relative to the client or investors personal financial situation to ensure
the investment management service provided is appropriate. Further, the Advisor is committed to its
obligation to ensure associated persons adhere to the Firm’s Code of Ethics and to ensure that the Firm and
its associated persons fulfill their fiduciary duty to clients or investors.
Item 7: Types of Clients
Description
The Advisor generally provides services to individuals, pension and profit-sharing plans, trusts, estates, or
charitable organizations and corporations, and business entities. Client relationships vary in scope and length
of service.
Account Minimums
The Advisor generally prefers a $40,000 minimum investment to open an account. Advisor may accept a
smaller amount at its sole discretion.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods may include fundamental analysis and cyclical analysis. The main sources of
information include financial newspapers and magazines, research materials prepared by others, corporate
rating services, annual reports, prospectuses and filings with the Securities and Exchange Commission.
The Advisor also makes use of a proprietary technology in the allocation of assets within a client’s account
called Portfolio Builder. Portfolio Builder includes six (6) basic allocations that are tailored to differing levels
of financial need and risk tolerance. Investment Advisor Representatives may select one of those six (6)
model allocations or further modify the allocation based on the specific needs of each client. Portfolio Builder
also reflects suggested mutual funds to fill the client allocations and provides modeled historical performance
information based on the client’s specific allocation.
Investment Strategies
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. Each client provides risk tolerance and suitability information to
their Advisor representative that documents their objectives and their desired investment strategy. The
Advisor’s strategies do not involve frequent trading. The Advisor generally uses a long-term purchases
strategy meaning securities held at least a year.
Market, Security and Regulatory Risks
Any investment with the Advisor involves significant risk, including a complete loss of capital and conflicts
of interest. All investment programs have certain risks that are borne by the investor which are described
below:
Market Risks:
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Competition: The securities industry and the varied strategies and techniques to be engaged in by the Advisor
are extremely competitive and each involves a degree of risk. The Advisor will compete with firms, including
many of the larger securities and investment banking firms, which have substantially greater financial resources
and research staffs.
Market Volatility: The profitability of the Advisor substantially depends upon it correctly assessing the future
price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates.
The Advisor cannot guarantee that it will be successful in accurately predicting price and interest rate
movements.
Statherόs Financial Solutions, Inc.’s Investment Activities: The Advisors’ investment activities involve a
significant degree of risk. The performance of any investment is subject to numerous factors which are neither
within the control of nor predictable by the Advisor. Such factors include a wide range of economic, political,
competitive, technological and other conditions (including acts of terrorism and war) that may affect
investments in general or specific industries or companies. The securities markets may be volatile, which may
adversely affect the ability of the Advisor to realize profits. Additionally, specific investments under the
Advisors’ strategy may require significant time to realize the expected return and may experience a pricing
correction in a faster-than-expected time, subjecting the Advisor to reinvestment risk. Likewise, the investment
strategy of the Advisor is partially dependent on its ability to correctly identify and assess technology’s impact
on a company’s business. As a result of the nature of the Advisors’ investing activities, it is possible that its
financial performance may fluctuate substantially over time and from period to period.
Material Non-Public Information: By reason of their responsibilities in connection with other activities of
the advisor and/or its affiliates, certain principals or employees of the Advisor and/or its affiliates may acquire
confidential or material non-public information or be restricted from initiating transactions in certain securities.
The Advisor will not be free to act upon any such information. Due to these restrictions, the Advisor may not
be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment
that it otherwise might have sold.
Accuracy of Public Information: The Advisor selects investments, in part, on the basis of information and
data filed by issuers with various government regulators or made directly available to the Advisor by the issuers
or through sources other than the issuers. Although the Advisor evaluates all such information and data and
sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the
Advisor is not in a position to confirm the completeness, genuineness or accuracy of such information and data,
and in some cases, complete and accurate information is not available. Investments may not perform as expected
if information is inaccurate.
Volatility of Currency Prices: The profitability of the Advisors’ portfolios depends, in part, upon the Advisor
correctly assessing the future price movements of currencies. However, price movements of currencies are
difficult to predict accurately because they are influenced by, among other things, changing supply and demand
relationships; governmental, trade, fiscal, monetary and exchange control programs and policies; national and
international political and economic events; and changes in interest rates. Governments from time to time
intervene in certain markets in order to influence prices directly. The Advisor cannot guarantee that it will be
successful in accurately predicting currency price and interest rate movements.
Market or Interest Rate Risk: The price of most fixed income securities moves in the opposite direction of
the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the
Advisor holds a fixed income security to maturity, the change in its price before maturity may have little impact
on the Advisor’s performance; however, if the Advisor has to sell the fixed income security before the maturity
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date, an increase in interest rates could result in a loss to the Advisor.
Investments in Non-U.S. Investments: From time to time, the Advisor may invest and trade a portion of its
assets in non-U.S. securities and other assets (through mutual funds of foreign securities and otherwise), which
will give rise to risks relating to political, social and economic developments abroad, as well as risks resulting
from the differences between the regulations to which U.S. and foreign issuers and markets are subject. Such
risks may include:
• Political or social instability, the seizure by foreign governments of company assets, acts of war or
terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, and limitations
on the use or transfer of portfolio assets.
• Enforcing legal rights in some foreign countries is difficult, costly and slow, and there are sometimes
special problems enforcing claims against foreign governments.
• Foreign securities and other assets often trade in currencies other than the U.S. dollar, and the Advisor
may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange
contracts. Changes in currency exchange rates will affect the Advisor’s net asset value, the value of
dividends and interest earned, and gains and losses realized on the sale of investments. An increase in
the strength of the U.S. dollar relative to these other currencies may cause the value of the Advisor’s
investments to decline. Some foreign currencies are particularly volatile. Foreign governments may
intervene in the currency markets, causing a decline in value or liquidity of the Advisor’s foreign
currency holdings. If the Advisor enters into forward foreign currency exchange contracts for hedging
purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if the
Advisor enters forward contracts for the purpose of increasing return, it may sustain losses.
• Non-U.S. securities, commodities and other markets may be less liquid, more volatile and less closely
supervised by the government than in the United States. Foreign countries often lack uniform
accounting, auditing and financial reporting standards, and there may be less public information about
the operations of issuers in such markets.
Risk of Default or Bankruptcy of Third Parties: The Advisor may engage in transactions in securities,
commodities, other financial instruments and other assets that involve counterparties. Under certain conditions,
the Advisor could suffer losses if counterparty to a transaction were to default or if the market for certain
securities, commodities, other financial instruments and/or other assets were to become illiquid. In addition, the
Advisor could suffer losses if there were a default or bankruptcy by certain other third parties, including
brokerage firms and banks with which the Advisor does business, or to which securities, commodities, other
financial instruments and/or other assets have been entrusted for custodial purposes. For example, if the
Advisor’s prime broker and custodian were to become insolvent or file for bankruptcy, the Advisor could suffer
firm.
significant
losses
with
respect
to
any
securities
held
by
such
Regulatory Risks:
Strategy Restrictions: Certain institutions may be restricted from directly utilizing investment strategies of the
type in which the Advisor may engage. Such institutions, including entities subject to ERISA, should consult
their own Advisors, counsel and accountants to determine what restrictions may apply and whether an
investment in the Advisor is appropriate.
Trading Limitations: For all securities, instruments and/or assets listed on an exchange, including options
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listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain
circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and
subject the Advisor to loss. Also, such a suspension could render it impossible for the Advisor to liquidate
positions and thereby expose the Advisor to potential losses.
Tax Risk: The tax aspects of an investment in the Advisor are complicated and each investor should have them
reviewed by professional advisors familiar with such investor’s personal tax situation and with the tax laws and
regulations applicable to the investor and private investment vehicles as applicable.
Conflicts of Interest: In the administration of client accounts, portfolios and financial reporting, the Advisor
faces inherent conflicts of interest which are described in this brochure. Generally, the Advisor mitigates
these conflicts through its Code of Ethics which provides that the client’s interest is always held above that
of the Firm and its associated persons.
Supervision of Trading Operations: The Advisor’s, with assistance from its brokerage and clearing firms,
intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and
client objectives. Despite the Advisor’s efforts, however, there is a risk that unauthorized or otherwise
inappropriate trading activity may occur in portfolio accounts.
Security Specific Risks:
Depending on the nature of the investment management service selected by a client and the securities used to
implement the investment strategy, clients will be exposed to risks that are specific to the securities in their
particular investment portfolio.
Currency: 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
Limited Liquidity of Interests: An investment in a partnership usually involves substantial restrictions on
liquidity and its interests are not freely transferable. There is no market for the interests the Advisor and no
market should be expected to develop. Additionally, transfers are usually subject to the consent of the general
partner at the general partner’s sole discretion.
Item 9: Disciplinary Information
Legal and Disciplinary
The firm and its employees have not been involved in legal or disciplinary events related to past or present
investment clients.
Item 10: Other Financial Industry Activities and Affiliations
Affiliations
The Advisor has material relationships with certain broker dealers and investment advisors that use the
Advisor’s administrative investment management services to augment their own investment management
services as previously described under Full-Service Administrative Services and Retirement Plan Advisory
Services
The Advisor's associates are CPAs and licensed real estate agents/brokers. Client’s use of the accountancy
services or real estate services of investment advisor representatives is not required and the Advisor does not
represent these services are available at the lowest cost. A conflict of interest exists in that the associates will
devote time to these other business activities as needed which are separate and distinct from the Advisor’s
investment management services. However, this conflict is mitigated by the Advisor ensuring that it and its
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associated persons fulfill the fiduciary responsibility to the client and that at no time are the clients
compromised by the outside activities.
Item 11: Code of Ethics, Participation in Client Transactions and Personal Trading
Code of Ethics
The Advisor has adopted a Code of Ethics which establishes standards of conduct for its supervised persons.
The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary
obligations to clients and applicable securities laws, and specific requirements relating to, among other things,
personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires
supervised persons to report their personal securities transactions and holdings quarterly to the Advisor’s
Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised
persons to report any violations of the Code of Ethics promptly to the Advisor’s Compliance Officer. Each
supervised person of the Advisor receives a copy of the Code of Ethics and any amendments to it and must
acknowledge in writing having received the materials. Annually, each supervised person must certify that he
or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy
of the Advisor’s Code of Ethics by contacting the Compliance Officer of the Advisor.
Participation or Interest in Client Transactions
Under the Advisor’s Code of Ethics, the Advisor and its managers, members, officers and employees may
invest personally in securities of the same classes as are purchased for clients and may own securities of the
issuers whose securities are subsequently purchased for clients. Given that the Advisor almost exclusively
only purchases mutual funds for client portfolios, it is an uncommon occurrence for individual securities to
be purchased for client portfolios. However, if an issue is purchased or sold for clients and any of the Advisor,
managers, members, officers and employees on the same day purchase or sell the same security, either the
clients and the Advisor, managers, members, officers or employees shall receive or pay the same price or the
clients shall receive a more favorable price. The Advisor and its managers, members, officers and employee
may also buy or sell specific securities for their own accounts based on personal investment considerations,
which the Advisor does not deem appropriate to buy or sell for clients.
Personal Trading
The Chief Compliance Officer of The Advisor is Kelly Roemers. She reviews all employee trades each
quarter (except for her own trading activity that is reviewed by another principal or officer of the Firm). The
personal trading reviews ensure that the personal trading of employees does not affect the markets, and that
clients of the firm receive preferential treatment.
Item 12: Brokerage Practices
Brokerage Selection and Soft Dollars
The Advisor has the authority over the selection of the broker to be used and the commission rates to be paid
without obtaining specific client consent. The Advisor may recommend brokerage firms as qualified
custodians and for trade execution.
In selecting brokers or dealers to execute transactions, Advisor will seek to achieve the best execution possible
but this does not require it to solicit competitive bids and does not have an obligation to seek the lowest
available commission cost. Advisor is not required to negotiate "execution only" commission rates, thus the
client may be deemed to be paying for research and related services (i.e., "soft dollars") provided by the
broker which are included in the commission rate. It is the policy and practice of the Advisor to strive for the
best price and execution for costs and discounts which are competitive in relation to the value of the
transaction and which comply with Section 28(e) of the Securities Exchange Act of 1934, as amended.
Nevertheless, it is understood that the Advisor may pay compensation on a transaction in excess of the amount
of compensation that another broker or dealer may charge so long as it is in compliance with Section 28(e),
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and the Advisor makes no warranty or representation regarding compensation paid on transactions. In
negotiating mark-ups or mark-downs, the Advisor will take into account the financial stability and reputation
of brokerage firms and the brokerage and research services provided by such brokers, although the client may
not, in any particular instance, be the sole direct or indirect beneficiary of the research services provided. The
Advisor has no obligation to deal with any broker or group of brokers in executing transactions in portfolio
securities.
Order Aggregation
The nature of the clients and/or trading activity on behalf of client accounts are such that trade aggregation
does not garner any client benefit (in regards to mutual fund or exchange traded funds for example).
Directing Brokerage for Client Referrals
The Advisor and its associated persons do not receive client referrals from broker dealers or third parties as
consideration for selecting or recommending brokers for client accounts.
Item 13: Review of Accounts
Periodic Reviews
Account reviews are performed periodically by the Advisor representatives. They are instructed to consider
the client's current security positions and the likelihood that the performance of each security will contribute
to the investment objectives of the client.
Review Triggers
Accounts are reviewed at least bi-annually or more frequently when market conditions dictate. Other
conditions that may trigger a review are changes in the tax laws, new investment information, and changes in
a client's financial or personal situation.
Regular Reports
Clients receive statements of account positions no less than quarterly from the custodian of the account. In
addition, the Advisor provides quarterly performance reports to wealth management clients that access their
online portal.
Item 14: Client Referrals and Other Compensation
Incoming Client Referrals
The Advisor engages independent solicitors to provide client referrals. If a client is referred to us by a solicitor,
this practice is disclosed to the client in writing by the solicitor and the Advisor pays the solicitor out of its
own funds—specifically, the Advisor generally pays the solicitor a portion of the advisory fees earned for
managing the capital of the client or investor that was referred. The use of solicitors is strictly regulated under
applicable federal and state law. The Advisor’s policy is to fully comply with the requirements of Rule 206(4)-
3, under the Investment Advisers Act of 1940, as amended, and similar state rules, as applicable.
Item 15: Custody
Custody Policy
The Advisor does not accept or permit the Firm or its associated persons from acting as trustee, provide bill
paying service, have password access to control account activity or any other form of controlling client assets.
All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian
and transferred to the custodian by the end of the next business day.
In certain cases, and at the client’s request, the Advisor allows the use of a standing letters of authorization
(“SLOA”) that permits, with certain limitations the third-party transfer of money between their accounts.
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Based on the No-Action Letter submitted by the Investment Adviser Association dated February 21, 2017,
the SEC indicates that an adviser generally has custody where a client grants the adviser power in a standing
letter of authorization (“SLOA”) to conduct third party transfers. The No-Action Letter further states that an
Adviser is exempt from the annual surprise audit requirement if it complies with the seven stated conditions
of the letter that are intended to protect client assets in such situations. The Advisor meets the seven
conditions the SEC has set forth and is therefore not subject to an annual surprise audit.
Account Statements
All assets are held at qualified custodians and the custodians provide account statements not less than
quarterly to clients at their address of record. Clients should carefully review such statements for any
discrepancies or inaccuracies.
Performance Reports
Utilizing the Orion Report Builder platform, the Advisor provides quarterly performance reports for most
wealth management clients that access their online portal. All performance reports are based on security
valuations provided directly from Qualified Custodians.
Item 16: Discretionary Authority for Trading
Wealth Management Clients:
The Advisor receives discretionary authority from the client to select the securities to be bought or sold as
well as the brokerage firms that will execute the trades (with transaction fees), without obtaining consent from
the client before transactions take place. In all cases, however, such discretion is to be exercised in a manner
consistent with the stated investment objectives for the particular client account. Discretionary authority is
conveyed to the Advisor at the outset of an advisory relationship by the client’s execution of; (1) a brokerage
application with the selected third-party custodian, and (2) a formal investment management agreement with
the Adviser.
The Advisor does not receive any portion of the transaction fees or commissions paid by the client to the
custodian on any trades.
Retirement Plan Clients:
The Advisor has designed and manages six model portfolios for use by its retirement plan clients. Advisor
has discretion over the models and can make changes to the underlying funds and allocation percentages
without obtaining consent from the client.
The client retains discretion to select the custodian to be used. The Advisor does not receive any portion of
the transaction fees or commissions paid by the client to the custodian for any trades.
Item 17: Voting Client Securities
Proxy Votes
The Advisor will not vote nor advise clients how to vote proxies for securities held in client accounts. The
client clearly keeps the authority and responsibility for the voting of these proxies. The Advisor does not give
any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions
of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps
the authority and responsibility for the voting of any proxies for securities held in plan accounts. Also, the
Advisor cannot give any advice or take action with respect to the voting of these proxies. The Advisor
promptly passes along any proxy voting information to the clients or their representatives.
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Item 18: Financial Information
Financial Condition
The Advisor does not have any financial impairment that will preclude the firm from meeting contractual
commitments to clients and The Advisor meets all net capital requirements that it may be subject to. The
Advisor has not been the subject of a bankruptcy petition in the last 10 years.
The Advisor is not required to provide a balance sheet as it does not serve as a custodian for client funds or
securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in
advance.
Business Continuity Plan
General
The Advisor has a Business Continuity Plan in place that provides detailed steps to mitigate and recover from
the loss of office space, communications, services or key people.
Disasters
The Business Continuity Plan covers natural disasters such as earthquakes, snow storms, hurricanes, tornados,
and flooding. The Plan covers man-made disasters such as loss of electrical power, loss of water pressure,
fire, bomb threat, nuclear emergency, chemical event, biological event, T-1-communications line outage,
Internet outage, railway accident and aircraft accident. Electronic files are backed up daily and archived
offsite.
Alternate Offices
Alternate offices are identified to support ongoing operations in the event the main office is unavailable. It
is our intention to contact all clients within five days of a disaster that dictates moving our office to an alternate
location.
Summary of Business Continuity Plan
A summary of the business continuity plan is available on the Advisor’s website or upon request to the
Advisor’s Chief Compliance Officer.
Information Security Program
Information Security
The Advisor maintains an information security program to reduce the risk that your personal and confidential
information may be breached.
Privacy Practices
Below is a summary of the Advisor’s Privacy Policy regarding client personal information. A complete
version of the Privacy Policy is contained in your client Advisory agreement and may be obtained by
contacting the Compliance Officer of the Advisor.
Statherόs Financial Solutions, Inc.:
1. Collects non-public personal information about its clients from the following sources:
a. Information received from clients on applications or other forms;
b. Information about clients’ transactions with the Advisor, its affiliates and others;
c. Information received from our correspondent clearing broker with respect to client accounts;
d. Medical information submitted as part of an insurance application for a traditional life or
variable life policy; and
e. Information received from service bureaus or other third parties.
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2. The Advisor will not share such information with any affiliated or nonaffiliated third party except:
a. When necessary to complete a transaction in a customer account, such as with the clearing
firm or account custodians;
b. When required to maintain or service a customer account;
c. To resolve customer disputes or inquiries;
d. With persons acting in a fiduciary or representative capacity on behalf of the customer;
e. With rating agencies, persons assessing compliance with industry standards, or to the
attorneys, accountants and auditors of the firm;
In connection with a sale or merger of the Advisor’s business;
f.
g. To protect against or prevent actual or potential fraud, identity theft, unauthorized
transactions, claims or other liability;
h. To comply with federal, state or local laws, rules and other applicable legal requirements;
i.
j.
In connection with a written agreement to provide investment management or advisory
services when the information is released for the sole purpose of providing the products or
services covered by the agreement;
In any circumstances with the customer’s instruction or consent.
3. Restricts access to confidential client information to individuals who are authorized to have access to
confidential client information and need to know that information to provide services to clients.
4. Maintains physical, electronic and procedural security measures that comply with applicable state
and federal regulations to safeguard confidential client information.
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