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ITEM 1
Cover Page
Form ADV Part 2A
Firm Brochure
July 2, 2025
This Brochure provides
information about the
qualifications and business
practices of Storehouse Financial
LLC. If you have any questions
about the contents of this
Brochure, please contact us at
877-305-3233 or via email at
info@storehousefinancial.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.
Storehouse Financial LLC is a
registered investment advisory
firm. Registration of an
investment advisory firm does
not imply a particular level of skill
or training.
Additional information about
Storehouse Financial LLC is also
available on the SEC’s website at
www.adviserinfo.sec.gov.
Storehouse Financial LLC
IARD#140738
3200 Riverfront Dr., Suite 204
Fort Worth, TX 76107
877-305-3233
info@storehousefinancial.com
www.storehousefinancial.com
ITEM 2 Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material changes occur
since the previous release of our Firm Brochure. This Item discusses only specific material changes made
to this Brochure and provides our clients with a summary of such changes.
Material Changes since the Last Update
Since the last amendment, made on July 9, 2024, we have made the following changes:
• We have updated the risk disclosures in Item 8.
• We have revised item 10 to update that our IARs are not registered representatives.
Full Brochure and Additional Information
Full Brochure and additional information about Storehouse Financial LLC are available via the SEC’s
website www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons
affiliated with us who are registered or are required to be registered as investment adviser
representatives (“IAR”).
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ITEM 3
Table of Contents
ITEM 1
Cover Page .................................................................................................................. 1
ITEM 2
Material Changes ......................................................................................................... 2
ITEM 3
Table of Contents ........................................................................................................ 3
ITEM 4
Advisory Business ........................................................................................................ 4
ITEM 5
Fees and Compensation ............................................................................................... 5
ITEM 6
Performance-Based Fees .............................................................................................. 7
ITEM 7
Types of Clients Description .......................................................................................... 7
ITEM 8
Methods of Analysis, Investment Strategies, and Risk of Loss ........................................... 7
ITEM 9
Disciplinary Information ............................................................................................. 10
ITEM 10 Other Financial Activities and Affiliations ...................................................................... 10
ITEM 11
Code of Ethics, Participation in Client Transactions and Personal Trading ......................... 10
ITEM 12
Brokerage Practices ................................................................................................... 11
ITEM 13
Review of Accounts .................................................................................................... 13
ITEM 14
Client Referrals and Other Compensation ..................................................................... 13
ITEM 15
Custody .................................................................................................................... 14
ITEM 16
Investment Discretion ................................................................................................ 14
ITEM 17
Voting Client Securities .............................................................................................. 15
ITEM 18
Financial Information ................................................................................................. 15
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ITEM 4 Advisory Business
FIRM INFORMATION
Storehouse Financial LLC (“Storehouse,” “we,” “us,” “our”), a limited liability company formed in 2006, is
a registered investment advisory firm located in Fort Worth, Texas.
PRINCIPAL OWNERS
Storehouse is owned and controlled by Stephen Stull and Leigh Ann Stull. Stephen Stull serves as Chief
Compliance Officer.
INVESTMENT ADVISORY SERVICES
Asset Management Services:
We provide asset management services in which investment advisers manage your accounts. Our services
provide additional investment opportunities among mutual funds, stocks, bonds, mutual funds, exchange-
traded funds (ETFs), Real Estate Investment Trusts (REITs), options, and additional securities. Our asset
management services involve providing you with the continuous and ongoing supervision of your
custodial accounts.
Financial Planning and Consulting Services:
We provide financial planning services that find ways to help you understand your overall financial
situation and help you set financial objectives. We accomplish this by helping you review your financial
goals, tax planning strategies, asset allocation, risk management, retirement planning, and other areas
and objectives.
CLIENT INVESTMENT OBJECTIVES/RESTRICTIONS
Storehouse offers the same suite of services to all our clients. However, specific client financial plans and
their implementation are dependent upon the individual client’s Investment Policy Statement, which
outlines a client’s current financial situation such as income, net worth, and risk tolerance levels. This
information is essential in the development of a client-specific plan in the selection of investments that
matches restrictions, needs, and targets. On a case by case basis, our clients may impose restrictions on
investing in certain securities or types of securities in accordance with their values or beliefs. However, if
the restrictions prevent us from properly servicing the client’s account, or if the restrictions would require
us to deviate from our standard suite of services, we reserve the right to end the relationship. We may
request additional information and documentation such as current investments, tax returns, insurance
policies, and estate plan. We will discuss your investment objectives, needs, and goals, but you must
inform us of any changes. Unless directed by you, we do not independently verify any information
provided to us by you or your attorney, accountant, or other professionals.
WRAP FEE PROGRAMS
Storehouse does not participate in, recommend, or offer wrap fee programs.
ASSETS UNDER MANAGEMENT
As of December 31, 2024, Storehouse manages $207,903,023 on a discretionary basis only.
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ITEM 5
Fees and Compensation
ANNUAL FEES FOR ADVISORY SERVICES
Storehouse is compensated for providing Asset Management services by charging an asset management
fee. The asset management fee is based on the total assets under management.
The fees charged for financial planning services are negotiable and vary depending on the complexity of
the process undertaken, the types of issues addressed, the scope of services provided, and the frequency
with which the services are rendered. All fees are agreed upon before entering into the Financial Planning
and Consulting Agreement you sign.
The below ranges are the standard fee ranges that are typically charged. We may waive the agreed-upon
financial planning fees if you engage our asset management services.
Asset Management Fee Schedule
First $0 - $2,000,000
1.5%
Next $2,000,001 - $5,000,000
1.0%
Next $5,000,001+
0.5%
Financial Planning and Consulting Fee Schedule
Hourly
Negotiable
Storehouse may enter into arrangements where performance-based fees are assessed for advisory
services. Performance-based fees are individually negotiated with clients. Adviser’s performance fee
may only be utilized by the following types of clients: (i) A client that is a natural person who or a
company that immediately after entering into an advisory agreement has at least $1,100,000 under the
management of Adviser; (ii) A client that is a natural person who or a company that Adviser reasonably
believes, immediately prior to entering into the advisory agreement, has a net worth (together, in the
case of a natural person, with assets held jointly with a spouse and excluding the value of the clients 5
residence) of more than $2,200,000 at the time the advisory agreement is entered into, or (iii) a client
that is a natural person who does not meet either definition as outlined above but who shall not be
charged a performance fee based on the status of nonqualified or non-accredited.
Performance Based Fees
Management Fee
Performance Allocation
1.00%
50% over 8% hurdle rate
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FEE BILLING & PAYMENT
Advisory fees are invoiced and billed directly to you. Payments are due by the end of the month or quarter.
The fee billing will be pre-determined in writing in the investment advisory agreement that is executed by
you and Storehouse. We will deduct our asset management fee only when in receipt of your written
authorization by executing an investment advisory agreement permitting the fees to be paid directly from
your account. We will send a copy of your invoice to the custodian. The qualified custodian will deliver an
account statement to you at least quarterly, which will show all disbursements from your account. We
urge you to review all statements for accuracy.
Financial planning and consulting fees may be assessed on an hourly basis. Hourly fees will be invoiced
upon completion of the financial plan or the rendering of consulting services with a thirty (30) day written
notice. In no case will Storehouse require a fee of $500 or more to be paid six months or more in advance.
Financial planning and consulting fees are paid via credit card or check.
You are responsible for all third-party fees (i.e., custodian fees, mutual fund fees, transaction fees, etc.).
These fees are separate and distinct from the fees and expenses charged by Storehouse.
TERMINATION OF AGREEMENT
Either party may terminate the investment advisory agreement by providing 30-day advance written
notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any
earned, unpaid fees will be due and payable up to and including the effective date of termination.
Notwithstanding the above, if we do not deliver the appropriate disclosure statement to you at least 48
hours prior to you entering into any written or oral advisory contract with this us, then you have the right
to terminate the contract without penalty within five (5) business days after entering into the contract.
OTHER EXPENSES AND FEES
The fees discussed above include payment solely for our asset management and financial planning
services provided by us and are separate to certain fees or charges that are imposed by third parties in
connection with investments made on your behalf for your account. Third-party fees may include
markdowns, markups, brokerage commissions, other transaction costs, and/or custodial fees.
Also, all fees paid to us for asset management services are separate from the expenses charged by
exchange-traded funds and mutual funds to their shareholders. These fees and expenses will be used to
pay management fees for the funds, other fund expenses, account administration, and a possible
distribution fee. Exchanged traded funds and mutual funds can be invested in directly by you without our
services. However, you would not receive our services to assist you in determining which products or
services are most suitable for your financial situation and objectives. You should review both the fees we
charge and the fees charged by the fund(s) to understand the total fees to be paid fully.
OTHER COMPENSATION
Certain associated persons are also licensed, certified public accountants. In this capacity, the IARs may
recommend accounting and tax preparation services and receive additional compensation in this capacity.
Thus, a conflict of interest exists between the interests of this individual and those of the advisory clients,
creating an incentive to recommend accounting services based on the compensation received rather than
on a client’s needs. However, clients are under no obligation to act upon any of these recommendations.
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Clients have the option to utilized accounting services not affiliated with our firm. Please refer to Item 10
of this Brochure for a more detailed explanation of how our firm handles and mitigates these conflicts of
interest.
ITEM 6
Performance-Based Fees
Our Performance Allocation is a performance-based fee which is a fee based on a share of capital gains
on or capital appreciation of the assets of a client. Our performance-based fee schedule is only available
for those that meet the qualified client definition under federal and state securities rules and regulations.
The specific Performance Allocations are outlined above in Item 5.
The negotiable performance fee shall not exceed 50% of investment returns over a hurdle rate of 8%,
billed quarterly in arrears. For example, if in a given quarter we achieve total returns of 10%, then the
maximum performance fee assessable would be 50% of the 2% excess return over the hurdle rate of 8%.
If in a given year we achieve a total return equal to or less than the 8% hurdle rate, then no performance
fee shall be assessed.
Receiving a performance-based fee creates an incentive for Storehouse to make investments that are
riskier or more speculative than would be the case in the absence of those performance-based
arrangements. Such fee arrangements could also create an incentive to favor higher fee-paying accounts
over other accounts in the allocation of investment opportunities. However, Storehouse has procedures
designed and implemented to ensure that all clients are treated fairly and equally, and to mitigate this
conflict from influencing the allocation of investment opportunities among clients. We do not charge any
fees based on a share of capital gains on or capital appreciation of the assets of a client.
ITEM 7
Types of Clients Description
We provide our investment advisory services to:
- Individuals
- High Net Worth Individuals
- Pension and profit-sharing plans
- Trusts
- Estates or charitable organizations
- Corporations
- Other business entities
We do not have a minimum account size for our asset management services.
ITEM 8 Methods of Analysis, Investment Strategies, and Risk of
Loss
METHODS OF ANALYSIS
We use various methods of analysis and investment strategies, including the following:
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Cyclical Analysis - This is a type of technical analysis that involves evaluating recurring price patterns and
trends based upon business cycles. Economic/business cycles may not be predictable and may have many
fluctuations between long-term expansions and contractions. The lengths of economic cycles may be
difficult to predict with accuracy. Therefore, the risk of cyclical analysis is the difficulty in predicting
economic trends and, consequently, the changing value of securities that would be affected by these
changing trends.
Fundamental Analysis – We evaluate economic and financial factors to determine if a security may be
underpriced, overpriced, or fairly priced. This method entails assessing a security by attempting to
determine its intrinsic value by examining related financial, economic, and other qualitative and
quantitative factors. Fundamental analysis requires an in-depth look at all factors that can affect the
security's value, from macroeconomic factors (like the overall economy and industry conditions) to
individually specific factors (like the financial situation and management of companies). The overall
objective of performing the fundamental analysis is to determine a value that an investor can use to
determine what sort of position to take with that security. This method of security analysis is contrary to
technical analysis. Fundamental analysis involves using real data to evaluate a security's value. Although
most analysts use fundamental analysis to value stocks, this method of valuation can be used for just
about any type of security.
Technical Analysis – This method involves the evaluation of securities by performing an analysis of statical
information that is generated by market activity, such as past prices and volume. Technical analysis does
not attempt to measure a security's intrinsic value but instead use charts and other tools to determine
the patterns that can suggest future activity. Technical analysts believe that the historical performance of
stocks and markets are indications of future performance.
INVESTMENT STRATEGIES
Your accounts are managed separately with your underlying investment strategies, restrictions, or
investment limitations defined within the investment management agreement.
POTENTIAL RISKS
Investing involves different levels of risk that can result in the loss of any profits and/or principal you have
not realized. We manage your account in a manner consistent with your pre-determined risk tolerance
and suitability profile. However, we cannot guarantee that our efforts will be successful. Investing in
securities involves the risk of loss clients should be prepared to bear.
Investing involves the assumption of risk, including:
Financial Risk: which is the risk that the companies we recommend to you perform poorly, which affect
the price of your investment.
Market Risk: which is the risk that the stock market will decline, decreasing the value of the securities we
recommend to you with it.
Inflation Risk: which is the risk that the rate of price increases in the economy deteriorates the returns
associated with the stock.
Interest Rate Risk: which is the risk that the value of the investments we recommend to you will fall if
interest rates rise.
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Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a
potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.
Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the
currency of the investment’s originating country. This is also referred to as exchange rate risk.
Business Risk: These risks are associated with a particular industry or a particular company within an
industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process,
before they can generate a profit. They carry a higher risk of profitability than an electric company, which
generates its income from a steady stream of customers who buy electricity no matter what the economic
environment is like.
Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are
more liquid if many traders are interested in a standardized product. For example, Treasury Bills are
highly liquid, while real estate properties are not.
Leverage Exchange Traded-Funds (L-ETFs) and Inverse Exchange Traded Funds (Inverse ETFs): The
Leverage ETF obtains investment exposure in excess of its assets in seeking to achieve its investment
objective — a form of leverage — and will lose more money in market environments adverse to its daily
objective than a similar fund that does not employ such leverage. The use of such leverage could result in
the total loss of an investor’s investment. For example: a 2X fund will have a multiplier of two times (2x)
the Index. A single day movement in the Index approaching 50% at any point in the day could result in the
total loss of a shareholder’s investment if that movement is contrary to the investment objective of the L-
ETF, even if the Index subsequently moves in an opposite direction, eliminating all or a portion of the
earlier movement. This would be the case with any such single day movements in the Index, even if the
Index maintains a level greater than zero at all times. Compounding affects all investments but has a more
significant impact on a leveraged fund. Particularly during periods of higher Index volatility, compounding
will cause results for periods longer than a single day to vary from the stated multiplier of the return of
the Index. This effect becomes more pronounced as volatility increases.
Inverse products seek to deliver the opposite of the performance of the index or benchmark they track.
An inverse product that tracks a particular index, for example, seeks to deliver the inverse of the
performance of that index, while a 2x (two times) leveraged inverse product seeks to deliver double the
opposite of that index’s performance. Inverse Funds involve certain risks, which include increased
volatility due to the Funds’ possible use of short sales of securities and derivatives, such as options and
futures. The Funds’ use of derivatives, such as futures, options and swap agreements, may expose the
Funds’ shareholders to additional risks that they would not be subject to if they invested directly in the
securities underlying those derivatives. Short-selling involves increased risks and costs. You risk paying
more for a security than you received from its sale.
Leverage and Inverse Exchange Traded Funds are subject to Asset-Backed Securities Risk, Collateralized
Loan Obligations (“CLO”) and Collateralized Debt Obligations (“CDO”) Risk, Compounding Risk, Correlation
Risk, Counterparty Credit Risk, Derivaties Risk (Futures Contracts Risk; Options Risk; Swap Agreements
Risk), Early Closing Risk, Financial Sector Risk, High Yieldd and Unrated Securities Risk, Interest Rate Risk,
Investment in Investment Vehichles Risk, Investment in Loans Risk, Liquidity and Valuation Risk, Market
Risk, OTC Trading Risk, Passive Investment Risk, Portfolio Turnover Risk, Prepayment and Extension Risk,
Regulatory and Legal Risk, Repurchase Agreement Risk, Shareholder Trading Risk, Short Sale and Short
Exposure Risk, Tracking Error Risk, Trading Halt Risk, US Government Securities Risk.
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ITEM 9 Disciplinary Information
As of the date of this brochure, we have not been subject to any disciplinary, legal, or regulatory events
related to past or present investment clients. There has been no disciplinary, legal, or regulatory events
related to us or any of our management persons.
ITEM 10 Other Financial Activities and Affiliations
FINANCIAL INDUSTRY ACTIVITIES
Neither Storehouse nor its management persons are registered or has an application pending to register
as a broker-dealer or a registered representative of a broker-dealer.
Neither Storehouse nor its management persons are registered or has an application pending to register
as a futures commission merchant, commodity pool operator, or commodity trading advisor.
AFFILIATIONS
Stephen Stull is the owner of Public Accounting Stull, CPA, LLC. Public Accounting Stull, CPA LLC, offers
accounting and tax preparation services. Stephen Stull spends 33% of his time in this role. Thus, a conflict
of interest exists between the interests of this individual and those of the advisory clients, creating an
incentive to recommend accounting and tax preparation services based on the compensation received
rather than on a client’s needs. We require that all IARs disclose this conflict of interest when such
recommendations are made. However, clients are under no obligation to act upon any of these
recommendations. Clients have the option to utilized accounting services not affiliated with our firm.
ITEM 11 Code of Ethics, Participation in Client Transactions and
Personal Trading
CODE OF ETHICS
Storehouse has developed a code of ethics that will apply to all of our supervised persons. We and our
IARs must act in a fiduciary capacity when providing investment advisory services to you. As a fiduciary, it
is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act
solely in the best interest of each of our clients at all times. Storehouse has a fiduciary duty to all clients.
This fiduciary duty is considered the core underlying principle of our code of ethics, which also covers our
insider trading and personal securities transactions policies and procedures. We require all of our
supervised persons to conduct business with the highest level of ethical standards and to comply with all
federal and state securities laws at all times. Upon employment or affiliation and at least annually
thereafter, all supervised persons will acknowledge that they have read, understand, and agree to comply
with our Code of Ethics.
Our Code of Ethics is available to clients and prospective clients upon request.
RECOMMENDATIONS INVOLVING A MATERIAL FINANCIAL INTEREST
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Neither we nor any related person recommend to clients or buys or sells for clients’ accounts securities
in which we or a related person has a material financial interest.
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
There may be instances where an IAR will recommend to investment advisory clients or prospective clients
the purchase or sale of securities in which an IAR, its affiliates, or other clients may also have a position
or interest. Certain affiliated accounts may trade in the same securities with client accounts on an
aggregated basis. Generally, in such circumstances, the affiliated and client accounts will share execution
costs equally. Completed trade orders will be allocated according to the instructions from the initial trade
order. Partially filled trade orders will be allocated on a pro-rata basis. Any exceptions will be explained in
the trade order.
PERSONAL TRADING
Employees are permitted to have personal securities accounts as long as personal investing practices are
in line with fiduciary standards and regulatory requirements and do not conflict with their duty to
Storehouse and our clients. Storehouse monitors and controls personal trading through pre-approval of
all personal securities transactions or blackout periods imposed upon employees trading in the same
securities as Storehouse. We forbid any officer or employee, either personally or on behalf of others, to
trade on material, nonpublic information, or to communicate such information to others in violation of
the law.
ITEM 12 Brokerage Practices
We recommend broker/dealers for our clients to use in order to custody their accounts. The firms we
recommend will be independent SEC-registered broker-dealers and members of FINRA and SIPC.
As a fiduciary, we are obligated to seek out the best execution of client transactions for that accounts that
we manage. In general, the execution of securities transactions is at a total cost to process each
transaction and are the most favorable under the circumstances. However, we do not limit the best
execution to the lowest available price. Additional factors are taken into consideration when determining
the arrangement and services in the selection of a broker-dealer or qualified custodian. Our review
consists of reviewing the commission and fee structures of various broker/dealers, research platforms,
and execution services. Accordingly, while we do consider competitive rates, we do not necessarily obtain
the lowest possible commission rates for account transactions. Therefore, the overall services provided
by our unaffiliated broker-dealers and qualified custodians are evaluated to determine the best execution.
You may pay trade execution charges and higher commissions through the trading platforms approved by
us than through platforms that have not been approved by us.
RESEARCH AND OTHER SOFT DOLLAR BENEFITS
We receive soft dollar benefits in that certain custodians can make other products and services available
to us, such as trade execution software, investment research, pricing information, market data,
recordkeeping, publications, and conferences in return for effecting transactions through them. Such
arrangements will be pursuant to Section 28(e) of the Securities and Exchange Act of 1934 and are
available to all of the retail and professional clients of the custodians on an unsolicited basis.
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Products & Services Available to Us from Schwab
Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent
investment advisory firms like ours. They provide us and our clients with access to its institutional
brokerage – trading, custody, reporting, and related services – many of which are not typically available
to Schwab retail customers. Schwab also makes available various support services. Some of those
services help us manage or administer our clients’ accounts, while others help us manage and grow our
business. Schwab’s support services are generally available on an unsolicited basis and at no charge to
us as long as we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab.
Services that Benefit Client
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access, or that would require a
significantly higher minimum initial investment by our clients. Schwab’s services described in this
paragraph generally benefit clients or their account(s).
Services that May Not Directly Benefit Clients
Schwab also makes available to us other products and services that benefit us but cannot directly
benefit the client or their account(s). These products and services assist us in managing and
administering our clients’ accounts. They include investment research, both Schwab’s own and that of
third parties. We can use this research to service all or some substantial number of our clients’ accounts,
including accounts not maintained at Schwab. In addition to investment research, Schwab also makes
available software and other technology that:
provides access to client account data (such as duplicate trade confirmations and account
•
statements);
•
facilitates trade execution and allocates aggregated trade orders for multiple client accounts;
•
provides pricing and other market data;
•
facilitates payment of our fees from our clients’ accounts; and
•
assists with back-office functions, recordkeeping, and client reporting.
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services include:
•
educational conferences and events
•
technology, compliance, legal, and business consulting;
•
publications and conferences on practice management and business succession; and
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•
access to employee benefits providers, human capital consultants, and insurance providers.
Schwab can provide some of these services itself. In other cases, it will arrange for third-party vendors
to provide the services to us. Schwab can also discount or waive its fees for some of these services or
pay all or a part of a third party’s fees.
Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the client’s
experience, help reach their goals and put their interests before that of our firm or its associated
persons.
BROKERAGE FOR CLIENT REFERRALS
We do not receive client referrals from broker/dealers.
DIRECTED BROKERAGE
Clients will be permitted to select any broker/dealer of their choosing. In these situations, we may be
unable to achieve the most favorable execution for client transactions. Directing brokerage may cost
clients more money in that the client may pay higher brokerage commissions because we may not be able
to aggregate orders to reduce transaction costs, or the client may receive less favorable prices.
TRADE AGGREGATION
We do not aggregate trade orders.
ITEM 13 Review of Accounts
PERIODIC REVIEWS
We review asset management accounts no less than annually. These accounts will be reviewed by Stephen
Stull. Accounts are reviewed to evaluate asset allocation, investment strategy and objectives, cash
balance, and performance, as well as the general economic outlook and current investment trends.
REVIEW TRIGGERS
We conduct periodic reviews to evaluate the current market, economic and political events and how
these may affect client accounts. Additional reviews may be triggered by these events or by events in
the client’s financial or personal status.
REGULAR REPORTS
Financial planning and consulting clients are provided a one-time written financial plan concerning their
financial situation. After the presentation of the plan, there are no further reports. Clients may request
additional plans or reports for a fee.
ITEM 14 Client Referrals and Other Compensation
We do not engage in referral relationships with vendors and/or unaffiliated third-party custodians, which
provide services that may include custody of securities, trade execution, and clearance and settlement of
transactions.
Please see Item 12 Brokerage Practices for information regarding benefits we receive from our custodian.
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OTHER COMPENSATION
We may have obligations under referral programs with custodians to certain clients, including clients who
become clients of the firm as part of its merger and acquisition activities. Under such programs, ongoing
fee arrangements require us to pay our custodian an ongoing fee, usually as a percentage of the asset
management fees that are billed to the account or a percentage of assets, with a one-time fee if the
account is transferred to another custodian. Since the one-time fee may be higher than the ongoing fee,
we will have an incentive to maintain the account at the present custodian.
We do not pay a referral fee to third party solicitors.
ITEM 15 Custody
We do not have custody of client funds and securities due to our ability to deduct management fees from
clients’ accounts. Clients will receive account statements from the qualified custodian(s) holding their
funds and securities at least quarterly. The custodian’s account statements will indicate the amount of
our advisory fees deducted from the clients’ account(s) each billing period. These statements should be
carefully reviewed by the client for accuracy. Item 5 – Fees and Compensation has additional information
regarding our ability to deduct management fees from clients’ accounts.
ITEM 16
Investment Discretion
DISCRETIONARY AUTHORITY FOR TRADING
If you are participating in our asset management services, upon receiving your written authorization via
our executed investment advisory agreement, we will maintain trading authorization over your
designated account and may also implement trades on a discretionary basis.
When discretionary authority is granted, we will have the limited authority to determine the type of
securities to be purchased, sold, or exchanged and a number of securities that can be bought, sold, or
exchanged for your portfolio without obtaining your consent for each transaction.
If you do not grant this limited investment discretion, your IAR will be required to contact you and get
affirmation regarding our investment recommendations, such as the security being recommended, the
number of shares, whether the security should be bought or sold before implementing changes in your
account.
Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing
of buying or selling an investment and the price at which the investment is bought or sold. If your accounts
are managed on a non-discretionary basis, it is critical that you respond promptly. If we do not receive a
response to our request immediately, the timing of trade implementation can lead to an adverse impact
where we cannot achieve the optimal trading price.
On a case-by-case basis, you can place reasonable restrictions on the types of investments that can be
purchased or sold in your account so long as the restrictions are explicitly set forth or included as an
attachment to the investment advisory agreement.
On a case by case basis, you may place reasonable restrictions on the types of investments that may be
purchased or sold in your account so long as the restrictions are explicitly set forth or included as an
attachment to the investment advisory agreement.
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ITEM 17 Voting Client Securities
We do not have the authority to vote proxies as it pertains to the issuers of securities held in your account.
The responsibility for voting your securities places increased liability to us and does not add enough value
to the services provided to you to justify the additional compliance and regulatory costs associated with
voting your securities.
Therefore, you are responsible for voting all proxies for securities held in accounts managed by us.
Typically, our qualified custodian will forward you your proxy information. Although we do not vote your
proxies, you can contact us if you have a question about a particular proxy.
ITEM 18 Financial Information
We are not required to include a balance sheet for our most recent fiscal year. We are not subject to a
financial condition that is reasonably likely to impair our ability to meet contractual commitments to our
clients.
We are currently not in, nor have been historically in a financially precarious situation or the subject of a
bankruptcy petition.
15
Storehouse Financial