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ITEM 1 COVER PAGE
STORYONE FAMILY OFFICE
7501 College Blvd.
Suite 120
Overland Park, KS 66210
www.story-one.com/
CRD #: 331394
April 28, 2026
This brochure provides information about the qualifications and business practices of
StoryOne Family Office. If you have any questions about the contents of this brochure, please
contact us at 913-544-0600. 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. Registration (e.g., “registered investment advisor”) does not imply a certain level
of skill or training.
Additional information about StoryOne Family Office is also available on the SEC’s
website at www.adviserinfo.sec.gov.
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ITEM 2 MATERIAL CHANGES
Pursuant to SEC rules, StoryOne Family Office will ensure that clients receive a summary of any
material changes to this and subsequent disclosure brochures within 120 days after the Firm’s
fiscal year end, December 31. This means that if there were any material changes over the past
year, clients will receive a summary of those changes no later than April 30. At that time,
StoryOne Family Office will also offer a copy of its most current disclosure brochure and may
also provide other ongoing disclosure information about material changes as necessary. If there
are no material changes over the past year, no notices will be sent.
Clients and prospective clients can always receive the most current disclosure brochure for
StoryOne Family Office at any time by contacting their investment advisor representative.
Since our last annual amendment filing on March 25, 2025, we have the following material
changes to report:
Item 4 has been updated to disclose that we may recommend third-party managers.
Item 4 and Item 5 have been updated to disclose that our Firm has entered into a sub-
advisory arrangement with another registered investment adviser. Under this
arrangement, our Firm provides portfolio management services on a sub-advisory basis
and receives a portion of advisory fees pursuant to a revenue-sharing agreement.
Item 10 has been updated to disclose that certain employees are also licensed as insurance
agents and the associated conflicts.
Item 14 has been updated to disclose that the Firm previously received transition-related
payments from Raymond James & Associates, Inc. in connection with a platform
transition, and to reflect the Firm’s policy regarding disclosure of economic benefits
received from non-client sources.
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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 .................................................................................................. 6
ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .......................... 7
ITEM 7 TYPES OF CLIENTS .................................................................................................................. 7
ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .......... 9
ITEM 9 DISCIPLINARY INFORMATION .......................................................................................... 15
ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ........................ 15
ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING ................................................................................................................. 16
ITEM 12 BROKERAGE PRACTICES .................................................................................................. 16
ITEM 13 REVIEW OF ACCOUNTS ..................................................................................................... 18
ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION ................................................ 19
ITEM 15 CUSTODY ................................................................................................................................ 19
ITEM 16 INVESTMENT DISCRETION ............................................................................................... 20
ITEM 17 VOTING CLIENT SECURITIES .......................................................................................... 20
ITEM 18 FINANCIAL INFORMATION ............................................................................................... 20
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ITEM 4 ADVISORY BUSINESS
Firm Description
StoryOne, LLC, d/b/a StoryOne Family Office (the “Firm” or “SOFO”) is an SEC-registered
investment advisor. The Firm was founded on April 9, 2024.
The Principal Owners of SOFO are John Christensen and Cameron Bond.
Types of Advisory Services
The Firm offers a large variety of services, including portfolio management, investment analysis,
and financial planning for individuals and high net worth individuals. The Firm offers these
services to clients or prospective clients (“Client” or “Clients”).
Prior to providing any investment advisory services, SOFO requires a written investment
advisory agreement (“IAA”) to be executed by the Client. The IAA will outline the services
available to the Client and the fees the Client will incur.
Discretionary Investment Management Services
Models:
The Firm constructs model portfolios based on risk, asset allocation, diversification, and expected
returns. These models can be utilized at the account level to help Clients accomplish their financial
goals. These models are constructed by utilizing third party research, which includes economic
research, market research, and publicly available information. Models may be comprised of
publicly traded stocks, bonds, mutual funds, exchange traded funds (ETFs), exchanged traded
notes (ETNs), closed end mutual funds, and money markets or cash equivalents. Models may
include non-publicly traded securities such as certificates of deposit (CDs), or structured notes.
These models include aggressive (90 to 100% equities), growth (75% to 90% equities), balanced
growth (60 to 75% equities), balanced (46 to 60% equities) and conservative (30 to 45% equities).
These models may be utilized at the individual account level or aggregated at the household level
to accomplish the target asset allocation for clients.
Custom Portfolios:
The Firm may construct custom portfolios for Clients. These portfolios are constructed by utilizing
third party research, which includes economic research, market research, and publicly available
information. Portfolios may be comprised of publicly traded stocks, bonds, mutual funds,
exchange traded funds (ETFs), exchanged traded notes (ETNs), closed end mutual funds, foreign
currency, options contracts, and money markets or cash equivalents. Portfolios may include non-
publicly traded securities such as certificates of deposit (CDs), structured notes, hedge funds, funds
of funds, private real estate or private real estate funds, private equity or private equity funds,
venture capital, or venture capital funds, private credit, or private credit funds. Non-publicly traded
securities may be direct investments or custodied at a custodian selected by SOFO. Custom
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portfolios take into account the long-term goals of Client, while taking into consideration the
Client’s ability to manage and accept the lack of liquidity and marketability of non-publicly traded
securities. Custom portfolios may utilize firm constructed model portfolios, and investments that
are not held in those model portfolios, which when taken in aggregate is designed to accomplish
the clients target risk and return.
Selection of Independent Managers:
SOFO may allocate, and/or recommend that the client allocate, a portion of the client's investment
assets among unaffiliated independent investment managers in accordance with the client's
designated investment objectives. In such situations, the Independent Manager(s) shall have day-
to-day responsibility for the active discretionary management of the allocated assets. SOFO shall
continue to render investment supervisory services to the client relative to the ongoing monitoring
and review of account performance, asset allocation, and client investment objectives. Factors
which SOFO shall consider in recommending Independent Managers include the client's
designated investment objectives, tax sensitivity, the taxation classification of the account or
portfolio, management style, performance, reputation, financial strength, reporting, pricing, and
research. Please Note: The investment management fee charged by the Independent Managers is
separate from, and in addition to, SOFO’s advisory fee as set forth in Item 5 below.
Sub-advisory Services:
SOFO provides investment advisory services to certain clients through a sub-advisory
arrangement with Sound Stewardship, LLC, another registered investment adviser. Under this
arrangement, clients enter into an advisory relationship with Sound Stewardship, LLC, and
Sound Stewardship, LLC appoints SOFO to manage the client’s assets on a discretionary basis in
accordance with the client’s investment objectives and guidelines. SOFO is responsible for
investment management decisions, while Sound Stewardship, LLC provides administrative
assistance and access to custodial platforms.
Family Office:
Family Office is for families with substantial, multi-generational wealth in need of a more
sophisticated approach to managing the complexity of their wealth and family dynamic. Family
Office services include Wealth Design Services, Trust Administration Services, Lifestyle
Management, Investments, Family Coaching, Mentoring and Education, Philanthropic Services,
Tax Services, and Insurance Services. These services are in addition and more complex than a
typical financial plan, and the scope of work will typically take years to complete or will
continue for the duration of the Client’s life.
The Firm does not offer a Wrap Fee Program
As of December 31, 2025, SOFO has the following assets under management:
Discretionary assets:
Non-discretionary assets:
$259,411,503
$0
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ITEM 5 FEES AND COMPENSATION
Individually Managed Accounts
Fees for individually managed accounts are tier priced as follows:
Account Size
Fee (Annual percentage)*
$0 to $1 million
$1 to $2 million
$2 to $5 million
$5 to $10 million
$10 to $25 million
$25 to $100 million
Above $100 million
1.35%
1.10%
0.85%
0.70%
0.50%
0.30%
0.20%
Our advisory fee is negotiable and will not exceed an annualized fee of 1.35%. The exact fee
structure applicable to your accounts will be clearly stated in the portfolio management agreement.
All asset-based fees are deducted by the qualified custodian of record quarterly, in advance, based
on the previous quarter’s daily average, or as otherwise indicated in the IAA. For the first billing
quarter, the Firm will use the balance of the Account, or Accounts, at the time assets transfer into
the Account or Accounts, prorated for the days remaining in the first billing quarter to calculate
the fee, and to calculate the fee for the following quarter. Client statements for prior deductions
will be provided on a monthly basis.
All fees paid to SOFO for investment advisory services are separate and distinct from the expenses
charged by Independent Managers, third-party managers and investment companies to their
shareholders. These fees and expenses are described to the Client in separate disclosures. These
fees will generally include third-party management fees, an investment company management fee,
other fund expenses, and in some situations a possible distribution fee.
The Firm will provide investment advisory services and portfolio management services but will
not provide custodial or other administrative services. At no time will SOFO accept or maintain
custody of a Client funds or securities except for authorized fee deduction. The Client may contact
the Custodian directly for disbursements, or account record changes, but in the normal course of
business SOFO will coordinate distributions and account record changes for clients to align with
SOFO's best practices and those of the respective custodian.
Client is responsible for all custodial and securities execution fees charged by the custodian and
executing broker-dealer. Fees paid to SOFO are separate and distinct from the custodian and
execution fees.
Clients may request to terminate their advisory contract with SOFO, in whole or in part, by
providing advance written notice. Upon termination, any fees paid in advance will be prorated to
the date of termination and any excess will be refunded to Client through the Custodian. Client’s
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advisory agreement with the Advisor is non-transferable without Advisor’s and Client’s written
approval.
As described in Item 4 above, SOFO provides investment advisory services to certain clients
through a sub-advisory arrangement with Sound Stewardship, LLC. Under the sub-advisory
arrangement, advisory fees are charged by Sound Stewardship, LLC pursuant to the above
advisory fee schedule. The total advisory fee is then allocated between Sound Stewardship, LLC
and SOFO pursuant to a written sub-advisory agreement. SOFO receives 80% of the advisory fee
for its portfolio management services and Sound Stewardship, LLC receives 20% of the advisory
fee as compensation for its services.
Fixed Fees
The Firm offers Family Office services for families with complex planning needs. These services
are in addition and more complex than a typical financial plan, and the scope of work will typically
take years to complete or will continue for the duration of the Client’s life. Family Office fees are
initially calculated by taking into account the expected scope of work to be completed, and the
allocation of time the firm will need to complete said tasks and then negotiated with the Client
from time to time, to make sure that the Client and SOFO are satisfied with the existing
arrangement. Family Office fees may be stand alone or bundled with investment management
services.
All fixed fees for services offered by SOFO will be determined in advance by the investment
advisory agreement and based on the information provided by the Client at that time. Unless
otherwise set out in the investment advisory agreement, fixed fees will be charged on a quarterly
basis in advance.
Fixed fees paid in advance will be prorated to the date of termination and the excess refunded to
the Client by check as soon as practicable. Where SOFO may request a fee in advance, the amount
paid in advance will not be more than $1,200 per Client and no longer than six (6) months in
advance.
Right of Cancellation
In addition to the right to terminate the investment advisory agreement pursuant to its terms, Client
can terminate its IAA with SOFO within five (5) business days of first receiving a copy of this
disclosure brochure and supplement without penalty or fee.
ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
The Firm does not accept performance-based fees and so does not use side-by-side management.
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ITEM 7 TYPES OF CLIENTS
The Firm provides investment management and financial planning services to:
Individuals, including high net worth individuals.
Families, trusts, and estates.
Corporations and other business entities.
Qualified and 401k plans.
Non-profits, private foundations, public charities, and ministries
The Firm has a minimum investment account balance of $1,000,000. This minimum investment
account balance is negotiable.
ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Methods of Analysis
The Firm may use the following methods when considering investment strategies and
recommendations.
Charting Review
Charting is a technical analysis that charts the patterns of stocks, bonds, and commodities
to help determine buy and sell recommendations for Clients. It is a way of gathering and
processing price and volume information in a security by applying mathematical equations
and plotting the resulting data onto graphs in order to predict future price movements. A
graphical historical record assists the analyst in spotting the effect of key events on a
security’s price, its performance over a period of time, and whether it is trading near its
high, near its low or in between. Chartists believe that recurring patterns of trading,
commonly referred to as indicators, can help them forecast future price movements.
Fundamental Review
A fundamental analysis is a method of evaluating a company or security by attempting to
measure its intrinsic value. Fundamental analysis attempts to determine the true value of a
company or security by looking at all aspects of the company or security, including both
tangible factors (e.g., machinery, buildings, land, etc.) and intangible factors (e.g., patents,
trademarks, “brand” names, etc.). Fundamental analysis also involves examining related
economic factors (e.g., overall economy and industry conditions, etc.), financial factors
(e.g., company debt, interest rates, management salaries, and bonuses, etc.), qualitative
factors (e.g., management expertise, industry cycles, labor relations, etc.), and quantitative
factors (e.g., debt-to-equity and price-to-equity ratios).
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The end goal of performing fundamental analysis is to produce a value that an investor can
compare with the security's current price with the aim of determining what sort of position
to take with that security (e.g., if underpriced, the security should be bought; if overpriced
the security should sold). Fundamental analysis uses 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 many types of securities.
Technical Review
A technical analysis is a method of evaluating securities that analyzes statistics generated
by market activity, such as past prices and volume. Technical analysis does not attempt to
measure a security's intrinsic value but instead uses past market data and statistical tools to
identify patterns that can suggest future activity. Historical performance of securities and
the markets can indicate future performance.
Cyclical Review
A cyclical analysis assumes the market reacts in reoccurring patterns that can be identified
and leveraged to provide performance. Cyclical analysis of economic cycles is used to
determine how these reoccurring patterns, or cycles, affect the returns of a given
investment, asset, or company. Cyclical analysis is a time-based assessment which
incorporates past and present performance to determine future value. Cyclical analyses
exist because the broad economy has been shown to move in cycles, from periods of peak
performance to periods of low performance. The risks of this strategy are two-fold: (1) the
markets do not always repeat cyclical patterns; and (2) if too many investors begin to
implement this strategy, it changes the very cycles of which they are trying to take
advantage.
Economic Review
An economic analysis determines the economic environment over a certain time horizon.
This involves following and updating historic economic data such as U.S. gross domestic
product and consumer price index as well as monitoring key economic drivers such as
employment, inflation, and money supply for the world’s major economies.
Investment Strategies
When implementing investment advice to Clients, SOFO may employ a variety of strategies to
best pursue the objectives of Clients. Depending on market trends and conditions, SOFO will
employ any technique or strategy herein described, at SOFO’s discretion and in the best interests
of the Client. The Firm does not recommend any particular security or type of security. Instead,
SOFO makes recommendations to meet a particular Client’s financial objectives. There is inherent
risk to any investment and Clients may suffer a loss of all or part of a principal investment.
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Long-Term Purchases
Long-term purchases are securities that are purchased with the expectation that the value
of those securities will grow over a relatively long period, generally greater than one year.
Long-term purchases may be affected by unforeseen changes in the company in which a
Client is invested or in the overall market. Long-term trading is designed to capture market
rates of both return and risk. Frequent trading can affect investment performance,
particularly through increased brokerage and other transaction costs and taxes. Due to its
nature, the long-term strategy can expose Clients to various other types of risk that will
typically surface at various intervals during the time the Client owns the investments. These
risks include, but are not limited to, inflation (purchasing power) risk, interest rate risk,
economic risk, and political/regulatory risk.
Short-Term Purchases
Short-term purchases are securities that are purchased with the expectation that they will
be sold within a relatively short period of time, generally less than one year, to take
advantage of the securities’ short-term price fluctuations. Short-term trading generally
holds greater risk. Frequent trading can affect investment performance due to increased
brokerage fees and other transaction costs and taxes.
Strategic Asset Allocation
Asset allocation is a combination of several different types of investments; typically, this
includes stocks, bonds, and cash equivalents among various asset classes to achieve
diversification. The objective of asset allocation is to manage risk and market exposure
while still positioning a portfolio to meet financial objectives.
Risk of Loss
Investing inherently involves risk up to and including loss of the principal sum. Further, past
performance of any security is not necessarily indicative of future results. Therefore, future
performance of any specific investment or investment strategy based on past performance should
not be assumed as a guarantee. The Firm does not provide any representation or guarantee that the
financial goals of Clients will be achieved.
The potential return or gain and potential risk or loss of an investment varies, generally, with the
type of product invested in. Below is an overview of the types of products available on the market
and the associated risks of each:
General Risks. Investing in securities always involves risk of loss that the Client should be
prepared to bear. The Firm does not represent or guarantee that SOFO’s services or methods of
analysis can or will predict future results, successfully identify market tops or bottoms, or insulate
Clients from losses due to market corrections or declines. The Firm cannot offer any guarantees or
promises that a Client’s financial goals and objectives can or will be met. Past performance is in
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no way an indication of future performance. The Firm also cannot assure that third parties will
satisfy their obligations in a timely manner or perform as expected or marketed.
General Market Risk. Investment returns will fluctuate based upon changes in the value of the
portfolio securities. Certain securities held may be worth less than the price originally paid for
them, or less than they were worth at an earlier time.
Common Stocks. Investments in common stocks, both directly and indirectly through investment
in shares of ETFs (i.e., exchange-traded funds) or mutual funds may fluctuate in value in response
to many factors, including, but not limited to, the activities of the individual companies, general
market and economic conditions, interest rates, and specific industry changes. Such price
fluctuations subject certain strategies to potential losses. During temporary or extended bear
markets, the value of common stocks may decline, which could also result in losses for such
strategy.
Portfolio Turnover Risk. High rates of portfolio turnover can lower performance of an investment
strategy due to increased costs and may result in the realization of capital gains. If an investment
strategy realizes capital gains when it sells its portfolio investments, it will increase taxable
distributions to the Client. High rates of portfolio turnover in a given year may result in short-term
capital gains and under current tax law the Client would be taxed on short-term capital gains at
ordinary income tax rates, if held in a taxable account.
Non-Diversified Strategy Risk. Some investment strategies may be non-diversified (e.g., investing
a greater percentage of portfolio assets in a particular issuer and owning fewer securities than a
diversified strategy). Accordingly, each such strategy is subject to the risk that a large loss in an
individual issuer will cause a greater loss than it would if the strategy held a larger number of
securities or smaller positions sizes.
Model Risk. Financial and economic data series are subject to regime shifts, meaning past
information may lack value under future market conditions. Models are based upon assumptions
that may prove invalid or incorrect under many market environments. The Firm may use certain
model outputs to help identify market opportunities and/or to make certain asset allocation
decisions.
There is no guarantee that any model will work under all market conditions. For this reason, SOFO
includes model related results as part of its investment-decision process but often weigh
professional judgment more heavily in making trades or asset allocations.
ETF Risks, including Net Asset Valuations and Tracking Error. An ETF's performance may not
exactly match the performance of the index or market benchmark that the ETF is designed to track
because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index
or market benchmark; 2) certain securities comprising the index or market benchmark tracked by
the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the
market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to
trade at a premium or discount to the actual net asset value of the securities owned by the ETF.
Certain ETF strategies may from time to time include the purchase of fixed income, commodities,
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foreign securities, American Depository Receipts, or other securities for which expenses and
commission rates could be higher than normally charged for exchange-traded equity securities,
and for which market quotations or valuation may be limited or inaccurate.
Clients should be aware that to the extent they invest in ETF securities they will pay two levels of
advisory fees – advisory fees charged by SOFO plus any advisory fees charged by the issuer of
the ETF. While SOFO is not compensated by any fees paid to the issuer, this scenario may cause
a higher advisory cost (and potentially lower investment returns) than if a Client purchased the
ETF directly. An ETF typically includes embedded expenses that may reduce the ETF's net asset
value, and therefore directly affect the ETF's performance and indirectly affect a Client’s portfolio
performance or an index benchmark comparison. Expenses of the ETF may include investment
advisor management fees, custodian fees, brokerage commissions, and legal and accounting fees.
ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking
error and expenses may vary.
Mutual Funds Risks – A pool of funds collected from many investors for the purpose of investing
in securities such as stocks, bonds, money market instruments and similar assets. Open-End
Mutual Funds – a type of mutual fund that does not have restrictions on the amount of shares the
fund will issue and will buy back shares when investors wish to sell. Investing in mutual funds
carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual
funds have cost that lower investment returns. The funds can be of bond “fixed income” nature
(lower risk) or stock “equity” nature. Closed-End Mutual Funds – a type of mutual fund that raises
a fixed amount of capital through an initial public offering (IPO). The fund is then structured,
listed, and traded like a stock on a stock exchange. Clients should be aware that closed-end funds
available within the program are not readily marketable. To provide investor liquidity, the funds
may offer to repurchase a certain percentage of shares at net asset value on a periodic basis. Thus,
clients may be unable to liquidate all or a portion of their shares in these types of funds.
Alternative Investments - Alternative investments typically include investments in direct
participation program securities (partnerships, limited liability companies, business development
companies, or real estate investment trusts), private equity, private debt, or hedge funds. Investors
considering an investment strategy utilizing alternative investments should understand that many
alternative investments are considered speculative in nature and may involve a high degree of risk,
particularly if concentrating investments in one or few alternative investments. These risks are
potentially greater and substantially different than those associated with traditional equity or fixed
income investments. Alternative investments do not trade on a national securities exchange, and
as such may have limited liquidity due to the lack of secondary markets. This may impair the
ability of the client to exit such investments in times of adversity. Other risks associated with
Alternative Investments are that a) they may utilize highly speculative investment strategies,
including leverage, b) the calculation of fair market value of alternatives can be difficult or
delayed, c) they typically have fees that are higher compared to publicly traded securities, and d)
they may utilize debt to increase the leverage within the fund. Most offerings are sold by
prospectus or offering memorandum which contains more complete information including risks,
costs, and expenses. Investors should read these carefully before investing.
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Inflation, Currency, and Interest Rate Risks. Security prices and portfolio returns will likely vary
in response to changes in inflation and interest rates. Inflation causes the value of future dollars to
be worth less and may reduce the purchasing power of an investor’s future interest payments and
principal. Inflation also generally leads to higher interest rates, which in turn may cause the value
of many types of fixed income investments to decline. In addition, the relative value of the U.S.
dollar-denominated assets primarily managed by SOFO may be affected by the risk that currency
devaluations affect Client purchasing power.
Liquidity Risk. Liquidity is the ability to readily convert an investment into cash to prevent a loss,
realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally,
investments are more liquid if the investment has an established market of purchasers and sellers,
such as a stock or bond listed on a national securities exchange. Conversely, investments that do
not have an established market of purchasers and sellers may be considered illiquid. An investment
in illiquid investments may be for an indefinite time, because of the lack of purchasers willing to
convert the investment to cash or other assets.
Legislative and Tax Risk. Performance may directly or indirectly be affected by government
legislation or regulation, which may include, but is not limited to: changes in investment advisor
or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment
of principal and interest on certain government securities; and changes in the tax code that could
affect interest income, income characterization and/or tax reporting obligations, particularly for
options, swaps, master limited partnerships, Real Estate Investment Trust, Exchange Traded
Products/Funds/Securities.
Foreign Investing and Emerging Markets Risk. Foreign investing involves risks not typically
associated with U.S. investments, and the risks maybe exacerbated further in emerging market
countries. These risks may include, among others, adverse fluctuations in foreign currency values,
as well as adverse political, social, and economic developments affecting one or more foreign
countries.
In addition, foreign investing may involve less publicly available information and more volatile or
less liquid securities markets, particularly in markets that trade a small number of securities, have
unstable governments, or involve limited industry. Investments in foreign countries could be
affected by factors not present in the U.S., such as restrictions on receiving the investment proceeds
from a foreign country, foreign tax laws or tax withholding requirements, unique trade clearance
or settlement procedures, and potential difficulties in enforcing contractual obligations or other
legal rules that jeopardize shareholder protection. Foreign accounting may be less transparent than
U.S. accounting practices and foreign regulation may be inadequate or irregular.
Information Security Risk. The Firm may be susceptible to risks to the confidentiality and security
of its operations and proprietary and customer information. Information risks, including theft or
corruption of electronically stored data, denial of service attacks on SOFO’s website or websites
of SOFO’s third-party service providers, and the unauthorized release of confidential information
are a few of the more common risks faced by us and other investment advisors. Data security
breaches of the Firm’s electronic data infrastructure could have the effect of disrupting the Firm’s
operations and compromising the Firm’s customers' confidential and personally identifiable
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information. Such breaches could result in the inability of the Firm to conduct business, potential
losses, including identity theft and theft of investment funds from customers, and other adverse
consequences to customers. The Firm proactively takes steps to secure Client data and have
implemented policies and procedures to increase cybersecurity.
Tax Risks. Tax laws and regulations applicable to an account with SOFO may be subject to change
and unanticipated tax liabilities may be incurred by an investor as a result of such changes. In
addition, customers may experience adverse tax consequences from the early assignment of
options purchased for a customer's account. Customers should consult their own tax advisors and
counsel to determine the potential tax-related consequences of investing.
Advisory Risk. There is no guarantee that the Firm’s judgment or investment decisions on behalf
of any particular account will necessarily produce the intended results. The Firm’s judgment may
prove to be incorrect, and an account might not achieve its investment objectives. In addition, it is
possible that SOFO may experience computer equipment failure, loss of internet access, viruses,
or other events that may impair access to the custodians’ software. The Firm and its representatives
are not responsible to any account for losses unless caused by SOFO breaching its fiduciary duty.
Dependence on Key Employees. An accounts success depends, in part, upon the ability of SOFO’s
key professionals to achieve the targeted investment goals. The loss of any of these key personnel
could adversely impact the ability to achieve such investment goals and objectives of the account.
The Firm does not primarily recommend a particular type of security.
ITEM 9 DISCIPLINARY INFORMATION
There are no legal or disciplinary events to disclose for the advisory firm or any management
personnel of the advisory firm.
ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Neither the advisory firm nor any of its management persons are registered or have an application
pending to register as a broker-dealer, a registered representative of a broker -dealer, a futures
commission merchant, commodity pool operator, commodity trading advisor, nor is there any
association with any of these mentioned types of entities.
Certain SOFO employees are also licensed as insurance agents. These individuals will earn
commission-based compensation for selling insurance products to clients. Insurance commissions
earned by these individuals are separate and in addition to our advisory fees. This practice presents
a conflict of interest because persons providing investment advice on behalf of our firm, who are
insurance agents, have an incentive to recommend insurance products to you for the purpose of
generating commissions rather than solely based on your needs. You are under no obligation,
contractually or otherwise, to purchase insurance products through any person affiliated with our
firm.
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SOFO does not receive, directly or indirectly, compensation from investment advisors that it
recommends or selects for its clients.
ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Fiduciary Status
According to federal and state law, an investment advisor is considered a fiduciary. As a fiduciary,
it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts.
In addition, an investment advisor has a duty of utmost good faith to act solely in the best interest
of each of its Clients. The Firm and its representatives have a fiduciary duty to all Clients. The
fiduciary duty of SOFO and its representatives toward its Clients is considered the core underlying
principal for SOFO’s Code of Ethics and represents the expected basis for all dealings SOFO’s
representatives have with its Clients. The Firm has the responsibility to ensure that the interests of
its Clients are placed ahead of its own investment interests, as well as the investment interests of
its representatives. All representatives will conduct business in an honest, ethical, and fair manner.
All representatives will comply with all federal and state securities laws at all times. Full disclosure
of all material facts and potential conflicts of interest will be provided to Clients prior to services
being conducted. All representatives have a responsibility to avoid circumstances that might
negatively affect or appear to affect their duty of complete loyalty to SOFO’s Clients. A copy of
the Firm’s code of ethics is available upon request.
Personal Trading in the Same Securities as Clients
The Firm or its representatives may from time to time purchase or sell products or investments that
they may recommend to Clients. The Firm has adopted a Code of Ethics that sets forth the basic
policies of ethical conduct for all managers, officers, and employees of the SOFO
In addition, the Code of Ethics governs personal trading by each employee of the SOFO deemed
to be an “Access Person” and is intended to ensure that securities transactions effected by Access
Persons of SOFO are conducted in a matter that avoids any actual or potential conflict of interest
between such persons and Clients of the SOFO or its affiliates.
ITEM 12 BROKERAGE PRACTICES
Selection and Recommendation
The Firm has a duty to select brokers, dealers, and other trading venues that provide best execution
for Clients. The duty of best execution requires an investment advisor to seek to execute securities
transactions for Clients in such a manner that the Client’s total cost or proceeds in each transaction
is the most favorable under the circumstances, taking into account all relevant factors. The lowest
possible commission, while very important, is not the only consideration.
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It is the policy of SOFO to seek best execution in all portfolio trading activities for all investment
disciplines and products, regardless of whether commissions are charged. This applies to trading
in any instrument, security, or contract including equities, bonds, and forward or derivative
contracts.
The standards and procedures governing best execution are set forth in several written policies.
Generally, to achieve best execution, SOFO considers the following factors, without limitation, in
selecting brokers and intermediaries:
Execution capability;
Order size and market depth;
Availability of competing markets and liquidity;
Trading characteristics of the security;
Availability of accurate information comparing markets;
Quantity and quality of research received from the broker dealer;
Financial responsibility of the broker-dealer;
Confidentiality;
Reputation and integrity;
Responsiveness;
Recordkeeping;
Ability and willingness to commit capital;
Available technology; and
Ability to address current market conditions.
The Firm evaluates the execution, performance, and risk profile of the broker-dealers it uses at
least annually.
Research and Other Soft Dollar Benefits
Soft dollar practices are arrangements whereby an investment advisor directs transactions to a
broker‐dealer in exchange for certain products and services that are allowable under federal and
state law. Client commissions may be used to pay for brokerage and research services and products
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as long as they are eligible under Section 28(e) of the Exchange Act of 1934. Section 28(e) sets
forth a “safe harbor,” which provides that an investment advisor that has discretion over a Client
account is not in breach of its fiduciary duty when paying more than the lowest commission rate
available if the advisor determines in good faith that the rate paid is commensurate with the value
of brokerage and research services provided by the broker‐dealer.
The Firm does not currently have any soft dollar benefit arrangements that fall outside of Section
28(e).
Brokerage for Client Referrals
The Firm does not receive Client referrals from third parties for recommending the use of specific
broker-dealer brokerage services.
Directed Brokerage
The Firm generally, does not permit its clients to select a broker-dealer or custodian other than the
recommended brokers for trade execution and custodial services (i.e., client directed brokerage).
Clients should be aware of the fact that not all investment advisors require clients to use a particular
custodial broker-dealer for trade execution services. The Client should further be aware that
because SOFO requires Clients to engage the recommended custodial broker-dealers, the Firm
may not be able to achieve the lowest cost of execution of specific Client transactions. Thus, the
exclusive use of only SOFO’s recommended custodial broker-dealers may cost Clients more
money compared to other arrangements.
Order Aggregation
The Firm may, at times, aggregate sale, and purchase orders of securities (“block trading”) for
advisory accounts with similar orders in order to obtain the best pricing averages and minimize
trading costs. This practice is reasonably likely to result in administrative convenience or an overall
economic benefit to the Client. Clients also benefit relatively from better purchase or sale
execution prices, or beneficial timing of transactions or a combination of these and other factors.
Aggregate orders will be allocated to Client accounts in a systematic non-preferential manner. The
Firm may aggregate or “bunch” transactions for a Client’s account with those of other Clients in
an effort to obtain the best execution under the circumstances.
Trade Error Policy
The Firm maintains a record of any trading errors that occur in connection with investment
activities of its Clients. Both gains and losses that result from a trading error made by SOFO will
be borne or realized by SOFO.
ITEM 13 REVIEW OF ACCOUNTS
Periodic Reviews
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The Firm regularly reviews and evaluates Client accounts for compliance with each Client’s
investment objectives, policies, and restrictions. The Firm analyzes rates of return and allocation
of assets to determine model strategy effectiveness. Such reviews are conducted by the investment
adviser on the account and shall occur at least once per calendar year.
Intermittent Review Factors
Intermittent reviews may be triggered by substantial market fluctuation, economic or political
events, or changes in the Client’s financial status (such as retirement, termination of employment,
relocation, inheritance, etc.). Clients are advised to notify SOFO promptly if there are any material
changes in their financial situation, investment objectives, or in the event they wish to place
restrictions on their account.
Reports
Clients may receive confirmations of purchases and sales in their accounts and will receive, at least
quarterly, statements containing account information such as account value, transactions, and other
relevant information. Confirmations and statements are prepared and delivered by the respective
custodian, electronically or in paper form.
ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION
The Firm has not entered into solicitation or referral agreements with individuals, financial
intermediaries, or others who are not supervised persons of SOFO.
From June 2024 through August 2025, the Firm received approximately $110,000 in transition-
related payments from Raymond James & Associates, Inc. in connection with the Firm’s migration
of client custodial accounts to the Raymond James platform. These payments were made pursuant
to a Client Benefit Confirmation Agreement under which the Firm received installment payments
contingent on maintaining a prescribed level of client assets in custody with Raymond James. The
arrangement presented a conflict of interest because the Firm had a financial incentive to
recommend Raymond James as broker and custodian for client accounts. That arrangement has
been terminated, all payments have been received, and the Firm does not anticipate entering into
similar arrangements in the future.
It is the Firm’s policy to promptly disclose any future arrangement under which it receives
economic benefits from non-client sources, including transition-related or platform-related
payments from broker-dealers or custodians, in connection with advisory services provided to
clients.
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ITEM 15 CUSTODY
Custodian of Assets
Custody means holding, directly or indirectly, Client funds or securities or having any authority to
obtain possession of them.
The Firm does not have direct custody of any Client funds or securities. The Firm will not maintain
physical possession of Client funds and securities. Instead, Client funds and securities are held by
a qualified custodian.
While SOFO does not have physical custody of Client funds or securities, payments of fees may
be paid by the custodian from the custodial brokerage account that holds Client funds pursuant to
the Client’s account application.
In certain jurisdictions, the ability of SOFO to withdraw its management fees from the Client’s
account may be deemed custody. Prior to permitting direct debit of fees, each Client provides
written authorization permitting fees to be paid directly from the custodian.
As part of the billing process, the Client’s custodian is advised of the amount of the fee to be
deducted from that Client’s account. On at least a quarterly basis, the custodian is required to send
to the Client a statement showing all transactions within the account during the reporting period,
either electronically or in paper form. The custodian does not calculate the amount of the fee to be
deducted and does not verify the accuracy of SOFO’s advisory fee calculation. Therefore, it is
important for Clients to carefully review their custodial statements to verify the accuracy of the
calculation. Clients should contact SOFO directly if they believe that there may be an error in their
statement. Clients can also request information directly from SOFO about their respective fees and
the calculation of said fees.
ITEM 16 INVESTMENT DISCRETION
The Firm may exercise full discretionary authority to supervise and direct the investments of a
Client’s account. This authority will be granted by Clients upon completion of The Firm’s IAA.
This authority allows SOFO and its affiliates to implement investment decisions without prior
consultation with the Client. Such investment decisions are made in the Client’s best interest and
in accordance with the Client’s investment objectives. Other than agreed upon management fees
due to SOFO, this discretionary authority does not grant SOFO the authority to have custody of
any assets in the Client’s account or to direct the delivery of any securities or the payment of any
funds held in the account to SOFO. The discretionary authority granted by the Client to SOFO
does not allow SOFO to direct the disposition of such securities or funds to anyone except the
account holder.
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ITEM 17 VOTING CLIENT SECURITIES
The Firm does not perform proxy voting services on the Client’s behalf. Clients are encouraged to
read through the information provided with the proxy voting documents and to make a
determination based on the information provided. Upon the Client’s request, Firm representatives
may provide limited clarifications of the issues presented in the proxy voting materials based on
his or her understanding of issues presented in the proxy voting materials. However, Clients have
the ultimate responsibility and authority for making all proxy voting decisions.
ITEM 18 FINANCIAL INFORMATION
Balance Sheet Requirement
The Firm is not the qualified custodian for Client funds or securities and does not require
prepayment of fees of more than $1,200 per Client for six months or more in advance.
Financial Condition
The Firm does not have any financial impairment that would preclude SOFO from meeting
contractual commitments to Clients.
Bankruptcy Petition
The Firm has not been the subject of a bankruptcy petition at any time during the last 10 years.
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