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F O R M A D V P A R T 2 A
D I S C L O S U R E B R O C H U R E
Office Address:
190 South Main Street
Bountiful, UT 84010
Telephone: 801-627-2200
Facsimile: 801-627-2205
RCraner@SPGUtah.com
www.SPGUtah.com
AUGUST 15, 2025
This brochure provides information about the qualifications and business practices
of Strategic Planning Group. Being registered as a registered investment adviser
does not imply a certain level of skill or training. If you have any questions about
the contents of this brochure, please contact us at 801-627-2200. 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 Strategic Planning Group (IARD#113844) is available
on the SEC’s website at www.adviserinfo.sec.gov.
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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 Form ADV Part 2A
Disclosure Brochure.
Material Changes since the Last Update
Since the last annual updating amendment filing submitted to regulators on March
26, 2024, we submitted our required annual updating amendment filing for the
fiscal year 2024 on March 24, 2025. We updated Item 8 with important disclosures
regarding risks associated with investing in cryptocurrency, including investing in
registered investment companies, such as Exchange Traded Funds (ETFs) that
invest in cryptocurrency. From time to time, where suitable, we may recommend
small allocations in ETFs that hold Bitcoin, for example, but we do not make client
investments directly in cryptocurrency.
Full Brochure Available
This Firm Brochure being delivered is the complete brochure for the Firm. In
addition to the changes referenced above, we encourage you to review this entire
brochure. If you have questions or would like to receive a copy of our current
brochure at any time, free of charge, please contact Jeff Draper, Chief Compliance
Officer at jeff@strategicutah.com or 801-627-2200.
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Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes ............................................................................................................. ii
Annual Update
Material Changes since the Last Update
................................................................................................................................................ ii
Full Brochure Available
........................................................................................ ii
Item 3: Table of Contents ............................................................................................................ iii
............................................................................................................................. ii
Item 4: Advisory Business ........................................................................................................... 1
Firm Description
Types of Advisory Services
............................................................................................................................................ 1
Client Tailored Services and Client Imposed Restrictions
....................................................................................................................... 1
Wrap Fee Programs
................................................... 6
Client Assets under Management
...................................................................................................................................... 6
Item 5: Fees and Compensation ............................................................................................... 6
....................................................................................................... 6
Method of Compensation and Fee Schedule
Client Payment of Fees
.................................................................................. 6
Additional Client Fees Charged
.............................................................................................................................. 8
Prepayment of Client Fees
............................................................................................................ 9
External Compensation for the Sale of Securities to Clients
....................................................................................................................... 9
External Compensation for the Sale of Insurance Products to Clients
.............................................. 9
Item 6: Performance-Based Fees and Side-by-Side Management ..................... 10
........................ 9
Sharing of Capital Gains
Item 7: Types of Clients ............................................................................................................... 10
......................................................................................................................... 10
Description
Account Minimums
....................................................................................................................................................... 10
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ........... 10
..................................................................................................................................... 10
Methods of Analysis
Investment Strategy
................................................................................................................................... 10
Security Specific Material Risks
.................................................................................................................................. 10
......................................................................................................... 11
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Item 9: Disciplinary Information .......................................................................................... 16
Criminal or Civil Actions
Administrative Enforcement Proceedings
........................................................................................................................ 16
Self-Regulatory Organization Enforcement Proceedings
.................................................................................... 16
Item 10: Other Financial Industry Activities and Affiliations ............................ 16
.................................................... 16
Broker-Dealer or Representative Registration
Futures or Commodity Registration
.......................................................................... 16
................................................................................................ 16
Material Relationships Maintained by this Advisory Business and Conflicts of
Interest
............................................................................................................................................................... 16
Recommendations or Selections of Other Investment Advisors and Conflicts of
Interest
Item 11: Code of Ethics, Participation or Interest in Client Transactions
............................................................................................................................................................... 17
and Personal Trading .................................................................................................................. 17
Code of Ethics Description
..................................................................................................................... 17
Investment Recommendations Involving a Material Financial Interest and
Conflict of Interest
...................................................................................................................................... 18
Advisory Firm Purchase of Same Securities Recommended to Clients and
Conflicts of Interest
.................................................................................................................................... 18
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
Item 12: Brokerage Practices .................................................................................................. 19
.................................................................... 18
Factors Used to Select Broker-Dealers for Client Transactions
Directed Brokerage
..................................... 19
Best Execution
..................................................................................................................................... 22
Soft Dollar Arrangements
............................................................................................................................................... 23
Aggregating Securities Transactions for Client Accounts
...................................................................................................................... 23
Item 13: Review of Accounts .................................................................................................... 24
.................................................. 23
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Review of Client Accounts on a Non-Periodic Basis
.......................................................................................................................................... 24
Content of Client Provided Reports and Frequency
............................................................... 24
Item 14: Client Referrals and Other Compensation .................................................. 24
............................................................... 24
Economic Benefits Provided to the Advisory Firm from External Sources and
Conflicts of Interest
Advisory Firm Payments for Client Referrals
.................................................................................................................................... 24
........................................................................... 25
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Item 15: Custody .............................................................................................................................. 25
Account Statements
Item 16: Investment Discretion .............................................................................................. 26
.................................................................................................................................... 25
Discretionary Authority for Trading
Item 17: Voting Client Securities .......................................................................................... 26
................................................................................................ 26
Proxy Votes
Item 18: Financial Information .............................................................................................. 26
...................................................................................................................................................... 26
Balance Sheet
................................................................................................................................................. 26
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to
Meet Commitments to Clients
Bankruptcy Petitions during the Past Ten Years
............................................................................................................. 27
Brochure Supplement (Part 2B of Form ADV) ............................................................. 29
.................................................................... 27
Principal Executive Officer - Ryan Eugene Craner
Item 2 Educational Background and Business Experience
................................................................ 29
Item 3 Disciplinary Information
............................................... 29
Item 4 Other Business Activities
......................................................................................................... 29
Item 5 Additional Compensation
....................................................................................................... 29
Item 6 Supervision
....................................................................................................... 29
Brochure Supplement (Part 2B of Form ADV) ............................................................. 32
...................................................................................................................................... 29
William Jeffrey Draper (“Jeff”)
Item 2 Educational Background and Business Experience
............................................................................................................ 32
Item 3 Disciplinary Information
............................................... 32
Item 4 Other Business Activities
......................................................................................................... 32
Item 5 Additional Compensation
....................................................................................................... 33
Item 6 Supervision
....................................................................................................... 33
Brochure Supplement (Part 2B of Form ADV) ............................................................. 35
...................................................................................................................................... 33
Principal Executive Officer - John Michael Park
Item 2 Educational Background and Business Experience
..................................................................... 35
Item 3 Disciplinary Information
............................................... 35
Item 4 Other Business Activities
......................................................................................................... 35
Item 5 Additional Compensation
....................................................................................................... 35
Item 6 Supervision
....................................................................................................... 35
...................................................................................................................................... 35
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Brochure Supplement (Part 2B of Form ADV) ............................................................. 37
Thomas James Craner
Item 2 Educational Background and Business Experience
.............................................................................................................................. 37
Item 3 Disciplinary Information
............................................... 37
Item 4 Other Business Activities
......................................................................................................... 37
Item 5 Additional Compensation
....................................................................................................... 38
Item 6 Supervision
....................................................................................................... 38
Brochure Supplement (Part 2B of Form ADV) ............................................................. 40
...................................................................................................................................... 38
Alexander G. Craner
Item 2 Educational Background and Business Experience
.................................................................................................................................. 40
Item 3 Disciplinary Information
............................................... 40
Item 4 Other Business Activities
......................................................................................................... 40
Item 5 Additional Compensation
....................................................................................................... 41
Item 6 Supervision
....................................................................................................... 41
PRIVACY POLICY NOTICE ...................................................................................................... 42
...................................................................................................................................... 41
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Item 4: Advisory Business
Firm Description
Strategic Planning Group, LLC doing business as Strategic Planning Group was
formed as a Registered Investment Advisor in August 1999. Ryan Craner is the
principal owner.
Strategic Planning Group is a fee-based financial planning and investment
management firm. Investment Advisor Representatives of Strategic Planning
Group also offer insurance products and services as independent insurance agents.
Strategic Planning Group does not act as a custodian of Client assets.
An evaluation of each Client's initial situation is provided to the Client, often in the
form of a net worth statement, risk analysis, or similar document. Periodic reviews
are also communicated to provide reminders of the specific courses of action that
need to be taken. More frequent reviews occur but are not necessarily
communicated to the Client unless immediate changes are recommended.
Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents,
etc.) are engaged directly by the Client on an as-needed basis and may charge fees
of their own. Conflicts of interest will be disclosed to the Client in the event they
should occur.
Types of Advisory Services
Asset Management Services: Strategic Planning Group offers discretionary
direct asset management services to advisory Clients. Strategic Planning Group will
offer Clients ongoing portfolio management services by determining individual
investment goals, time horizons, objectives, and risk tolerance. Investment
strategies, investment selection, asset allocation, portfolio monitoring, and the
overall investment program will be based on the above factors.
Discretionary: When the Client provides Strategic Planning Group discretionary
authority the Client will sign a limited trading authorization or equivalent.
Strategic Planning Group will have the authority to execute transactions in the
account without seeking Client approval on each transaction.
Strategic Planning Group will customize an investment portfolio for the Client
according to the Client’s risk tolerance, investment objectives, and other factors as
described above or Strategic Planning Group will invest the Client’s assets
according to one or more model portfolios developed by Strategic Planning Group
and/or other registered investment advisers. Once the investment portfolio is
constructed or a model portfolio developed by Strategic Planning Group or a third
party is selected, Strategic Planning Group will monitor the Client’s portfolio
performance on an ongoing basis and will rebalance the portfolio as indicated by
changes in market conditions and the Client’s stated financial circumstances as
communicated to and as updated from time to time by the Client to Strategic
Planning Group. Additionally, from time to time we may also use third-party
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managers or separately managed account providers available through the account
custodian’s platform. Clients will provide discretion for those SMA managers to
manage a portion or all of the assets under our supervision for a separate and
additional fee.
In the Asset Management Agreement between the Client and Strategic Planning
Group, the Client will also grant Strategic Planning Group full discretion to hire
Sub-Advisors to manage all or a portion of the assets in the Client account(s).
Strategic Planning Group will be responsible for the overall direct relationship with
the Client. As such, Strategic Planning Group will have full authority to further
delegate such discretionary authority to selected Sub-Advisors to actively manage
the Client’s portfolio and execute trades on behalf of Strategic Planning Group in
Client accounts. Sub-Advisors will maintain the models or investment strategies
agreed upon between Sub-Advisor and Strategic Planning Group. Additionally, at
Strategic Planning Group’s discretion, Strategic Planning Group may grant such
Sub-Advisors full authority to further delegate such discretionary investment
authority to other investment advisers and service providers. Strategic Planning
Group retains the authority to terminate the Sub-Advisor relationship at Strategic
Planning Group’s discretion and/or to reallocate the Client’s assets to other Sub-
Advisors where Strategic Planning Group deems such action to be appropriate and
suitable for the Client.
When Strategic Planning Group engages a Sub-Adviser, the Client will be provided
with a current copy of the Sub-Advisor’s Form ADV Brochure, and associated
disclosure documents prior to or at the time the Sub-Advisor begins providing
services to the Client’s account on behalf of Strategic Planning Group. Such
documents provide important disclosures and other information about the Sub-
Adviser to help the Client understand the scope of the Sub-Advisory services to be
provided.
ERISA Plan Services: Strategic Planning Group provides service to qualified
retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing
plans, cash balance plans, and deferred compensation plans. Strategic Planning
Group may act as either a 3(21) or 3(38) advisor:
Limited Scope ERISA 3(21) Fiduciary: Strategic Planning Group may serve as a
limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors
with their investment decisions. As an investment advisor Strategic Planning
Group has a fiduciary duty to act in the best interest of the Client. The plan sponsor
is still ultimately responsible for the decisions made in their plan, though using
Strategic Planning Group can help the plan sponsor delegate liability by following a
diligent process.
1. Fiduciary Services are:
• Provide investment advice to the Client about asset classes and investment
alternatives available for the Plan in accordance with the Plan’s investment
policies and objectives. The Client will make the final decision regarding the
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initial selection, retention, removal, and addition of investment options.
Strategic Planning Group acknowledges that it is a fiduciary as defined in
ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement
(“IPS”). The IPS establishes the investment policies and objectives for the
Plan. The Client shall have the ultimate responsibility and authority to
establish such policies and objectives and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of
a qualified default
investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make
investment elections. The Client retains the sole responsibility to provide all
notices to the Plan participants required under ERISA Section 404(c) (5) and
404(a)-5.
investment performance, consistency of
• Assist in monitoring investment options by preparing periodic investment
fund
reports that document
management, and conformance to the guidelines set forth in the IPS and
make recommendations to maintain, remove or replace investment options.
• Meet with the Client on a periodic basis to discuss the reports and the
investment recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment
information and the investment alternatives available to them under the
Plan. The Client understands Strategic Planning Group’s assistance in
education of the Plan participants shall be consistent with and within the
scope of the Department of Labor’s definition of investment education
(Department of Labor Interpretive Bulletin 96-1). As such, Strategic
Planning Group is not providing fiduciary advice as defined by ERISA
3(21)(A)(ii) to the Plan participants. Strategic Planning Group will not
provide investment advice concerning the prudence of any investment option
or combination of investment options for a particular participant or
beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
financial
the employees and
investment and
participation among
understanding by the employees.
Strategic Planning Group may provide these services or, alternatively, may arrange
for the Plan’s other providers to offer these services, as agreed upon between
Strategic Planning Group and the Client.
3. Strategic Planning Group has no responsibility to provide services related to the
following types of assets (“Excluded Assets”):
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• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts
and similar vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to Strategic
Planning Group on the ERISA Agreement. Specific services will be outlined in
detail to each plan in the 408(b)2 disclosure.
ERISA 3(38) Investment Manager: Strategic Planning Group can also act as an
ERISA 3(38) Investment Manager in which it has discretionary management and
control of a given retirement plan’s assets. Strategic Planning Group would then
become solely responsible and liable for the selection, monitoring, and replacement
of the plan’s investment options.
1. Fiduciary Services are:
• Strategic Planning Group has discretionary authority and will make the final
decision regarding the initial selection, retention, removal, and addition of
investment options in accordance with the Plan’s investment policies and
objectives.
• Assist the Client with the selection of a broad range of investment options
consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Client in the development of an investment policy statement
(“IPS”). The IPS establishes the investment policies and objectives for the
Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to
the selection of a qualified default investment alternative for participants
who are automatically enrolled in the Plan or who have otherwise failed to
make investment elections. The Client retains the sole responsibility to
provide all notices to the Plan participants required under ERISA Section
404(c) (5).
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment
information and the investment alternatives available to them under the
Plan. The Client understands the Strategic Planning Group’s assistance in
the education of the Plan participants shall be consistent with and within the
scope of the Department of Labor’s definition of investment education
(Department of Labor Interpretive Bulletin 96-1). As such, the Strategic
Planning Group is not providing fiduciary advice as defined by ERISA to the
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Plan participants. Strategic Planning Group will not provide investment
advice concerning the prudence of any investment option or combination of
investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
financial
the employees and
investment and
participation among
understanding by the employees.
Strategic Planning Group may provide these services or, alternatively, may arrange
for the Plan’s other providers to offer these services, as agreed upon between
Strategic Planning Group and the Client.
3. Strategic Planning Group has no responsibility to provide services related to the
following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts
and similar vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to the Adviser on
the ERISA Agreement. Specific services will be outlined in detail to each plan in the
408(b)2 disclosure
Qualified Plan Consulting Services: Strategic Planning Group offers qualified
plan consulting services to individuals on an ongoing basis to current Clients.
Strategic Planning Group will meet with the Client for information gathering.
Strategic Planning Group will review the investment options available within the
plan and then make investment recommendations to the Client based on the
investment options available and the Client’s financial objectives in a face-to-face
meeting.
Financial Planning and Consulting Services: Strategic Planning Group offers
financial planning and consulting services to individuals. Services include but are
not limited to a thorough review of all applicable topics including Wills, Estate
Plans/Trusts, Investments, Taxes, and Insurance. A conflict of interest exists
between the interests of the investment advisor and the interests of the Client. The
Client is under no obligation to act upon the investment advisor’s recommendation.
If the Client elects to act on any of the recommendations, the Client is under no
obligation to effect the transaction through Strategic Planning Group.
Variable Annuity Management: Strategic Planning Group offers discretionary
direct asset management services to advisory Clients on their variable annuities
and variable life products. Strategic Planning Group will work with individuals to
assemble an appropriate portfolio of investment options as provided through the
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insurance company that services variable annuity investment. The accounts will be
monitored on an annual basis.
Seminars and Workshops Services: Strategic Planning Group holds seminars
and workshops to educate Clients on different types of investments and the
different services they offer. The seminars are educational in nature and no specific
investment or tax advice is given. Seminars are conducted at the discretion of
Strategic Planning Group.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each Client are documented in our Client files.
Investment strategies are created that reflect the stated goals and objectives.
Clients may impose restrictions on investing in certain securities or types of
securities. However, restrictions on specific securities, sectors, types of securities, or
allocations may not be possible in third-party programs or models; therefore, you
may not be able to participate in certain models or Sub-Advisory programs.
Agreements may not be assigned without written Client consent.
Wrap Fee Programs
Strategic Planning Group does not sponsor any wrap fee programs.
Client Assets under Management
As of August 8, 2025, Strategic Planning Group had approximately $813,369,866 in
Client assets under management on a discretionary basis and $0 Client assets
under management on a non-discretionary basis.
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
Asset Management Services Fees: Strategic Planning Group offers discretionary
asset management services to advisory Clients. Fees for these services will be based
on a percentage of the Client’s Assets Under Management. Strategic Planning
Group’s annual fee is negotiable; accounts within the same household may be
combined for a reduced fee. The advisory fees are:
Assets Under Management
Up to $250,000
$250,001 to $1,000,000
$1,000,001 and Above
Annual Fee*
1.75%
1.55%
1.35%
*If Strategic Planning Group selects a Sub-advisor for the Client’s account or
portion of the account, the Sub-Adviser’s fee will be paid from the annual fee paid to
Strategic Planning Group. Where SMA managers are used the total combined fee
will not exceed 2.5%. Lower fees may be available through other firms that do not
use SMA managers.
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Fees are billed monthly in advance. The fee will be calculated using the total
market value of the assets in the Client’s account as of the last business day of the
previous month. Monthly advisory fees deducted from the Client's account(s) by the
custodian will be reflected in the custodial statement. Lower fees for comparable
services may be available from other sources.
Clients may terminate their Asset Management Agreement within five (5) business
days of signing without penalty and with a full refund. Thereafter, either the Client
or Strategic Planning Group may terminate the Asset Management Agreement with
thirty (30) days written notice to the other party. The Client is entitled to a pro rata
refund based on the days service was not provided in the final month. Client shall
be given thirty (30) days prior written notice of any increase in fees, and Client will
acknowledge, in writing, any agreement of increase in said fees.
ERISA Plan Services: The annual fees are based on the market value of the
Included Assets and will not exceed 1.5%. The annual fee is negotiable and will be
charged as a percentage of the Included Assets. Fees may be charged quarterly or
monthly in arrears or in advance based on the assets as calculated by the custodian
or record keeper of the Included Assets (without adjustments for anticipated
withdrawals by Plan participants or other anticipated or scheduled transfers or
distribution of assets). If the services to be provided start any time other than the
first day of a quarter or month, the fee will be prorated based on the number of days
remaining in the quarter or month. If this Agreement is terminated prior to the end
of the billing cycle, Strategic Planning Group shall be entitled to a prorated fee
based on the number of days during the fee period services were provided or the
Client will be due a prorated refund of fees for days services were not provided in
the billing cycle.
The fee schedule, which includes compensation of Strategic Planning Group for the
services is described in detail in Schedule A of the ERISA Plan Agreement. The
Plan is obligated to pay the fees; however, the Plan Sponsor may elect to pay the
fees. Client may elect to be billed directly or have fees deducted from Plan Assets.
Strategic Planning Group does not reasonably expect to receive any additional
compensation, directly or indirectly, for its services under this Agreement. If
additional compensation is received, Strategic Planning Group will disclose this
compensation, the services rendered, and the payer of compensation. Strategic
Planning Group will offset the compensation against the fees agreed upon under the
Agreement.
Qualified Plan Consulting Services Fees: Strategic Planning Group does not
charge an additional fee for this service. Qualified Plan Consulting Services are only
offered to current Clients of Strategic Planning Group who are utilizing other
services.
Financial Planning and Consulting Services Fees: Strategic Planning Group
intends to be compensated for financial planning and consulting services by
charging fees on either an hourly basis of $150 or fixed fee basis of $1,000. Strategic
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Planning Group fees will be negotiated in advance and will be set out in each
Client’s advisory contract. Payment in full is due upon commencement of the
planning process. Completed plans are delivered inside of sixty (60) days. Clients
may request to terminate their advisory contract with Strategic Planning Group, in
whole or in part, by giving written notice. Upon termination, any fees paid in
advance will be prorated to the date of termination and any excess will be refunded
to the Client.
Variable Annuity Management: The fees for these services will be based on a
percentage of Assets Under Management and will not exceed an annual fee of 1.5%
of the assets managed. Fees will be disclosed prior to the Client signing the
Investment Advisory Agreement.
Strategic Planning Group’s fees are billed monthly in advance based on the amount
of assets managed as of the close of business on the last business day of the previous
month. Monthly advisory fees will be paid in the following ways:
• Deducted from Client’s annuity account
• Deducted from another of the client’s non-qualified account(s) managed by
Strategic Planning Group
The annual fee may be negotiable based upon certain criteria (e.g., historical
relationship, type of assets, anticipated future earning capacity, anticipated future
additional assets, dollar amounts of assets to be managed, related accounts, account
composition, negotiations with Clients, etc.). Accounts within the same household
may be combined for a reduced fee. Lower fees for comparable services may be
available from other sources. Clients may terminate their account within five (5)
business days of signing the Investment Advisory Agreement with no obligation and
without penalty. Clients may terminate advisory services with thirty (30) days
written notice. Client will be entitled to a pro rata refund for the days service was
not provided in the final billing period. Client shall be given thirty (30) days prior
written notice of any increase in fees, and Client will acknowledge, in writing, any
agreement of increase in said fees.
Seminars and Workshops Services: Strategic Planning Group does not charge a
fee for attendance to seminars and/or workshops.
Client Payment of Fees
Investment management fees are billed monthly in advance. Fees are usually
deducted from a designated Client account to facilitate billing. The Client must
consent in advance to direct debiting of their investment account.
ERISA services fees are billed monthly or quarterly, in advance, or in arrears. The
Client must consent in advance to direct debiting of their investment account.
Fees for financial plans are due at the commencement of the planning process.
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Additional Client Fees Charged
Custodians may charge asset-based fees or transaction fees on purchases or sales of
certain mutual funds, equities, bonds, options, and exchange-traded funds. These
charges may include mutual fund transaction fees, postage, and handling fees.
For our Client accounts maintained in Fidelity’s custody, Fidelity is compensated by
account holders through asset-based fees for securities trades that are executed
through Fidelity or that settle into Fidelity accounts. These annual fees will be
based on either .06% of assets or $100, whichever is greater.
Strategic Planning Group, in its sole discretion, may waive its minimum fee and/or
charge a lesser investment advisory fee based upon certain criteria (e.g., historical
relationship, type of assets, anticipated future earning capacity, anticipated future
additional assets, dollar amounts of assets to be managed, related accounts, account
composition, negotiations with Clients, etc.).
For more details on the brokerage practices, see Item 12 of this brochure.
Prepayment of Client Fees
Investment management and Variable Annuity fees and Financial Planning and
Consulting fees are due in advance. Upon termination, any fees paid in advance will
be prorated to the date of termination and any excess will be refunded to the Client.
External Compensation for the Sale of Securities to Clients
Strategic Planning Group does not receive any external compensation for the sale of
securities to Clients, nor do any affiliates of Strategic Planning Group.
External Compensation for the Sale of Insurance Products to Clients
Certain Executive officers and other Associated Persons of our firm are licensed as
independent
insurance agents. These persons will earn commission-based
compensation for selling insurance products, including insurance products they sell
to our clients. Insurance commissions earned by these persons are separate from
and in addition to our advisory fees. The sale of insurance instruments and other
commissionable products offered by Associated Persons are intended to complement
our advisory services. However, 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. We address this
conflict of interest by recommending insurance products only where we, in good
faith, believe that it is appropriate for the client’s particular needs and
circumstances and only after a full presentation of the recommended insurance
product to our client. In addition, we explain the insurance underwriting process to
our clients to illustrate how the insurer also reviews the client’s application and
disclosures prior to the issuance of a resulting insuring agreement. Clients to whom
the firm offers advisory services are informed that they are under no obligation to
purchase insurance services. Clients who do choose to purchase insurance services
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are under no obligation to use our licensed Associated Persons and may use any
insurance agent or provider they choose.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of
managed securities.
Strategic Planning Group does not use a performance-based fee structure because of
the conflict of interest. Performance-based compensation may create an incentive
for the adviser to recommend an investment that may carry a higher degree of risk
to the Client.
Item 7: Types of Clients
Description
Strategic Planning Group generally provides investment advice to individuals, high-
net-worth individuals, corporations, or business entities. Client relationships vary
in scope and length of service.
Account Minimums
Strategic Planning Group requires an account minimum of $25,000 for asset
management services. Strategic Planning Group may waive this minimum at their
discretion based on circumstances such as Client relationships.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods may include technical analysis and cyclical analysis.
Investing in securities involves the risk of loss that Clients should be prepared to
bear. Past performance is not a guarantee of future returns.
Technical analysis involves evaluating securities based on past prices and volume.
Cyclical analysis involves analyzing the cycles of the market.
In developing a financial plan for a Client, Strategic Planning Group’s analysis may
include cash flow analysis, investment planning, risk management, tax planning,
and estate conservation. Based on the information gathered, a detailed strategy is
tailored to the Client’s specific situation.
The main sources of information include financial newspapers and magazines,
research material prepared by others, corporate rating services, annual reports,
prospectuses, filings with the Securities and Exchange Commission, and company
press releases.
Investment Strategy
The investment strategy for a specific Client is based on the objectives stated by the
Client during consultations. The Client may change these objectives at any time.
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Each Client executes an Investment Policy Statement or Risk Tolerance that
documents their objectives and their desired investment strategy.
Other strategies may include long-term purchases, short-term purchases, and
trading.
Security Specific Material Risks
All investment programs have certain risks that are borne by the investor. Risks
involved in technical analysis are inflation risk, reinvestment risk, and market risk.
Cyclical analysis involves inflation risk, market risk, and currency risk.
Our investment approach constantly keeps the risk of loss in mind. Investors face
the following investment risks and should discuss these risks with Strategic
Planning Group:
Market Risk: The price of a security, bond, or mutual fund may drop in
reaction to tangible and intangible events and conditions. This type of risk is
caused by external factors independent of a security’s particular underlying
circumstances. For example, political, economic, and social conditions may
trigger market events.
Inflation Risk: When any type of inflation is present, a dollar today will buy
more than a dollar next year, because purchasing power is eroding at the rate
of inflation.
Currency Risk: Overseas investments are subject to fluctuations in the value
of the dollar against the currency of the investment’s originating country.
This is also referred to as exchange rate risk.
Reinvestment Risk: This is the risk that future proceeds from investments
may have to be reinvested at a potentially lower rate of return (i.e. interest
rate). This primarily relates to fixed income securities.
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.
Management Risk: The advisor’s investment approach may fail to produce the
intended results. If the advisor’s assumptions regarding the performance of a
specific asset class or fund are not realized in the expected time frame, the
overall performance of the Client’s portfolio may suffer.
limited markets, product
lines,
financial resources, and
Equity Risk: Equity securities tend to be more volatile than other investment
choices. The value of an individual mutual fund or ETF can be more volatile
than the market as a whole. This volatility affects the value of the Client’s
overall portfolio. Small and mid-cap companies are subject to additional risks.
Smaller companies may experience greater volatility, higher failure rates,
more
less
management experience than larger companies. Smaller companies may also
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have a lower trading volume, which may disproportionately affect their
market price, tending to make them fall more in response to selling pressure
than is the case with larger companies.
Fixed Income Risk: The issuer of a fixed income security may not be able to
make interest and principal payments when due. Generally, the lower the
credit rating of a security, the greater the risk that the issuer will default on
its obligation. If a rating agency gives a debt security a lower rating, the
value of the debt security will decline because investors will demand a higher
rate of return. As nominal interest rates rise, the value of fixed income
securities held by a fund is likely to decrease. A nominal interest rate is the
sum of a real interest rate and an expected inflation rate.
Investment Companies Risk: When a Client invests in open-end mutual funds
or ETFs, the Client indirectly bears their proportionate share of any fees and
expenses payable directly by those funds. Therefore, the Client will incur
higher expenses, which may be duplicative. In addition, the Client’s overall
portfolio may be affected by losses of an underlying fund and the level of risk
arising from the investment practices of an underlying fund (such as the use
of derivatives). ETFs are also subject to the following risks: (i) an ETF’s
shares may trade at a market price that is above or below their net asset
value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s
officials deem such action appropriate, the shares are de-listed from the
exchange, or the activation of market-wide “circuit breakers” (which are tied
to large decreases in stock prices) halts stock trading generally. Adviser has
no control over the risks taken by the underlying funds in which Client
invests.
Derivatives Risk: Funds
in a Client’s portfolio may use derivative
instruments. The value of these derivative instruments derives from the
value of an underlying asset, currency, or index. Investments by a fund in
such underlying funds may involve the risk that the value of the underlying
fund’s derivatives may rise or fall more rapidly than other investments, and
the risk that an underlying fund may lose more than the amount that it
invested in the derivative instrument in the first place. Derivative
instruments also involve the risk that other parties to the derivative contract
may fail to meet their obligations, which could cause losses.
terrorism, war, social and economic
Foreign Securities Risk: Funds in which Clients invest may invest in foreign
securities. Foreign securities are subject to additional risks not typically
associated with investments in domestic securities. These risks may include,
among others, currency risks, country risks (political, diplomatic, regional
instability, currency
conflicts,
devaluations, and policies that have the effect of limiting or restricting
foreign investment or the movement of assets), different trading practices,
less government supervision, less publicly available information, limited
trading markets, and greater volatility. To the extent that underlying funds
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invest in issuers located in emerging markets, the risk may be heightened by
political changes, changes in taxation, or currency controls that could
adversely affect the values of these investments. Emerging markets have
been more volatile than the markets of developed countries with more mature
economies.
Long-term purchases: Long-term investments are those vehicles purchased
with the intention of being held for more than one year. Typically the
expectation of the investment is to increase in value so that it can eventually
be sold for a profit. In addition, there may be an expectation for the
investment to provide income. One of the biggest risks associated with long-
term investments is volatility, the fluctuations in the financial markets that
can cause investments to lose value.
Short-term purchases: Short-term investments are typically held for one year
or less. Generally, there is not a high expectation for a return or an increase
in value. Typically, short-term investments are purchased for the relatively
greater degree of principal protection they are designed to provide. Short-
term investment vehicles may be subject to purchasing power risk — the risk
that your investment’s return will not keep up with inflation.
Trading risk: Investing involves risk, including possible loss of principal.
There is no assurance that the investment objective of any fund or
investment will be achieved.
Options Trading: The risks involved with trading options are that they are
very time-sensitive investments. An options contract is generally a few
months. The buyer of an option could lose his or her entire investment even
with a correct prediction about the direction and magnitude of a particular
price change if the price change does not occur in the relevant time period
(i.e., before the option expires). Additionally, options are less tangible than
some other investments. An option is a “book-entry” only investment without
a paper certificate of ownership.
Variable Annuity Risk: A variable annuity is a form of insurance where the
seller or issuer (typically an insurance company) makes a series of future
payments to a buyer (annuitant) in exchange for the immediate payment of a
lump sum (single-payment annuity) or a series of regular payments (regular-
payment annuity). The payment stream from the issuer to the annuitant has
an unknown duration based principally upon the date of death of the
annuitant. At this point, the contract will terminate, and the remainder of
the funds accumulated is forfeited unless there are other annuitants or
beneficiaries in the contract. Annuities can be purchased to provide income
during retirement. Unlike fixed annuities that make payments in fixed
amounts or in amounts that increase by a fixed percentage, variable
annuities, pay amounts that vary according to the performance of a specified
set of investments, typically bond and equity mutual funds. Many variable
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annuities typically impose asset-based sales charges or surrender charges for
withdrawals within a specified period. Variable annuities may impose a
variety of fees and expenses, in addition to sales and surrender charges, such
as mortality and expense risk charges; administrative fees; underlying fund
expenses; and charges for special features, all of which can reduce the return.
Earnings in a variable annuity do not provide all the tax advantages of
401(k)s and other before-tax retirement plans. Once the investor starts
withdrawing money from their variable annuity, earnings are taxed at the
ordinary income rate, rather than at the lower capital gains rates applied to
other non-tax-deferred vehicles which are held for more than one year.
Proceeds of most variable annuities do not receive a "step-up" in cost basis
when the owner dies like stocks, bonds, and mutual funds do. Some variable
annuities offer "bonus credits." These are usually not free. In order to fund
them, insurance companies typically impose mortality and expense charges
and surrender charge periods. In an exchange of an existing annuity for a
new annuity (so-called 1035 exchanges), the new variable annuity may have
a lower contract value and a smaller death benefit; may impose new
surrender charges or increase the period of time for which the surrender
charge applies; may have higher annual fees; and provide another
commission for the broker.
Structured Products Risk: The risks involved with using structured products
include liquidity and the credit risk of the issuing investment bank. The
products themselves are considered to be the issuing financial institution's
liability. During a financial crisis, structured products could possibly lose
principal, similar to the risks associated with options. Structured products
may not be insured by the Federal Deposit Insurance Corporation (FDIC) but
by the issuer itself. If the issuer has liquidity problems or goes bankrupt,
investors may lose the initial investment. There is no uniform pricing
standard which makes it difficult to compare net pricing across multiple
offerings. It is also important to understand that these types of products are
considered complex in nature.
Crytptocurrency Risk: Cryptocurrency (e.g., Bitcoin and Ether), often referred
to as “virtual currency”, “digital currency,” or “digital assets,” is designed to
act as a medium of exchange. Cryptocurrency is an emerging asset class.
There are thousands of cryptocurrencies, the most well-known of which is
Bitcoin. Certain of the firm’s clients may have exposure to bitcoin or another
cryptocurrency, directly or indirectly through an investment such as an ETF
or other investment vehicles. Cryptocurrency operates without central
authority or banks and is not backed by any government. Cryptocurrencies
may experience very high volatility and related investment vehicles may be
affected by such volatility. As a result of holding cryptocurrency, certain of
the firm’s clients may also trade at a significant premium or discount to NAV.
Cryptocurrency is also not legal tender. Federal, state or foreign governments
may restrict the use and exchange of cryptocurrency, and regulation in the
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U.S. is still developing. The market price of many cryptocurrencies, including
bitcoin, has been subject to extreme fluctuations. If cryptocurrency markets
continue to be subject to sharp fluctuations, investors may experience losses
if the value of the client’s investments decline. Similar to fiat currencies (i.e.,
a currency that is backed by a central bank or a national, supra-national or
quasi-national organization), cryptocurrencies are susceptible to theft, loss
and destruction. Cryptocurrency exchanges and other trading venues on
which cryptocurrencies trade are relatively new and, in most cases, largely
unregulated and may therefore be more exposed to fraud and failure than
established, regulated exchanges for securities, derivatives and other
currencies. The SEC has issued a public report stating U.S. federal securities
laws require treating some digital assets as securities.
Cryptocurrency exchanges may stop operating or permanently shut down due
to fraud, technical glitches, hackers or malware. Due to relatively recent
launches, most cryptocurrencies have a limited trading history, making it
difficult for investors to evaluate investments. Generally, cryptocurrency
transactions are irreversible such that an improper transfer can only be
undone by the receiver of the cryptocurrency agreeing to return the
cryptocurrency to the original sender. Digital assets are highly dependent on
their developers and there is no guarantee that development will continue or
that developers will not abandon a project with little or no notice. Third
parties may assert intellectual property claims relating to the holding and
transfer of digital assets, including cryptocurrencies, and their source code.
Any threatened action that reduces confidence in a network’s long-term
ability to hold and transfer cryptocurrency may affect investments in
cryptocurrencies.
Many significant aspects of the U.S. federal income tax treatment of
investments in cryptocurrency are uncertain, and investing in cryptocurrency
may produce income that is not treated as qualifying income for purposes of
the income test applicable to regulated investment companies. Certain
cryptocurrency investments may be treated as a grantor trust for U.S. federal
income tax purposes, and an investment by the firm’s clients in such a vehicle
will generally be treated as a direct investment in cryptocurrency for tax
purposes and “flow-through” to the underlying investors.
Selection of Third-Party Models and Sub-Advisors
In the event Strategic Planning Group selects a Sub-Advisor or third-party model
for the management of all or a portion of the Client’s assets, Strategic Planning
Group will allocate the Client’s assets among various classes of securities, Sub-
Advisors, or managed model portfolios. If there is a significant deviation in
characteristics or performance from the stated strategy and/or benchmark, we may
recommend changing models or replacing a Sub-Advisor or model. The primary risk
associated with reliance on a Sub-Advisor is that while a particular Sub-Advisor
may have demonstrated a certain level of success in the past; it may not be able to
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replicate that success in future markets. In addition, as we do not control the
underlying investments in third-party model portfolios, there is also a risk that a
Sub-Advisor may deviate from the stated investment mandate or strategy of the
portfolio, making it a less suitable investment for our Clients. To mitigate this risk,
we seek Sub-Advisors with proven track records that have demonstrated a
consistent level of performance and success over time. A Sub-Advisors’ past
performance is not a guarantee of future results and certain market and economic
risks exist that may adversely affect an account’s performance that could result in
capital losses in your account. Please refer to the Sub-Advisor’s Form ADV
Brochure, and associated disclosure documents for details on their specific
investment strategies, methods of analysis, and associated risks.
Additionally, our investment committee may use the services of an independent,
outside portfolio consultant help review and propose adjustments for our portfolios.
Item 9: Disciplinary Information
Criminal or Civil Actions
Strategic Planning Group and its management have not been involved in any
criminal or civil action.
Administrative Enforcement Proceedings
Strategic Planning Group and its management have not been involved in
administrative enforcement proceedings.
Self-Regulatory Organization Enforcement Proceedings
Strategic Planning Group and its management have not been involved in legal or
disciplinary events related to past or present investment Clients.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Strategic Planning Group is not registered as a Broker-Dealer and no affiliated
persons of Strategic Planning Group are registered representatives of a Broker-
Dealer.
Futures or Commodity Registration
Neither Strategic Planning Group nor its employees are registered or have an
application pending to register as a futures commission merchant, commodity pool
operator, or commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts
of Interest
As disclosed above in Item 5, Investment Advisor Representatives of Strategic
Planning Group are also licensed as independent insurance agents.
This practice represents a conflict of interest because it gives Investment Advisor
Representatives an incentive to recommend products based on the commission
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amount received. This conflict is mitigated by the fact that Investment Advisor
Representatives have a fiduciary responsibility to place the best interest of the
Client first and the Clients are not required to purchase any recommended
insurance products. Moreover, if Clients choose to purchase insurance products,
they have the option to purchase insurance products through any insurance agent
or provider they choose.
Recommendations or Selections of Other Investment Advisors and
Conflicts of Interest
Strategic Planning Group may also utilize the services of a Sub-Advisor to manage
Clients’ investment portfolios. Sub-Advisors will maintain the models or investment
strategies agreed upon between Sub-Advisor and Strategic Planning Group. Sub-
Advisors execute all trades on behalf of Strategic Planning Group in Client
accounts. Strategic Planning Group will be responsible for the overall direct
relationship with the Client. Strategic Planning Group retains the authority to
terminate the Sub-Advisor relationship at Strategic Planning Group’s discretion.
In addition to the authority granted to Strategic Planning Group, Clients will grant
Strategic Planning Group full discretionary authority and authorizes Strategic
Planning Group to select and appoint one or more independent investment advisors
(“Advisors”) to provide investment advisory services to Client without prior
consultation with or the prior consent of Client. Such Advisors shall have all of the
same authority relating to the management of Client’s investment accounts as is
granted to Strategic Planning Group in the Agreement. In addition, at Strategic
Planning Group’s discretion, Strategic Planning Group may grant such Advisors full
authority to further delegate such discretionary investment authority to additional
Advisors. Strategic Planning Group ensures that before selecting other advisors for
Client that the other advisors are properly licensed or registered as investment
advisors.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics Description
The employees of Strategic Planning Group have committed to a Code of Ethics
(“Code”). The purpose of our Code is to set forth standards of conduct expected of
Strategic Planning Group employees and address conflicts that may arise. The Code
defines acceptable behavior for employees of Strategic Planning Group. The Code
reflects Strategic Planning Group and its supervised persons’ responsibility to act in
the best interest of their Client.
One area the Code addresses is when employees buy or sell securities for their
personal accounts and how to mitigate any conflict of interest with our Clients. We
do not allow any employees to use non-public material information for their
personal profit or to use internal research for their personal benefit in conflict with
the benefit to our Clients.
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Strategic Planning Group policy prohibits any person from acting upon or otherwise
misusing non-public or inside information. No advisory representative or other
employee, officer, or director of Strategic Planning Group may recommend any
transaction in a security or its derivative to advisory Clients or engage in personal
securities transactions for a security or its derivatives if the advisory representative
possesses material, non-public information regarding the security.
Strategic Planning Group’s Code is based on the guiding principle that the interests
of the Client are our top priority. Strategic Planning Group’s officers, directors,
advisors, and other employees have a fiduciary duty to our Clients and must
diligently perform that duty to maintain the complete trust and confidence of our
Clients. When a conflict arises, it is our obligation to put the Client’s interests over
the interests of either employees or the company.
The Code applies to “access” persons. “Access” persons are employees who have
access to non-public information regarding any Clients' purchase or sale of
securities, or non-public information regarding the portfolio holdings of any
reportable fund, who are involved in making securities recommendations to Clients,
or who have access to such recommendations that are non-public.
Strategic Planning Group will provide a copy of the Code of Ethics to any Client or
prospective Client upon request.
Investment Recommendations Involving a Material Financial Interest and
Conflict of Interest
Strategic Planning Group and its employees do not recommend to Clients securities
in which there is a material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and
Conflicts of Interest
Strategic Planning Group and its employees may buy or sell securities that are also
held by Clients. In order to mitigate conflicts of interest such as front running,
employees are required to disclose all reportable securities transactions as well as
provide Strategic Planning Group with copies of their brokerage statements.
The Chief Compliance Officer of Strategic Planning Group is Jeff Draper. He
reviews all employee trades each quarter. 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 over employee transactions.
Client Securities Recommendations or Trades and Concurrent Advisory
Firm Securities Transactions and Conflicts of Interest
Strategic Planning Group does not maintain a firm proprietary trading account and
does not have a material financial interest in any securities being recommended.
However, employees may buy or sell the same securities they buy or sell for Clients,
which may pose a conflict of interest with clients. In an effort to uphold our
fiduciary duties to clients, employees’ securities transactions will generally be “last
in” and “last out” for the trading day when trading occurs in close proximity to
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client trades. Front running (trading shortly ahead of clients) is prohibited. Should
a conflict occur because of materiality (e.g., a thinly traded stock), disclosures will
be made to the client(s) at the time of trading. Incidental trading not deemed to be a
conflict (e.g., a purchase or sale that is minimal in relation to the total outstanding
value, and as such would have a negligible effect on the market price) would not be
deemed a material conflict requiring disclosure at the time of trading. Additionally,
employees are required to disclose all reportable securities transactions as well as
provide Strategic Planning Group with copies of their brokerage statements.
The Chief Compliance Officer of Strategic Planning Group is Jeff Draper. He
reviews all employee trades each quarter. 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 over employee transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
Strategic Planning Group requires the use of a particular broker-dealer. Strategic
Planning Group will select appropriate brokers based on a number of factors
including but not limited to their relatively low transaction fees and reporting
ability. Strategic Planning Group relies on its broker to provide its execution
services at the best prices available. Lower fees for comparable services may be
available from other sources. Clients pay for any and all custodial fees in addition to
the advisory fee charged by Strategic Planning Group.
Custodian(s) and Broker(s) We Use
Our firm will not maintain custody of your assets that we manage, although we are
deemed to have custody of your assets if you give us authority to withdraw assets
from your account (see Item 15—Custody, below). Your assets must be maintained
in an account at a “qualified custodian,” generally a broker-dealer, bank, or trust
company, for example. We routinely recommend that our clients use Fidelity
Brokerage Services and/or its affiliates, (collectively “Fidelity”) or Charles Schwab
& Co., Inc. (“Schwab”), both registered broker-dealers, members SIPC, as the
qualified custodian.
We are independently owned and operated and are not affiliated with any broker-
dealer/custodian. Selected broker-dealers/custodians will hold your assets in a
brokerage account and buy and sell securities when we or you instruct them to.
While we recommend that you use a particular broker-dealer/custodian, you will
decide whether to do so and will open your account with the selected firm by
entering into an account agreement directly with them. Conflicts of interest
associated with these arrangements are described below as well as in Item 14
(Client Referrals and Other Compensation). You should consider these conflicts of
interest when selecting your custodian.
We do not open the account for you, although we may assist you in doing so. Not all
advisors require their clients to use a particular broker-dealer or custodian.
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From time-to-time, we nay still use other brokers to execute trades for your account
as described below. Defined benefit or defined contribution plans may be held
elsewhere as selected by the plan sponsor.
How We Select Brokers/Custodians
When considering whether the terms that a broker-dealer/custodian provides are,
overall, most advantageous to you when compared with other available providers
and their services, we take into account a wide range of factors, including:
• Combination of transaction execution services and asset custody services
(generally without a separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your
account)
• Capability to facilitate transfers and payments to and from accounts (wire
transfers, check requests, bill payments, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds,
exchange-traded funds (ETFs), etc.)
• Availability of investment research and tools that assist us in making
investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin
interest rates, other fees, etc.) and willingness to negotiate the prices
• Reputation, financial strength, security and stability
• Prior service to us and our clients
• Services delivered or paid for by Schwab
• Availability of other products and services that benefit us, as discussed below
Your Brokerage and Custody Costs at Schwab
For our clients’ accounts that Schwab maintains, Schwab generally does not charge
you separately for custody services but is compensated by charging you commissions
or other fees on trades that it executes or that settle into your Schwab account.
Certain trades (for example, certain mutual funds and ETFs) do not incur Schwab
commissions or transaction fees. Schwab is also compensated by earning interest on
the uninvested cash in your account in Schwab’s Cash Features Program. In
addition to transaction fees, Schwab charges you a flat dollar amount as a “prime
broker” or “trade away” fee for each trade that we have executed by a different
broker-dealer but where the securities bought or the funds from the securities sold
are deposited (settled) into your Schwab account. These fees are in addition to the
commissions or other compensation you pay the executing broker-dealer. Because of
this, in order to minimize your trading costs, we will have Schwab execute most
trades for your account.
We are not required to select the broker or dealer that charges the lowest
transaction cost, even if that broker provides execution quality comparable to other
brokers or dealers. Although we are not required to execute all trades through
Schwab, we have determined that having Schwab execute most trades is consistent
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with our duty to seek “best execution” of your trades. Best execution means the
most favorable terms for a transaction based on all relevant factors, including those
listed above (see “How We Select Brokers/Custodians”). By using another broker or
dealer you may pay lower transaction costs.
Research and Other Soft Dollar Benefits
Although the following products and services are not purchased with “soft dollar”
credits, we will receive certain economic benefits (soft dollar benefits) from Schwab
in the form of access to Schwab’s institutional brokerage and support services at no
additional cost or a discounted cost. Below is a detailed description of Schwab’s
support services:
Products and Services Available to Us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment
advisory firms like ours. They provide our clients and us with access to their
institutional brokerage services (trading, custody, reporting, and related services),
many of which are not typically available to Schwab retail customers. However,
certain retail investors may be able to get institutional brokerage services from
Schwab without going through us. 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 (we don’t have to request them) and at
no charge to us.
Services that Benefit You: 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 you and your account.
Services that Do Not Directly Benefit You: Schwab also makes available to us
other products and services that benefit us but do not directly benefit you or your
account. These products and services assist us in managing and administering our
clients’ accounts and operating our firm. They include investment research, both
Schwab’s own and that of third parties. We use this research to service all or a
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:
• provide access to client account data (such as duplicate trade confirmations
•
and account statements)
facilitate trade execution and allocate aggregated trade orders for multiple
client accounts
facilitate payment of our fees from our clients’ accounts
• provide pricing and other market data
•
• assist with back-office functions, recordkeeping, and client reporting
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Services that Generally Benefit Only Us: Schwab also offers other services
intended to help us manage and further develop our business enterprise. These
services include:
• Educational conferences and events
• Consulting on technology and business needs
• Consulting on legal and compliance-related needs
• Publications and conferences on practice management and business
succession
• Access to employee benefits providers, human capital consultants, and
insurance providers
• Marketing consulting and support
• Recruiting and custodial search consulting
Schwab provides some of these services itself. In other cases, it will arrange for
third-party vendors to provide the services to us. Schwab also discounts or waives
its fees for some of these services or pays all or a part of a third party’s fees. Schwab
also provides us with other benefits, such as occasional business entertainment for
our personnel. If you did not maintain your account with Schwab, we would be
required to pay for those services from our own resources.
Our firm understands its duty for best execution and considers all factors in making
recommendations to clients. These research services may be useful in servicing all
clients and may not be used in connection with any particular account that may
have paid compensation to the firm providing such services. While we may not
always obtain the lowest commission rate, we believe the rate is reasonable in
relation to the value of the brokerage and research services provided.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to
produce or purchase them. We don’t have to pay for Schwab’s services.
Schwab has also agreed to pay for certain technology, research, marketing, and
compliance consulting products and services on our behalf once the value of our
clients’ assets in accounts at Schwab reaches certain thresholds.
The fact that we receive these benefits from Schwab is an incentive for us to
recommend the use of Schwab rather than making such a decision based exclusively
on your interest in receiving the best value in custody services and the most
favorable execution of your transactions. This is a conflict of interest. We believe,
however, that taken in the aggregate our recommendation of Schwab as custodian
and broker is in the best interests of our clients. Our selection is primarily
supported by the scope, quality, and price of Schwab’s services (see “How We Select
Brokers/Custodians”) and not Schwab’s services that benefit only us.
Directed Brokerage
Strategic Planning Group does not allow Clients to direct brokerage. Not all
advisers require Clients to direct brokerage. By directing brokerage, Strategic
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Planning Group may be unable to achieve most favorable execution of Client
transactions which may cost Clients more money.
Best Execution
Investment advisors who manage or supervise Client portfolios have a fiduciary
obligation of best execution. The determination of what may constitute best
execution and price in the execution of a securities transaction by a broker involves
a number of considerations and is subjective. Factors affecting brokerage selection
include the overall direct net economic result to the portfolios, the efficiency with
which the transaction is effected, the ability to effect the transaction where a large
block is involved, the operational facilities of the broker-dealer, the value of an
ongoing relationship with such broker and the financial strength and stability of the
broker. Strategic Planning Group does not receive any portion of the trading fees.
Soft Dollar Arrangements
The Securities and Exchange Commission defines soft dollar practices as
arrangements under which products or services other than execution services are
obtained by Strategic Planning Group from or through a broker-dealer in exchange
for directing Client transactions to the broker-dealer. As permitted by Section 28(e)
of the Securities Exchange Act of 1934, Strategic Planning Group receives economic
benefits as a result of commissions generated from securities transactions by the
broker-dealer from the accounts of Strategic Planning Group. These benefits include
both proprietary research from the broker and other research written by third
parties.
A conflict of interest exists when Strategic Planning Group receives soft dollars.
This conflict is mitigated by the fact that Strategic Planning Group has a fiduciary
responsibility to act in the best interest of its Clients and the services received are
beneficial to all Clients.
Strategic Planning Group utilizes the services of custodial broker-dealers. Economic
benefits are received by Strategic Planning Group which would not be received if
Strategic Planning Group did not give investment advice to Clients. These benefits
include a dedicated trading desk, a dedicated service group, and an account services
manager dedicated to Strategic Planning Group's accounts, the ability to conduct
"block" Client trades, electronic download of trades, balances, and positions,
duplicate and batched Client statements, and the ability to have advisory fees
directly deducted from Client accounts.
Aggregating Securities Transactions for Client Accounts
Strategic Planning Group does not place block trades (i.e., aggregate trades for
multiple Clients' accounts for an average share price). Therefore, some Clients may
pay higher costs than other Clients may pay for the same securities. Sub-Advisors
may or may not aggregate trades for Client accounts across multiple Client
accounts or models. Please review the relevant Sub-Adviser’s disclosure documents
regarding their policies on trade aggregation.
23
Strategic Planning Group
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and
Advisory Persons Involved
Account reviews are performed quarterly by Investment Advisor Representatives of
Strategic Planning Group. Account reviews are performed more frequently when
market conditions dictate. Financial planning relationships are considered complete
at the delivery of the plan.
Review of Client Accounts on a Non-Periodic Basis
Other conditions that may trigger a review of Clients’ accounts are changes in tax
laws, new investment information, and changes in a Client's own situation.
Content of Client Provided Reports and Frequency
Clients receive written account statements no less than quarterly for managed
accounts. Account statements are issued by Strategic Planning Group’s custodian.
Client receives confirmations of each transaction in the account from the Custodian
and an additional statement during any month in which a transaction occurs.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources
and Conflicts of Interest
Strategic Planning Group from time to time refers Clients to an unaffiliated
attorney for estate planning. The attorney pays Strategic Planning Group a fee for
acting as the “paralegal” and notarizing documents. This presents a conflict of
interest as Strategic Planning Group has an incentive to refer Clients to attorneys
with whom they have such compensation arrangements. However, Clients are not
obligated to use any particular attorney or law firm for legal services and may use
any legal professional they choose.
Strategic Planning Group and its associated persons may receive additional
compensation from product sponsors. However, such compensation will not be tied
to the sales of any products. Compensation could include such items as gifts of a de
minimis value; an occasional dinner or ticket to a sporting event; reimbursement in
connection with educational meetings with an associated person, Client workshops,
or events; or marketing events or advertising initiatives, including services for
identifying prospective Clients. Product sponsors may also pay for or reimburse
Strategic Planning Group for the costs associated with its associate persons
attending various education or training events, as well as Strategic Planning Group
sponsored conferences and events. These practices represent conflicts of interest
because they give Strategic Planning Group an incentive to recommend products
based on the sponsorship amount or other compensation received. These conflicts
are mitigated by disclosures, procedures, and Strategic Planning Group’s fiduciary
obligation to act in the Client’s best interest.
As described in Item 12 above, we receive economic benefits from our custodial
broker-dealer(s) in the form of support products and services they make available to
24
Strategic Planning Group
us and other independent investment advisors whose clients maintain their
accounts at these custodial broker-dealer(s). The availability of custodial products
and services is not dependent upon or based on the specific investment advice we
provide our clients, such as buying or selling specific securities or specific types of
securities for our clients. The products and services provided by the custodial
broker-dealer(s), how they benefit us, and the related conflicts of interest are
described above (see Item 12 – Brokerage Practices).
Advisory Firm Payments for Client Referrals
Strategic Planning Group does not directly or indirectly compensate any person or
entity who is not our supervised person for Client referrals.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide
account statements directly to Clients at their address of record. Clients are urged
to compare the account statements received directly from their custodians to the
performance report statements prepared by Strategic Planning Group.
Strategic Planning Group is deemed to have constructive custody solely because
advisory fees are directly deducted from the Client’s account(s) by the custodian on
behalf of Strategic Planning Group.
Strategic Planning Group is also deemed to have limited custody due to its Third-
Party Standing Letters of Authorization (“SLOA”).
Strategic Planning Group and its qualified custodian meet the following seven (7)
conditions in order to avoid maintaining full custody and be subject to the surprise
exam requirement:
1.
The Client provides an instruction to the qualified custodian, in writing, that
includes the Client’s signature, the third party’s name, and either the third
party’s address or the third party’s account number at a custodian to which
the transfer should be directed.
2.
The Client authorizes Strategic Planning Group, in writing, either on the
qualified custodian’s form or separately, to direct transfers to the third party
either on a specified schedule or from time to time.
3.
The Client’s qualified custodian performs appropriate verification of the
instruction, such as a signature review or other method to verify the Client’s
authorization, and provides a transfer of funds notice to the Client promptly
after each transfer.
The Client has the ability to terminate or change the instruction to the
Client’s qualified custodian.
4.
25
Strategic Planning Group
5.
Strategic Planning Group has no authority or ability to designate or change
the identity of the third party, the address, or any other information about the
third party contained in the Client’s instruction.
6.
Strategic Planning Group maintains records showing that the third party is
not a related party nor located at the same address as Strategic Planning
Group.
The Client’s qualified custodian sends the Client, in writing, an initial notice
confirming the instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Discretionary Authority for Trading
Generally, Clients grant Strategic Planning Group complete discretion over the
selection and amount of securities to be bought or sold for their account (within the
parameters established by their Advisory Agreement) without obtaining their
consent or approval. Strategic Planning Group will allow Clients to place certain
restrictions on accounts which will be handled on a Client-by-Client basis. However,
these purchases may be subject to specified investment objectives and guidelines.
For example, a Client may specify that the investment in any particular stock or
industry should not exceed specified percentages of the value of the portfolio.
Discretionary authority will only be authorized upon full disclosure to the Client
and by that Client specifically authorizing said authority through the execution of
an Investment Advisory Agreement. All discretionary trades made by Strategic
Planning Group on behalf of their discretionary accounts (Clients) will be in
accordance with that Client’s investment objectives and goals.
Item 17: Voting Client Securities
Proxy Votes
Strategic Planning Group does not vote proxies on securities. Clients are expected
to vote their own proxies. The Client will receive their proxies directly from the
custodian of their account or a transfer agent.
When assistance on voting proxies is requested, Strategic Planning Group will
provide recommendations to the Client. If a conflict of interest exists, it will be
disclosed to the Client.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because Strategic Planning Group
does not serve as a custodian for Client funds or securities and Strategic Planning
Group does not require prepayment of fees of more than $1200 per Client and six
months or more in advance.
26
Strategic Planning Group
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability
to Meet Commitments to Clients
Strategic Planning Group has no condition that is reasonably likely to impair our
ability to meet contractual commitments to our Clients.
Bankruptcy Petitions during the Past Ten Years
Neither Strategic Planning Group nor its management has had any bankruptcy
petitions in the last ten years.
27
Strategic Planning Group
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Ryan Eugene Craner
Office Address:
190 South Main Street
Bountiful, UT 84010
Telephone: 801-627-2200
Facsimile: 801-627-2205
RCraner@SPGUtah.com
www.SPGUtah.com
This brochure supplement provides
information about Ryan Craner and
supplements the Strategic Planning Group’s brochure. You should have received a
copy of that brochure. Please contact Ryan Craner if you did not receive the
brochure or if you have any questions about the contents of this supplement.
MARCH 24, 2025
Additional information about Ryan Craner (CRD#1752377) is available on the
SEC’s website at www.adviserinfo.sec.gov.
28
Strategic Planning Group
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer - Ryan Eugene Craner
Year of birth: 1963
Item 2 Educational Background and Business Experience
Business Experience:
Craner Holdings, LLC, Managing Member, 04/2021 - Present
Strategic Capital Enterprises LLC; Managing Member; 12/2015 – 4/2021
Strategic Planning Group; President/Investment Advisor Representative; 08/1999 – Present
Action Recovery Group; Owner; 05/2011 – Present
Purshe Kaplan Sterling Investments, Inc.; Registered Representative; 11/2017 – 01/2022
Ryan E. Craner; Notary Public; 07/1998 – Present
Ryan E. Craner; Independent Insurance Agent; 08/1985 – Present
Capital Concepts Financial Services Corp.; President; 07/1985 – Present
Educational Background:
Weber State University; Finance; 1985 - 1986
Item 3 Disciplinary Information
Criminal or Civil Action: None to report.
Administrative Proceeding: None to report.
Self-Regulatory Proceeding: None to report.
Item 4 Other Business Activities
Ryan Craner has a financial industry affiliated business as an insurance agent. From time to time,
he may offer Clients advice or products from this activity.
This practice represents a conflict of interest because it gives Mr. Craner an incentive to
recommend products based on the commission/fee amount received. This conflict is mitigated by the
fact that Mr. Craner has a fiduciary responsibility to place the best interest of the Client first and
the Clients are not required to purchase any products. Moreover, Clients have the option to
purchase these products through any insurance agent or provider they choose.
In addition, Mr. Craner is the President of Capital Concepts Financial Services, Inc. In this
capacity, he manages the facility and the personnel. Mr. Craner is also the Managing Manager of
Craner Holdings, LLC which is his personal real estate holding company. These relationships
create no conflicts of interest as Clients of Strategic Planning Group will not be solicited for services
offered by Capital Concepts Financial Services, Inc. or Craner Holdings, LLC and vice versa.
Item 5 Additional Compensation
Ryan Craner receives additional compensation in his additional roles, but he does not receive any
performance-based fees.
Item 6 Supervision
As President of Strategic Planning Group, Ryan Craner does not report directly to other persons.
He is responsible for the overall supervision of the firm’s personnel and advisory activities. If you
29
Strategic Planning Group
have questions about the supervision of the firm’s representatives, Mr. Craner can be reached at
rcraner@spgutah.com or 801-627-2200.
The firm has implemented a Code of Ethics and an internal compliance program that guides the
firm and its personnel in complying with applicable state and federal securities laws and in meeting
their fiduciary obligations to Clients. Jeff Draper, the firm’s Chief Compliance Officer is responsible
for the implementation and supervision of the firm’s Code of Ethics and compliance program.
As investment representatives of the firm, both Mr. Craner and Mr. Draper are responsible for
monitoring Client portfolios for investment objectives and other supervisory reviews. If you have
questions or would like to receive a copy of the firm’s Code of Ethics, Mr. Draper can be reached at
jeff@strategicutah.com or 801-627-2200.
30
Strategic Planning Group
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
William J. Draper
Office Address:
190 South Main Street
Bountiful, UT 84010
Telephone: 801-627-2200
Facsimile: 801-627-2205
jeff@strategicutah.com
www.SPGUtah.com
MARCH 24, 2025
This brochure supplement provides information about William J. Draper and
supplements the Strategic Planning Group brochure. You should have received a
copy of that brochure. Please contact William J. Draper if you did not receive the
brochure or if you have any questions about the contents of this supplement.
Additional information about William J. Draper (CRD#4907513) is available on
the SEC’s website at www.adviserinfo.sec.gov.
31
Strategic Planning Group
Brochure Supplement (Part 2B of Form ADV)
Principal Executive Officer
William Jeffrey Draper (“Jeff”)
Year of birth: 1981
Item 2 Educational Background and Business Experience
Business Experience:
Strategic Planning Group; Chief Compliance Officer/Investment Advisor Representative;
06/2021 – Present
Self Employed; Web Administrator/Developer; 06/2021 – 10/2021
Foresight Wealth Management, LLC; 401K Operations; 06/2019 – 05/2021
Utah Retirement Systems; Retirement Planning Advisor; 10/2016 – 06/2019
Educational Background:
University of Utah; Bachelor of Science; Finance; 2007
Item 3 Disciplinary Information
A. Jeff Draper has never been involved in a criminal or civil action in a domestic, foreign or
military court of competent jurisdiction for which he:
1. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b)
misdemeanor that involved investments or an investment-related business, fraud, false
statement or omissions, wrongful taking of property, bribery, perjury, counterfeiting, or
extortion; or (c) a conspiracy to commit any of these offenses;
2. Is the named subject of a pending criminal proceeding that involves an investment-related
business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury,
forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses;
3. Was found to have been involved in a violation of an investment-related statute or
regulation; or
4. Was the subject of any order, judgement or decree permanently or temporarily enjoining, or
otherwise limiting, him from engaging in any investment related activity, or from violating
any investment-related statute, rule, or order.
B. Jeff Draper never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in
which he:
1. Was found to have caused an investment-related business to lose its authorization to do
business; or the subject of an order by the agency or authority;
2. Was found to have been involved in a violation of an investment-related statute or regulation
or was the subject of an order by the agency or authority
(a)denying, suspending or revoking the authorization of the supervised person to act in an
investment-related business; (b) barring or suspending his association with an investment-
related business; (c) otherwise significantly limiting his investment-related activities; or (d)
imposing a civil money penalty of more than $2,500 on him.
C. Jeff Draper has never been the subject of a self-regulatory organization (SRO) proceeding in
which he:
1. Was found to have caused an investment-related business to lose its authorization to do
business; or
32
Strategic Planning Group
2. Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or
suspended from membership or from association with other members, or was expelled from
membership; (b) otherwise significantly limited from investment-related activities; or (c)
fined more than $2,500.
D. Jeff Draper has not been involved in any other hearing or formal adjudication in which a
professional attainment, designation, or license of the supervised person was revoked or
suspended because of a violation of rules relating to professional conduct.
Item 4 Other Business Activities
Mr. Draper has no other business to disclose.
Item 5 Additional Compensation
Mr. Draper does not receive any additional compensation or performance-based fees.
Item 6 Supervision
The firm has implemented a Code of Ethics and an internal compliance program that guides the
firm and its personnel in complying with applicable state and federal securities laws and in meeting
their fiduciary obligations to Clients. As an investment representative of the firm, Jeff Draper is
responsible for monitoring Client portfolios for investment objectives and other supervisory reviews.
As the firm’s Chief Compliance Officer, Mr. Draper is responsible for the implementation and
supervision of the firm’s Code of Ethics and compliance program. Mr. Draper reports directly to Mr.
Ryan Craner, President of Strategic Planning Group. Mr. Craner can be reached at
rcraner@spgutah.com or 801-627-2200.
If you have questions or would like to receive a copy of the firm’s Code of Ethics, Mr. Draper can be
reached at jeff@strategicutah.com or 801-627-2200.
33
Strategic Planning Group
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
John Michael Park
Office Address:
190 South Main Street
Bountiful, UT 84010
Telephone: 801-627-2200
Facsimile: 801-627-2205
John@SPGUtah.com
www.SPGUtah.com
MARCH 24, 2025
This brochure supplement provides information about John Park and supplements
the Strategic Planning Group’s brochure. You should have received a copy of that
brochure. Please contact John Park if you did not receive the brochure or if you
have any questions about the contents of this supplement.
Additional information about John Park (CRD#6166417) is available on the SEC’s
website at www.adviserinfo.sec.gov.
34
Strategic Planning Group
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer - John Michael Park
Year of birth: 1985
Item 2 Educational Background and Business Experience
Business Experience:
Strategic Planning Group; Investment Advisor Representative; 12/2014 – Present
John M. Park, Sole Proprietor; Independent Insurance Agent; 10/2014 – Present
John M. Park, Sole Proprietor; Online Retailer; 01/2021 – Present
Purshe Kaplan Sterling Investments, Inc.; Registered Representative; 11/2017 – 09/2020
Educational Background:
Weber State University; Associates Degree – General Studies; 2011
Item 3 Disciplinary Information
Criminal or Civil Action: None to report.
Administrative Proceeding: None to report.
Self-Regulatory Proceeding: None to report.
Item 4 Other Business Activities
John Park has a financial industry affiliated business as an insurance agent. From time to time, he
may offer Clients advice or products from this activity.
This practice represents a conflict of interest because it gives Mr. Park an incentive to recommend
products based on the fee amount received. This conflict is mitigated by the fact that Mr. Park has
a fiduciary responsibility to place the best interest of the Client first and the Clients are not
required to purchase any products. Clients have the option to purchase these products through
another insurance agent, of their choosing.
Item 5 Additional Compensation
John Park receives additional compensation in his capacity as an insurance agent and online
retailer, but he does not receive any performance-based fees.
Item 6 Supervision
The firm has implemented a Code of Ethics and an internal compliance program that guides the
firm and its personnel in complying with applicable state and federal securities laws and in meeting
their fiduciary obligations to Clients. As an investment representative of the firm, John Park is
responsible for monitoring Client portfolios for investment objectives and other account reviews.
Mr. Park is supervised by Mr. Ryan Craner, President of Strategic Planning Group. Mr. Craner can
be reached at rcraner@spgutah.com or 801-627-2200.
Jeff Draper, the firm’s Chief Compliance Officer is responsible for the implementation and
supervision of the firm’s Code of Ethics and compliance program. If you have questions or would
like to receive a copy of the firm’s Code of Ethics, Mr. Draper can be reached at
jeff@strategicutah.com or 801-627-2200.
35
Strategic Planning Group
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Thomas James Craner
Office Address:
190 South Main Street
Bountiful, UT 84010
Telephone: 801-627-2200
Facsimile: 801-627-2205
tom@spgutah.com
www.SPGUtah.com
MARCH 24, 2025
This brochure supplement provides information about Thomas Craner and
supplements the Strategic Planning Group brochure. You should have received a
copy of that brochure. Please contact Thomas Craner if you did not receive the
brochure or if you have any questions about the contents of this supplement.
Additional information about Thomas James Craner (CRD#6488075) is available
on the SEC’s website at www.adviserinfo.sec.gov.
36
Strategic Planning Group
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Thomas James Craner
Year of birth: 1990
Item 2 Educational Background and Business Experience
Business Experience:
Strategic Planning Group; Investment Advisor Representative; 06/2019 – Present
Thomas Craner, Sole Proprietor; Independent Insurance Agent; 09/2020 – Present
Strategic Planning Group; Operations Manager; 01/2017 – 06/2019
Capital Concepts; Client Services; 01/2017 – 02/2021
Purshe Kaplan Sterling Investments; Registered Representative; 11/2017 – 12/2021
Educational Background:
Conservatory of Recording Arts and Sciences; Certificate of Audio Engineering; 2011
Item 3 Disciplinary Information
A. Thomas Craner has never been involved in a criminal or civil action in a domestic, foreign or
military court of competent jurisdiction for which he:
1. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b)
misdemeanor that involved investments or an investment-related business, fraud, false
statement or omissions, wrongful taking of property, bribery, perjury, counterfeiting, or
extortion; or (c) a conspiracy to commit any of these offenses;
2. Is the named subject of a pending criminal proceeding that involves an investment-related
business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury,
forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses;
3. Was found to have been involved in a violation of an investment-related statute or
regulation; or
4. Was the subject of any order, judgement or decree permanently or temporarily enjoining, or
otherwise limiting, him from engaging in any investment related activity, or from violating
any investment-related statute, rule, or order.
B. Thomas Craner never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in
which he:
1. Was found to have caused an investment-related business to lose its authorization to do
business; or the subject of an order by the agency or authority;
2. Was found to have been involved in a violation of an investment-related statute or regulation
or was the subject of an order by the agency or authority (a)denying, suspending or revoking
the authorization of the supervised person to act in an investment-related business; (b)
barring or suspending his association with an investment-related business; (c) otherwise
significantly limiting his investment-related activities; or (d) imposing a civil money penalty
of more than $2,500 on him.
C. Thomas Craner has never been the subject of a self-regulatory organization (SRO) proceeding in
which he:
1. Was found to have caused an investment-related business to lose its authorization to do
business; or
37
Strategic Planning Group
2. Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or
suspended from membership or from association with other members, or was expelled from
membership; (b) otherwise significantly limited from investment-related activities; or (c)
fined more than $2,500.
D. Thomas Craner has not been involved in any other hearing or formal adjudication in which a
professional attainment, designation, or license of the supervised person was revoked or
suspended because of a violation of rules relating to professional conduct.
Item 4 Other Business Activities
Thomas Craner has a financial industry affiliated business as an insurance agent. From time to
time, he may offer Clients advice or products from this activity.
This practice represents a conflict of interest because it gives Mr. Craner an incentive to
recommend products based on the fee amount received. This conflict is mitigated by the fact that
Mr. Craner has a fiduciary responsibility to place the best interest of the Client first and the
Clients are not required to purchase any products. Clients have the option to purchase these
products through another insurance agent, of their choosing.
Item 5 Additional Compensation
Thomas Craner receives additional compensation in his capacity as an insurance agent, but he does
not receive any performance-based fees.
Item 6 Supervision
The firm has implemented a Code of Ethics and an internal compliance program that guides the
firm and its personnel in complying with applicable state and federal securities laws and in meeting
their fiduciary obligations to Clients. As an investment representative of the firm, Thomas Craner
is responsible for monitoring Client portfolios for investment objectives and other account reviews.
Thomas Craner is supervised by Mr. Ryan Craner, President of Strategic Planning Group. Mr.
Craner can be reached at rcraner@spgutah.com or 801-627-2200.
Jeff Draper, the firm’s Chief Compliance Officer is responsible for the implementation and
supervision of the firm’s Code of Ethics and compliance program. If you have questions or would
like to receive a copy of the firm’s Code of Ethics, Mr. Draper can be reached at
jeff@strategicutah.com or 801-627-2200.
38
Strategic Planning Group
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Alexander G. Craner
Office Address:
190 South Main Street
Bountiful, UT 84010
Telephone: 801-627-2200
Facsimile: 801-627-2205
alex@strategicutah.com
www.SPGUtah.com
MARCH 24, 2025
This brochure supplement provides information about Alexander Craner and
supplements the Strategic Planning Group brochure. You should have received a
copy of that brochure. Please contact Alexander Craner if you did not receive the
brochure or if you have any questions about the contents of this supplement.
Additional information about Alexander Gordon Craner (CRD#7370986) is
available on the SEC’s website at www.adviserinfo.sec.gov.
39
Strategic Planning Group
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Alexander G. Craner
Year of birth: 1996
Item 2 Educational Background and Business Experience
Business Experience:
Strategic Planning Group
o Investment Advisor Representative; 05/2021 – Present
o Client Services/Administrative Assistant; 06/2019 – Present
Alexander Craner, Sole Proprietor; Insurance Agent; 10/2021 – Present
JP Morgan Chase Bank; Lead Teller of Operations; 04/2017 – 05/2019
Full-Time Student; 08/2010 – 05/2019
Educational Background:
Weber State University; Associate of Science Degree-General Studies; 2019
Item 3 Disciplinary Information
A. Alexander Craner has never been involved in a criminal or civil action in a domestic, foreign or
military court of competent jurisdiction for which he:
2.
1. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any felony; (b)
misdemeanor that involved investments or an investment-related business, fraud, false
statement or omissions, wrongful taking of property, bribery, perjury, counterfeiting, or
extortion; or (c) a conspiracy to commit any of these offenses;
Is the named subject of a pending criminal proceeding that involves an investment-
related business, fraud, false statements or omissions, wrongful taking of property,
bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these
offenses;
3. Was found to have been involved in a violation of an investment-related statute or
regulation; or
4. Was the subject of any order, judgement or decree permanently or temporarily enjoining,
or otherwise limiting, him from engaging in any investment related activity, or from
violating any investment-related statute, rule, or order.
B. Alexander Craner never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in
which he:
1. Was found to have caused an investment-related business to lose its authorization to do
business; or the subject of an order by the agency or authority;
2. Was found to have been involved in a violation of an investment-related statute or regulation
or was the subject of an order by the agency or authority
(a)denying, suspending or revoking the authorization of the supervised person to act in an
investment-related business; (b) barring or suspending his association with an investment-
related business; (c) otherwise significantly limiting his investment-related activities; or (d)
imposing a civil money penalty of more than $2,500 on him.
40
Strategic Planning Group
C. Alexander Craner has never been the subject of a self-regulatory organization (SRO) proceeding
in which he:
1. Was found to have caused an investment-related business to lose its authorization to do
business; or
2. Was found to have been involved in a violation of the SRO’s rules and was: (a) barred or
suspended from membership or from association with other members, or was expelled from
membership; (b) otherwise significantly limited from investment-related activities; or (c)
fined more than $2,500.
D. Alexander Craner has not been involved in any other hearing or formal adjudication in which a
professional attainment, designation, or license of the supervised person was revoked or
suspended because of a violation of rules relating to professional conduct.
Item 4 Other Business Activities
Mr. Craner has a financial industry affiliated business as an insurance agent. From time to time,
he may offer Clients advice or products from this activity.
This practice represents a conflict of interest because it gives Mr. Craner an incentive to
recommend products based on the fee amount received. This conflict is mitigated by the fact that
Mr. Craner has a fiduciary responsibility to place the best interest of the Client first and the
Clients are not required to purchase any products. Clients have the option to purchase these
products through another insurance agent, of their choosing.
Item 5 Additional Compensation
Alexander Craner does receive additional compensation in his capacity as an insurance agent. He
does not receive any performance-based fees.
Item 6 Supervision
The firm has implemented a Code of Ethics and an internal compliance program that guides the
firm and its personnel in complying with applicable state and federal securities laws and in meeting
their fiduciary obligations to Clients. As an investment representative of the firm, Alexander
Craner is responsible for monitoring Client portfolios for investment objectives and other account
reviews. Alexander Craner is supervised by Mr. Ryan Craner, President of Strategic Planning
Group. Mr. Craner can be reached at rcraner@spgutah.com or 801-627-2200.
Jeff Draper, the firm’s Chief Compliance Officer is responsible for the implementation and
supervision of the firm’s Code of Ethics and compliance program. If you have questions or would
like to receive a copy of the firm’s Code of Ethics, Mr. Draper can be reached at
jeff@strategicutah.com or 801-627-2200.
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Strategic Planning Group
PRIVACY POLICY NOTICE
Rev April 27, 2023
This notice is being provided to you in accordance with the Securities and Exchange Commission’s rule regarding
the privacy of consumer financial information (“Regulation S-P”). Please take the time to read and understand the
privacy policies and procedures that we have implemented to safeguard your nonpublic personal information.
INFORMATION WE COLLECT
Strategic Planning Group, LLC (Strategic Planning Group) must collect certain personally identifiable financial
information about its customers to provide financial services and products. The personally identifiable financial
information that we gather during the normal course of doing business with you may include:
information we receive from you on applications or other forms;
information about your transactions with us, our affiliates, or others;
information we receive from a consumer reporting agency.
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INFORMATION WE DISCLOSE
We do not disclose any nonpublic personal information about our customers or former customers to anyone, except
as permitted or required by law, or as necessary to provide services to you. In accordance with Section 248.13 of
Regulation S-P, we may disclose all of the information we collect, as described above, to certain nonaffiliated third
parties such as our attorneys, accountants, auditors, and persons or entities that are assessing our compliance
with industry standards. We enter into contractual agreements with all nonaffiliated third parties that prohibit
such third parties from disclosing or using the information other than to carry out the purposes for which we
disclose the information.
REGULATION S-ID
Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that controls reasonably
foreseeable risks to customers or the safety and soundness of our firm from identity theft. We have developed an
ITPP to adequately identify and detect potential red flags to prevent and mitigate identity theft.
CONFIDENTIALITY AND SECURITY
We restrict access to nonpublic personal information about you to those Employees who need to know that
information to provide financial products or services to you. We maintain physical, electronic, and procedural
safeguards that comply with federal standards to guard your nonpublic personal information.
ACCURACY
Strategic Planning Group strives to maintain accurate personal information in our Client files at all times.
However, as personal situations, facts, and data change over time; we encourage our Clients to provide feedback
and updated information to help us meet our goals.
CLOSED OR INACTIVE ACCOUNTS
If you decide to close your account(s) or become an inactive customer, our Privacy Policy will continue to apply to
you.
CHANGES TO THIS PRIVACY POLICY
If we make any substantial changes in the way we use or disseminate confidential information, we will notify you.
If you have any questions concerning this Privacy Policy, please contact us at. 801-627-2200.
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Strategic Planning Group