Overview
Assets Under Management: $155 million
Headquarters: CAMARILLO, CA
High-Net-Worth Clients: 190
Average Client Assets: $964,188
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Clients
Number of High-Net-Worth Clients: 190
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 81.05
Average High-Net-Worth Client Assets: $964,188
Total Client Accounts: 470
Discretionary Accounts: 470
Regulatory Filings
CRD Number: 170029
Last Filing Date: 2024-07-22 00:00:00
Website: https://lpl.com
Form ADV Documents
Primary Brochure: FORM ADV PART 2A - FIRM BROCHURE (2025-08-05)
View Document Text
Form ADV Part 2A – Firm Brochure
Item 1: Cover Page
July 2025
Summit Wealth Management Group, Inc.
400 Camarillo Ranch Road, Suite 202
Camarillo, CA 93012
www.yoursummitwealth.com
Firm Contact:
Christina Zins
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Summit
Wealth Management Group, Inc. If you have any questions about the contents of this brochure, please
contact us by telephone at (805) 384-1186 or email (c.zins@lpl.com). The information in this
brochure has not been approved or verified by the United States Securities and Exchange
Commission.
Additional information about Summit Wealth Management Group, Inc. also is available on the SEC’s
website at www.adviserinfo.sec.gov.
Please note that the use of the term “registered investment adviser” and description of Summit
Wealth Management Group, Inc. and/or our associates as “registered” does not imply a certain level
of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our
firm’s associates who advise you for more information on the qualifications of our firm and our
employees.
Item 2: Material Changes
Summit Wealth Management Group, Inc. is required to advise you of any material changes to the Firm
Brochure (“Brochure”) from our last annual update.
•
•
Item 5: We updated this section to disclose additional annuity fees. We also clarified
compensation related to annuities and disclosed 1035 Exchange risks and fees.
Item 8: We updated the risks related to investing and annuities.
Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................. 1
Item 2: Material Changes ...................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................... 3
Item 4: Advisory Business ................................................................................................................................... 4
Item 5: Fees & Compensation .............................................................................................................................. 9
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................... 14
Item 7: Types of Clients & Account Requirements .................................................................................... 14
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .................................................... 14
Item 9: Disciplinary Information .................................................................................................................... 15
Item 10: Other Financial Industry Activities & Affiliations ................................................................... 16
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading
.......................................................................................................................................................................................................17
Item 12: Brokerage Practices ........................................................................................................................... 18
Item 13: Review of Accounts or Financial Plans ........................................................................................ 20
Item 14: Client Referrals & Other Compensation ...................................................................................... 20
Item 15: Custody ................................................................................................................................................... 21
Item 16: Investment Discretion....................................................................................................................... 21
Item 17: Voting Client Securities ..................................................................................................................... 22
Item 18: Financial Information ....................................................................................................................... 22
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Summit Wealth Management Group, Inc.
Item 4: Advisory Business
We are dedicated to providing individuals and other types of clients with a wide array of investment
advisory services. Our firm is a corporation formed in the State of California and registered with the
United States Securities Exchange Commission (“SEC”). Our firm has been in business as an
independent investment adviser since 2014, and a recent change has been made to the ownership
structure. Effective January 1, 2025 Christina Zins is now 80% shareholder of Summit Wealth
Management Group, Inc., (SWMG) and Jerry Zins is 20% shareholder of SWMG.
Description of the Types of Advisory Services We Offer
Asset Management:
We emphasize continuous and regular account supervision. As part of our asset management service,
which is offered through LPL Financials’ Strategic Wealth Management platform, we generally create a
portfolio consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds
and other public and private securities or investments. The client’s individual investment strategy is
tailored to their specific needs and can include some or all of the previously mentioned securities. Each
portfolio will be initially designed to meet a particular investment goal, which we determine to be
suitable to the client’s circumstances. Once the appropriate portfolio has been implemented, we review
the portfolio periodically to ensure that the portfolio is in line with the client’s individual needs, stated
goals and objectives. Each client has the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio.
We also offer a wrap fee program, offered through LPL Financial’s Strategic Wealth Management
Platform, where the client pays a higher advisory fee to compensate for the investment advisory
services described above and for the execution of transactions. For more information, please refer to
the Form ADV 2A Appendix 1 – Wrap Fee Program Brochure.
Clients should be aware that LPL transaction charges may be applicable to the Strategic Wealth
Management (SWM) platform. The transaction charges vary based on the type of transaction (e.g.,
mutual fund, equity or ETF) and for mutual funds based on whether or not the mutual fund pays
12b-1 fees and/or recordkeeping fees to LPL. Clients should understand that the transaction
charges can be paid by either the client or Advisor and the cost to Advisor of transaction charges
may be a factor that is considered when determining the account’s fee, deciding which securities
to select and how frequently to place transactions in a SWM account.
To the extent you own a 12b-1 paying mutual fund or other mutual fund that pays a distribution,
marketing or sales fee, please know that no one at our firm will receive that fee. However, such
fees and expenses are retained by LPL in their capacity as your account broker/dealer and
qualified custodian. LPL does not incentivize us or otherwise try to influence us to pick
investments that pay them a 12b-1, distribution, marketing, sales or other fees and expenses.
In many instances, LPL makes available mutual funds in a SWM account that offer various classes of
shares, including shares designated as Class A Shares and shares designed for advisory programs,
“Platform Shares”. The Platform Share class offered for a particular mutual fund in SWM in many
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Summit Wealth Management Group, Inc.
cases will not be the least expensive share class that the mutual fund makes available, and was
selected by LPL in certain cases because the share class pays LPL compensation for the
administrative and recordkeeping services LPL provides to the mutual fund. Client should
understand that another financial services firm may offer the same mutual fund at a lower overall
cost to the investor than is available through SWM. In other instances, a mutual fund may offer
only Class A Shares, but another similar mutual fund may be available that offers Platform Shares.
Class A Shares typically pay LPL a 12b-1 fee for providing shareholder services, distribution, and
marketing expenses (“brokerage-related services”) to the mutual funds. Platform Shares generally
are not subject to 12b-1 fees. As a result of the different expenses of the mutual fund share classes,
it is generally more expensive for a client to own Class A Shares than Platform Shares. An investor
in Platform Shares will pay lower fees over time, and keep more of his or her investment returns
than an investor who holds Class A Shares of the same fund.
Our client portfolios that hold A shares are limited to legacy holdings that have been owned for a
number of years. We no longer recommend Class A Shares in be held in managed accounts and are
transitioning client portfolios into Platform Shares when it is in the client’s best interest.
Financial Planning & Consulting:
We provide a variety of financial planning and consulting services to individuals, families and other
clients regarding the management of their financial resources based upon an analysis of the client’s
current situation, goals, and objectives. Generally, such financial planning services will involve
preparing a financial plan or rendering a financial consultation for clients based on the client’s
financial goals and objectives. This planning or consulting can encompass one or more of the
following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning,
Education Planning, Personal Tax Planning, Insurance Analysis, Business and Personal Financial
Planning.
Our written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. For example,
recommendations will be made that the clients begin or revise investment programs, create or revise
wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or
establish education or charitable giving programs. It should also be noted that we refer clients to an
accountant, attorney or other specialist, as necessary for non-advisory related services. For written
financial planning engagements, we provide our clients with a written summary of their financial
situation, observations, and recommendations. For financial consulting engagements, we usually do
not provide our clients with a written summary of our observations and recommendations as the
process is less formal than our planning service. Plans or consultations are typically completed within
six (6) months of the client signing a contract with us, assuming that all the information and
documents we request from the client are provided to us promptly. Implementation of the
recommendations will be at the discretion of the client.
The client is under no obligation to act upon the investment adviser’s recommendation. If the client
elects to act on our recommendations, the client is under no obligation to effect the transaction
through us. Implementation of the recommendations will be at the discretion of the client.
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Summit Wealth Management Group, Inc.
LPL Financial Sponsored Advisory Programs:
Our firm does provide advisory services through certain programs sponsored by LPL Financial
(“LPL”), a registered investment adviser and broker-dealer. Below is a brief description of each LPL
advisory program available to our firm. For more information regarding the LPL programs, including
more information on the advisory services and fees that apply, the types of investments available in
the programs and the potential conflicts of interest presented by the programs please see the LPL
Financial Form ADV Part 2 or the applicable program’s Appendix 1 (wrap fee program brochure) and
the applicable client agreement.
Guided Wealth Portfolios Program (GWP)
GWP provides clients with an online centrally managed, algorithm-based, investment program.
Advisor oversees initial review of asset allocation and model at account opening and reviews any
updates clients make that require a change in allocation, either after annual review or on an ongoing
basis. GWP uses proprietary, automated, computer algorithms to generate
investment
recommendations based upon model portfolios constructed by LPL. This program will have
discretion to purchase and sell pursuant to the portfolio selected by the client. LPL will also have
authority to rebalance the account.
Optimum Market Portfolios Program (OMP)
OMP offers clients the ability to participate in a professionally managed asset allocation program
using Optimum Funds Class I shares. Under OMP, client will authorize LPL on a discretionary basis
to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Advisor
will assist the client in determining the suitability of OMP for the client and assist the client in setting
an appropriate investment objective. Advisor will have discretion to select a mutual fund asset
allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have
discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL
will also have authority to rebalance the account.
Model Wealth Portfolios Program (MWP)
MWP offers clients a professionally managed mutual fund asset allocation program. We will obtain
the necessary financial data from the client, assist the client in determining the suitability of the MWP
program and assist the client in setting an appropriate investment objective. The Advisor will initiate
the steps necessary to open an MWP account and have discretion to select a model portfolio designed
by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s
Research Department is responsible for selecting the mutual funds within a model portfolio and for
making changes to the mutual funds selected.
The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds
(including in certain circumstances exchange traded funds) and to liquidate previously purchased
securities. The client will also authorize LPL to effect rebalancing for MWP accounts.
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Summit Wealth Management Group, Inc.
The MWP program makes available model portfolios designed by strategists other than LPL’s
Research Department. The Advisor will have discretion to choose among the available models
designed by LPL and outside strategists.
Personal Wealth Portfolios Program (PWP)
PWP offers clients an asset management account using asset allocation model portfolios designed by
LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on client’s
investment objective. Advisor will also have discretion for selecting third party money managers
(PWP Advisors) or mutual funds within each asset class of the model portfolio. LPL will act as the
overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on a
discretionary basis mutual funds and equity and fixed income securities.
Manager Access Select Program
Manager Access Select provides clients access to the investment advisory services of professional
portfolio management firms for the individual management of client accounts. Advisor will assist
client in identifying a third party portfolio manager (Portfolio Manager) from a list of Portfolio
Managers made available by LPL. The Portfolio Manager manages client’s assets on a discretionary
basis. Advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection
process.
Retirement Plan Rollover Recommendations
When Summit Wealth Management Group provides investment advice about your retirement plan
account or individual retirement account (“IRA”) including whether to maintain investments
and/or proceeds in the retirement plan account, roll over such investment/proceeds from the
retirement plan account to a IRA or make a distribution from the retirement plan account, we
acknowledge that Summit Wealth Management Group is a “fiduciary” within the meaning of Title I
of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”) as applicable, which are laws governing retirement accounts. The way Summit Wealth
Management Group makes money creates conflicts with your interests so Summit Wealth
Management Group operates under a special rule that requires Summit Wealth Management Group
to act in your best interest and not put our interest ahead of you.
Under this special rule’s provisions, Summit Wealth Management Group must as a fiduciary to a
retirement plan account or IRA under ERISA/IRC:
•
•
•
•
•
Meet a professional standard of care when making investment recommendations
(e.g., give prudent advice);
Never put the financial interests of Summit Wealth Management Group ahead of
you when making recommendations (e.g., give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that Summit Wealth
Management Group gives advice that is in your best interest;
Charge no more than is reasonable for the services of Summit Wealth Management
Group ; and
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Summit Wealth Management Group, Inc.
•
Give Client basic information about conflicts of interest.
To the extent we recommend you roll over your account from a current retirement plan account to
an individual retirement account managed by Summit Wealth Management Group , please know
that Summit Wealth Management Group and our investment adviser representatives have a
conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over your account
at the retirement plan to an IRA managed by Summit Wealth Management Group . We will earn
fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA
managed by Summit Wealth Management Group .
Thus, our investment adviser representatives have an economic incentive to recommend a rollover
of funds from a retirement plan to an IRA which is a conflict of interest because our
recommendation that you open an IRA account to be managed by our firm can be based on our
economic incentive and not based exclusively on whether or not moving the IRA to our
management program is in your overall best interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial conduct
standard whereby our investment adviser representatives will (i) provide investment advice to a
retirement plan participant regarding a rollover of funds from the retirement plan in accordance
with the fiduciary status described below, (ii) not recommend investments which result in Summit
Wealth Management Group receiving unreasonable compensation related to the rollover of funds
from the retirement plan to an IRA, and (iii) fully disclose compensation received by Summit
Wealth Management Group and our supervised persons and any material conflicts of interest
related to recommending the rollover of funds from the retirement plan to an IRA and refrain from
making any materially misleading statements regarding such rollover.
When providing advice to your regarding a retirement plan account or IRA, our investment advisor
representatives will act with the care, skill, prudence, and diligence under the circumstances then
prevailing that a prudent person acting in a like capacity and familiar with such matters would use
in the conduct of an enterprise of a like character and with like aims, based on the investment
objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the
financial or other interests of Summit Wealth Management Group or our affiliated personnel.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Asset Management service.
Additionally, we offer general investment advice to clients utilizing our Financial Planning &
Consulting service.
Each client has the opportunity to place reasonable restrictions on the types of investments to be held
in the portfolio. Restrictions on investments in certain securities or types of securities may not be
possible due to the level of difficulty this would entail in managing the account. Restrictions would
be limited to our Asset Management service. We do not manage assets through our other services.
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Summit Wealth Management Group, Inc.
Participation in Wrap Fee Programs
We offer wrap fee programs as further described in Part 2A, Appendix 1 (the “Wrap Fee Program
Brochure”) of our Brochure. Our wrap fee and non-wrap fee accounts are managed on an
individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc.
We do not manage wrap fee accounts in a different fashion than non-wrap fee accounts. As further
described in our Wrap Fee Program Brochure, we receive a portion of the wrap fee for our services.
Regulatory Assets Under Management
As of December 31, 2024, we manage $226,022,233.00 of client assets on a discretionary basis and $0
of client assets on a non-discretionary basis.
Item 5: Fees & Compensation
How We Are Compensated for Our Advisory Services
The maximum annual fee for asset management services will be up to a maximum of 2.0% of the
assets held in the managed account.
Prior to engaging Summit Wealth Management Group (SWMG) to provide investment management
services, you are required to enter into a formal investment advisory agreement with us setting
forth the terms and conditions, including the amount of investment advisory fees, under which we
manage your assets and also a separate custodial/clearing agreement with LPL Financial.
LPL Financial is responsible for calculating and debiting all fees from client accounts. Clients must
provide LPL Financial written authorization to debit advisory fees from their accounts and pay such
fees to directly to our firm. You should review your account statements received from LPL
Financial and verify that appropriate investment advisory fees are being deducted. LPL Financial
will not verify the accuracy of the investment advisory fees deducted.
Fees charged for our asset management services are charged based on a percentage of assets under
management, billed in advance (at the start of the billing period) on a quarterly calendar basis and
calculated based on the fair market value of your account as of the last business day of the current
billing period. Fees are prorated (based on the number of days service is provided during the initial
billing period) for your account opened at any time other than the beginning of the billing period. If
asset management services are commenced in the middle of a billing period, the prorated fee for
the initial billing period is billed in arrears at the same time as the next full billing period’s fee is
billed.
The asset management services continue in effect until terminated by either party (i.e., Summit
Wealth Management or you) by providing written notice of termination to the other party. Any
prepaid, unearned fees will be promptly refunded by LPL Financial to you. Fee refunds will be
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Summit Wealth Management Group, Inc.
determined on a pro rata basis using the number of days services are actually provided during the
final period.
Fees charged for our asset management services are negotiable based on the type of client, the
complexity of the client's situation, the composition of the client's account (i.e., equities versus
mutual funds), the potential for additional account deposits, the relationship of the client with the
investment adviser representative, and the total amount of assets under management for the client.
Summit Wealth Management believes that its annual fee is reasonable in relation to: (1) services
provided and (2) the fees charged by other investment advisers offering similar services/programs.
However, our annual investment advisory fee may be higher than that charged by other investment
advisers offering similar services/programs. In addition to our compensation, you may also incur
charges imposed at the mutual fund level (e.g., advisory fees and other fund expenses).
You can open a Strategic Wealth Management (SWM) non-wrap fee or SWM wrap-fee account.
With a non-wrap fee account, in addition to our investment advisory fee, you also pay certain
transaction charges to defray the costs associated with trade execution. These costs are set out in
the LPL Financial Strategic Wealth Management platform brokerage account and application
agreement. With a wrap-fee you do not pay transaction charges associated with trade execution.
You may incur certain charges imposed by third parties other than Summit Wealth Management in
connection with investments made through the account including, but not limited to, 12b-1 fees and
surrender charges, and IRA and qualified retirement plan fees. Our management fees (which
include transaction and execution fees charged by LPL Financial for wrap-fee accounts) are
separate and distinct from the fees and expenses charged by investment company securities that
may be recommended to you. A description of these fees and expenses are available in each
investment company security’s prospectus.
The Strategic Wealth Management accounts may cost you more or less than if the assets were held
in a traditional brokerage account. In a brokerage account, you are charged commissions for each
transaction, and the registered representative assigned to the account, if any, has no duty to
provide ongoing advice with respect to the account. If you plan to follow a buy and hold investment
strategy for the account or do not wish to purchase ongoing investment advice or management
services, you should consider opening a brokerage account rather than a Strategic Wealth
Management account.
The cost for a SWM non-wrap fee account is typically higher than a SWM wrap fee account. This is
because transaction costs are passed along to you in SWM non-wrap fee accounts while the
transaction costs are covered under the overall fee charged for SWM wrap fee accounts.
Certain investment adviser representatives of Summit Wealth Management are also associated with
LPL Financial as broker-dealer registered representatives (“Dually Registered Persons”). They do
not earn commissions on the sale of securities or investment products recommended or purchased
in advisory accounts through Summit Wealth Management. See Item 10 – Other Financial Industry
Activities and Affiliations for further information regarding our investment advisor representatives’
affiliation as registered representatives of LPL Financial.
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Summit Wealth Management Group, Inc.
LPL FINANCIAL ADVISORY PROGRAMS
Account minimum requirements vary among the LPL Financial Advisory programs based on the
services offered by each program.
The annual account fee is divided and paid quarterly in advance through a direct debit in your
account. LPL Financial is responsible for calculating and debiting all fees from your accounts. You
must provide LPL Financial written authorization to debit advisory fees from your account(s). Part
of the fee will be retained by LPL Financial, part of the fee will be paid to Summit Wealth
Management, and if applicable, part of the fee may be used to pay a third party subadvisor (MAS,
MAN, MWP and GWP programs). The account quarter begins on the first day of the month in which
the account is accepted.
You can terminate an account in an LPL Financial Advisory Program by providing written notice to
LPL Financial. Upon termination, you are entitled to a prorated refund of any pre-paid quarterly
fees based on the number of days remaining in the quarter after termination. If you close the
account within the first six months as a result of withdrawals bringing the account value below the
required minimum, we, along with LPL Financial, reserve the right to retain the pre-paid quarterly
fees for the current quarter in order to cover the administrative cost of establishing the account.
Under these programs, you may incur additional charges including but not limited to, mutual fund
management fees, mutual fund sales loads, 12b-1 fees and surrender charges, omnibus processing
fees, sub-transfer agent fees, networking fees and IRA and qualified retirement plan fees,
administrative servicing fees for trust accounts, and other charges required by law. LPL Financial
may receive a certain portion of these third party fees.
Summit Wealth Management may receive other compensation for participating in LPL Financial
Programs such as bonuses, awards, or other things of value. The amount of this compensation may
be more or less than if you had participated in our other advisory programs or if you paid
separately for investment advice, brokerage and other client services.
We have a conflict of interest by only offering those third-party money managers available through
LPL Financial Programs (MAS, MAN, GWP). There may be other third-party money managers that
may be suitable for you that may be more or less costly.
The account fee charged to the client for each LPL Financial advisory program is negotiable,
dependent on the market value of the account, asset types, your financial situation and trading
activity, and subject to the following maximum account fees:
Optimum Market Portfolios (OMP)
Model Wealth Portfolios (MWP)
Manager Access Select (MAS)
Manager Access Network (MAN)
Guided Wealth Portfolios (GWP)
Personal Wealth Portfolios (PWP)
2.5%
2.65%*
2.5%**
3.0%
1.35%
2.95%
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Summit Wealth Management Group, Inc.
* The MWP account fee consists of an LPL Financial program fee, a strategist fee (if applicable) and
an advisor fee of up to 2.00%. Accounts remaining under the legacy fee structure may be charged
one aggregate account fee, for which the maximum account fee is 2.50%. See the MWP program
brochure for more information.
** The maximum Manager Access Select account fee for new accounts was reduced to 2.5%
effective July 3, 2017.
A complete description of the services, fee schedules and account minimums is disclosed in the LPL
Financial Form ADV Part 2A and in the advisory program brochure. Each advisory program has its
own Form ADV Part 2A brochure except the MAN program. A copy of the LPL Financial Form ADV
Part 2A and a copy of the program brochure is provided to all clients participating in an LPL
Financial program prior to or at the time an agreement for services is executed and the account is
established. You may also request copies from your investment advisory representative.
Manager Access Select Program (MAS)
The fees for LPL’s Financial Sponsored Advisory Programs are billed on a pro-rata annualized basis
quarterly in advance based on the value of your account on the last day of the previous quarter. LPL
serves as program sponsor, investment adviser and broker-dealer for the LPL advisory programs. Our
firm and LPL may share in the account fee and other fees associated with program accounts.
Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of
your account on the last day of the previous quarter. Management fees will be deducted from the
client’s managed account, upon a signed Account Application Form. The ultimate management fee is
indicated on the Account Application Form. Our firm does not have the authority to instruct LPL
Financial to change or deduct fees without written client consent. LPL Financial sends a quarterly
statement showing all fees deducted from the clients’ accounts.
Financial Planning & Consulting:
We charge on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of
our engagement with you. Our hourly fees are up to $400. Fees for financial planning services
typically range from $500 to $10,000. SWMG offers three levels of Financial Planning packages to
clients – Core, Comprehensive and Advanced.
• The Core level offers a 6-month engagement for individual and couples accumulating wealth
or retirees. The Core package offers 10 or more planning hours and a minimum of 3 meetings
provided to clients. The fee for the Core Package starts at $3000.
• The Comprehensive level offers a 9-month engagement for couples and families in peak
earning years or nearing or in retirement. The Comprehensive Package offers 20 or more
planning hours and a minimum of 4 meetings provided to clients. The fee for the
Comprehensive Package starts at $4000.
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Summit Wealth Management Group, Inc.
• The Advanced level offers a 12-month engagement for families or business owners focused
on protecting and transferring wealth. The Advanced Package offers 30 or more planning
hours and a minimum of 4 to 6 meetings provided to clients. The fee for the Comprehensive
Package starts at $5000.
After the initial plan engagement has expired, we offer On-Going Financial Planning services starting
at $1,200 which offers annual reanalysis of the Financial Plan with revised deliverables, continued
access and updates to the online Financial Plan portal, and an open telephone policy for financial
planning needs.
The actual fee to be charge for any of our packages will be specified in your client agreement.
Dependent upon the complexity of a client’s situation SWMG may require a retainer of fifty percent
(50%) of the ultimate financial planning or consulting fee with the remainder of the fee directly billed
to you and due to us within thirty (30) days of your financial plan being delivered or consultation
rendered to you. In all cases, we will not require a retainer exceeding $500 when services cannot be
rendered within 6 (six) months.
Other Fees:
Clients may incur transaction charges for trades executed in their accounts. These transaction fees
are separate from our fees and will be disclosed by the firm that the trades are executed through.
Also, clients will pay the following separately incurred expenses, which we do not receive any part of:
charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be
disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses).
Wrap fee clients will receive our Form ADV, Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”).
Wrap fee clients will not incur transaction costs for trades. More information about this is disclosed
in our separate Wrap Fee Program Brochure.
Refunds Following Termination
We charge our advisory fees quarterly in advance. In the event that you wish to terminate our
services, we will refund the unearned portion of our advisory fee to you. You need to contact us in
writing and state that you wish to terminate our services. Upon receipt of your letter of termination,
we will proceed to close out your account and process a pro-rata refund of unearned advisory fees.
Commissionable Securities Sales
In order to sell securities for a commission, our supervised persons are registered representatives of
LPL, member FINRA/SIPC. Our supervised persons will accept compensation for the sale of securities
or other investment products, including distribution or service (“trail”) fees from the sale of mutual
funds. You should be aware that the practice of accepting commissions for the sale of securities:
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Summit Wealth Management Group, Inc.
1. Presents a conflict of interest and gives our firm and/or our supervised persons an incentive to
recommend investment products based on the compensation received, rather than on your
needs. We generally address commissionable sales conflicts that arise when explaining to clients
that commissionable securities sales creates an incentive to recommend products based on the
compensation we and/or our supervised persons can earn and/or when recommending
commissionable mutual funds, explaining that “no-load” funds are also available.
2. In no way prohibits you from purchasing investment products recommended by us through other
brokers or agents which are not affiliated with us.
Annuity Fees and Compensation
When annuity products are held within a fee-based advisory account, clients should be aware
that these products typically include several internal costs assessed by the issuing insurance
company. These may include mortality and expense risk charges, administrative or contract fees,
investment subaccount expenses, and fees associated with optional riders, such as guaranteed
income or enhanced death benefits. These charges are assessed by the insurance carrier and are
separate from, and in addition to, the advisory fee charged by SWMG for ongoing portfolio
management and financial advice. While these fees are not deducted directly from the client’s
advisory account, they are embedded within the annuity and may affect the overall performance
and account value.
With respect to compensation, when annuities are held in fee-based advisory accounts, neither
SWMG nor its Investment Adviser Representatives (“IARs”) receive any upfront commissions or
ongoing trail compensation from the insurance company. Instead, SWMG charges an asset-based
advisory fee in accordance with the client’s advisory agreement, based on the value of the annuity
contract and any other managed assets.
If an annuity contract was originally purchased outside of a fee-based arrangement and is
subsequently transferred into a fee-based advisory account, any existing commission or trail
compensation arrangements may be discontinued, depending on the terms of the annuity
product and the policies of the issuing carrier. Clients will be provided with written disclosures
regarding all applicable advisory fees,
internal annuity expenses, and compensation
arrangements prior to the execution of any such transaction.
SWMG and its representatives seek to recommend annuity products based solely on the client’s
best interests, taking into account the client’s financial situation, objectives, time horizon, and
risk tolerance. Clients are encouraged to carefully review all annuity prospectuses and disclosure
documents provided by the insurance carrier prior to purchase.
In certain circumstances, clients may purchase annuity products that are not held within a fee-
based advisory account. In such cases, a commission or other compensation may be paid by the
insurance carrier to the selling agent. This compensation may include upfront commissions,
ongoing trail payments, or both, and may vary depending on the specific annuity product and
features selected.
Any such compensation is separate from, and in addition to, any fees the client may pay to SWMG
for advisory services. If a commission-based annuity is recommended, clients will receive full
disclosure of all associated costs, compensation arrangements, and potential conflicts of interest
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Summit Wealth Management Group, Inc.
prior to the execution of the transaction. SWMG and its supervised persons are committed to
recommending products that are in the best interest of the client, and no client is under any
obligation to purchase annuity products through any particular agent or affiliate.
1035 Exchange Disclosure
SWMG may recommend the replacement of an existing annuity or life insurance contract through
a tax-deferred Section 1035 exchange. While such exchanges may offer certain benefits, such as
improved contract features, lower internal expenses, or enhanced riders, clients should be aware
that 1035 exchanges may also result in costs and other material considerations.
These may include, but are not limited to:
• Surrender charges on the existing contract
• New surrender schedules on the replacement contract
• Loss of existing benefits, such as living or death benefit guarantees
• Higher internal expenses or rider costs on the new contract
• New commissions or compensation paid to the insurance agent or representative
Clients are encouraged to review all applicable product disclosures, prospectuses, and cost
comparisons carefully and to consider whether the exchange is in their best interest given their
long-term financial goals.
Item 6: Performance-Based Fees & Side-By-Side Management
We do not accept performance-based fees.
Item 7: Types of Clients & Account Requirements
We have the following types of clients:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Corporations, Limited Liability Companies and/or Other Business Types.
Our requirements for opening and maintaining accounts or otherwise engaging us:
• We generally require a minimum household account size of $500,000 for our Asset
Management service.
• We generally charge a minimum fee of $3,000 for written financial plans.
These requirements may be waived depending on the scope of the engagement. The investment
adviser representative ultimately holds the discretion to waive account requirements.
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Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Technical Analysis. We analyze past market movements and apply that analysis to the present in an
attempt to recognize recurring patterns of investor behavior and potentially predict future price
movement. Technical analysis does not consider the underlying financial condition of a company.
This presents a risk in that a poorly-managed or financially unsound company may underperform
regardless of market movement.
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Investment Strategies We Use
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Long-term purchases. When utilizing this strategy, we will purchase securities with the idea of
holding them for a relatively long time (typically held for at least a year). A risk in a long-term
purchase strategy is that by holding the security for this length of time, we may not take advantages
of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a
security can decline sharply in value before we make the decision to sell. Typically we employ this
sub-strategy when we believe the securities to be well valued and/or we want exposure to a
particular asset class over time, regardless of the current projection for this class. In addition, we
utilize Model Portfolios, as appropriate, that are created in house to target certain investment
objectives, currently Growth with Income and Income with Moderate Growth. The portfolio
structure focuses on utilizing diversified investment vehicles consisting of mutual funds and ETFs,
combining the use of passive and active investment strategies. There is no minimum for these
accounts types.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market can increase and your account(s) could enjoy a gain, it is also possible that the stock market
can decrease and your account(s) could suffer a loss. It is important that you understand the risks
associated with investing in the stock market, are appropriately diversified in your investments, and
ask us any questions you may have.
Description of Material, Significant or Unusual Risks
We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we
try to achieve the highest return on our client’s cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to Asset
Management, as applicable.
Additional Risks:
•
•
• Market Risk: The value of investments may decline due to fluctuations in overall market
conditions, economic events, geopolitical developments, or interest rate changes. All securities
are subject to market risk, including stocks, bonds, and mutual funds.
Inflation Risk: The purchasing power of investment returns may be eroded by inflation over
time, particularly in fixed income investments that do not adjust with inflation.
Interest Rate Risk: Changes in interest rates may negatively impact the value of fixed income
securities. Rising rates typically reduce the market value of existing bonds.
• Liquidity Risk: Certain securities or investments, including private funds and alternative
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Summit Wealth Management Group, Inc.
investments, may not be easily sold or converted to cash without significant loss in value.
Illiquidity can also affect the ability to rebalance or exit a position during market stress.
• Concentration Risk: Portfolios with large positions in specific securities, sectors, or asset
classes may be more volatile and vulnerable to adverse events affecting those holdings.
• Credit Risk: Issuers of bonds or other debt instruments may default on their obligations,
leading to loss of income and principal.
• Annuity Risk: Annuities may include complex fee structures, surrender penalties, and limited
liquidity. Guarantees are subject to the claims-paying ability of the insurance company. Fees
may include mortality and expense charges, administrative costs, subaccount fees, and rider
charges.
• Valuation Risk: Certain investments, including private placements or infrequently traded
securities, may be difficult to value and may rely on estimated or subjective pricing.
• Operational Risk: Errors, fraud, system failures, or cybersecurity incidents affecting
custodians, third-party vendors, or the advisory firm itself could result in financial loss, data
compromise, or disrupted access to accounts.
• Cybersecurity Risk: The use of technology in providing advisory services exposes both clients
and the firm to cybersecurity risks. Cybersecurity breaches may result from intentional attacks
(e.g., hacking, phishing, ransomware) or unintentional events (e.g., software errors or system
failures). Such incidents may compromise sensitive client data, disrupt access to accounts, or
affect the integrity of account transactions. While we and our third-party service providers
employ physical, electronic, and procedural safeguards designed to protect information, no
system is entirely secure. Clients should be aware that cybersecurity incidents may result in
financial loss, identity theft, or unauthorized access to confidential information. We regularly
review our internal cybersecurity policies and vendor practices to help mitigate these risks, but
cannot guarantee that such events will not occur.
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Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
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Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are financial advisors of LPL member FINRA/SIPC, and licensed
insurance agents. They do offer products and receive normal and customary commissions as a result
of these transactions. A conflict of interest can arise as these commissionable securities sales will
create an incentive to recommend products based on the compensation they will earn. In any event,
as a fiduciary, we always put our Client’s interest above our own.
Certain investment advisor representatives of SWMG are also licensed as investment adviser
representatives with LPL. SWMG and LPL are not affiliated. Through LPL the representatives
provide investment advisory services to ERISA covered retirement plans. They earn advisory fees
when providing these services through LPL. Therefore, you could receive advisory services from
one individual acting as an investment adviser representative on behalf of two separate registered
investment advisors. If the representatives of SWMG provide investment advisory services to you
under their relationship with LPL you will be given the disclosure brochure of LPL describing the
services provided, fees charged and other information. You are encouraged to read and review the
disclosure brochures for both SWMG and LPL and direct questions to your representative.
You may work with your investment adviser representative in his or her separate capacity as an
insurance agent. When acting in his or her separate capacity as an insurance agent, the investment
adviser representative may sell, for commissions, general disability insurance, long term care
insurance, life insurance, annuities, and other insurance products to you. As such, your investment
adviser representative in his or her separate capacity as an insurance agent, may suggest that you
implement recommendations of SWMG by purchasing disability insurance, life insurance, annuities,
or other insurance products. This receipt of commissions creates an incentive for the
representative to recommend those products for which your investment adviser representative will
receive a commission in his or her separate capacity as an insurance agent. Consequently, the
advice rendered to you could be biased. You are under no obligation to implement any insurance or
annuity transaction through your investment adviser representative.
Beginning in 2015, it is SWMG's policy to primarily offer wrap and non-wrap advisory accounts to
its new and existing clients. Commissionable accounts for existing clients who have legacy assets
with the firm will continue to be serviced, provided that an existing advisory account is established.
It is not the intention of SWMG to offer or service commission based accounts, unless the account
enhances the diversification of the clients’ advisory assets with investments that can only be
purchased on a commissioned basis (i.e., non-traded REIT's, etc.)
However, to the extent SWMG recommends you use LPL Financial for such services, it is primarily
because SWMG believes that it is in your interest to do so based on the quality and pricing of the
execution, benefits of an integrated platform for brokerage and advisory accounts, and other services
provided by LPL Financial. To further control for this conflict of interest, you are not required to use
LPL Financial and can use another SWMG approved brokerage platform.
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Summit Wealth Management Group, Inc.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions & Personal Trading
We recognize that the personal investment transactions of members and employees of our firm demand
the application of a high Code of Ethics and require that all such transactions be carried out in a way that
does not endanger the interest of any client. At the same time, we believe that if investment goals are
similar for clients and for members and employees of our firm, it is logical and even desirable that there
be common ownership of some securities.
Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-
clearing procedure) with respect to transactions effected by our members, officers and employees for
their personal accounts1. In order to monitor compliance with our personal trading policy, we have a
quarterly securities transaction reporting system for all of our associates.
Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An
investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility
to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our
clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core
underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities
Transactions Policies and Procedures. We require all of our supervised persons to conduct business with
the highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an
acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our
firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all
circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients.
This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a
potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon
request.
Neither our firm nor a related person recommends to clients, or buys or sells for client accounts,
securities in which our firm or a related person has a material financial interest.
Related persons of our firm have the ability to buy or sell securities and other investments that are
also recommended to clients. In order to minimize this conflict of interest, our related persons will
place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of
which is available upon request.
Related persons of our firm have the ability to buy or sell securities for themselves at or about the same
time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest,
our related persons will place client interests ahead of their own interests and adhere to our firm’s Code
of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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Summit Wealth Management Group, Inc.
or selling the same securities within 24 hours prior to buying or selling for our clients. If related persons’
accounts are included in a block trade, our related persons will always trade personal accounts last.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
We seek to recommend a custodian/broker who will hold your assets and execute transactions on
terms that are overall most advantageous when compared to other available providers and their
services. We consider a wide range of factors, including, among others, these:
• Ability to maintain the confidentiality of trading intentions
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Liquidity of the securities traded
• Willingness to commit capital
• Ability to place trades in difficult market environments
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
With this in consideration, our firm has an arrangement with LPL. LPL offers to independent
investment advisers non-soft dollar services which include custody of securities, trade execution,
clearance and settlement of transactions. We receive non-soft-dollar services such as research and
administrative functions including portfolio pricing, account statement generation and fee calculations,
which are intended to support our firm in conducting business and in serving the best interests of our
clients. These services do not incentivize us to recommend LPL Financial. Our recommendation of LPL
Financial to our clients is based on our clients’ interests in receiving best execution and the level of
competitive, professional services LPL Financial provides. Our firm does not receive client brokerage
commissions (or markups or markdowns) to obtain research or other products or services. Neither
our firm receive brokerage commissions for client referrals. We do not allow client-directed
brokerage, as trades in our clients’ accounts are executed through LPL Financial, a qualified custodian
and broker-dealer; neither do we direct client transactions to LPL Financial in return for soft-dollar
benefits.
A retirement or ERISA plan client can direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
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Summit Wealth Management Group, Inc.
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, we will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
We perform investment management services for various clients. There are occasions on which
portfolio transactions can be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when we believe that to
do so will be in the best interest of the effected accounts. When such concurrent authorizations occur,
the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, we attempt to allocate trade executions in the most equitable manner
possible, taking into consideration client objectives, current asset allocation and availability of funds
using price averaging, proration and consistently non-arbitrary methods of allocation.
Transactions for each client account generally will be effected independently, unless we decide to
purchase or sell the same securities for several clients at approximately the same time. We can, but are
not obligated to, combine or "batch" such orders to obtain “best execution”, to negotiate more favorable
commission rates, to allocate fairly among the clients’ differences in prices and commissions or other
transaction costs that might have been obtained had such orders been placed independently. Under this
procedure, transactions will be averaged as to price and will be allocated among our clients in
proportion to the purchase and sale orders placed for each client account on any given day. To the extent
that we determine to aggregate client orders for the purchase or sale of securities, including securities
in which our principals (and/or associated persons) may invest, we shall generally do so in accordance
with the parameters set forth in SEC No-Action Letter, SMC Capital, Inc. We shall not receive any
additional compensation or remuneration as a result of the aggregation. When referring clients to
dealers, we will only refer clients to dealers registered in states where the clients reside.
If requested, we will arrange for the execution of securities brokerage transactions for the account
through broker-dealers that we reasonably believe will provide "best execution". In seeking “best
execution”, the determinative factor is not the lowest possible commission cost, but whether the
transaction represents the best qualitative execution. We also take into consideration the full range
of a broker-dealer's services including execution capability, commission rates, and responsiveness.
Although we will seek competitive commission rates, it may not necessarily obtain the lowest
possible commission rates for account transactions. Over-the-Counter (OTC) securities transactions
for our clients are generally effected based on two (2) separate broker-dealers: (1) a “dealer” or
“principal” acting as market-maker; and (2) the executing broker-dealer that acts in an agency
capacity for the client’s account. Dealers executing principal transactions typically include a mark-
up/down, which is included in the offer or bid price of the securities purchased or sold. In addition
to the dealer mark-up/down, the client can also incur the transaction fee imposed by the executing
broker-dealer. We do not receive any portion of the dealer mark-up/down or the executing broker-
dealer transaction fee.
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Item 13: Review of Accounts or Financial Plans
We review accounts on a periodic basis for our clients subscribing to our Asset Management service.
The nature of these reviews is to learn whether clients’ accounts are in line with their investment
objectives, appropriately positioned based on market conditions, and investment policies, if
applicable. We do not provide written reports to clients, unless asked to do so. Verbal reports to
clients take place on at least an annual basis when we contact clients who subscribe to our Asset
Management service.
Only Jerry J. Zins, Jr. and Christina Zins will conduct reviews of client accounts.
We can review client accounts on a more consistent basis, specifically when accounts are affected by
major market or economic events, the client’s life events, requests by the client, etc.
Financial Planning clients will receive reviews of their written plans upon completion to discuss the
summary of recommendations. We do not provide ongoing services to financial planning clients, but
are willing to meet with such clients upon their request to discuss updates to their plans, changes in
their circumstances, etc. Financial Planning clients do not receive written or verbal updated reports
regarding their financial plans unless they separately contract with us for a post-financial plan
meeting or update to their initial written financial plan.
Item 14: Client Referrals & Other Compensation
LPL Financial
We do receive from LPL or a mutual fund company, without cost and/or at a discount support
services and/or products, to assist us to better monitor and service client accounts maintained at
such institutions. Included within the support services we will receive investment-related research,
pricing information and market data, software and other technology that provide access to client
account data, compliance and/or practice management-related publications, discounted or gratis
consulting services, discounted and/or gratis attendance at conferences, meetings, and other
educational and/or social events, marketing support, computer hardware and/or software and/or
other products used by us to assist us in our investment advisory business operations.
SWMG will from time to time receive expense reimbursement for travel and/or marketing
expenses from distributors of investment products. Travel expense reimbursements are typically
a result of attendance at due diligence and/or investment training events hosted by product
sponsors. Marketing expense reimbursements are typically the result of informal expense
sharing arrangements in which product sponsors will underwrite costs incurred for marketing of
client appreciation events and/or seminar expenses. The product sponsor reimbursements are
typically made by those sponsors for which we have used their products or it is anticipated that
we will use their products in the future. This can create a conflict of interest in that there would be
an incentive to recommend certain products and investments based on the receipt of these
marketing expense reimbursements. SWMG attempts to control this conflict by always basing
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investment decisions on the individual needs of our clients.
Our clients do not pay more for investment transactions effected and/or assets maintained at LPL
as result of this arrangement. There is no commitment made by us to LPL or any other institution as
a result of the above arrangement.
Referral Fees
We do not pay referral fees (non-commission based) to independent solicitors (non-registered
representatives) for the referral of their clients to our firm in accordance with relevant state statutes
and rules.
Please see Item 5: Fees and Compensation, Item 10: Other Financial Industry Activities and
Affiliations, and Item 12: Brokerage Practices for additional discussion about other compensation
and non-economic benefits.
Item 15: Custody
State Securities Bureaus, or their equivalents, generally take the position that any arrangement under
which a registered investment adviser is authorized or permitted to withdraw client funds or
securities maintained with a custodian upon the adviser’s instruction to the custodian is deemed to
have custody of client funds and securities. Based on this understanding, it is important to note that
LPL is deemed to have constructive custody and not the Adviser since clients of our firm direct LPL
to deduct advisory fees from their accounts through the account opening paperwork and not through
the Adviser’s client agreement. LPL is responsible for calculating fees and deducting fees from client’s
accounts. Therefore, the Adviser does not hold either constructive or actual custody of client accounts.
As part of this process, you understand and acknowledge the following:
a) LPL Financial as the custodian sends statements at least quarterly to Clients showing all
disbursements for their account, including the amount of the advisory fees paid to our firm;
b) The Client has provided authorization permitting fees to be directly paid by these terms;
c) LPL Financial calculates the advisory fees and deducts them from the Client’s account.
We encourage our clients to raise any questions with us about the custody, safety or security of their
assets. The custodians we do business with will send you account statements listing your account
balance(s), transaction history and any fee debits or other fees taken out of your account.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, we are
authorized to execute securities transactions, which securities are bought and sold, the total amount
to be bought and sold, and the costs at which the transactions will be effected. Limitations may be
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imposed by the client in the form of specific constraints on any of these areas of discretion with our
firm’s written acknowledgement.
Item 17: Voting Client Securities
We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies
or other solicitations directly from their custodian or a transfer agent. In the event that proxies are
sent to our firm, we will forward them on to you and ask the party who sent them to mail them
directly to you in the future. Clients may call, write or email us to discuss questions they may have
about particular proxy votes or other solicitations.
Item 18: Financial Information
We are not required to provide financial information in this Brochure because:
• We do not require the prepayment of more than $500 in fees and six or more months in
advance.
• We do not take custody of client funds or securities.
• We do not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
We have never been the subject of a bankruptcy proceeding.
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