Overview
- Headquarters
- Irvine, CA
- Average Client Assets
- $1.1 million
- SEC CRD Number
- 166372
Fee Structure
Primary Fee Schedule (SGWP-FORM ADV PART 2A, APPENDIX 1: WRAP FEE PROGRAM)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 3.00% |
| $1,000,001 | $5,000,000 | 2.00% |
| $5,000,001 | and above | 1.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $30,000 | 3.00% |
| $5 million | $110,000 | 2.20% |
| $10 million | $160,000 | 1.60% |
| $50 million | $560,000 | 1.12% |
| $100 million | $1,060,000 | 1.06% |
Clients
- HNW Share of Firm Assets
- 77.99%
- Total Client Accounts
- 589
- Discretionary Accounts
- 589
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection, Educational Seminars
Regulatory Filings
Primary Brochure: SGWP-FORM ADV PART 2A, APPENDIX 1: WRAP FEE PROGRAM (2026-02-23)
View Document Text
Form ADV Part 2A Appendix 1 - Wrap Fee Program Brochure
Item 1: Cover Page
February 2026
17500 Red Hill Ave, Suite 140
Irvine, CA 92614
Firm Contact:
Brandon Chang,
Chief Compliance Officer
Firm Website Address:
www.sungroupwp.com
This wrap fee program brochure provides information about the qualifications and business
practices of Sun Group Wealth Partners LLC. If you have any questions about the contents of
this brochure, please contact Brandon Chang, Chief Compliance Officer, by telephone at (949)
625-6800 or by email at team@sungroupwp.com. The information in this brochure has not
been approved or verified by the United States Securities and Exchange Commission or by any
State Securities Authority.
Additional information about Sun Group Wealth Partners LLC is also available on the SEC’s
website at www.adviserinfo.sec.gov by searching IARD/CRD#: 166372.
Please note use of the term “registered investment adviser” and description of Sun Group
Wealth Partners LLC 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 its employees.
Item 2: Material Changes
LLC
is required to advise you of any material changes to our Wrap
Sun Group Wealth Partners
Brochure (“Brochure”) from our last annual update.
rd
, 2025, we have no material changes to report.
Since our last annual amendment filed on January 23
2
Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................................. 1
Item 2: Material Changes ...................................................................................................................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Services, Fees & Compensation .......................................................................................................................... 4
Item 5: Account Requirements & Types of Clients .................................................................................................... 5
Item 6: Portfolio Manager Selection & Evaluation ..................................................................................................... 6
Item 7: Client Information Provided to Portfolio Manager(s) .............................................................................. 8
Item 8: Client Contact with Portfolio Manager(s) ...................................................................................................... 8
Item 9: Additional Information .......................................................................................................................................... 8
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Item 4: Services, Fees & Compensation
A wrap fee program allows our clients to pay a specified fee for investment advisory services and the
execution of transactions. The advisory services may include portfolio management and/or advice
concerning selection of other advisers, and the fee is not based directly upon transactions in your
account. Your fee is bundled with our costs for executing transactions in your account(s). This results
in a higher advisory fee to you. We do not charge our clients higher advisory fees based on their
trading activity, but you should be aware that we may have an incentive to limit our trading activities
in your account(s) because we are charged for executed trades.
LPL Financial offers a trading platform with select exchange traded funds (“ETFs”) that do not charge
transaction fees. The no-transaction-fee ETF trading platform is available to clients participating in
LPL Financial’s Strategic Wealth Management (“SWM”) and Strategic Asset Management (“SAM”)
programs. Since our firm pays the transaction fees charged by LPL Financial to clients participating
in our wrap fee program, we are incentivized to recommend no-transaction-fee ETFs over other
types of securities and ETFs in order to reduce our costs. This presents a conflict of interest because
the limited number of ETFs available on the no-transaction fee platform may have higher overall
expenses than other types of securities and ETFs not included in the platform. In addition, other
major custodians have eliminated transaction fees for all ETFs and U.S. equities, so clients may pay
more for investing in the same securities at LPL Financial.
Our Wrap Advisory Services
Our comprehensive wrap portfolio management service encompasses asset management as well as
providing financial planning/financial consulting to clients. It is designed to assist clients in meeting
their financial goals through the use of financial investments. We conduct at least one, but sometimes
more than one meeting (in person if possible, otherwise via telephone conference) with clients in
order to understand their current financial situation, existing resources, financial goals, and
tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may
propose an investment portfolio, consisting of exchange traded funds, mutual funds, individual
stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan,
we work with the client to establish or transfer investment accounts so that we can manage the
client’s portfolio. Once the relevant accounts are under our management, we review such accounts
on a regular basis and at least quarterly. We may periodically rebalance or adjust client accounts
under our management. If the client experiences any significant changes to his/her financial or
personal circumstances, the client must notify us so that we can consider such information in
managing the client’s investments.
Our firm may utilize the sub-advisory services of third party investment advisor to aid in the
implementation of an investment portfolio designed by our firm. Before selecting a firm or individual,
our firm will ensure that the chosen party is properly licensed or registered.
Our maximum fee for our Comprehensive Wrap Portfolio Management service is 3.00% and our
baseline fee schedule is as follows:
Maximum Fee Schedule: Fee-Based Accounts Managed by Sun Group Wealth Partners
Assets Under Management
Annual Percentage of Assets Charge
$0 to $999,999.00
$999,999.01 to $5,000,000.00
3.00%
2.00%
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Over $5,000,000.01
1.00%
Maximum Fee Schedule: Fee-Based Accounts Utilizing Third Party Money Managers
Assets Under Management
Annual Percentage of Assets Charge
$0 to $999,999.00
$999,999.01 to $5,000,000.00
Over $5,000,000.01
3.00%
2.00%
1.00%
Our firm’s fees are generally negotiable and will be determined on a case-by-case basis. Further, 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. Please note that fees will be adjusted for deposits and
withdrawals made during the quarter. Unless otherwise noted in writing, our firm bills on cash. As
part of this process, you understand and acknowledge the following:
a)
b)
c)
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;
The Client has provided authorization permitting fees to be directly paid by these terms;
LPL Financial calculates the advisory fees and deducts them from the Client’s account.
Other Types of Fees & Expenses:
You may pay custodial fees, 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), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and
other fees and taxes on brokerage accounts and securities transactions. These fees are not included
within the wrap-fee you are charged by our firm.
Our investment advisory representatives receive a portion of the advisory fee that you pay us, either
directly as a percentage of your overall fee or as their salary from our firm. In cases where our
investment advisory representatives are paid a percentage of your overall advisory fee, this may
create an incentive to recommend that you participate in a wrap fee program. This is because, in
some cases, we may stand to earn more compensation from advisory fees paid to us through a wrap
fee program arrangement if your account is not actively traded.
Although clients do not pay a transaction charge for transactions in a SWM II account, clients should
be aware that our firm pays LPL transaction charges for those transactions. The transaction charges
paid by our firm 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. Transaction charges paid by the Advisor for equities and ETFs are $9. For mutual funds, the
transaction charges range from $0 to $26.50. Because our firm pays the transaction charges in SWM
II accounts, there is a conflict of interest in cases where the mutual fund is offered at both $0 and
$26.50. Clients should understand that the cost to our firm for transaction charges may be a factor
that we consider when deciding which securities to select and how frequently to place transactions
in a SWM II account.
In many instances, LPL makes available mutual funds in a SWM II account that offer various classes
of shares, including shares designated as Class A Shares and shares designed for advisory programs,
which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,”
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“administrative” or “platform” share classes (“Platform Shares”). The Platform Share class offered for
a particular mutual fund in SWM II in many 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 II. 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 firm has a financial incentive to recommend Class A Shares in cases where both Class A and
Platform Shares are available. This is a conflict of interest which might incline our firm, consciously
or unconsciously, to render advice that is not disinterested. Although the client will not be charged a
transaction charge for transactions, Advisor pays LPL a per transaction charge for mutual fund
purchases and sales in the account. our firm generally does not pay transaction charges for Class A
Share mutual fund transactions accounts, but generally does pay transaction charges for Platform
Share mutual fund transactions. The cost to our firm of transaction charges generally may be a factor
Advisor considers when deciding which securities to select and whether or not to place transactions
in the account.
The lack of transaction charges to our firm for Class A Share purchases and sales, together with the
fact that Platform Shares generally are less expensive for a client to own, presents a significant
conflict of interest between our firm and the client. In short, it costs our firm less to recommend and
select Class A share mutual funds than Platform shares, but Platform shares will generally
outperform Class A mutual fund shares on the basis of internal cost structure alone. Clients should
understand this conflict and consider the additional indirect expenses borne as a result of the mutual
fund fees when negotiating and discussing with your Advisor the advisory fee for management of an
account.
Item 5: Account Requirements & Types of Clients
We do not require a minimum account size to open or maintain an account.
Types of clients we typically manage wrap fee accounts on behalf of, include:
•
•
•
•
Individuals;
High Net-Worth Individuals;
Trusts, Estates or Charitable Organizations;
Pension and Profit-Sharing Plans; and
Item 6: Portfolio Manager Selection & Evaluation
Our firm and its related persons act as portfolio manager(s) for this wrap fee program(s). This may
create a conflict of interest in that other investment advisory firms may charge the same or lower
fees than our firm for similar services. Our related person portfolio managers are not subject to the
same selection and review as outside portfolio managers that participate in the wrap fee program.
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Our firm selects and reviews outside portfolio managers based on the following factors:
•
•
•
•
•
•
past performance;
investment philosophy;
market outlook;
experience of portfolio managers and executive team;
disciplinary, legal and regulatory histories of the firm and its associates;
whether established compliance procedures are in place to address at a minimum, insider
trading, conflicts of interest, anti-money laundering.
Advisory Business:
See Item 4 of this Wrap Fee Program Brochure for information about our wrap fee advisory
programs. Our wrap fee accounts are managed on an individualized basis according to the client’s
investment objectives, financial goals, risk tolerance, etc.
We usually do not allow clients to impose restrictions on investing in certain securities or types of
securities due to the level of difficulty this would entail in managing their account. In the rare
instance, we would allow reasonable restrictions.
Performance-Based Fees & Side-By-Side Management:
Methods of Analysis, Investment Strategies & Risk of Loss:
We do not charge performance fees to our clients.
Charting.
In this type of technical analysis, we review charts of market and security activity in an
attempt to identify when the market is moving up or down and to predict when how long the
Fundamental Analysis.
trend may last and when that trend might reverse.
We attempt to measure the intrinsic value of a security by looking at
economic and financial factors (including the overall economy, industry conditions, and the
financial condition and management of the company itself) to determine if the company is
underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to
sell). Fundamental analysis does not attempt to anticipate market movements. This presents a
potential risk, as the price of a security can move up or down along with the overall market
Technical Analysis.
regardless of the economic and financial factors considered in evaluating the stock.
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.
Cyclical Analysis.
In this type of technical analysis, we measure the movements of a particular
Investment Strategies We Use:
stock against the overall market in an attempt to predict the price movement of the security.
Long-Term Purchases.
When utilizing this strategy, we may 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
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Short-Term Purchases.
are incorrect, a security may decline sharply in value before we make the decision to sell.
When utilizing this strategy, we may also purchase securities with the idea
of selling them within a relatively short time (typically a year or less). We do this in an attempt
to take advantage of conditions that we believe will soon result in a price swing in the securities
Trading.
we purchase.
We purchase securities with the idea of selling them very quickly (typically within 30
Option Writing.
days or less). We do this in an attempt to take advantage of our predictions of brief price swings.
Please Note:
We may use options as an investment strategy. An option is a contract that gives
the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a
specific price on or before a certain date. An option, just like a stock or bond, is a security. An
option is also a derivative, because it derives its value from an underlying asset.
Investing in securities involves risk of loss that clients should be prepared to bear.
While the stock market may increase and your account(s) could enjoy a gain, it is also possible that
the stock market may 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
Voting Client Securities:
your investments, and ask us any questions you may have.
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 7: Client Information Provided to Portfolio Manager(s)
We are required to describe the information about you that we communicate to your portfolio
manager(s), and how often or under what circumstances we provide updated information. Our firm
communicates with your portfolio manager(s) on a regular basis as needed (daily, weekly, monthly,
etc) to ensure your most current investment goals and objectives are understood by your portfolio
manager(s). In most cases, we will communicate such information as part of our regular investment
management duties. Nevertheless, we will also communicate information to your portfolio
manager(s) when you ask us to, when market or economic conditions make it prudent to do so, etc.
Item 8: Client Contact with Portfolio Manager(s)
Clients are always free to directly contact their portfolio manager(s) with any questions or concerns
they have about their portfolios or other matters
Item 9: Additional Information
Disciplinary Information
We have determined that our firm and management have no disciplinary information to disclose.
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Financial Industry Activities & Affiliations
We have the following financial industry activities and affiliations to disclose:
a. Our firm’s supervised persons are registered representatives of LPL Financial, LLC (“LPL”),
member FINRA/SIPC. They may offer securities and receive normal and customary
commissions as a result of securities transactions. A conflict of interest may arise as these
commissionable securities sales may create an incentive to recommend products based on
the compensation they may earn and may not necessarily be in the best interests of the client.
This is fully disclosed to Clients and Clients are under no obligation to purchase securities
from our firm’s supervised persons.
Code of Ethics, Participation or Interest in Client Transactions & Personal Trading
b. Representatives of our firm are insurance agents/brokers. They may offer insurance
products and receive normal and customary fees as a result of insurance sales. A conflict of
interest may arise as these insurance sales may create an incentive to recommend products
based on the compensation adviser and/or our supervised persons may earn and may not
necessarily be in the best interests of the client. Clients are under no obligation to purchase
insurance products from our representatives.
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.
1
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
. In order to monitor compliance with our personal trading policy, we have a
their personal accounts
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.
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.
9
Review of Accounts
We review accounts on at least a quarterly basis for our clients. 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. Only our Financial Advisors or
Portfolio Managers will conduct reviews.
We may review client accounts more frequently than described above. Among the factors which may
trigger an off-cycle review are major market or economic events, the client’s life events, requests by
the client, etc.
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.
Client Referrals & Other Compensation
We may receive from LPL, without cost and/or at a discount non soft-dollar support services and/or
products, to assist us to better monitor and service client accounts maintained at LPL. Included
within the support services we may 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.
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.
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm provides cash or
non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals). Such compensation arrangements will not result in
higher costs to the referred client. In this regard, our firm maintains a written agreement with each
unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of
$1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period
in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and
federal laws. The following information will be disclosed clearly and prominently to referred
prospective clients at the time of each testimonial or endorsement:
•
•
•
Whether or not the unaffiliated person is a current client of our firm,
A description of the cash or non-cash compensation provided directly or indirectly by our
firm to the unaffiliated person in exchange for the referral, if applicable, and
A brief statement of any material conflicts of interest on the part of the unaffiliated person
giving the referral resulting from our firm’s relationship with such unaffiliated person.
In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are
paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm
is paying solicitation fees to another registered investment adviser, the licensure of individuals is the
Financial Information
other firm’s responsibility.
10
•
We are not required to provide financial information in this Brochure because:
•
•
•
We do not require the repayment of more than $1,200 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 its ability to meet
contractual and fiduciary obligations to clients.
We have never been the subject of a bankruptcy proceeding.
11
Additional Brochure: SGWP-FORM ADV PART 2A: FIRM BROCHURE (2026-02-23)
View Document Text
Form ADV Part 2A - Firm Brochure
Item 1: Cover Page
February 2026
17500 Red Hill Ave, Suite 140
Irvine, CA 92614
Firm Contact:
Brandon Chang
Chief Compliance Officer
Firm Website Address:
www.sungroupwp.com
This brochure provides information about the qualifications and business practices of Sun
Group Wealth Partners LLC. If you have any questions about the contents of this brochure,
please contact Brandon Chang, Chief Compliance Officer, by telephone at (949) 625-6800 or
by email at team@sungroupwp.com. The information in this brochure has not been approved
or verified by the United States Securities and Exchange Commission or by any State Securities
Authority.
Additional information about Sun Group Wealth Partners LLC also is available on the SEC’s
website at www.adviserinfo.sec.gov by searching IARD/CRD#: 166372.
Please note that the use of the term “registered investment adviser” and description of Sun
Group Wealth Partners LLC 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
LLC
is required to advise you of any material changes to our Firm
Sun Group Wealth Partners
Brochure (“Brochure”) from our last annual update.
rd
, 2025, we have no material changes to report.
Since our last annual amendment filed on January 23
2
Item 3: Table of Contents
Item 1: Cover Page for Part 2A of Form ADV: Firm Brochure ............................................................................... 1
Item 2: Material Changes to Our Part 2A of Form ADV: Firm Brochure ........................................................... 2
Item 3: Table of Contents ..................................................................................................................................................... 3
Item 4: Advisory Business.................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................. 7
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 9
Item 7: Types of Clients & Account Requirements .................................................................................................... 9
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 9
Item 9: Disciplinary Information .................................................................................................................................... 10
Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 11
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............. 11
Item 12: Brokerage Practices ........................................................................................................................................... 12
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 12
Item 14: Client Referrals & Other Compensation ..................................................................................................... 14
Item 15: Custody .................................................................................................................................................................... 14
Item 16: Investment Discretion ....................................................................................................................................... 15
Item 17: Voting Client Securities ..................................................................................................................................... 15
Item 18: Financial Information ........................................................................................................................................ 15
3
Item 4: Advisory Business
Sun Group Wealth Partners LLC is a full-service wealth management firm located in Irvine, California.
Our firm is a limited liability company
formed in the State of California on February 2011 and began
registration as an independent investment adviser in 2012. The firm is owned by Winnie Sun, C.E.O.
& Founding Partner and Brandon Chang, Co-Founder & Chief Compliance Officer.
With more than 25 years of collective advisory experience, the representatives of Sun Group Wealth
Partners LLC serves wealthy families, business owners, corporate executives, Hollywood elite and
nonprofit organizations throughout the West Coast. Offering a wide range of services from financial
planning to investment management to charitable giving, Sun Group Wealth Partners aligns clients’
financial lives with their goals for the future.
Description of the Types of Advisory Services We Offer
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 may encompass one or more of the
following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning,
Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate
Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit
Evaluation, 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 may 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. 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.
Pension Consulting:
We provide pension consulting services to employer plan sponsors on a one-time or ongoing basis.
Generally, such pension consulting services consist of assisting employer plan sponsors in
establishing, monitoring and reviewing their company's participant-directed retirement plan. As the
needs of the plan sponsor dictate, areas of advising could include: investment options, plan structure
and participant education.
All pension consulting services shall be in compliance with the applicable state law(s) regulating
pension consulting services. This applies to client accounts that are pension or other employee
benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide
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our services to such accounts, we acknowledge that we are a fiduciary within the meaning of Section
3(21) of ERISA (but only with respect to the provision of services described in section 1 of the
Pension Consulting Agreement).
LPL Financial Sponsored Advisory Programs:
Our firm may provide advisory services through certain programs sponsored by LPL Financial, LLC
(“LPL”), a registered investment advisor 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 program
account packet (which includes the account agreement and LPL Form ADV program brochure) and the
Form ADV, Part 2A of LPL or the applicable program.
The following advisory services are made available through LPL:
• Manager Access Select (MAS)
Manager Access Select offers clients the ability to participate in the Separately Managed
Account Platform (the “SMA Platform”) or the Model Portfolio Platform (the “MP Platform”).
In the SMA Platform, our firm will assist client in identifying a third party portfolio manager
(SMA Portfolio Manager) from a list of SMA Portfolio Managers made available by LPL, and
the SMA Portfolio Manager manages client’s assets on a discretionary basis. Our firm will
provide initial and ongoing assistance regarding the SMA Portfolio Manager selection
process. In the MP Platform, clients authorize LPL to direct the investment and reinvestment
of the assets in their accounts, in accordance with the selected model portfolio provided by
LPL’s Research Department or a third-party investment advisor.
A minimum account value of $50,000 is required for Manager Access Select, however, in
certain instances, the minimum account size may be lower or higher.
• Model Wealth Portfolios Program (MWP)
MWP offers clients a professionally managed mutual fund asset allocation program. Our firm
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. Our firm 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, a third-party portfolio
strategist and/or Advisor, through its IAR, may act as a portfolio strategist responsible for
selecting the mutual funds or ETFs within a model portfolio and for making changes to the
mutual funds or ETFs selected.
The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds
and ETFs and to liquidate previously purchased securities. The client will also authorize LPL
to effect rebalancing for MWP accounts.
MWP requires a minimum asset value for a program account to be managed. The minimums
vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios.
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The lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a
portfolio is permitted.
• Guided Wealth Portfolios Program (“GWP”):
GWP offers clients the ability to participate in a centrally managed, algorithm-based
investment program, which is made available to users and clients through a web-based,
interactive account management portal (“Investor Portal”). Investment recommendations to
buy and sell open-end mutual funds and exchange-traded funds are generated through
proprietary, automated, computer algorithms (collectively, the “Algorithm”) of Xulu, Inc.,
doing business as FutureAdvisor (“FutureAdvisor”), based upon model portfolios
constructed by LPL and selected for the account as described below (such model portfolio
selected for the account, the “Model Portfolio”). Communications concerning GWP are
intended to occur primarily through electronic means (including but not limited to, through
email communications or through the Investor Portal), although our firm will be available to
discuss investment strategies, objectives or the account in general in person or via telephone.
A preview of the GWP Program (the “Educational Tool”) is provided for a period of up to 45
days to help users determine whether they would like to become advisory clients and receive
ongoing financial advice from LPL, FutureAdvisor and our firm by enrolling in the advisory
service (the “Managed Service”). The Educational Tool and Managed Service are described in
more detail in the GWP Program Brochure. Users of the Educational Tool are not considered
to be advisory clients of LPL, FutureAdvisor or our firm, do not enter into an advisory
agreement with LPL, FutureAdvisor or our firm, do not receive ongoing investment advice or
supervisions of their assets, and do not receive any trading services.
A minimum account value of $5,000 is required to enroll in the Managed Service.
Newsletters/Educational Seminars
We may offer newsletters which generally include market updates. We may also offer educational
seminars covering topics such as retirement, investments and financial planning.
Tailoring of Advisory Services
We offer general investment advice to clients utilizing our Financial Planning & Consulting, LPL
Sponsored Advisory Programs and Pension Consulting services.
Each client has the opportunity to place reasonable restrictions on the types of investments to be held
in the portfolio. However, 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.
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 accounts are managed on an individualized basis according
to the client’s investment objectives, financial goals, risk tolerance, etc. As further described in our
Wrap Fee Program Brochure, we receive a portion of the wrap fee for our services.
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Regulatory Assets Under Management
As of December 31, 2025, our firm manages $224,450,529 on a discretionary basis and $0 on a non-
discretionary basis.
Item 5: Fees & Compensation
How We Are Compensated for Our Advisory Services
& Compensation
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 fee is $350. Flat fees generally range from $2,000 to $5,000.
We 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 $1,200 when services cannot be rendered within 6 (six) months.
Pension Consulting:
We charge on an hourly, flat fee, or percentage of assets under management for pension 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.
For one-time engagements, our hourly fee is $350. Our flat fees generally range from $2,000 to
$5,000.
For ongoing monitoring and management, we charge based on a percentage of assets under
management up to 1.00%.
The fee-paying arrangements for pension consulting service will be determined on a case-by-case
basis and will be detailed in the signed Pension Consulting Agreement. Clients will either be invoiced
directly or fees may be withdrawn from their managed account.
LPL Sponsored Advisory Programs:
The account fee charged to the client for each LPL advisory program is negotiable, subject to the
following maximum account fees:
Advisory Program
Annual Percentage of Assets Charge
Manager Access Select
Model Wealth Portfolios
Guided Wealth Portfolios
3.00%
2.65%
1.35%
Account fees are payable quarterly in advance. LPL Financial has a separate billing process which we
have no control over. In general, they will directly bill you and describe how this works in their
separate written disclosure documents. Unless otherwise noted in writing, our firm bills on cash.
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Our firm receives compensation as a result of a client’s participation in an LPL program. Depending
on, among other things, the type and size of the account, type of securities held in the account,
changes in its value over time, the ability to negotiate fees or commissions, the historical or expected
size or number of transactions, and the number and range of supplementary advisory and client-
related services provided to the client, the amount of this compensation may be more or less than
what the our firm would receive if the client participated in other programs, whether through LPL or
another sponsor, or paid separately for investment advice, brokerage and other services.
The account fee may be higher than the fees charged by other investment advisors for similar
services. For instance, FutureAdvisor offers direct-to-consumer services similar to GWP. Therefore,
clients could generally pay a lower advisory fee for algorithm-driven, automated (“robo”) investment
advisory services through FutureAdvisor or other robo providers. However, clients using such direct
robo services will forgo opportunities to utilize LPL-constructed model portfolios or to work directly
with a financial advisor.
Clients should consider the level and complexity of the advisory services to be provided when
negotiating the account fee (or the advisor fee portion of the account fee, as applicable) with our firm.
With regard to accounts utilizing third-party portfolio managers under aggregate, all-in-one account
fee structures (including MAS, PWP and the legacy MWP fee structure), because the portion of the
account fee retained by our firm varies depending on the portfolio strategist fee associated with a
portfolio, our firm has a financial incentive to select one portfolio instead of another portfolio.
Please refer to the relevant LPL Form ADV program brochure for a more detailed discussion of
conflicts of interest.
Newsletters/Educational Seminars
We do not charge a fee for these services.
Other Types of Fees & 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.
Termination & Refunds
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
As registered representatives of LPL Financial, LLC (“LPL”), our adviser representatives may sell
securities for a commission. Our supervised persons may 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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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 may earn and may not
necessarily be in the best interests of the client; or when recommending commissionable
mutual funds, explaining that “no-load” funds are available through our firm if the client
wishes to become an investment advisory client.
2) In no way prohibits you from purchasing investment products recommended by us through
other brokers or agents which are not affiliated with us.
3) Does not exceed more than 50% of our revenue.
4) Does not reduce your advisory fees to offset the commissions our supervised persons receive.
The individuals that are licensed as registered representatives of LPL Financial are subject to
regulations that restrict them from conducting securities transactions away from LPL Financial
without written authorization from LPL Financial. Clients should, therefore, be aware that our firm
is limited to offering services and investment vehicles that are approved by LPL Financial, and may
be prohibited from offering services and investment vehicles that may be available through other
broker/dealers and custodians
Item 6: Performance-Based Fees & Side-By-Side Management
We do not charge performance fees to our clients.
Item 7: Types of Clients & Account Requirements
We have the following types of clients:
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Individuals;
High Net Worth Individuals;
Trusts, Estates or Charitable Organizations;
Pension and Profit-Sharing Plans; and
We do not require a minimum account size to open or maintain an account.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis:
Charting.
In this type of technical analysis, we review charts of market and security activity in an
attempt to identify when the market is moving up or down and to predict when how long the
trend may last and when that trend might reverse.
Fundamental Analysis.
We attempt to measure the intrinsic value of a security by looking at
economic and financial factors (including the overall economy, industry conditions, and the
financial condition and management of the company itself) to determine if the company is
underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to
sell). Fundamental analysis does not attempt to anticipate market movements. This presents a
potential risk, as the price of a security can move up or down along with the overall market
regardless of the economic and financial factors considered in evaluating the stock.
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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.
Cyclical Analysis.
In this type of technical analysis, we measure the movements of a particular
stock against the overall market in an attempt to predict the price movement of the security.
Investment Strategies We Use:
Long-Term Purchases.
When utilizing this strategy, we may 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 may decline sharply in value before we make the decision to sell.
Short-Term Purchases.
When utilizing this strategy, we may also purchase securities with the idea
of selling them within a relatively short time (typically a year or less). We do this in an attempt
to take advantage of conditions that we believe will soon result in a price swing in the securities
we purchase.
Trading.
We purchase securities with the idea of selling them very quickly (typically within 30
days or less). We do this in an attempt to take advantage of our predictions of brief price swings.
Option Writing.
We may use options as an investment strategy. An option is a contract that gives
the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a
specific price on or before a certain date. An option, just like a stock or bond, is a security. An
option is also a derivative, because it derives its value from an underlying asset.
Please Note
: Investing in securities involves risk of loss that clients should be prepared to bear.
While the stock market may increase and your account(s) could enjoy a gain, it is also possible that
the stock market may 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.
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, as applicable.
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
Our firm’s supervised persons are registered representatives of LPL, member FINRA/SIPC. They may
offer securities and receive normal and customary commissions as a result of securities transactions.
A conflict of interest may arise as these commissionable securities sales may create an incentive to
recommend products based on the compensation they may earn and may not necessarily be in the
best interests of the client. This is fully disclosed to Clients and Clients are under no obligation to
purchase securities from our firm’s supervised persons.
Representatives of our firm are insurance agents/brokers. They may offer insurance products and
receive normal and customary fees as a result of insurance sales. A conflict of interest may arise as
these insurance sales may create an incentive to recommend products based on the compensation
adviser and/or our supervised persons may earn and may not necessarily be in the best interests of
the client. Clients are under no obligation to purchase insurance products from our representatives.
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 accounts. 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.
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Related persons of our firm may 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 may 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.
Item 12: Brokerage Practices
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:
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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 some non-soft dollar benefits from LPL through
our participation in the program. Please see the disclosure under Item 14 of this Brochure.
Our firm receives support services and/or products from LPL Financial, many of which assist our
firm to better monitor and service program accounts maintained at LPL Financial; however, some of
the services and products benefit our firm and not client accounts. These support services and/or
products may be received without cost, at a discount, and/or at a negotiated rate, and may include
the following:
investment-related research
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• pricing information and market data
• software and other technology that provide access to client account data
• compliance and/or practice management-related publications
• consulting services
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• attendance at conferences, meetings, and other educational and/or social events
• marketing support
• computer hardware and/or software
• other products and services used by our firm in furtherance of its investment advisory
business operations
LPL Financial may provide these services and products directly, or may arrange for third party
vendors to provide the services or products to Advisor. In the case of third party vendors, LPL
Financial may pay for some or all of the third party’s fees.
These support services are provided to our firm based on the overall relationship between our firm
and LPL Financial. It is not the result of soft dollar arrangements or any other express arrangements
with LPL Financial that involves the execution of client transactions as a condition to the receipt of
services. Our firm will continue to receive the services regardless of the volume of client transactions
executed with LPL Financial. Clients do not pay more for services as a result of this arrangement.
There is no corresponding commitment made by the our firm to LPL or any other entity to invest any
specific amount or percentage of client assets in any specific securities as a result of the arrangement.
However, because Advisor receives these benefits from LPL Financial, there is a potential conflict of
interest. The receipt of these products and services presents a financial incentive for Advisor to
recommend that its clients use LPL Financial’s custodial platform rather than another custodian’s
platform.
As stated previously, individuals associated with our firm are licensed as registered representatives
of LPL Financial. As a result of this licensing relationship, LPL Financial is responsible for supervising
certain activities of our firm to the extent our firm manages assets at a broker/dealer and custodian
other than LPL Financial. LPL Financial charges a fee for this oversight. This presents a conflict of
interest in that our firm has a financial incentive to recommend that you maintain your account with
LPL Financial rather than another custodian in order to avoid the oversight fee. However, to the
extent our firm recommends you use LPL Financial for such services, it is because our firm believes
that it is in your best 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
Item 13: Review of Accounts or Financial Plans
Financial.
We review accounts on at least a quarterly basis for our clients. 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. Only our Financial Advisors or
Portfolio Managers will conduct reviews.
We may review client accounts more frequently than described above. Among the factors which may
trigger an off-cycle review are major market or economic events, the client’s life events, requests by
the client, etc.
We do not issue regular reports. Account statements are issued by the custodian(s). Clients receive
confirmations of each transaction in accounts from the Custodian and an additional statement during
any month in which a transaction occurs.
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Item 14: Client Referrals & Other Compensation
LPL Financial
We may receive from LPL or a mutual fund company, without cost and/or at a discount non soft-
dollar 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 may 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.
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm provides cash or
non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals). Such compensation arrangements will not result in
higher costs to the referred client. In this regard, our firm maintains a written agreement with each
unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of
$1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period
in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and
federal laws. The following information will be disclosed clearly and prominently to referred
prospective clients at the time of each testimonial or endorsement:
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Whether or not the unaffiliated person is a current client of our firm,
A description of the cash or non-cash compensation provided directly or indirectly by our
firm to the unaffiliated person in exchange for the referral, if applicable, and
A brief statement of any material conflicts of interest on the part of the unaffiliated person
giving the referral resulting from our firm’s relationship with such unaffiliated person.
In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are
paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm
is paying solicitation fees to another registered investment adviser, the licensure of individuals is the
other firm’s responsibility.
Item 15: Custody
We do not have custody of client funds or securities. All of our clients receive at least quarterly
account statements directly from their custodians. Upon opening an account with a qualified
custodian on a client's behalf, we promptly notify the client in writing of the qualified custodian's
contact information. If we decide to also send account statements to clients, such notice and account
statements include a legend that recommends that the client compare the account statements
received from the qualified custodian with those received from our firm.
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 independent account statements listing
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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
a signed 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 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
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We are not required to provide financial information in this Brochure because:
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We do not require the repayment of more than $1,200 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 its ability to meet
contractual and fiduciary obligations to clients.
We have never been the subject of a bankruptcy proceeding.
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