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Item 1: Cover Page
SwitchPoint Financial Planning LLC
2901 W Bluegrass Blvd
Suite 200 - 26
Lehi, UT 84043
Phone: (801) 753-8538
Form ADV Part 2A – Firm Brochure
Dated March 27, 2025
This Brochure provides information about the qualifications and business practices of SwitchPoint
Financial Planning LLC, “SwitchPoint”. If you have any questions about the contents of this Brochure,
please contact us at 801.753.8538. 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.
SwitchPoint Financial Planning LLC is registered as an Investment Adviser with the Securities and Exchange
Commission. Registration of an Investment Adviser does not imply any level of skill or training.
Additional information about SwitchPoint is available on the SEC’s website at www.adviserinfo.sec.gov
which can be found using the firm’s identification number 282856.
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Item 2: Material Changes
The material changes in this brochure from the last annual updating amendment of SwitchPoint on
3/15/2024 are described below. Material changes relate to SwitchPoint’s policies, practices, or conflicts
of interest.
No material changes to report
Future Changes
From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices,
changes in regulations and routine annual updates as required by the securities regulators. This
complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client
annually and if a material change occurs in the business practices of SwitchPoint.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser
Public Disclosure website at http://www.adviserinfo.sec.gov by searching for our firm name or by our
CRD number 282856. You may also request a copy of this Disclosure Brochure at any time, by contacting
us at 801.753.8538.
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Item 3: Table of Contents
Item 1: Cover Page
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Item 2: Material Changes
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Item 3: Table of Contents
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Item 4: Advisory Business
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Item 5: Fees and Compensation
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Item 6: Performance-Based Fees and Side-By-Side Management
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Item 7: Types of Clients
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Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
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Item 9: Disciplinary Information
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Item 10: Other Financial Industry Activities and Affiliations
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
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Item 12: Brokerage Practices
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Item 13: Review of Accounts
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Item 14: Client Referrals and Other Compensation
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Item 15: Custody
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Item 16: Investment Discretion
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Item 17: Voting Client Securities
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Item 18: Financial Information
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Item 4: Advisory Business
Description of Advisory Firm
SwitchPoint Financial Planning LLC is registered as an Investment Adviser with the Securities and Exchange
Commission. We were founded in March 2016. James R. Sweeney is the principal owner of SwitchPoint.
As of December 31, 2024, SwitchPoint Financial Planning LLC reports $275,481,297 in Discretionary
Assets Under Management and $6,004,647 in Non-Discretionary Assets Under Management.
Types of Advisory Services
Financial Planning
Financial planning is a comprehensive evaluation of a client’s current and future financial state by using
currently known variables to predict future cash flows, asset values and withdrawal plans. The key
defining aspect of financial planning is that through the financial planning process, all questions,
information and analysis will be considered as they impact and are impacted by the entire financial and
life situation of the client. Clients purchasing this service will receive a written or an electronic report,
providing the client with a detailed financial plan designed to achieve his or her stated financial goals
and objectives.
In general, the financial plan will address any or all of the following areas of concern. The client and
advisor will work together to select the specific areas to cover. These areas may include, but are not
limited to, the following:
Cash Flow and Debt Management: We will conduct a review of your income and expenses to
determine your current surplus or deficit along with advice on prioritizing how any surplus should
be used or how to reduce expenses if they exceed your income. Advice may also be provided on
which debts to pay off first based on factors such as the interest rate of the debt and any income
tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that
should be considered for emergencies and other financial goals, along with a review of accounts
(such as money market funds) for such reserves, plus strategies to save desired amounts.
College Savings: Includes projecting the amount that will be needed to achieve college or other
post-secondary education funding goals, along with advice on ways for you to save the desired
amount. Recommendations as to savings strategies are included, and, if needed, we will review
your financial picture as it relates to eligibility for financial aid or the best way to contribute to
grandchildren (if appropriate).
Employee Benefits Optimization: We will provide review and analysis as to whether you, as an
employee, are taking the maximum advantage possible of your employee benefits. If you are a
business owner, we will consider and/or recommend the various benefit programs that can be
structured to meet both business and personal retirement goals.
Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current
estate plan, which may include whether you have a will, powers of attorney, trusts and other
related documents. Our advice also typically includes ways for you to minimize or avoid future
estate taxes by implementing appropriate estate planning strategies such as the use of applicable
trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or
complete estate planning activities. We may provide you with contact information for attorneys who
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specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we may
participate in meetings or phone calls between you and your attorney with your approval or request.
Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We
will identify what you plan to accomplish, what resources you will need to make it happen, how
much time you will need to reach the goal, and how much you should budget for your goal.
Investment Analysis: Our investment approach is holistic in nature. We consider not only accounts
managed by SwitchPoint, but other assets owned by the client in developing an asset allocation
strategy to meet clients’ financial goals and risk tolerance. This includes, but is not limited to,
reviewing employee stock options, defined contribution plans (401k, 403b, etc), real estate assets,
and other private investments, as well as assisting you in establishing investment accounts at a
selected broker/dealer or custodian. The strategies and types of investments we may recommend
are further discussed in Item 8 of this brochure.
Retirement Planning: Our retirement planning services typically include projections of your
likelihood of achieving your financial goals. For situations where projections show less than the
desired results, we may make recommendations, including those that may impact the original
projections by adjusting certain variables (i.e., working longer, saving more, spending less, taking
more risk with investments). If you are near retirement or already retired, we will do a thorough
analysis of your social security and pension benefits, as well as retirement accounts and other
assets available for retirement needs. Advice may be given on appropriate distribution strategies to
minimize the likelihood of running out of money or having to adversely alter spending during your
retirement years.
Insurance/Risk Management: A risk management review includes an analysis of your exposure to
major risks that could have a significant adverse impact on your financial picture, such as premature
death, disability, property and casualty losses, or the need for long‐term care planning. Advice may
be provided on ways to minimize such risks and about weighing the costs of purchasing insurance
versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self‐
insuring”).
Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a
part of your overall financial planning picture. For example, we may make recommendations on
which type of account(s) or specific investments should be owned based in part on their “tax
efficiency,” with consideration that there is always a possibility of future changes to federal, state or
local tax laws and rates that may impact your situation. We recommend that you consult with a qualified
tax professional before initiating any tax planning strategy, and we may provide you with contact information
for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We
will participate in meetings or phone calls between you and your tax professional with your approval.
Investment Management Services
We are in the business of managing individually tailored investment portfolios on a discretionary and
non-discretionary basis. Our firm provides continuous advice to a client regarding the investment of
client funds based on the individual needs of the client. Through personal discussions in which goals and
objectives based on a client's particular circumstances are established, we develop a client's personal
investment plan with an asset allocation target and create and manage a portfolio based on that policy
and allocation target. During our data-gathering process, we determine the client’s individual objectives,
time horizons, risk tolerance, and liquidity needs. We may also review and discuss a client’s prior
investment history, as well as family composition and background.
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Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation,
growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable
restrictions on investing in certain securities, types of securities, or industry sectors. Fees pertaining to
this service are outlined in Item 5 of this brochure.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow us to determine
the specific securities and the amount of securities to be purchased or sold for your account without
your approval prior to each transaction. Discretionary authority is typically granted by the investment
advisory agreement you sign with our firm and the appropriate trading authorization forms. You may, in
our sole discretion, limit our discretionary authority (for example, limiting the types of securities that
can be purchased for your account) by providing our firm with your restrictions and guidelines in writing.
If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to
executing any transactions on behalf of your account.
Retirement Plan Consulting
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis.
Generally, such 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. Retirement Plan Consulting services typically include:
Establishing an Investment Policy Statement – Our firm will assist in the development a statement
that summarizes the investment goals and objectives along with the broad strategies to be employed
to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment
options and make recommendations for appropriate changes.
Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models
to aid Participants in developing strategies to meet their investment objectives, time horizon,
financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and notify the
client in the event of over/underperformance and in times of market volatility.
In providing services for retirement plan consulting, our firm does not provide any advisory services with
respect to the following types of assets: employer securities, real estate (excluding real estate funds and
publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid
investments, or brokerage window programs (collectively, “Excluded Assets”).
All retirement plan consulting services shall be in compliance with the applicable state laws regulating
retirement consulting services. This applies to client accounts that are retirement or other employee
benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974 (“ERISA”). If
the client accounts are part of a Plan, and our firm accepts appointments to provide services to such
accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of
ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of
services described therein.
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Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all of our clients. However, specific client financial plans and their
implementation are dependent upon the client Investment Policy Statement which outlines each client’s
current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific
plan to aid in the selection of a portfolio that matches restrictions, needs, and targets.
Clients may impose restrictions in investing in certain securities or types of securities in accordance with
their values or beliefs. However, if the restrictions prevent SwitchPoint from properly servicing the client
account, or if the restrictions would require SwitchPoint to deviate from its standard suite of services,
SwitchPoint reserves the right to end the relationship.
Wrap Fee Programs
We do not participate in wrap fee programs.
Item 5: Fees and Compensation
Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing
the investment advisory contract, the investment advisory contract may be terminated by the client
within five (5) business days of signing the contract without incurring any advisory fees.
How we are paid depends on the type of advisory service we are performing. Our primary fee type is
Comprehensive Financial Planning and Investment Management. All other fee types offered on case-by-
case basis at our discretion and will be outlined in the Client’s advisory contract.
Please review the fee and compensation information below.
Comprehensive Financial Planning and Investment Management
The fee for Comprehensive Financial Planning and Investment Management is an annual fee as follows:
Individual
Couple
Level 1
$6,000
$7,200
Level 2
$8,800
$10,200
Level 3
$11,600
$13,200
The above annual fees shall not to exceed 3% of client assets under management. The fee will be paid
quarterly, in advance at ¼ the annual rate. These fees may be negotiable in certain cases.
Clients may choose to have advisory fees debited from client accounts or to pay by check or ACH. This
service may be terminated with 30 days’ notice, and any unearned portion of the fee will be refunded.
No increase in the annual fee shall be effective without agreement from the client by signing a new
agreement or amendment to their current advisory agreement.
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Retirement Plan Consulting
Our firm’s fees are a flat fee based on the complexity of the plan, with a minimum annual fee of $2,400
per year. The final agreed upon annual fee will be memorialized in the client’s advisory agreement.
Fees are billed on a pro-rata basis quarterly in arrears. Fees are negotiable in certain circumstances. Fees
may be paid by the sponsor of the Qualified Plan or directly deducted from the assets of the Qualified
Plan. The fee-paying arrangements for Retirement Plan Consulting service will be determined on a case-
by-case basis and will be detailed in the signed consulting agreement.
Hourly Planning and Project Fees
Financial Planning projects will generally be offered on a fixed fee basis, which is agreed upon before the
start of any work. Fixed fees will be determined on a case-by-case basis with the fee based on an
estimate of the number of hours required to complete the project, multiplied by $300.00 per hour. The
fixed fee for planning projects typically ranges between $1,000.00 - $3,000.00. The fee is negotiable in
certain cases. If a fixed fee program is chosen, half of the fee is due at the beginning of process and the
remainder is due at completion of work. However, SwitchPoint will not bill an amount above $1,200.00
more than 6 months in advance. If the situation necessitates additional work beyond the typical project
range, an hourly rate of $300.00 per hour will be billed.
Investment Management Only
The standard advisory fee for investment management only services is 1.5% of the market value of the
assets under management. The annual advisory fee is pro-rated and paid in advance on a quarterly
basis. The advisory fee is calculated by using the value of the assets in the account(s) on the last business
day of the prior billing period, then multiplying by ¼ the annual fee. The fee may be negotiable in certain
cases.
The advisory fee is directly debited from Client accounts. Accounts initiated during a calendar quarter
will be charged a pro-rated fee based on the amount of time remaining in the billing period. An account
may be terminated with written notice of at least 30 calendar days in advance. Upon termination of the
account, any unearned fee will be refunded to the Client.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses
which may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers,
and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer
taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
securities transactions. Mutual fund and exchange traded funds also charge internal management fees,
which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in
addition to our fee, and we shall not receive any portion of these commissions, fees, and costs.
Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for
client’s transactions and determining the reasonableness of their compensation (e.g., commissions).
We do not accept compensation for the sale of securities or other investment products including asset-
based sales charges or service fees from the sale of mutual funds.
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Item 6: Performance-Based Fees and Side-By-
Side Management
We do not offer performance-based fees.
Item 7: Types of Clients
We provide financial planning and portfolio management services to individuals, high net-worth
individuals, pension and profit-sharing plans, and corporations or business entities.
We do not have a minimum account size requirement.
Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss
Passive Investment Management
We primarily practice passive investment management. Passive investing involves building portfolios that
are comprised of various distinct asset classes. The asset classes are weighted in a manner to achieve a
desired relationship between correlation, risk and return. Funds that passively capture the returns of the
desired asset classes are placed in the portfolio. The funds that are used to build passive portfolios are
typically index mutual funds or exchange traded funds.
Passive investment management is characterized by low portfolio expenses (i.e. the funds inside the
portfolio have low internal costs), minimal trading costs (due to infrequent trading activity), and relative
tax efficiency (because the funds inside the portfolio are tax efficient and turnover inside the portfolio is
minimal).
In contrast, active management involves a single manager or managers who employ some method,
strategy or technique to construct a portfolio that is intended to generate returns that are greater than
the broader market or a designated benchmark. Academic research indicates most active managers
underperform the market.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment which
you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities and
any other investment or security. Material risks associated with our investment strategies are listed
below.
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Market Risk: Market risk involves the possibility that an investment’s current market value will fall
because of a general market decline, reducing the value of the investment regardless of the operational
success of the issuer’s operations or its financial condition.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as
intended.
Small and Medium Cap Company Risk: Securities of companies with small and medium market
capitalizations are often more volatile and less liquid than investments in larger companies. Small and
medium cap companies may face a greater risk of business failure, which could increase the volatility of
the client’s portfolio.
Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at
times be more volatile than at other times. Under certain market conditions we may be unable to sell or
liquidate investments at prices we consider reasonable or favorable, or find buyers at any price.
Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or
types of investment. From time to time these strategies may be subject to greater risks of adverse
developments in such areas of focus than a strategy that is more broadly diversified across a wider
variety of investments.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may
fall below par value or the principal investment. The opposite is also generally true: bond prices
generally rise when interest rates fall. In general, fixed income securities with longer maturities are more
sensitive to these price changes. Most other investments are also sensitive to the level and direction of
interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or
the securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of
your investments remains the same.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities
may have other risks.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s
bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment
could have an adverse effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest
and repay the amount borrowed either periodically during the life of the security and/or at maturity.
Alternatively, investors can purchase other debt securities, such as zero coupon bonds, which do not pay
current interest, but rather are priced at a discount from their face values and their values accrete over
time to face value at maturity. The market prices of debt securities fluctuate depending on such factors
as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when
interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the
greater its interest rate risk.
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Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in
the banking industry. Banks and other financial institutions are greatly affected by interest rates and
may be adversely affected by downturns in the U.S. and foreign economies or changes in banking
regulations.
Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes,
including the construction of public facilities. Municipal bonds pay a lower rate of return than most
other types of bonds. However, because of a municipal bond’s tax-favored status, investors should
compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s
tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general.
Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk,
credit risk, and liquidity and valuation risk.
Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions.
Certain Exchange Traded Funds may not track underlying benchmarks as expected.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client
indirectly bears its proportionate share of any fees and expenses payable directly by those funds.
Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the
client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from
the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to
the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset
value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of
an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares
are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to
large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks
taken by the underlying funds in which clients invest.
Item 9: Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of SwitchPoint or the integrity of our
management. We have no information applicable to this Item.
Item 10: Other Financial Industry Activities
and Affiliations
No SwitchPoint employee is registered, or have an application pending to register, as a broker-dealer or
a registered representative of a broker-dealer.
No SwitchPoint employee is registered, or have an application pending to register, as a futures
commission merchant, commodity pool operator or a commodity trading advisor.
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SwitchPoint does not have any related parties. As a result, we do not have a relationship with any
related parties.
SwitchPoint only receives compensation directly from Clients. We do not receive compensation from
any outside source. We do not have any conflicts of interest with any outside party.
Item 11: Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests
of each client. Our clients entrust us with their funds and personal information, which in turn places a high
standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and
represents the expected basis of all of our dealings. The firm also accepts the obligation not only to comply
with the mandates and requirements of all applicable laws and regulations but also to take responsibility
to act in an ethical and professionally responsible manner in all professional services and activities.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance with each
of its specific provisions will not shield associated persons from liability for personal trading or other
conduct that violates a fiduciary duty to advisory clients. A summary of the Code of Ethics' Principles is
outlined below.
Integrity - Associated persons shall offer and provide professional services with integrity.
Objectivity - Associated persons shall be objective in providing professional services to clients.
Competence - Associated persons shall provide services to clients competently and maintain the
necessary knowledge and skill to continue to do so in those areas in which they are engaged.
Fairness - Associated persons shall perform professional services in a manner that is fair and
reasonable to clients, principals, partners, and employers, and shall disclose conflict(s) of interest
in providing such services.
Confidentiality - Associated persons shall not disclose confidential client information without the
specific consent of the client unless in response to proper legal process, or as required by law.
Professionalism - Associated persons’ conduct in all matter shall reflect credit of the profession.
Diligence - Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we require
all firm access persons to attest to their understanding of and adherence to the Code of Ethics at least
annually. Our firm will provide a copy of its Code of Ethics to any Client or prospective Client upon request.
Investment Recommendations Involving a Material Financial Interest and
Conflicts of Interest
Neither our firm, its associates or any related person is authorized to recommend to a Client or effect a
transaction for a Client, involving any security in which our firm or a related person has a material
financial interest, such as in the capacity as an underwriter, adviser to the issuer, etc.
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Advisory Firm Purchase of Same Securities Recommended to Clients and
Conflicts of Interest
Our firm and its “related persons” (associates, their immediate family members, etc.) may buy or sell
securities the same as, similar to, or different from, those we recommend to clients for their accounts. A
recommendation made to one client may be different in nature or in timing from a recommendation made
to a different client. Clients often have different objectives and risk tolerances. At no time, however, will
our firm or any related party receive preferential treatment over our clients. SwitchPoint does not
recommend securities to clients in which the Adviser or a related person has material financial interest.
Trading Securities At/Around the Same Time as Client’s Securities
In an effort to reduce or eliminate certain conflicts of interest involving the firm or personal trading, our
policy may require that we restrict or prohibit associates’ transactions in specific securities transactions.
Any exceptions or trading pre‐clearance must be approved by our Chief Compliance Officer in advance
of the transaction in an account, and we maintain the required personal securities transaction records
per regulation.
Item 12: Brokerage Practices
Factors Used to Select Custodians and/or Broker-Dealers
SwitchPoint Financial Planning LLC does not have any affiliation with any custodian we recommend.
Specific custodian recommendations are made to the Client based on their need for such services. We
recommend custodians based on the reputation and services provided by the firm.
In recommending custodians, we have an obligation to seek the “best execution” of transactions in
Client accounts. The determinative factor in the analysis of best execution is not the lowest possible
commission cost, but whether the transaction represents the best qualitative execution, taking into
consideration the full range of the custodian’s services. The factors we consider when evaluating a
custodian for best execution include, without limitation, the custodian’s:
− Combination of transaction execution services and asset custody services (generally without a
separate fee for custody);
− Capability to execute, clear, and settle trades (buy and sell securities for your account);
− Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.);
− Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds
(ETFs), etc.);
− Availability of investment research and tools that assist us in making investment decisions
− Quality of services;
− Competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate the prices;
− Reputation, financial strength, security and stability;
− Prior service to us and our clients.
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With this in consideration, our firm recommends Charles Schwab & Co., Inc., a registered broker-dealer,
member FINRA and SIPC (“Schwab”) and National Financial Services, LLC/Fidelity Brokerage Services, LLC
(together with all affiliates, “Fidelity”). Although Clients may request us to use a custodian of their
choosing, we generally recommend that Clients open brokerage accounts with Schwab and Fidelity. We
are not affiliated with Schwab or Fidelity. The Client will ultimately make the final decision of the
custodian to be used to hold the Client’s investments by signing the selected custodian’s account
opening documentation.
Research and Other Soft-Dollar Benefits
SwitchPoint does not have any soft-dollar arrangements with custodians whereby soft-dollar credits,
used to purchase products and services, are earned directly in proportion to the amount of commissions
paid by a Client. However, as a result of being on their institutional platform, Schwab and Fidelity may
provide us with certain services and products that may benefit us.
SCHWAB: Schwab Advisor Services™ is Schwab’s business serving independent investment advisory
firms like us. They provide our Clients and us with access to their institutional brokerage services
(trading, custody, reporting and related services), many of which are not typically available to Schwab
retail customers. Schwab also makes available various support services. Some of those services help us
manage or administer our Clients’ accounts, while others help us manage and grow our business.
Schwab’s support services are generally available on an unsolicited basis (we don’t have to request
them) and at no charge to us. The benefits received by SwitchPoint or its personnel do not depend on
the number of brokerage transactions directed to Schwab. As part of its fiduciary duties to Clients,
SwitchPoint at all times must put the interests of its Clients first. Clients should be aware, however, that
the receipt of economic benefits by SwitchPoint or its related persons in and of itself creates a potential
conflict of interest and may indirectly influence the SwitchPoint’s choice of Schwab for custody and
brokerage services. This conflict of interest is mitigated as SwitchPoint regularly reviews the factors used
to select custodians to ensure our recommendation is appropriate. Following is a more detailed
description of Schwab’s support services:
1. SERVICES THAT BENEFIT YOU. Schwab’s institutional brokerage services include access to a broad
range of investment products, execution of securities transactions, and custody of Client assets.
The investment products available through Schwab include some to which we might not otherwise
have access or that would require a significantly higher minimum initial investment by our Clients.
Schwab’s services described in this paragraph generally benefit you and your account.
2. SERVICES THAT MAY NOT DIRECTLY BENEFIT YOU. Schwab also makes available to us other
products and services that benefit us but may not directly benefit you or your account. These
products and services assist us in managing and administering our Clients’ accounts. They include
investment research, both Schwab’s own and that of third parties. We may use this research to
service all or a substantial number of our Clients’ accounts, including accounts not maintained at
Schwab. In addition to investment research, Schwab also makes available software and other
technology that:
− provide access to Client account data (such as duplicate trade confirmations and account
statements)
facilitate trade execution and allocate aggregated trade orders for multiple Client accounts
−
− provide pricing and other market data
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facilitate payment of our fees from our Clients’ accounts
−
− assist with back-office functions, recordkeeping, and Client reporting
3. SERVICES THAT GENERALLY BENEFIT ONLY US. Schwab also offers other services intended to help
us manage and further develop our business enterprise. These services include:
− Educational conferences and events
− Consulting on technology, compliance, legal, and business needs
− Publications and conferences on practice management and business succession
4. YOUR BROKERAGE AND CUSTODY COSTS. For our Clients’ accounts that Schwab maintains,
Schwab generally does not charge you separately for custody services but is compensated by
charging you commissions or other fees on trades that it executes or that settle into your Schwab
account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab
commissions or transaction fees.
FIDELITY: SwitchPoint has an arrangement with Fidelity through which Fidelity provides SwitchPoint with
Fidelity’s “platform” services. The platform services include, among others, brokerage, custodial,
administrative support, record keeping and related services that are intended to support intermediaries
like SwitchPoint in conducting business and in serving the best interests of their clients, but that may
benefit SwitchPoint.
1. SERVICES THAT BENEFIT YOU. Fidelity provides access to a range of investment products,
execution of securities transactions, and custody of client assets through National Financial
Services, LLC and Fidelity Brokerage, LLC. Also, Fidelity provides discount brokerage rates that are
generally lower than retail investor rates. Fidelity services described in this paragraph generally
benefit you and your account.
2. SERVICES THAT MAY NOT DIRECTLY BENEFIT YOU. Fidelity also makes available to us other
products and services that benefit us, but may not directly benefit you or your account. These
products and services assist us in managing and administering our clients’ accounts, such as
software and technology that may:
− Assist with back-office functions, recordkeeping, and client reporting of our clients’
accounts.
− Provide access to client account data (such as duplicate trade confirmations and account
statements).
Investment research.
− Provide pricing and other market data.
− Assist with back-office functions, recordkeeping, and client reporting.
−
− Access to Fidelity’s trading desk for Advisors.
− Access to block trading.
3. SERVICES THAT GENERALLY BENEFIT ONLY US. By using Fidelity, we will be offered other services
intended to help us manage and further develop our business enterprise. These services include:
− Educational conferences and events.
− Consulting on technology, compliance, legal, and business needs.
− Publications and conferences on practice management and business succession.
− Vendor discounts to purchase business services, such as consulting, marketing and
branding, technology support and other similar business services.
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4. YOUR BROKERAGE AND CUSTODY COSTS. Fidelity charges brokerage commissions and transaction
fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-
load mutual funds, commissions are charged for individual equity and debt securities transactions).
Fidelity enables SwitchPoint to obtain many no-load mutual funds without transaction charges and
other no-load funds at nominal transaction charges. Fidelity’s commission rates are generally
considered discounted from customary retail commission rates. However, the commissions and
transaction fees charged by Fidelity may be higher or lower than those charged by other
custodians.
Brokerage for Client Referrals
We receive no referrals from a custodian, broker-dealer or third party in exchange for using that
custodian, broker-dealer or third party.
Clients Directing Which Broker/Dealer/Custodian to Use
We do recommend a specific custodian for Clients to use, however, Clients may custody their assets at a
custodian of their choice. Clients may also direct us to use a specific custodian to execute transactions.
By allowing Clients to choose a specific custodian, we may be unable to achieve the most favorable
execution of Client transactions and this may cost Clients money over using a lower-cost custodian.
Aggregating (Block) Trading for Multiple Client Accounts
Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts
we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion
of the shares to participating accounts in a fair and equitable manner. The distribution of the shares
purchased is typically proportionate to the size of the account, but it is not based on account
performance or the amount or structure of management fees. Subject to our discretion, regarding
particular circumstances and market conditions, when we combine orders, each participating account
pays an average price per share for all transactions and pays a proportionate share of all transaction
costs. Accounts owned by our firm or access persons may participate in block trading with your
accounts; however, they will not be given preferential treatment.
Item 13: Review of Accounts
Kyle Wilhelm, Chief Compliance Officer, will monitor your accounts on an ongoing basis and will conduct
account reviews at least annually and/or upon your request to ensure that the advisory services
provided to you are consistent with your stated investment needs and objectives. Additionally,
reasonable client imposed restrictions will be reviewed to confirm that they are being enforced. Events
that may trigger a special review would be unusual performance, addition or deletions of client imposed
restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or
per client's needs.
Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well
as monthly or quarterly statements and annual tax reporting statements from their custodian showing
all activity in the accounts, such as receipt of dividends and interest.
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SwitchPoint will not provide written reports to Investment Management clients.
Comprehensive Financial Planning clients will have their Financial Plans reviewed at least annually in
conjunction with the annual review meeting.
Item 14: Client Referrals and Other
Compensation
Compensation Received by SwitchPoint Financial Planning, LLC
SwitchPoint is a fee-only firm that is compensated solely by its Clients. SwitchPoint does not receive
commissions or other sales-related compensation. Except as mentioned in Item 12 above, we do not
receive any economic benefit, directly or indirectly, from any third party for advice rendered to our Clients.
Client Referrals from Solicitors
SwitchPoint does not, directly or indirectly, compensate any person who is not advisory personnel for
Client referrals.
Item 15: Custody
SwitchPoint Financial Planning LLC has limited custody solely due to the direct withdrawal of fees. We do
not have physical custody of client assets or securities.
Clients should receive at least quarterly statements from the broker dealer, bank or other qualified
custodian that holds and maintains client's investment assets. We urge you to carefully review such
statements and compare such official custodial records to the account statements or reports that we
may provide to you. Our statements or reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
For client accounts in which SwitchPoint directly debits their advisory fee:
i.
ii.
SwitchPoint will send an invoice to the custodian.
The custodian will send at least quarterly statements to the client showing all disbursements
for the account, including the amount of the advisory fee.
The client will provide written authorization to SwitchPoint, permitting them to be paid directly for their
accounts held by the custodian.
Item 16: Investment Discretion
For those client accounts where we provide investment management services, we maintain discretion
over client accounts with respect to securities to be bought and sold and the amount of securities to be
bought and sold. You may specify investment objectives, guidelines, and/or impose certain conditions
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or investment parameters for your account(s). For example, you may specify that the investment in any
particular stock or industry should not exceed specified percentages of the value of the portfolio and/or
restrictions or prohibitions of transactions in the securities of a specific industry or type. Investment
discretion is explained to clients in detail when an advisory relationship has commenced. At the start of
the advisory relationship, the client will execute a Limited Power of Attorney which will grant our firm
discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory
contract and signed by the client.
If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the
execution of any transactions for your account(s). You have an unrestricted right to decline to
implement any advice provided by our firm on a non-discretionary basis.
Item 17: Voting Client Securities
We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies,
and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct
the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder
communications relating to the Client’s investment assets. If the client would like our opinion on a
particular proxy vote, they may contact us at the number listed on the cover of this brochure.
In most cases, you will receive proxy materials directly from the account custodian. However, in the
event we were to receive any written or electronic proxy materials, we would forward them directly to
you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we
would forward you any electronic solicitation to vote proxies.
Item 18: Financial Information
Registered investment advisers are required in this Item to provide you with certain financial
information or disclosures about our financial condition. We have no financial commitment that impairs
our ability to meet contractual and fiduciary commitments to clients, and we have not been the subject
of a bankruptcy proceeding.
We do not have custody of client funds or securities or require or solicit prepayment of more than
$1,200 in fees per client six months in advance.
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