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Form ADV Part 2A
Firm Brochure
Advisory Group of San Francisco, LLC.
44 Montgomery Street
Suite 300
San Francisco, CA 94104
T: 415-977-1201
F: 415-977-1204
www.advisorygroupsf.com
March 2025
Item 1 – Cover Page
This brochure provides information about the qualifications and business practices of The Advisory
Group of San Francisco, LLC. If you have any questions about the contents of this brochure, contact us
at 415-977-1201. 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 The Advisory Group of San Francisco, LLC is available on the SEC's
website at www.adviserinfo.sec.gov.
The Advisory Group of San Francisco, LLC is a registered investment adviser. Registration with the
United States Securities and Exchange Commission or any state securities authority does not imply a
certain level of skill or training.
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Item 2 – Material Changes
Since the last annual filing of this brochure on 3/22/2024, no material changes have occurred.
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Item 3 – Table of Contents
Item 1 – Cover Page ................................................................................................................................. i
Item 2 – Material Changes ....................................................................................................................... ii
Item 3 – Table of Contents ...................................................................................................................... iii
Item 4 – Advisory Business ...................................................................................................................... 4
Item 5 – Fees and Compensation ............................................................................................................ 8
Item 6 – Performance-Based Fees and Side-By-Side Management ..................................................... 10
Item 7 – Types of Clients ....................................................................................................................... 10
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 11
Item 9 – Disciplinary Information ............................................................................................................ 15
Item 10 – Other Financial Industry Activities and Affiliations ................................................................. 15
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 15
Item 12 – Brokerage Practices ............................................................................................................... 16
Item 13 – Review of Accounts ............................................................................................................... 19
Item 14 – Client Referrals and Other Compensation ............................................................................. 19
Item 15 – Custody .................................................................................................................................. 19
Item 16 – Investment Discretion ............................................................................................................ 20
Item 17 – Voting Client Securities .......................................................................................................... 20
Item 18 – Financial Information .............................................................................................................. 20
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Item 4 – Advisory Business
The Advisory Group of San Francisco, LLC (“Advisory Group” or “Firm”) is an SEC-registered investment
adviser based in San Francisco, California. We are organized as a limited liability company under the
laws of the State of Delaware. We have been providing investment advisory services since 1999.
Gregory H. Patterson and Roger B. Patterson are our principal owners with more than 30 years of
collective industry experience.
We are a "fee-only" investment advisor. "Fee-only" means we are paid exclusively by our clients and
the amounts of all such compensation are fully disclosed to clients in writing. We do not sell products,
and we do not receive commissions or other remuneration from any source.
Advisory Services
PERSONAL WEALTH MANAGEMENT SERVICES
We provide holistic Personal Wealth Management Services to families and individuals, as detailed
below. These services include discretionary Investment Advisory services that serve the needs of the
taxable, tax-deferred, and non-taxable portions of our Clients' portfolios. Our Personal Wealth
Management Services combines both Investment Management Services and Financial Planning
Services, and are provided at two levels of service: Full-Service and Limited-Service. For Full- Service
clients, this advice is included on an ongoing basis; for Limited-Service clients, it is provided throughout
the first year, with annual updates to the financial independence portion only.
INVESTMENT MANAGEMENT SERVICES
AGSF offers Investment Management Services to Personal Wealth Management clients. AGSF will offer
clients ongoing Investment Management Services by determining individual investment goals, time
horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation,
portfolio monitoring, and the overall investment program will be based on the above factors.
Discretionary
When the Client elects to use AGSF on a discretionary basis, the Client will sign a limited trading
authorization or equivalent allowing AGSF to determine the securities to be bought or sold and the
amount of the securities to be bought or sold. AGSF will have the authority to execute transactions
in the account without seeking Client approval on each transaction.
AGSF has the authority to select the investments in your portfolio and make sub-asset class allocation
decisions. However, any such selection must be consistent with your designated portfolio allocation as
indicated in your Investment Policy Statement, as we cannot change the overall objective of your
portfolio without your prior written authorization. We periodically rebalance your portfolio in accordance
with your designated equity/fixed-income allocation. We also perform tax loss harvesting for taxable
accounts in the Full-Service and Limited-Service levels, as appropriate.
AGSF may also select and appoint one or more Sub-Advisor(s) to provide Sub-Advisor Services to
Client’s Account. Such Sub-Advisor Services will be as determined by AGSF. Such Sub-Advisor(s), in
providing Sub-Advisor Services, shall have all of the same authority relating to the management,
including fee deduction authority, of Client’s Account as is granted to AGSF. In addition, at AGSF’s
discretion, AGSF may grant such Sub-Advisor(s) full authority to further delegate such discretionary
investment authority to other Money Managers. Client will agree to such authority within AGSF’s
Advisory Agreement. All fees paid by Client to AGSF are inclusive of the fees paid to Sub-Advisor
Use of DFA Mutual Funds
AGSF utilizes the mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally
only available through registered investment advisers approved by DFA. Thus, if the client were to
terminate AGSF’s services and transition to another adviser who has not been approved by DFA to
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utilize DFA funds, restrictions regarding additional purchases of or reallocation among other DFA funds
would generally apply.
FINANCIAL PLANNING AND CONSULTING
Services include an evaluation of a Client's current and future financial state using currently known
variables to predict future cash flows, asset values, recommend purchase and sales, and withdrawal
plans. AGSF will use current net worth, tax liabilities, asset allocation, and future retirement and estate
plans in developing financial plans. Topics for planning may include, but are not limited:
• Personal net worth statement: A snapshot of assets and liabilities serves as a benchmark for
measuring progress towards financial goals.
• Cash flow analysis: An income and spending plan determines how much can be set aside for debt
repayment, savings and investing each month.
• Retirement strategy: A strategy for achieving retirement independent of other financial priorities.
Including a strategy for accumulating the required retirement capital and its planned lifetime
distribution.
• Long-term investment plan: Build a customized asset allocation strategy based on specific
investment objectives and a risk profile. This strategy sets guidelines for selecting, buying, and
selling investments and establishing benchmarks for performance review.
• Tax reduction strategy: Identify ways to minimize taxes on personal income to the extent
permissible by the tax code. The strategy should include identification of tax favored investment
vehicles that can reduce taxation of investment income.
• Estate preservation: Help update accounts, review beneficiaries for retirement accounts and life
insurance, provide a second look at your current estate planning documents, and prompt you to
update your plan when the legal environment changes or you have major life events such as a
marriage, death, or births.
If a conflict of interest exists between the interests of AGSF and the interests of the Client, the Client is
under no obligation to act upon AGSF’s recommendation. If the Client elects to act on any of the
recommendations, the Client is under no obligation to affect the transaction through AGSF.
Financial Planning is also available as a stand-alone service.
INVESTMENT MANAGEMENT SERVICES (STAND-ALONE)
Foundations, Endowments, and other Institutions
AGSF provided discretionary Investment Management Services to foundations, endowments, and other
institutions. The primary duty of most financial stewards is to manage a prudent investment process. We
help you understand and fulfill your fiduciary responsibility, simplify your job, and improve outcomes for
beneficiaries and stakeholders. Our institutional-quality, proven endowment planning process applies
industry best practices and uncommon insight, so you can focus on your core mission or business.
AGSF will help you set a(n)
• spending policy strategy
•
investment policy consistent with spending policy
AGSF also provides:
•
fiduciary support for UPMIFA compliance
• sophisticated reporting
• audit support
• short- and long-term strategies as needed
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WealthStep Portfolio
The WealthStep Portfolio program (previously known as the Personal Managed Portfolio program) is a
limited-scope arrangement designed for clients with accounts of $100,000 or more. Clients utilizing the
WealthStep Portfolios can customize their investment portfolio by choosing amongst an array of stock-
bond mixes. Accounts are managed by AGSF on a discretionary basis. Investments in the WealthStep
Portfolios consist of both actively and passively managed mutual funds and are rebalanced periodically.
WealthStep services do not include Financial Planning services.
ERISA PLAN SERVICES
AGSF offers service to qualified and non-qualified retirement plans including 401(k) plans, 403(b) plans,
pension and profit-sharing plans, cash balance plans, and deferred compensation plans (“Plan”). AGSF
may act as a 3(21) or 3(38) advisor:
Limited Scope ERISA 3(21) Fiduciary. AGSF acts as a limited scope ERISA 3(21) fiduciary that
can advise, help, and assist plan sponsors with their investment decisions. As an investment
advisor AGSF has a fiduciary duty to act in the best interest of the Client. The plan sponsor is still
ultimately responsible for the decisions made in their plan, though using AGSF can help the plan
sponsor delegate liability by following a diligent process.
1. Fiduciary Services are:
• Provide investment advice to the Plan about asset classes and investment alternatives
available for the Plan in accordance with the Plan’s investment policies and objectives. The
Plan Sponsor will make the final decision regarding the initial selection, retention, removal,
and addition of investment options. AGSF acknowledges that it is a fiduciary as defined in
ERISA section 3 (21) (A) (ii).
• Assist the Plan in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan. Plan shall have the ultimate
responsibility and authority to establish such policies and objectives and to adopt and
amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a qualified
default investment alternative (QDIA) for participants who are automatically enrolled in the
Plan or who have otherwise failed to make investment elections. The Plan retains the sole
responsibility to provide all notices to the Plan participants required under ERISA Section
404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance to
the guidelines set forth in the IPS and make recommendations to maintain, remove or
replace investment options.
• Meet with the Plan Sponsor on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the
investment alternatives available to them under the Plan. Plan understands AGSF’s
assistance in education of the Plan participants shall be consistent with and within the
scope of the Department of Labor’s definition of investment education (Department of
Labor Interpretive Bulletin 96-1). As such, AGSF is not providing fiduciary advice as defined
by ERISA 3(21)(A)(ii) to the Plan participants. AGSF will not provide investment advice
concerning the prudence of any investment option or combination of investment options for
a particular participant or beneficiary under the Plan.
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• Assist in the group enrollment meetings designed to increase retirement plan participation
among the employees and investment and financial understanding by the employees.
AGSF may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between AGSF and the Plan.
3. AGSF has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar
vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to AGSF on the ERISA Agreement.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
3(38) Investment Manager. AGSF acts as an ERISA 3(38) Investment Manager in which it has
discretionary management and control of a given retirement plan’s assets. AGSF would then
become solely responsible and liable for the selection, monitoring and replacement of the plan’s
investment options.
1. Fiduciary Services include:
• Advisor has discretionary authority and will make the final decision regarding the initial
selection, retention, removal, and addition of investment options in accordance with the
Plan’s investment policies and objectives.
• Assist the Plan Sponsor with the selection of a broad range of investment options
consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Plan Sponsor in the development of an investment policy statement. The IPS
establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection
of a qualified default investment alternative for participants who are automatically enrolled
in the Plan or who have otherwise failed to make investment elections. The Plan Sponsor
retains the sole responsibility to provide all notices to the Plan participants required under
ERISA Section 404(c) (5).
• Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance to
the guidelines set forth in the IPS and make recommendations to maintain, remove or
replace investment options.
• Meet with Plan Sponsor on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services include:
• Assist in the education of Plan participants about general investment information and the
investment alternatives available to them under the Plan. The Advisor’s assistance in
education of the Plan participants shall be consistent with and within the scope of the
Department of Labor’s definition of investment education (Department of Labor Interpretive
Bulletin 96-1). As such, the Advisor is not providing fiduciary advice as defined by ERISA
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to the Plan participants. Advisor will not provide investment advice concerning the
prudence of any investment option or combination of investment options for a particular
participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation
among the employees and investment and financial understanding by the employees.
AGSF may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between Advisor and Plan Sponsor.
3. AGSF has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
a. Employer securities;
b. Real estate (except for real estate funds or publicly traded REITs);
c. Stock brokerage accounts or mutual fund windows;
d. Participant loans;
e. Non-publicly traded partnership interests;
f. Other non-publicly traded securities or property (other than collective trusts and similar
vehicles); or
g. Other hard-to-value or illiquid securities or property.
Client-Tailored Services and Client-Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment strategies are
created that reflect the stated goals and objectives. Clients may impose restrictions on investing in
certain securities or types of securities. These restrictions may, however, prohibit engagement with
AGSF.
Wrap Fee Programs
AGSF does not participate in a Wrap Fee Program.
Assets Under Management
As of December 31, 2024, we manage a total of $825,288,953, and of this amount, we manage all client
assets on a discretionary basis and $0 in client assets on a non-discretionary basis. The firm had
$162,561,079 in assets under advisement.
Item 5 – Fees and Compensation
Fee Schedule
PERSONAL WEALTH MANAGEMENT SERVICES FEES
Full-Service Wealth Strategy
Our Full-Service Wealth Strategy level is generally available to clients with managed assets over
$1,500,000 and/or significant complexity in their financial circumstances and is subject to a minimum
fee of $15,000 annually. This service includes ongoing wealth management and financial advice as well
as coordination of relevant financial issues. These issues may include financial independence planning,
retirement, analysis of insurance needs, estate review, charitable giving, education funding, and special
needs planning, as detailed in our Wealth Strategies Service Agreement. In order to implement this
strategy, we provide ongoing discretionary investment management for those assets separately
designated in the Client's Investment Policy Statement.
Although we generally recommend that our clients select Schwab as the custodian of the managed
assets, Full-Service clients may utilize other custodians, with some limitations, and additional fees as
detailed in our Wealth Strategy Services Agreement.
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Limited-Service Wealth Strategy
Our Limited-Service Wealth Strategy level is generally available to clients with managed assets over
$750,000 and/or a level of complexity in their financial circumstances which warrants significant financial
analysis. Limited-Service Wealth Strategy level and is subject to a minimum fee of $10,000 annually. In
addition to discretionary investment management, integrated financial planning services are included in
the fee for Limited-Service Wealth Strategy for the first year of our engagement.
FINANCIAL PLANNING AND CONSULTING FEES
Prior to engaging our firm to provide Financial Planning Services not otherwise included in Full Service
or Limited Service Wealth Strategy Services (e.g. planning projects beyond the usual scope or planning
projects after year 1 for Limited Service), Client will generally be required to enter into a written Planning
Agreement with us setting forth the terms and conditions of the engagement, describing the scope of
the services to be provided, and any portion of the fee that is due from Client before we commence
services. In no event will we accept fees for services that are to be performed later than six months from
receipt of any fee.
Our planning fees are negotiable, but generally range from $5,000 - $20,000 on a fixed fee basis,
depending on the level and scope of the services required. We may, in our sole discretion, charge a
lesser planning fee or waive all, or a portion of, planning fees based upon various criteria we deem
sufficient. In the event Client terminates the Planning Agreement prior to completion of the financial
planning services, we will promptly refund any unearned balance of our fee.
Financial Planning fees will be invoiced directly to the client. 50% of the Financial Planning Fee is due
upon execution of our Financial Planning Agreement, and the remaining 50% is due upon completion of
the plan.
INVESTMENT MANAGEMENT SERVICES FEES
Our fees for Institutional and Individual Clients are normally calculated on a tiered schedule based upon
a percentage of assets under management ("AUM"). Specific assets or accounts that Client designates
as unmanaged (i.e., courtesy accounts) are not included in fee calculations or performance reporting.
The effective rate of our annual fee typically ranges from.35% to 1.10% of assets under management.
The standard minimum annual fee for Institutional clients is $30,000 ($7,500 per quarter), or $15,000
($3,750 per quarter). Minimum fees may be reduced or waived in limited instances. Fees are fully
disclosed in writing prior to engagement. Fees are charged quarterly in advance and are based upon
the value of the assets under management as of the last day of the preceding quarter. Generally, our
fees are deducted directly from Client's accounts for individual clients and pooled institutional accounts
and billed to the plan sponsor for participant-directed institutional accounts. Initial billing generally begins
upon execution of the Wealth Services agreement and for Institutional Clients upon the execution of the
Investment Advisory Agreement.
WealthStep
For each account within our WealthStep Portfolio program, our Fee for services shall be assessed at an
annual rate of 0.85% of assets (85 basis points). For participants in the plans of certain Institutional
Clients that have terminated their plans, we have made available to those plan participants our
WealthStep Portfolio program at a reduced annual rate. We do not impose a minimum fee for this
service, but we do generally require a minimum asset value of $100,000. Fees are fully disclosed in
writing prior to engagement and are deducted from the client's account. Fees are charged quarterly, in
advance, and are based upon the value of the assets under management as of the last day of the
preceding quarter. Initial billing begins upon the date the rollover is deposited into the account and is
prorated to take into consideration the number of days in the quarter. No fee adjustment is made for
cash inflows or outflows during billing cycles. We may, in our sole discretion, charge a lesser annual
investment management fee.
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ERISA PLAN SERVICES FEES
The annual fees are based on the market value of the Included Assets and shall not exceed 1%. Fees
may be charged quarterly or monthly in arrears or in advance based on the assets as calculated by the
custodian or record keeper of the Included Assets (without adjustments for anticipated withdrawals by
Plan participants or other anticipated or scheduled transfers or distribution of assets) on the last
business day of the previous quarter.
The fee schedule, which includes compensation of AGSF for the services is described in detail in the
ERISA Plan Agreement. The Plan is obligated to pay the fees; however, the Plan Sponsor may elect to
pay the fees. Clients may elect to be billed directly or have fees deducted from Plan Assets. AGSF does
not reasonably expect to receive any additional compensation, directly or indirectly, for its services. If
additional compensation is received, AGSF will disclose this compensation, the services rendered, and
the payer of compensation.
Payment of Investment Advisory Fees
Our Investment Advisory Agreement authorizes us to instruct Client's account Custodian to debit Client's
account for the amount of our investment advisory fee and to remit that fee directly to us in accordance
with procedures accepted by the United States Securities and Exchange Commission. Immediately
upon the deduction of the fee, but no less than quarterly, we provide Client with a written billing statement
showing the amount of fee deducted from each account and the calculation upon which the fee was
based. Clients also receive statements directly from the custodian which reflect the deduction of our fee.
Institutional or Premier Clients may request that fees to be deducted from a single account or invoiced
directly to Client. In the event that automatic fee deduction is not possible, we will invoice Client for the
amount of our quarterly fee.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange-traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds (described in each fund's prospectus) to their shareholders. These fees will generally
include a management fee and other fund expenses. You will also incur transaction charges and/or
brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by
the broker-dealer or custodian through whom your account transactions are executed. We do not share
in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To
fully understand the total cost you will incur, you should review all the fees charged by mutual funds,
exchange traded funds, our firm, and others. Refer to the Brokerage Practices section below for
additional disclosure on this topic.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or participate in side-by-side management. Performance-
based fees are fees that are based on a share of capital gains or capital appreciation of a client's
account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-
based fees. Our fees are calculated as described in the Fees and Compensation section above and are
not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your
advisory account.
Item 7 – Types of Clients
We offer investment advisory services to individuals, pension and profit-sharing plans, trusts, estates,
charitable organizations, endowments, corporations, and other business entities.
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Minimum account thresholds are as follows:
PERSONAL WEALTH MANAGEMENT:
Full-Service minimum account size:
Limited-Service minimum account size:
$1,500,000.
$750,000.
INVESTMENT MANAGEMENT SERVICES:
Institutional minimum account size:
WealthStep:
$1,000,000.
$100,000.
ERISA PLAN SERVICES FEES:
ERISA 3(21) Services:
ERISA 3(38) Services:
$1,000,000.
$1,000,000.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is
not a guarantee of future returns. Security analysis methods may include:
Fundamental analysis concentrates on factors that determine a company’s value and expected future
earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or
priced below their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Technical analysis attempts to predict a future stock price or direction based on market trends. The
assumption is that the market follows discernible patterns and if these patterns can be identified then a
prediction can be made. The risk is that markets do not always follow patterns and relying solely on this
method may not take into account new patterns that emerge over time.
Charting analysis strategy involves using and comparing various charts to predict long and short-term
performance or market trends. The risk involved in using this method is that only past performance data
is considered without using other methods to crosscheck data. Using charting analysis without other
methods of analysis would be making the assumption that past performance will be indicative of future
performance. This may not be the case.
Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be
leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always
repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes
the very cycles these investors are trying to exploit.
Quantitative analysis deals with measurable factors as distinguished from qualitative considerations
such as the character of management or the state of employee morale, such as the value of assets, the
cost of capital, historical projections of sales, and so on.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for
a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each
by carefully choosing the proportions of various assets.
In developing a financial plan for a Client, AGSF’s analysis may include cash flow analysis, investment
planning, risk management, tax planning and estate planning. Based on the information gathered, a
detailed strategy is tailored to the Client’s specific situation.
The main sources of information include financial newspapers and magazines, annual reports,
prospectuses, and filings with the SEC.
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Investment Strategies
The investment strategy for a specific Client is based upon the objectives stated by the Client during
consultations. The Client may change these objectives at any time by providing written notice to AGSF.
Each Client executes a Client profile form or similar form that documents their objectives and their
desired investment strategy.
Risks of Investments and Strategies Utilized
Investing in securities involves risk of loss that Clients should be prepared to bear. AGSF’s investment
approach constantly keeps the risk of loss in mind. Investors may face the following investment risks:
General Investment and Trading Risks. Clients may invest in securities and other financial
instruments using strategies and investment techniques with significant risk characteristics. The
investment program utilizes such investment techniques as option transactions, margin transactions,
short sales, leverage, and derivatives trading, the use of which can, in certain circumstances, maximize
the adverse impact to which a Client may be subject.
Interest-rate Risk. Fluctuations in interest rates may cause investment prices to fluctuate. For example,
when interest rates rise, yields on existing bonds become less attractive, causing their market values to
decline.
Inflation Risk. When any type of inflation is present, a dollar today will buy more than a dollar next year,
because purchasing power is eroding at the rate of inflation.
Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against the
currency of the investment’s originating country. This is also referred to as exchange rate risk.
Reinvestment Risk. This is the risk that future proceeds from investments may have to be reinvested
at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.
Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Generally, assets are
more liquid if many traders are interested in a standardized product. For example, Treasury Bills are
highly liquid, while real estate properties are not.
Management Risk. The advisor’s investment approach may fail to produce the intended results. If the
advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in
the expected time frame, the overall performance of the Client’s portfolio may suffer.
Cybersecurity Risk. AGSF and its service providers may be subject to operational and information
security risks resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or
corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized
release of confidential information or various other forms of cybersecurity breaches. Cybersecurity
attacks affecting AGSF and its service providers may adversely impact Clients. For instance,
cyberattacks may interfere with the processing of transactions, cause the release of private information
about Clients, impede trading, subject AGSF to regulatory fines or financial losses, and cause
reputational damage. Similar types of cybersecurity risks are also present for issuers of securities in
which Clients may invest in, qualified custodians, governmental and other regulatory authorities,
exchange and other financial market operators, or other financial institutions. Cybersecurity incidents
that could ultimately cause them to incur losses, including for example: financial losses, cost and
reputational damages, and loss from damage or interruption of systems. Although AGSF has
established its systems to reduce the risk of these incidents from coming to fruition, there is no guarantee
that these efforts will always be successful, especially considering that AGSF does not directly control
the cybersecurity measures and policies employed by third party service providers.
Options Trading. The risks involved with trading options are that they are very time-sensitive
investments. An options contract is generally a few months. The buyer of an option could lose his or her
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entire investment even with a correct prediction about the direction and magnitude of a particular price
change if the price change does not occur in the relevant time period (i.e., before the option expires).
Additionally, options are less tangible than some other investments. An option is a “book-entry” only
investment without a paper certificate of ownership.
Trading on Margin. In a cash account, the risk is limited to the amount of money that has been invested.
In a margin account, risk includes the amount of money invested plus the amount that has been loaned.
As market conditions fluctuate, the value of marginable securities will also fluctuate, causing a change
in the overall account balance and debt ratio. As a result, if the value of the securities held in a margin
account depreciates, the Client will be required to deposit additional cash or make full payment of the
margin loan to bring the account back up to maintenance levels. Clients who cannot comply with such
a margin call may be sold out or bought in by the brokerage firm.
Exchange-Traded Funds. ETFs are a type of index fund bought and sold on a securities exchange.
The risks of owning an ETF generally reflect the risks of owning the underlying securities they are
designed to track, although lack of liquidity in an ETF could result in it being more volatile and ETFs
have management fees that increase their costs. ETFs are also subject to other risks, including: (i) the
risk that their prices may not correlate perfectly with changes in the underlying reference units; and (ii)
the risk of possible trading halts due to market conditions or other reasons that, in the view of the
exchange upon which an ETF trades, would make trading in the ETF inadvisable.
Mutual Fund Risks. An investment in mutual funds could lose money over short or even long periods.
A mutual fund’s share price and total return are expected to fluctuate within a wide range, like the
fluctuations of the overall stock market.
Common Stocks and Equity-Related Securities. Certain ETFs or mutual funds hold common stock.
Prices of common stock react to the economic condition of the company that issued the security, industry
and market conditions, and other factors which may fluctuate widely. Investments related to the value
of stocks may rise and fall based on an issuer’s actual and anticipated earnings, changes in
management, the potential for takeovers and acquisitions, and other economic factors. Similarly, the
value of other equity-related securities, including preferred stock, warrants, and options, may also vary
widely.
Small- and Mid-Cap Risks. Certain ETFs and mutual funds hold securities of small- and mid-cap
issuers. Securities of small-cap issuers may present greater risks than those of large-cap issuers. For
example, some small- and mid-cap issuers often have limited product lines, markets, or financial
resources. They may be subject to high volatility in revenues, expenses, and earnings. Their securities
may be thinly traded, may be followed by fewer investment research analysts, and may be subject to
wider price swings and thus may create a greater chance of loss than when investing in securities of
larger-cap issuers. The market prices of securities of small- and mid-cap issuers generally are more
sensitive to changes in earnings expectations, to corporate developments, and to market rumors than
are the market prices of large-cap issuers.
Futures, Commodities, and Derivative Investments. Certain ETFs and mutual funds hold
commodities, commodities contracts, and/or derivative instruments, including futures, options, and swap
agreements. The prices of commodities contracts and derivative instruments, including futures and
options, are highly volatile. Payments made pursuant to swap agreements may also be highly volatile.
Price movements of commodities, futures and options contracts, and payments pursuant to swap
agreements are influenced by, among other things, interest rates, changing supply and demand
relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and
national and international political and economic events and policies. The value of futures, options, and
swap agreements also depends upon the price of the commodities underlying them. In addition, Client
assets are subject to the risk of the failure of any of the exchanges on which its positions trade or of its
clearinghouses or counterparties.
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Highly Volatile Markets. The prices of financial instruments can be highly volatile. Price movements of
forward and other derivative contracts are influenced by, among other things, interest rates, changing
supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies
of governments, and national and international political and economic events and policies. Clients are
also subject to the risk of failure of any of the exchanges on which their positions trade or of its
clearinghouses.
Non-U.S. Securities. Certain ETFs and mutual funds hold securities of non-U.S. issuers. Investments
in securities of non-U.S. issuers pose a range of potential risks which could include expropriation,
confiscatory taxation, imposition of withholding or other taxes on dividends, interest, capital gains or
other income, political or social instability, illiquidity, price volatility, and market manipulation. In addition,
less information may be available regarding securities of non-U.S. issuers, and non-U.S. issuers may
not be subject to accounting, auditing and financial reporting standards, and requirements comparable
to or as uniform as those of U.S. issuers.
Emerging Markets. Certain ETFs and mutual funds hold securities of emerging markets issuers. In
addition to the risks associated with investments outside of the United States, investments in emerging
markets (i.e., the developing countries) may involve additional risks. Emerging markets generally are
not as efficient as those in developed countries. In some cases, a market for the security may not exist
locally, and transactions will need to be made on a neighboring exchange. Volume and liquidity levels
in emerging markets are lower than in developed countries. When seeking to sell emerging market
securities, little or no market may exist for the securities. In addition, issuers based in emerging markets
are not generally subject to uniform accounting and financial reporting standards, practices, and
requirements comparable to those applicable to issuers based in developed countries, thereby
potentially increasing the risk of fraud or other deceptive practices.
Capitalization Risks. Investing in Companies within the same market capitalization category carries
the risk that the category may be out of favor due to current market conditions or investor sentiment.
Market Risks. Turbulence in the financial markets and reduced liquidity may negatively affect the
Companies, which could have an adverse effect on each of them. If the securities of the Companies
experience poor liquidity, investors may be unable to transact at advantageous times or prices, which
may decrease the Company’s returns. In addition, there is a risk that policy changes by central
governments and governmental agencies, including the Federal Reserve or the European Central Bank,
which could include increasing interest rates, could cause increased volatility in financial markets, which
could have a negative impact on the Companies. Furthermore, local, regional, or global events such as
war, acts of terrorism, the spread of infectious illness or other public health issues, recessions, or other
events could have a significant impact on the Companies. For example, the rapid and global spread of
a highly contagious novel coronavirus respiratory disease, designated COVID-19, has resulted in
extreme volatility in the financial markets and severe losses; reduced liquidity of many Companies’
securities; restrictions on international and, in some cases, local travel; significant disruptions to
business operations (including business closures); strained healthcare systems; disruptions to supply
chains, consumer demand and employee availability; and widespread uncertainty regarding the duration
and long-term effects of this pandemic. Some sectors of the economy and individual issuers have
experienced particularly large losses. In addition, the COVID-19 pandemic may result in a sustained
economic downturn or a global recession, domestic and foreign political and social instability, damage
to diplomatic and international trade relations and increased volatility and/or decreased liquidity in the
securities markets. The Companies’ values could decline over short periods due to short-term market
movements and over longer periods during market downturns.
Penny Stock Risks. Generally, Penny Stocks are low-priced shares of small companies that are not
traded on an exchange. Penny Stocks typically trade over-the-counter, such as on the OTC Bulletin
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Board or Pink Sheets. Penny Stocks, unlike listed stocks, are not subject to SEC reporting requirements
or the listing standards of stock exchanges. Because of this, information about the Penny Stock
companies can be difficult to find and verify. Penny Stocks also have lower liquidity as they are traded
less frequently. This also leads to higher volatility. For these reasons, Penny Stocks are considered to
be speculative investments and Clients who trade in penny stocks should be prepared for the possibility
that they may lose their entire investment, or an amount in excess of their investment if they purchased
Penny Stocks on margin.
Alternative Investments. When appropriate for a Client’s objective, risk tolerance and qualifications,
AGSF recommends the client participate in private issues, such as single purpose vehicles, funds of
funds, private equity, and hedge funds. These are usually structured as limited partnerships with differing
minimum investments, liquidity, fees, and carriers.
The foregoing list of risk factors does not purport to be a complete enumeration or explanation
of the risks involved in an investment with AGSF.
Item 9 – Disciplinary Information
The Advisory Group of San Francisco, LLC has been registered and providing investment advisory
services since 1999. Neither our firm nor any of our Associated Persons has any disciplinary information.
Item 10 – Other Financial Industry Activities and Affiliations
Advisory Group has no other financial industry activities or affiliations. Neither the Firm nor its
management persons are registered as a broker-dealer or broker-dealer representative. Neither the
Firm nor its management persons are registered as futures commission merchant, commodity pool
operator, or a commodity trading advisor. Neither Advisory Group nor its representatives have any
material relationships to this advisory business that would present a possible conflict of interest.
Selection of Other Advisers
AGSF does not utilize nor select other advisors.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics
The affiliated persons (affiliated persons include employees and/or independent contractors) of the
AGSF have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards
of conduct expected of the Firm’s affiliated persons and addresses conflicts that may arise. The Code
defines acceptable behavior for affiliated persons of the Advisory Group. The Code reflects the Firm and
its supervised persons’ responsibility to act in the best interest of their Client.
One area which the Code addresses is when affiliated persons buy or sell securities for their personal
accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated
persons to use non-public material information for their personal profit or to use internal research for
their personal benefit in conflict with the benefit to our Clients.
AGSF’s policy prohibits any person from acting upon or otherwise misusing non-public or inside
information. No advisory representative or other affiliated person, officer or director of the Firm may
recommend any transaction in a security or its derivative to advisory Clients or engage in personal
securities transactions for a security or its derivatives if the advisory representative possesses material,
non-public information regarding the security.
AGSF’s Code is based on the guiding principle that the interests of the Client are our top priority. The
Firm’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and
must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a
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conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons
or the company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-
public information regarding any Clients' purchase or sale of securities, or non-public information
regarding the portfolio holdings of any reportable fund, who are involved in making securities
recommendations to Clients, or who have access to such recommendations that are non-public.
The Advisory Group will provide a copy of the Code of Ethics to any Client or prospective Client upon
request.
Recommendations Involving Material Financial Interests
Neither the Advisory Group nor its related persons recommend to Clients, or buys or sells for Client
accounts, securities in which the Firm or a related person has a material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and
Conflicts of Interest
AGSF does not maintain a firm proprietary trading account and does not have a material financial
interest in any securities being recommended and therefore no conflicts of interest exist.
Advisory Firm Purchase of Same Securities Recommended to Clients and
Conflicts of Interest
AGSF and its affiliated persons may invest in the same securities (or related securities, e.g., warrants,
options, or futures) that AGSF or an affiliated person recommends to Clients. In order to mitigate conflicts
of interest, such as frontrunning, AGSF’s Chief Compliance Officer, or their designee, will no less than
quarterly, review firm and/or personal holdings of its affiliated persons. These reviews ensure that the
personal trading of affiliated persons does not disadvantage Clients of AGSF.
Client Securities Recommendations or Trades and Concurrent Advisory
Firm Securities Transactions and Conflicts of Interest
AGSF and its affiliated persons may buy or sell securities at the same time they buy or sell securities
for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required
to disclose all reportable securities transactions as well as provide the Firm with copies of their brokerage
statements.
The Chief Compliance Officer of the Advisory Group is Lisette Smith. She reviews all trades of the
affiliated persons each quarter. The personal trading reviews ensure that the personal trading of
affiliated persons does not affect the markets and that Clients of the Firm’s receive preferential treatment
over associated persons’ transactions.
Item 12 – Brokerage Practices
When making investment decisions for client accounts, we determine the broker-dealer/custodian to be
used in each specific transaction with the objective of negotiating the best execution available under the
circumstances. In recommending broker-dealers/custodians, we will generally seek the best
combination of net price and execution for client accounts and may consider other factors, including
financial strength, execution capabilities, efficiency, acceptable record keeping, ability to obtain best
price, transaction charges, access to low cost share classes of mutual funds, quality and timeliness of
execution, technological integration with our systems, front and back office service, frequency of failed
trades, error policies, financial stability and reputation and integrity. Although transaction fees paid by
our clients shall comply with our duty to obtain best execution, a client may pay a transaction fee that is
higher than another qualified broker-dealer might charge to effect the same transaction where we
determine, in good faith, that the transaction fee is reasonable in relation to the value of the brokerage
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services received. In seeking best execution, the determinative factor is not the lowest possible cost,
but whether the transaction represents the best qualitative execution, taking into consideration the full
range of broker-dealer services, as detailed above. Accordingly, although we will seek competitive rates,
we may not necessarily obtain the lowest possible commission rates for client account transactions. The
brokerage commissions or transaction fees charged by the designated broker-dealer are exclusive of,
and in addition to, our Investment Advisory Fee as detailed above at the Fees and Compensation
section. In addition to our investment advisory fee, brokerage commissions and/or transactions fees,
Client will also incur, relative to all investment vehicles, charges imposed at the investment level (e.g.,
management fees and other fund expenses.) Our best execution responsibility as it pertains to pricing
is satisfied if securities that we purchase for client accounts are open-ended mutual funds that trade at
net asset value as determined at the daily market close. Our best execution responsibility with respect
to equitable pricing on individual securities traded in multiple accounts is met if we block trade those
securities that trade inter-day and if we determine the allocation of shares prior to executing the block
trade.
Certain custodians enable our firm to obtain many no-load mutual funds without transaction charges
and other no-load and load waived funds at nominal transaction charges. These transaction charges
and/or commission rates are generally considered discounted from customary retail transaction charges
and commission rates.
Best execution is not measured solely by reference to commission rates. Paying a broker
dealer/custodian a higher commission rate than another broker dealer/custodian might charge is
permissible if the difference in cost is reasonably justified by the quality of the brokerage services
offered. We do not obligate ourselves to seek the lowest transaction charges in all cases except to the
extent that it contributes to the overall goal of obtaining the best results for your account. It is expected
that our firm will receive some economic benefits, for example, research and access to industry
consultants, from various full-service and discount brokers in connection with utilizing their brokerage
services.
When helping a Client determine an appropriate custody/brokerage provider, the primary factors we
consider include: 1) stability and quality of the organization; 2) ability to serve the Client's specific
custody (including the broadest array of mutual fund and separate account manager custody possible)
and reporting needs; 3) relatively low cost to custody assets, whether that cost be fee-based or
transaction based; 4) transparency of commissions and any other charges or revenue obtained from the
Client. Where a Client uses separate account managers, we offer, for an additional fee, to coordinate
outside "Trading & Execution Cost Analysis" services, in order to assess the effectiveness and
reasonableness of the costs incurred by the investment manager and custodian. Refer to the Advisory
Business section and Fees and Compensation section above for additional disclosures on this topic.
Clients (other than those on the WealthStep Portfolio program, or those who utilize the Callan UMA
Program) are not obligated to use any particular custodian/brokerage firm; however, to the extent that
Client requires performance reporting (i.e. all individual clients and non-participant-directed institutional
clients), Client must use a custodian with electronic links to our portfolio accounting software or pay an
additional fee for manual data entry (see Fees and Compensation section above). Currently the
custodian with such links is the Schwab Institutional (SI) platform. Clients using our WealthStep Portfolio
program or the Callan UMA program, must designate Schwab as their custodian.
The Advisory Group may receive soft dollar or similar benefits, from broker-dealers or TPMMs, such as
research (or other products or services). Since the Firm generally does not have to pay for these
products or services, the Firm has an incentive to select or recommend a broker-dealer based on the
Advisory Group’s interest in receiving the research or other products or services, rather than the Clients’
interest in receiving the most favorable execution. This conflict is mitigated by disclosures, procedures,
and the Firm’s fiduciary obligation to place the best interest of the Client first.
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While there is no direct linkage between the investment advice given and the use of any given custodian
by Clients, we do receive some benefits that would not be received if we did not suggest that Clients
use Schwab as their custodian. These benefits are common industry services, benefiting the Client by
improving our ability to service and monitor Client assets and include: receipt of duplicate Client
confirmations and bundled duplicate statements, access to a trading desk serving SI Clients exclusively,
electronic daily downloads of price and transaction files, ability to have investment advisory fees
deducted directly from Client's accounts, access to an electronic communication network for client order
entry and account information, receipt of compliance publications and access to mutual funds which
generally require significantly higher minimum initial investments or are generally available only to
institutional investors. The benefits received through participation in these programs do not depend upon
the amount of transactions we direct to SI.
As indicated above, certain of the support services and/or products that may be received may assist us
in managing and administering client accounts. Others do not directly provide such assistance, but
rather assist us in the management and further development of our business enterprise. Examples of
such additional support are our receipt of generic newsletters and attendance at seminars sponsored
by Schwab.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such
as brokerage services or research.
Directed Brokerage
In limited circumstances, and at our discretion, some clients may instruct our firm to use one or more
particular brokers for the transactions in their accounts. If you choose to direct our firm to use a particular
broker, you should understand that this might prevent our firm from aggregating trades with other client
accounts or from effectively negotiating brokerage commissions on your behalf. Where a client directs
our firm to use a particular broker, we are not obligated to negotiate commissions on the client's behalf.
Thus, when directing brokerage business, you should consider whether the commission expenses,
execution, clearance, and settlement capabilities that you will obtain through your broker are adequately
favorable in comparison to those that we would otherwise obtain for you.
Block Trades
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 amount to be traded, but it is not based on account
performance or the amount or structure of management fees. Subject to our discretion regarding factual
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 persons associated with our firm may participate in block trading with
your accounts; however, they will not be given preferential treatment.
We combine multiple orders for shares of the same securities purchased for discretionary accounts;
however, we do not combine orders for non-discretionary accounts. Accordingly, non-discretionary
accounts may pay different costs than discretionary accounts pay. If you enter into non-discretionary
arrangements with our firm, we may not be able to buy and sell the same quantities of securities for you
and you may pay higher commissions, fees, and/or transaction costs than clients who enter into
discretionary arrangements with our firm.
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Item 13 – Review of Accounts
We monitor client portfolios as part of an ongoing process while regular account reviews are conducted
at least annually. Full-Service and Limited-Service clients are encouraged to discuss their needs, goals,
and investment objectives with our firm, and to keep us informed of any changes which might affect this
information. Full-Service and Limited-Service clients are encouraged to meet with a member of our
professional team at least annually, or more frequently depending on client preferences. At these
meetings or phone conferences, we will conduct a review of your investment objectives and account
performance. Additional reviews may be conducted at your request, or based on various circumstances,
including, but not limited to, contributions and withdrawals, year-end tax planning, market moving
events, security specific events, and/or, changes in your risk/return objectives. Due to the limited scope
arrangement of the WealthStep Portfolio program, WealthStep Portfolio clients do not typically have
consultations with our firm.
Personnel currently performing reviews are:
• Gregory H. Patterson, Chief Executive Officer/Senior Advisor
• Lisette C. Smith, Chief Operating Officer, Chief Compliance Officer, & Senior Advisor
• Tanya Rapacz, Senior Advisor
The individuals conducting reviews may vary from time to time, as personnel join or leave our firm.
You will receive transaction confirmation notices and regular summary account statements, at least
quarterly, directly from your account custodian. As an investment advisory client of our firm, we will also
provide you with written quarterly performance reports that generally include relevant account and/or
market-related information such as an inventory and appraisal of account holdings and investment
performance for the quarter versus a given benchmark and/or predetermined performance objectives.
The statement you receive from your account custodian and the report you receive from us will reflect
the deduction of our advisory fee from your account.
We encourage you to reconcile our reports with those received from the qualified custodian. If you find
your holdings differ between these two statements, please call our main office number located on the
cover page of this brochure.
Item 14 – Client Referrals and Other Compensation
Economic Benefits from Others
AGSF does not receive any economic benefits from external sources.
Compensation to Non-Advisory Personnel for Client Referrals
AGSF does not compensate for Client referrals.
Item 15 – Custody
All assets are held at qualified custodians, which means the custodians provide account statements
directly to Clients at least quarterly. Clients are urged to compare the account statements received
directly from their custodians to any documentation or reports prepared by AGSF.
AGSF is deemed to have limited custody solely because advisory fees are directly deducted from
Client’s accounts by the custodian on behalf of AGSF. AGSF will obtain written authorization from Client
to allow for such deductions.
AGSF is also deemed to have custody of funds for certain accounts where you have established a
standing letter of authorization (“SLOA”) that allows us to disburse funds upon your direction to one or
more third parties that you designate. We follow seven conditions provided by the SEC in their No-Action
Letter on Custody dated 2/21/2017, which allows us to avoid an annual surprise custody examination.
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AGSF is not affiliated with the custodian. The custodian does not supervise AGSF, its employees, or its
activities.
Item 16 – Investment Discretion
If applicable, Client will authorize AGSF discretionary authority, via the Advisory Services Agreement,
to determine, without obtaining specific Client consent, the securities to be bought or sold and the
amount of the securities to be bought or sold. If applicable, Client will authorize AGSF discretionary
authority to execute selected investment program transactions as stated within the Investment Advisory
Agreement. If, however, consent for discretion is not given, AGSF will obtain prior Client approval before
executing each transaction.
AGSF allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement
or similar document. Such restrictions could include only allowing purchases of socially conscious
investments. These restrictions must be provided to AGSF in writing.
AGSF does not receive any portion of the transaction fees or commissions paid by the Client to the
custodian.
Item 17 – Voting Client Securities
AGSF does not vote proxies for securities held in clients’ accounts. Clients receive proxy material directly
from their account custodian or broker by either email or U.S. mail. Clients may address questions
concerning a proxy matter to AGSF personnel via email or phone.
Item 18 – Financial Information
AGSF does not solicit prepayment of more than $1,200.00 in fees per client six months or more in
advance.
At this time, neither AGSF nor its management persons have any financial conditions that are likely to
reasonably impair its ability to meet contractual commitments to Clients. AGSF has not been the subject
of a bankruptcy petition in the last ten years.
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