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Form ADV Part 2A – Firm Brochure
Item 1: Cover Page
March 2024
The Fauser Group, LLC
3040 78th Ave SE #591
Mercer Island, WA 98040
www.FauserGroup.com
Firm Contact:
Michael Fauser
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of The Fauser
Group, LLC. If clients have any questions about the contents of this brochure, please contact us at
(206) 466-2542 or mike@fausergroup.com. The information in this brochure has not been approved
or verified by the United States Securities and Exchange Commission or by any State Securities
Authority. Additional information about our firm is also available on the SEC’s website at
www.adviserinfo.sec.gov by searching CRD #282351.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
The Fauser Group, LLC is required to make clients aware of information that has changed since the
last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can
then determine whether to review the brochure in its entirety or to contact us with questions about
the changes.
At this time, there are no material changes to report about the Brochure since the last annual
amendment filed on 03/13/2025.
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Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................................... 1
Item 2: Material Changes........................................................................................................................................................ 2
Item 3: Table of Contents ....................................................................................................................................................... 3
Item 4: Advisory Business ..................................................................................................................................................... 4
Item 5: Fees & Compensation ............................................................................................................................................... 6
Item 6: Performance-Based Fees & Side-By-Side Management.............................................................................. 8
Item 7: Types of Clients & Account Requirements ....................................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ...................................................................... 8
Item 9: Disciplinary Information.......................................................................................................................................11
Item 10: Other Financial Industry Activities & Affiliations ....................................................................................11
Item 11: Code of Ethics, Participation or Interest in .................................................................................................11
Client Transactions & Personal Trading ........................................................................................................................ 11
Item 12: Brokerage Practices ............................................................................................................................................. 12
Item 13: Review of Accounts or Financial Plans ......................................................................................................... 15
Item 14: Client Referrals & Other Compensation ....................................................................................................... 15
Item 15: Custody ..................................................................................................................................................................... 16
Item 16: Investment Discretion ......................................................................................................................................... 17
Item 17: Voting Client Securities ....................................................................................................................................... 17
Item 18: Financial Information .......................................................................................................................................... 17
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Item 4: Advisory Business
Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company formed under the laws of the
State of Washington in 2016 and has been in business as an investment adviser since April 2016. Our
firm is wholly owned by Michael Fauser.
Our firm provides asset management and investment consulting services for many different types of
clients to help meet their financial goals while remaining sensitive to risk tolerance and time
horizons. As a fiduciary it is our duty to always act in the client’s best interest. This is accomplished
in part by knowing the client. Our firm has established a service-oriented advisory practice with open
lines of communication. Working with clients to understand their investment objectives while
educating them about our process, facilitates the kind of working relationship we value.
Types of Advisory Services Offered
Comprehensive Investment Advisory
As part of our Comprehensive Investment Advisory service, clients will be provided asset
management and financial planning or consulting services. This service is designed to assist clients
in meeting their financial goals through the use of a financial plan or consultation. Our firm conducts
client meetings to understand their current financial situation, existing resources, financial goals, and
tolerance for risk. Financial planning and consultation services are included in our Comprehensive
Portfolio Management service. Generally, such financial planning and consulting services will involve
preparing a financial plan or rendering a financial consultation for clients based on the client’s
financial goals and objectives. This planning or consulting may encompass Investment Planning,
Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and
Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis,
Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal
Financial Planning. Based on what is learned, an investment approach is presented to the client,
consisting of individual stocks, bonds, ETFs, options, mutual funds and other public and private
securities or investments. Once the appropriate portfolio has been determined, portfolios are
continuously and regularly monitored, and if necessary, we periodically rebalance or adjust client
accounts under our management, upon the client’s consent or upon written discretionary authority.
Upon client request, our firm provides a summary of observations and recommendations for the
planning or consulting aspects of this service.
We manage investment portfolios on a separately-managed account basis for individuals, high net
worth individuals, trusts, businesses, and non-profit organizations. We will work with you to
determine your investment objectives and investor risk profile. We will allocate your portfolio, taking
into consideration the overall management style selected by you. You may impose restrictions on
investing in certain securities or types of securities. You must clearly state these restrictions to us in
writing.
We work with new clients to develop a plan to transition from your existing portfolio to the desired
portfolio. All investing involves risk. We believe that it is our duty to understand your risk tolerance
and be sure that our recommendations are consistent with your needs and objectives. We also believe
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that effective investment management involves consistent communication between the client and
advisor. We will then monitor and update the allocations that make up your portfolio.
Our investment style typically includes multiple asset classes (stocks, bonds, commodities, real
estate). We believe global allocations offer less risk than investing exclusively in your home-country.
We have a preference for exchange traded funds and individual issues over mutual funds due to the
superior transparency, lower cost, tax efficiency, and portability.
Asset Management:
As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds,
exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or
investments. The client’s individual investment strategy is tailored to their specific needs and may
include some or all of the previously mentioned securities. Portfolios will be designed to meet a
particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate
portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary,
we periodically rebalance or adjust client accounts under our management, upon the client’s consent
or upon written discretionary authority.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. Financial planning
services may include:
Investment Planning/Investment Policy Statements
Income Tax Planning
•
• Financial Independence/Retirement Planning
• Capital Needs Analysis (Goal Funding)
•
• Estate Planning
• Education Planning
• Risk Management (Life and Disability Insurance)
• Employee Benefit and Stock Option Planning
• Tax minimization strategies
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. Clients are
ultimately responsible for the assumptions and personal data upon which The Fauser Group’s
projections are based. The financial plan assumptions and reports are primarily a tool to alert clients
to certain potential financial outcomes. The reports are not intended to nor do they provide any
guarantee about future events including your investment returns. In fact, there is little evidence that
economic outcomes can be accurately forecasted. The implementation of the plan is solely the client’s
responsibility. Our firm provides clients with a summary of their financial situation, and observations
for financial planning engagements. Financial consultations are not typically accompanied by a
written summary of observations and recommendations, as the process is less formal than the
planning service. Assuming that all the information and documents requested from the client are
provided promptly, plans or consultations are typically completed within six (6) months of the client
signing a contract with our firm.
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Tailoring of Advisory Services
Our firm offers individualized investment advice to our Comprehensive Investment Advisory and
Asset Management clients. General investment advice will be offered to our Financial Planning &
Consulting clients. Each Comprehensive Investment Advisory and Asset Management client has the
opportunity to place reasonable restrictions on the types of investments to be held in the portfolio.
Restrictions on investments in certain securities or types of securities may not be possible due to the
level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2025, our firm manages $311,830,040 in discretionary assets under management
and $2,646,314 in non-discretionary assets under management with a total of $314,476,354.
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Comprehensive Investment Advisory:
Assets Under Management
$0 to $249,999.99
$250,000 to $499,999.99
$500,000 to $999,999.99
$1,000,000 to $2,499,999.99
$2,500,000 to $5,000,000
Annual Percentage of Assets Charge
1.50%
1.25%
1.00%
0.85%
0.70%
Fees on assets in excess of $5,000,000 are negotiated. Fees to be assessed will be outlined in the
advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata basis monthly
in arrears based on the value of the account(s) on the time-weighted daily average of the previous
month. Fees are negotiable and will be deducted from client account(s). Adjustments will be made
for deposits and withdrawals during the month. Our firm bills on cash unless indicated otherwise in
writing. Our firm does not offer direct billing as an option.
a) Clients must provide our firm with written authorization permitting direct payment of
advisory fees from their account(s) maintained by a custodian who is independent of our
firm;
b) Each time a fee is directly deducted from the Clients account(s) our firm sends an invoice to
the client showing the fee amount, the value of the assets upon which the fee is based, and
the specific manner in which the fee is calculated as well as disclosing that it is the client’s
responsibility to verify the accuracy of fee calculation, and that the custodian does not
determine its accuracy; and
c) The account custodian sends a statement to the client, at least quarterly, showing all account
disbursements, including advisory fees.
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Asset Management:
Assets Under Management
$0 to $249,999.99
$250,000 to $499,999.99
$500,000 to $999,999.99
$1,000,000 to $2,499,999.99
$2,500,000 to $5,000,000
Annual Percentage of Assets Charge
1.25%
1.20%
0.90%
0.70%
0.50%
Fees on assets in excess of $5,000,000 are negotiated. Fees to be assessed will be outlined in the
advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata basis monthly
in arrears based on the value of the account(s) on the time-weighted daily average of the previous
month. Fees are negotiable and will be deducted from client account(s). Adjustments will be made
for deposits and withdrawals during the quarter. Our firm does not offer direct billing as an option.
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Financial Planning & Consulting:
Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The
maximum hourly fee to be charged will not exceed $300. Flat fees range from $1,000 to $10,000. Our
firm requires a retainer of 50% of the ultimate financial planning or consulting fee at the time of
signing. The total estimated fee, as well as the ultimate fee charged, is based on the scope and
complexity of our engagement with the client. $1,000 would be for a simple case with one or two
services. $10,000 would be for a complex case with multiple services. The price range is based on
the complexity of the client’s situation and the number of services to be provided. The more complex
the case (typically higher net worth clients) and more services provided, the higher the fee. The
remainder of the fee will be directly billed to the client and due within 30 days of a financial plan
being delivered or consultation rendered. The client’s invoice will include the fee charged, the
formula used to calculate the fee(s) and the time period covered by the fee(s). Our firm will not
require a retainer exceeding $1,200 when services cannot be rendered within 6 months.
Other Types of Fees & Expenses
Clients will incur transaction charges for trades executed in their accounts. These transaction fees
are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Charles
Schwab & Co., Inc., (“Charles Schwab”), does not charge transaction fees for U.S. listed equities and
exchange traded funds.
Clients may also pay charges imposed directly by a mutual fund, index fund, or exchange traded fund,
which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales
charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and
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qualified retirement plan fees, and other fund expenses). Our firm does not receive a portion of these
fees.
Termination & Refunds
The client may terminate the advisory contract within five (5) business days without penalty.
Following those five (5) days, either party may terminate the advisory agreement signed with our
firm for Comprehensive Investment Advisory and Asset Management services in writing at any time.
Upon notice of termination pro-rata advisory fees for services rendered to the point of termination
will be charged. If advisory fees cannot be deducted, our firm will send an invoice for due advisory
fees to the client.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Our firm works with Individuals and High Net Worth Individuals.
Our firm has a current minimum household requirement balance of $500,000; however, the
household minimum balance is negotiable at the firm’s discretion.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Our goal is not to beat the market, a particular index, or your neighbor’s returns. We believe investing
is about providing long-term financial security. Our goal is to preserve and grow your assets by
designing portfolios which are extremely well diversified, tax efficient, and low cost. This protects
against short-term swings in any one asset class and helps grow your wealth over the long-term. No
investment strategy will make up for inadequate savings.
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The primary vehicles used in our portfolios are individual stocks and exchange traded funds (ETFs).
Secondarily, we will use mutual funds when warranted by the underlying asset class. This approach
prioritizes low costs, tax efficiency, transparency, and liquidity.
Our portfolios are global in nature and will frequently have a significant allocation towards
international stocks, international bonds, and international real estate. Portfolios will typically have
exposure to emerging markets and currency risks. In order to help manage risk, a portfolio must be
properly diversified at all times. This means not simply owning a large number of stocks and bonds,
but spreading investment assets over many asset classes, each of which may behave differently in
response to varying economic and market conditions. By building a portfolio that invests in asset
classes that are not perfectly correlated with one another, we strive to create a more optimized
portfolio that minimizes risk for a given level of return or maximizes return for a given level of risk.
The second part of our approach to portfolio management involves managing costs. We strive to seek
low cost investments within each asset class, we monitor trading costs, we attempt to be very tax
efficient (typically harvesting tax losses one or more times a year when the losses are material,) and
we keep our management fees competitive.
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Long-Term Purchases: When utilizing this strategy, we may purchase securities with the idea of
holding them for a relatively long time (typically held for at least a year). A risk in a long-term
purchase strategy is that by holding the security for this length of time, we may not take advantages
of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a
security may decline sharply in value before we make the decision to sell. Typically we employ this
sub-strategy when we believe the securities to be well valued; and/or we want exposure to a
particular asset class over time, regardless of the current projection for this class. The potential risks
associated with this investment strategy involve a lower than expected return, for many years in a
row. Lower-than-expected returns that last for a long time and/or that are severe in nature would
have the impact of dramatically lowering the ending value of your portfolio, and thus could
significantly threaten your ability to meet financial goals.
Short-Term Purchases: When utilizing this strategy, we may also purchase securities with the idea
of selling them within a relatively short time (typically a year or less). We do this in an attempt to
take advantage of conditions that we believe will soon result in a price swing in the securities we
purchase. The potential risk associated with this investment strategy is associated with the currency
or exchange rate. Currency or exchange rate risk is a form of risk that arises from the change in price
of one currency against another. The constant fluctuations in the foreign currency in which an
investment is denominated vis-à-vis one's home currency may add risk to the value of a security.
Currency risk is greater for shorter term investments, which do not have time to level off like longer
term foreign investments.
Trading: We purchase securities with the idea of selling them very quickly (typically within 30 days
or less). We do this in an attempt to take advantage of our predictions of brief price swings. Trading
involves risk that may not be suitable for every investor, and may involve a high volume of trading
activity. Each trade generates a commission and the total daily commission on such a high volume of
trading can be considerable. Active trading accounts should be considered speculative in nature with
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the objective being to generate short-term profits. This activity may result in the loss of more than
100% of an investment.
Margin Transactions: We will purchase stocks for your portfolio with money borrowed from your
brokerage account. This allows you to purchase more stock than you would be able to with your
available cash, and allows us to purchase stock without selling other holdings. Margin accounts and
transactions are risky and not necessarily for every client. The potential risks associated with these
transactions are (1) You can lose more funds than are deposited into the margin account; (2) the
force sale of securities or other assets in your account; (3) the sale of securities or other assets
without contacting you; and (4) you may not be entitled to choose which securities or other assets in
your account(s) are liquidated or sold to meet a margin call.
Option Writing: We may use options as an investment strategy. An option is a contract that gives
the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific
price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a
derivative, because it derives its value from an underlying asset. The two types of options are calls
and puts. A call gives us the right to buy an asset at a certain price within a specific period of time.
We will buy a call if we have determined that the stock will increase substantially before the option
expires. A put gives us the holder the right to sell an asset at a certain price within a specific period
of time. We will buy a put if we have determined that the price of the stock will fall before the option
expires. We will use options to "hedge" a purchase of the underlying security; in other words, we will
use an option purchase to limit the potential upside and downside of a security we have purchased
for your portfolio. We use "covered calls", in which we sell an option on security you own. In this
strategy, you receive a fee for making the option available, and the person purchasing the option has
the right to buy the security from you at an agreed-upon price. We use a "spreading strategy", in
which we purchase two or more option contracts (for example, a call option that you buy and a call
option that you sell) for the same underlying security. This effectively puts you on both sides of the
market, but with the ability to vary price, time and other factors. The potential risks associated with
these transactions are that (1) all options expire. The closer the option gets to expiration, the quicker
the premium in the option deteriorates; and (2) Prices can move very quickly. Depending on factors
such as time until expiration and the relationship of the stock price to the option’s strike price, small
movements in a stock can translate into big movements in the underlying options.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, are appropriately diversified in investments, and ask
any questions.
Additional Information
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to our
Comprehensive Investment Advisory and Asset Management services, as applicable.
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Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
In addition to being a registered investment adviser, our firm is also registered as an insurance
producer with the State of Washington’s Office of the Insurance Commissioner. As such,
representatives of our firm are licensed insurance agents. As a result of these transactions, they
receive normal and customary commissions. A conflict of interest exists as these commissionable
securities sales create an incentive to recommend products based on the compensation earned. To
mitigate this potential conflict, our firm will act in the client’s best interest. Clients are under no
obligation to purchase insurance products through our firm or its representatives and are free to
purchase investments products recommended by our firm through another unaffiliated provider.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. Our firm requires all representatives to conduct business with the
highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
our representatives for their personal accounts1. In order to monitor compliance with our personal
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities prior to buying or selling for our clients in the same day. If related persons’
accounts are included in a block trade, our related persons will always trade personal accounts last.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
Our firm does not maintain custody of client assets. Client assets must be maintained by a qualified
custodian. Our firm seeks to recommend a custodian who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. The factors considered, among others, are these:
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
• Quality of services
With this in consideration, our firm has an arrangement with Charles Schwab & Co., Inc., (“Charles
Schwab”), member FINRA/SIPC. Charles Schwab offers services to independent investment
advisers which includes custody of securities, trade execution, clearance and settlement of
transactions. Charles Schwab enables us to obtain many no-load mutual funds without transaction
charges and other no-load funds at nominal transaction charges. Charles Schwab does not charge
client accounts separately for custodial services. Client accounts will be charged transaction fees,
commissions or other fees on trades that are executed or settle into the client’s custodial account.
Transaction fees are negotiated with Charles Schwab and are generally discounted from customary
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retail commission rates. This benefits clients because the overall fee paid is often lower than would be
otherwise.
Charles Schwab may make certain research and brokerage services available at no additional cost
to our firm. Research products and services provided by Charles Schwab may include: research
reports on recommendations or other information about particular companies or industries;
economic surveys, data and analyses; financial publications; portfolio evaluation services; financial
database software and services; computerized news and pricing services; quotation equipment for
use in running software used in investment decision-making; and other products or services that
provide lawful and appropriate assistance by Charles Schwab to our firm in the performance of our
investment decision-making responsibilities. The aforementioned research and brokerage services
qualify for the safe harbor exemption defined in Section 28(e) of the Securities Exchange Act of
1934.
Charles Schwab does not make client brokerage commissions generated by client transactions
available for our firm’s use. The aforementioned research and brokerage services are used by our
firm to manage accounts for which our firm has investment discretion. Without this arrangement,
our firm might be compelled to purchase the same or similar services at our own expense.
As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of
our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm
or our related persons creates a potential conflict of interest and may indirectly influence our firm’s
choice of Charles Schwab as a custodial recommendation. Our firm examined this potential conflict
of interest when our firm chose to recommend Charles Schwab and have determined that the
recommendation is in the best interest of our firm’s clients and satisfies our fiduciary obligations,
including our duty to seek best execution.
Our clients may pay a transaction fee or commission to Charles Schwab that is higher than another
qualified broker dealer might charge to effect the same transaction where our firm determines in
good faith that the commission is reasonable in relation to the value of the brokerage and research
services provided to the client as a whole.
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 a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Soft Dollars
As disclosed above, we participate in Charles Schwab’s institutional customer program and we may
recommend Charles Schwab to Clients for custody and brokerage services. There is no direct link
between our firm’s participation in the program and the investment advice we give to our Clients,
although we receive economic benefits through our participation in the program that are typically
not available to Charles Schwab retail investors. These benefits include the following products and
services (provided without cost or at a discount): receipt of duplicate Client statements and
confirmations; research related products and tools; consulting services; access to a trading desk
serving our firm’s participants; access to block trading (which provides the ability to aggregate
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securities transactions for execution and then allocate the appropriate shares to Client accounts); the
ability to have advisory fees deducted directly from Client accounts; access to an electronic
communications network for Client order entry and account information; access to mutual funds
with no transaction fees and to certain institutional money managers; and discounts on compliance,
marketing, research, technology, and practice management products or services provided to us by
third party vendors. Charles Schwab may also have paid for business consulting and professional
services received by our firm’s related persons. Some of the products and services made available by
Charles Schwab through the program may benefit our firm but may not benefit our Client accounts.
These products or services may assist us in managing and administering Client accounts, including
accounts not maintained at Charles Schwab. Other services made available by Charles Schwab are
intended to help us manage and further develop our business enterprise. The benefits received by
our firm or our personnel through participation in the program do not depend on the amount of
brokerage transactions directed to Charles Schwab. As part of our fiduciary duties to our clients, we
endeavor at all times to put the interests of our clients first. Clients should be aware, however, that
the receipt of economic benefits by our firm or our related persons in and of itself creates a potential
conflict of interest and may indirectly influence our firm’s choice of Charles Schwab for custody and
brokerage services.
Client Brokerage Commissions
Charles Schwab does not make client brokerage commissions generated by client transactions
available for our firm’s use.
Client Transactions in Return for Soft Dollars
Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar
benefits.
Directed Brokerage
In certain instances, clients may seek to limit or restrict our discretionary authority in making the
determination of the brokers with whom orders for the purchase or sale of securities are placed for
execution, and the commission rates at which such securities transactions are effected. Clients may
seek to limit our authority in this area by directing that transactions (or some specified percentage
of transactions) be executed through specified brokers in return for portfolio evaluation or other
services deemed by the client to be of value. Any such client direction must be in writing (often
through our advisory agreement), and may contain a representation from the client that the
arrangement is permissible under its governing laws and documents, if this is relevant.
Our firm provides appropriate disclosure in writing to clients who direct trades to particular brokers,
that with respect to their directed trades, they will be treated as if they have retained the investment
discretion that our firm otherwise would have in selecting brokers to effect transactions and in
negotiating commissions and that such direction may adversely affect our ability to obtain best price
and execution. In addition, our firm will inform clients in writing that the trade orders may not be
aggregated with other clients’ orders and that direction of brokerage may hinder best execution.
Client-Directed Brokerage
Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to
achieve the most favorable execution of client transactions. Client directed brokerage may cost
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The Fauser Group, LLC
clients more money. For example, in a directed brokerage account, clients may pay higher brokerage
commissions because our firm may not be able to aggregate orders to reduce transaction costs, or
clients may receive less favorable prices.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when our firm believes
that to do so will be in the best interest of the effected accounts. When such concurrent authorizations
occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, our firm attempts to allocate trade executions in the most equitable
manner possible, taking into consideration client objectives, current asset allocation and availability of
funds using price averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
Mr. Fauser, Chief Compliance Officer, reviews accounts on at least an annual basis for our
Comprehensive Investment Advisory and Asset Management clients. The nature of these reviews is
to learn whether client accounts are in line with their investment objectives, appropriately
positioned based on market conditions, and investment policies, if applicable. Our firm may review
client accounts more frequently than described above. Among the factors which may trigger an off-
cycle review are major market or economic events, the client’s life events, requests by the client, etc.
Our firm provides quarterly performance reports to clients. Verbal reports to clients take place on at
least an annual basis when our Asset Management and Comprehensive Investment Advisory and
Asset Management clients are contacted.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or update to their initial written financial plan.
Item 14: Client Referrals & Other Compensation
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
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Item 15: Custody
While our firm does not maintain physical custody of client assets (which are maintained by a
qualified custodian, as discussed above), we are deemed to have custody of certain client assets if
given the authority to withdraw assets from client accounts, as further described below under “Third
Party Money Movement.” All our clients receive account statements directly from their qualified
custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review
these statements. Additionally, if our firm decides to send its own account statements to clients, such
statements will include a legend that recommends the client compare the account statements
received from the qualified custodian with those received from our firm. Clients are encouraged to
raise any questions with us about the custody, safety or security of their assets and our custodial
recommendations.
Clients are encouraged to raise any questions with us about the custody, safety or security of their
assets and our custodial recommendations.
The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under
the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody
Rule as well as clarified that an adviser who has the power to disburse client funds to a third party
under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has
adopted the following safeguards in conjunction with our custodian, Charles Schwab:
• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
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Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, our firm is
authorized to execute securities transactions, determine which securities are bought and sold, and
the total amount to be bought and sold. Should clients grant our firm non-discretionary authority,
our firm would be required to obtain the client’s permission prior to effecting securities transactions.
Limitations may be imposed by the client in the form of specific constraints on any of these areas of
discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients are free to contact Mr. Fauser with any questions
about proxies or other solicitations.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
• Our firm does not require the prepayment of more than $1,200 in fees and six or more months
in advance.
• Our firm does not take custody of client funds or securities.
• Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
Our firm has never been the subject of a bankruptcy proceeding.
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