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Ultra Advisory Group LLC
This brochure provides information about Ultra Advisory Group LLC dba Ultra Advisory Group (“Ultra Advisory Group”
“Advisor” or “Firm”) qualifications and business practices. If you have any questions about the contents of this brochure,
please contact us at (949) 590 4923 or by email at bryan.gould@ultraadvisorygroup.com. The information in this
brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any
State Securities Authority.
Additional information about Ultra Advisory Group is also available at the SEC’s website https://adviserinfo.sec.gov/
(select “investment adviser firm” and type in our firm name). Results will provide you with both Part 1 and 2 of our Form
ADV.
We are a registered investment advisory firm. Our registration does not imply any level of skill or training. The oral and
written communications we provide to you, including this brochure, are for you to evaluate us. Please use this
information as factors in your decision to hire us or to continue our business relationship.
Item 1 – Cover Page ADV Part 2 A
March 17, 2026
CRD #: 338775
19800 MacArthur BLVD, Ste. 300
Irvine, CA 92612
bryan.gould@ultraadvisorygroup.com
(949) 590-4923
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Item 2 – Material Changes
This brochure dated March 17 2026, has been prepared by Ultra Advisory Group LLC to meet SEC requirements it has changed
materially since our initial filing in the following ways:
UPDATED:
4e: Assets under Management (AUM)
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Item 3 – Table of Contents
Item 1 – Cover Page ADV Part 2 A ........................................................................................................................................ 1
Item 2 – Material Changes ................................................................................................................................................... 2
Item 3 – Table of Contents ................................................................................................................................................... 3
Item 4 – Advisory Business .................................................................................................................................................. 4
Item 5 – Fees and Compensation......................................................................................................................................... 9
Item 6 – Performance-Based Fees and Side-by-Side Management .................................................................................... 11
Item 7 – Types of Clients .................................................................................................................................................... 12
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................... 12
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 ........................................ 16
Item 12 – Brokerage Practices ............................................................................................................................................ 16
Item 13 – Review of Accounts ............................................................................................................................................ 17
Item 14 – Client Referrals and Other Compensation .......................................................................................................... 18
Item 15 – Custody .............................................................................................................................................................. 18
Item 16 – Investment Discretion ........................................................................................................................................ 18
Item 17 – Voting Client Securities ...................................................................................................................................... 19
Item 18 – Financial Information ......................................................................................................................................... 19
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Item 4 – Advisory Business
4a: Firm Description
ULTRA ADVISORY GROUP LLC was established in 2025 by Bryan Gould. Ultra Advisory Group became registered as an
investment advisor with the Securities and Exchange Commission in 2025. Our main office is located in Irvine, CA.
4a1: Principal Members
Bryan Gould, CCO and Member: Mr. Gould may be contacted by email at bryan.gould@ultraadvisorygroup.com or by
telephone at (949) 590 4923.
4b: Types of Advisory Services
Ultra Advisory Group offers a variety of investment advisory services to our clients with discretionary authority. Ultra
Advisory Group’s services include investment management, financial planning and consulting services. Prior to providing
advisory services, clients are required to enter into a written agreement with Ultra Advisory Group.
When we provide investment advice to you regarding your retirement plan account or individual retirement account,
we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal
Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some
conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put
our interests ahead of yours. As fiduciaries we are obligated to do the following:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Investment Management Services
We work with our clients to identify their investment goals and objectives as well as risk tolerance in order to create an
initial portfolio allocation designed to complement our clients’ financial goals and objectives. We may create a portfolio,
consisting of, but not limited to, no-load funds, exchange traded funds, individual stocks or bonds and certificates of
deposit. Some assets will be liquid and non-liquid Limited Partnership vehicles.
Each portfolio will be initially designed to meet a particular investment goal which Ultra Advisory Group has determined
to be suitable for the client’s circumstances. Once the appropriate portfolio has been determined, we will review the
portfolio and rebalance the account based upon our client’s individual needs, stated goals and objectives. Ultra Advisory
Group’s strategy, generally, is to seek to meet the client’s investment objectives while providing access to personal
advisory services. Ultra Advisory Group may also provide advice about any type of legacy position or other investment
held in client portfolios.
Ultra Advisory Group owes the client a fiduciary duty to put the client’s interest first which includes, but is not limited
to, a duty of care, loyalty, and utmost good faith. Your portfolio is customized based on your investment objectives. You
may make requests or suggestions in writing regarding the investments made in your portfolio. Restrictions on trading
which, in our opinion, are not in your best interest cannot be honored and if forced may result in the termination of our
agreement.
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In cases where we are not given discretion, we must receive permission from the client to make any trades on a non-
discretionary basis. In non-discretionary accounts, you have the right to decide whether to act upon Ultra Advisory Group
recommendations.
Occasionally our firm utilizes the sub-advisory services of a Third-Party Money Manager (“manager”) for the
management of client accounts. Sub-advisors are utilized by Ultra Advisory Group to offer funds to clients managed to
a specific investment objective. The client will not engage the subadvisor directly; the client’s advisory relationship
remains with Ultra Advisory Group as set forth in the client’s Investment Advisory Agreement. Our firm will not offer
advice on any specific securities or other investments in connection with this service. Prior to utilizing sub-advisors for
our clients, our firm will provide initial due diligence on managers and ongoing reviews of their management of client
accounts. To assist in the selection of a manager, our firm will gather information pertaining to the client’s financial
situation and investment objectives.
Our firm will periodically review manager reports provided to the client at least annually. Our firm will contact clients
from time to time in order to review their financial situation and objectives; communicate information to managers as
warranted; and assist the client in understanding and evaluating the services provided by the managers.
Clients will be expected to notify our firm of any changes in their financial situation, investment objectives, or account
restrictions that could affect their financial standing.
Our firm takes actions on behalf of the client to hire or fire managers used in the implementation of a client’s investment
plan and execution of the Advisory Agreement with our Firm. Therefore, the firm has the discretionary authority to hire
or fire the manager or to allocate assets among managers without obtaining the Client’s consent.
Clients should carefully review the disclosure documents of managers for a full description of the services offered,
investments, and strategies used.
Financial Planning
Financial Planning includes, in all or part, but is not limited to, the preparation of a financial plan for an investment
advisory client which may include reviews and recommendations on any or all of the following areas depending on the
client’s circumstances:
•
•
Investment Planning: Determine with the client, based on their goals, time horizon, and risk tolerance, how to structure a
suitable portfolio (using mutual funds and ETFs) using principles of diversification, asset allocation, and sometimes asset
location.
Investment Policy Statements: Determining specific parameters within which a client’s investments will be managed that
can include the weighting of stocks to bonds to cash, the limitation on the use of any particular type of security, the
methodology used for rebalancing and so on.
• Portfolio Review and Evaluation: Assessing a client’s existing portfolio to determine suitability of their current investments
and, in some cases, evaluating the differences between such and the methods Ultra Advisory Group utilizes to manage
assets. Evaluation can include weighting of asset classes, types of securities used, concentrated positions, tax efficiency of
investments, expense ratios, and so forth.
• Capital Needs Analysis (Goal Funding): A method using time value of money calculations to determine how much a client
would need to save, at a given level of return, every month or year in order to achieve a certain financial goal, such as paying
for four years of college for their child.
• Tax Management and Planning: Forward-looking tax strategy that can help a client minimize their tax expenses and
maximize what they have to invest. This can include planning for Roth conversions, strategic charitable giving, deferring
income into tax- advantaged retirement accounts, and tax-loss harvesting, to name a few.
• Trust and Estate Planning: Helping a client understand how assets are distributed upon death and, at times, working with
their estate planning attorneys to achieve both their financial and estate planning goals. This also involves review of
beneficiary designations and ensuring clients have the proper and updated documents drafted to ensure they are always in
control of how assets will be distributed.
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• Retirement Planning: Gathering data that relates to a client’s assets, liabilities, expenses, goals, and savings and evaluating
such to determine the most appropriate strategy to achieving the greatest probability of being able to retire in the lifestyle
they desire and maintain such for the rest of their lives.
• Social Security: Helping a client decide when to file for social security is a critical part of the retirement planning process.
Married clients are advised on how to make their selections based on their particular circumstances as a couple and can
involve a complex analysis that depends on longevity, income needs, and whether the client(s) intend to work in their
retirement.
• Employee Benefits: If a client is an employee and has access to benefits, an analysis of available benefits can be done
together with the client, offering advice on what benefits should be selected based upon the particular client’s wishes, goals
and family needs. This can include various types of insurance, Flexible Spending accounts, Employee Stock Purchase plans,
Restricted Stock Awards, Options, and so on.
• Education Planning: Helping clients plan financially for the expenses involved in educating their children and the function
of various tax advantaged ways of saving for such expenses such as with a 529 plan and annual gifting.
• Budgeting and Cash Flow Planning: Determining with the client what their net income and monthly/annual expenses are
to determine where costs might be reduced to produce additional cash flow that can be allocated toward goals.
• Debt Management: Where a client has debts, gathering data on the nature and interest rates being paid on all liabilities,
then completing a cash flow analysis to come up with the best strategy for tackling the paying down of debt in the most
efficient way possible.
• Charitable Giving: When a client wishes to be philanthropic, Ultra Advisory Group can assist the client in how to leverage
their investments to maximize contributions and provide tax advantages simultaneously. This can include gifting of required
minimum distributions (RMDs), setting up of Donor Advised Funds or gifting of highly appreciated shares, to name a few.
• Risk Management (Life and Disability Insurance): Ultra Advisory Group does not sell insurance products but can offer advice
on what types of insurance a client may need or be lacking and how much would be adequate to ensure their goals are still
met in the event of a disability or premature death.
• Disability Planning and Income Protection: Using various planning tools, an analysis of any current income protection a
client may have through work (or owned individually) is completed to determine whether there are any “gaps” that might
leave the client’s family unable to meet financial goals and, if so, providing advice with finding the appropriate coverage.
• Long Term Care Insurance: We may provide clients with advice and guidance related to long-term care planning as part
of our overall financial planning services. Such services may include helping clients evaluate potential long-term care
needs, discussing insurance options (including long-term care insurance policies or hybrid products), and analyzing
how long-term care considerations may impact retirement and estate planning. Our role is limited to providing
education and advice; we do not sell insurance products, and we do not receive commissions or other compensation
from any insurance provider. Clients are responsible for making all decisions regarding the purchase of long-term care
coverage and for working directly with insurance carriers or licensed agents if they wish to obtain such products.
Financial planning services can vary and are customized depending on each client’s complexity and circumstances.
The financial planning services will be defined and agreed upon by both parties in advance. For example, a client who is
not using Ultra Advisory Group’s investment management services may request a comprehensive financial plan or
certain components of our planning services.
The amount of time it could take to provide each of the financial planning services will depend on the client’s unique
circumstances and will vary from client to client. Our services are customized based on what a client may request. In
addition, the amount of time it takes to provide these services is dependent on the quality and scope of the information
that is provided by the client to the advisor.
Clients are encouraged to review their plans on a regular basis.
Ultra Advisory Group has a conflict of interest because it offers both financial planning and investment management
services. When providing financial planning services, Ultra Advisory Group has an incentive to recommend itself for
investment management services as Ultra Advisory Group receives additional compensation. Ultra Advisory Group
mitigates this conflict of interest by disclosing this conflict to the client and disclosing that clients always have the right
to decide whether to act on any of the recommendations made by Ultra Advisory Group. If the client elects to act on
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any of these recommendations, they retain the right to affect the transactions through a professional unaffiliated with
Ultra Advisory Group. Our fiduciary obligation is to always act and recommend in the client’s best interest.
4c: Retirement Plan Advisory Services
The Retirement Plan Advisory Services we offer help employer plan sponsors to establish, monitor and review their
company’s retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment
selection and monitoring plan structure and participant education.
Our firm provides its advisory services as an investment advisor as defined under Section 3(21) and Section 3(38) of the
Employee Retirement Income Security Act of 1974, as amended (“ERISA”). We offer investment management of 401(k)
accounts, profit sharing plans and defined contribution plans on a Plan level by managing the investment line- up making
changes as necessary. Our firm will establish the plan’s needs and objectives through an initial meeting to collect data,
review plan information and assist in developing or updating the plan’s provision. Ongoing services may include
recommendations regarding the selection and review of unaffiliated mutual funds that, in the Firm’s judgment, are
suitable for plan assets to be invested. We periodically review the investment options selected and make
recommendations to keep or replace plans investment options as appropriate.
For employer-sponsored retirement plans, we provide advisory services as an investment advisor as defined under
Section 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
When serving as an ERISA 3(38) investment manager, the plan sponsor is relieved of all fiduciary responsibility for the
investment decisions made by our firm. We are the discretionary investment manager in accordance with the terms of
a separate ERISA 3(38) Investment Management Agreement between our firm and the plan sponsor. Our investment
management is limited in that it has the discretion solely to replace funds in plan fund lineups and initiate the transfer
of existing balances to the replacements without prior approval from the client.
Additionally, our firm offers Retirement Plan Consulting Services to our Plan Sponsors. Our Firm may assist the Plan
Sponsor by acting as a service provider liaison, providing participant enrollment meetings, and assisting with participant
education. While the primary clients for these services will be pension, profit sharing and 401(k) plans, we offer these
services, where appropriate, to individuals and trusts and organizations. Pension Consulting Services are comprised of
four distinct services. Clients may choose to use any or all of these services.
•
SELECTION OF INVESTMENT VEHICLES - We assist plan sponsors in constructing appropriate asset allocation
models. We will then review various mutual funds (both index and managed) to determine which investments
are appropriate. The number of investments to be recommended will be determined by the client.
• MONITORING OF INVESTMENT PERFORMANCE - We monitor client investments continually, based on the
procedures and timing intervals detailed in the Investment Policy Statement. Although our firm is not involved
in any way in the purchase or sale of these investments, we supervise the client's portfolio and will make
recommendations to the client as market factors and the client's needs dictate.
•
PLAN EDUCATION - We will assist in participant education, which may include preparation of education
materials and/or conducting investment education seminars and meeting for Plan Participants. Such meetings
may be on a group and/or individual basis. Such meetings shall not include specific investment advice about
investment options under the Plan as being appropriate for a particular participant but may include the use of
education investment models.
Plan participants have the ability to exercise control over the assets in their account, and we have no authority
or discretion to direct the investment of assets of any participant’s account under the Retirement Plan
Consulting services offered by our firm.
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• ADDITIONAL INFORMATION CONCERNING PENSION & RETIREMENT PLAN CONSULTING- All pension
consulting services shall be in compliance with applicable State rules and statutes and/or the Investment
Advisers Act of 1940, rules and regulations thereunder regulating the services provided by this Agreement. This
section applies to an Account that is a pension or other employee benefit plan (a “Plan”) governed by the
Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the Account is part of a Plan and
we accept appointments to provide advisory services to such Account, Adviser acknowledges that it is a
fiduciary within the meaning of Section 3(21) of ERISA (but only with respect to the provision of services
described in section 1 of this agreement). Client represents that (i) Adviser’s appointment and services are
consistent with the Plan documents, (ii) Client has furnished Adviser true and complete copies of all documents
establishing and governing the Plan and evidencing your authority to retain Adviser. Client further represents
that they will promptly furnish Adviser with any amendments to the Plan, and Client agrees that, if any
amendment affects our rights or obligations, such amendment will be binding on Adviser only with our prior
written consent. If ERISA or other applicable law requires bonding with respect to the assets in the account,
Client will obtain and maintain at his/her/its expense bonding that satisfies this requirement and covers Adviser
and any of our affiliates.
As an investment adviser registered under the Securities Act of California and other applicable federal and state
securities laws, Ultra Advisory Group owes the client a fiduciary duty to put the client’s interest first which includes, but
is not limited to, a duty of care, of loyalty, to act in accordance with plan documents, and utmost good faith.
4d: Client Tailored Relationships and Restrictions
Ultra Advisory Group owes the client a fiduciary duty to put the client’s interest first, which includes, but is not limited
to, a duty of care, of loyalty, and utmost good faith. Your portfolio is customized based on your investment objectives.
You may make requests or make suggestions regarding the investments made in your portfolio.
Restrictions on trading which, in our opinion, are not in your best interest cannot be honored and if forced may result
in the termination of our agreement. You are under no obligation to act upon Ultra Advisory Group’s or associated
person's recommendations.
4d: Wrap Fee Programs
Ultra Advisory Group offers Anchor Point, where appropriate, to interested prospects and advisory clients. Anchor Point
utilizes different custodians for the wrap fee program. For more detailed information regarding our wrap fee program,
Anchor Point, please review the complete brochure.
4e: Assets under Management (AUM)
Ultra Advisory Group as of March 13, 2026, has $142,609,950 in discretionary assets under management and $0 in non-
discretionary assets under management for $142,609,950 total assets under management.
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Item 5 – Fees and Compensation
5a, b, c & d: Fee Schedules, Payments & Options
Investment Management
Our Maximum fee is 1.25% of assets under management. Our standard fees are shown in the table below:
Assets Under Management
Annual Fee as Percent
$0-$999,999
1.25%
$1,000,000 - $1,999,999
1.00%
$2,000,000 - $9,999,999
0.75%
$10,000,000 - $19,999,999
0.50%
$20,000,000 - $29,999,999
0.40%
$30,000,000 - $39,999,999
0.35%
$40,000,000 - $49,999,999
0.30%
$50,000,000 and above
0.25%
Fees are negotiable. Fees may be lower based on a number of factors, including:
•
•
Size of the relationship – Larger accounts may receive more favorable pricing.
Accounts within the same household will be combined under a signed householding form for a reduced fee
unless the client instructs otherwise.
Loyal long-term clients may retain legacy pricing from their original agreements.
•
• Our employees and their family related accounts are charged a reduced fee for services.
• Matching Bonafide competitor fees.
For purposes of determining value, securities and other instruments traded on a market for which actual transaction
prices are publicly reported are valued at the last reported sale price on the principal market in which they are traded.
If the investments are not managed assets, they are not included in Ultra Advisory Group’s fee calculation.
Compensation for our services will be calculated in accordance with what is set in the client agreement. We may modify
the terms of any agreement by written changes submitted to the client for signature. Changes excluding fee reductions
will not become effective until after the client has agreed to the change in writing. While we strive to maintain
competitive fees, the same or similar services may be available from other firms at higher or lower fees.
Ultra Advisory Group requires written authorization from the client to deduct advisory fees from an account held by a
qualified custodian. Ultra Advisory Group fees are paid from your account by the custodian when we submit an invoice
to them. At the same time, Ultra Advisory Group sends the qualified custodian written notice of the amount of the fee
to be deducted from the client’s account. The invoice will contain the name of the custodian on the invoice. We strongly
urge you to compare our invoices with the fees listed in the custodian account statements.
Invoicing includes fee arrangements with third-party investment advisers when the third-party adviser sends invoice
information, which includes Ultra Advisory Group’s advisory fee. If any invoice information relating to Ultra Advisory
Group’s advisory fees is missing, Ultra Advisory Group will provide the missing information.
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Ultra Advisory Group fees are paid quarterly in advance as indicated in your investment advisory agreement based on
the value as of the last business day of the prior quarter. Our fee is determined by taking the percentage rate we charge,
divided by four, times the market value of the account. The market value is the sum of the values of all managed assets
in the account, not adjusted by any margin debit.
In cases where there are partial fees at the commencement or termination of our agreement, they will be billed or
refunded on a pro-rated basis contingent on the number of days the account was open. Quarterly fee adjustments for
additional assets received into the account during a quarter or for partial withdrawals will also be provided on the above
pro rata basis. If there is insufficient cash in your account to pay your fees, securities in your portfolio may be sold to
pay our fee.
In addition to our fees, there may be custodial, mutual fund, 12b-1 fees or similar third-party management fees and
charges. See 5c: Third Party Fees below.
Sub-Advised Programs.
As discussed in Item 4 above, there are occasions where an independent Third-Party Money Manager (“manager”) acts
as a sub-adviser to our firm. In those circumstances, the manager manages the assets based upon the parameters
provided by our firm. The client will not engage the subadvisor directly; the client’s advisory relationship remains with
Ultra Advisory Group as set forth in the client’s Investment Advisory Agreement. Sub-advisers charge separate fees for
the services provided. A separate fee is charged by Ultra Advisory Group for portfolio monitoring, oversight and ongoing
due diligence on the manager. See Item 4 for other services provided by Ultra Advisory Group when utilizing subadvisors.
The total advisory fee may be collected from the custodian by our firm. Alternatively, the manager fee may be collected
separately from the custodian. The total fee will include our firm’s portion of the investment advisory fee as well as the
manager’s fee. Fees charged by the managers range from 0% to 1.0%. Clients may be able to go to the sub-adviser
directly for advisory services.
Ultra Advisory Group may at any time terminate the relationship with a manager that manages your assets. Ultra
Advisory Group will notify you of instances where we have terminated a relationship with any manager you are investing
with. Ultra Advisory Group will not conduct ongoing supervisory reviews of the manager following such termination.
Factors involved in the termination of a manager may include a failure to adhere to their stated management style or
your objectives, a material change in the professional staff of the manager, unexplained poor performance, unexplained
inconsistency of account performance, or our decision to no longer include the manager on our list of approved
managers.
Information regarding the services and strategies provided by managers can be found in the specific manager’s ADV
2A. Clients are encouraged to carefully review each manager’s ADV 2A disclosure brochure for service level, fee, conflict
of interest, and professional background information applicable to each sub-adviser.
Financial Planning & Consulting Fees
Standard Financial Planning and consulting services are complimentary for clients that have investment management services.
Retirement Plan Advisory Services
Fees for portfolio monitoring, retirement plan ERISA planning, and consulting services depend on the types of services
that serve the client. We typically use our standard fee schedule. Fees are negotiable depending on the size of the plan
and services rendered. Fees are paid quarterly in advance as designated in our agreement with you. Fees billed in
advance are based on the value of the assets in the account as of the last business day of the prior quarter. For Plans
where our fee is billed to the custodian, the fee is deducted directly from the participant accounts. Written authorization
permitting us to be paid directly from the custodial account is outlined in the Agreement. Our maximum investment
advisory fee is 1.25%, or we may negotiate a lower advisory fee. The specific advisory fees are set forth in your
Investment Advisory Agreement.
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Ultra Advisory Group does not take receipt of more than $1,200 in fees per client six (6) months or more in advance.
Lower fees for comparable services may be available from other sources. If a conflict exists between the interests of the
Advisor or its associated persons and the interest of the client, the client always has the right to decide whether to act
on any of the recommendations made by Ultra Advisory Group. If you elect to act on any of the recommendations, you
have the right to affect the transactions through a professional unaffiliated with Ultra Advisory Group. Our fiduciary
obligation is to always act and recommend in the client’s best interest.
5b: Account Requirements and Types of Clients.
Ultra Advisory Group caters primarily to affluent individuals and their retirement accounts, family offices and family
investment vehicles who seek an approach to capital appreciation by investing in established stocks, exchange traded
funds, mutual funds and fixed income. Ultra Advisory Group investment programs are also suitable for institutional
investors such as pension and profit sharing plans, trust, estates and/or charitable organizations and corporations. While
there is no account minimum, Ultra Advisory Group may decline to accept accounts smaller than $1,000,000.
5c: Third Party Fees
You are responsible for the payment of all third-party fees (i.e. custodian fees, mutual fund fees, 12b-1 fees, transaction
fees, etc.). Those fees are also separate and distinct from the fees we charge. Ultra Advisory Group does the best we
can to minimize all fees and transaction costs.
All brokerage commissions, stock transfer fees, 12b-1 fees and other similar charges incurred in connection with
transactions for the account will be paid out of the assets in the account and are in addition to the investment
management fees paid to us. While we take measures to ensure the fees charged are accurate, it is your responsibility
to ensure the amount of fee charged is correct. In addition to invoices and reports sent by us, you will receive statements
directly from the custodian or mutual funds or other investments you hold. We strongly urge you to compare our
invoices and reports to custodian statements for accuracy. Wrap fee clients should refer to the wrap fee brochure for
definitions of these fees.
5.d: Termination
The investment advisory contract may be terminated by the client within five (5) business days of signing the contract
without incurring any advisory fees or penalty. After signing, Ultra Advisory Group or our clients can terminate our
agreement upon receipt of written notice to the other party.
When an agreement is terminated, we will refund any pre-paid, unearned fees based on the number of days remaining
in the quarter after termination. Refunds will be made within 30 days of the effective date of termination.
You will be responsible for paying all fees including full quarterly custodial administrative fees, account closure fees,
mutual fund fees and all trading costs due to the termination. If there is insufficient cash in the account, the liquidation
of some securities may be used to pay the fees. Prior to termination of an agreement, we can provide a good faith
estimate of these fees.
5e: Other Investment Compensation
Ultra Advisory Group does not accept commission for the sale of securities or other investment products, including
asset-based sales charges or service fees from the sale of mutual funds.
Item 6 – Performance-Based Fees and Side-by-Side Management
Ultra Advisory Group does not charge advisory fees on the performance of funds or securities in your account and does
not participate in side by side management.
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Item 7 – Types of Clients
Ultra Advisory Group generally provides asset management and financial planning services to the following types of
clients:
Individuals
Trusts
Estates
High-Net-Worth Individuals
Pension and Profit Sharing Plans
Charitable Organizations
Corporations
Individuals
Minimum Account Size: Ultra Advisory Group does not have an account minimum.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
8a: Analysis
In determining the recommendations to give to you, we first gather and consider information regarding several factors
including our client’s:
Current financial situation;
Investment goals and objectives;
Current and long-term needs;
Tolerance and appetite for risk;
Level of investment knowledge.
•
•
•
•
•
Ultra Advisory Group uses multiple sources of information to obtain analysis and strategies. They include sources such
as financial newspapers, financial magazines, research prepared by others, corporate rating services, prospectuses,
company press releases, annual reports and filings with the SEC.
Ultra Advisory Group’s methods of analysis include Fundamental analysis, Modern portfolio theory and Cyclical Analysis,
Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or
the analysis of management or competitive advantages.
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.
Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security.
8b: Investment Strategies
Asset Allocation
Ultra Advisory Group recommends a mix of asset classes for your portfolio based on an assessment of your long- term
financial objectives. Where appropriate, we will recommend an allocation to high-quality, short-term and intermediate
term bonds (within a broadly diversified index or asset class mutual fund) to reduce overall portfolio risk, generate a
more predictable cash flow (interest income), facilitate portfolio rebalancing, and provide a hedge against inflation.
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If your objective is a higher annual expected return and you are willing to accept a higher degree of risk, we will
recommend a portfolio with greater weighting to stocks in general and small company and value stocks specifically
(using index or asset class mutual funds). Recommended stock allocations will generally be globally diversified among
the U.S., foreign developed markets, and emerging markets. In certain circumstances, we may include traded REITs in
limited percentages. Our recommended asset allocation is not influenced by current market conditions. This asset
allocation is altered only when your long-term investment objectives have changed.
Asset Allocation is based on the principle that different assets perform differently in different market and economic
conditions. It is difficult to predict how any particular asset class will perform in any given year.
Diversification is a strategy for managing risk. Diversification does not ensure a profit or protect against a loss in a
declining market. Asset Allocation is unlikely to generate the greatest returns since not all asset classes will do equally
well.
Rebalancing
Asset allocations for your portfolio will change as financial markets rise and fall and the specific assets of different parts
of your portfolio change. This creates the opportunity to selectively rebalance your portfolio in order to bring asset
class percentages back to your policy targets. Asset classes that have risen beyond predetermined limits are sold by an
amount that brings the allocation back in line with policy targets, and those that have fallen in value are purchased in
the same way. This is a method of buying low and selling high that is not based on trying to predict the direction of
markets or asset returns.
This rebalancing has the effect of enhancing portfolio returns while maintaining the agreed-upon risk. In order to limit
rebalancing transactions and the costs associated with buying and selling mutual funds through the chosen custodian,
Ultra Advisory Group has pre-determined ranges in which allocations may vary and at which rebalancing is initiated.
Specific Investments
While we generally select ETFs, mutual funds or similar securities, we may at times select individual securities or build
individual stock and bond portfolios for our clients. In these cases, Ultra Advisory Group examines each securities’
management, financial condition, and market position and ensures that any purchases of individual securities work
towards the client’s portfolio goals, investment horizons and exposure to risk. Individual stocks present potential risks
as prices of individual securities can move up or down due to general economic conditions, industry specific conditions,
government regulations or corporate management, among other factors.
8c: Risk of Loss
All investments include a risk of loss that clients should be prepared to bear. Performance of any investment is not
guaranteed. We use our best efforts and expertise to manage your assets. However, we cannot guarantee any level of
performance or that you will not experience financial loss.
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.
Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same
expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated
by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact
trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on
individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second
portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio
exists which has better expected returns.
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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 two-fold: 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.
Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed
below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or
any other government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual
funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower
risk) or stock “equity” nature.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in
ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of
concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility
of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic
shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large
sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals,
(2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in
the attitude of speculators and investors.
Equity investments generally refers to buying shares of stocks in return for receiving a future payment of dividends
and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific
situations for each company, industry conditions and the general economic environments.
Options strategies are complex investments and entail risks that vary with the type of options strategy employed.
Buying Options:
When you buy an option, you pay a premium for the right to buy or sell an underlying asset (like a stock, commodity, or
currency) at a specific price (strike price) before a certain date (expiration date). The risk in buying an option is that if
the underlying asset doesn't move in the direction you anticipated or if it doesn't move enough, you could lose the
premium you paid for the option. In other words, if the option expires out of the money (meaning the underlying asset's
price did not reach the strike price before the expiration date), the buyer loses their premium.
Selling Options:
When you sell an option, you receive a premium from the buyer in exchange for the obligation to buy or sell an
underlying asset at a specific price before a certain date. The risk in selling an option is that if the underlying asset moves
in the opposite direction of what you anticipated, you could lose more money than the premium you received. In other
words, if the option expires in the money (meaning the underlying asset's price reaches the strike price before the
expiration date), the seller could be obligated to buy or sell the underlying asset at a loss.
In summary, the risks of buying or selling options involve potential losses if the underlying asset does not move in the
anticipated direction or if it moves too much in the opposite direction.
Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This
type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment
grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may
be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income
securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually
more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and
credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation
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linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk
of losing share price value, albeit rather minimal.
Item 9 – Disciplinary Information
9a: Civil or Criminal Actions
Ultra Advisory Group and its managers have never been found guilty, convicted or pleaded to a criminal or civil action in
a domestic, foreign or military court.
9b: Administrative Enforcement Proceedings
Ultra Advisory Group and its managers have never been found by the SEC, any other state or federal agency or any
foreign regulatory agency to have caused loss of the ability of an investment-related business to do business or been
sanctioned, barred or limited in investment-related activities.
9c: Self-Regulatory Organization Enforcement Proceedings
Ultra Advisory Group and its managers have never been found by a self-regulatory agency to have caused loss of the
ability of an investment-related business to do business. Additionally, Ultra Advisory Group and its managers have never
been found in violation of self-regulatory agencies rules such that they were barred, suspended, limited in advisory
functions or fined.
Item 10 – Other Financial Industry Activities and Affiliations
10a: Broker Dealers and Registered Representatives
Ultra Advisory Group is not registered as a broker-dealer and our employees are not registered representatives of any
broker-dealer.
10b: Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor
Neither Ultra Advisory Group nor our employees hold any of the above registrations.
10c: Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests
The principal business of Ultra Advisory Group is that of a registered investment advisor and provider of financial
planning services. Bryan Gould is a licensed insurance agent. When acting in the capacity of an insurance agent, Bryan
receives the usual and customary commissions or fees associated with the insurance products that the client
purchases. Receiving commissions on insurance products creates a conflict of interest. To mitigate this conflict, clients
are informed of the potential compensation received, and the client is reminded that they are free to select another
insurance broker for implementation of advisor's insurance recommendations, and all recommendations are made
in accordance with the fiduciary duty owed to our clients
10d: Selection of Other Advisors and How this Advisor is Compensated for those Selections
Ultra Advisory Group is not paid for the selection of other advisors, asset managers or portfolio managers.
Ultra Advisory Group may enter directly into sub-advisory relationships with independent registered investment
advisory firms (“sub-advisors”) on behalf of its clients as part of our discretionary services. We do not receive any
additional compensation for selecting a sub-advisor. Prior to entering into a relationship, Ultra Advisory Group performs
a due diligence review of the sub-advisor. This review includes, but is not limited to, the review of regulatory filings,
investment offerings, and the performance of the strategies considered. When a strategy offered through a subadvisor
is appropriate for a client of Ultra Advisory Group, the client will be given the subadvisor’s Form ADV Part 2A, Privacy
Notice, and any other information that may be relevant or informative to the client.
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Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
11a: Code of Ethics Description
We have adopted a Code of Ethics to which all investment advisor representatives and employees are bound to adhere.
The key component of our Code of Ethics states that Ultra Advisory Group and its investment advisor representatives
and employees shall always:
Act with integrity, competence, dignity, and ethics when dealing with the public, clients, prospects, employers,
and employees.
Exercise its authority and responsibility for the benefit and interest of its clients first and to refrain from having
outside interests that conflict with the interests of its clients. Ultra Advisory Group must avoid any
circumstances that might adversely affect or appear to affect its duty of complete loyalty to its clients.
Refrain from disclosing any nonpublic personal information about a client to any nonaffiliated third-party unless
the client expressly gives permission to Ultra Advisory Group to do so. All client information will otherwise be
treated as confidential.
Maintain the physical security of nonpublic information, including information stored on computers.
This Code of Ethics is in place to guide the personal conduct of our team and embodies our fiduciary duties and
responsibilities to you and sets forth our practice of supervising the personal securities transactions of employees with
prior or concurrent access to client trade information. A copy of the Ultra Advisory Group Code of Ethics is available,
free of charge, upon request.
11b, c & d: Participation or Interest in Client Transactions
Ultra Advisory Group, or its employees, may buy and sell some of the same securities for our own accounts that we buy
and sell for our clients. We will always buy or sell from our clients’ accounts before we buy or sell from our accounts. In
some cases, Ultra Advisory Group, or its employees, may buy or sell securities for our own accounts and not for clients’
accounts, as it may not meet the objectives or plans for the client. There are possible conflicts of interest, which our
Code of Ethics addresses. We will always evaluate our activity from the view of our clients to ensure that any and all
required disclosures are made. For example, we will disclose anything that would cause you to be unfairly influenced to
make any decision regarding actions or inactions in your account.
Ultra Advisory Group does not buy or sell between Ultra Advisory Group, our employees or our clients’ accounts.
Ultra Advisory Group does not recommend securities to advisory clients, nor buy or sell securities for advisory client
accounts in which Ultra Advisory Group or a related person has a material financial interest.
Item 12 – Brokerage Practices
12a: Selecting Brokerage Firms
The Custodian and Brokers We Use
Ultra Advisory Group does not maintain custody of your assets that we manage. Your assets must be maintained in an
account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Fidelity
Investments or Charles Schwab & Co., Inc. (Schwab), both FINRA-registered broker-dealers, and members of SIPC, as
qualified custodians. Ultra Advisory Group is independently owned and operated and not affiliated with Fidelity or
Schwab. Both Fidelity and Schwab will hold your assets in a brokerage account and buy and sell securities when
instructed to do so. While we recommend that you use Fidelity or Schwab as custodian/broker, you will decide whether
to do so and open your account with Fidelity or Schwab by entering into an account agreement directly with them. If
you do not wish to place your assets with Fidelity or Schwab, then we cannot manage your account. Even though your
account is maintained at Fidelity or Schwab, we can still use other brokers to execute trades for your account, as
described under Your Custody and Brokerage Costs below. Ultra Advisory Group does not receive any client referrals
from Schwab or Fidelity.
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How We Select Brokers/Custodians
We seek to select a custodian/broker who will hold your assets and execute transactions on terms that are overall most
advantageous when compared to other available providers and their services. We consider a wide range of factors,
including, among others, these:
o
o
o
combination of transaction execution services along with asset custody services (generally without a
separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for your account)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill
payment, etc.)
o breadth of investment products made available (stocks, bonds, mutual funds, exchange traded funds (ETFs),
etc.)
o availability of investment research and tools that assist us in making investment decisions o quality of
o
o
services
competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and
willingness to negotiate them
reputation, financial strength and stability of the provider or their prior service to us and our other clients o
availability of other products and services that benefit us, as discussed below (see “Products and Services
Available to Us from Custodians”)
To avoid creating a possible conflict of interest in recommending broker-dealers, we have established the following
restrictions in order to ensure our fiduciary responsibilities:
1. Ultra Advisory Group adheres to our Code of Ethics as outlined in Item 11 above.
2. If Ultra Advisory Group receives separate compensation for transactions, we will fully disclose them.
3. Ultra Advisory Group emphasizes the unrestricted right of you to select and choose your own broker or
dealer.
4. Ultra Advisory Group will always act in accordance with all applicable federal and state regulations
governing registered investment advisory practices.
12.b: Sales Aggregation
Ultra Advisory Group does not engage in block trades.
Item 13 – Review of Accounts
13a: Periodic Reviews
Accounts are managed and reviewed by Bryan Gould, CCO or his designee. The frequency of reviews is determined
based on your investment objectives, but no less than annually. Accounts are reviewed to determine if the positions,
transactions and strategies are consistent with the Client’s stated investment objective(s) and whether any rebalancing
or adjustments may be necessary.
Depending on the type of financial planning service requested, we may meet on a regular basis with you to discuss any
potential changes to your financial plan.
13b: Review Triggers
More frequent reviews are triggered by a change in your investment objectives; tax considerations; large deposits or
withdrawals; large sales or purchases; loss of confidence in corporate management; or, changes in economic climate.
13c: Regular Reports
All investment advisory clients receive reports as needed on representative investments recommended specifically by Ultra
Advisory Group. Reports are generated through Orion based on custodian data. Orion is a provider of integrated, web-
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based portfolio rebalancing, performance reporting and customer relationship management software for independent
advisors. Performance Reporting reports may contain such items as: Performance Review, Summary by Account, Asset
Allocation, Security Performance, Realized Gains/Losses, Holdings, and Transactions that occurred during the period.
Custodian data is provided to Orion directly and reports are generated only using the custodian data.
Investment advisory clients also receive standard account statements from the custodian of their accounts on at least a
quarterly basis.
Item 14 – Client Referrals and Other Compensation
14a: Economic Benefits Provided by Third Parties for Advice Rendered to Clients
We receive an economic benefit from Fidelity in the form of the support products and services it makes available to us
and other independent investment advisors that have their clients maintain accounts at Fidelity. We receive similar
benefits from Schwab. These products and services, how they benefit us, and the related conflicts of interest are
described above (see Item 12 – Brokerage Practices). The availability to us of Fidelity’s and Schwab’s products and
services is not based on us giving particular investment advice, such as buying particular securities for our clients.
Ultra Advisory Group does not receive economic benefits from third parties for the advice we render to our clients. As
disclosed in Item 12 above, broker-dealers may provide services, tools or other non-financial benefits to us as a benefit
for using the broker-dealer’s services. However, we endeavor at all times to put the interests of our clients first. You
should be aware, however, that the receipt of benefits can create a potential conflict of interest by influencing our choice
of broker-dealer.
14b: Compensation to Non-Advisory Personnel for Client Referrals
Ultra Advisory Group does not directly or indirectly compensate any person for client referrals.
Item 15 – Custody
Ultra Advisory Group clients’ accounts are held by a qualified custodian, as designated by the client in writing, and other
than to withdraw advisory fees, Ultra Advisory Group shall have no liability to the client for any loss or other harm to
any property in the account. This includes harm to any property in the account resulting from the insolvency of the
custodian or any unauthorized acts of the agents or employees of the custodian and whether or not the full amount or
such loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance which may be
carried by the custodian. The client understands that SIPC provides only limited protection for the loss of property held
by a broker-dealer.
Ultra Advisory Group owes the client a fiduciary duty to put the client’s interest first which includes, but is not limited to, a duty
of care, of loyalty, and utmost good faith.
Custodial statements will include fees charged by Ultra Advisory Group.
Item 16 – Investment Discretion
Ultra Advisory Group asks our clients to give us discretionary authority to execute transactions without our client’s prior
approval. These transactions may include the purchase and selling of securities, arranging for payments or generally
acting on behalf of our clients in most matters necessary to the handling of the account. This includes the buying or
selling of securities, the rebalancing and selection of portfolios, the selection of portfolio managers or subadvisors or
the disbursement of funds to the client as requested or arranged. Discretionary authority is granted once an election is
made on the Investment Advisory Agreement and the agreement is signed by the client. In cases where we are not given
discretion, we must receive permission from the client to make any trades on a non-discretionary basis.
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You may make requests or make suggestions regarding the investments made in your portfolio. Restrictions on trading
which, in our opinion, are not in your best interest cannot be honored and if forced may result in the termination of our
agreement.
Item 17 – Voting Client Securities
The clients of Ultra Advisory Group retain the authority to proxy vote. You should ensure that proxy ballots are mailed
directly to you by selecting this option on your custodial application forms. You are welcome to delegate said proxy
voting authority to a third-party representative (non-advisory personnel) by filing the appropriate custodial form. Ultra
Advisory Group will not accept authority to vote client proxies. This policy is set forth in Ultra Advisory Group’s standard
advisory agreements. Proxy material will be sent from the transfer agent and in rare cases could come from Schwab or
Fidelity.
Should Ultra Advisory Group inadvertently receive proxy information for a security held in clients' accounts, it would
immediately forward such information on to clients but will not take any further action with respect to the voting of
such proxy. Upon termination of the advisory relationship, Ultra Advisory Group will make a good faith and reasonable
attempt to forward proxy information inadvertently received on behalf of clients to the forwarding address provided by
clients. Clients may contact Ultra Advisory Group for advice or information about a particular proxy vote; however, Ultra
Advisory Group shall not be deemed to have proxy voting authority solely as a result of providing such advice to clients.
Item 18 – Financial Information
18a: Balance Sheet
Ultra Advisory Group does not solicit prepayment of more than $1200 in fees per client six (6) months or more in
advance.
18b: Financial Conditions
Ultra Advisory Group has no financial issues that could impair our ability to carry out our fiduciary duty to our clients.
18c: Bankruptcy Petition
Ultra Advisory Group has never been the subject of a bankruptcy petition.
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