Overview
- Headquarters
- Columbus, OH
- Average Client Assets
- $3.4 million
- Minimum Account Size
- $200,000
- SEC CRD Number
- 108830
Fee Structure
Primary Fee Schedule (VAWTER FINANCIAL ADV PART 2A ANNUAL AMENDMENT V.03.27.26)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $5,000,000 | 0.50% |
| $5,000,001 | $10,000,000 | 0.35% |
| $10,000,001 | $25,000,000 | 0.25% |
| $25,000,001 | and above | Negotiable |
Minimum Annual Fee: $5,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $30,000 | 0.60% |
| $10 million | $47,500 | 0.48% |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- HNW Share of Firm Assets
- 88.40%
- Total Client Accounts
- 1,155
- Discretionary Accounts
- 1,155
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Regulatory Filings
Additional Brochure: VAWTER FINANCIAL ADV PART 2A ANNUAL AMENDMENT V.03.27.26 (2026-03-27)
View Document Text
Part 2A of Form ADV: Firm Brochure
Item 1 Cover Page
March 27, 2026
1161 Bethel Road, Suite 304
Columbus, OH 43220
Phone: 614-451-1002
Fax: 614-538-2812
Firm Contact: Jacqueline Washburn
info@vawterfinancial.com
www.vawterfinancial.com
This brochure provides information about the qualifications and business practices of Vawter
Financial, Ltd. If clients have any questions about the contents of this brochure, please contact us at
(614) 451-1002 or info@vawterfinancial.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 Vawter Financial, Ltd. is also available on the
SEC’s website at www.adviserinfo.sec.gov by searching CRD #108830.
Please note that the use of the term “registered investment advisor” and description of Vawter
Financial, Ltd. 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 Vawter Financial,
Ltd.’s associates who advise clients, for more information on the qualifications of Vawter Financial,
Ltd. and our employees.
i
Item 2 Material Changes
Vawter Financial, Ltd. (“VF”) is required to advise you of any material changes to the Firm Brochure
(“Brochure”) from our last annual update. As of our last annual amendment filing of 03/28/2025, our
firm has the following material changes to disclose:
ii
Item 3 Table of Contents
Item 1 Cover Page
i
Item 2 Material Changes
ii
Item 3 Table of Contents
iii
Item 4 Advisory Business
4
Item 5 Fees and Compensation
5
Item 6 Performance-Based Fees and Side-By-Side Management
7
Item 7 Types of Clients
7
Item 8
Investment Strategies, Methods of Analysis, and Risk of Loss
7
Item 9 Disciplinary Information
8
Item 10 Other Financial Industry Activities and Affiliations
8
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
9
Item 12 Brokerage Practices
9
Item 13 Review of Accounts
11
Item 14 Client Referrals and Other Compensation
11
Item 15 Custody
12
Item 16 Investment Discretion
12
Item 17 Voting Client Securities
13
Item 18 Financial Information
13
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Item 4 Advisory Business
About Vawter Financial, Ltd. (VF)
VF provides fee-only comprehensive financial planning and investment management services to our
clients to help them achieve their unique personal and business financial objectives. Our firm is
solely owned by Gary Vawter, William Whitaker & Jacqueline Washburn.
Wealth Advisory Service
The Wealth Advisory service that we provide is tailored to the individual needs of our clients. We
understand that each client’s goals are unique, as are the various factors of their personal and
professional lives on which their financial plan and investment portfolio is built. Our plans, strategies,
and recommendations are adaptive to the changes in our clients’ goals, priorities, and financial
situations.
As part of our Wealth Advisory service, clients receive asset management included with financial
planning services. This service is designed to assist clients in meeting their financial goals through
the use of a financial plan or consultation. VF conducts client meetings and broad-based analysis of a
client’s financial situation. VF makes use of current and historical financial information to understand
a client’s current financial situation, existing resources, financial and personal goals, attitudes,
investment objectives, and tolerance for risk. 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. If necessary, a portfolio is rebalanced based
upon market performance and the client’s individual needs, stated goals and objectives.
VF provides a written analysis and recommendations for the planning or consulting aspects of this
service. The financial plan or consultation may encompass one or more of the following areas:
Investment Planning, Tax Planning, Retirement Planning, Estate Planning, Charitable Planning,
Education Planning, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation,
Business and Personal Financial Planning. The specific scope of services to be provided can only be
determined after a thorough and ongoing review of the documentation provided by the client. VF will
assist with the implementation of the financial plan or consultation. However, VF will not provide
legal advice or tax preparation services. Clients are urged to work closely with their attorney and/or
accountant in implementing strategies in those areas, and VF will be happy to work with the client’s
attorney and/or accountant concerning these matters.
VF will provide ongoing monitoring of the client’s financial circumstances and provide continued
advice to help them reach the goals we have discussed. VF will also provide advice concerning
changes in these goals or in the client’s circumstances. Each element of the client’s plan is reviewed
at least annually, including estate plans, tax planning, insurance, cash flow, goal setting and financial
advice in other areas.
VF will recommend and manage an agreed-upon portfolio relative to the client’s risk tolerance and
time parameters. VF will make investment decisions for the client’s portfolio according to the client’s
investment objectives and financial circumstances. Clients are required to promptly inform VF if any
material changes occur in their circumstances. Clients must also consult with VF at least annually to
provide updated information, if any, about their financial circumstances and financial objectives.
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Tailoring of Advisory Services
Our firm offers individualized investment advice to our Wealth Advisory clients.
Each Wealth Advisory 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.
Wrap Fee Program
We do not offer wrap fee programs.
Assets Under Management
As of December 31, 2025, our assets under management totaled approximately $394,368,793. These
assets are all managed on a discretionary basis.
Item 5 Fees and Compensation
How We Are Compensated
Wealth Advisory Service:
VF charges on a flat fee or a percentage of assets under management for our Wealth Advisory service.
We will provide clients with the option to select whether they wish to be charged on a flat fee or fee
based on the percentage of assets under management for our Wealth Advisory services. Annualized
fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the
last day of the previous quarter. Our firm bills on cash unless indicated otherwise in writing. The fee
will be based on client complexity as well as the total assets the client has custodied with our
Custodian and will be renegotiated at the end of every odd year at a minimum (2019, 2021, etc.). The
fee for our service is negotiable and will be payable in advance on a quarterly basis depending on
what the client selects in the signed Client Care Agreement. We will provide clients with the option
to have their fee debited from their portfolio or the client may choose to be invoiced at the beginning
of each quarter. VF does not receive fees, commissions or other remuneration of any kind from
advisors, originators, sponsors, or distributors of investments or products recommended to clients.
Our only source of income is from the client.
Option 1 – Flat Fee
The fee will be based on client complexity and will have an annual inflation adjustment/increase of
3% thereafter. VF will review client fee levels at least every two years or when there has been a
significant increase or decrease in client complexity. Any fee adjustment, outside of the 3% annual
inflation increase, will be presented for the client’s approval before a change is made. The fee for our
service is negotiable and will be payable in advance on a quarterly basis. This fee may be debited
from your Portfolio, as your signature on the Client Care Agreement authorizes this practice, or you
may choose to be invoiced at the beginning of each quarter. The fee below is for comprehensive
planning and includes all accounts that are linked, and regularly updated, on your VF personal
website. VF does not accept nor receive fees, commissions or other remuneration of any kind from
advisors, originators, sponsors, or distributors of investments or products recommended to you. Our
only source of income is from you directly.
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Our flat fee option has an annual minimum of $5,000 and a maximum of $50,000 depending on client
complexity and the resources required.
Option 2 – Tiered Fee
Assets Under Management
$0 to $1,000,000
$1,000,001 to $5,000,000
$5,000,001 to $10,000,000
$10,000,001 to $25,000,000
Over $25,000,000
Annual Fee
1.00%
0.50%
0.35%
0.25%
Negotiable
Quarterly Fee
0.250%
0.125%
0.0875%
0.0625%
Negotiable
Other Types of Fees & Expenses
Some investment accounts may be subject to annual maintenance fees charged by the account
custodian, usually on or around the anniversary of the date the account was opened. Clients have the
option of having these fees drawn from the associated account or paying by check.
Processing fees and recordkeeping fees may apply to some account types, such as individual 401(k)s.
If applicable, these fees will be disclosed to the client in advance of their agreement to open/own
these types of accounts. These fees are payable to the service provider, not VF.
Clients will incur transaction charges for trades executed in their accounts. These transaction fees
are separate from our fees and will be disclosed by the firm through which the trades are executed.
Charles Schwab & Co. Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and
exchange traded funds.
Also, clients will pay the following separately incurred expenses: charges imposed directly by a
mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus
(i.e., fund management fees and other fund expenses).
VF does not receive any portion of the other types of fees and expenses described in this section.
Direct Deduction of Advisory Fees
In cases where VF directly deducts advisory fees from Client accounts, Clients understand the
following:
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) Our firm sends a copy of our invoice to the client upon their request.
Client Care Agreement Termination
VF’s Client Care Agreement may not be modified or amended except in writing and signed by both
the client and VF. Either party may terminate our Client Care Agreement within five (5) business days
as of the date of acceptance without penalty. After the five-day period, our Client Care Agreement
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Vawter Financial, Ltd.
may be terminated by either party upon thirty (30) days written notice to the other party. VF shall
be paid its fee through the effective date of the termination, and any unearned, prepaid fees will be
refunded to the client.
The death, disability or incompetency of a client will not terminate or change the terms of our
advisory agreement. In the event of the client’s death, disability or incompetency, VF will assist the
client’s executor, guardian, attorney-in-fact or other authorized representative. The client’s
authorized representative may terminate our Client Care Agreement by giving written notice with
the termination becoming effective upon receipt. We shall be paid our fee through the effective date
of the termination, and any unearned, prepaid fees will be refunded. All actions taken by VF
hereunder, either before or after the death or incapacity of the client, but before receipt by VF of
information of such death or incapacity, shall be binding upon the client and the client’s legal
representatives who shall hold VF harmless hereunder from all liability arising from such action.
Item 6 Performance-Based Fees and Side-By-Side Management
VF does not charge performance-based fees.
Item 7 Types of Clients
We typically provide investment advice to individuals, trusts, and small business owners, including
those with 401(k)s or pension plans. In some cases, we may refer a small business owner with an
employer plan to an unaffiliated plan servicing representative to manage the plan and its assets. We
receive no additional compensation from this arrangement.
The minimum Wealth Advisory fee for clients who sign an advisory agreement is $5,000. The
minimum value to open and maintain an investment account is $200,000 and/or subject to the
requirements of the account custodian.
Item 8 Investment Strategies, Methods of Analysis, and Risk of Loss
Strategic Asset Allocation
We recommend a target equity-to-fixed-income asset mix based on each client’s individual financial
situation and objectives. We suggest the periodic rebalancing of a client’s assets in order to maintain
a range centered around the target mix as well as the risk potential, an approach known as “strategic
asset allocation”. When substantial growth in one category leads to overexposure relative to others,
investments in this category should be trimmed back (profits taken) and reallocated to where growth
has not been as strong. This often results in a “selling high and buying low” approach to
investing. Behavioral finance studies tell us people would rather do the opposite. We are a buy-hold
investment firm preferring to use the Warren Buffett approach to investing – “be greedy when others
are fearful, and fearful when others are greedy”.
Margin Transactions: Our firm may purchase securities 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 securities without selling other holdings. Margin accounts
and transactions are risky and not necessarily appropriate for every client.
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Vawter Financial, Ltd.
The potential risks associated with these transactions are (1) You can lose more funds than are
deposited into the margin account; (2) the forced sale of securities or other assets in your account;
(3) the sale of securities or other assets without contacting you; (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; and
(5) custodians charge interest on margin balances which will reduce your returns over time.
Diversification
While most all of our clients are interested in having their wealth grow over time, often their primary
objective is to not lose what they have accumulated. Investing in any one particular type of security
increases the potential for hitting a “home run”, but it also brings in more chances to “strike out”. We
strongly recommend a diversified financial portfolio for all of our clients to help reduce risk. It is
important to understand, however, that diversification alone does not necessarily prevent the loss of
principal.
Fund Analysis
When choosing investments to recommend to our clients, we use data from outside sources to
compare investment expenses, performance as compared to others within the same category
(typically over the last 1-, 3-, and 5-year periods), total returns (also typically over the last 1-, 3-, and
5-year periods) and standard deviation, among other factors. We continue to monitor the
investments held by our clients during periodic portfolio reviews.
Risk of Loss
Investing in any securities involves a risk of loss that clients should be prepared to bear. We impress
upon clients that there are no “risk-free” investments. Even FDIC-insured investments, after
considering taxes and inflation, can cause a person to lose purchasing power over time. This in turn
can jeopardize their standard of living while in their retirement years. We believe a prudent level of
risk is necessary to combat the loss of purchasing power and other uncertainties when pursuing their
goals.
Item 9 Disciplinary Information
VF and its management personnel have not been the subject of any legal or disciplinary events by a
criminal or civil court, regulatory agency, or self-regulatory organization.
Item 10 Other Financial Industry Activities and Affiliations
In the process of providing Wealth Advisory services to our fee-based clients, VF may recommend
services that we feel are beneficial to the client in reaching their goals, such as tax and estate planning.
In order to work in the best interests of the client, we strive to develop relationships with other
professionals who adhere to the same principles that VF adopts. VF does not receive any direct or
indirect benefits from these introductions.
Accountants/Tax Preparers
For our clients looking for tax preparation services or consultations, we may refer our clients to
Nerone & Associates, Inc. With the approval of our mutual clients, we communicate with these and
other tax preparers on a regular basis and provide them with input on the clients’ account
transactions and copies of tax documents related to their accounts managed by VF. VF receives no
fees when our clients use either of these tax services.
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Attorneys
For our clients looking for estate document preparation services or consultations, we may refer our
clients to David Onega at Bailey Cavalieri, LLC. With the approval of our mutual clients, we will
communicate this and other attorneys on a regular basis and provide them with information to
prepare their legal documents. VF receives no fees when our clients use this provider.
There may be other attorneys and CPAs to whom we would refer our clients to as well, depending on
the client’s needs. None of the firms above compensate VF for our referrals.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
VF has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code
of Ethics applies to all persons associated with VF (our “Supervised Persons”). The Code of Ethics was
developed to provide general ethical guidelines and specific instructions regarding our duties to our
clients. VF and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each
Client. It is the obligation of VF’s associates to adhere not only to the specific provisions of the Code,
but also to the general principles that guide the Code. The Code of Ethics covers a range of topics that
address ethics and conflicts of interest. To request a copy of our Code of Ethics, please contact us at
614-451-1002.
Personal Trading with Material Interest
VF does not purchase or sell the same securities that it has a material interest in. VF does not act as
principal in any transactions. VF will not engage in any principal transactions (i.e., trade of any
security from or to the Firm’s own account) or cross transactions with other Client accounts (i.e.,
purchase of a security into one Client account from another Client’s account[s]). In addition, VF does
not act as the general partner of a fund or advise an investment company. VF does not have a material
interest in any securities traded in Client accounts.
Personal Trading in Same Securities as Clients
VF allows our employees to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities we recommend (purchase or sell) to you
presents a potential conflict of interest that, as fiduciaries, we must disclose to you and mitigate
through policies and procedures. The fiduciary duty to act in the best interest of its clients can
potentially be violated if personal trades are made with more advantageous terms than Client trades,
or by trading based on material non-public information.
Item 12 Brokerage Practices
Selecting Brokerage Firms
Clients are free to use any service provider to execute their transactions, and they are responsible for
negotiating any terms or arrangements for their account. Our firm will not be obligated to conduct
due diligence of the client’s selected service provider, seek better execution services or prices from
any provider, or aggregate client transactions for trade execution. Since your transactions are
completed with a service provider of your choice, you may potentially pay more for your transaction
or experience wider price spreads. Not all advisers require their clients to direct brokerage.
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Vawter Financial, Ltd.
While Clients are free to select their brokerage, VF recommends discount brokerage firms and trust
companies (qualified custodians) to clients. VF seeks competitive rates but may not necessarily
obtain the lowest possible commission rates for client transactions. Factors which VF considers in
recommending a broker-dealer/custodian to clients include their respective financial strength,
reputation, execution, pricing, research and service.
Clients may pay commissions that are higher than another qualified financial institution might charge
to effect the same transaction where VF determines that the charges are reasonable in relation to the
value of the brokerage and research services received. In seeking best execution, the determinative
factor is not the lowest possible cost, but whether the transaction represents the best qualitative
execution, taking into consideration the full range of a financial institution’s services, including
among others, the value of research provided, execution capability, commission rates and
responsiveness VF does not receive fees or commissions from any arrangement with any broker-
dealer or any other custodian.
Soft Dollars
Although not a material consideration when determining whether to recommend that a client
utilize the services of a particular broker-dealer or custodian, VF receives from a custodian
without cost (and/or at a discount) support services and/or products which assist us to better
monitor and service client accounts maintained at such institutions. Included within the support
services that may be obtained by us may be investment-related research, pricing information and
market data, software and other technology that provide access to client account data,
compliance and/or practice management-related publications, discounted and/or gratis consulting
services, discounted and/or gratis attendance at conferences, meetings, and other educational
and/or social events, marketing support, computer hardware and/or software, and/or other
products used by VF in furtherance of its investment supervisory business operations. Clients do
not pay more for investment transactions affected and/or assets maintained at a recommended
custodian. There is no corresponding commitment made by us to any recommended custodian, or
any other entity to invest any specific amount or percentage of client assets in any specific
mutual funds, securities, or other investment products as result of the above arrangement.
Certain of the support services and/or products that may be received assist VF in managing and
administering client accounts. Others do not directly provide such assistance but rather assist us to
manage and further develop our business enterprise. All the benefits and services received fall with the
safe harbor of Section 28(e) of the Securities Exchange Act.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for their account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, VF will request that direct plan
sponsors provide VF with a letter documenting that this arrangement will be for the exclusive benefit
of the plan.
Aggregation of Purchase or Sale
VF performs 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
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same security for numerous accounts served by VF, 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 we believe that
doing so will be in the best interest of the affected 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, we attempt 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
Portfolio and Planning Reviews
In-depth reviews of a client’s investment portfolio and financial plans are completed at least
annually; the scope depends on the complexity of a client’s financial position. Our main emphasis is
to ensure that a client’s portfolio and the strategies now in place are consistent with their stated
goals. During our periodic reviews, we may discuss items in the following areas: retirement planning,
income tax planning, estate planning, insurance planning, college planning, debt management,
business planning, asset allocation and investment performance. Some review meetings are
scheduled to explain recent developments in the client’s portfolio and/or the financial markets. At
each meeting, the client is given a summary of their portfolio, including accounts and investment
holdings. Other reports which are prepared in-house or using financial planning software may also
be reviewed with the client, as needed.
Portfolio reviews are conducted by Gary Vawter, CFP®, MS, William Whitaker, CFP®, MS, Senior
Advisors of VF. VF does not provide hard copy reports unless asked to do so. Verbal reports take
place on at least an annual basis when clients are contacted. Clients have online access to their
accounts to check account values and performance at any time through the MyMoney portal and their
custodian.
Account Statements and Transaction Confirmations
All clients receive monthly or quarterly account statements and transaction confirmations directly
from the institution(s) having custody of their assets. These can be in hardcopy and/or electronic
formats based upon client preferences.
Item 14 Client Referrals and Other Compensation
Charles Schwab & Co. Inc.
Our firm may recommend Charles Schwab to clients for custody and brokerage services. There is no
direct link between our firm’s use of our custodian and the investment advice given to clients,
although we receive economic benefits through our participation 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 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
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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 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 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.
Referral Fees
VF does not pay referral fees to independent solicitors for the referral of their clients to VF in
accordance with Rule 206 (4)-3 of the Investment Advisers Act of 1940.
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 constructive custody because
clients’ consent to have their accounts directly debited for the payment of fees. All Clients’ accounts
are held at an independent qualified custodian. 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, our firm will send its own account statements to
clients upon their request. Clients are encouraged to raise any questions with us about the custody,
safety or security of their assets and our custodial recommendations.
VF is also deemed to have constructive custody resulting from the use of Standing Letters of
Authorization (“SLOA”) for money transfer between a client’s account and a third-party account as
designated by the client. The Firm follows the guidance set forth in the SEC No Action Letter of
February 21, 2017, and maintains records to avoid the surprise audit requirement in those accounts
that would otherwise be required of advisers with custody.
Item 16 Investment Discretion
As per VF’s advisory agreement, we manage investment accounts on a discretionary basis to buy, sell,
or otherwise trade securities or other investments in the client’s portfolio without discussing the
transaction with them in advance in accordance with the client’s discussed and agreed upon
investment objectives. The client also authorizes VF to take all necessary action to effect securities
transactions in their portfolio. A client accepts this arrangement by signing our advisory agreement.
If a client wishes to limit this discretionary authority in any way, they must submit a detailed letter
describing the limitations, and an amendment to the advisory agreement must be signed by the client
and the Investment Advisor Representative (IAR). VF will maintain discretionary authority until the
amendment is signed by all parties.
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Item 17 Voting Client Securities
VF 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 VF,
VF 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 may call, write or email us to discuss questions they may have about
particular proxy votes or other solicitations.
Item 18 Financial Information
We do not require or solicit pre-payment of more than $1200 in fees per client, six months or more
in advance. We do not have any financial condition that is reasonably likely to impair our ability to
meet contractual commitments to our clients.
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