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Yeomans Consulting Group, Inc.
d/b/a Your Retirement Coach
61 Atlanta Street SE
Marietta, Georgia 30060
Phone: 770-427-5227
Fax: 770-919-2076
www.YourRetirementCoach.com
May 29, 2025
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Yeomans
Consulting Group, Inc. If you have any questions about the contents of this brochure, please contact
us at 770-427-5227. 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 Yeomans Consulting Group, Inc. is also available on the SEC's website
at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Yeomans Consulting Group, Inc.
is 125573.
Yeomans Consulting Group, Inc. is a registered investment adviser. Registration with the United
States Securities and Exchange Commission or any state securities authority does not imply a certain
level of skill or training.
Item 2 Summary of Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the
adviser is required to notify you and provide you with a description of the material changes.
The material changes in this brochure since our last annual updating amendment dated February 27, 2025,
are described below. Material changes relate to the firm’s policies, practices or conflicts of interests.
• The firm has removed Roxane Sue Dimon. (Item 13)
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Item 3 Table of Contents
Item 2 Summary of Material Changes
Item 3 Table Of Contents
Item 4 Advisory Business
Item 5 Fees and Compensation
Item 6 Performance-Based Fees and Side-By-Side Management
Item 7 Types of Clients
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16 Investment Discretion
Item 17 Voting Client Securities
Item 18 Financial Information
Item 19 Requirements for State Registered Investment Advisers
Item 20 Additional Information
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Item 4 Advisory Business
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Description of Services and Fees
Yeomans Consulting Group, Inc. d/b/a Your Retirement Coach is a registered investment adviser based in
Marietta, Georgia. We are organized as a corporation under the laws of the State of Georgia. We have been
providing investment advisory services since 1995. Randall J. Yeomans and Nicholas B. Yeomans are our
principal owners. Currently, we offer the following investment advisory services which are personalized to
each individual client:
Investment Management Services
Selection of Other Advisers
Financial Planning and Consulting Services
Investment Consulting/Portfolio Monitoring Services
Consulting Services to Investment Advisers and Investment Adviser Representatives
Succession and Transition Planning for Business Owners
Pension Consulting Services
Asset Allocation Services
Annuity, Insurance, and Directly-Held Mutual Fund Consulting
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The following paragraphs describe our services and fees. Please refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we", "our" and "us" refer to Yeomans Consulting Group, Inc. and
the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you
may see the term Associated Person or Investment Adviser Representative throughout this brochure. As
used in this brochure, our Associated Persons or Investment Adviser Representatives are our firm's officers,
employees, and all individuals providing investment advice on behalf of our firm.
Investment Management Services
We offer discretionary and non-discretionary investment management services that are tailored to meet our
clients' needs and investment objectives. Once you have retained our firm for investment management
services, we will gather information about your financial situation and objectives, and assist you in
determining your investment goals, objectives, risk tolerance, and retirement plan time horizon . We will
then monitor your account on an ongoing basis. Where appropriate, we may provide you with
recommendations to change your investment management or allocation program in an effort to remain
consistent with your stated financial objectives.
Direct Asset Allocation Services through SEI Advisor Program
The SEI Asset Management Program is a program where our Investment Adviser Representatives ("IARs")
can make the SEI family of mutual funds available to our firm's clients. SEI is not an investment adviser in
this instance and does not have an investment adviser relationship with you. Although, SEI re-balances your
portfolio to maintain the proper asset allocation to each asset class in the percentages you chose, SEI does
not exercise discretion when providing these re-balancing services. SEI re-balances based on your written
instructions.
Our firm charges an advisory fee. SEI charges an expense ratio to the funds. All expense ratios are disclosed
in the prospectuses of the funds. SEI Trust Company, a subsidiary of SEI Investments Co., acts as the transfer
agent and custodian for your account. Our advisory fee is debited from your account by SEI Trust Company
on our behalf. SEI does not participate in our advisory fee.
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You will sign an advisory contract with our firm and account opening documentation with SEI. We provide
you with our Form ADV Part 2A and SEI provides a prospectus for the mutual funds utilized in your fee-
based account. As custodian, SEI Trust Company provides all reporting functions for your account, and
supplies you with at least a quarterly statement. SEI does not act in the capacity of an investment adviser to
you and therefore does not provide a solicitor's agreement, or their Form ADV Part 2. The fee schedule that
our firm charges for our advisory services in connection with the SEI Asset Management Program is included
in our ADV Part 2A and in the SEI Advisory Agreement.
Our firm's IARs also offer through SEI, the Mutual Fund Program ("SEI Funds") comprised exclusively of
mutual funds and the Managed Account Program ("Managed Account Assets") comprised of individual
securities to our clients. The SEI Funds and Managed Account Assets Programs are designed as follows:
SEI will have complete investment authority, with respect to the Managed Account Assets, in order
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We determine your risk profile and investment objectives. Your IAR determines your investment
objectives, investment time horizon, and risk profile by means of an interview and the completion of a
questionnaire.
2.
We will establish an asset allocation policy for you and you choose one of many mutual fund asset
allocation models. You may also purchase the individual mutual funds without choosing one of the asset
allocation models.
3.
The asset allocation models help you diversify among asset classes and styles. The investment
managers of the underlying mutual funds are selected by SEI. SEI utilizes institutional investment
management firms. The managers are monitored by SEI to ensure that their investment styles and
performance remain consistent with the objectives of the mutual funds.
4.
Your portfolio will be re-balanced. Re-balancing maintains the proper allocation to each asset class
in the model. Re-balancing occurs automatically if the underlying mutual funds deviate from the prescribed
quarterly allocation by greater than a 2% variance. For the tax-managed models, the variance is 3%. Re-
balancing occurs monthly with no transaction fees.
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to carry out the investment strategy chosen by your IAR on your behalf.
6.
You will receive report results. SEI Trust Company (a subsidiary of SEI Investments Company) acts
as the transfer agent and custodian for the investor's account. SEI Trust Company provides reporting
services including consolidated monthly statements, quarterly performance reports, and year-end tax
reports.
Market Value Breakpoints Maximum Annual Advisory Fee
$0 - $500,000
$500,001 - $1,000,000
$1,000,001 - $2,000,000
$2,000,001 - $3,000,000
Over $3,000,001
2.00%
1.75%
1.50%
1.25%
1.00%
SEI Trust Company will debit your account on a quarterly basis for the above-mentioned fees and charges.
The charges to the account will be on an arrears basis and will be remitted quarterly net of any applicable
account and performance reporting charges not charged to you. Upon written notification, either your IAR
or you may terminate the Agreement. Prorated fees will be charged based on the market value of your
account on the date notice is received.
You will receive statements from the SEI Trust Company indicating holdings. A quarterly report, indicating
market value, cash flows, gains and losses, asset allocation, and performance as it relates to market indices,
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is also available if you select that option. Annually, you will receive a tax report for your account.
If you open a Tax Controlled Program Investment Account, SEI will remain as the investment adviser on the
account, and your IAR on behalf of our firm will act in a solicitor capacity only and have you sign the
appropriate documentation.
SEI Asset Allocation Program
We participate in The SEI Asset Allocation Program, which is offered to high net worth individuals, defined
benefit plans, participant and non-participant directed defined contribution plans,
institutions,
endowments, and foundations.
With the SEI Asset Allocation Program, we serve as the investment adviser to the investor, and are
responsible for analyzing the investor's current financial situation, return expectations, risk tolerance, time
horizon, and asset class preference, pursuant to the Adviser's investment advisory agreement. Based upon
the investor's information, our firm and the investor select an investment strategy and choose from one of
many mutual fund asset allocation models, which may be provided by SEI Investments Management
Corporation ("SIMC"), or purchase the individual mutual funds to include customized portfolios designed by
our firm.
We will allocate the assets placed in the investor's account among the SEI Funds (a family of mutual funds
advised by SIMC) in accordance with the investment strategy, goal or model selected by the investor or
designed by our firm. The investor, through our firm, may adjust their asset allocation to help ensure that
the mix reflects the objectives of the chosen strategy. The investor may, at any time, impose reasonable
restrictions on the management of his/her account or choose a new investment strategy.
PC Models: In accordance with the investor's investment objectives, we may also allocate assets placed in
the investor's account among the SEI Funds through SEI's Private Client Models, which reflect SIMC's
institutional asset allocation models more aligned with individual investors' goals. SIMC expects to make
changes to the Private Client Models periodically to incorporate changes to the mutual fund asset allocations
underlying the models. Upon consent from us (on behalf of the investor), these asset allocation changes will
be made to the investor's accounts invested in the Private Client Models.
Custom Models: Yeomans Consulting Group Portfolios (Yeomans TM Defensive, TM Conservative, TM
Moderate Growth & Income, and TM Growth Plus / Yeomans Defensive, Conservative, Moderate Growth
& Income, and Growth Plus / Yeomans MAD, Yeomans Relative Strength, and Yeomans Sector Rotation). In
accordance with the investor's investment objectives, we may also allocate assets placed in the investor's
account among the SEI Funds and non-SEI Funds, ETFs, or Individual Stocks and Bonds through Yeomans
Custom Models which are aligned with individual investors' goals. We expect to make changes to the Custom
Portfolios periodically to incorporate changes to the asset allocations underlying the models on a
discretionary basis. Upon consent from us (on behalf of the investor), these discretionary asset allocation
changes will be made to the investor's accounts invested in the Yeomans Consulting Group, Inc. as Yeomans
Custom Models.
The SEI Funds are administered, distributed, and in some cases advised by SIMC or its affiliates for which it
is paid fees as disclosed in the SEI Funds' prospectuses. The prospectus(es) should be read carefully by all
investors before investing in the SEI Funds.
The applicable fees are the same as set forth under the Direct Asset Allocation Services through SEI Advisor
Program section above.
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Selection of Other Advisers
As part of our investment advisory services, we may recommend that you use the services of a third party
investment adviser ("TPMM") to manage your entire, or a portion of your, investment portfolio. We may
recommend TPMMs who offer timing services and asset allocation services. After gathering information
about your financial situation and objectives, we will recommend that you engage a specific TPMM or
investment program. Factors that we take into consideration when making our recommendation(s) include,
but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial
needs, investment goals, risk tolerance, and investment objectives. The TPMM(s) will actively manage your
portfolio and will assume discretionary investment authority over your account. We will periodically
monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with
your investment goals and objectives.
Compensation generally consists of four elements: i) management and advisory fees shared by the TPMM,
our firm, and our IARs; ii) transaction costs, if applicable, which may be paid to purchase and sell such
securities; and iii) custody fees.
Such compensation is charged through the following pricing structure: TPMM's fee may be separate from
the advisory fee charged by our firm. Transaction costs may also be charged for the execution and clearance
of advisory transactions directed by the TPMM. Further, compensation to our firm's IARs may be in the form
of commissions earned in the underlying securities portfolios, which are managed by the TPMM.
You will receive an account statement from the TPMM at least quarterly, which includes the amount of any
fees paid directly for the TPMM's services, or any other adviser selected by you to manage the account. These
fees are in addition to the internal advisory fees and expenses paid by the mutual funds or variable annuity
companies to their separate investment advisers. In addition, variable annuity companies generally impose
mortality charges on such accounts, of approximately 1.25% annually.
The amount of total fees, the services provided, the payment structure, termination provisions and other
aspects of each program are detailed and disclosed in: i) the TPMM's Form ADV Part 2; ii) the disclosure
documents of the portfolio manager or managers selected; or, iii) the TPMM's account opening documents.
Our firm will not be paid fees directly by you, but will receive a portion of the advisory fee paid to the
TPMM as a solicitor. The same or similar services may be available elsewhere at a lower cost to you.
If you are required to sign an agreement directly with the recommended TPMM(s), you may terminate your
advisory relationship with the TPMM according to the terms of your agreement with the TPMM. You should
review each TPMM's brochure for specific information on how you may terminate your advisory
relationship with the TPMM and how you may receive a refund, if applicable. You should contact the TPMM
directly for questions regarding your advisory agreement with the TPMM.
Financial Planning and Consulting Services
We offer broad-based and modular financial planning services. If you retain our firm for financial planning
services, we will meet with you to gather information about your financial circumstances and objectives.
Once we review and analyze the information you provide to our firm, we will deliver a written plan to you,
designed to help you achieve your stated financial goals and objectives.
In general, financial planning and consulting services may include, but is not limited to, any one or all of the
following:
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Personal Planning - This includes a review of family records, budgeting, personal liability, estate
information, and financial goals. We may offer advice on how to reduce risk, and to coordinate and organize
records, as well as estate information. We will also help you identify and prioritize financial goals.
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Tax & Cash Flow Planning - This encompasses a large array of services that are customized to your
specific financial circumstances including income tax and spending analysis. Our firm may illustrate how tax
laws will affect various financial decisions, such as investing in new opportunities or consolidation of
existing investments and individual taxation issues, among others. The impact of those decisions on your
current income tax and future tax liability may also be assessed.
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Insurance Planning - This includes risk management associated with advisory recommendations
based on the combination of insurance types that best meet your specific needs, such as life, health,
disability, and long-term care insurance. This will generally include analysis of cash needs at death, income
needs of surviving dependents, and disability income analysis.
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Retirement Planning - This involves advice with respect to alternatives and techniques for
accumulating wealth for retirement income or advice relative to appropriate distribution of assets following
retirement. Tax consequences and their implications are identified and evaluated.
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Investment Planning - This involves advice with respect to investment alternatives and their effect
on your portfolio. Evaluations are made of existing investments in terms of their economic and tax
characteristics as well as their suitability for meeting your objectives. Tax consequences and their
implications are identified and evaluated.
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Estate Planning - This involves the strategies and techniques to arranging assets in a manner that
meets lifetime financial objectives while simultaneously providing for survivors' needs. A carefully
implemented estate plan can help create and conserve assets, and minimize death taxes, income taxes and
estate settlement costs. This may ensure that cash is available to pay unavoidable expenses and provide
an orderly distribution of assets that meets the estate owner's objectives and intentions.
Consulting on topics not specifically described above, such as risk management, legacy planning, and liability
management may be provided based on your individual needs. Financial plans are based on your financial
situation at the time we present the plan to you, and on the financial information you provide to our firm.
You must promptly notify our firm if your financial situation, goals, objectives, or needs change. You are
under no obligation to act on our financial planning recommendations. Should you choose to act on any of
our recommendations, you are not obligated to implement the financial plan through any of our other
investment advisory services. Moreover, you may act on our recommendations by placing securities
transactions with any brokerage firm.
Our firm uses the following financial planning fee schedule:
Fixed Fees: Fixed fees for financial planning services generally range between $2,500 and $50,000.
Hourly Fees: The firm charges an hourly fee ranging between $250 and $500 if you request general
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consulting services.
We also offer Professional Plan Analysis, which involves providing a financial plan or tax analysis to
accountants and/or attorneys. The fee for this service ranges between $250 to $500 an hour.
An estimate of the total time/cost will be determined at the start of the advisory relationship. In limited
circumstances, the cost/time could potentially exceed the initial estimate. In such cases, we will notify you
and request that you approve the additional fee. Our fees are negotiable depending upon the complexity and
scope of the plan, your financial situation, and your objectives. Unless agreed otherwise, we require that you
pay 50% of the fee in advance and the remaining portion upon the completion of the services rendered. We
will not require prepayment of a fee more than six months in advance and in excess of $500. We may reduce
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our financial planning fee for those clients making use of our portfolio management services.
All clients wishing to engage our firm for the implementation of its financial and/or retirement plan must
complete our internal documents and investment advisory agreement. Upon completion of the
aforementioned documents, together with our securing of the relevant approvals, we will be considered
engaged by you. The term of engagement will be either a "one- time only" or ongoing, as set forth in the
advisory agreement. For ongoing agreements, you will be responsible for ensuring that we have been timely
informed of changes in investment objectives and risk tolerance.
You may terminate the financial planning agreement by providing written notice to our firm within five days
from the date of acceptance. After the five-day period, either you or our firm may terminate the financial
planning agreement by providing written notice to the other party. You will incur a pro rata charge for
services rendered prior to the termination of the agreement. If you have pre-paid advisory fees that we have
not yet earned, you will receive a prorated refund of those fees.
Asset Allocation Services
We offer asset allocation services that are tailored to meet our clients' needs and investment objectives.
Once you have retained our firm for asset allocation services, we will gather information about your financial
situation and objectives, and assist you in determining your investment goals, objectives, risk tolerance, and
retirement plan time horizon. We will initially provide you with recommendations as to how to allocate your
investments among categories of assets. We will then review your account on a periodic basis. Where
appropriate, we may provide you with recommendations to change your asset allocation in an effort to
remain consistent with your stated financial objectives. You are free at all times to accept or reject any of
our investment recommendations. You are solely responsible for implementing our recommendations.
Unless you separately retain our services, we will not execute any transactions or changes in asset allocation
on your behalf.
We charge a fixed fee for our asset allocation services. Our fixed fee ranges from $1,000 to $12,000.
Investment Consulting/Portfolio Monitoring Services
We offer non-discretionary, non-continuous investment consulting and portfolio monitoring services with
respect to accounts not managed by our firm. As part of this service, we will gather information about your
financial situation and objectives, and assist you in determining your investment goals, objectives, risk
tolerance, and time horizon. We will then monitor your account on a periodic basis and will make
recommendations to you consistent with your stated financial objectives. We may review accounts on a
quarterly, annual or semi-annual basis. You are free at all times to accept or reject any investment
recommendation from our firm. You are solely responsible for implementing any of our recommendations.
Our fees for this service is either a fixed fee or a percentage of the assets being monitored, as follows:
generally ranging between $500 - $50,000 or a percentage of the assets being monitored, which generally
range between 0.25% - 1.50%
Retainer costs: Fixed fees generally range between $500 - $50,000 annually. Fees are due and
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payable quarterly.
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Asset-Based Retainer costs: Our annual asset-based fee generally ranges between 0.25% - 1.50%,
which is billed and payable quarterly in advance based on the value of your account being monitored as
of the last day of the previous quarter.
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Consulting Services to Investment Advisers and Investment Adviser Representatives
We offer personalized consulting services to other financial advisors and advisory firms on an hourly or flat
fee basis. Services include generally assisting in case design, portfolio review, and review of investment
strategies. We offer this service exclusively to unaffiliated RIAs and IARs who want to offer clients a second
option and the ability to outsource research and strategies. This gives RIAs and IARs the ability to offer
investment and planning strategies that may distinguish them from the typical advisor. We do not
participate in sharing fees or commissions that may be generated from an IAR's implementation of our
recommendations or solutions. The RIA and IAR is free at all times to accept or reject any of our investment
recommendations, and is solely responsible for implementing any of our recommended planning solutions
or strategies. We make observations and recommendations believed to be compatible around the
understanding of circumstances and data provided by the RIA or IAR's own data research and
understanding of their individual client needs.
We charge either an hourly fee or fixed fee for this service. Hourly fees range between $250 - $500 per hour,
depending on complexity of the case and existing knowledge base of the RIA or IAR. Fixed fees range
generally from $2,500 to $50,000, depending on the schedule and complexity of the case or cases agreed
upon in the consulting agreement. Fees are due upon completion of the services rendered. We may also offer
these services on an annual retainer basis. Annual retainer fees are payable quarterly in advance.
Annuity, Insurance and Directly-Held Mutual Fund Consulting
For annuity or other insurance products or mutual funds that are commission products, we advise on these
as a consultant. We can advise on commissionable products already owned by clients or that clients are
considering purchasing as part of financial planning. For clients who would like advice and servicing help
on these commissionable products, they can assign Mutual Securities, LLC as the agent. Mutual Securities
provides servicing and then contracts with us to provide investment advisory services for those clients who
have provided written consent. Mutual Securities pays us for consulting on these accounts and policies. See
Item 10 for details on this arrangement.
Succession and Transition Planning for Business Owners
We offer succession and transition planning which typically involves providing a variety of advisory services
to business owners. These services can range from broad-based succession or transition planning to
consultative or single subject planning. If you retain our firm for succession and transition planning, we will
meet with you to gather information about your business's financial circumstances and the ultimate
succession or transition objective. Once we review and analyze the information you provide to our firm, we
will designed a plan to help you achieve your succession or transition goal.
We charge either an hourly fee or fixed fee for this service. Hourly fees range between $250 - $500 per hour,
depending on complexity of the case and existing knowledge base of the business and/or transition. Fixed
fees range generally from $2,500 to $50,000, depending on the schedule and complexity of the case or cases
agreed upon in the consulting agreement. Fees are due upon completion of the services rendered.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs
of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services
may include an existing plan review and analysis, plan-level advice regarding fund selection and investment
options, education services to plan participants, investment performance monitoring, and/or ongoing
consulting. These pension consulting services will be either non-discretionary or discretionary. In the case
of a non-discretionary basis, the ultimate decision to act on behalf of the plan shall remain with the plan
sponsor or other named fiduciary.
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We may also assist with participant enrollment meetings and provide investment-related educational
seminars to plan participants on such topics as:
Diversification;
Asset allocation;
Risk tolerance; and
Time horizon
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Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually negotiated
basis. All services, whether discussed above or customized for the plan based upon requirements from the
plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a
written agreement and be consistent with the parameters set forth in the plan documents.
Our advisory fees for these customized services will be negotiated with the plan sponsor or named fiduciary
on a case-by-case basis.
You may terminate the pension consulting services agreement upon to our firm. You will incur a pro rata
charge for services rendered prior to the termination of the agreement, which means you will incur advisory
fees only in proportion to the number of days in the quarter for which you are a client. If you have pre-paid
advisory fees that we have not yet earned, you will receive a prorated refund of those fees.
Types of Investments
We primarily offer advice on equity securities, corporate debt securities, commercial paper, certificates of
deposit, municipal securities, mutual funds, exchange traded funds, no-load funds, non-commission funds,
variable annuities, variable life insurance, U.S. Government securities, interest in partnerships investing in
real estate, oil and gas interests, and the selection of third party advisers.
Additionally, we may advise you on any type of investment that we deem appropriate based on your stated
goals and objectives. We may also provide advice on any type of investment held in your portfolio at the
inception of our advisory relationship.
You may request that we refrain from investing in particular securities or certain types of securities. You
must provide these restrictions to our firm in writing.
Assets Under Management
As of December 31, 2024, we manage $ 375,470,705 in client assets on a discretionary basis and $1,597,092
in client assets on a non-discretionary basis.
Item 5 Fees and Compensation
Please refer to the "Advisory Business" section in this brochure for information on our advisory fees, fee
payment arrangements, and refund policies.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual
funds and exchange traded funds. The fees that you pay to our firm for investment advisory services are
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separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds
(described in each fund's prospectus) to their shareholders. These fees will generally include a management
fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing
or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through
whom your account transactions are executed. We do not share in any portion of the brokerage
fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you
will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and
others. For information on the fees by program or advisory service, please refer to the "Advisory Business"
section of this brochure. For information on our firm's brokerage practices, please refer to the "Brokerage
Practices" section of this brochure.
Variable annuity companies generally impose internal fees and expenses on your variable annuity
investment. These fees are in addition to the fees and expenses referenced above. Complete details of such
internal expenses are specified and disclosed in each variable annuity company's prospectus. Please review
the Variable Annuity prospectus for full details.
There are additional fees relating to IRA and Qualified Retirement Plan accounts that you may incur such as
maintenance and termination fees. You will find these fees disclosed in the account application paperwork
provided to you associated with these accounts.
Compensation for the Sale of Securities or Other Investment Products
Please be aware that you are under no obligation to purchase products or services recommended by us or
members of our firm in connection with providing you with any advisory service that we offer.
At our discretion, we may offset our advisory fees to the extent our associated persons earn commissions in
their separate capacities as registered representatives and/or insurance agents.
Item 6 Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or participate in side-by-side management. Side-by-side
management refers to the practice of managing accounts that are charged performance-based fees while at
the same time managing accounts that are not charged performance-based fees. Performance-based fees are
fees that are based on a share of capital gains or capital appreciation of a client's account. Our fees are
calculated as described in the "Advisory Business" section above, and are not charged on the basis of a share
of capital gains upon, or capital appreciation of, the funds in your advisory account.
Item 7 Types of Clients
We offer investment advisory services to individuals, pension and profit sharing plans, trusts, estates,
charitable organizations, corporations, and other business entities.
Our account minimum will depend on the specific advisory program you choose. However, we generally
require an account minimum of $500,000, which may be waived in our discretion.
Each Third Party Advisory Service that we offer has their own account minimum. Their account minimums
are disclosed to you through their own Form ADV and associated paperwork that will be presented to you.
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Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Our Methods of Analysis and Investment Strategies
We may use one or more of the following methods of analysis or investment strategies when providing
investment advice to you:
Long Term Purchases - securities purchased with the expectation that the value of those securities
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Charting Analysis - involves the gathering and processing of price and volume information for a
particular security. This price and volume information is analyzed using mathematical equations. The
resulting data is then applied to graphing charts, which is used to predict future price movements based on
price patterns and trends.
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Technical Analysis - involves studying past price patterns and trends in the financial markets to
predict the direction of both the overall market and specific stocks. The risk of market timing based on
technical analysis is that charts may not accurately predict future price movements. Current prices of
securities may reflect all information known about the security and day to day changes in market prices of
securities may follow random patterns and may not be predictable with any reliable degree of accuracy.
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Fundamental Analysis - involves analyzing individual companies and their industry groups, such as
a company's financial statements, details regarding the company's product line, the experience and
expertise of the company's management, and the outlook for the company's industry. The resulting data is
used to measure the true value of the company's stock compared to the current market value. The risk of
fundamental analysis is that information obtained may be incorrect and the analysis may not provide an
accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly
to new information, utilizing fundamental analysis may not result in favorable performance.
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will grow over a relatively long period of time, generally greater than one year.
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Short Term Purchases - securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities' short-term
price fluctuations.
We also use trend analysis, which in investment terms, refers to investment methodology that is related to
historical price movements, irrespective of economic fundamentals. Technicians believe patterns will
emerge within the price action and trading volume of an asset, which indicate particular trends and
reversals. Trend, in investment terms, refers to the regular tendency of securities to increase or decrease in
value over a set period of time. Analysts work to identify trends and time their buying and selling activity to
profit from particular chart patterns. Bullish trends indicate that the investment will continue to increase in
value. Higher highs and higher lows signal bullish trends. The higher lows are benchmarked against, or
compared with, a level of support, which identify short-term low price points for the security that have not
been breached over set periods of time. "Breakouts," refer to strong price appreciation above a point of
resistance, or short-term high points for the investments that have not been overtaken during a specific time
frame. Bearish trends indicate that the investment is set to lose value. Lower highs and lower lows are
associated with bearish trends. Securities are unable to move beyond a high point of resistance and break
down past support levels. Reversals: a security will not approach infinity or collapse to zero without
interruptions. Reversals are inflection points at which trends switch from bullish to bearish or vice verse.
The head and shoulders pattern is typically associated with reversals. Conversely, the inverted head and
shoulders is "a reversal pattern in a downtrend," which is bullish.
The risks of using trend analysis is that trends may not be long-sustaining, resulting in insufficient gain or a
loss if followed. Also, the securities selected may not trend in which case an increase or decrease in their
value may not be estimated.
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The risk of market timing based on technical analysis is that charts may not accurately predict future price
movements. Current prices of securities may reflect all information known about the security and day to day
changes in market prices of securities may follow random patterns and may not be predictable with any
reliable degree of accuracy. The risk of fundamental analysis is that information obtained may be incorrect
and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value.
If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in
favorable performance. The risk of cyclical analysis is that economic/business cycles may not be predictable
and may have many fluctuations between long term expansions and contractions. The lengths of economic
cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in
predicting economic trends and consequently the changing value of securities that would be affected by
these changing trends.
Long term purchases may also be affected by unforeseen long term changes in the company in which you
are invested or in the overall market. Short term trading generally involves a greater degree of risk than long
term trading due to market volatility over a short period of time.
Our strategies and investments may have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the
management of your assets. Regardless of your account size or any other factors, we strongly recommend
that you continuously consult with a tax professional prior to and throughout the investing of your assets.
Moreover, as a result of revised IRS regulations, custodians and broker-dealers will begin reporting the cost
basis of equities acquired in client accounts on or after January 1, 2011. Your custodian will default to the
FIFO (First-In First-Out) accounting method for calculating the cost basis of your investments. You are
responsible for contacting your tax advisor to determine if this accounting method is the right choice for
you. If your tax advisor believes another accounting method is more advantageous, please provide written
notice to our firm immediately and we will alert your account custodian of your individually selected
accounting method. Please note that decisions about cost basis accounting methods will need to be made
before trades settle, as the cost basis method cannot be changed after settlement.
In instances where we recommend that a third party manage your assets, please refer to the third party’s
ADV and associated disclosure documents for details on their investment strategies, methods of analysis
and associated risks.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully identify
market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot
offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in
no way an indication of future performance.
Recommendation of Particular Types of Securities
As disclosed under the "Advisory Business" section in this Brochure, we offer advice on all types of securities,
however, we primarily recommend mutual funds; however, since each client has different needs and
different tolerance for risk, we may recommend other types of investments as appropriate for your situation.
Each type of security has its own unique set of risks associated with it and it would not be possible to list
here all of the specific risks of every type of investment. Even within the same type of investment, risks can
vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher
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the risk of loss associated with it.
Mutual funds are professionally managed collective investment systems that pool money from many
investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other
securities or any combination thereof. The fund will have a manager that trades the fund's investments in
accordance with the fund's investment objective. While mutual funds generally provide diversification, risks
can be significantly increased if the fund is concentrated in a particular sector of the market, primarily
invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or
concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types
of securities. The returns on mutual funds can be reduced by the costs to manage the funds. Also, while some
mutual funds are "no load" and charge no fee to buy into, or sell out of, other types of mutual funds do charge
such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called
"open end" mutual funds continue to allow in new investors indefinitely which can dilute other investors'
interests.
Item 9 Disciplinary Information
Neither our firm nor any of our Associated Persons has any reportable disciplinary information.
Item 10 Other Financial Industry Activities and Affiliations
Arrangements with Affiliated Persons or Entities
Persons providing investment advice on behalf of our firm are also licensed as insurance agents. These
persons will earn commission-based compensation for selling insurance products, including insurance
products they sell to you. Insurance commissions earned by these persons are separate from our advisory
fees. Please see the "Fees and Compensation" section in this brochure for more information on the
compensation received by insurance agents who are affiliated with our firm.
Recommendation of Other Advisers
We may recommend that you use a third party money manager ("TPMM") based on your needs and
suitability. We will receive compensation from the TPMM for recommending that you use their services.
These compensation arrangements present a conflict of interest because we have a financial incentive to
recommend the services of the third party adviser. You are not obligated, contractually or otherwise, to use
the services of any TPMM we recommend.
Annuity, Insurance, and Directly-Held Mutual Fund Consulting
We have entered into an investment advisory contract with Mutual Securities, Inc. to provide investment
advisory services for annuity or other insurance products or mutual funds that are commission products.
We receive a flat advisory fee of 50-85 basis points for the advisory services provided.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of
Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to
protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty,
good faith, and fair dealing with you. All of our Associated Persons are expected to adhere strictly to these
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guidelines. Our Code of Ethics also requires that certain persons associated with our firm submit reports of
their personal account holdings and transactions to a qualified representative of our firm who will review
these reports on a periodic basis. Persons associated with our firm are also required to report any violations
of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent
the misuse or dissemination of material, non-public information about you or your account holdings by
persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone
number on the cover page of this brochure.
Participation or Interest in Client Transactions
Neither our firm nor any of our associated persons has any material financial interest in client transactions
beyond the provision of investment advisory services as disclosed in this brochure.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you
or securities in which you are already invested. A conflict of interest exists in such cases because we have
the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To
eliminate this conflict of interest, it is our policy that neither our Associated Persons nor we shall have
priority over your account in the purchase or sale of securities.
Item 12 Brokerage Practices
Custodians/broker-dealers will be recommended based on our duty to seek “best execution,” which is the
obligation to seek to execute securities transactions for a client on terms that are the most favorable to the
client under the circumstances. The client will not necessarily pay the lowest commission or commission
equivalent, and we may also consider the market expertise and research access provided by the payment of
commissions, including but not limited to access to written research, oral communication with analysts,
admittance to research conferences and other resources provided by the brokers to aid in the research
efforts of our firm. We will never charge a premium or commission on transactions, beyond the actual cost
imposed by the broker-dealer/custodian. We typically recommend the following custodians: SEI Trust
Company and Fidelity Brokerage Services.
Trades will be placed within the established account at the custodian designated by the client. We will not
engage in any principal transactions (i.e., trade of any security from or to our own account) or cross
transactions with other client accounts (i.e., purchase of a security into one client account from another
client’s account). We will not be obligated to select competitive bids on securities transactions and do not
have an obligation to seek the lowest available transaction costs. These costs are determined by the
custodian. A client may pay a commission that is higher than another qualified custodian might charge to
effect the same transaction. We have determined in good faith that the commissions charged by the
custodian are reasonable in relation to the value of the brokerage and research services received.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as
brokerage services or research.
Block Trades
If we buy or sell the same securities on behalf of more than one client, we might, but would be under no
obligation to, aggregate or bunch, to the extent permitted by applicable law and regulations, the securities
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to be purchased or sold for multiple clients in order to seek more favorable prices, lower brokerage
commissions or more efficient execution. In such case, we would place an aggregate order with the broker
on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would
be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. When
trades cannot or are not aggregated, clients may receive less favorable prices, pay higher brokerage
commissions, or experience less efficient trade execution.
The aggregation and allocation practices of third party managers that we recommend to you are disclosed
in the third party manager disclosure documents which will be provided to you.
Item 13 Review of Accounts
Randall Yeomans, CEO; Nicholas Yeomans, President and CCO; and John Richter, Jr., and Aaron Calhoun,
Investment Adviser Representatives, will monitor your accounts on an ongoing basis and will conduct
account reviews at least annually in an effort to ensure the advisory services provided to you are consistent
with your stated investment needs and objectives. Additional reviews may be conducted based on various
circumstances, including, but not limited to:
contributions and withdrawals,
year-end tax planning,
market moving events,
security specific events, and/or,
changes in your risk/return objectives.
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We will not provide you with regular written reports in conjunction with account reviews. You will receive
trade confirmations, monthly or quarterly statements, and year-end tax statements from your account
custodian(s).
If you are a financial planning client, you may receive annual updates from our firm upon request for an
additional fee.
Item 14 Client Referrals and Other Compensation
Certain Third Party Advisory Service programs may provide our Advisory Representatives with the
opportunity to attend training or education conferences. Such conferences include the payment or
reimbursement of travel, meals and lodging expenses for attendees. Payment/reimbursement of expenses
is not contingent upon sales targets or contests, but rather on total assets managed on their respective Third
Party Advisory Service platforms. We may have an incentive to recommend Third Party Advisory Service
programs that provide us with the above referenced opportunities over those that do not.
While our security sales are reviewed for suitability by an appointed supervisor, you should be aware of the
incentives we have to sell certain securities products and are encouraged to ask us about any conflict
presented.
We may provide direct or indirect compensation to individuals for client referrals. All such referral activities
will be conducted in accordance with Rule 206(4)-1 under the Advisers Act, where applicable.
We have access to a variety of economic benefits, services, and products in connection with our use of SEI’s
investment adviser platform. The terms and availability of these benefits vary among advisors on the SEI
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platform depending on the business conducted with SEI and other factors. These services generally help us
conduct advisory business, but each specific benefit does not necessarily benefit each client.
Beyond access to SEI investment products, these include conferences, seminars and other educational and
networking activities, business entertainment, reimbursement of travel and attendance expenses, research
and other investment support services (such as client proposal and other financial planning support),
technical and operational solutions (including the SEI Wealth Platform), marketing assistance (including
joint marketing designed to promote SEI’ investment products), compliance services, human resources
consulting, risk management/insurance assistance, front office, middle office, back office and other
administrative support (including providing clerical staff to assist in the completion of required paperwork),
SEI attendance at client meetings, information technology services, continuity and succession planning,
access to financing and banking options, trust services, portfolio reporting, automatic rebalancing, tax loss
harvesting, waiver or payment of certain fees (including paying account transfer fees or other charges that
we or our clients would incur when changing service providers), vendor discounts, discount pricing on SEI
services, and broader practice management consulting. These benefits may be provided via SEI, its affiliates,
or third parties and may be made available to us at no fee, at a discounted fee, or via financial compensation
provided by SEI. Some of these offerings depend on us conducting a minimum amount or type of current or
expected future business with SEI, or having a minimum account size or amount of assets under
management with SEI or invested in SEI investment products. Certain of these services or products,
including those provided by or paid for by SEI, may be used by us in connection with our general business
activities, in addition to supporting our interaction with SEI systems. The benefits, services, products, or
payments discussed herein may be significant to us and create an incentive for us to utilize SEI services or
investment products for our customers rather than other service providers or investment products.
However, we strive at all times to put the interests of its clients first, including when selecting custodians or
investment products for clients. Yeomans Consulting Group is independently owned and operated; it is not
affiliated with SEI.
Item 15 Custody
As paying agent for our firm, your independent custodian will directly debit your account(s) for the payment
of our advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise
limited custody over your funds or securities. We do not have physical custody of any of your funds and/or
securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified
custodian. You will receive account statements from the independent, qualified custodian(s) holding your
funds and securities at least quarterly. The account statements from your custodian(s) will indicate the
amount of our advisory fees deducted from your account(s) each billing period. You should carefully review
account statements for accuracy.
If you have a question regarding your account statement or if you did not receive a statement from your
custodian, please contact us directly at the telephone number on the cover page of this brochure.
Custody is also disclosed in Form ADV because we have authority to transfer money from client account(s),
which constitutes a standing letter of authorization (SLOA). Accordingly, we will follow the safeguards
specified by the SEC rather than undergo an annual audit
Item 16 Investment Discretion
Before we can buy or sell securities on your behalf, you must first sign our discretionary management
agreement and/or trading authorization forms.
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You may grant our firm discretion over the selection and amount of securities to be purchased or sold for
your account(s) without obtaining your consent or approval prior to each transaction. You may specify
investment objectives, guidelines, and/or impose certain conditions or investment parameters for your
account(s). For example, you may specify that the investment in any particular stock or industry should not
exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions
in the securities of a specific industry or security. Your consent is typically granted and evidenced in the
client agreement that you sign with us. Please refer to the "Advisory Business" section in this brochure for
more information on our discretionary management services.
If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the
execution of any transactions for your account(s). You have an unrestricted right to decline to implement
any advice provided by our firm on a non-discretionary basis.
Item 17 Voting Client Securities
We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice
regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common stock
or mutual funds, you are responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event
we were to receive any written or electronic proxy materials, we would forward them directly to you by
mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward
any electronic solicitation to vote proxies.
Item 18 Financial Information
We are not required to provide financial information to our clients because we do not:
require the prepayment of more than $1200 in fees and six or more months in advance, or
take custody of client funds or securities, or
have a financial condition that is reasonably likely to impair our ability to meet our commitments to
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you.
Item 19 Requirements for State Registered Investment Advisers
We are a federally registered investment adviser; therefore, we are not required to respond to this item.
Item 20 Additional Information
Your Privacy
We view protecting your private information as a top priority. Pursuant to applicable privacy requirements,
we have instituted policies and procedures to ensure that we keep your personal information private and
secure.
We do not disclose any non-public personal information about you to any non-affiliated third parties, except
as permitted by law. In the course of servicing your account, we may share some information with our
service providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and
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attorneys.
We restrict internal access to non-public personal information about you to employees, who need that
information in order to provide products or services to you. We maintain physical and procedural
safeguards that comply with regulatory standards to guard your non-public personal information and to
ensure our integrity and confidentiality. We will not sell information about you or your accounts to anyone.
We do not share your information unless it is required to process a transaction, at your request, or required
by law.
You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our
firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Please
contact our main office at the telephone number on the cover page of this brochure if you have any questions
regarding this policy.
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position it
should have been in had the trading error not occurred. Depending on the circumstances, corrective actions
may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, If a
trade error results in a profit, the trade error will be corrected in the trade error account of the executing
broker-dealer and you will not keep the profit.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you are
eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to
recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of
securities held by you.
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