Overview
Assets Under Management: $229 million
High-Net-Worth Clients: 62
Average Client Assets: $3 million
Services Offered
Services: Portfolio Management for Individuals, Investment Advisor Selection
Fee Structure
Primary Fee Schedule (ADV PART 2A-YOUR PRIVATE CLIENT GROUP, INC.)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.00% |
| $500,001 | $1,000,000 | 0.80% |
| $1,000,001 | $5,000,000 | 0.50% |
| $5,000,001 | and above | 0.30% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $9,000 | 0.90% |
| $5 million | $29,000 | 0.58% |
| $10 million | $44,000 | 0.44% |
| $50 million | $164,000 | 0.33% |
| $100 million | $314,000 | 0.31% |
Clients
Number of High-Net-Worth Clients: 62
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 72.35
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 439
Discretionary Accounts: 439
Regulatory Filings
CRD Number: 292621
Last Filing Date: 2025-01-14 00:00:00
Website: https://yourpcg.com
Form ADV Documents
Primary Brochure: ADV PART 2A-YOUR PRIVATE CLIENT GROUP, INC. (2025-07-30)
View Document Text
Your Private Client Group, Inc.
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Your Private Client Group,
Inc. If you have any questions about the contents of this brochure, please contact us at (800) 346-0138 or by email
at: info@yourpcg.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 Your Private Client Group, Inc. is also available on the SEC’s website at
www.adviserinfo.sec.gov. Your Private Client Group, Inc.’s CRD number is: 292621.
5267 Warner Ave #235
Huntington Beach, CA 92649
(800) 346-0138
info@yourpcg.com
www.yourpcg.com
Registration does not imply a certain level of skill or training.
Version Date: 07/30/2025
i
Item 2: Material Changes
There are no material changes in this brochure from the last annual updating amendment on 01/14/2025
of Your Private Client Group, Inc.. Material changes relate to Your Private Client Group, Inc.’s policies,
practices or conflicts of interests.
ii
Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes .......................................................................................................................................................................................... ii
Item 3: Table of Contents ......................................................................................................................................................................................... iii
Item 4: Advisory Business ......................................................................................................................................................................................... 2
A. Description of the Advisory Firm................................................................................................................................................................... 2
B. Types of Advisory Services.............................................................................................................................................................................. 2
Selection of Other Advisers ............................................................................................................................................................................. 2
C. Client Tailored Services and Client Imposed Restrictions .......................................................................................................................... 2
D. Wrap Fee Programs .......................................................................................................................................................................................... 3
E. Assets Under Management .............................................................................................................................................................................. 3
Item 5: Fees and Compensation ................................................................................................................................................................................ 3
A. Fee Schedule ...................................................................................................................................................................................................... 3
B. Payment of Fees................................................................................................................................................................................................. 5
Payment of Selection of Other Advisers Fees ............................................................................................................................................... 5
C. Client Responsibility For Third Party Fees .................................................................................................................................................... 5
D. Prepayment of Fees .......................................................................................................................................................................................... 5
E. Outside Compensation For the Sale of Securities to Clients ........................................................................................................................ 6
Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................................................................ 6
Item 7: Types of Clients ............................................................................................................................................................................................. 6
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ................................................................................................................... 6
A. Methods of Analysis and Investment Strategies .......................................................................................................................................... 6
B. Material Risks Involved.................................................................................................................................................................................... 7
C. Risks of Specific Securities Utilized ................................................................................................................................................................ 8
Item 9: Disciplinary Information .............................................................................................................................................................................. 8
A. Criminal or Civil Actions................................................................................................................................................................................. 8
B. Administrative Proceedings ............................................................................................................................................................................ 9
C. Self-regulatory Organization (SRO) Proceedings ......................................................................................................................................... 9
Item 10: Other Financial Industry Activities and Affiliations ............................................................................................................................... 9
A. Registration as a Broker/Dealer or Broker/Dealer Representative ........................................................................................................... 9
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ............................ 9
C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ...................................................... 9
D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ............................................ 9
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................................................... 9
A. Code of Ethics ................................................................................................................................................................................................. 10
iii
B. Recommendations Involving Material Financial Interests ........................................................................................................................ 10
C. Investing Personal Money in the Same Securities as Clients .................................................................................................................... 10
D. Trading Securities At/Around the Same Time as Clients’ Securities ...................................................................................................... 10
Item 12: Brokerage Practices.................................................................................................................................................................................... 10
A. Factors Used to Select Custodians and/or Broker/Dealers ...................................................................................................................... 10
1. Research and Other Soft-Dollar Benefits ................................................................................................................................................. 11
2. Brokerage for Client Referrals ................................................................................................................................................................... 11
3. Clients Directing Which Broker/Dealer/Custodian to Use .................................................................................................................. 11
B. Aggregating (Block) Trading for Multiple Client Accounts ...................................................................................................................... 11
Item 13: Review of Accounts ................................................................................................................................................................................... 11
A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ....................................................................................... 11
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ..................................................................................................... 11
C. Content and Frequency of Regular Reports Provided to Clients ............................................................................................................. 11
Item 14: Client Referrals and Other Compensation ............................................................................................................................................. 12
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ............... 12
B. Compensation to Non – Advisory Personnel for Client Referrals ............................................................................................................ 12
Item 15: Custody ....................................................................................................................................................................................................... 12
Item 16: Investment Discretion ............................................................................................................................................................................... 12
Item 17: Voting Client Securities (Proxy Voting) .................................................................................................................................................. 13
Item 18: Financial Information ................................................................................................................................................................................ 13
A. Balance Sheet ................................................................................................................................................................................................... 13
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ........................................ 13
C. Bankruptcy Petitions in Previous Ten Years ............................................................................................................................................... 13
iv
Item 4: Advisory Business
A. Description of the Advisory Firm
Your Private Client Group, Inc. (hereinafter “Your PCG”) is a corporation organized in the
State of California. The firm was formed in January 2018, and the principal owners are
Todd D'Agostino and Matthew D’Agostino
B. Types of Advisory Services
Your PCG offers the following services to advisory clients:
Selection of Other Advisers
Your PCG directs clients to AssetMark, an SEC registered investment adviser
CRD #109018 to use the asset allocation and individual account management platform
sponsored by AssetMark. Client will sign an Account Set-up and Application Form to
establish an account on the platform. AssetMark, Inc. will not provide any advisory
services to the client account. Clients will be given Asset Mark’s brochure which will
describe the platform and services of AssetMark, Inc. in greater detail. There is no referral
fee received by Your PCG as the firm's fee is separate from AssetMark, Inc. Before
selecting other advisers for clients, Your PCG will verify that all recommended advisers
are properly licensed, notice filed, or exempt in the states where Your PCG is
recommending the adviser to clients.
Services Limited to Specific Types of Investments
Your PCG generally limits its investment advice to mutual funds, fixed income securities
and ETFs. Your PCG may use other securities as well to help diversify a portfolio when
applicable.
C. Client Tailored Services and Client Imposed Restrictions
Your PCG offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client’s current
situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions
in investing in certain securities or types of securities in accordance with their values or
beliefs.
2
D. Wrap Fee Programs
A wrap fee program is an investment program wherein the investor pays one stated fee
that includes management fees, transaction costs, fund expenses, and any other
administrative fees. Your PCG does not participate in any wrap fee programs.
E. Assets Under Management
Your PCG has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 228,629,398.00
$ 0.00
December 2024
Item 5: Fees and Compensation
A. Fee Schedule
Selection of Other Advisers Fees
Fees and compensation for using the AssetMark Platform are provided in more detail in
the AssetMark Platform Disclosure Brochure. Fees and Investment Minimums schedules
are included Asset Mark’s Platform Disclosure Brochure, and the Client Billing
Authorization will also state the fee applicable to the client’s account. The fees applicable
to each Account on the AssetMark Platform will include: 1. Financial Advisor Fee, 2.
Platform Fee, which includes any Strategist or Manager Fee, as applicable, and most
custody fees. Other fees for special services may also be charged. The Client should
consider all applicable fees. It is important to note that the program fees can differ based
on the specific strategy chosen for each individual client. Clients are encouraged to refer
to their initial account application for further details on Asset Mark's program fee.
The quarterly Advisory Fee is calculated by multiplying the market value of all Account
assets inclusive of accrued interest and dividends as of the end of the previous calendar
quarter by the “quarterly rate.” The quarterly rate is number of calendar days in the
quarter, divided by 365 (or 366, as applicable) days in the year, multiplied by the
applicable annual Advisory Fee which includes both Your PCG’s fee and Asset Mark’s
Platform fee.
3
Your PCG Fees
Fixed Income Tiered Schedule
Total Assets
Annual Fee
First $500,000
0.50%
Next $500,000
0.50%
Next $4,000,000
0.25%
Over $5,000,000
0.15%
Equities Tiered Schedule
Total Assets
Annual Fee
First $500,000
1.00%
Next $500,000
0.80%
Next $4,000,000
0.50%
Over $5,000,000
0.30%
These fees are negotiable and the final fee schedule is attached as Exhibit II of the
Investment Advisory Contract. Lower fees for comparable services may be available from
other sources. The balance in the client’s account on the last day of the prior billing period
is used to determine the market value of the assets upon which the advisory fee is based.
Clients may terminate the agreement without penalty, for full refund of Your PCG’s fees,
within five business days of signing the Investment Advisory Contract. Thereafter, clients
may terminate the Investment Advisory Contract with thirty days’ written notice.
4
AssetMark Fees
B. Payment of Fees
Payment of Selection of Other Advisers Fees
Fees for selection of AssetMark as third-party adviser are withdrawn by AssetMark
directly from client accounts. Your PCG then receives its portion of the fees from
AssetMark; Your PCG does not directly deduct the advisory fees. Fees are collected
quarterly in advance with client’s written authorization
C. Client Responsibility for Third Party Fees
Clients are responsible for the payment of all third-party fees (i.e., custodian fees,
commissions, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are
separate and distinct from the fees and expenses charged by Your PCG. Please see Item
12 of this brochure regarding broker-dealer/custodian.
D. Prepayment of Fees
Your PCG will not provide refunds on prepaid fees for withdrawals, which may result in
clients being overcharged for withdrawals made during the billing period. Additional
deposits are prorated and included for fee calculation purposes.
Upon termination, asset-based fees paid in advance will be refunded the balance of the
fees collected in advance minus the daily rate* times the number of days elapsed in the
5
billing period up to and including the day of termination. (*The daily rate is calculated by
dividing the annual asset-based fee by 365.)
E. Outside Compensation for the Sale of Securities to Clients
Neither Your PCG nor its supervised persons accept any compensation for the sale of
investment products, including asset-based sales charges or service fees from the sale of
mutual funds.
Item 6: Performance-Based Fees and Side-By-Side Management
Your PCG does not accept performance-based fees or other fees based on a share of capital gains
on or capital appreciation of the assets of a client.
Item 7: Types of Clients
Your PCG generally provides advisory services to the following types of clients:
❖
❖
Individuals
High-Net-Worth Individuals
There is an account minimum of $100,000, which may be waived by Your PCG at its discretion.
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
Your PCG’s methods of analysis include Cyclical analysis, Fundamental analysis, Modern
portfolio theory and Quantitative analysis.
Cyclical analysis involves the analysis of business cycles to find favorable conditions for
buying and/or selling a security.
Fundamental analysis involves the analysis of financial statements, the general financial
health of companies, and/or the analysis of management or competitive advantages.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio
expected return for a given amount of portfolio risk, or equivalently minimize risk for a
given level of expected return, each by carefully choosing the proportions of various asset.
6
Quantitative analysis deals with measurable factors as distinguished from qualitative
considerations such as the character of management or the state of employee morale, such
as the value of assets, the cost of capital, historical projections of sales, and so on.
Investment Strategies
Your PCG uses long term trading.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
B. Material Risks Involved
Methods of Analysis
Cyclical analysis assumes that the markets react in cyclical patterns which, once
identified, can be leveraged to provide performance. The risks with this strategy are two-
fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors
begin to implement this strategy, then it changes the very cycles these investors are trying
to exploit.
Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is
that the market will fail to reach expectations of perceived value.
Modern portfolio theory assumes that investors are risk averse, meaning that given two
portfolios that offer the same expected return, investors will prefer the less risky one.
Thus, an investor will take on increased risk only if compensated by higher expected
returns. Conversely, an investor who wants higher expected returns must accept more
risk. The exact trade-off will be the same for all investors, but different investors will
evaluate the trade-off differently based on individual risk aversion characteristics. The
implication is that a rational investor will not invest in a portfolio if a second portfolio
exists with a more favorable risk-expected return profile – i.e., if for that level of risk an
alternative portfolio exists which has better expected returns.
Quantitative analysis Investment strategies using quantitative models may perform
differently than expected as a result of, among other things, the factors used in the models,
the weight placed on each factor, changes from the factors’ historical trends, and technical
issues in the construction and implementation of the models.
Investment Strategies
Long term trading is designed to capture market rates of both return and risk. Due to its
nature, the long-term investment strategy can expose clients to various types of risk that
7
will typically surface at various intervals during the time the client owns the investments.
These risks include but are not limited to inflation (purchasing power) risk, interest rate
risk, economic risk, market risk, and political/regulatory risk.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
C. Risks of Specific Securities Utilized
Clients should be aware that there is a material risk of loss using any investment strategy.
The investment types listed below are not guaranteed or insured by the FDIC or any other
government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may
lose money investing in mutual funds. All mutual funds have costs that lower investment
returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity”
nature.
Fixed income investments generally pay a return on a fixed schedule, though the amount
of the payments can vary. This type of investment can include corporate and government
debt securities, leveraged loans, high yield, and investment grade debt and structured
products, such as mortgage and other asset-backed securities, although individual bonds
may be the best-known type of fixed income security. In general, the fixed income market
is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond
prices usually fall, and vice versa. This effect is usually more pronounced for longer-term
securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and
credit and default risks for both issuers and counterparties. The risk of default on treasury
inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting
(extremely unlikely); however, they carry a potential risk of losing share price value, albeit
rather minimal. Risks of investing in foreign fixed income securities also include the
general risk of non-U.S. investing described below.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges,
similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100%
loss in the case of a stock holding bankruptcy). Areas of concern include the lack of
transparency in products and increasing complexity, conflicts of interest and the
possibility of inadequate regulatory compliance.
Past performance is not indicative of future results. Investing in securities involves a
risk of loss that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
8
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither Your PCG nor its representatives are registered as, or have pending applications
to become, a broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity Pool
Operator, or a Commodity Trading Advisor
Neither Your PCG nor its representatives are registered as or have pending applications
to become either a Futures Commission Merchant, Commodity Pool Operator, or
Commodity Trading Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business and
Possible Conflicts of Interests
Neither Your PCG nor its representatives have any material relationships to this advisory
business that would present a possible conflict of interest.
D. Selection of Other Advisers or Managers and How This Adviser is
Compensated for Those Selections
Your PCG has a fee-sharing agreement with AssetMark, Inc., an SEC registered
investment adviser CRD #109018, to use the asset allocation and individual account
management platform sponsored by AssetMark. Clients will be given
Asset Mark’s brochure which will describe the platform and services of AssetMark, Inc.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
9
A. Code of Ethics
Your PCG has a written Code of Ethics that covers the following areas: Prohibited
Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted
Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment,
Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance
with Laws and Regulations, Procedures and Reporting, Certification of Compliance,
Reporting Violations, Compliance Officer Duties, Training and Education,
Recordkeeping, Annual Review, and Sanctions. Your PCG's Code of Ethics is available
free upon request to any client or prospective client.
B. Recommendations Involving Material Financial Interests
Your PCG does not recommend that clients buy or sell any security in which a related
person to Your PCG or Your PCG has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of Your PCG may buy or sell securities for themselves
that they also recommend to clients. This may provide an opportunity for representatives
of Your PCG to buy or sell the same securities before or after recommending the same
securities to clients resulting in representatives profiting off the recommendations they
provide to clients. Such transactions may create a conflict of interest. Your PCG will
always document any transactions that could be construed as conflicts of interest and will
never engage in trading that operates to the client’s disadvantage when similar securities
are being bought or sold.
D. Trading Securities At/Around the Same Time as Clients’ Securities
From time to time, representatives of Your PCG may buy or sell securities for themselves
at or around the same time as clients. This may provide an opportunity for representatives
of Your PCG to buy or sell securities before or after recommending securities to clients
resulting in representatives profiting off the recommendations they provide to clients.
Such transactions may create a conflict of interest; however, Your PCG will never engage
in trading that operates to the client’s disadvantage if representatives of Your PCG buy or
sell securities at or around the same time as clients.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
Your PCG does not trade client’s accounts. However, Your PCG will recommend
AssetMark to clients.
10
1. Research and Other Soft-Dollar Benefits
Your PCG does not trade client’s accounts and therefore receives no research, product,
or services from a broker-dealer (“soft dollar benefits”).
2. Brokerage for Client Referrals
Your PCG receives no referrals from a broker-dealer or third party in exchange for
using that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
Your PCG does not trade client’s accounts or recommend broker/custodians, and
therefore does not direct brokerage.
B. Aggregating (Block) Trading for Multiple Client Accounts
Your PCG does not trade clients' accounts and therefore does not have the ability to block
trade purchases across accounts.
Item 13: Review of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those
Reviews
All client accounts for Your PCG's advisory services provided on an ongoing basis are
reviewed at least Annually by Todd D'Agostino, CCO & CFO, with regard to clients’
respective investment policies and risk tolerance levels. All accounts at Your PCG are
assigned to this reviewer.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews may be triggered by material market, economic or political events, or by changes
in client's financial situations (such as retirement, termination of employment, physical
move, or inheritance).
C. Content and Frequency of Regular Reports Provided to Clients
Each client of Your PCG's advisory services provided on an ongoing basis will receive a
monthly report detailing the client’s account, including assets held, asset value, and
calculation of fees. This written report will come from the custodian.
11
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered
to Clients (Includes Sales Awards or Other Prizes)
Your PCG has a relationship with AssetMark, Inc., an SEC registered investment adviser
CRD #109018, to use the asset allocation and individual account management platform
sponsored by AssetMark. AssetMark, Inc. Client will sign an Account Set-up and
Application Form to establish an account on the platform. AssetMark, Inc. will not
provide any advisory services to the client account. Your PCG is encouraged to utilize
AssetMark, Inc.’s advisor-directed tools, templates and best practices, or to engage with
AssetMark Inc. to provide education and guidance in implementing a growth plan for
their business. Certain Financial Advisors can receive an allowance or “growth support”
for reimbursement of qualified expenses incurred by the Financial Advisor based on their
participation in AssetMark sponsored events, marketing initiatives, or use technology
resources and tools. This program creates a financial incentive for Financial Advisors to
recommend that Clients invest assets through the AssetMark Platform. Clients will be
given Asset Mark’s brochure which will describe the platform and services of AssetMark,
Inc. in greater detail. There is no referral fee received by Your PCG as the firm's fee is
separate from AssetMark, Inc.
B. Compensation to Non – Advisory Personnel for Client Referrals
Your PCG does not directly or indirectly compensate any person who is not advisory
personnel for client referrals.
Item 15: Custody
Your PCG does not take custody of client accounts at any time. Custody of client’s accounts is
held primarily at the client’s custodian. Clients will receive account statements from the custodian
and should carefully review those statements for accuracy.
Item 16: Investment Discretion
Your PCG provides discretionary and non-discretionary investment advisory services to clients.
The Investment Advisory Contract established with each client outlines the discretionary
authority for trading. Where investment discretion has been granted, Your PCG generally
manages the client’s account and makes investment decisions without consultation with the client
12
as to what securities to buy or sell, when the securities are to be bought or sold for the account,
the total amount of the securities to be bought/sold, or the price per share.
Item 17: Voting Client Securities (Proxy Voting)
Your PCG will not ask for, nor accept voting authority for client securities. Clients will receive
proxies directly from the issuer of the security or the custodian. Clients should direct all proxy
questions to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
Your PCG neither requires nor solicits prepayment of more than $1,200 in fees per client,
six months or more in advance, and therefore is not required to include a balance sheet
with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet
Contractual Commitments to Clients
Neither Your PCG nor its management has any financial condition that is likely to
reasonably impair Your PCG’s ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
Your PCG has not been the subject of a bankruptcy petition in the last ten years.
13