Kovitz is an investment adviser that provides investment management, wealth management, and financial planning
services. Kovitz has over 90 employees, and we provide our services to individual and institutional clients. Our
institutional clients include endowments, employee benefit (ERISA) plans, corporations, and other entities. We provide
our services from three main locations: our headquarters in Chicago (“Chicago Office”), and from our offices in Orange
County, California (“California Office”), and Madison, Wisconsin (“Madison Office”).
As of March 3, 2023, Kovitz managed approximately $7.2 billion of assets on a discretionary basis. We generally do not
manage assets on a non-discretionary basis. In addition, we calculate our assets under management on a “net” basis
(rather than gross), although the differences between the two are usually not significant.
Kovitz is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Kovitz is a wholly-owned
subsidiary of Focus Operating, LLC (“Focus Operating”), which is a wholly-owned subsidiary of Focus LLC. Focus
Financial Partners Inc. (“Focus Inc.”) is the sole managing member of Focus LLC and is a public company traded on the
NASDAQ Global Select Market. Focus Inc. owns approximately two-thirds of the economic interests in Focus LLC.
Focus Inc. has no single 25% or greater shareholder. Focus Inc. is the managing member of Focus LLC and has 100% of its
governance rights. Accordingly, all governance is through the voting rights and Board at Focus Inc.
Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business
managers, and other financial service firms (the “Focus Partners”), most of which provide wealth management, benefit
consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners
also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form
ADVs.
INVESTMENT MANAGEMENT – GENERAL
Our main business is providing discretionary investment advice to individuals and institutions in separate accounts
(further described below under the section entitled “Item 16. Investment Discretion”). We primarily invest each of our
client’s portfolios in equities (stocks) and/or fixed income (bond) securities. Each of our clients has his/her own account,
and the equities and bonds in the account are usually individual securities.
We first consult with our clients to understand their financial situation, such as their objectives for asset growth, income
and liquidity, principal protection, risk tolerance, and tax minimization.
Next, based on the above information, we recommend an initial target asset allocation for each client, generally meaning
the percentage of stocks and bonds to be put in the portfolio. After working with the client to select an appropriate asset
allocation, Kovitz generally implements it across the client relationship, or all of the client’s accounts (“allocation group”),
to the extent feasible. Generally, Kovitz manages an asset allocation at the allocation group level, which means there will
be variation as to asset allocation within a specific underlying account. In addition, if a client adds an account to their
relationship with us, we will add the account to the existing allocation group, with the agreed-upon asset allocation,
unless directed otherwise by the client. We meet with our clients to understand their needs, circumstances and objectives,
work with our clients’ other advisers, and rebalance, and periodically review the client’s asset allocation. We will consider
the client’s individual situation and the nature, position size, and suitability of specific securities when reviewing and
making purchase and sale decisions for each of our clients. In this manner, we tailor our investment management services
to the needs of our clients.
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Our clients may restrict us in the management of their accounts, such as the amount, type, or identity of stocks or bonds
to buy or sell, as long as they are reasonable, consistent with our professional responsibility and investment philosophy,
and allow us to substantially implement our investment strategies.
As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and
state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our
agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or
as a waiver of any unwaivable rights you possess.
Additionally, Kovitz is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with
respect to investment management services and investment advice provided to ERISA plan clients, including ERISA plan
participants. Kovitz is also a fiduciary under section 4975 of the Internal Revenue Code (the “IRC”) with respect to
investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans,
and ERISA plan participants (collectively, “Retirement Account Clients”). As such, Kovitz is subject to specific duties and
obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to
prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest,
the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”).
INVESTMENT MANAGEMENT – CALIFORNIA OFFICE
Kovitz also offers discretionary investment advice on individual securities to clients by way of its California office through
various strategies in separately managed accounts. The California Office’s philosophy includes primarily investing in
equity securities that are considered out-of-favor and undervalued by the investing public. The philosophy also includes
holding them until they have reached what their investment team believes is a reasonable fair value, or until the team finds
equity candidates with what it believes are more attractive risk/reward attributes, or the particular equity’s risk/reward
profile does not justify continued ownership. Kovitz California generally implements it strategy on an account basis
instead of across all of the client’s accounts. Additional details about the California Office’s strategies are further
described in the sections entitled, “Equities – California Office,” “ETFs – California Office,” and “The Prudent Speculator
– California Office.”
INVESTMENT MANAGEMENT – MADISON OFFICE
In addition, Kovitz offers discretionary investment advice through various strategies in separately managed accounts via
its Madison Office. The Madison Office’s philosophy includes investing primarily in equity and fixed income securities,
along with exchange-traded funds (“ETFs”) and mutual funds. Client accounts in these strategies can solely hold equities,
solely fixed income securities, or a combination of several security types. The philosophy of the Madison Office is suited
for those who share their belief in long-term investment strategies. Kovitz Madison generally implements it strategy on an
account basis instead of across all of the client’s accounts. Additional details about strategies offered by the Madison
Office are further described in the sections entitled, “Equities – Madison Office” and “Fixed Income Securities – Madison
Office.”
EQUITIES – GENERAL
For the equities portion of our clients’ portfolios, we seek to maximize total return through a combination of long-term
capital appreciation and the receipt of dividends and income while maintaining an emphasis on the preservation of
capital. We approach buying equities for our clients as if we are part owners of businesses, not traders of stocks. We look
to maximize the investment return we achieve given the investment risk we take. We view risk as the odds of a permanent
loss of capital and not volatility of returns. We believe purchasing stock in competitively advantaged and financially
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strong companies at prices substantially less than our assessment of their intrinsic (business) value is the best way to
preserve client capital over long periods of time. Generally, the companies we invest in are usually larger capitalization
companies.
EQUITIES – CALIFORNIA OFFICE
The equity strategies (the ones that are currently “marketed” to current and prospective clients of the California Office)
include the following:
The Kovitz ValuePlus strategy (also known as “Kovitz Dividend Value,” which combined the strategies formerly
known as “Al Frank Value” and “Al Frank Select Value”) includes both dividend and non-dividend paying stocks
and seeks broad diversification through exposure to a significant number of major market sectors and industry
groups. For client accounts in this strategy, the investment team in the California Office typically builds
portfolios containing 70 – 90 stocks.
The Kovitz Focused ValuePlus strategy (formerly known as “Al Frank Select Focused Value”) seeks long-term
capital appreciation by investing in a more concentrated portfolio of stocks across major market sectors and
industry groups. For client accounts in this strategy, the California Office investment team typically builds
portfolios containing roughly 30 – 40 stocks.
The Kovitz Dividend Income strategy (which combined the strategies formerly known as “Al Frank Dividend
Value” and “Al Frank Select Dividend Value”) includes dividend paying stocks, and seeks broad diversification
through exposure to a significant number of major market sectors and industry groups. For client accounts in
this strategy, the California Office investment team typically builds portfolios of equally weighted positions
containing 60 – 80 stocks.
The Kovitz Focused Dividend strategy (formerly known as “Al Frank Select Focused Dividend”) seeks long-term
capital appreciation and dividend income through mostly dividend-paying stocks, and seeks broad
diversification through exposure to major market sectors and industry groups. For client accounts in this
strategy, the California Office investment team typically builds portfolios that contain roughly 30 – 40 stocks.
The Kovitz Small-Mid Dividend Value strategy (formerly known as “Al Frank Select Small-Mid Dividend Value”)
includes primarily micro, small, and mid-cap dividend paying stocks, and seeks broad diversification to a
significant number of major market sectors and industry groups, although market appreciation sometimes results
in these stocks moving into what is known as the “large-cap” category. For client accounts in this strategy, the
investment team in the California Office typically builds portfolios containing 70 to 90 stocks.
The Prudent Speculator strategy generally mirrors the TPS portfolio (“TPS Strategy”), the basis for “The Prudent
Speculator” newsletter (which is further described below). The TPS Strategy includes both dividend and non-
dividend paying stocks and seeks broad diversification through exposure to a significant number of major market
sectors and industry groups. For clients in the TPS Strategy, the investment team in the California Office
typically builds portfolios that initially contain 70 to 90 positions.
EQUITIES – MADISON OFFICE
The primary goal of the equity strategies managed by the Madison Office (whether as part of stock-only portfolio, or as
part of a “balanced” portfolio containing a mix of equities and bonds) is to provide performance returns from a diversified
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portfolio of stocks that exceed appropriate benchmarks, such as the S&P 500 Index. The Madison Office’s equity
strategies typically include a mix of small-, mid-, and large-capitalization domestic and international stocks.
The investment team in the Madison Office uses internal and external research to help identify companies where the
current market prices do not correctly reflect the team’s opinion of the underlying value or future growth potential. The
team’s decisions to buy or sell securities are based on expected return, as well as the potential impact of the transactions
on the applicable clients’ overall diversification. For certain client account groups, the team also uses cash (and/or cash
equivalents) as a way to help reduce market risk at times when it believes the overall stock market is unattractive on a
risk/return basis, or to enhance the client’s portfolio yield and/or liquidity.
FIXED INCOME SECURITIES – GENERAL
For the bond portion of our clients’ portfolios, we focus on diligent execution and high credit quality. We take into
consideration our client’s tax situation, the type of issuer and bond, and general market conditions when we construct
bond portfolios for our clients. Depending on the client’s needs, market conditions, and pricing, we typically purchase the
following types of bonds for our clients:
Taxable, tax-free, and alternative minimum tax (AMT) municipal bonds;
Municipal bonds;
Corporate bonds;
Mortgage-Backed Securities; and
U.S. Treasury and government agency bonds.
Our goal is to capture excess yield without incurring additional risk. We primarily try to accomplish this by patiently
bidding on bonds owned by third party bond sellers, by finding bonds with perceived complexity and liquidity risks, and
by our willingness to buy odd (smaller) lots of bonds. The demand for these kinds of bonds is typically lower, and
therefore we attempt to buy them at lower prices (and higher yields) for our clients.
The firm primarily uses a network of third-party dealers and electronic trading platforms to help construct fixed income
portfolios for clients. Please refer to the “Directed Brokerage” section under “Item 12. Brokerage Practices” for examples of
these brokers.
We generally buy bonds with the intent to hold to maturity, and therefore we are less concerned about interim price
changes.
We do not keep bonds in an inventory for later sale to our clients. We buy bonds for direct allocation to specific client
accounts based on the specific client’s asset allocation and circumstances.
Depending on our specific client’s investment objective, we will typically build a bond ladder of individual bonds maturing
in different years in order to provide liquidity, an income stream, and to help guard against interest rate and credit risk.
FIXED INCOME SECURITIES – MADISON OFFICE
The primary goal of the fixed income strategy of the Madison Office (whether as part of a bond-only portfolio, or a
balanced portfolio containing a mix of equities and bonds) is to provide performance returns from a diversified portfolio
of bonds that exceed industry-recognized benchmarks, such as the Barclays Intermediate Government/Credit Index. The
fixed income strategy typically includes a mix of U.S. Treasury and government agency bonds; investment and below-
investment grade corporate bonds; convertible bonds; municipal bonds; mutual funds; and fixed income ETFs.
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The Madison Office investment team evaluates and selects fixed income securities based on its assumptions about
interest rates, the treasury yield curve, company-specific risk, and other variables that will impact the relative performance
of the security. Similar to what it does for its equity (and balanced) strategies for certain client account groups, the team
uses cash (and/or cash equivalents) when it believes that the fixed income market is unattractive on a risk/return basis or
to enhance the client’s portfolio yield and/or liquidity.
OTHER TYPES OF SECURITIES
OPTIONS
We use option transactions in conjunction with our day-to-day management of clients’ equity investments. We primarily
do this by selling covered calls. Our clients own the stock and, in return for a premium, we sell to a third party the right to
buy the stock at a certain price by a certain date. We usually do this for tax reasons to extend the holding period so our
clients can get more favorable long-term capital gains tax treatment. When option prices are volatile, we have also sold
covered calls to generate income for clients and to manage their sector exposures. Typically, we will sell “at the money”
calls (where the call strike price is near the underlying stock’s market price) in order to maximize the premium that the
client receives.
We also use other option strategies as a way for clients to earn income while
waiting to invest their assets in our primary
equity strategy. We accomplish this by, for example, buying or selling options on index-tracking ETFs, or by selling puts
on our equity recommendations. The goal of these strategies is to supplement the firm’s primary equity investment
strategies as a way to enhance client returns.
MUTUAL FUNDS
Open-End Mutual Funds
Occasionally, we recommend investments in no-load, open-end mutual funds instead of individual equity or fixed income
securities. We believe this is appropriate for diversification in smaller accounts below our recommended investment
minimums (described below in the section entitled “Types of Clients”) or to gain access to sectors outside of our core
investment strategies, and usually at a client’s request.
Al Frank Fund
We also manage an affiliated mutual fund, the Al Frank Fund (ticker: VALAX). The Al Frank Fund is an advisory client of
Kovitz, and Kovitz generally intends to manage the Al Frank Fund according to the same strategy as that of its separate
(equity) account clients that are managed by the investment team in the California Office. Depending on the prospective
client or client’s investment objectives and risk tolerance, the California Office generally recommends the Al Frank Fund
for those clients who have assets below applicable investment minimums (refer to the section below entitled “Types of
Clients”), or otherwise for clients and prospective clients who we believe would be better served by the diversification that
we intend for the Al Frank Fund to provide. Please refer to the Al Frank Fund prospectus for more information, or the
website (www.alfrankfunds.com).
Absolute Capital Opportunities Fund
In addition to the mutual funds noted above, we are the sole sub-adviser of an affiliated mutual fund, the Absolute Capital
Opportunities Fund (ticker: CAPOX). The primary adviser of CAPOX has hired us to manage the fund consistent with,
and according to the same long/short equity strategy as our affiliated hedge funds (which we further describe below).
Depending on the prospective client or client’s investment objectives and risk tolerance, we also recommend CAPOX to
our clients as a way to diversify a traditional portfolio of equity and bond investments. Our goal is for CAPOX investors
to achieve returns that do not always directly relate to those in the equity markets, and to preserve capital significantly
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better than “unhedged” equity investments. We believe CAPOX is suitable for advisory clients who have assets below our
“separate account” or hedge fund investment minimums, and for those who desire daily liquidity, as it is a publicly
registered mutual fund. Please refer to the CAPOX prospectus for more information, or the CAPOX website
(www.absoluteadvisers.com/absolute-capital-opportunities-fund/fund-overview).
ETFS – GENERAL
Similar to our approach with open-end mutual funds, we occasionally recommend investments in ETFs instead of
individual equity or fixed income securities. We believe this is appropriate for diversification in smaller accounts below
our recommended investment minimums, to gain access to sectors outside of our core investment strategies, or at a
client’s request. Additionally, we leverage ETFs as a strategy where we use passively managed indexes by using various
index ETFs to give our clients direct exposure to the various markets. In addition, we use active ETF’s, such as EQTY, for
a portion of a client’s equity portfolio.
Kovitz Core Equity ETF
We manage an affiliated ETF, the Kovitz Core Equity ETF (ticker: EQTY) (“EQTY”). EQTY is an advisory client of Kovitz,
and Kovitz generally intends to manage EQTY according to the same strategy as that of its separate (equity) account
clients that are managed by the investment team in the Chicago Office. Depending on the prospective client or client’s
investment objectives and risk tolerance, the Chicago Office generally recommends EQTY for those advisory clients who
have assets below our investment minimums (refer to the section below entitled “Types of Clients”), or otherwise for
clients and prospective clients who we believe would be better served by the diversification that we intend for EQTY to
provide. Please refer to the EQTY prospectus for more information, or the EQTY website (www.Kovitz.com/eqty).
ETFS – CALIFORNIA OFFICE
Aside from our general use of ETFs in the context described above, the California Office recommends strategies that
invest in portfolios of ETFs, with the goal of outperforming applicable benchmarks on a risk-adjusted basis through
diversification; active management; style integrity; minimized security selection risk; trading; and cost efficiency. The
California Office offers the following ETF strategy:
Kovitz Global Value (also known as Dynamic Portfolio Series (“DPS”))
The Dynamic Portfolio Series seeks opportunities in U.S. equities, developed international equities, emerging and frontier
market equities, commodities, REITs and global fixed income. The family of portfolios seek to provide long-term absolute
return through a combination of enhanced diversification and tactical management of portfolio-level exposures to
valuation and behavioral factors over time. The valuation factors ensure the portfolio maintains a preference to
exposures with strong fundamentals, while the behavioral factor seeks to capitalize on near-term opportunities. The
country rotation segment of the strategy seeks to provide complimentary returns through enhanced diversification at the
individual country equity market level. In strategies with lower risk tolerance, a Fixed Income portion acts as a ballast
during challenging market conditions, while maximizing income for a set level of risk.
ETFS – MADISON OFFICE
The Madison Office’s strategies occasionally use ETFs with the goal of increasing diversification and enhancing returns.
The investment team believes certain ETFs can provide client portfolios with exposure to investment opportunities that
fall outside the team’s traditional research universe, such as market segments (market capitalization or style),
international, alternative investment, or sectors where the team believes that individual stock selection does not
adequately reflect the desired exposure for the client.
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ETFS – HEDGED FUNDS AND RELATED ACCOUNTS
In managing our affiliated hedge funds and certain separately managed accounts (described below under “Hedge Funds”),
we take short positions in ETFs that are sometimes held as long positions in individual advisory client accounts. We
acknowledge the potential conflict of interest in making such recommendations. However, we believe that it is not
inconsistent or disadvantageous to a particular client to use ETFs in the hedge funds as part of an overall hedging
strategy (and not necessarily as an assertion of our view on the sector covered by the ETF), and also as a way to gain
exposure in a diversified manner to that same sector for a particular advisory client. We have considered that it is unlikely
that our trading activities would impact the price of ETFs, and that their use for individual advisory clients is not a
significant part of the firm’s overall assets under management.
COLLATERALIZED MORTGAGE OBLIGATIONS
If suitable for a particular client, we also recommend investments in collateralized mortgage obligations (CMOs), also
known as mortgage-backed securities (MBS). This recommendation depends on the client’s investment objectives and
risk tolerance, and is part of the client’s overall asset allocation.
HEDGE FUNDS AND OTHER PRIVATE PLACEMENTS
Kovitz manages hedge funds in which clients and others are solicited to invest. All such funds are limited to accredited
investors. The hedge funds generally invest in equities and options. Kovitz also provides services to, or certain of its
employees are otherwise involved in several private real estate funds in which clients and others have been solicited to
invest. These funds are limited to accredited investors, and their objectives are to invest in properties across the real
estate sector, including industrial, commercial, and residential. In addition, certain of Kovitz’s executive officers own a
separate company that sponsors and manages private equity funds. All such funds are limited to accredited investors.
The private equity funds’ primary investment objectives are to acquire controlling interests in existing companies and to
make other investments.
WRAP AND UNIFIED MANAGED ACCOUNT PROGRAMS
We also participate in several wrap, Unified Managed Account (UMA), and other “turnkey” asset management programs
(TAMPs), although we do not “sponsor” any such programs. In these cases, the sponsors of such programs typically have
contracts directly with their clients to perform various types of investment management services. For UMA programs, the
sponsors hire us to deliver “model” portfolios to them. We generally apply the same equity investment philosophy and
strategy for clients of wrap and UMA programs as we do for our own separate account clients, depending upon the
strategy for which they’ve hired us, and depending upon any restrictions, limitations, or specific directions that the
sponsors or their clients give to us. The sponsors of the wrap and UMA programs generally charge their clients an
aggregated or “all-inclusive” fee, and we receive a portion of those fees.
THE PRUDENT SPECULATOR – CALIFORNIA OFFICE
Kovitz publishes “The Prudent Speculator” (“TPS”), an investment newsletter which is written by the investment team in
the California Office, and charges an annual subscription fee. TPS provides frequent commentary about the financial
markets, macro-economic trends, and individual equities to subscribers. TPS also issues commentaries centered around
equity recommendations, provides “sales alerts” when the TPS “newsletter portfolios” sell certain equities, and provides
subscribers access to holdings reports. The holdings report allows subscribers to “mirror” the activities and holdings of
their own personal securities accounts to TPS recommendations if they wish. Separate account clients in the firm’s
California Office receive a complimentary subscription to TPS.
FINANCIAL PLANNING SERVICES
Kovitz also provides financial planning services (Planning Services) to certain investment management clients. The
Planning Services include the following: analyses regarding retirement cash flows; goal identification and funding; Monte
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Carlo simulations; education funding; estate planning; tax planning; and charitable giving. Kovitz determines client
eligibility for Planning Services on a case-by-case basis. Kovitz will consider the size of the client relationship and whether
the client uses other financial advisers in determining whether to offer Planning Services. Kovitz generally does not
charge fees for Planning Services in addition to the fees it charges for investment management services.
The scope of Planning Services is agreed upon by Kovitz and the client, although Kovitz and its clients typically do not
execute formal, written “agreements” in this context, as Kovitz provides the services to complement its day-to-day,
ongoing investment management services. Kovitz acknowledges that if it provides Planning Services and investment
management services to a particular client, there is a potential conflict of interest in making and implementing planning
and investment recommendations to the client. The conflict is that the planner is a Kovitz employee and will have an
incentive to choose to use or recommend Kovitz as investment manager. We believe that the conflict is addressed by the
aligned long-time horizon of the client, the Kovitz planner, the Kovitz investment professionals, and by the fact that the
Kovitz employees are not compensated in a manner that will incentivize inconsistent or short-term recommendations.
Kovitz uses a combination of its Certified Financial Planner™ (CFP®) Professionals, non-CFP Professionals, and certified
public accountants (CPAs) in the process of gathering and analyzing client information, in providing recommendations to
the client, and in providing Planning Services.
FAMILY OFFICE SERVICES
In addition to Planning Services, Kovitz offers “Family Office Services” to certain investment management clients. The
Family Office Services include the following: comprehensive reviews and monitoring of clients’ investment assets,
including investment strategies and assets that are not directly managed by Kovitz; tax planning and services; family
succession planning and education; bookkeeping; insurance advice; and bill paying services, among other things. Kovitz
determines eligibility for Family Office Services on a case-by-case basis. Kovitz typically charges fixed, hourly, or “project-
based” fees for Family Office Services, depending on the nature of services provided. These fees may or may not separate
from the firm’s standard “asset-based” fees that it charges for ongoing investment management The exact fee structure is
laid out in an engagement letter executed by the client.
Kovitz uses a combination of its Certified Financial Planner™ (CFP®) Professionals, non-CFP Professionals, and CPAs in
the process of providing Family Office Services to clients.
THIRD-PARTY MANAGERS
Kovitz will leverage the use of unaffiliated third-party managers in some limited situations. Kovitz uses these managers for
their expertise and/or services to manage a portion of the client’s assets. Kovitz will use outside managers for clients that
are looking for active management and exposure to a wide array of asset classes. Kovitz may recommend to client, or
engage on client’s behalf, one or more third-party managers to provide access to these different strategies and/or asset
classes. The selection or replacement of any third-party manager will be based on Advisor’s discretion or by client’s
acceptance, depending on outside manager’s structure. These third-party managers will have discretion over the assets
allocated to them and Kovitz will have no ability to affect the trading decisions of said manager.
Kovitz will evaluate the third-party manager initially and on an ongoing basis to confirm whether the manager is suitable
for Kovitz clients. Kovitz will review, among other things, the manager’s performance and management, background,
specialized knowledge, expertise investment objective, and fees. In these instances, client pays Kovitz’s advisory fee in
addition to the fee charged by the outside manager for the assets allocated to the outside manager. This is a conflict as
client could invest directly with the outside manager without having to pay Kovitz’s advisory fee. Kovitz reduces this
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conflict by adding value to the outside manager relationship by performing initial due diligence on the manager and
ongoing monitoring of the manager and their performance.
BUSINESS RELATIONSHIPS
We have a business arrangement with Strategic Wealth Partners Group, LLC (“SWP”) under which certain clients of SWP
have the option of investing in certain private funds that we manage. Kovitz is an affiliate of SWP by virtue of being under
common control with it, through Focus LLC. Please see Items 5 and 10 of this Brochure for further details.
Additionally, we have a business arrangement with Institutional and Family Asset Management, LLC (“IFAM”) under which
Kovitz refers certain retirement plan clients to IFAM. Kovitz is an affiliate of IFAM by virtue of being under common
control with it, through Focus LLC. Please see Items 5, 10 and 14 of this Brochure for further details.
Finally, we have a business arrangement with a subsidiary or subsidiaries of Origin Investments Group, LLC (“Origin”), who
are each an indirect, wholly-owned subsidiary of Focus LLC, under which certain clients of Kovitz have the option of
investing in certain private investment vehicles managed by Origin. Kovitz is an affiliate of Origin by virtue of being under
common control with it. Please see Items 5, 10, and 11 of this Brochure for further details.
FOCUS TREASURY & CREDIT SOLUTIONS (“FTCS”)
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions with
the assistance of our affiliate, Focus Treasury & Credit Solutions, LLC (“FTCS”), a wholly owned subsidiary of our parent
company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of these services and other
important information.