Diversified Resources, LLC was founded in 1983 and has been a registered investment advisor
since 1993. We are also a broker-dealer, registered with the Financial Industry Regulatory
Authority (FINRA), the Municipal Securities Regulatory Board (MSRB) and the Securities
Industry Protection Corporation (SIPC). The Firm is owned by Karen J. Bacon, Principal, Chief
Executive Officer and Chief Compliance Officer.
We currently offer investment management services through a custom asset allocation
program and a third-party adviser, SEI Investment Management Corporation (SEI) whose
Custodian is SEI Private Trust Co. (SPTC). We also offer holistic financial planning services.
Diversified Resources, LLC (us, we or our) offers broad-based, modular, and consultative
financial planning services, as well as investment management services to you (you; your, which
will refer to you and/or your spouse or partner), based on your individual and family needs. To
determine the direction of our advice, you may be asked to complete our proprietary
Confidential Fact Finder, risk tolerance quiz and/or our proprietary Retirement Income
Questionnaire, which will help to identify your financial goals and objectives and to list your
liquid, non-liquid, tangible and intangible assets. Investment plans are based on your financial
situation at the time we present the plan to you, and on the financial and personal information
you provide to us.
Portfolio Management
We offer discretionary portfolio management services whereby our investment advice is
tailored to meet your needs and investment objectives. If you retain our Firm for portfolio
management services, we will initially meet with you to determine your investment objectives,
risk tolerance and other relevant suitability information. We will develop a strategy that will
enable our Firm to give you continuous and focused investment advice and to make
investments on your behalf. As part of our portfolio management services, we may customize
an investment portfolio for you in accordance with your risk tolerance and investment
objectives. We may also invest your assets in one or more model portfolios developed by our
Firm. Once we construct an investment portfolio for you, or select a model portfolio, we will
monitor your portfolio’s performance on an ongoing basis and may rebalance the portfolio as
required by changes in market conditions.
We offer portfolio management services through the SEI Asset Management Program (the
Program).
SEI Private Client Program
We provide our discretionary portfolio management services using our Private Client Program.
In our Private Client Program, we primarily invest your assets in mutual funds and/or exchange-
traded funds (ETFs) and such portfolios are comprised of a mix of asset classes which may be
based on one or more model portfolios. However, you may wish to transact in other types of
securities, such as individual stocks and fixed-income securities, through this account. Under
these circumstances, we will invest in these types of securities only upon specific direction from
you. Moreover, choosing to purchase/sell these types of securities in our Private Client Program
may cause the portfolio's percentage weightings in certain assets classes to be over- or under-
weighted. As a result, you may be exposed to more (or less) risk and may experience larger (or
smaller) performance returns in your account.
We require you to grant our Firm discretionary authority to manage your account. Discretionary
authorization will allow our Firm to determine the specific securities, and the amount of
securities, to be purchased or sold for your account without your approval prior to each
transaction. You may limit our discretionary authority (for example, limiting the types of
securities that can be purchased for your account) by providing our Firm with your restrictions
and guidelines in writing.
SEI Trust Private Trust Company may rebalance the investments within your account(s) at the
end of each calendar quarter (unless you choose an alternative rebalancing date, or decide to
not have the account rebalanced), so that the market value in each asset class in the account(s)
is within the normal weight range. You realize and understand that rebalancing in a taxable
(non-retirement) account will create a taxable loss or a taxable gain.
If you are in a specific investment model and we feel at some future date that it would be
appropriate, beneficial and timely to make an adjustment to that model for all of our clients
who are in it, you agree to give us authority to do so. This would not change the percentage in
your model. For example, if your investment model was 70% Global Stocks & 30% Global Bonds
and Cash, we would not change that percentage blend without obtaining your approval, but
within that blend (as an example) you held 4% in a particular bond fund and we saw more (or
less) opportunity in that fund for you going forward and commensurate with your overall goals,
you agree to give us authority to change that fund for another bond fund within or outside of
SEI’s fund selection and/or to raise or lower that percentage providing we stay within the
investment model percentages. There are no sales charges or commissions payable to us or to
SEI by making that adjustment. In a non-retirement taxable account an adjustment like this, just
as with the periodic rebalancing of your portfolio(s), will create a taxable gain or taxable loss.
For those SEI Funds which employ the ‘manager of managers’ structure, SEI Investments
Management Corporation (SIMC) has ultimate responsibility for the investment performance
of
the Funds due to its responsibility to oversee the sub-advisers and recommend their hiring,
termination and replacement. SIMC is the advisor to the SEI Funds, which are distributed by SEI
Investments Distributions Co. (SIDCO). Custody services are provided by the SEI Private Trust
Company (SPTC), a federally chartered limited purpose savings association. SIMC, SIDCO and
SPTC are wholly owned subsidiaries of SEI Investments Company. Neither SEI nor its
subsidiaries are affiliated with Diversified Resources, LLC.
Financial Planning
If you require advice on a single aspect of the management of your financial resources, we offer
financial plans in a modular format and/or general consulting services that address only those
specific areas of concern. These areas may include, but are not limited to, retirement planning,
education planning, insurance and risk management, income tax planning, business planning,
portfolio review and asset allocation, estate planning, and/or financial decision
making/negotiation.
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 with us or use any of the financial services or products we offer. You may act on our
recommendations through any other brokerage Firm, investment advisor, or provider of
investment or insurance products.
Tailored Advice
We tailor investment management services to the unique needs of each client.
Fiduciary Statement
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act,
(“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing
retirement accounts.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Wrap Fee Programs
We may recommend Wrap Fee Programs when they are suitable for the client.
Through our relationship with SEI Investment Management Company (SIMC) we offer Managed
Account Solutions (MAS) and Distribution Focused Strategies (DFS). They are wrap fee programs
which charge a bundled fee that includes advisory, brokerage and custody services. MAS and
DFS are subject to a separate administrative fee that is not part of the bundled fee as explained
in SIMC’s wrap fee program brochure. The wrap fee brochure can be found at
www.adviserinfo.sec.gov. All fees are disclosed prior to account application.
Under MAS and DFS, SIMC enters into a tri-party investment advisory agreement (Managed
account agreement) with Diversified Resources, LLC and the Client, which provides for the
management of Client assets allocated to MAS and DFS, in accordance with the terms of the
Managed Account Agreement. Pursuant to the Managed Account Agreement, the Client
appoints Diversified Resources, LLC as its investment advisor to assist the Client in selecting an
appropriate asset allocation strategy and selecting available sub-advisors that have been
assigned to the strategy by SIMC. The Client appoints SIMC, through its manager-of-managers
structure, to manage the assets in each portfolio in accordance with the strategy selected by
the Client together with Diversified Resources, LLC.
Assets Under Management
Diversified Resources, LLC has $209,109,584 under management as of December 31, 2023. All
assets under management are managed on a discretionary basis.