href="https://www.fca.org.uk/consumers"> at https://www.fca.org.uk/consumers. The process begins with your authorization for BGAN to request a statement of benefit from the existing UK pension plan administrator or trustee. If suitable and in the client’s best interest, and in conjunction with an FCA regulated advisor with the relevant permissions for the transfer of Safe Guarded Benefits for defined benefit plans, BGAN will assist with a transfer of pension assets to a Self-Invested Personal Pension ("SIPP"), a Qualifying Recognised Overseas Pension Scheme ("QROPS"), and/or other applicable plans. Pension assets are held by a regulated pension trustee (authorized by the relevant financial services regulator where the pension plan is held) and subject to the terms and conditions of a separate agreement between the client and the pension trustee. March 2024 Form ADV Part 2A 8 of 42 Your BGAN Advisory Representative will provide ongoing management of your pension assets. Management strategies can include the use of a third party selected investment manager (aka discretionary fund management (DFM)) (subject to the terms and conditions of a separate management agreement between the client's pension trustee and the investment manager). Assets are managed within a life bond platform such as: Utmost, Quilter or RL360 or on an investment platform such as: Novia; MorningStar (formerly Praemium,), Ardan International, or Capital International Group. Clients are encouraged to review the agreement between the client and the pension trustee and other disclosure materials (such as Key Features documents) provided by the pension trustee and the investment manager for a full understanding of the services provided and any associated costs therein. Clients will receive a written assessment and recommendations of their pension review. Additionally, pension plan statements and other reports are generally sent directly to clients on an annual basis (unless requested more frequently) by the selected pension trustee, the custodian of record, and/or others similarly involved with the client pension plan. Clients are encouraged to review such material carefully for a complete understanding of the services offered and the costs associated with the management of such pension plans. BGAN does not provide tax advice including, without limitation, in relation to any US tax reporting requirements and/or other tax implications arising in relation to clients' pension transfers. BGAN recommends the clients seek their own tax advice, including in relation to procedures under tax treaties between the United States and the UK (or other applicable jurisdiction) for the avoidance of double taxation on their UK/EU pension arrangements. General Information Investment recommendations and advice offered by BGAN are not legal advice or accounting advice. You should coordinate and discuss the impact of financial advice with your attorney and/or accountant. You are advised that it is necessary to inform BGAN promptly with respect to any changes in your financial situation and investment goals and objectives. Failure to notify BGAN of any such changes could result in investment recommendations not meeting your needs. C. BGAN tailors the advisory services it offers to your individual needs. You may impose restrictions and/or limitations on the investing in certain securities or types of securities. Services will begin with an initial consultation and data gathering. Your Advisory Representative will ask you various questions about your financial situation and request certain documents about your financial accounts. You may be asked to complete a fact finder or data gathering document. The information gathered by BGAN will assist BGAN to provide you with the requested services and customize the services to your financial situation. Depending on the services you have requested, BGAN will gather various financial information and history from you including, but not limited to:
• Retirement and financial goals
• Investment objectives
• Investment horizon
• Financial needs
• Cash flow analysis March 2024 Form ADV Part 2A 9 of 42
• Cost of living needs
• Education needs
• Savings tendencies
• Other applicable financial information required by BGAN in order to provide the investment advisory services requested. IRA Rollover Considerations When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. As part of our consulting and advisory services, we offer you recommendations and advice concerning your employer retirement plan or other qualified retirement account. Our recommendations can include you consider withdrawing the assets from your employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA"). Further, we offer our management services be applied to those funds and securities rolled into an IRA or other account for which we will receive compensation. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as described above under Item 5. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us. It is important for you to understand many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: 1. Leave the funds in your employer's (former employer's) plan. 2. Move the funds to a new employer's retirement plan. 3. Cash out and taking a taxable distribution from the plan. 4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage it is important you understand the following: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. March 2024 Form ADV Part 2A 10 of 42 a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans often have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the costs of those products and services. c. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. In the event your plan offers asset management or model management, there may be a fee associated with the services that is more or less than our asset management fee. 3. Our strategy can have higher risk than the option(s) provided to you in your plan. 4. Your current plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost. 5. If you keep your assets titled in a 401k or retirement account, you could delay your required minimum distribution beyond age 73. (You must take your first required minimum distribution for the year in which you turn age 73 (70 ½ if you reached 70 ½ before January 1, 2020 or 72 if you reached 72 prior to January 1, 2023). If you reach 70½ in 2020 or 72 in 2022, you have to take your first RMD by April 1 of the year after you reach the aforementioned age prior to the stated years age. For all subsequent years, including the year in which you were paid the first RMD by April 1, you must take the RMD by December 31 of the year. (Source IRS.gov)) 6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. D. Wrap Program. BGAN does not offer a wrap fee program. Clients will pay a fee for asset management services, third-party manager(s) or strategist(s) if used, and transaction fees. March 2024 Form ADV Part 2A 11 of 42 E. Assets Under Management. As of December 31, 2023, BGAN has $291,581,847 of regulatory assets under management. Of that number, $489,981 was managed on a non- discretionary basis. The remainder was managed on a discretionary basis. Some of our investment adviser representatives (IAR) are also registered with Hoxton Capital Management (“Hoxton”). Services provided through Hoxton are supervised by their Chief Compliance Officer. Some services available to investors may not be available at both firms. In those situations, you must either forgo the service or do business with your IAR through the offering firm. Your IAR will provide you with disclosure and a client agreement that indicates the firm through which they are providing the service. In situations where the investor is conducting business with both affiliates, contracts for each will be executed.