Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company formed under the laws of the
State of Colorado in 2017 and has been in business as an investment adviser since that time. Our firm
is wholly owned by David Morgan and the Eric B. Rosel Revocable Trust.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Types of Advisory Services Offered
Asset Management:
As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds,
exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or
investments. The client’s individual investment strategy is tailored to their specific needs and may
include some or all of the previously mentioned securities. Portfolios will be designed to meet a
particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate
portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary,
rebalanced based upon the client’s individual needs, stated goals and objectives.
Comprehensive Portfolio Management:
As part of our Comprehensive Portfolio Management service, clients will be provided asset
management and financial planning or consulting services. This service is designed to assist clients
in meeting their financial goals through the use of a financial plan or consultation. Our firm conducts
client meetings to understand their current financial situation, existing resources, financial goals, and
tolerance for risk. Based on what is learned, an investment approach is presented to the client,
consisting of individual stocks, bonds, ETFs, options, mutual funds and other public and private
securities or investments. Once the appropriate portfolio has been determined, portfolios are
continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual
needs, stated goals and objectives. Upon client request, our firm provides a summary of observations
and recommendations for the planning or consulting aspects of this service.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
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plan sponsor dictate, areas of advising could include: investment options, plan structure and
participant education. Retirement Plan Consulting services typically include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic
asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
Referrals to Third Party Money Managers:
Our firm may utilize the services of a third-party money manager for the management of client accounts.
Investment advice and trading of securities will only be offered by or through the chosen third party
money manager. Our firm will not offer advice on any specific securities or other investments in
connection with this service. Prior to referring clients, our firm will provide initial due diligence on third
party money managers and ongoing reviews of their management of client accounts. In order to assist
in the selection of a third-party money manager, our firm will gather client information pertaining to
financial situation, investment objectives, and reasonable restrictions to be imposed upon the
management of the account.
Our firm will periodically review third party money manager reports provided to the client at least
annually. Our firm will contact clients from time to time in order to review their financial situation
and objectives; communicate information to third party money managers as warranted; and, assist
the client in understanding and evaluating the services provided by the third party money manager.
Clients will be expected to notify our firm of any changes in their financial situation, investment
objectives, or account restrictions that could affect their financial standing.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Asset Management, Comprehensive Portfolio
Management, Retirement Plan Consulting, and Referrals to Third Party Money Management clients.
Each client has the opportunity to place reasonable restrictions on the types of investments to be held
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in the portfolio. Restrictions on investments in certain securities or types of securities may not be
possible due to the level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm sponsors a wrap fee program, as further described in Part 2A, Appendix 1 (the “Wrap Fee
Program Brochure”). However, we have discontinued offering our wrap fee program to new clients.
Our firm does not manage wrap fee accounts in a different fashion than non-wrap fee accounts. All
accounts are managed on an individualized basis according to the client’s investment objectives,
financial goals, risk tolerance, etc.
Regulatory Assets Under Management
As of December 31st, 2023, our firm managed $409,864,243 on a discretionary basis, which was our
total amount of assets under management.