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 California in 2017 and has been in business as an investment adviser since that time. Our
firm is wholly owned by a Trust owned by Igor Lotsvin and Caroline Novak.
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 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.
Our firm may utilize the sub-advisory services of a third party investment advisory firm (“Sub-
Adviser”) or separately managed account (“SMA”) to aid in the implementation of an investment
portfolio. Before selecting a Sub-Adviser or SMA, our firm will ensure that the chosen party is
properly licensed or registered.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
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Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial
planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming
that all the information and documents requested from the client are provided promptly, plans or
consultations are typically completed within 6 months of the client signing a contract with our firm.
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
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.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Asset Management clients. General
investment advice will be offered to our Financial Planning & Consulting and Retirement Plan
Consulting clients. Each Asset Management client has the opportunity to place reasonable restrictions
on the types of investments to be held 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.
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Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2023, our firm manages $712,243,670.82. All of these assets are managed on a
discretionary basis.