Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a corporation formed under the laws of the State of
California in 2006. Our firm is wholly owned by John Simon and Richard Toscano.
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
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.
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.
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
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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.
Institutional Intelligent PortfoliosTM
Our firm provides portfolio management services through Institutional Intelligent Portfolios™, an
automated, online investment management platform for use by independent investment advisers
and sponsored by Schwab Wealth Investment Advisory, Inc. (the “Program” and “SWIA,”
respectively). Through the Program, our firm offers clients a range of investment strategies we have
constructed and manage, each consisting of a portfolio of exchange traded funds (“ETFs”) and a cash
allocation. The client may instruct our firm to exclude up to three ETFs from their portfolio. The
client’s portfolio is held in a brokerage account opened by the client at SWIA’s affiliate, Charles
Schwab & Co., Inc. Our firm is independent of and not owned by, affiliated with, or sponsored or
supervised by SWIA, Schwab or their affiliates (together, “Schwab”). The Program is described in the
Schwab Wealth Investment Advisory, Inc. Institutional Intelligent Portfolios™ Disclosure Brochure
(the “Program Disclosure Brochure”), which is delivered to clients by SWIA during the online
enrollment process. The minimum investment required to open an account in the Program is $5,000.
Our firm, and not Schwab, is the client’s investment adviser and primary point of contact with respect
to the Program. Our firm is solely responsible, and Schwab is not responsible, for determining the
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appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio
for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. SWIA’s
role is limited to delivering the Program Disclosure Brochure to clients and administering the
Program so that it operates as described in the Program Disclosure Brochure.
Our firm has contracted with SWIA to provide the technology platform and related trading and
account management services for the Program. This platform enables our firm to make the Program
available to clients online and includes a system that automates certain key parts of the investment
process (the “System”). The System includes an online questionnaire that helps our firm determine
client investment objectives and risk tolerance and select an appropriate investment strategy and
portfolio. Clients should note that our firm will recommend a portfolio via the System in response to
the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio
that is one level less or more conservative or aggressive than the recommended portfolio, but our
firm will make the final decision and select a portfolio based on all the information made available
about the client. The System also includes an automated investment engine through which our firm
manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss
harvesting (if the client is eligible and elects).
Investment Management for Direct Mutual Fund Accounts:
Our firm may also provide investment management services with respect to allocations of previously
purchased direct mutual fund accounts. If applicable and if client decides to engage in this type of
service, client will sign a separate agreement and/or an additional addendum authorizing our firm
on a discretionary basis without prior consultant to buy, sell, and exchange account allocations within
their direct mutual fund accounts (pursuant to the predetermined investment objective guidelines).
Before any action is taken, our firm shall obtain the necessary financial circumstances, investment
objectives and any special instruction or limits from the client.
Account Monitoring:
Our firm provides account monitoring services in which we provide only for the housekeeping of
Client assets. Our firm will not manage the assets nor will our firm provide investment
recommendations. Clients are responsible to execute trades on their own. We may execute trades
only under the following circumstances: (1) under the Client’s specific instruction and direction;
and/or (2) to sell in order to raise cash to pay our firm’s advisory fee. Unless the Client requests
otherwise, our firm will sell the Client’s largest position in the event we need to raise cash to pay our
firm’s advisory fee.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Comprehensive Portfolio Management,
Institutional Intelligent PortfoliosTM, and Direct Mutual Fund Account clients. General investment
advice will be offered to our Financial Planning & Consulting, and Retirement Plan Consulting clients.
No advice will be offered to Account Monitoring clients. Each Comprehensive Portfolio 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 $228,057,952 on a discretionary basis and $371,170 on
a non-discretionary basis.