use of financial investments. We conduct at least
one, but sometimes more than one meeting (in person, if possible, otherwise via telephone
conference) with clients to understand their current financial situation, existing resources,
financial goals, and tolerance for risk. Based on what we learn, we propose an investment
approach to the client. We may propose an investment portfolio, consisting of exchange
traded funds (“ETFs”), mutual funds, individual stocks or bonds, or other securities. Upon the
client’s agreement to the proposed investment plan, we work with the client to establish or
transfer investment accounts so that we can manage the client’s portfolio. Once the relevant
accounts are under our management, we review such accounts on a regular basis and at least
quarterly. We may periodically rebalance or adjust client accounts under our management.
If the client experiences any significant changes to his/her financial or personal
circumstances, the client must notify us so that we can consider such information in
managing the client’s investments.
(iii) 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 may 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.
• Participant Education – Our firm will provide opportunities to educate plan
participants about their retirement plan offerings, different investment options, and
general guidance on allocation strategies.
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.
C. Explanation of whether (and, if so, how) we tailor our advisory services to the individual needs
of clients, whether clients may impose restrictions on investing in certain securities or types of
securities.
(i) Individual Tailoring of Advice to Clients:
We offer individualized investment advice to clients utilizing our Comprehensive Portfolio
Management service. Additionally, we offer general investment advice to clients utilizing our
firm’s Pension Consulting Service.
(ii) Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of
Securities:
Each 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.
Restrictions would be limited to our Comprehensive Portfolio Management service. We do
not manage assets through our other services.
D. Participation in Wrap Fee Programs.
Our firm does not offer or sponsor a wrap fee program.
E. Disclosure of the amount of client assets we manage on a discretionary basis and the amount of
client assets we manage on a non-discretionary basis as of December 31st, 2022.
We manage
1 $131,593,680 on a discretionary basis and $16,974,952 on a non-discretionary
basis.