We provide individuals and other types of clients with a wide array of investment advisory services.
Our firm is a corporation formed in the State of Connecticut and has been in business as an
investment adviser since 2014. Our firm is owned by Kevin Kennedy, CPA (50%) and Gregory J.
Bunger, EA, CFP® (50%).
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.
Description of the Types of Advisory Services We Offer
Asset Management:
We emphasize continuous and regular account supervision. As part of our asset management service,
we generally create a portfolio, consisting of individual stocks or 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. Each portfolio will be initially designed to meet a particular investment goal,
which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been
determined, we review the portfolio at least twice a year and if necessary, rebalance the portfolio based
upon the client’s individual needs, stated goals and objectives.
Our firm may utilize the sub-advisory services of a third-party investment advisory firm or individual
advisor to aid in the implementation of an investment portfolio designed by our firm. Before selecting
a firm or individual, our firm will ensure that the chosen party is properly licensed or registered. Our
firm will not offer advice on any specific securities or other investments in connection with this service.
We will provide initial due diligence on third-party money managers and ongoing reviews of their
management of client accounts. 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 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.
Comprehensive Portfolio Management:
Our Comprehensive Portfolio Management service encompasses asset management as well as
providing financial planning/financial consulting to clients. It is designed to assist clients in meeting
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their financial goals using 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 twice a year. 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.
Our firm may utilize the sub-advisory services of a third-party investment advisory firm or individual
advisor to aid in the implementation of an investment portfolio designed by our firm. Before selecting
a firm or individual, our firm will ensure that the chosen party is properly licensed or registered. Our
firm will not offer advice on any specific securities or other investments in connection with this service.
We will provide initial due diligence on third-party money managers and ongoing reviews of their
management of client accounts. 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 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.
Financial Planning & Consulting:
We provide a variety of financial planning and consulting services to individuals, families, and other
clients regarding the management of their financial resources based upon an analysis of the client’s
current situation, goals, and objectives. Generally, such financial planning services will 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 one or more of the
following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning,
Education Planning, Corporate and Personal Tax Planning, Corporate Structure, Real Estate Analysis,
Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal
Financial Planning.
Our 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. For example,
recommendations may be made that the clients begin or revise investment programs, create or revise
wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or
establish education or charitable giving programs. It should also be noted that we refer clients to an
attorney or other specialist, as necessary for non-advisory related services. For written financial
planning engagements, we provide our clients with a written summary of their financial situation,
observations, and recommendations. For financial consulting engagements, we usually do not
provide our clients with a written summary of our observations and recommendations as the process
is less formal than our planning service. Plans or consultations are typically completed within six (6)
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months of the client signing a contract with us, assuming all the information and documents we
request from the client are provided to us promptly. Implementation of the recommendations will be
at the discretion of the client.
Pension Consulting:
We provide pension consulting services to employer plan sponsors on an ongoing basis. Generally,
such pension 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. All pension consulting services shall comply with the applicable state law(s)
regulating pension consulting services.
This applies to client accounts that are pension 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 we accept appointments to provide our services to such accounts, we
acknowledge that we are a fiduciary within the meaning of Section 3(21) of ERISA (but only with
respect to the provision of services described in section 1 of the Pension Consulting Agreement).
Trustee Support Services
We provide trustee support services to individual trustees and their Trust. As part of the Trustee
Support Services, the Trust, consisting of individual stocks, bonds, exchange traded funds (“ETFs”),
options, mutual funds and other public and private securities or investments, will be guided by the
Trustee and Investment Policy Statement (“IPS”). Our firm will draft an IPS under the guidance of the
Trustee and Trust document. An IPS will be drafted for each individual Trust and must be signed by the
Trustee. 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. The service to be provided by our firm is limited to the management of the Assets, fiduciary
accounting, and fiduciary income tax preparation, which shall include the preparation of one Form
1041 for each trust and does not include financial planning or consulting services. Our firm will never
act as a trustee on the accounts managed, the current trustee will retain all fiduciary decision-making
responsibilities.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Asset Management, Comprehensive
Portfolio Management, and Trustee Support services. Additionally, we offer general investment
advice to clients utilizing our Financial Planning & Consulting and Pension Consulting services.
Each client may 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
Asset Management, Comprehensive Portfolio Management, and Trustee Support services. We do not
manage assets through our other services.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
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Regulatory Assets Under Management
As of December 31, 2023, we manage $185,749,156 on a discretionary basis and $10,108,044 on a
non-discretionary basis.