A. Description of the Advisory Firm
The Professional Financial Company LLC dba PROFi (hereinafter “PROFi”) is a Limited Liability
Company organized in the State of Utah. The firm was formed in September 2015, applied for
registration as an investment adviser in February 2017, and became registered as an investment
adviser in May 2018. [The entity did not provide any business activities until after it was approved
as an investment adviser in June 2018.] The principal owner (via The W. Bruce Miller Revocable
Trust) is William Bruce Miller.
B. Types of Advisory Services
Portfolio Management Services
PROFi offers ongoing portfolio management services based on the individual goals, objectives, time
horizon, and risk tolerance of each client. PROFi creates an Investment Policy Statement for each
client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and
then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation.
Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
PROFi evaluates the current investments of each client with respect to their risk tolerance levels and
time horizon. PROFi will request discretionary authority from clients in order to select securities and
execute transactions without permission from the client prior to each transaction. Risk tolerance
levels are documented in the Investment Policy Statement, which is given to each client.
PROFi seeks to provide investment decisions made in accordance with the fiduciary duties owed to
its accounts and without consideration for PROFi’s economic, investment or other financial interests.
To meet its fiduciary obligations, PROFi attempts to avoid, among other things, investment or trading
practices that systematically advantage or disadvantage certain client portfolios, and accordingly,
PROFi’s policy is to seek fair and equitable allocation of investment opportunities/transactions
among its clients to avoid favoring one client over another over time. It is PROFi’s policy to allocate
investment opportunities and transactions it identifies as being appropriate and prudent, including
initial public offerings ("IPOs") and other investment opportunities that might have a limited supply,
among its clients on a fair and equitable basis over time.
Pension Consulting Services
PROFi offers consulting services to pension or other employee benefit plans (including but not
limited to 401(k) plans). Pension consulting may include, but is not limited to:
• Identifying investment objectives and restrictions
• Providing guidance on various assets classes and investment options
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• Recommending money managers to manage plan assets in ways designed to achieve
objectives
• Monitoring performance of money managers and investment options and making
recommendations for changes
• Recommending other service providers, such as custodians, administrators and broker-
dealers
• Creating a written pension consulting plan
These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance
of the plan and its participants.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
management; tax concerns; retirement planning; estate protection; education planning;
insurance planning; net worth, cash flow, and debt/credit planning.
Insurance Services
PROFi does not directly offer insurance products for sale to customers. However, PROFi is a member
of DPL Financial Partners, LLC (“DPL”), which is a third-party provider of a platform of insurance
consultation services to investment advisers with clients who have current or future needs for
insurance products. DPL's services are available to PROFi’s clients for a fixed annual fee paid by
PROFi. Through its licensed insurance
agents, who are also registered representatives of The Leaders
Group, Inc. (“The Leaders Group”), an unaffiliated SEC-registered broker-dealer and FINRA member,
DPL offers our clients services relating to commission free insurance products. These services
include, among others, providing our clients with analyses of our current methodology for evaluating
client insurance needs, educating and acting as a resource for us regarding insurance products
generally and specific insurance products owned by our clients or that our clients are considering
purchasing, and provides us access to, and marketing support for, commission free insurance
products.
For providing platform services, DPL receives service fees from the insurers that offer their
commission free products through the platform to clients. These service fees are based on the
insurance premiums received by the insurers from clients who purchase through the DPL platform.
We do not receive any commissions or other payments from our client’s purchases of insurance
policies. Our fees are limited to the management of the insurance policies’ separate accounts, for
which we charge a management fee as disclosed in Item 5. Clients are under no obligation to
purchase insurance through DPL.
Services Limited to Specific Types of Investments
PROFi generally limits its investment advice to mutual funds, fixed income securities, real estate
funds (including REITs), equities, treasury inflation protected/inflation linked bonds,
commodities, non-U.S. securities, although PROFi primarily recommends mutual funds. PROFi
may use other securities as well to help diversify a portfolio when applicable.
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Recommendation of Unaffiliated Sub-Advisers or Joint-Advisers
PROFi may provide recommendations to the client to utilize one or more specific Sub-Adviser(s) or
joint advisers to manage the Account or a portion of the assets of the Account. When a Sub-Adviser
is selected, the Sub-Adviser will have discretionary authority on your Account to place trades and
make changes to the Account or the portion of your Account the Sub-Adviser is authorized to manage.
PROFi will conduct due diligence of any recommended Sub-Adviser and monitor the performance of
Sub-Adviser with respect to the Sub-Advisor’s management of the designated assets of Account
relative to appropriate peers and/or benchmarks. The recommendation of a Sub-Adviser shall be
made on a non-discretionary basis and is always based on each client’s individual needs. PROFi will
be available to answer questions client may have regarding any portion of client’s Account managed
by a Sub-Adviser and will act as the communication conduit between Client and the Sub-Adviser.
A complete description of the Sub-Adviser’s services, practices and fees will be disclosed in the Sub-
Adviser’s Form ADV Part 2A that will be provided to client.
C. Client Tailored Services and Client Imposed Restrictions
PROFi will tailor a program for each individual client. This will include an interview session to
get to know the client’s specific needs and requirements as well as a plan that will be executed
by PROFi on behalf of the client. PROFi may use model allocations together with a specific set of
recommendations for each client based on their personal restrictions, needs, and targets. Clients
may impose restrictions in investing in certain securities or types of securities in accordance
with their values or beliefs. However, if the restrictions prevent PROFi from properly servicing the
client account, or if the restrictions would require PROFi to deviate from its standard suite of
services, PROFi reserves the right to end the relationship.
D. Wrap-fee Programs
PROFi does not act as portfolio manager for and/or sponsor of a wrap fee program.
E. Assets Under Management
PROFi has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 206,183,702 $0 December 31, 2023
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