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) months
of the client signing a contract with us, assuming that 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. Clients may terminate advisory services with 30 days written notice.
Tailoring of Advisory Services
We offer individualized investment advice to all of our clients. 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.
Retirement Rollover Recommendations
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”) and/or the Internal Revenue Code (the “Code”), as
applicable, which are laws governing retirement accounts. The way we make money creates some
conflicts with your interests, so we operate under a special rule that requires us to act in your best
interest and not put our interest ahead of yours.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give
prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give
loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
When providing recommendations to retirement plan accounts involving rollover considerations, there
are generally four options regarding an existing retirement plan account. An employee may use a
combination of those options, such as; (i) leave the funds in the former employer’s plan, if permitted,
(ii) roll over the funds to a new employer’s plan, if one is available and rollovers are permitted, (iii) roll
over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the individual’s age, result in adverse tax consequences). If your designated
investment adviser representative recommends that you rollover your retirement plan assets into an
account to be managed by our firm, such recommendation creates a conflict of interest insofar as we
will earn an advisory fee on the rolled over assets. You are under no obligation to roll over retirement
plan assets to an account managed by us.
Participation in Wrap Fee Programs
We do not offer wrap fee programs.
Regulatory Assets Under Management
As of December 31, 2022, we manage approximately $166,899,181
on a non-discretionary basis.
How We Are Compensated for Our Advisory Services
Comprehensive Portfolio Management:
Our annual fees shall be based on a negotiated percentage of the market value of the assets under
management not to exceed 1.50%. The fees shall be payable in one of the formats below. These fees
shall be detailed on Schedule A of the client agreement.
Quarterly Fee Payable in Advance
Our annual fees shall be based on a negotiated percentage of the market value of the assets under
management not to exceed 1.50% (“Annual Percentage Rate”). The fee is based on the market value of
assets in the account, including cash holdings, and is payable quarterly in advance. The annual fee is
billed on a pro-rata basis based on the value of your account on the last day of the previous quarter.
Your initial quarterly advisory fee will include a pro-rated amount for services rendered from the
account enrollment date with the qualified custodian. Fees are negotiable and will be deducted from
your account.
Quarterly Billing Cycle (Every Three Months)
Your quarterly billing cycle will depend on your account enrollment date. Your billing cycle will
commence at the beginning of the month following your account enrollment date. For example, if your
account enrollment date is May 15, you would be billed at the beginning of each following June,
September, December and March, based on the market value of your assets under management as of
the last business day of May, August, November and February (subject to adjustment as described
below).
For example, if the market value of your assets under management is $100,000 on May 31, and your
Annual Percentage Rate is 1.50%, at the beginning of June, you would be billed as follows: $100,000
(market value at May 31) times 1.50%, divided by 360 (assumed days in year) times 90 (assumed days
in quarter) = $375.00.
Adjustment for Deposits and Withdrawals During Preceding Quarter
If, however, you made any deposits to or withdrawals from your account during the preceding quarter,
the quarterly fee will be adjusted on a prorated basis.
For example, assume you are billed at the beginning of June and the market value of your assets under
management was $100,000 at May 31, but you had withdrawn $20,000 from your account on April 15.
The quarterly fee assessed at the beginning of June would be based on an adjusted market value of
assets under management of $110,000, computed as follows: $120,000 x 46 (number of days in the
quarter prior to account withdrawal) plus $100,000 x 46 (number of days in the quarter following
account withdrawal), divided by 92 (total number of days in quarterly period) = $110,000.
Initial Billing – Normal Advance Quarterly Billing Plus Arrears Billing
Your initial quarterly bill will include the advance quarterly billing as described above plus an arrears
billing which is necessary to charge your account for assets deposited before a fee is assessed.
For example, assume your Annual Percentage Rate is 1.50%, your account was initially funded with
$100,000 on May 14 and no other deposits were made before June 1. In addition to the normal quarterly
advance billing, you would be billed for the assets under management for the period from May 15 and
May 31 on a pro rata basis as follows: the initial deposit ($100,000) times the Annual Percentage Rate
(for purposes of this example, 1.50%) divided by 360 (assumed year of 360 days) times 17 (the number