A. Description of the Advisory Firm
Dahring | Cusmano LLC d.b.a Dahring | Cusmano and Associates, (“Dahring | Cusmano” or the “Firm”) is
a limited liability company organized in the State of Michigan. Dahring | Cusmano is an investment
advisory firm registered with the United States Securities and Exchange Commission (“SEC”). Dahring |
Cusmano is wholly owned by Kirk Dahring and Angela Cusmano. Dahring | Cusmano has been registered
since 2019.
B. Types of Advisory Services
Dahring | Cusmano provides holistic and personalized financial planning and discretionary and non-
discretionary investment advisory services to individuals, including high net worth individuals, and entities,
including, but not limited to, family offices, trusts, estates, private foundations, and qualified retirement
plans.
Financial Planning and Consulting Services
Dahring | Cusmano offers personal comprehensive financial planning services to set forth goals, objectives
and implementation strategies for the client over the long-term. Depending upon individual client
requirements, the comprehensive financial plan will include recommendations for retirement planning,
educational planning, estate planning, cash flow planning, tax planning and insurance needs and analysis.
Dahring | Cusmano prepares and provides the financial planning client with a written comprehensive
financial plan. Depending upon the agreement with the client, after the delivery of the financial plan
Dahring | Cusmano may have no other obligation to, or interaction with, the client or may perform quarterly,
semi-annual or annual reviews of the plan with the client. Clients should notify us promptly anytime there
is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the
financial information initially provided to us. In addition, Dahring | Cusmano provides consulting services
to business entities.
Clients are under no obligation to implement any of the recommendations provided in their written financial
plan. However, should a client decide to proceed with the implementation of the investment
recommendations then the client can either have Dahring | Cusmano implement those recommendations or
utilize the services of any investment adviser or broker-dealer of their choice.
Dahring | Cusmano cannot provide any guarantees or promises that a client’s financial goals and
objectives will be met.
Investment Management Services
Dahring | Cusmano offers investment management services on a discretionary basis and non-discretionary
basis. All investment advice provided is customized to each client’s investment objectives and financial
needs. The information provided by the client, together with any other information relating to the client’s
overall financial circumstances, will be used by Dahring | Cusmano to determine the appropriate portfolio
asset allocation and investment strategy for the client. Financial planning services also are provided,
depending on the needs of the client.
The securities utilized by Dahring | Cusmano for investment in client accounts mainly consist of registered
mutual funds and exchange traded funds (ETFs), but we will also invest in equity securities, corporate
bonds, REITS and variable annuities, among others, if we determine such investments fit within a client’s
objectives and are in the best interest of our clients.
When Adviser provides investment advice to you regarding your retirement plan account or individual
retirement account, Adviser is a fiduciary within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way Adviser makes money creates some conflicts with your interests, so Adviser operates
under a special rule that requires Adviser to act in your best interest and not put our interest ahead of yours.
Investment Management Services for Qualified Retirement Plans
Discretionary Investment Advisory Services to Plans: When serving in a discretionary investment advisory
capacity for a Plan, Dahring | Cusmano is in the status defined by section 3(38) of the Employee Retirement
Income Security Act of 1974 (“ERISA”). As a discretionary investment advisor to qualified retirement
plans (“Plans”) Dahring | Cusmano assumes the fiduciary responsibility for the selection, monitoring and
replacement of the investment options of the Plan. As an initial action step, Dahring | Cusmano seeks to
obtain the investment policy statement for the Plan that details the methodologies and criteria utilized to
define the style universe of investment options, the specific investment options to be utilized and the
ongoing criteria for monitoring and replacing investment options. If the Plan does not have an investment
policy statement Dahring | Cusmano may assist the Plan sponsor/trustees of the Plan in drafting an
investment policy statement.
In instances where an investment policy statement is not available, Dahring |
Cusmano will collect information from the Plan sponsor/trustees determined necessary for Dahring |
Cusmano’s provision of services to the Plan.
In its role as a 3(38) fiduciary, Dahring | Cusmano is only responsible for those Plan investments selected
by Dahring | Cusmano and Dahring | Cusmano has no responsibility for any other Plan investments
maintained in the Plan by direction of the Plan sponsor/trustees or any other person or entity. As an
example, employer securities and investments held in a directed brokerage account are not subject to any
fiduciary responsibility or duty on the part of Dahring | Cusmano. Furthermore, the Plan sponsor/trustees
should be aware that when Dahring | Cusmano assumes the investment responsibilities by serving as a 3(38)
fiduciary, the Plan sponsor/trustees retain all of their fiduciary duties, obligations and responsibilities
pursuant to applicable law.
Non-Discretionary Investment Advisory Services to Plans: When serving in a non-discretionary investment
advisory capacity for a Plan, Dahring | Cusmano is in the status defined by section 3(21) of ERISA. In this
capacity, Dahring | Cusmano assumes no fiduciary responsibility for the completion of an investment policy
statement or any aspect of the definition, selection, maintenance or replacement of any Plan investment
options. In this non-discretionary role Dahring | Cusmano provides information to the Plan sponsor/trustees
regarding investment option style parameters and performance reporting. The Plan sponsor/trustees
exercise full authority over the selection of Plan investment options and may, or may not, utilize the
information provided by Dahring | Cusmano as part of their decision-making process.
Other Services for Plans: As part of providing the discretionary or non-discretionary investment services
to Plans, Dahring | Cusmano may provide certain information and services to the Plan and the Plan
sponsor/trustees. These other services are designed to assist the Plan sponsor/trustees in meeting their
management and fiduciary obligations to the Plan. The other services may consist of the following:
Assist with platform provider search and Plan set-up;
Plan review;
Plan fee and cost review;
Acting as third party service provider liaison;
Plan participant education and communication;
Plan benchmarking;
Assist with Plan conversion to new vendor platform; and
Assistance in Plan merger.
Additional Information Regarding ERISA Plans and Individual Retirement Accounts
As detailed above, Dahring | Cusmano is a fiduciary under ERISA with respect to investment management
services and investment advice provided to ERISA plan clients, including ERISA plan participants.
Dahring | Cusmano is also a fiduciary under the Internal Revenue Code (the “IRC”) with respect to
investment management services and investment advice provided to ERISA plans, ERISA plan participants,
individual retirement accounts and individual retirement account owners (collectively “Retirement Account
Clients”). As such, Dahring | Cusmano is subject to specific duties and obligations under ERISA and the
IRC, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries
from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the
fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a
“PTE”).
C. Client-Tailored Advisory Services
Dahring | Cusmano provides portfolio management services designed to meet a variety of client investment
objectives. Client portfolios are managed on the basis of individual clients’ financial situation and
investment objectives. Clients may impose reasonable restrictions on the management of their accounts if
Dahring | Cusmano determines, in its sole discretion, that the conditions would not materially impact the
performance of a management strategy or prove overly burdensome for Dahring | Cusmano’s management
efforts.
D. Information Received From Clients
Dahring | Cusmano will not assume any responsibility for the accuracy or the information provided by
clients. Dahring | Cusmano is not obligated to verify any information received from a client or other
professionals (e.g., attorney, accountant) designated by a client, and Dahring | Cusmano is expressly
authorized by the client to rely on such information provided. Under all circumstances, clients are
responsible for promptly notifying Dahring | Cusmano in writing of any material changes to the client’s
financial situation, investment objectives, time horizon, or risk tolerance.
E. Assets Under Management
Dahring | Cusmano has $535,130,456 in Assets Under Management, of which $453,575,762 is
discretionary, and $81,554,694 is non-discretionary.