FIRM DESCRIPTION
Benchmark Advisory Services, LLC (“BAS” or “Adviser”) was organized as a Limited Liability
Company in the State of Delaware in 2019 and is a Registered Investment Advisor (“RIA”) with
the Securities Exchange Commission (“SEC”). Such registration does not imply that the Adviser
has attained a certain level of skill or training and does not mean BAS is endorsed by any
regulatory authority.
BAS provides investment management services to other Investment Advisors, individuals and
wealthy individuals on a separate account management basis. BAS is a fee-only investment
manager. The Advisor does not sell securities on a commission basis, however, from time-to-time
clients may incur separate transactional costs from affiliated and non-affiliated firms creating the
potential for a conflict of interest. Clients should carefully review all fees and commissions prior
to making an investment decision. BAS does not act as a custodian of client assets and the client
always maintains asset control.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by
the client on an as-needed basis. Any conflicts of interest arising out of the Adviser’s or its
associated persons are disclosed in this brochure.
PRINCIPAL OWNERS
Benchmark Advisory Services is 100% owned by Kingswood US, LLC (formerly known as
Manhattan Harbor Capital, LLC).
ASSETS UNDER MANAGEMENT
Total assets under management (“AUM”) as of the date of this filing:
Non-Discretionary $ 0
Discretionary $ 0
Total $0
TYPES OF SERVICES
BAS offers investment advisory and financial planning services through individuals associated
with BAS as Investment Advisory Representatives (“IARs”) by a written agreement. Services are
focused on specific areas and based upon each client’s individual financial situation and personal
or business objectives, liquidity needs, sophistication and time horizon. The degree of detail and
complexity of the financial planning services provided varies according to the individual client’s
situation. Each client is provided with a written summary of the work undertaken.
TAILORED SERVICES
The goals and objectives for each client are documented in our client relationship paperwork.
Investment Policy Guidelines (“IPG”) are created that reflect the stated goals and objective.
Clients may impose restrictions on investing in certain securities or types of securities.
ASSIGNMENT OF INVESTMENT MANAGEMENT AGREEMENTS
Agreements may not be assigned without client consent. In situations where the client’s IAR is
no longer registered with the Advisor or available to provide services, the Advisor may assign an
interim IAR pursuant to a written negative consent notification.
TYPES OF AGREEMENTS
Investment Management Agreement
As part of the investment management service, all aspects of the client’s disclosed financial affairs
are reviewed and realistic and measurable goals are set and objectives to reach those goals are
defined. As goals and objectives change over time, suggestions are made and implemented on
an ongoing basis. The Adviser periodically reviews a client’s financial situation and portfolio
through regular contact with the client which often includes an annual meeting with the client.
The scope of work and fee for an Advisory Service Agreement is provided to the client in writing
prior to the start of the relationship. The agreement sets forth the services to be provided, the fees
for the service and the agreement may be terminated by either party in writing at any time.
Financial Planning Agreement
The financial plan may include, but is not limited to: a net worth statement; a cash flow statement;
a review of investment accounts, including reviewing asset allocation and providing repositioning
recommendations; strategic tax planning; a review of retirement accounts and plans including
recommendations; a review of insurance policies and recommendations for changes, if
necessary; one or more retirement scenarios; estate planning review and recommendations; and
education planning with funding recommendations.
The financial planning may be the only service provided to the client and does not require that the
client use or purchase the investment advisory services offered by the Advisor or any of the
insurance products or other products and services offered by the associated persons of the
Advisor, including offerings from affiliated entities. There is an inherent conflict of interest for the
Advisor whenever a financial plan recommends use of professional investment management
services or the purchase of insurance products or other financial products or services. The
Advisor or its associated persons may receive compensation for financial planning and the
provision of investment management services and/or the sale of insurance and other products
and services. The Advisor does not make any representation that these products and services
are offered at the lowest available cost and the client may be able to obtain the same products or
services at a lower cost from other providers. However, the client is under no obligation to accept
any of the recommendations of the Advisor or use the services of the Advisor in particular.
Asset Management
Investments may also include: equities (stocks), warrants, corporate debt securities, investment
company securities (variable life insurance, variable annuities, and mutual funds shares), and
U.S. government securities.
Assets are invested primarily in no-load or low-load mutual funds and exchange-traded funds,
usually through brokers or fund companies. Fund companies charge each fund shareholder an
investment management fee that is disclosed in the fund prospectus. Brokerages, including
affiliates, may charge a transaction fee for the purchase of some funds.
Stocks and bonds may be purchased or sold through a brokerage account when appropriate. The
brokerage firm charges a fee for stock and bond trades. The Adviser does not receive any
compensation, in any form, from fund companies. Advisor affiliates do receive compensation
creating a conflict of interest.
Advisory Referral Program
All clients are required to sign an advisory agreement with BAS and will also sign an advisory
agreement directly with the third-party adviser of the program selected should a third-party
manager be utilized. The client, BAS or the third-party adviser may terminate the advisory
relationship in accordance with the provisions of those agreements. The client will typically
receive a pro rata refund of any prepaid advisory fees upon termination of an advisory agreement.
Additionally, a client may terminate its advisory relationship with BAS without being assessed any
penalty within five (5) business days of its signing an advisory agreement. BAS encourages clients
to carefully review the terms set forth in the agreement prior to signing the agreement.
BAS will also prepare and present for client signature a separate written disclosure document that
describes the fees clients pay for services, the percentage of the fee paid to each adviser, how
the fee is calculated, whether the fee paid to BAS represents an additional fee the client would
not have paid for direct services with the third-party adviser, and when the fees are payable. BAS
and its representatives may not verify information provided by third-party advisers and are
required to direct clients to confirm all third-party fees and expenses directly with the provider.
Termination of Agreements
A client may terminate any of the aforementioned agreements at any time by notifying the Adviser
in writing. Clients shall be charged pro rata for services provided through to the date of
termination. If the client made an advance payment, the Adviser will refund any unearned portion
of the advance payment.
The Adviser may terminate any of the aforementioned agreements at any time by notifying the
client in writing. If the client made an advance payment, the Adviser will refund any unearned
portion of the advance payment.
The Adviser reserves the right to terminate any engagement where a client has willfully concealed
or has refused to provide pertinent information about financial situations when necessary and
appropriate, in the Adviser’s judgment, to providing proper financial advice. Any unused portion
of fees collected in advance will be refunded.
DESCRIPTION OF INVESTMENT STRATEGIES
Benchmark Asset Management
Benchmark Asset Management (“BAM”) offers clients access to mutual funds, ETFs, equities and
other Eligible Assets on a discretionary and non-discretionary basis. RBC, TD, Schwab or
another QC will maintain custody of BAM accounts.
In opening a BAM account, Clients complete an Investment Policy Guideline (“IPG”), Qualified
Custodian New Account Form and a BAM Investment Advisory Agreement. The BAS IAR
completes a client investment suitability review and creates an asset allocation plan with the
client. Once proper allocation is determined, IARs can present the client with a wide range of
investment vehicles designed to achieve their risk and allocation parameters.
All trades entered per the plan are non-discretionary, unless the client signs discretionary trading
authorization, with the client acknowledging and accepting responsibility for trading privileges and
investment selections used in the Program. Client and IAR may also determine that, in the case
of an account transfer, existing products and allocations are appropriate at the time of account
opening. IAR will offer at minimum annual account reviews and make recommendations to client
regarding ongoing allocation and rebalancing.
Kingswood Family Office
The Kingswood Family Office (“KWFO”) offers high net worth clients access to mutual funds,
ETFs, equities and other Eligible Assets on a discretionary and non-discretionary basis. RBC,
TD, Schwab or another QC will maintain custody of KWFO accounts.
In opening a KWFO account, Clients complete an Investment Policy Guideline (“IPG”), Qualified
Custodian New Account Form and a KWFO Investment Advisory Agreement. The KWFO IAR
completes a client investment suitability review and creates an asset allocation plan with the
client. Once proper allocation is determined, IARs can present the client with a wide range of
investment vehicles designed to achieve their risk and allocation parameters.
All trades entered per the plan are non-discretionary, unless the client signs discretionary trading
authorization, with the client acknowledging and accepting responsibility for trading privileges and
investment selections used in the Program. Client and IAR may also determine that, in the case
of an account transfer, existing products and allocations are appropriate at the time of account
opening. IAR will offer at minimum annual account reviews and make recommendations to client
regarding ongoing allocation and rebalancing.
Advisory Referral Program
BAS associates may act as solicitors on behalf of third-party investment managers. These
managers may be managers and/or general partners of partnerships investing in a variety of
securities and non-securities. BAS reviews the investment strategies, performance record, and
regulatory history, among other criteria, before recommending, selecting and entering into an
agreement with a third-party manager. All third-party managers to whom BAS refers clients are
registered as investment advisers by their resident state, with other states as required by
regulation, and/or with the Securities and Exchange Commission (SEC) or properly exempted
from registration.
BAS associates assist clients in selecting a particular third-party manager or managers based on
the client’s financial situation and investment objectives. The advisory associate will contact the
client invested in third-party management programs at least quarterly, and will make written
inquiry regarding changes in the client's financial situation and needs or investment objectives on
a periodic basis. In addition, the advisory associate will offer to meet with the client at least
annually to review any changes in the client's financial situation, needs or investment objectives,
as well as the performance of the programs managed by the third-party investment adviser.
Clients may contact a BAS associates for consultation during normal business hours.
BAS receives compensation according to its agreements with these third-party managers for
introducing clients and for certain ongoing services such as monitoring investment performance
and client consultations. BAS’s compensation, which is disclosed to the client in a separate
disclosure document, may be in the form of fixed or recurring fees for marketing and other
services, a percentage of assets managed by the third party, or both.
Sub-Advisory Arrangements
The Adviser in certain circumstances will enter into sub-advisory agreements with various
advisers (“primary advisers”) in order to offer investment management services to prospected
clients. Primary advisers will be licensed as investment advisers by their resident state and other
applicable jurisdictions or with the Securities and Exchange Commission or properly exempted
from registration.
In these situations, BAS will gather information about the client's financial situation and investment
objectives, among other things, the primary adviser will then provide the client with asset
allocation guidelines. BAS will have the power and authority to supervise and direct on a
discretionary or non-discretionary basis any investment for those accounts designated by the
primary adviser, including the purchase and sale of any securities and any other transaction
unless specifically directed otherwise in writing by the primary adviser.
The Adviser will receive compensation pursuant to its agreements with the primary advisers. The
compensation is generally a portion of the percentage of the assets under management but may
vary depending on the range of services the Adviser provides such as specialized report and
more frequent reporting. Fees are payable in accordance with the provisions of the primary
advisers’ Form ADV Part 2A or equivalent disclosure document.
Financial Planning
General financial planning involves data gathering and goal setting; reviewing current and
anticipated assets and liabilities such as insurance, savings, investments, and anticipated
retirement or other employee benefits; creating a cash flow analysis; and finally developing a plan
based on a computer model that incorporates BAS’s recommendations for a course of activity or
specific actions that the client should take. For example, an advisory associate may recommend
that the client obtain insurance or revise existing insurance coverage, establish an individual
retirement account, increase or decrease estate plans, and/or refer the client to an accountant or
attorney. Financial plan recommendations are not limited to any specific product or service offered
by a broker-dealer or insurance company.
BAS may recommend the services of itself and/or other professionals to implement its
recommendations. Clients should be aware that a conflict of interest exists if BAS recommends
its own services. The Adviser or its advisory associates may receive compensation for financial
planning, providing investment management services, and/or the sale of insurance and other
products and services. BAS does not represent that these products and services are offered at
the lowest available cost and the client may be able to obtain the same products or services at a
lower cost from other providers. However, clients are under no obligation to act upon any of the
recommendations made by BAS under a financial planning engagement and/or engage the
services of BAS or any other recommended professional.
Product Direct Program (“DP”)
The DP Program provides advisory services to clients with accounts held directly with a third-
party provider or through an approved QC. DP accounts are available on a limited basis to
specific clients.
BAS does not maintain custody of DP accounts. The QC, Investment Advisor, Broker-Dealer,
Mutual Fund Company, Variable Annuity Company and/or Transfer Agent act as the Qualified
Custodian for all DP accounts. DP accounts are managed on a non-discretionary basis. The
transactions in Mutual Funds and Variable Annuities are not part of the DP Program.
Your IAR may be involved in your transactions in underlying products in DP accounts. In this
instance, your IAR is acting in their capacity as a registered-representative (“RR”) of a broker
dealer or IAR of another Investment Advisor (“Outside IAR”). In their capacity as an RR or Outside
IAR, BAS IARs may from time to time receive commissions or other revenue from transactions.
This creates a conflict of interest because the Commissions received as an RR are in addition to
Fees earned as an IAR. This may also be confusing to clients when receiving statements and
disclosures from various parties. All DP clients and IARs acknowledge the conflict of interest and
are responsible for reviewing the list of Eligible Assets and the total Fee and Commission cost to
the client.
Clients and IARs are required to acknowledge their DP Program Fee and their understanding of
Eligible Assets in the DP Advisory Agreement. Comparable services may be available at a lower
cost.
Apex Financial Retirement Plan Advisory and Consulting Services
Investment advisory services provided to a company for their retirement plan vary depending
on the scope of the agreement. The scope of the services provided would be discussed and
agreed upon and typically include some or all of the following:
Retirement Plan Investment Committee Services
o Preparation of Investment Policy Statement
o Investment recommendations
o Investment review and monitoring
o Education services to the plan committee
Plan Participant Services
o Participant enrollment and education
o One-on-one participant meetings
o Development and communication of model portfolio
Plan Design and Construction
o Plan design consulting
o Plan search coordination
o Provider review
Consulting Services
Services may be provided that include but are not limited to, real estate transactions, banking
services, special estate planning needs, business management, buy-out negotiations,
review of individual or company benefit offerings, or insurance assessment, of life, health,
property and casualty. These special services will be clearly defined in a client’s contract.
This may be done on an hourly or through the receipt of commissions.
Note: BAS relies on the information it gathers from the client or from the client’s other
professionals (e.g., attorney, accountant) and does not independently verify any of the
information. Furthermore, every client should promptly notify BAS if there is ever any change in
his or her financial situation (e.g., financial needs, objectives, net worth, income, investments
held at other firms, or any other information that might affect the client’s financial condition) for
the purpose of reviewing, evaluating, or revising the Adviser’s previous recommendations
and/or services.