A. Kreitler Financial, LLC (the “Registrant”) is a limited liability company formed in the state
of Connecticut in February 2003. The Registrant became a registered investment advisor
with the U.S. Securities and Exchange Commission in May 2020. The Registrant is
principally owned by Charles Kreitler. Mr. Kreitler is also the Registrant’s Managing
Member.
B.
INVESTMENT ADVISORY SERVICES
The Registrant provides discretionary and non-discretionary investment advisory services
on a fee basis. Registrant’s annual investment advisory fee may include investment advisory
services, and, to the extent specifically requested by the client, financial planning and
consulting services. In the event that the client requires extraordinary planning and/or
consultation services (to be determined in the sole discretion of the Registrant), the
Registrant may determine to charge for such additional services, the dollar amount of which
shall be set forth in a separate written notice to the client.
The Registrant provides investment advisory services specific to the needs of each client.
Before providing investment advisory services, an investment adviser representative will
ascertain each client’s investment objectives. Thereafter, the Registrant will recommend
that the client allocate investment assets consistent with the designated investment
objectives.
The Registrant primarily recommends that clients allocate investment assets among various
mutual funds and/or exchange traded funds (“ETFs”), individual equity (stocks), debt
(bonds) and fixed income securities in accordance with the client’s designated investment
objective(s). Once allocated, the Registrant provides ongoing monitoring and review of
account performance, asset allocation and client investment objectives.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND -ALONE)
The Registrant may provide financial planning and/or consulting services (including
investment and non-investment related matters, including estate planning, insurance
planning, etc.) on a stand-alone separate fee basis.
Prior to engaging the Registrant to provide planning or consulting services, clients are
generally required to enter into an agreement with Registrant setting forth the terms and
conditions of the engagement (including termination), describing the scope of the services
to be provided, and the portion of the fee that is due from the client prior to Registrant
commencing services.
It remains the client’s responsibility to promptly notify the Registrant if there is ever any
change in their financial situation or investment objectives for the purpose of reviewing,
evaluating or revising Registrant’s previous recommendations and/or services.
Miscellaneous
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by a client, Registrant may provide
financial planning and related consulting services inclusive of its advisory fee as set forth at
Item 5 below (exceptions may occur based upon assets under management, special projects,
etc., for which the Registrant may charge a separate fee). However, neither the Registrant
nor its investment adviser representatives assist clients with the implementation of any
financial plan, unless they have agreed to do so in writing. The Registrant does not monitor
a client’s financial plan, unless specifically engaged to do so, and it is the client’s
responsibility to revisit the financial plan with the Registrant, if desired.
Furthermore, although the Registrant may provide recommendations regarding non-
investment related matters, such as estate planning, tax planning and insurance, the
Registrant does not serve as an attorney or accountant, and no portion of its services should
be construed as legal or accounting services. Accordingly, the Registrant does not prepare
estate planning documents or tax returns.
To the extent requested by a client, the Registrant may recommend the services of other
professionals for certain non-investment implementation purposes (i.e., attorneys,
accountants, insurance, etc.), including certain of the Registrant’s representatives in their
individual capacities as licensed insurance agents (See disclosure at Item 10.C below). The
client is under no obligation to engage the services of any such recommended professional.
The client retains absolute discretion over all such implementation decisions and is free to
accept or reject any recommendation from Registrant and/or its representatives.
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional(s) (i.e.,
attorney, accountant, insurance agent, etc.), and not the Registrant, shall be responsible for
the quality and competency of the services provided.
Non-Discretionary Service Limitations. Clients that determine to engage the Registrant
on a non-discretionary investment advisory basis must be willing to accept that the
Registrant cannot effect any account transactions without obtaining prior consent to any
such transaction(s) from the client. Therefore, in the event of a market correction during
which the client is unavailable, the Registrant will be unable to effect any account
transactions (as it would for its discretionary clients) without first obtaining the client’s
consent.
Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded
funds are available directly to the public. Therefore, a prospective client can obtain many
of the funds that may be utilized by Registrant independent of engaging Registrant as an
investment advisor. However, if a prospective client determines to do so, he/she will not
receive Registrant’s initial and ongoing investment advisory services.
Use of DFA Mutual Funds. Certain mutual funds, such as those issued by Dimensional
Fund Advisors (“DFA”), are generally only available through selected registered
investment advisers. Registrant may allocate client investment assets to DFA mutual funds.
Therefore, upon the termination of Registrant’s services to a client, restrictions regarding
transferability and/or additional purchases of, or reallocation among DFA funds will apply.
Mutual Fund and ETF Fees In addition to Registrant’s investment advisory fee described
below, and transaction and/or custodial fees discussed below, clients will also incur, relative
to all mutual fund and exchange traded fund purchases, charges imposed at the fund level
(e.g., management fees and other fund expenses).
ByAllAccounts and eMoney. Registrant may provide its clients with access to an online
platform hosted by ByAllAccounts or “eMoney Advisor” (“eMoney”). These platforms
allow a client to view their complete asset allocation, including those assets that Registrant
does not manage (the “Excluded Assets”). Registrant does not provide investment
management, monitoring, or implementation services for the Excluded Assets. Unless
otherwise specifically agreed to, in writing, Registrant’s service relative to the Excluded
Assets is limited to reporting only. Therefore, Registrant shall not be responsible for the
investment performance of the Excluded Assets.
Without limiting the above, the Registrant shall not be responsible for any implementation
error (timing, trading, etc.) relative to the Excluded Assets. The client may choose to engage
Registrant to manage some or all of the Excluded Assets pursuant to the terms and conditions
of an Investment Advisory Agreement between Registrant and the client.
The eMoney platform also provides access to other types of information and applications
including financial planning concepts and functionality, which should not, in any manner
whatsoever, be construed as services, advice, or recommendations provided by Registrant.
Finally, Registrant shall not be held responsible for any adverse results a client may
experience if the client engages in financial planning or other functions available on the
eMoney platform without Registrant’s assistance or oversight.
Socially Responsible Investing Limitations. Socially Responsible Investing involves the
incorporation of Environmental, Social and Governance (“ESG”) considerations into the
investment due diligence process. ESG investing incorporates a set of criteria/factors used
in evaluating potential investments: Environmental (i.e., considers how a company
safeguards the environment);
Social (i.e., the manner in which a company manages
relationships with its employees, customers, and the communities in which it operates);
and Governance (i.e., company management considerations). The number of companies
that meet an acceptable ESG mandate can be limited when compared to those that do not,
and could underperform broad market indices. Investors must accept these limitations,
including potential for underperformance. Correspondingly, the number of ESG mutual
funds and exchange-traded funds are limited when compared to those that do not maintain
such a mandate. As with any type of investment (including any investment and/or
investment strategies recommended and/or undertaken by Registrant), there can be no
assurance that investment in ESG securities or funds will be profitable or prove
successful. Registrant generally relies on the assessments undertaken by the unaffiliated
mutual fund, exchange traded fund or separate account portfolio manager to determine that
the fund’s or portfolio’s underlying company securities meet a socially responsible
mandate.
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Registrant will review
client portfolios on an ongoing basis to determine if any changes are necessary based upon
various factors, including, but not limited to, investment performance, fund manager tenure,
style drift, account additions/withdrawals, and/or a change in the client’s investment
objective. Based upon these factors, there may be extended periods of time when Registrant
determines that changes to a client’s portfolio are neither necessary nor prudent. Clients
nonetheless remain subject to the fees described in Item 5 below during periods of account
inactivity.
Cash Positions. Registrant treats cash as an asset class. As such, unless determined to the
contrary by Registrant, all cash positions (money markets, etc.) shall continue to be
included as part of assets under management for purposes of calculating Registrant’s
advisory fee. At any specific point in time, depending upon perceived or anticipated market
conditions/events (there being no guarantee that such anticipated market conditions/events
will occur), Registrant may maintain cash positions for defensive and liquidity purposes.
In addition, while assets are maintained in cash, such amounts could miss market advances.
Furthermore, should Registrant hold any portion of the client’s assets in a money market
fund, Registrant’s advisory fee could exceed the interest paid by the fund, depending upon
current yields.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from
account transactions or new deposits, be swept to and/or initially maintained in a
specific custodian designated sweep account. The yield on the sweep account will
generally be lower than those available for other money market accounts. When this
occurs, to help mitigate the corresponding yield dispersion Registrant shall (usually within
30 days thereafter) generally (with exceptions) purchase a higher yielding money market
fund (or other type security) available on the custodian’s platform, unless Registrant
reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day
period to purchase additional investments for the client’s account. Exceptions and/or
modifications can and will occur with respect to all or a portion of the cash balances for
various reasons, including, but not limited to the amount of dispersion between the sweep
account and a money market fund, the size of the cash balance, an indication from the client
of an imminent need for such cash, or the client has a demonstrated history of writing
checks from the account.
The above does not apply to the cash component maintained within a Registrant actively
managed investment strategy (the cash balances for which shall generally remain in the
custodian designated cash sweep account), an indication from the client of a need for access
to such cash, assets allocated to an unaffiliated investment manager and cash balances
maintained for fee billing purposes.
The client shall remain exclusively responsible for yield dispersion/cash balance decisions
and corresponding transactions for cash balances maintained in any Registrant unmanaged
accounts.
Retirement Plan Rollovers–Conflict of Interest. A client or prospective client leaving
an employer typically has four options regarding an existing retirement plan (and may
engage in a combination of these options): (i) leave the money in the former employer’s
plan, if permitted, (ii) roll over the assets to the 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 client’s age, result in
adverse tax consequences). If Registrant recommends that a client roll over their retirement
plan assets into an account to be managed by Registrant, such a recommendation creates a
conflict of interest if Registrant will earn new (or increase its current) compensation as a
result of the rollover. If Registrant provides a recommendation as to whether a client should
engage in a rollover or not, Registrant is acting as 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. No client is under any obligation
to roll over retirement plan assets to an account managed by Registrant.
Client Obligations. In performing its services, Registrant shall not be required to verify
any information received from the client or from the client’s other professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify the Registrant if there is ever any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating or revising
Registrant’s previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that Registrant
and its third-party service providers use to provide services to Registrant’s clients employ
various controls, which are designed to prevent cybersecurity incidents stemming from
intentional or unintentional actions that could cause significant interruptions in Registrant’s
operations and result in the unauthorized acquisition or use of clients’ confidential or non-
public personal information. Clients and Registrant are nonetheless subject to the risk of
cybersecurity incidents that could ultimately cause them to incur losses, including for
example: financial losses, cost and reputational damage to respond to regulatory
obligations, other costs associated with corrective measures, and loss from damage or
interruption to systems. Although Registrant has established procedures to reduce the risk
of cybersecurity incidents, there is no guarantee that these efforts will always be successful,
especially considering that Registrant does not directly control the cybersecurity measures
and policies employed by third-party service providers. Clients could incur similar adverse
consequences resulting from cybersecurity incidents that more directly affect issuers of
securities in which those clients invest, broker-dealers, qualified custodians, governmental
and other regulatory authorities, exchange and other financial market operators, or other
financial institutions.
Disclosure Statement. A copy of the Registrant’s written Brochure and CRS, as set forth
on Parts 2 and 3 of Form ADV, respectively, shall be provided to each client prior to the
execution of any new advisory agreement.
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser representative
will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate
and/or recommend that the client allocate investment assets consistent with the designated
investment objective(s). The client may, at any time, impose reasonable restrictions, in
writing, on the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2023, the Registrant had $472,824,425 in assets under management
on a discretionary basis and $3,905,385 in assets under management on a non-discretionary
basis.