A. Firm Information
Prosperity Road, LLC (“Prosperity Road” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”)
under the laws of the State of California. Prosperity Road was founded in October 2015. Prosperity Road is
primarily owned by E4 Vantage, LLC, a holding company registered as an LLC in California. Prosperity Road is
operated by Emily T. Hermeno (Principal and Chief Compliance Officer). This Disclosure Brochure provides
information regarding the qualifications, business practices, and the advisory services provided by Prosperity
Road.
B. Advisory Services Offered
Prosperity Road offers investment advisory services to individuals, high net worth individuals, trusts, estates,
retirement plans, charitable organizations and corporations (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Prosperity Road’s fiduciary commitment is further described in the Advisor’s Code of Ethics.
For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest
in Client Transactions and Personal Trading.
Wealth Management Services
Prosperity Road provides customized wealth advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary and non-discretionary investment
management and financial planning services. Prosperity Road works closely with each Client to identify their
investment goals and objectives, as well as risk tolerance and financial situation in order to create an investment
strategy. Prosperity Road will develop an asset allocation strategy based on the Client’s unique situation and
then construct a portfolio primarily consisting of no-load mutual funds. The Advisor may also utilize exchange-
traded funds (“ETFs”), individual stocks, individual bonds and other types of investments, as appropriate, to meet
the needs of its Clients. The Advisor typically constructs portfolios using institutional mutual funds through
Dimensional Funds Advisors (“DFA”) to creating a Client’s portfolio. The Advisor may retain certain legacy
investments based on portfolio fit and/or tax considerations.
Prosperity Road’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-
allocate positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Prosperity Road will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
Prosperity Road evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. Prosperity Road may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. Prosperity Road may recommend specific positions to increase sector or asset class
weightings. The Advisor may recommend employing cash positions as a possible hedge against market
movement. Prosperity Road may recommend selling positions for reasons that include, but are not limited to,
harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities,
overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating
cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will Prosperity Road accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at
the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
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Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Use of Independent Managers
Prosperity Road will recommend that Clients utilize one or more unaffiliated investment managers or investment
platforms (collectively “Independent Manager”) for all or a portion of a Client’s investment portfolio, based on the
Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each
Independent Manager to ensure the strategy remains
aligned with its Clients investment objectives and overall
best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and
managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV
Part 2A – Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Prosperity Road may recommend Buckingham Strategic Partners, LLC (“BSP” or the “Investment Platform”), if
appropriate. The Advisor will then enter into one or more agreements with BSP on behalf of the Client to
authorize discretionary investment management.
Financial Planning Services
Prosperity Road will typically provide a variety of financial planning services to Clients, either as a component of
wealth management services, or pursuant to a written financial planning agreement. Services are offered in
several areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan or rendering a financial
consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass
one or more areas of need, including, but not limited to investment planning, retirement planning, personal
savings, education savings, and other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
Prosperity Road may also refer Clients to an accountant, attorney or another specialist, as appropriate for their
unique situation. For certain financial planning engagements, the Advisor will provide a written summary of
Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the
Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months
of contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
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Retirement Plan Advisory Services
Prosperity Road provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and
the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the
Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is
customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight Services (ERISA 3(21))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
These services are provided by Prosperity Road serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2),
the Plan Sponsor is provided with a written description of Prosperity Road’s fiduciary status, the specific services
to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging Prosperity Road to provide investment advisory services, each Client is required to enter into
one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the
Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Prosperity Road, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – Prosperity Road will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk of each Client.
• Portfolio Construction – Prosperity Road will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – Prosperity Road will provide investment management,
financial planning and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Prosperity Road does not manage or place Client assets into a wrap fee program. Investment advisory services
are provided directly by Prosperity Road.
E. Assets Under Management
As of December 31, 2023, Prosperity Road manages $143,336,933 in Client assets, $139,167,378 of which are
managed on a discretionary basis and $4,169,555 on a non-discretionary basis. Clients may request more current
information at any time by contacting the Advisor.
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