A. Firm Information
Prosperity Advisory Group LLC (“PAG” or the “Advisor”) is a Registered Investment Advisor with the U.S. Securities
and Exchange Commission (“SEC”). The Advisor was organized as a Limited Liability Company (“LLC”) under the
laws of the State of New York in August 2020 and became a Registered Investment Advisor in October 2020. PAG
is owned and operated by John Harnish (Principal and Chief Compliance Officer). This Disclosure Brochure
provides information regarding the qualifications, business practices, and the advisory services provided by PAG.
B. Advisory Services Offered
PAG offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, and
retirement plans (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. PAG'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.
Investment Management Services
PAG provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related advisory
services. PAG works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. PAG will then construct an investment
portfolio, consisting of diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s
investment goals. The Advisor may also utilize individual stocks, individual bonds and/or variable annuities to meet
the needs of its Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax
considerations.
PAG’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. PAG 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.
PAG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. PAG may recommend, on occasion, redistributing investment allocations to diversify the portfolio. PAG
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. PAG 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 PAG 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 the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
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
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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.
Participant Account Management – As part of the Advisor’s Investment Management Services, when appropriate,
the Advisor will use a third party platform to facilitate management of held away assets such as defined contribution
plan participant accounts, with discretion. The platform allows the Advisor to avoid being considered to have
custody of Client funds since the Advisor does not have direct access to Client log-in credentials to affect trades.
The Advisor is not affiliated with the platform in any way and does not receive compensation from them for using
their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once
Client account(s) is connected to the platform, the Advisor will review the current account allocations. When
deemed necessary, the Advisor will rebalance the account considering client investment goals and risk tolerance,
and changes in allocations will take
into account current economic and market trends. The goal is to improve
account performance over time, minimize loss during difficult markets, and manage internal fees that harm account
performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed
necessary.
Financial Planning Services
PAG will typically provide a variety of financial planning and consulting services to Clients, 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 involve preparing a formal financial plan or
rendering a specific 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, insurance needs 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.
PAG may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation.
For certain financial planning engagements, the Advisor will provide a written summary of the 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.
Retirement Plan Advisory Services
PAG 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
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These services are provided by PAG 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 PAG’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 PAG 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 – PAG, in connection with the Client, will develop a strategy that seeks
to achieve the Client’s goals and objectives.
• Asset Allocation – PAG will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – PAG will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
• Investment Management and Supervision – PAG will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
PAG includes securities transaction fees and custody fees together with its investment advisory fee. Including these
fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor sponsors the PAG Wrap Fee
Program solely as a supplemental disclosure regarding the combination of fees. The Advisor customizes its
investment management services for its Clients and does not provide different services for Clients in the Wrap Fee
Program. Depending on the level of trading or the security selection required for the Client’s account[s], the costs
for securities transaction fees borne by the Advisor may vary. Held-away assets are excluded from the PAG Wrap
Fee Program. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this
Disclosure Brochure.
E. Assets Under Management
As of December 31, 2023, PAG manages $196,822,842 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.