Who We Are
Lighthouse Retirement1 (hereinafter referred to as “the Company”, “we”, “us” and “our”) is a
Florida-based investment advisory firm that provides investment supervisory services on a
discretionary basis to certain clients described in Item 7 herein. The investment instruments we
advise our clientele on include, but are not limited to, equity stocks, fixed income securities,
bonds, exchange traded funds (“ETFs”), mutual funds, options, and cash equivalent instruments.
Please refer to Item 8 for additional information relating to the investment strategies pursued
by our firm and their associated risks.
Lighthouse Retirement is the “doing-business-as” name for Martin D. Parlato & Associates, Inc.
Lighthouse Retirement began as a Sole Proprietorship of Martin D. Parlato. In the fall of 2012,
Martin D. Parlato & Associates, LLC was organized as a Florida Limited Liability Company and
acquired all the assets of the existing advisory firm Martin D. Parlato, Sole Proprietorship. In
March of 2017, Martin D. Parlato & Associates, LLC was converted to a corporation. Martin D.
Parlato (“Mr. Parlato”) is the sole owner of the Company, and as such, is the control person for
the Company.
What we Do
Investment Management Services
We provide discretionary investment advice and management to separately managed accounts
on a continuous basis. We typically hold a limited power of attorney to act on a discretionary
basis with client funds. Our discretionary authority is subject to conditions or restrictions
imposed by a client, such as when a client restricts or prohibits transactions in a particular
security. Please refer to Item 16 for additional information.
Client managed account assets are typically invested and managed based on an investment
portfolio of securities determined for the account assets. While we will customize the portfolio,
for example to help ensure suitability and/or to incorporate client restrictions, several clients
will be invested in the same or similar investment portfolios at any given time. To begin the
process, we gather information from each client and establish an Investment Policy Statement
(“IPS”). We utilize both in-person meetings and/or telephonic interviews with the clients to
gather information in generating the IPS. The firm typically employs an investment strategy
that includes industry concentration, high risks, and a limited number of investments. The
strategy is not suitable for all potential clients. We select investment opportunities and invest
client assets in various types of securities including equity (“stock”) positions, exchange-traded
funds (“ETFs”), investment company (“mutual funds”) products, and fixed income/debt (“bond”)
instruments. At times, if deemed in the best interest of the client, we will also employ margin,
options and/or leveraged and inverse ETFs on behalf of clients. We may also review and discuss
a client’s prior investment history, as well as family composition and background. We may also
provide additional advice which is investment advisory in nature (i.e., opinions relating to asset
allocation, cash flow, risk management and various other financial issues).
1 Lighthouse Retirement is the doing-business-as name for Martin D. Parlato & Associates, Inc. Lighthouse Retirement began as a Sole
Proprietorship of Martin D. Parlato. In the fall of 2012, Martin D. Parlato & Associates, LLC was organized as a Florida Limited Liability
Company and acquired all the assets of the existing advisory firm Martin D. Parlato, Sole Proprietorship. In March of 2017, Martin D.
Parlato & Associates, LLC was converted to a corporation.
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You can find more information about our management services under “Investment Management”
in Item 5, “Fees & Compensation” below and further description of our investment strategies
under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss.”
Selection of Other Advisers
At times, we direct clients to third-party investment advisers. Before selecting other advisers for
clients, we will verify that all recommended advisers are properly licensed, notice filed, or
exempt in the states where we are recommending the adviser to clients. Specifically, the
Company participates in the Model Marketplace of Altruist LLC (“Altruist LLC”), an SEC registered
investment adviser and affiliate of Altruist Financial LLC. At times, we will assign to client
accounts any of the available Altruist LLC generated portfolios, third-party portfolios, or other
portfolios made available through Altruist LLC’s Model Marketplace. All Altruist LLC advisory fees
for assigned portfolios are charged directly to client accounts, and are separate from, and in
addition to, the fees assessed by us of our advisory services.
At times, we will also utilize separate account managers available through the Managers Resource
Network offered by Envestnet Asset Management, Inc. (“Envestnet”), an unaffiliated SEC
registered investment adviser. We will select one or more separate account managers available
through the Envestnet platform. Once selected, the Company will monitor the separate account
managers, and shall have discretion to add, remove, and change managers, as well as change
the allocation of assets among managers, on our discretion when believed to be in the client’s
best interest. The independent money managers will have discretionary authority to maintain
the designated allocation in the client’s portfolio. Accounts managed by independent money
managers are managed in accordance with their respective investment guidelines and
restrictions; and generally are not tailored to the individualized needs of any particular investor.
We will provide clients using the Envestnet platform with the required disclosure document(s) of
Envestnet and each independent manager. Separate and apart from our Company’s fee (as
discussed in Item 5 below), Envestnet and the independent money managers will charge clients
a fee according to Envestnet’s and the independent money manager’s filings, disclosures, and
any written agreements with clients.
In other cases, we will manage client accounts on a discretionary basis based on advice provided
to us by unaffiliated investment advisers (“Model Manager”) as to the securities and other
investments to be purchased and sold for a particular strategy. We will generally implement the
Model Manager’s recommendations without change, subject to any reasonable restrictions the
client may impose. The Model Manager assesses a fee based upon the assets under management
in the account(s) of each client whose assets, or a portion thereof, are being managed by the us
with use of the Model Manager’s signals. While we will remit payment directly to the Model
Manager, all Model Manager advisory fees are separate from, and in addition to, the fees assessed
by us for our advisory services. As such, client assets managed pursuant to the Model Manager’s
strategy will pay higher fees than assets managed solely by us.
Variable Annuity and Insurance Products
We also provide management services to clients owning variable annuity or life insurance
products. From time to time, we will recommend no-load variable annuities from Nationwide
Advisory Solutions (formerly Jefferson National) (“Nationwide”). In most instances, we are not
involved in the decision-making process on which product the Client should purchase, and the
Client generally makes this decision with their registered representative or the broker-dealer.
After purchasing an insurance product, we can be engaged by the Client to manage proprietary
investment strategies contained within the variable annuity product. Specifics regarding the
annuity are found in the annuity prospectus and application documents. The Client should review
the prospectus carefully before investing
Financial Planning
Our financial planning services range from comprehensive financial planning to more focused
consultations, depending on the needs of each client. Generally, we evaluate the client’s
financial, business, and investment information and make recommendations designed with the
intention of achieving the client’s overall goals and objectives. Clients have the option of utilizing
our services to implement certain investment recommendations but are under no obligation to
do so. Advice and recommendations may also be given on non-securities matters and any
implementation of our recommendations is entirely at the client’s discretion. Clients are always
free to accept or reject any or all recommendations made by the Company, and Clients retain
the authority and discretion on whether to implement any recommendations.
Clients should understand that a potential conflict of interest exists if we recommend our own
investment management services. Financial planning recommendations are based on the client’s
financial situation at the time the recommendations are provided and are based on the
information provided by the client. In addition, certain assumptions may be made with respect
to interest and inflation rates, use of past trends, and performance of the market and economy.
Past performance is in no way an indication of future performance and we cannot offer any
guarantees or promises that the Client’s financial goals and objectives will be met. As a client’s
financial situation, goals, objectives, or needs change, the client is strongly urged to promptly
notify the Company. For more information on the risks associated with investing, please refer to
Item 8, below. Please refer to Item 5 below for detailed information on fees and compensation
for these services.
Advisory Agreements
Information Received by Individual Clients
At the onset of the client relationship, we gather information about the client. We do not assume
responsibility for the accuracy of the information provided by the client and are not obligated to
verify any information received from the client or from any of the client’s other professionals
(e.g., attorney, accountant, etc.). Under all circumstances, clients are responsible for promptly
notifying us in writing of any material changes to the client’s objectives, risk tolerance, time
horizon, and financial goals. In the event a client notifies us of any changes, we will review such
changes and implement any necessary revisions to the client’s portfolio.
Client Agreements and Disclosures
Each client is required to enter into a written agreement with us setting forth the terms and
conditions under which we will render our services (the “Agreement”). In accordance with
applicable laws and regulations, we will provide our disclosure brochure (ADV Part 2A), brochure
supplement (ADV Part 2B) and most recent Privacy Notice to each client prior to or
contemporaneously with the execution of the Agreement. The Agreement between us and the
client will continue in effect until terminated in writing by either party pursuant to the terms of
the Agreement. Neither the Company nor the client may assign the Agreement without the prior
consent of the other party. Transactions that do not result in a change of actual control or
management of the Company shall not be considered an assignment. '
Participation in Wrap Programs
We do not participate in any wrap programs currently.
Assets Under Management
As of December 31, 2023, the following represents the amount of client assets under management
by the Company on a discretionary and non-discretionary basis:
Discretionary Accounts .................................... $ 139,022,779
Non-Discretionary Accounts ............................... $ 0
FEES & COMPENSATION
Investment Management Fees
Our typical fee for Investment Management Services is based upon a percentage of assets under
management and are fixed at a rate that will vary by client up to 2.00% of assets under
management, subject to a $250/quarter minimum fee. For the avoidance of doubt, the fixed rate
is an absolute, agreed-upon amount and will not fluctuate up or down pursuant to a prescribed
“break-point” schedule. The exact fee for each client is set forth in the client’s Agreement and
is based on factors such as: client’s total assets under management; client’s financial complexity;
and anticipated or requested frequency of client interaction.
Generally, pursuant to client instructions and consent, we will directly debit the client’s
custodial accounts for fees related to Investment Management Services. Unless otherwise agreed
upon as part of the client Agreement, management fees are billed in advance, at the beginning
of each quarter, based upon the market value of assets under management within client’s
custodial account (including cash and cash equivalents) based upon a 365-day count (i.e., for
quarterly billing we divide by the number of days in the upcoming calendar quarter).
The fee structure outlined above will be used for all assets under management including assets
managed at Nationwide (otherwise known as Jefferson National). However, for accounts held
through Nationwide, we will not automatically debit the client’s account. Rather, Nationwide
will conduct the billing in the client’s account, and remit to the firm our relevant fees.
Minimum Fee
If a client maintains less than $500,000 of assets under management, and fees are otherwise less
than $1,000 annually, the Firm will typically assess an annual minimum fee of $1,000. This means
combined accounts with a small balance may pay a higher fee on a percentage basis than they
would otherwise according to the standard fee schedule above. The firm has the discretion to
waive the minimum fee.
New Accounts
The initial fee for Investment Management Services shall be based on the client’s accounts’
market value (including cash and cash equivalents) at the inception of our management (i.e., the
date the account(s) is funded at the custodian) and shall be prorated for the number of days in
the quarter that the account is under our management. Subsequent quarterly fees shall be
assessed in accordance with the terms above.
New Money on Existing Accounts
Assets deposited into managed accounts between billing cycles will be subject to pro-rated
partial billing procedures as outlined above. While we do not want to discourage clients from
investing additional capital for their future; such deposits require modifications and adjustments
to the client’s investment allocation and are considered managed assets as soon as they are
funded at the custodian. Conversely, for assets clients may withdraw during the quarter, we do
not make partial refunds of their fees. Just as with deposits, withdrawals from your portfolio will
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require modifications and adjustments to be made to correct the allocation of assets in the
accounts.
At times, we will utilize margin in client accounts (please refer to Item 8 below for detailed
information regarding the risks surrounding margin). When utilizing margin strategies as part of
a client’s portfolio account, we use the “gross value” of the client’s margin account assets for
determining fees. Thus, fees are charged on the amount of assets in the underlying client
account, as well as the margin portion of the account. For example, in an account holding $100K
in equities, but $25K is attributable to margin loan, the entire $100K will be included when
determining fees. This creates a conflict of interest in that we have an incentive to utilize margin
accounts to receive additional fees. We mitigate this conflict of interest by disclosing it to clients
as part of this Brochure and verbally prior to opening any margin accounts. Further, as part of
our fiduciary duty to clients, we always endeavor to act in the client’s best interest, and
recommendations will only be made to the extent that they are reasonably believed to be in the
best interests of the client.
Advisory fees will typically be deducted first from any money market funds or cash balances. If
such assets are insufficient to satisfy payment of such fees, a portion of the account assets will
be liquidated to cover the fees. Typically, unless instructed otherwise, each client account will
be billed individually for its respective share of fees. However, we will at times
disproportionately bill accounts for fees should such actions be necessary due to insufficient
funds in any respective account, or if doing so is deemed to be in the best interest of a client.
Fees are negotiable and arrangements with any client can differ from those described above.
Negotiated fees will be captured in and agreed upon by the client as part of the client’s
Agreement. In addition, for family and friends of the Company, we will at times, in our sole
discretion, reduce or waive management fees in their entirety.
We may amend our fee schedule at any time by giving thirty (30) days advanced written notice
to clients. Although we believe our Investment Management Fees are competitive, clients should
be aware that lower fees for comparable services may be available from other sources.
Financial Planning Fees
Fees for our Financial Planning Services will be charged either at an hourly rate of $250 per hour,
or at a fixed annual rate $4,500. Financial Planning Fees may be reduced, or waived in their
entirety, if the Firm also provides additional services, such as Investment Management Services,
to the client.
Clients receiving “one-time” Financial Planning Services are generally requested to pay the
entirety of the estimated fee upon execution of the Agreement. An invoice for any additional
services is issued on completion of the written analysis, which is payable upon receipt. Clients
under a one-time Agreement can terminate the Agreement, without penalty, at any time upon
written notice. At the time of termination, any prepaid fees will be prorated based on the amount
of work completed by the Firm as of the date the notice of termination is received, and any
unearned fees will be returned to the client. It is possible that if the client seeks to terminate
the Agreement, and substantial work has been done to provide services to the client, the client
may not receive any return of the initial payment.
Clients engaging for “ongoing” Services are requested to pay 50% of the negotiated first year flat
fee upon execution of the Agreement, with the remaining balance paid in 3 equal installments
billed quarterly in advance. Such fee will be payable upon receipt of the invoice. Clients under
an ongoing Agreement are subject to a term of one year from execution of the Agreement. Clients
terminating prior to the ending term will be invoiced for the balance of the fee, which is payable
within 30 days of notice of termination. Following the one-year term, fees under the Agreement
will automatically renew and will be billed quarterly in advance. After the initial term, clients
may terminate ongoing services at any time by providing thirty (30) days’ notice. At the time of
termination, any prepaid fees will be prorated based on the amount of work completed and
returned to the client.
Fee Exclusions/Other Fees and Expenses
The above fees for our Investment Management Services are exclusive of any charges imposed by
the custodial firm including, but not limited to: (i) any Exchange/SEC fees; (ii) certain transfer
taxes; (iii) service or account charges, including, postage/handling fees, electronic fund and wire
transfer fees, auction fees, debit balances, margin interest, certain odd-lot differentials and
mutual fund short-term redemption fees; and (iv) brokerage and execution costs associated with
securities held in your managed account. There can also be other fees charged to your account
that are unaffiliated with our services.
In addition, all fees paid to us for Investment Management Services are separate from any fees
and expenses charged on mutual fund shares by the investment company or by the investment
advisor managing the mutual fund portfolios. These expenses generally include management fees
and various fund expense, such as: redemption fees, account fees, and purchase fees may occur
but are the exception within managed accounts at institutional custodians. A complete
explanation of these expenses charged by the mutual funds is contained in each mutual fund’s
prospectus. You are encouraged to carefully read the fund prospectus.
Further, Nationwide typically imposes monthly and other fees for insurance and annuity
products. We do not share in such fees, and those fees are paid directly to Nationwide.
Termination of Investment Management Services
Either party (you or us) may terminate our provision of advisory services at any time by issuing
written notification to the other party. Such notification should include the date the termination
will go into effect, along with any final instructions on the account (i.e., liquidate the account,
finalize all transactions and/or cease all investment activity). In the event termination does not
fall on the last day of a calendar quarter, you shall be entitled to a pro-rated refund of the
prepaid quarterly management fee based upon the number of days remaining in the quarter after
the termination notice goes into effect. However, as we utilize billing systems that are
automated and require a date of termination to produce a pro-rata refund, you must provide
written notification of termination with a prescribed termination date. Once the termination
of investment advisory services has been implemented, neither party has any obligation to
the other – we no longer earn management fees or give investment advice and you become
responsible for making your own investment decisions.
PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT
We do not charge fees based on a share of capital gains or the capital appreciation of the
assets held in your accounts. Consequently, we do not engage in side-by-side management of
accounts that are charged a performance-based fee with accounts that are charged another
type of fee (such as assets under management). As described above, we provide advisory
services for a percentage of assets under management.