My Personal CFO offers a variety of advisory services, which include financial planning and consulting
services, wealth management services, and retirement plan services. Prior to My Personal CFO
rendering any of the foregoing advisory services, clients are required to enter into one or more written
agreements with My Personal CFO setting forth the relevant terms and conditions of the advisory
relationship (the “Advisory Agreement”).
My Personal CFO was formed in 2018 and is principally owned by Mark Bernazzani. As of December
31, 2023, My Personal CFO had $277, 000,000.00 in assets under management, of which all was
managed on a discretionary basis.
While this brochure generally describes the business of My Personal CFO, certain sections also discuss
the ,activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other
persons occupying a similar status or performing similar functions), employees or other persons who
provide investment advice on My Personal CFO’s behalf and are subject to the Firm’s supervision or
control.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title 1 of the Employee Retirement Income
Act (ERISA) and the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
•
Avoid misleading statements about conflicts of interest, fees, and investments;
•
Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than a level fee that is reasonable for our services; and
• Give you basic information about conflicts of interest.
Financial Planning and Consulting Services
My Personal CFO offers clients a broad range of financial planning and consulting services, which
include any or all of the below-mentioned areas. Examples of the type of advice included for each area
are included for reference.
• Education Planning - advising clients on the appropriate amount of capital required to pay for college
costs, including a review of factors such as the age of potential students, the cost of potential anticipated
higher education institution(s), inflation factors, and appropriate college savings programs;
•
Insurance Planning - reviewing clients’ existing life, health, and property insurance contracts and
making recommendations based on clients’ particular needs, such as retirement assets, college funding
assets, and general liability coverage;
•
Tax Planning and Compliance - reviewing clients’ federal and state personal tax returns and providing
planning strategies designed to reduce clients’ overall effective income tax rates based on their current
taxable and qualified investments and income sources, as appropriate;
• Retirement Planning - counseling clients on appropriate accumulation and distribution techniques
concerning their taxable and qualified investments;
•
Trust and Estate Planning – reviewing clients existing estate planning documents consisting of wills,
trusts, and power of attorney forms and providing guidance on minimizing estate taxes and risks and/or
opportunities related to the implementation and execution of their estate plan;
•
Cash Flow Forecasting and Budgeting – reviewing clients income and regular expenses and offering
analysis and recommendations related to maintaining sufficient assets to address planned and
unforeseen expenses;
• Philanthropic Advisory – consulting with clients on creative ways to maximize their charitable goals
while leveraging income tax rules to also meet their other objectives, including helping clients understand
the various tax advantages to different giving strategies;
•
Executive Benefits Planning – advising clients on various aspects of their company benefit plans,
including how to leverage those plans for tax planning purposes and risk management;
• Equity Compensation – providing counsel to clients who are recipients of equity from their employers,
including the tax advantages or consequences and the impact of the equity to clients’ overall wealth and
investments; and
• Business Succession Advice – providing recommendations to entrepreneurial clients who need to
explore the business and tax implications of succession planning.
While each of these services is available on a stand-alone basis, certain of them can also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below).
In performing these services, My Personal CFO is not required to verify any information received from
the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly
authorized to rely on such information. My Personal CFO recommends certain clients engage the Firm
for additional related services and/or other professionals to implement its recommendations. Clients are
advised that a conflict of interest exists for the Firm to recommend that clients engage My Personal CFO
or its affiliates to provide additional services for compensation, including the Firm’s wealth management
services discussed in this Item 4 and the accounting services discussed in Item
10, below. Clients retain
absolute discretion over all
decisions regarding implementation and are under no obligation to act upon any of the recommendations
made by My Personal CFO under a financial planning or consulting engagement. Further, clients have
the option to purchase investment products that the Firm recommends through other professionals (e.g.,
brokers or investment advisers) are not affiliated with the Firm. Clients are advised that it remains their
responsibility to promptly notify the Firm of any change in their financial situation or investment
objectives for the purpose of reviewing, evaluating, or revising My Personal CFO’s recommendations
and/or services.
Wealth Management Services
My Personal CFO manages client investment portfolios thorough a wealth management relationship,
whereby My Personal CFO provides a broad range of financial planning and consulting services and
discretionary investment management services.
In managing client investment portfolios, My Personal CFO primarily allocates client assets among
various mutual funds and exchange-traded funds (“ETFs”). Where appropriate, the Firm uses standard
exchange- traded option contracts (i.e. put or call option contacts) as a risk management tool. Where
appropriate, the Firm also provides advice about any type of legacy position or other investment held in
client portfolios, however, clients should not assume that these assets are being continuously monitored
or otherwise advised on by the Firm unless specifically agreed upon. Clients can also engage My Personal
CFO to manage and/or advise on certain investment products that are not maintained at their primary
custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored
retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, My Personal CFO directs
or recommends the allocation of client assets among the various investment options available with the
product. These assets are generally maintained at the underwriting insurance company, or the custodian
designated by the product’s provider.
My Personal CFO tailors its advisory services to meet the needs of its individual clients and seeks to
ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs
and objectives. My Personal CFO consults with clients on an initial and ongoing basis to assess their
specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the
management of their portfolios. Clients are advised to promptly notify My Personal CFO if there are
changes in their financial situation or if they wish to place any limitations on the management of their
portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts
if My Personal CFO determines, in its sole discretion, the conditions will not materially impact the
performance of a management strategy or prove overly burdensome to the Firm’s management efforts.
Retirement Plan Services
My Personal CFO provides advisory services to defined benefit plans subject to the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). Each defined benefit plan client is
required to enter into an investment advisory or investment management agreement with My Personal
CFO describing the services that My Personal CFO will perform for the retirement plan client and/or its
participants. For defined benefit plans, My Personal CFO’s advisory services typically consist of
investing and reinvesting the defined benefit plan’s assets on a discretionary basis. In this capacity, My
Personal CFO provides ERISA fiduciary services to defined benefit plans and is deemed to be acting as
an investment manager under Section 3(38) of ERISA. In managing defined benefit plans’ investment
portfolios, My Personal CFO primarily allocates assets among various mutual funds and exchange-traded
funds (“ETFs”). Where appropriate, the Firm uses standard exchange-traded option contracts (i.e. put
or call option contacts) as a risk management tool.
Sub-Advisors
My Personal CFO retains sub-advisors or third-party managers to assist with managing portfolios if you
need or are seeking a specific type of investment management or strategy. Sub-advisors provide
investment allocations and securities selection and may execute securities transactions in your accounts
pursuant to the agreement between Tactive and the subadvisor. This relationship will be fully disclosed
with those sub-advisors in your Advisory Agreement. Certain sub-advisors use ETFs and or mutual
funds in Client portfolios to which they are manager or sub-advisor. In these cases, the selection of
these investments creates conflicts of interest for the sub-advisor. The sub-advisors disclose conflicts of
interests including their selection of such investments, in their Form ADV 2. We advise you in
establishing investment objectives, and work with the sub-advisors to ensure an appropriate investment
strategy for you. You are provided the sub-advisor’s Form ADV Part 2, and may be asked to enter into
a separate Advisory Agreement.
Alternative Investments
Our Firm allows the use of Alternative Investments, if deemed suitable for the client portfolio. All client portfolios
that are invested in Alternative Investments will be periodically reviewed by the CCO. Proper due diligence will be
completed for all investments offered to clients which may include documentation of the firm’s analysis of such
alternative investments, and a description of how the firm will monitor these types of investments. Alternative
Investments represent an asset class outside of the realm of traditional stocks, bonds and cash equivalents and
may include; Opportunity zones, etc. . Most alternative investments have a high risk associated with including in
a client’s portfolio. (See Item 8: Risks)