FIRMDESCRIPTION
Ares Financial Consulting LLC (AresFC) was founded in 2016 by Mr. Jeffrey Richter, who is the
sole owner of the firm.
AresFC provides personalized confidential financial planning and investment management to
individuals, pension and profit-sharing plans, trusts, estates, charitable organizations and small
businesses. Advice is provided through consultation with the client and may include
determination of financial objectives, identification of financial challenges, cash flow
management, tax planning, investment management, education funding, retirement planning,
and estate planning. AresFC may also be hired to give educational seminars or workshops.
AresFC operates on a fee-only basis, generally a flat dollar fee for services. No commissions in
any form are accepted by AresFC. AresFC does not sell annuities, insurance, stocks, bonds,
mutual funds, limited partnerships, or other commissioned products outside of a fee-based
managed account. However, the firm is affiliated with other entities, such as Ares Insurance,
that offers insurance products and services through individually licensed insurance agents.
Investment Advisor Representatives (IARs) of AresFC may also be individually licensed insurance
agents and accept commissions for insurance sales, away from AresFC, as an outside business
activity. No finder’s fees are accepted at AresFC and AresFC does not benefit financially from
insurance sales and services conducted by AresFC IARs away from AresFC.
AresFC does not act as a custodian of client assets. The client always maintains asset control.
AresFC places trades for clients under a limited power of attorney. Clients typically grant us
limited discretionary powers for trading purposes, but it’s not mandatory.
An evaluation of each client's situation may be provided to the client, often in the form of a
portfolio analysis report or financial plan. Frequent reviews of the assets under management
occur but are not necessarily communicated to the client unless immediate changes are
recommended and the IAR does not have trading discretion.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by
the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the event
they should occur.
The initial meeting, which may be by telephone or video conference, is typically free of charge
and is considered an exploratory interview to determine the extent to which financial planning
and investment management services offered by AresFC may be beneficial to the client.
PRINCIPALOWNERS
AresFC is wholly owned by Mr. Jeffrey Richter, Founder and CEO.
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TYPESOFADVISORYSERVICES
AresFC generally works with clients under two types of service arrangements – Limited Scope
Services and Comprehensive Services. Additionally, AresFC offers Corporate Retirement Plan
Consulting and Investment-Only Services.
Limited Scope Services – Under this arrangement, AresFC furnishes advice to clients on-
demand in a limited scope. Generally, this service can be divided into two subject matters –
planning advice/education and investment analysis. Possible topics for planning
advice/education matters are business owner consulting, cash flow and debt management,
charitable giving strategies, college savings, employee benefits optimization (for a company or
employee), educational workshops, estate planning, financial goal refinement, retirement
planning, investment asset allocation and risk management, tax planning. Portfolio Analysis
generally focuses on risk, performance, and fees. If applicable, an assessment report will be
created and may be supplemented by a formal financial plan and/or performance reports,
typically generated using a software program. In some cases, clients may hire us to spend time
educating them on various financial concepts of their choosing.
Comprehensive Services – Under this arrangement, AresFC furnishes advice to clients both on-
demand and proactively on an on-going basis. A service plan will be customized for clients
based on their needs for our time and expertise. Below represents a list of services we may
provide to a client under this arrangement:
Financial planning and advice – The most important service we can offer to clients is to
help them achieve peace of mind through proactive planning and quality advice. The
following is a list of our advice offering:
o Management of a financial plan - We take the time to get to know our clients’
needs, wants, and desires so that we can devise a plan for them to live the life
that they want. When a client comes onboard with us, a formal financial plan is
created to help a client chart out their priorities and prepare for the unknown
result of life and risk-taking. Ongoing updates and goal management will be
provided as directed by the client.
o Financial Advice – Depending on the complexity of the client’s needs, we will
provide advice in one or many of the following areas: retirement planning,
college savings, estate planning, charitable giving, company benefits, risk
management and insurance, cash flow and debt management, and financial goal
management.
o Investment advice – We will do an assessment that will help us advise you in the
area of risk management and asset allocation. This will generally involve one or
more meetings, an analysis of your current situation, and a risk tolerance
questionnaire. AresFC will prepare an Investment Policy Statement (IPS) for the
client summarizing how investment management should be handled going
forward. Whether or not a client hires AresFC to manage investments, this IPS is
a valuable tool to guide clients through the potential challenges of investing.
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o Company Benefits – We can help clients navigate the many choices that come
with working for or owning a company with employee benefits.
Discretionary management of investment portfolios – AresFC will manage a client’s
investment accounts on a discretionary basis. This means that trades can be placed
without discussing them with the client first. All portfolios are customized to match the
client’s Investment Policy Statement (IPS). However, investment moves that are “non-
routine” would likely result in a scheduled discussion with the client before proceeding.
Rebalancing – Rebalancing is a service to make sure a client’s portfolio stays within the
bounds of their Investment Policy Statement (IPS). There are two types of rebalancing
offered by AresFC:
o Basic – AresFC will rebalance at an account level only, once a year in frequency.
This is appropriate for clients with only one or two investment accounts and a
relatively simple IPS. This is the default option if Enhanced Rebalancing is not
elected in the client service agreement.
o Enhanced – AresFC will look for household level optimizations and rebalance up
to four times a year. This is appropriate for clients in a high tax bracket, over
two investment accounts and a more complex IPS.
Formal review meetings – Clients will be entitled to a formal annual review meeting but
may choose to have more frequent meetings. The number of meetings per year will be
agreed upon in the AresFC Client Service Agreement. AresFC offers to hold client
meetings in person (at one of our offices or at another mutually agreed upon location),
over the phone, or over the internet via web-meeting.
Telephone and email access to advisory team – Things come up during the year in
between formal meetings. AresFC is dedicated to respond to client requests and
questions in a timely manner throughout the year.
Access to and management of non-commission insurance products – Insurance is a key
component of a comprehensive financial plan. AresFC has access to products that do
not pay a commission and may provide an advantage for the client over commission-
based insurance products. AresFC helps clients understand their insurance needs,
assists in the purchasing process, and assists with the ongoing management needs of
the insurance products owned by the client.
Access to non-commission alternative investment products – Alternative investments
may be desired by the client and/or presented by AresFC. By accessing these
investments through AresFC, clients may gain an advantage over commission-based
products, typically in the form of a discounted purchase price, a share class with lower
internal costs, or an increase in the number of shares bought for the same investment
amount.
Business owner consulting – Clients that are business owners may wish to consult with
AresFC on a wide variety of issues pertaining to running a business. AresFC consultants
will have varying degrees of experience working with businesses of different sizes and in
different industries. This consulting service may be appropriate when AresFC can
leverage the firm’s cumulative experience and expertise to advise on operational or
economic efficiencies for the client’s business.
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Online tools
o Subscription to the AresFC monthly newsletter and other timely articles
proactively sent by AresFC
o Client portal with access to consolidated client account information,
performance reporting tools, and a secure document vault
Note: AresFC does not typically provide investment management services as a stand-alone
service. We believe that successful management of a portfolio is directly tied to the client’s
goals and circumstances (i.e. their financial plan). Only under special circumstances will an
exception be made (see Investment-Only Services section).
Corporate Retirement Plan Consulting – Under this arrangement, AresFC provides consulting
services for companies with regards to their retirement plan benefits. Services are tailored to
the needs of the client and may include the following services:
Fiduciary Services:
Review Plan and recommend Plan vendors
Non-Fiduciary Services:
Provide educational presentations to participants, either in person, via conference call,
or via webinar.
During established times (“Office Hours”), advisor will (in person or by telephone)
respond to general questions from participants regarding Plan features, general
investment concepts (but in no event will AresFC or the Investment Adviser
Representative provide investment advice to participants), or general financial planning
concepts.
Manage the implementation of changes in Plan design and/or investment options as
directed by the Plan Sponsor, but in no event will AresFC or the Investment Adviser
Representative provide any advice with respect to selection of investment options for
the Plan or otherwise provide advice with respect to performance of investment
options.
AresFC acknowledges its role as a fiduciary under the Employee Retirement Income Security Act
(“ERISA”) as it pertains to the Fiduciary Services performed above.
Neither AresFC nor the Investment Adviser Representative shall render “investment advice” to
the Plan or participants in the Plan, including without limitation investment advice under ERISA
§ 3(21) or ERISA § 3(38), advice regarding investment policies or strategy or the allocation of
assets among the options in the Plan. Further, neither AresFC nor the Investment Adviser
Representative is responsible for plan administration.
In performing the Non-Fiduciary Services above, AresFC is not acting as a fiduciary of the Plan as
defined in ERISA. These services, which are outside the scope of “investment advice”, include
the dissemination of plan information or general financial, investment and retirement
information.
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In performing both Non-Fiduciary Services and Fiduciary Services, AresFC does not act as, nor
has AresFC agreed to assume the duties of a trustee or the Plan Administrator, as defined in
ERISA.
Third Party Money Managers - AresFC may determine that opening an account with a
professional independent third- party money manager is in our clients’ best interests. If so, we
will provide you with information about the money manager, including the services they
provide and the fees they charge. You may approve or disapprove the use of the independent
money manager for your account.
Any money manager selected to manage an account for you will have discretion to determine
the securities to buy and sell for the account, subject to any reasonable restrictions imposed by
you. You will be provided with the money manager’s ADV Disclosure Brochure, which you
should carefully review for important details about the manager and their fees and services.
If we recommend the use of an independent money manager, AresFC will:
• Assist in the identification and ongoing review of your investment objectives
• Recommend and assist in the selection of appropriate money managers
• Recommend specific investment strategies offered by the money managers
• Assist in the review of performance and progress toward your investment objectives
• Recommend any appropriate changes to your investment strategy
• Recommend the hiring and firing of money managers, as needed.
Investment-Only Services – AresFC offers these two options:
1. Betterment – For clients that have relatively simple financial goals and seek a lower cost
option for investment management as the primary service, AresFC may recommend that
the Client appoint Betterment LLC as an investment sub-advisor and use Betterment
Securities as the custodian. Betterment uses algorithms to advise clients and manage
their accounts. These algorithms are developed, overseen, and monitored by
Betterment’s investment advisory personnel. Clients inform Betterment of their
financial goals and personal information through Betterment’s online applications,
thereby establishing an Investment Policy Statement (IPS). The algorithm then
recommends and builds a portfolio of exchange traded funds for each of the client’s
financial goals and account types. In the absence of a contrary direction, Betterment
periodically rebalances client portfolios so that in the face of fluctuating market prices
each Client’s portfolio remains within a range of the target allocation, keeping within
the bounds of the IPS. Betterment also offers optional tax loss harvesting and
automated asset location services. AresFC will review the Client’s IPS, accounts, and
goals at least annually to determine the suitability of the program. AresFC will also be
available to the Client for unlimited calls and/or emails related to their accounts at
Betterment as well as investments outside of Betterment. Clients who have needs
beyond these services may opt to engage AresFC separately in a limited scope capacity,
for an additional fee, or convert to a Comprehensive Services plan.
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2. American Funds – Under this arrangement, AresFC operates solely as an investment
advisor to clients. Although a suitability review is performed to establish client
investment objectives and parameters for which accounts will be managed, formal
financial planning is not part of this service. Clients in this situation who wish to add
additional services may opt to engage AresFC for financial planning separately, for an
additional fee, or convert to a Comprehensive Services plan. The portfolio’s assets will
be held in the American Funds F-2 share account(s) at Capital Bank and Trust Company
(CB&T), who serves as account custodian. This service is primarily for legacy clients, of
investment adviser representatives who join AresFC, who already have accounts at
CB&T and have previously paid an up-front fee to purchase mutual funds prior to
engaging AresFC. Upon engaging AresFC, any client assets not held in F-2 shares will be
converted to this new share class.
TAILOREDRELATIONSHIPS
AresFC has a duty of utmost good faith to act solely in the best interest of each of its clients.
AresFC utilizes model-based portfolios that match various levels of portfolio risk. Often times,
clients will be placed into those pre-constructed (but not static) models per their stated goals
and risk tolerance. If applicable, investment policy statements may be created that reflect each
clients’ unique objectives and preferences outside of the model portfolios. Clients may impose
restrictions on investing in certain securities or types of securities.
Agreements may not be assigned without prior written client consent.
AresFC does not participate in wrap fee programs as a Sponsor or Portfolio Manager.
ASSETSUNDERMANAGEMENT
As of December 31, 2023, AresFC manages approximately $185,889,545 in discretionary assets
for 714 accounts. AresFC does not manage any non-discretionary assets.
ASSETMANAGEMENT
Assets are invested primarily in no-load mutual funds and exchange-traded funds, usually
through discount brokers. Fund companies charge each fund shareholder an investment
management fee that is disclosed in the fund prospectus (reflected in the expense ratio).
Discount brokerages may charge a transaction fee for the purchase and sale of some funds.
Investments may also include: equities (stocks), warrants, corporate debt securities,
commercial paper, certificates of deposit, municipal securities, investment company securities
(mutual fund shares), U. S. government securities, alternative assets, options contracts, futures
contracts, and interests in partnerships.
Initial public offerings (IPOs) are not available through AresFC but may be available directly
through a discount broker-dealer firm.
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Stocks and bonds may be purchased or sold through a brokerage account when appropriate.
The brokerage firm (broker-dealer) charges a fee for stock and bond trades. AresFC does not
receive any transaction-based compensation, in any form, from fund companies or broker-
dealers.
TERMINATIONOFAGREEMENT
A Client or AresFC may terminate any of the arrangements at any time with written notice. A
final invoice will be generated based on the number of earned days (annualized fee divided by
365 X earned days) or hours worked if a fixed fee arrangement exists. If the client’s fees are
invoiced in advance, the calculated un-earned fee will be refunded within 30 days and any
completed work will be delivered to the client.
Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to
signing, the client agreement may be terminated by the client within five business days of
signing the contract without incurring any advisory fees.
FINANCIALPLANNINGCONFLICTOFINTERESTSTATEMENT
In the case where a client is receiving financial planning advice and insurance is part of the
conversation, a conflict exists between the interests of the investment advisor and the interests
of the client (if the insurance products mentioned are commission-based). Our clients are
under no obligation to act upon the investment advisor’s recommendations, and if the client
elects to act on any of the recommendations, the client is under no obligation to effect the
transaction through the investment advisor or its affiliates.
In the case where a client purchases insurance and a commission is paid to an AresFC
Investment Advisor Representative in the role of an insurance agent through an insurance
company or agency (as an approved Outside Business Activity) an AresFC advisory fee will not
be permitted to be charged to the client in addition to the commission for selling and/or
managing the policy. AresFC investment advisor representatives will recommend non-
commissionable insurance products, when available and as suitable, whichever would be in the
client’s best interest.
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