We are dedicated to providing individuals and other types of clients with a wide array of investment
advisory services. Our firm is a limited liability company formed in the State of California. Our firm
has been in business as an investment adviser since 2014 and is owned by Paul Grace and Chris
Winkler indirectly through his company, Legacy Advisors Agency, LLC.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Description of the Types of Advisory Services We Offer
Comprehensive Portfolio Management:
Our Comprehensive Portfolio Management service is our primary business activity. This service
encompasses asset management as well as providing financial planning/financial consulting to
clients. It is designed to assist clients in meeting their financial goals through the use of financial
investments. We conduct at least one, but sometimes more than one meeting (in person if possible,
otherwise via telephone conference) with clients in order to understand their current financial
situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we
propose an investment approach to the client. We may propose an investment portfolio, consisting
of exchange traded funds (“ETFs”), mutual funds, individual stocks or bonds, or other securities. Upon
the client’s agreement to the proposed investment plan, we work with the client to establish or
transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts
are under our management, we review such accounts on a regular basis and at least quarterly. We
may periodically rebalance or adjust client accounts under our management. If the client experiences
any significant changes to his/her financial or personal circumstances, the client must notify us so
that we can consider such information in managing the client’s investments.
We utilize Third Party Money Managers, where we design an investment portfolio on a fee-only basis
for a percentage of assets in conjunction with another registered investment advisory firm. Before
selecting other advisers, we make sure that they are properly licensed or registered. Currently, we
have Third Party Money Managers arrangements in place with Buckingham Strategic Partners, LLC
(“Buckingham”), AssetMark, Inc. (“AssetMark), and Flexible Plan Investments, Ltd. (“Flexible Plan
Investments”).
Financial Planning & Consulting:
We may also provide a variety of financial planning and consulting services to individuals, families
and other clients regarding the management of their financial resources based upon an analysis of
the client’s current situation, goals, and objectives. Generally, such financial planning services will
involve preparing a financial plan or rendering a financial consultation for clients based on the
client’s financial goals and objectives. This planning or consulting may encompass one or more of
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the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning,
Education Planning, Corporate and Personal Tax Planning, Corporate Structure, Real Estate Analysis,
Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal
Financial Planning.
Our written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. For example,
recommendations may be made that the clients begin or revise investment programs, create or revise
wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or
establish education or charitable giving programs. It should also be noted that we refer clients to an
accountant, attorney or other specialist,
as necessary for non-advisory related services. For written
financial planning engagements, we provide our clients with a written summary of their financial
situation, observations, and recommendations. For financial consulting engagements, we usually do
not provide our clients with a written summary of our observations and recommendations as the
process is less formal than our planning service. Plans or consultations are typically completed within
six (6) months of the client signing a contract with us, assuming that all the information and
documents we request from the client are provided to us promptly. Implementation of the
recommendations will be at the discretion of the client.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring, and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
Establishing an Investment Policy Statement – Our firm will assist in the development of a statement
that summarizes the investment goals and objectives along with the broad strategies to be employed
to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options
and make recommendations for appropriate changes.
Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models
to aid Participants in developing strategies to meet their investment objectives, time horizon, financial
situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and notify the
client in the event of over/underperformance and in times of market volatility.
Participant Education – Our firm will provide opportunities to educate plan participants about their
retirement plan offerings, different investment options, and general guidance on allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
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Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Comprehensive Portfolio
Management service. Additionally, we offer general investment advice to clients utilizing our
Financial Planning & Consulting or Retirement Plan Consulting services.
Each client has the opportunity to place reasonable restrictions on the types of investments to be
held in the portfolio. Restrictions on investments in certain securities or types of securities may not
be possible due to the level of difficulty this would entail in managing the account. Restrictions would
be limited to our Comprehensive Portfolio Management service. We do not manage assets through
our other services.
Participation in Wrap Fee Programs
Wrap fee programs are only available to Legacy Clients. Wrap fee programs are only offered through
Buckingham, AssetMark, and Flexible Plan Investments (herein after jointly referred to as “Third
Party Money Managers”). This is further described in Part 2A, Appendix 1 (the “Wrap Fee Program
Brochure”) of the Third Party Money Managers Form ADV Brochure. However, we do not offer a wrap
fee program.
Regulatory Assets Under Management
As of December 31, 2022, we manage1 $64,344,517 on a discretionary basis and $80,639,766 on a
non-discretionary basis.