4.1. Formation and Ownership
February 2008 NUA Advisors, LLC was formed as a New Jersey Limited Liability
Company
July 2008 Registered as an Investment Advisor with primary registration in State of
Maine
April 2009 Converted to Maine Limited Liability Company
May 2013 Changed name to Innovative Advisory Group, LLC and continued to do
business as NUA Advisors
Converted to Massachusetts Limited Liability Company
September 2013 Changed primary registration to Commonwealth of Massachusetts
August 2014 Included the use of IAG Wealth Management for marketing. IAG Wealth
Management is only a description of the services provided, and not the
name or assumed name under which Innovative Advisory Group provides
its services. IAG is an acronym for Innovative Advisory Group, and Wealth
Management is a descriptive service definition. Used together as IAG
Wealth Management is a service mark of Innovative Advisory Group, LLC.
CRD #: 146618 SEC #: 801-122046
Innovative Advisory Group, LLC (IAG) is owned by two individuals equally through their
appropriate intermediate holding companies as follows:
Mr. Kirk Chisholm – Stirling Global Advisors, LLC
Mr. Rajeev Kotyan – Blue Haven Group, Inc.
Each of the individuals is a 100% owner of their respective holding company. It should be noted
that ownership of IAG does not imply that the person or entity can provide investment advisory
services. Only disclosed Management Persons and those listed as Investment Advisor
Representatives in IAG’s Brochure Supplement is permitted to provide investment advisory services
through or on behalf of IAG.
4.2. Management Person
Mr. Kirk Chisholm and Mr. Rajeev Kotyan are Management Persons of IAG based on the
appointment by Managers as passed by resolution of Operating Agreement of IAG. Management
persons may also be IAG’s Investment Advisor Representatives only if they are appropriately
licensed and registered in accordance with appropriate regulators. Currently these are the only
management persons of IAG, and all of them are also Investment Advisor Representatives.
Mr. Kirk Chisholm
Born April 1975; BA in Economics; Trinity College, Hartford, CT. Independent Representative and
Investment Adviser Representative with UBS (1999-2003), Smith Barney (2003-2005), Royal
Alliance (2005-2008). Mr. Kirk Chisholm’s CRD # is 4004975
Mr. Rajeev Kotyan
Born July 1970; Bachelor of Engineering (Computers & Finance) - India. Financial and Technology
Risk Management for various firms 1991-2005 including Citigroup, Investors Bank and Trust and
Dow Jones. Business Advisor and Planner, owner for Blue Haven Group, Inc. Mr. Rajeev Kotyan’s
CRD # is 5479610
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4.3. Services Offered
Investment Advisory Services
Innovative Advisory Group, LLC provides Investment Advisory Services with regard to, but not
limited to mutual funds, stocks, bonds, private and public partnerships, annuities, real estate
investment trusts and other investment products that may not be considered securities. IAG
provides full-service investment management which will take into consideration the clients’
individual needs, objectives and risk tolerance. IAG as a full-service investment advisor will address
such issues as financial goals, risk management, taxation, retirement goals, investments, education
and estate planning, relative to the investment management. It also may provide more limited and
isolated services based on the clients’ request and requirements. IAG offers its services to
individuals, as well as corporate clients (including small businesses which may be sole proprietors
and other unregistered businesses and partnerships). Either client or IAG may terminate this service
agreement at any time with written notice to the other.
Asset Management Accounts (AMA): IAG may act as the investment manager for a client's
portfolio. IAG in its capacity as an investment advisor and IAG's Investment Advisor
Representatives (IAR) will manage and direct specified assets of a client on a discretionary basis.
Clients may request IAG and IAG IAR’s for asset management on a non-discretionary basis, and
such may be permitted on a case-by-case basis and in discussion with the client. Clients will permit
trading authority to IAG's representatives to purchase and sell in the account pursuant to investment
objectives of the client, to liquidate previously purchased investments, and purchase and sell separate
accounts within annuities. Other investments such as equities, fixed income, structured products,
and other investment products may be purchased and sold at the client's requirements. In
authorizing the use of an AMA, the IAR obtains the necessary financial data from the client, assists
the client in determining suitability, investment requirements, education and/or restrictions and
assists the client in setting appropriate investment objectives. The client receives a monthly or
quarterly statement showing account activity as well as positions held in the account as directly
provided by the custodian, in accordance with the custodian’s policy and procedure. IAG does not
custody any assets. Additionally, the client receives confirmation of each transaction that occurs with
the AMA directly from the custodian of the AMA and will be within their policy. The client may
also receive reports describing performance, positions and activities directly from the custodian of
the AMA. While IAG is not responsible for the policy and procedures of the AMA custodian, IAG
will make efforts to make sure that the AMA custodian follows the mentioned requirements.
Plan Participant Accounts (PPA): Clients may provide IAG and IAG’s IAR with authorization to
manage assets held within an Employer Sponsored Plan (i.e. plan participant account). IAG shall
provide Client with allocation services within the PPA, restricted to the options available within the
PPA. Unless separate trading authorization is provided to IAG, Client will be responsible for the
implementation and execution of allocation recommendations within the PPA. Client may permit
trading authorization to IAG and IAR, if such is available by the Plan, upon which IAG and its IAR
shall carry out trades within the PPA on behalf of the Client. Client should expect to receive detailed
quarterly reports, statements and trade confirmations in accordance with the PPA policies and
procedure.
One-Participant Plan Accounts (OPA): These plans shall be treated as AMA, limited to Client and
Client spouse as defined in the Internal Revenue Code for One-Participant Plans.
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As of December 31, 2023 (approx. and rounded to the nearest $100,000.00)
Discretionary Assets Under Management $ 129,000,000.00
Non-discretionary Assets Under Management $ 00,000.00
Totals $ 129,000,000.00
Comprehensive Financial Planning Services
IAG shall provide the client with comprehensive Financial Planning Services that will include a
review of client's financial circumstances, financial goals and a written report of recommendations.
This information normally would cover present and anticipated assets and liabilities, including
insurance, savings, investments, and anticipated retirement or other employee benefits. The program
developed for clients will usually include general recommendations for a course of activity or
specific actions to be taken by Clients. For example, recommendations may be made that the Client
obtains insurance or revise existing coverage, establish an individual retirement account, increase or
decrease funds held in savings accounts or investment funds in securities. IAG may refer clients to a
tax accountant or attorney for development of tax or estate plans, in coordination with the financial
plan recommendations. IAG does not render legal, tax or accounting advice or prepare any legal
documents for clients. Client's personal attorney shall be solely responsible for providing legal
advice, legal opinions,
legal determinations and legal documents. Client's personal tax adviser or
accountant shall be solely responsible for any tax or accounting services provided to client. IAG may
also create a cash flow analysis or work with and advise clients as to the rearrangement of cash flow
in order to achieve certain goals and objectives such as buying a house, education planning,
retirement planning, etc.. Clients who receive Financial Planning Services may receive Investment
Advisory Services from IAG. Thus, IAG may have a conflict of interest when providing
Comprehensive Financial Planning Services because IAG may receive additional compensation if
Client chooses to use Investment Advisory Services from IAG. Client is under no obligation to use
IAG's Investment Advisory Services.
Some of the planning services are:
a. Credit Report Analysis: Review of the credit reports as made available by the client to IAG
from the various credit bureaus to analyze how the various accounts and account types are
affecting the positive or negative aspects of the client’s credit worthiness.
b. Cash Flow Analysis: Review of the inflows and outflows of cash that a client has, based on
the data provided by the client to IAG. The analysis provides the client an understanding of
their potential for savings, spending and investment, and assists in the determination of
financial projections.
c. Income Tax Analysis: Review from an investment advisor perspective, including but not
limited to investment tax gains or losses and retirement contribution impact. IAG does not
render comprehensive tax advice, and shall with client approval, work with the clients’ tax
accountant, as appropriate.
d. Retirement Analysis: Projection to determine if client will have the resources to achieve their
stated retirement goals, and/or to provide optional strategies to improve the probability of
success.
e. Estate Plan Analysis: Provide an investment advisor perspective, including but not limited to
allocation of portfolio to beneficiaries and charities. IAG does not render legal advice, and
shall with client approval, work with clients’ estate planning attorney, as appropriate.
f. Insurance Analysis: Provide a review and analysis to include, but not limited to survivor
needs, disability needs, and long-term care needs. IAG hereby discloses that IAG is not
licensed to sell any insurance products, but the IAGs IAR’s may be licensed in certain states.
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g. Education Analysis: Project to determine if clients will have the resources to achieve their
stated education financial goals, and/or provide optional strategies and choice to improve
probability of success.
h. Individual Investment Analysis (non-securities investments): Provide a review of the non-
securities, based on the information that has been made available to the client, and/or from
publicly available sources, or from third-party providers and aggregators. IAG does not
provide legal or tax advice on the documents, and shall with client approval, work with the
client attorney and accountant, as appropriate.
i. Investment Portfolio Analysis: Provide a review of client investment portfolio, including but
not limited to the status, and the projections based on market assumptions. This service is
only available to client who do not use IAG’s Investment Advisory Services.
Start: Disclosures Specific to State of California Residents
In accordance with California Code of Regulations Title 10, Chapter 3, Subchapter 2, Article 10,
Section 260.235.2, IAG hereby discloses:
a) A conflict exists between the interests of IAG and the interests of the Client, and neither the
Client nor IAG are under any obligation to align their interests,
b) Client is under no obligation to act upon the financial plan recommendations provided by IAG,
c) If the Client elects to act on any of the financial plan recommendations provided by IAG, the
client is under no obligation to effect any transactions through the services provided by IAG.
End: Disclosures Specific to State of California Residents
Business Retirement Planning Services
IAG provides Business Retirement Planning Services with regard to, but not limited to development
and selection of Employee Retirement Plans. The services would include the following:
A. Plan and Platform Identification Services: This shall include plan participant profiling of risk,
retirement goals and objective, investment objective and estate planning objectives for the
purposes of development and/or identification of appropriate plans and platforms which meet
the requirements of the Client and plan participants.
B. Plan and Platform Document and Operation Review: This shall include review and analysis of
plan documents and platform operations, in accordance with the goals of the Client and the plan
participants.
C. Plan Administration Review: This shall include either, research and recommendation of Plan
Administrator to satisfy the need of the Plan or review and analysis of the Plan Administrator in
accordance with the Plan Document requirements.
D. Investment Recommendation Services: This shall include either the recommendation of types
investment, including but not limited to mutual funds, stocks, bonds, private and public
partnerships, annuities, real estate investment trusts and other investment products that may not
be considered securities, and/or the research and analysis of existing investments in the Plan, in
accordance with the Plan Documents.
Client may choose any/or all of the above services which shall determine the scope of the service
provided. As part of the service, IAG may refer clients to a specific Plan sponsor, platform,
broker(s), custodian(s) and administrator(s), accountants or attorneys for development,
administration, auditing or legal advice. IAG does not render legal, tax, plan sponsorship, or
administration of the Plan. Client's attorney shall be solely responsible for providing legal advice,
legal opinions, legal determinations and legal documents associated with the Plan or contracts with
the third-party provider, accountant or any other provider to the Plan. IAG shall provide review
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and analysis of the Plan on an annual basis, at the anniversary of the Plan, or anniversary of
agreement. IAG does not provide any ongoing supervision or monitoring of the Plan. Either client
or IAG may terminate this agreement at any time with written notice to the other.
IAG does not provide investment advice or allocation services to the Plan participants, unless the
individual plan participants have signed a separate Investment Advisory Services Agreement or
Comprehensive Financial Planning Services Agreement with IAG or is a one-participant plan. Plan
assets shall not be considered as Assets under Management, and the cumulative value of the Plan
Assets may only be used for the purposes of charging fees.
As of December 31, 2023 (approx. and rounded to the nearest $100,000.00)
ERISA Discretionary Plan Assets $ 0.00
ERISA Non-discretionary Plan Assets $ 0.00
Totals $ 0.00
Other Special Services
IAG may provide other services, such as identification of third-party money managers, business
management consulting, family office, office management or similar services under any other name.
Such services are discussed with the client, and terms and fees negotiated between the individual,
family or business requesting such services with IAG. Other services may be provided to clients who
do not use any of the aforementioned services provided by IAG and IAG IARs. With any of such
services, neither IAG nor IAG IARs shall have any custody of any client accounts in accordance
with
Item 15: Custody.
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