Brookwood Investment Group (“Brookwood”) is a registered investment advisor based in Phoenix,
Arizona, formed in 2021 as a Limited Liability Company (LLC) under the laws of the State of
Arizona, wholly owned by Kimberley A. Raimondo, Esq. and Robert W. Raimondo, JD.
Brookwood has a network of proprietary partners offices throughout the country as well as partner
offices that provide advisory services under local “doing business as” names. A complete list of
approved doing business as names came be found by searching for Brookwood Investment Group,
CRD: 316544 on at
www.adviserinfo.sec.gov. The investment advisory services of Brookwood are
provided to you through an appropriately licensed and qualified individual who is an investment
advisor representative of Brookwood (referred to as your investment adviser representative
throughout this brochure). Your investment advisor representative may either be an employee of
Brookwood or an independent contractor.
Within the parameters set by Brookwood (as disclosed in Item 5 – Fees and Compensation),
investment advisor representatives are free, to negotiate the asset management, financial planning,
and service fees charged to clients for the services provided and/or to waive, at the advisor’s
expense, clients’ operational and custodian fees. It is possible that different investment advisor
representatives may charge different fees for providing the same service to clients. The specific
level of services you will receive, and the fees you will be charged, by Brookwood will be
specified in your advisory services agreement.
Brookwood provides the following services:
Our focus is to manage investment portfolios for individual clients, high net-worth families, and
businesses. We also provide personal financial planning and investment advice designed to work
with our clients’ financial goals, objectives, and risk tolerances.
Portfolio Management Services. When providing Portfolio Management services, Brookwood
makes investment recommendations; implements such recommendations; and provides ongoing
monitoring and management of each account. Each portfolio is tailored to the individual needs of a
particular Client (whether an individual, a family or a business) through an assessment conducted
prior to an engagement. Clients may impose restrictions related to the level of discretion granted,
the types of investments used, etc. Clientsthat engage Brookwood on a non-discretionary
investment basis must be willing to accept that Brookwood cannot effect any account transactions
without obtaining prior consent to any such transaction(s) from the Client. Thus, in the event of a
market correction during which the Client is unavailable, Brookwood will be unable to effect any
account transactions (as it would for its discretionary Clients) without first obtaining the Client’s
consent. Terms of an actual engagement, including description of service, limitations and
restrictions, fees, etc., are all detailed before any engagement begins in a written Client agreement.
Financial Planning and Consulting Services. When providing Financial Planning/or Consulting
Servies, Brookwood provides financial planning and/or consulting services (including investment
and non-investment related matters, including estate planning, insurance planning, etc.) on a fixed
fee or hourly fee basis. Prior to engaging Brookwood to provide planning or consulting services,
Clients are required to enter into a
Financial Planning Agreement with Brookwood setting forth the
terms and conditions of the engagement (including termination), describing the scope of the
services to be provided, and the portion of the fee that is due from the Client prior to Brookwood
commencing services. The Client always retains absolute discretion over all such implementation
decisions and always has the rightwhether to accept or reject any recommendation from
Brookwood. Please Note: It is always the Client’s responsibility to promptly notify Brookwood if
there is ever any change in financial situation or investment objectives for the purpose of
reviewing, evaluating or revising Brookwood's previous recommendations and/or services.
Brookwood may provide financial planning and related consulting services regarding non
investment related matters, such as estate planning, tax planning, insurance, etc.
Estate/Tax Planning: Financial Planning and Consulting Services may include an analysis of your
exposure to estate taxes and a review of your current estate plan, which may include whether you
have a will, powers of attorney, trusts, and other related documents. Our advice may also include
ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning
strategies such as the use of applicable trusts. You should consult with a qualified attorney or
licensed tax professional when you initiate, update, or complete estate planning activities. We may
provide you with contact information for attorneys who specialize in estate planning when you
wish to hire an attorney for such purposes. From time-to-time, we may participate in meetings or
phone calls between you and your attorney with your approval or request. We may also refer you to
Estate Guru for Estate Planning services.
Estate Guru. Estate Guru is a third-party attorney guided digital estate planning service that
allows clients in need of estate planning to review, create or update tailored estate plans with
attorney guided software. Brookwood Advisors may help guide Clients through Estate Guru
software, but Brookwood Advisors are not attorneys and shall not provide legal advice. Typically,
clients will pay Estate Guru directly should they choose to utilize their services. In certain
circumstances, Estate Guru may determine a live attorney consultation is required and the Client
has the option to engage the Estate Guru network attorney directly to assist in more complex estate
matters. Brookwood does not receive any compensation from Estate Guru when client chooses to
utilize the platform or if client engages a live attorney for legal assistance.
Services provided by Brookwood should not be construed as legal or accounting advice, as
Brookwood does not prepare estate planning documents or tax returns. Brookwood may
recommend the services of legal or tax professionals or the use of Estate Guru. Clients are
reminded that they always have the right to decide whether to engage the services of any such
recommendation and are under no obligation to do so.
Implementation of Financial Planning Recommendations. Client retains absolute discretion
over all such implementation decisions and always has the right whether to accept or reject any
recommendation made by Brookwood or its representatives or any affiliated entities. Clients may
be offered insurance products through an affiliated entity, Brookwood Insurance Group, LLC (See
Item 10 of this Brochure for more information about affiliated entities). In the event Clients
purchase insurance products through an affiliated entity, the affiliated entity and or principals of
Brookwood may receive profits and your financial professional receives compensation in the form
of commission. While these individuals endeavor at all times to put the interests of the Clients first
as part of Brookwood's fiduciary duty, Clients should be aware that this practice presents a conflict
of interest because individuals providing investment advice on behalf of Brookwood, who are also
insurance agents may have an incentive to recommend products to Clients for the purpose of
generating commissions, rather than solely based on Client needs. Clients are under no obligation,
contractually or otherwise, to purchase insurance products through an affiliated entity or from your
Brookwood Advisor.
Selection of Other Advisers. Brookwood may direct clients to third party managers. Brookwood
will verify that all recommended managers are properly licensed, notice filed, or exempt from
registration prior to engaging the services of such managers..
Retirement Plan Services.
ERISA Section 3(21) Investment Advisor and 3(38) Investment Management Services
For employer-sponsored retirement plans, including cash balance plans, Brookwood provides its
Investment advisory services as an investment advisor as defined under Section 3(21) and as an
investment manager as defined under Section 3(38) of the Employee Retirement Income Security
Act of 1974, as amended (“ERISA”).
When serving as an ERISA 3(21) investment advisor, the plan sponsor and Brookwood share
fiduciary responsibility. The plan sponsor retains ultimate decision-making authority for the
investments and may accept or reject the recommendations in accordance with the terms of a
separate ERISA 3(21) Investment Advisor Agreement between Brookwood and the plan sponsor.
Brookwood may provides the following services to the plan sponsor including:
• Screen investments and make recommendations.
• Monitor the investments and suggest replacement investments when appropriate. • Provide a
monthly or quarterly monitoring report.
• Assist the plan sponsor in developing an IPS.
When serving as an ERISA 3(38) investment manager, the plan sponsor is relieved of all fiduciary
responsibility for the investment decisions made by Brookwood. Brookwood is a discretionary
investment manager in accordance with the terms of a separate ERISA 3(38) Investment
Management Agreement or a Cash Balance Investment Management Agreement between
Brookwood and the plan sponsor. Brookwood may provide the following services to the plan
sponsor:
• Select the investments.
• Monitor the investments and replace investments when appropriate.
• Provide a monthly or quarterly monitoring report.
• Develop a customized IPS.
Brookwood’s goal in identifying the plan’s investment options is to provide a range of options that
will enable plan participants to invest according to varying risk tolerances, savings, time horizons,
or other financial goals. The plan's investment options may consist of ETFs, CITs, mutual funds,
portfolios, or other similar investment funds.
The investment funds from which Brookwood will select from will be those that are available on
the plan recordkeeper’s investment platform.
Brookwood may prepare an IPS for the plan. The purpose of the IPS is to provide guidelines for
making investment related decisions in a prudent
manner. It outlines the underlying philosophies
and processes for the selection, monitoring, and replacement of the investment options offered by
the plan.
Investment Advice Relating to Retirement Accounts. When Brookwood provides investment
advice regarding a retirement plan account or individual retirement account, Brookwood is a
fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or
the Internal Revenue Code, as applicable. 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. As such, Brookwood is subject to specific duties and
obligations under ERISA and the IRC that include, among other things, prohibited transaction
rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a
fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or
eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”).
Under this special rule’s provisions, Brookwood 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 is reasonable for our services; and
● Give you basic information about conflicts of interest.
Retirement Rollovers Conflict of Interest. To the extent Brookwood recommends you roll over
your account from a current retirement plan account to an individual retirement account managed
by Brookwood, please know that Brookwood and our investment adviser representatives have a
conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over your account
at the retirement plan to an IRA managed by Brookwood. We will earn fewer investment advisory
fees if you do not roll over the funds in the retirement plan to an IRA managed by Brookwood.
Thus, our investment adviser representatives have an economic incentive to recommend a rollover
of funds from a retirement plan to an IRA which is a conflict of interest because our
recommendation that you open an IRA account to be managed by our firm can be based on our
economic incentive and not based exclusively on whether or not moving the IRA to our
management program is in your overall best interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial conduct
standard whereby our investment adviser representatives will (i) provide investment advice to a
retirement plan participant regarding a rollover of funds from the retirement plan in accordance
with the fiduciary status described below, (ii) not recommend investments which result in
Brookwood receiving unreasonable compensation related to the rollover of funds from the
retirement plan to an IRA, and (iii) fully disclose compensation received by Brookwood and our
supervised persons and any material conflicts of interest related to recommending the rollover of
funds from the retirement plan to an IRA and refrain from making any materially misleading
statements regarding such rollover.
When providing advice to your regarding a retirement plan account or IRA, our investment advisor
representatives will act with the care, skill, prudence, and diligence under the circumstances then
prevailing that a prudent person acting in a like capacity and familiar with such matters would use
in the conduct of an enterprise of a like character and with like aims, based on the investment
objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the
financial or other interests of Brookwood or our affiliated personnel.
The client has options other than rolling over the assets to an account managed by Brookwood,
including managing the assets without the assistance of Brookwood as part of their current
employer sponsored retirement plan or by rolling over the assets to an IRA. In both cases, the client
would not be required to pay additional fees to Brookwood and the client would be responsible for
managing the assets on their own. The Client always has the right to decide whether or not to
rollover retirement plan assets to an account managed by Brookwood.
Client Obligations. In performing its services, Brookwood shall not be required to verify any
information received from the Client or from the Client’s other professionals, and is expressly
authorized to rely thereon. Moreover, each Client is advised that it remains their responsibility to
promptly notify Brookwood if there is ever any change in their financial situation or investment
objectives for the purpose of reviewing, evaluating or revising Brookwood's previous
recommendations and/or services.
Brookwood shall provide investment services specific to the needs of each Client. Prior to
providing investment services, an investment adviser representative will ascertain each Client’s
investment objective(s). Thereafter, Brookwood shall allocate and/or recommend that the Client
allocate investment assets consistent with the designated investment objective(s). The Client may,
at any time, impose reasonable restrictions, in writing, on Brookwood's services.
Educational Workshops. Your Brookwood advisor may provide educational workshops for those
desiring information on personal finance and investing. Topics may include issues related to
general financial planning, educational funding, estate planning, retirement strategies, insurance
planning and various other current economic or investment topics.
Cash Management Accounts. Brookwood makes available to clients the FICA® cash
management program for Advisors sponsored by StoneCastle Cash Management, LLC
(‘StoneCastle’). StoneCastle is not a bank, nor does it offer bank deposits and its services are not
guaranteed or insured by The Federal Deposit Insurance Corporation, or any other governmental
agency. StoneCastle is not a bank, nor does it offer bank deposits and its services are not
guaranteed or insured by The Federal Deposit Insurance Corporation, or any other governmental
agency. The Federally Insured Cash Account, (“FICA”) is StoneCastle’s proprietary cash
management vehicle offering a high level of FDIC and NCUSIF insurance per client tax ID via
access to hundreds of participating banks and credit unions1 (“Network Institutions”). StoneCastle
is not a member of the FDIC or National Credit Union Administration (NCUA), but the Network
Institutions where FICA client funds are placed are FDIC and/or NCUA members. StoneCastle
requires a $250,000 minimum deposit to open a FICA account. Participating Brookwood Advisor
Representatives will assist clients in signing up for this program and facilitating the transfer of
funds between the client’s like-named accounts. Clients participating in this program will receive a
copy of the StoneCastle Form ADV. In the event Clients utilize StoneCastle’s FICA Cash
Management Program, Brookwood will receive a referral fee, indirectly paid from client’s deposits.
In this arrangement, a client introduced by Brookwood who deposits money in a StoneCastle FICA
account may earn a different monthly account yield, which will generally be less than the account
yield earned by a client depositing money directly to a FICA Program. Brookwood Advisor
Representatives must endeavor at all times to put the interests of the Clients first as part of
Brookwood's fiduciary duty, including recommending StoneCastle’s Cash Management Accounts.
However, Clients should be aware that a conflict of interest exists because there is a financial
incentive to recommend to Clients to StoneCastle. Clients are under no obligation, contractually or
otherwise, to utilize StoneCastle’s services.
UPTIQ. Brookwood has entered into a relationship with UPTIQ an unaffiliated internet-based
financial intelligence platform, to introduce clients in need of lending to utilize UPTIQ, a large
network of lenders to assist Advisory Clients with a variety of different types of personal and
business loans (i.e., mortgage, home equity, auto, commercial, working capital, etc.). Brookwood
does not perform any services for UPTIQ. UPTIQ’s platform seeks to match Clients with those
lenders who can best fulfill individual client’s borrowing needs. Once matched with a lender,
UPTIQ’s platform serves to help facilitate the loan application and fulfillment process. Neither
UPTIQ, nor Brookwood, serves as a lender. Neither UPTIQ, nor Brookwood, is registered or
licensed as a lender or lending broker with any state or federal regulatory agency or authority. There
can be no assurance that the lending terms obtained via the UPTIQ platform will be more favorable
than those available from non-platform lenders. UPTIQ is solely compensated by the lender for its
services. UPTIQ shares up to 25% of its compensation (derived from Lender’s fees) with
Brookwood as a referral fee. This does not change the amount a client pays to utilize the platform or
to obtain loans. Brookwood Advisor Representatives must endeavor at all times to put the interests
of Clients first, as part of Brookwood's fiduciary duty, including recommending UPTIQ.
Nevertheless, a conflict of interest exists because Brookwood’s acceptance of referral compensation
provides Brookwood with an economic incentive to introduce Clients to UPTIQ. Brookwood does
not provide any services on behalf of UPTIQ. In the event that a client desires to utilize the UPTIQ
platform, the client will receive a separate Acknowledgement from Brookwood for review prior to
utilizing UPTIQ. No portion of any loan proceeds received from Client(s) will knowingly be
accepted by Brookwood for investment purposes. No Client is under any obligation whatsoever to
utilize UPTIQ’s services. Client remains free to consider/evaluate/utilize other lenders and platforms,
and, to the extent reasonably requested, Brookwood shall remain available to help assist the client
with such evaluation process.
Wrap Program. Brookwood does not participate in a wrap fee program.
Assets Under Management. As of March 30, 2024 total Assets Under Management advised on a
discretionary basis is $689,082,702.00and $0 is advised on a non-discretionary basis.