This Disclosure document is being offered to you by O’Connell Investment & Insurance
Services, LLC (“OIIS” or “Firm”) about the investment advisory services we provide. It
discloses information about our services and the way those services are made available to
you, the client.
We are an investment management firm located in Eugene, Oregon. We make our advisory
services available to a wide variety of clients including, but not limited to, individuals,
pension and profit sharing plans, trusts, estates, charitable organizations, corporations and
business entities. Our Firm became a registered investment adviser in November 2017.
Gwen O’Connell is the Managing Member and owns 100% of the firm.
We are committed to helping clients build, manage, and preserve their wealth, and to
provide assistance that helps clients to achieve their stated financial goals. We will offer an
initial complimentary meeting upon our discretion; however, investment advisory services
are initiated only after you and our firm executes an Investment Management Agreement.
Investment and Wealth Management and Supervision Services
We manage advisory accounts on a discretionary and non-discretionary basis. For
discretionary accounts, once we have determined a profile and investment plan with a
client, we will execute the day-to-day transactions without seeking prior client consent.
Account supervision is guided by the written profile and investment plan of the client. We
primarily allocate client assets among various mutual funds, exchange-traded funds
(“ETFs”), and individual debt (bonds), alternative investments, cash or money market
funds, and equity securities in accordance with their stated investment objectives. All of
which are considered asset allocation categories for the client’s investment strategy.
During personal discussions with clients, we determine the client’s objectives, time
horizons, risk tolerance and liquidity needs. As appropriate, we also review a client’s prior
investment history, as well as family composition and background. Based on client needs,
we develop and document in writing, a client’s personal profile and investment plan. We
then create and manage the client’s investments based on that policy and plan.
It is the client’s obligation to notify us immediately if circumstances have changed with
respect to their goals.
Once we have determined the types of investments to be included in your portfolio and
allocated them, we will provide ongoing investment review and management services.
This approach requires us to periodically review your portfolio.
If a discretionary relationship is in place, we will rebalance the portfolio, as we deem
appropriate, to meet your financial objectives. We trade these portfolios and rebalance
them based on the combination of our market views and your objectives, using our
investment process. We tailor our advisory services to meet the needs of our clients and
seek to ensure that your portfolio is managed in a manner consistent with those needs and
objectives.
If a non-discretionary relationship is in place, calls will be placed presenting the
recommendation made and only upon your authorization will any action be taken on your
behalf. We do have limited authority to direct the Custodian to deduct our investment
advisory fees from accounts, but only with the appropriate written authorization from
clients.
In all cases, you have a direct and beneficial interest in your securities, rather than an
undivided interest in a pool of securities. We do have limited authority to direct the
Custodian to deduct our investment advisory fees from your accounts, but only with the
appropriate written authorization from you.
Where appropriate, we provide advice about any type of legacy position held in client
portfolios. Typically, these are assets that are ineligible to be custodied at our primary
custodian. Clients will engage us to advise on certain investment products that are not
maintained at their primary custodian, such as variable life insurance, annuity contracts
and assets held in employer sponsored retirement plans and qualified tuition plans (i.e.,
529 plans).
You are advised and are expected to understand that our past performance is not a
guarantee of future results. Certain market and economic risks exist that adversely affect
an account’s performance. This could result in capital losses in your account.
Participant Account Management
We use a third-party platform to facilitate management of held away assets such as
defined contribution plan participant accounts, with discretion. The platform allows us to
avoid being considered to have custody of Client funds since we do not have direct access
to Client log-in credentials to affect trades. We are not affiliated with the platform in any
way and receive no compensation from them for using their platform. A link will be
provided to the Client allowing them to connect an account(s) to the platform. Once Client
account(s) is connected to the platform, Adviser will review the current account
allocations. When deemed necessary, Adviser will rebalance the account considering client
investment goals and risk tolerance, and any change in allocations will consider current
economic and market trends. The goal is to improve account performance over time,
minimize loss during difficult markets, and manage internal fees that harm account
performance. Client account(s) will be reviewed at least quarterly and allocation changes
will be made as deemed necessary.
Employer Sponsored Retirement Plan Services
For employer-sponsored retirement plans with participant-directed investments, OIIS
provides its advisory services as an investment advisor as defined under Section 3(21) and
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 OIIS 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 OIIS and the plan
sponsor. OIIS provides the following services to the plan sponsor:
• Screen investments and make recommendations.
• Monitor the investments and suggests replacement investments when
appropriate.
• Provide a quarterly monitoring report.
• Assist the plan sponsor in developing an Investment Policy Statement (“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 OIIS. OIIS is a discretionary
investment manager in accordance with the terms of a separate ERISA 3(38) Investment
Management Agreement between OIIS and the plan sponsor. OIIS’s investment
management is limited in that it has the discretion solely to replace funds in plan fund
lineups and initiate the transfer of existing balances to the replacements without prior
approval from the client.
OIIS provides the following services to the plan sponsor:
• Select the investments.
• Monitor the investments and replace investments when appropriate.
• Provide a quarterly monitoring report.
• Develop a customized IPS.
Our 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, model portfolios, or other similar investment funds. The investment funds
from which our Firm will select from will be those that are available on the plan record-
keeper’s investment platform.
We will 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, evaluation, monitoring, and, if necessary,
replacement of the investment options offered by the plan. We will perform on-going
monitoring of the investment options within the plan. The ongoing monitoring of
investments is a regular and disciplined process. Monitoring confirms that the criteria
remain satisfied and that an investment option continues to be appropriate. The process
of monitoring investment performance relative to specified guidelines will be consistently
applied.
We provide these Plan consulting services separately or combined. Clients may choose to
use any or all of these services as indicated on the Investment Advisory Agreement with
our Firm.
Disclosure Regarding Rollover Recommendations
A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money
in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement
Account (“IRA”), or (iv) cash out the account value (which could, depending upon the
client’s age, result in adverse tax consequences). Our Firm may recommend an investor
roll over plan assets to an IRA for which our Firm provides investment advisory services.
As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a
recommendation that a client or prospective client leave their
plan assets with their
previous employer or roll over the assets to a plan sponsored by a new employer will
generally result in no compensation to our Firm. Our Firm therefore has an economic
incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various
factors that our Firm will consider before recommending a rollover, including but not
limited to: (i) the investment options available in the plan versus the investment options
available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an
IRA, (iii) the services and responsiveness of the plan’s investment professionals versus
those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required
minimum distributions and age considerations, and (vi) employer stock tax consequences,
if any. All rollover recommendations are reviewed by our Firm’s Chief Compliance Officer
and remains available to address any questions that a client or prospective client has
regarding the oversight.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide
investment advice to you regarding your retirement plan account or individual retirement
account, we are also fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws
governing retirement accounts. We have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates some conflicts
with your interests.
Participant Education
For pension, profit sharing and 401(k) plan clients in self-directed plans, we may provide
periodic educational support and investment workshops designed for the plan
participants, if provided for in our agreement with the client. Topics to be discussed will be
determined in conjunction with the plan sponsor and in accordance with guidelines
established in ERISA Section 404(c). The educational support and investment workshops
will not provide plan participants with individualized, tailored investment advice or
individualized, tailored asset allocation recommendations.
Consulting Services
We also provide clients investment advice on a more-limited basis on one-or-more isolated
areas of concern such as estate planning, real estate, retirement planning, or any other
specific topic. Additionally, we may provide advice on non-securities matters in connection
with the rendering of estate planning, insurance, real estate, and/or annuity advice. In
these cases, you may be required to select your own investment managers, broker-dealer
and/or insurance companies for the implementation of consulting recommendations. If
your needs include brokerage and/or other financial services, we may recommend the use
of one of several investment managers, brokers, banks, custodians, insurance companies
or other financial professionals. You must independently evaluate these independent firms
before opening an account or transacting business, and have the right to effect business
through any firm you choose. You are under no obligation to follow the consulting advice
that we provide.
Financial Planning
Financial Planning services are offered upon request. Through the Financial Planning
process, our team strives to engage our clients in conversations around the family’s goals,
objectives, priorities, vision, and legacy – both for the near term as well as for future
generations. With the unique goals and circumstances of each family in mind, our team
will offer financial planning ideas and strategies to address the client’s holistic financial
picture, including estate, income tax, charitable, cash flow, wealth transfer and family
legacy objectives. Our team partners with our client’s other advisors (CPA, Estate Attorney,
Insurance broker, etc.) to ensure a coordinated effort of all parties toward the client’s stated
goals. Such services include various reports on specific goals and objectives or general
investment and/or planning recommendations, guidance to outside assets.
Our specific services in preparing your plan may include:
• Review and clarification of your financial goals.
• Assessment of your overall financial position including cash flow, balance sheet,
investment strategy, risk management and estate planning.
• Creation of a unique plan for each goal you have including personal and business
real estate, education, retirement or financial independence, charitable giving,
estate planning, business succession and other personal goals.
• Development of a goal-oriented investment plan, with input from various advisors
to our clients around tax suggestions, asset allocation, expenses, risk and liquidity
factors for each goal. This includes IRA and qualified plans, taxable and trust
accounts that require special attention.
• Design of a risk management plan including risk tolerance, risk avoidance,
mitigation and transfer, including liquidity as well as various insurance and
possible company benefits.
• Crafting and implementation of, in conjunction with your estate and/or corporate
attorneys as tax advisor, an estate plan to provide for you and/or your heirs in the
event of an incapacity or death.
A written evaluation of each client's initial situation or Financial Plan is provided to the
client. The recommendations will not be reviewed nor updated, unless requested by the
client at which point a new Agreement between Client and Adviser may be executed.
Sub-Advisory Services
Our firm may determine that engaging the expertise of an independent sub-advisor is best
suited for your account. Our firm will have discretion to utilize independent third-party
investment adviser to aid in the implementation of investment strategies for your
portfolio. In certain circumstances, we may allocate a portion of a portfolio to an
independent third-party investment adviser (“Manager”) for separate account
management based upon your individual circumstances and objectives, including, but not
limited to, your account size and tax circumstances. Upon the recognition of such
situations, in coordination with you, we will hire a Manager for the management of those
assets. These advisers shall assist our Firm in managing the day‐to‐day investment
operations of the various allocations, shall determine the composition of the investments
comprising the allocation, shall determine what securities and other assets of the
allocation will be acquired, held, disposed of or loaned in conformity with the written
investment objectives, policies and restrictions and other statements of each client
comprising the allocation, or as instructed by our Firm.
Managers selected for your investments need to meet several quantitative and qualitative
criteria established by us. Among the criteria that may be considered are the Manager’s
experience, assets under management, performance record, client retention, the level of
client services provided, investment style, buy and sell disciplines, capitalization level, and
the general investment process.
You are advised and should understand that:
● A Manager’s past performance is no guarantee of future results;
● There is a certain market and/or interest rate risk which may adversely
effect any Manager’s objectives and strategies, and could cause a loss in a
Client's account(s); and
● Client risk parameters or comparative index selections provided to our firm
are guidelines only and there is no guarantee that they will be met or not
be exceeded.
Managers may take discretionary authority to determine the securities to be purchased
and sold for the client. As stated in the Discretionary Advisory Agreement, our Firm and its
associated persons will have discretionary authority to hire and fire the Manager. Our firm
will work with the sub-advisor to communicate any trading restrictions or standing
instructions to refrain from a particular industry requested by the Client. In all cases,
trading restrictions will depend on the sub-advisor and their ability to accommodate such
restrictions.
All performance reporting will be the responsibility of the respective Manager. Such
performance reports will be provided directly to you and our firm. Disclosures will indicate
what firm is providing the reporting.
Our Firm has entered into agreements with various independent Managers. All third-party
Managers to whom we will refer clients will be licensed as registered investment advisors
by their resident state and any applicable jurisdictions or registered investment advisors
with the Securities and Exchange Commission. A complete description of the Manager’s
services, fee schedules and account minimums will be disclosed in the Manager’s Form
ADV or similar Disclosure Brochure.
We review the performance of our Managers on at least a quarterly basis. More frequent
reviews may be triggered by changes in Manager’s management, performance or
geopolitical and macroeconomic specific events.
Our Firm only enters into only a select number of relationships with Managers. We have
agreed to pay a portion of the overall advisory fee charged to our clients to the Manager.
Wrap Fee Program
We do not offer a wrap fee program.
Assets
As of December 31, 2023, our firm’s total assets under management were $121,770,792.
Our firm’s discretionary assets under management totaled $121,456,420 and non-
discretionary assets under management totaled $314,372.