Description of Firm
Lumiere Financial Group LLC dba Lumiere Financial is a registered investment adviser based in New
York, NY. We are organized as a limited liability company ("LLC") under the laws of the state of
Delaware. We are owned by Zachary Brody and Tzvetelina Botchoukova.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we," "our," and "us" refer to Lumiere Financial Group
LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our
firm.
Portfolio Management Services
We offer discretionary and non-discretionary portfolio management services. Our investment advice is
tailored to meet our clients' needs and investment objectives.
If you participate in our discretionary portfolio management services, we require you to grant us
discretionary authority to manage your account. Subject to a grant of discretionary authorization, we
have the authority and responsibility to formulate investment strategies on your behalf. Discretionary
authorization will allow us to determine the specific securities, and the amount of securities, to be
purchased or sold for your account without obtaining your approval prior to each transaction. We will
also have discretion over the broker or dealer to be used for securities transactions in your account.
Discretionary authority is typically granted by the Discretionary Management Agreement you sign with
our firm, a power of attorney, or trading authorization forms.
You may limit our discretionary authority (for example, limiting the types of securities that can be
purchased or sold for your account) by providing our firm with your restrictions and guidelines in
writing.
We also offer non-discretionary portfolio management services. If you enter into non-discretionary
arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf
of your account. You have an unrestricted right to decline to implement any advice provided by our firm
on a non-discretionary basis.
As part of our portfolio management services, we may use one or more sub-advisers to manage a
portion of your account on a discretionary basis. The sub-adviser(s) may use one or more of their
model portfolios to manage some or all of your account. We will regularly monitor the performance of
your accounts managed by sub-adviser(s), and may hire and fire any sub-adviser without your prior
approval. We may pay a portion of our advisory fee to the sub-adviser(s) we use; however, you will not
pay our firm a higher advisory fee as a result of any sub-advisory relationships.
As part of our portfolio management services, in addition to other types of investments (see
disclosures below in this section), we may invest your assets according to one or more
model portfolios developed by our firm. These models are designed for investors with varying degrees
of risk tolerance ranging from a more aggressive investment strategy to a more conservative
investment approach. Clients whose assets are invested in model portfolios may not set restrictions on
the specific holdings or allocations within the model, nor the types of securities that can be purchased
in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of
securities in their account. In such cases, this may prevent a client from investing in certain models
that are managed by our firm.
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Asset Allocation Services
We offer asset allocation services that are tailored to meet our clients' needs and investment
objectives. Once you have retained our firm for asset allocation services, we will gather information
about your financial situation and objectives, and assist you in determining your investment goals,
objectives, risk tolerance, and retirement plan time horizon. We will initially provide you with
recommendations as to how to allocate your investments among categories of assets. We will then
review your account on a periodic basis. Where appropriate, we may provide you with
recommendations to change your asset allocation in an effort to remain consistent with your stated
financial objectives. You are free at all times to accept or reject any of our investment
recommendations. You are solely responsible for implementing our recommendations. Unless you
separately retain our services, we will not execute any transactions or changes in asset allocation on
your behalf.
Financial Planning Services
We offer 3 levels of financial planning services and fees are based on the components of each. The
levels and service included are as follows:
•Gold: 12 month engagement with 3 check-in calls and 1 full review plus a 72 hour response
time. Services included are comprehensive financial planning, an online tool, and ongoing
meetings.
•Platinum: 12 month engagement with 5 check-in calls and 1 full review plus a 48 hour response
time. Services include all of those in the Gold package plus: estate planning collaboration, and
tax consulting services (lite).
•Diamond: 12 month engagement with 8 check-in calls and 4 full reviews plus a 24 hours
response time. Services include all of those in the Platinum package plus: tax consulting
services, business valuation services, one-on-one consulting, and team coordination.
Financial Consulting Services
We offer financial consulting services that primarily involve advising clients on specific financial-related
topics. The topics we address may include, but are not limited to, risk assessment/management,
investment planning, financial organization, or financial decision making/negotiation.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based upon the
needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these
services may include an existing plan review and analysis, plan-level advice regarding fund selection
and investment options, education services to plan participants, investment performance monitoring,
and/or ongoing consulting. These pension consulting services will generally be non-discretionary and
advisory in nature where we act as an ERISA 3(21) co-fiduciary to the plan. The ultimate decision to
act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. Alternatively, we
may act as an ERISA 3(38) investment manager as a full-fiduciary to the plan. We will have
discretionary authority over the plan and all of its assets as detailed in the investment management
agreement. We may delegate such ERISA 3(21) or 3(38) responsibilities to the firm of our choosing.
We may also assist with participant enrollment meetings and provide investment-related educational
seminars to plan participants on such topics as:
•Diversification;
•Asset allocation;
•Risk tolerance; and
•Time horizon
Our educational
seminars may include other investment-related topics specific to the particular plan.
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We may also provide additional types of pension consulting services to plans on an individually
negotiated basis. All services, whether discussed above or customized for the plan based upon
requirements from the plan fiduciaries (which may include additional plan-level or participant-level
services) shall be detailed in a written agreement and be consistent with the parameters set forth in the
plan documents.
Either party to the pension consulting agreement may terminate the agreement upon written notice to
the other party in accordance with the terms of the agreement for services. The pension consulting
fees will be prorated for the quarter in which the termination notice is given and any unearned fees will
be refunded to the client.
Schwab Institutional Intelligent Portfolios Platform
We offer an automated investment program, the Schwab Institutional Intelligent Portfolios Program (the
"Program") through which you are invested in a range of investment strategies we have constructed
and manage, each consisting of a portfolio of exchange-traded funds ("Funds") and a cash allocation.
You may instruct us to exclude up to three Funds from your portfolio. Your portfolio is held in a
brokerage account opened by you at Charles Schwab & Co., Inc. ("CS&Co"). We use the Institutional
Intelligent Portfolios platform ("Platform"), offered by Schwab Performance Technologies ("SPT"), a
software provider to independent investment advisors and an affiliate of CS&Co., to operate the
Program. We are independent of and not owned by, affiliated with, or sponsored or supervised by SPT,
CS&Co., or their affiliates (together, "Schwab"). We, and not Schwab, are your investment adviser and
primary point of contact with respect to the Program. We are solely responsible, and Schwab is not
responsible, for determining the appropriateness of the Program for you, choosing a suitable
investment strategy and portfolio for your investment needs and goals, and managing that portfolio on
an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of
technology and related trading and account management services for the Program. The Platform
enables us to make the Program available to you online and includes a system that automates certain
key parts of our investment process (the "System"). Based on information you provides to us, we will
recommend a portfolio via the System. You may then indicate an interest in a portfolio that is one level
less or more conservative or aggressive than the recommended portfolio, but we then make the final
decision and select a portfolio based on all the information we have about you. The System also
includes an automated investment engine through which we manage your portfolio on an ongoing
basis through automatic rebalancing and tax-loss harvesting (if you are eligible and elects).
We charge you a fee for our services as described below under Item 5 Fees and Compensation. Our
fees are not set or supervised by Schwab. You do not pay brokerage commissions or any other fees to
CS&Co. as part of the Program. Schwab does receive other revenues, including (i) the profit earned by
Charles Schwab Bank, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep
Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii)
investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab
Investment Management, Inc., a Schwab affiliate, from Schwab ETFs, Schwab Funds, and Laudus
Funds that we select to buy and hold in your brokerage account; (iii) fees received by Schwab from
third-party ETFs that participate in the Schwab ETF OneSource program and mutual funds in the
Schwab Mutual Fund Marketplace (including certain Schwab Funds and Laudus Funds) in your
brokerage account for services Schwab provides; and (iv) remuneration Schwab may receive from the
market centers where it routes ETF trade orders for execution.
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Wrap Fee Programs
We do not participate in any wrap fee program.
Types of Investments
We offer advice on equity securities, warrants, corporate debt securities (other than commercial
paper), commercial paper, certificates of deposit, municipal securities, variable life insurance, variable
annuities, mutual fund shares, United States government securities, options contracts on securities,
options contracts on commodities, futures contracts on tangibles, futures contracts on intangibles,
private placements, money market funds, real estate, REITs, PIPEs, derivatives, structured products,
ETFs, leveraged ETFs, digital assets, interests in partnerships investing in real estate and interests in
partnerships investing in oil and gas interests, private equity, and hedge funds, and fee-based annuity
and life products.
Additionally, we may advise you on various types of investments based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception
of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the
investment advice we provide to you may be different or conflicting with the advice we give to other
clients regarding the same security or investment.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you. When we provide investment advice to you regarding your
retirement plan account or individual retirement account, we are 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. 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. Under this special rule's provisions, we 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.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Assets Under Management
As of March 4, 2024, we provide continuous management services for $44,981,403 in client assets on
a discretionary basis.
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