Firm Information
This Disclosure Brochure (“Form ADV Part 2”) provides information regarding the qualifications,
business practices, and the advisory services provided by Breakwater Capital Group’s
(Breakwater or “the Firm”, “we”, “us”, “ours”).
We were founded in 2022 and are owned and operated by Jeffrey C. Hanson, President.
We provide investment advisory services to individuals, pension and profit-sharing plans, trusts,
estates, charitable organizations, and corporations or other business entities. Our investment
advisory services include investment management, financial planning, consulting, and the
selection of other advisors.
Types of Advisory Services
Financial Planning
We offer financial planning services, which may include a review of all aspects of a client’s
current financial situation, including the following components: cash management, risk
management, insurance, education funding, goal setting, retirement planning, estate and
charitable giving planning, tax planning, and capital needs planning. Clients understand that
when are engaged to address only certain components, the client’s overall financial and
investment issues may not be taken into consideration.
We meet with the client to review risk tolerance, financial goals and objectives, and time
horizons. Additional meetings may include a review of additional financial information; sources
of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax
returns, investments, and personal and family obligations.
The financial plan may include both long and short-term considerations, depending upon the
individual scenario. Upon completion a plan is presented to the client and the client is provided
with recommendations that are deemed to be compatible with the client’s stated goals and
objectives. An implementation schedule is reviewed with the client to determine which steps
will be pursued, and with whom the steps may be accomplished. The client is under no
obligation to utilize the Firm to implement the advice or plan. Clients may choose all or certain
components of advice and recommendations and can implement the recommendations
through the service providers of their choice.
Wealth Management
We typically provide a variety of wealth management services to individuals and families, in
several areas of a client’s financial situation, depending on their goals, objectives, and
resources.
In Wealth Management engagements, we provide ongoing Financial Planning and Investment
Management services as described above and we provide customized investment management
solutions for our clients. We will manage advisory accounts on a discretionary or non-
discretionary basis, as agreed upon with the client. We work with each client to identify their
investment goals and objectives as well as risk tolerance and financial situation in order to
create a portfolio allocation.
We will then construct a portfolio consisting of exchange traded funds (“ETFs”), mutual funds,
individual stocks and bonds, or other securities, including alternative investments. We may also
provide advice about any type of legacy position or investment otherwise held in client
portfolios.
Consulting
We also offer investment advice on a more limited basis. This may include advice on reviewing
a client’s existing portfolio only an isolated area(s) of concern such as estate planning,
retirement planning, or any other specific topic. Additionally, we may provide advice on non-
securities matters; generally, in connection with the rendering of estate planning, insurance,
and/or annuity advice.
Advice is provided through consultation with the client and may include determination of
financial objectives, identification of financial problems, cash flow management, tax planning,
insurance review, investment management, education funding, retirement planning, and estate
planning.
Retirement Plan Advisory Services
We provide advisory services to retirement plans (each a “Plan”) and the company/sponsor of
the Plan (the “Plan Sponsor”). Our retirement plan advisory services are designed to assist the
Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each
engagement is customized to the needs of the Plan and Plan Sponsor. Services generally
include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment
Policy Statement (“IPS”) Design and Monitoring
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
We will have the discretion to select the investments for the Plan and/or make investment
decisions on behalf of Plan Participants.
Trustee Services
In limited circumstances, we may act as trustee for a client.
Use of Independent Managers
We may recommend that you authorize the active discretionary management of a portion of
your assets by independent investment manager(s) (“Independent Manager(s)”). The terms and
conditions under which you will engage the Independent Manager(s) will be set forth in a
separate written agreement between you and the Independent Manager(s). We will continue
to provide you with advice about the selection of Independent Manager(s) as well as
monitoring and review of your investment objectives and account performance.
When selecting an Independent Manager for you, we will review information about them from
their Form ADV, materials which they may supply and/or information from independent third
parties Factors that we consider in selecting Independent Manager(s) include your investment
objective(s), and the Independent Manager’s investment style, performance, risks, reputation,
financial strength, reporting, pricing, and research.
We do not receive compensation for the recommendation of Independent Managers.
Wrap Fee Programs
A “wrap-fee” program is one that provides the client with advisory and brokerage execution
services for an all-inclusive fee. The client is not charged separate fees for the respective
components of the total service. We do not sponsor, manage or participate in a Wrap Fee
Program.
Fiduciary Statement
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,
(“ERISA”) and/or the Internal Revenue Code, (“IRC”), 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. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Tailored Relationships
We tailor advisory services to the individual needs of the client. Clients may place reasonable
investment restrictions on their portfolios, including bans on investing in particular industries,
and investing in limited amounts of securities. All limitations and restrictions placed on
accounts must be presented to us in writing.
Assets Under Management
As of December 31, 2023, we manage $579,733,946 in discretionary assets under management.