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A. Levin Funding Group LLC
Levin Funding Group LLC (“LFG” and/or “the firm”) is an Arizona limited liability company principally
owned by the John and Kimberly Levin Exempt Trust dated 12/14/2017. John D. Levin is the firm’s
Managing Member. LFG has been providing investment advisory services since January 2014.
B. Advisory Services Offered
B.1. Investment Management Services
LFG manages investment portfolios for individuals, qualified retirement plans, trusts, charitable
organizations, corporations and small businesses. LFG will work with a client to determine the client's
investment objectives and investor risk profile and will design a written investment policy statement. LFG
evaluates the client's existing investments with respect to the client's investment policy statement. LFG
works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio
recommended by LFG. LFG will then continuously monitor the client's portfolio holdings and the overall
asset allocation strategy and hold review meetings with the client regarding the account as necessary.
LFG will typically create a portfolio of no-load mutual funds, exchange traded funds (ETFs) and individual
securities and may use model portfolios if the models match the client's investment policy. LFG will
allocate the client's assets among various investments, taking into consideration the overall management
style selected by the client. LFG primarily recommends portfolios consisting of passively managed asset
class and index mutual funds. LFG recommends mutual funds and/ETFs offered by Vanguard,
Dimensional Fund Advisors (DFA) and other fund families. Mutual funds and ETFs that follow a passive
investment philosophy generally have low holdings turnover.
Client portfolios may also include individual equity securities in situations where disposition of these
securities would present an overriding tax implication or the client specifically requests they be retained for
a personal reason. These situations will be specifically identified in the client’s Investment Policy
Statement (IPS). Additionally, for certain qualified clients, LFG may also recommend investments in
pooled investment vehicles (“Alternative Investments”).
Financial Planning & Consulting
LFG offers different levels of financial planning and consulting services to help clients identify, prioritize
and work towards their goals and objectives. Our consulting services give clients the ability to receive a
broad range of financial advice and services. Our process starts with an extensive review of a client’s family
situation, which includes assets and liabilities as well as estate, tax, and insurance needs. We then employ
a risk tolerance and risk capacity-focused simulation to get a detailed cash flow analysis and proposed asset
allocation. Together, this information is analyzed to develop a proposed financial plan, which is designed
to be dynamic in nature, ever-evolving due to life changes, along with changes in cash flow needs, risk
tolerance, time horizon, or investment objectives. Additionally, LFG can also provide consultation and
review services on a client’s existing insurance products.
In performing these services, LFG is not required to verify any information received from the client or from
the client's other professionals (e.g., attorneys, accountants, etc.), and is expressly authorized to rely on
such information.
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Implementation of financial planning recommendations is entirely at your discretion. You have complete
freedom in selecting a financial adviser to assist you with implementing the recommendations made in your
financial plan and are under no obligation to act on the advice of LFG. LFG will act solely in its capacity
as a registered investment adviser and does not provide any legal, accounting or tax advice. You should
seek the counsel of a qualified accountant and/or attorney when necessary.
Independent Third-party Managers
LFG can select certain Independent Managers to actively manage a Portion of its clients’ assets. Pursuant
to the terms of the investment advisory agreement, LFG shall have discretion to appoint and terminate
these third-party managers. Disclosure of the use of an Independent Manager and their fees will be provided
to clients. LFA can use SEI, Dimensional Fund Advisers, LP or Parametric (“Sub-Adviser”) for sub-
advisory services to separately managed portfolios. Sub-Adviser shall be responsible for the investment
and reinvestment of those assets in the client’s accounts. The Sub-Adviser shall manage the assets in
accordance with the investment strategy and any customization selected by LFG for each client account.
Use of Independent Managers can result in additional fees to the client.
LFG will continue to render advisory services to the client relative to the ongoing monitoring and review
of account performance, for which LFG will receive an annual advisory fee.
Factors that LFG will consider in recommending Independent Manager(s) include the client's stated
investment objective(s) and the independent manager(s) management style, performance, reputation,
financial strength, reporting, pricing, and research. In addition to LFG’s written disclosure statement, the
client will also receive the written disclosure statement of the Independent Manager(s). Certain Independent
Manager(s) will impose more restrictive account requirements and varying billing practices than LFG. In
such instances, LFG may alter its corresponding account requirements and/or billing practices to
accommodate those of the Independent Manager(s).
LFG’s engagement with a client will include, as appropriate, the following:
▪ Providing assistance in reviewing the client's current investment portfolio against the client's
personal and financial circumstances as disclosed to LFG in response to a questionnaire and/or in
discussions with the client and reviewed in meetings with LFG.
▪ Analyzing the client's financial circumstances, investment holdings and strategy, and goals.
▪ Providing assistance in identifying a targeted asset allocation and portfolio design.
▪ Implementing and/or recommending individual equity and fixed income securities, mutual funds,
ETFs and alternative investments
▪ Proposing changes in the client's investment portfolio in consideration of changes in the client's
personal circumstances, investment objectives and tolerance for risk.
In addition to providing LFG with information regarding their personal financial circumstances, investment
objectives and tolerance for risk, clients can provide the firm with reasonable investment restrictions that
should be imposed on the management of their portfolio, and to promptly notify the firm of any changes in
such restrictions or in the client's personal financial circumstances, investment objectives, goals and
tolerance for risk. LFG will remind clients of their obligation to inform the firm of any such changes or any
restrictions that should be imposed on the management of the client’s account. LFG will also contact clients
at least annually to determine whether there have been any changes in a client's personal financial
circumstances, investment objectives and tolerance for risk.
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C. Client-Tailored Services and Client-Imposed Restrictions
Each client’s account will be managed on the basis of the client’s financial situation and investment
objectives and in accordance with any reasonable restrictions imposed by the client on the management of
the account—for example, restricting the type or amount of security to be purchased in the portfolio.
D. Wrap Fee Programs
LFG is not involved with any wrap-fee programs.
E. Client Assets Under Management
As of December 31, 2023, LFG manages $164,530,650 of discretionary assets under management and no
assets on a non-discretionary basis.
Item 5: Fees and Compensation