Item 5 Additional Compensation ............................................................................................................................ 20
Item 6 Supervision ........................................................................................................................................................ 20
Firm Description
Opulen Financial Group, LLC (“OFG”) was founded in June of 2009 and began offering
investment advisory services in 2014. Thomas J. Cymer is the managing member.
Types of Advisory Services
ASSET MANAGEMENT
OFG offers discretionary and non-discretionary asset management services to advisory
Clients. OFG will offer Clients ongoing asset management services through determining
individual investment goals, time horizons, objectives, and risk tolerance. Investment
strategies, investment selection, asset allocation, portfolio monitoring and the overall
investment program will be based on the above factors.
Discretionary
When the Client provides OFG discretionary authority the Client will sign a limited
trading authorization or equivalent. OFG will have the authority to execute transactions
in the account without seeking Client approval on each transaction.
Non-Discretionary
When the Client elects to use OFG on a non-discretionary basis, OFG will determine the
securities to be bought or sold and the amount of the securities to be bought or sold.
However, OFG will obtain prior Client approval on each and every transaction before
executing any transaction.
Betterment Platform
OFG offers discretionary direct asset management services to advisory clients utilizing The
Betterment for Advisors platform for digital services. On this platform, OFG has the
discretion to delegate the management of all or part of the Assets to one or more
independent investment managers or independent investment management programs
(“Independent Managers”). To the extent utilized, Independent Managers will have limited
power-of-attorney and trading authority over those assets OFG directs to them for
management. OFG will supervise the Independent Managers and monitor and review asset
allocation and asset performance. OFG may terminate or change Independent Managers
when, in OFG’s sole discretion, OFG believes such termination or changes is in your best
interest.
FINANCIAL PLANNING AND CONSULTING
OFG offers financial planning and consulting services on a negotiable hourly fee basis.
Financial planning will typically involve providing a variety of advisory services to Clients
regarding the management of their financial resources based upon an analysis of their
individual needs. If you retain OFG for financial planning and consulting services, OFG will
meet with you to gather information about your financial circumstances and objectives.
Once OFG reviews and analyzes the information you provided, OFG will deliver a plan to
you, designed to help you achieve your stated financial goals and objectives.
Financial plans and/or consulting are based on your financial situation at the time OFG
presents the plan to you, and on the financial information you provided to OFG. You must
promptly notify OFG if your financial situation, goals, objectives, or needs change.
If financial planning services are applicable, a thorough review of all applicable topics
including but not limited to the following:
• Identification and Clarification of Goals -This step is all about collecting and
prioritizing short-term and long-term financial goals from client, who maybe
business owners, professionals, executives or individual, that need money and
planning to achieve.
• Cash Flow Planning, Debt Elimination and Budgeting - The planning review
Client’s current and projected incomes, expenses, current debts, and net assets.
And optimize the best pay off strategy along with achievable budgeting for Client
to become debt free while maintaining Client’s quality of life and lifestyle.
• Investment Planning - Advise Client how to smartly invest their money to ensure
wealth accumulation based on their time horizon and risk tolerance. Client may
also need recommendations on which diversified investment portfolio will be the
optimal to meet their financial goals. Additionally, Clients may be concerned about
how to invest in a tax-efficient way to accumulate their wealth to accomplish their
goals.
• Retirement Planning - Clients usually need answers to questions like: “Will we be
able to retire comfortably at age 62 or 65 or 67 or 70 based on the expected,
before-tax or after-tax, income for the lifestyle, considering traveling and health
care needs etc., with all of our current level of retirement savings? What
additional savings should one consider for the income level desired? If we can’t
make our goal, what will the outcome be for our retirement?” And what is the safe
and optimal income withdraw rate from retirement funds.
• College Planning - The expense for children’s higher education is expected to keep
increasing over time due to potential inflation. There are alternative ways and
strategies to save and fund for education. Based on the education goal, some is
more optimal than others, either through pre-paid tuition plan or a 529 College
Savings Plan etc. OFG will help explain and explore alternatives available to the
Client and offer recommendation as to what might be the most suitable to Client’s
goal.
• Life Insurance and Disability Income Planning - Assess areas of risk exposure to
ensure proper coverage are very important when it comes to protecting family
and business with either a lump sum payment or an income replacement for as
long as disability, in addition to home, auto and umbrella insurances. The planning
will be based on the financial goals and liability to determine what life insurance,
long-term-care insurance and disability income, if needed how much coverage,
are recommended to provide protection and risk management.
• Employee Benefit Planning - The planning applies a multi-disciplined approach
and education to recommend employee benefit program so that it improves
employee satisfaction, business productivity through non-wage compensation,
profit sharing, and other plans etc.
• Income Tax Planning - Income taxes can be costly, complicated, but optimized.
The planning will recommend some appropriate financial strategies considering
income tax scenarios to improve overall tax situation. Some unique tax savings
strategies may be available to the Client or their business. OFG will help identify
tax savings opportunities and potential pitfalls to avoid. OFG does not provide
income tax advice, and recommend Clients seek the services of a tax advisor as
needed.
• Estate Wealth
Transfer Strategies and Legacy Planning - The planning will review
Clients overall financial assets and advise Clients to best meet their legacy goals.
Assist Clients in working together with their attorney to develop long-term
strategies. These include as appropriate, gifting, living trusts, as well as more
sophisticated trusts and strategies, wills, review estate tax, powers of attorney,
beneficiary designations and health care directives. We do not provide legal
advice nor draft legal documents, but recommend Clients seek the services of an
attorney as collaboration needed.
• Charitable Giving Strategies and Planning - The planning tailors to Client’s charity
inclination to give to charity in the most tax-efficient manner. As one key
advantage of tax strategies is its reduction of the cost of donations that Client have
already chosen to make matching Client’s personal values and goals. For tax-
efficient charitable giving, the planning will consider one or more of standard tax
planning implementation strategies and collaborate with Client’s attorney.
You are under no obligation to act on our financial planning recommendations. Should you
choose to act on any of our recommendations, you are not obligated to implement the
financial plan through any of our other investment advisory services. Moreover, you may
act on our recommendations by placing securities transactions with any brokerage firm.
Financial plans will be completed and delivered inside of sixty (60) days. Client may
terminate advisory services with five (5) business days written notice. Services are
considered complete when the plan and/or recommendations are rendered.
ERISA PLAN SERVICES
OFG provides service to qualified and non-qualified retirement plans including 401(k)
plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred
compensation plans. OFG acts as a 3(21) advisor:
Limited Scope ERISA 3(21) Fiduciary. OFG typically acts as a limited scope ERISA 3(21)
fiduciary that can advise, help and assist plan sponsors with their investment decisions on
a non-discretionary basis. As an investment advisor OFG has a fiduciary duty to act in the
best interest of the Client. The plan sponsor is still ultimately responsible for the decisions
made in their plan, though using OFG can help the plan sponsor delegate liability by
following a diligent process.
1. Fiduciary Services are:
Provide non-discretionary investment advice to the Client about asset classes and
investment alternatives available for the Plan in accordance with the Plan’s
investment policies and objectives. Client will make the final decision regarding
the initial selection, retention, removal and addition of investment options.
Assist the Client in the development of an investment policy statement (“IPS”).
The IPS establishes the investment policies and objectives for the Plan. Client shall
have the ultimate responsibility and authority to establish such policies and
objectives and to adopt and amend the IPS.
Provide non-discretionary investment advice to the Plan Sponsor with respect to
the selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make
investment elections. The Client retains the sole responsibility to provide all
notices to the Plan participants required under ERISA Section 404(c) (5) and
404(a)-5.
2. Non-fiduciary Services are:
Assist in the education of Plan participants about general investment information and
the investment alternatives available to them under the Plan. Client understands the
Advisor’s assistance in education of the Plan participants shall be consistent with and
within the scope of the Department of Labor’s definition of investment education
(Department of Labor Interpretive Bulletin 96-1). As such, the Advisor is not
providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants.
Advisor will not provide investment advice concerning the prudence of any
investment option or combination of investment options for a particular participant
or beneficiary under the Plan.
Assist in monitoring investment options by preparing periodic investment reports
that document investment performance, consistency of fund management and
conformance to the guidelines set forth in the IPS and make recommendations to
maintain, remove or replace investment options.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
Advisor may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between Advisor and Client.
3. The Advisor has no responsibility to provide services related to the following types of
assets (“Excluded Assets”):
a. Employer securities;
b. Real estate (except for real estate funds or publicly traded REITs);
c. Stock brokerage accounts or mutual fund windows;
d. Participant loans;
e. Non-publicly traded partnership interests;
f. Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
g. Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to the Advisor under this
Agreement.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
SEMINARS
OFG holds seminars to educate the public on different types of investments and the
different services they offer. The seminars are educational in nature and no specific
investment or tax advice is given. OFG does not charge a fee for attendance to these
seminars.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objective. Clients may impose
restrictions on investing in certain securities or types of securities. Agreements may not be
assigned without written Client consent.
Wrap Fee Programs
OFG does sponsor and manage a wrap fee program. The Client pays one fee to OFG which
includes OFG’s Management Fee and the transaction costs associated with the transactions.
Thomas J. Cymer, Managing Member, will manage all Program accounts. Accounts will not
be managed by any other party. As of October 1, 2022, no new clients will be placed in the
wrap program sponsored and managed by OFG.
Client Assets under Management
OFG has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$103,616,000 $2,078,000 June 30, 2023