Description of Firm Encompass More Asset Management LLC ("Encompass More AM") is a registered investment adviser based in Danville, California. We are organized as a corporation under the laws of the state of Nevada, and we are owned by Encompass More Group Inc. We are indirectly owned by Brock McKinley.
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 Encompass More AM and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Encompass More has an affiliated broker-dealer, Encompass More Investments, LLC, member FINRA/SIPC. Portfolio Management Services We offer discretionary portfolio management services through a variety of investment models. The selection of models cover many investment needs and risk tolerance levels. Some models are proprietary to Encompass More AM and some are proprietary to outside sub-advisers, as disclosed below. 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 investment management agreement ("IMA" or "Agreement") you sign with our firm, a power of attorney, or trading authorization forms.
As part of our advisory services, you and your adviser ("IAR") will work together to determine your investment needs, financial objectives and risk tolerance. Once that information is reviewed, you and your IAR will select the appropriate models for your account(s). We will regularly monitor the performance of your models and may hire and fire any third-party money manager without your prior approval. Although we may select another third-party money manager and/or model for your account(s), we will take your current risk tolerance into account. This means we must either stay within your risk tolerance or choose a model that is one level up or down from your current risk tolerance. To go outside of these parameters, we will require your written authorization.
Since fees vary by model and sub-adviser, we will also require your written authorization if the fees for the new model are more than 5 basis points (0.05%) higher than what you currently pay. The available 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 set reasonable restrictions on the specific holdings within the model, and the types of securities that can be purchased in the model. Clients may not set restrictions on the investments held within a packaged product such as an ETF or mutual fund.
4 For some models, Encompass More AM may recommend the purchase of bitcoin futures, or use ETFs, mutual funds or third-party money managers that use of bitcoin futures. Additional details around the risks of bitcoin futures are included under Item 8 Methods of Analysis, Investment Strategies and Risk of Loss. Amplify Platform Encompass More AM's investment adviser representatives ("IARs") utilize the Amplify Platform for clients that engage us for Portfolio Management Services. The Amplify Platform provides back-office operational support services such as administrative, trading and reporting services and allows us to access to and select from independent third-party managers available through the Amplify Platform as our sub-advisers.
Upon executing the Platform Agreement, the investment adviser firm is considered a Platform Member.
Encompass More AM, a Platform Member, has chosen to receive certain back-office services, such as administrative, trading and reporting services as well as the ability to select independent third-party managers to manage underlying client assets on a sub-advisory basis. As a Platform Member we may choose to allocate all or a portion of our underlying client's assets among the different independent investment managers available through the Amplify Platform on a discretionary basis, as mentioned above.
We will have a direct contractual relationship with each of our underlying clients and obtain, through such agreements, the authority to engage Amplify Platform for services rendered through the Platform, including the selection of unaffiliated investment advisers to serve as sub-advisers. Sub-advisers available through the Amplify Platform will perform discretionary investment management services and shall manage, invest and reinvest our underlying client assets as designated by the Platform Member. As such, a selected manager(s) shall be authorized, without prior consultation with the Platform Member or our underlying client, to buy, sell trade or allocate the underlying client's assets in accordance with the underlying client's investment objectives and to deliver instructions in furtherance this responsibility to the underlying client's broker-dealer and or custodian.
We retain responsibility for the underlying client relationship, including the initial and ongoing suitability determination. Platform Members shall also retain the responsibility for implementing client investment recommendations in accordance with our fiduciary duty to the underlying client. We are also responsible for obtaining and furnishing information pertaining to sub-advisor selection and underlying client account guidelines along with any reasonable account restrictions imposed by our underlying client and agreed to by the investment adviser representative and/or the sub-adviser, as required.
Third-party money managers have a sub-advisory relationship with Encompass More AM and may be referred to throughout this disclosure brochure as a third-party money manager or a sub-adviser. Portfolio Managers refer to the managers of the models and can reference our sub-advisor relationships or our proprietary models.
Types of Investments We offer advice on equities (stocks), corporate debt (bonds) securities (other than commercial paper), municipal bonds, mutual funds, United States government securities, money market funds, REITs (real estate investment trusts) and ETFs (exchange-traded funds).
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.
5 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.
Private Placements or Private Equity A securities offering exempt from registration with the SEC is sometimes referred to as a private placement or an unregistered offering (referred to as the Fund or private placement). Under the federal securities laws, a company may not offer or sell

securities unless the offering has been registered with the SEC or an exemption from registration is available.
Private placements are used to raise funds from investors and have fewer disclosure obligations than other investments you may be familiar with. Because they are illiquid investments and may be difficult or impossible to re-sell, you should be comfortable holding the investment indefinitely. You should also ask your IAR questions such as:
•Are the claims and expectations reasonable?
•Who are the issuer's competitors?
•What is the experience and background of management?
•How does the issuer plan to use the money raised? Clients that meet the definition of accredited investor and other suitability requirements of the selected Fund may have the opportunity to purchase one or more Funds through the Adviser. The firm offering the Fund will typically receive a placement fee, along with marketing and due diligence fees, and the Adviser will charge an advisory fee in lieu of the selling commission. Private placements are exempt from registration pursuant to Rule 506(D) of Regulation D of the Securities Act of 1933. These Funds are illiquid and lack marketability. These Funds are long-term investments and cannot be purchased for trading or short-term ownership. In most cases you will not be able to withdraw all or part of your investment until the prescribed liquidation date(s) provided by the sponsor of the Fund.
Management fees are based on each investor's capital commitment to the Fund at closing date and are sometimes charged up front for the full term of the Fund. Each Fund the Adviser recommends to you may have different fees, expenses and holding periods. You should review these with your financial professional and carefully read the disclosure documents they provide.
Accredited investors are defined by the SEC and a variety of individuals and institutions may be able to meet the definition. The typical accredited investor working with the Adviser meets one of the following:
• An individual with a net worth or joint net worth with a spouse (or spousal equivalent) of at least $1 million, not including the value of your primary residence, or
•An individual with income of at least $200,000 in each of the two most recent calendar years or joint income with a spouse (or spousal equivalent) of at least $300,000 in each of the two most recent calendar years and a reasonable expectation of an equivalent income in the coming year. Retirement Platform Models Our firm provides discretionary portfolio management of retirement accounts for individual participants on certain retirement plan platforms, including those of TIAA, Fidelity Investments, IPX Retirement, Charles Schwab, TD Ameritrade, PCS, Aspire, and others. These accounts are managed using model portfolios offered through a sub-advisory relationship with one or more sub-advisors or in our Adviser Directed Program. Security selection for the retirement platform models is typically limited to the mutual funds (and, in some cases, variable annuity sub-accounts) available within each retirement 6 plan. As a result, the strategies are modified as appropriate based upon the specific fund options of each plan. A version of these mutual fund strategies is also available for accounts held outside of retirement plans.
These retirement plan accounts are not custodied at our qualified custodian but instead assets remain on the retirement plan platform selected by the Plan.
Some retirement plans offer Self-Directed Brokerage Account options, which provide access to a much larger universe of mutual funds. We offer versions of the models above designed specifically for these Self-Directed Brokerage Accounts, sometimes referring to them as "Sector Based" Models.
Employer Retirement Plans We will monitor the plan's investment lineup on a quarterly basis and provide reports to the plan sponsors. The reports will include funds that are on a "watch list" for possible replacement and recommendations for replacement of these funds when we believe such action is warranted.
We may also screen and recommend to plan sponsors an appropriate list of investment options for plan participants. This list of recommendations will take into account fund management, expenses, risk characteristics, and asset class among other factors required in the Plan's Investment Policy Statement.
Employer Retirement Plans are maintained at the employer's selected custodian. These could include TIAA, Fidelity Investments, IPX Retirement, Charles Schwab, TD Ameritrade, PCS, Aspire, and others.
Some Employer Retirement Plans and accounts in our Retirement Platform Models are managed by Verity Asset Management, Inc., in its role as a sub-adviser or turnkey asset manager. These accounts may also be maintained in one of the custodians listed above or at Axos Advisor Services. Financial Planning We provide financial planning services to clients that receive our portfolio management services. These services are based upon an analysis of your individual needs. These services range from broad-based financial planning to consultative or single subject planning. We use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
IRA Rollover Recommendations 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 7 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 February 15, 2023, we provide continuous management services for $113,344,175 in client assets managed on a discretionary basis.