A. Description of Firm
Plato’s Philosophy, LLC (“Plato’s Philosophy” or the “Firm”) is a Ventura, California-based
financial advisory firm founded in 2022. The Firm provides personalized investment advice to
individuals, companies, and other investment advisers. As discussed in greater detail below, this
advice encompasses aiding clients in defining their financial goals, addressing financial
challenges, managing cash flow, devising tax strategies, reviewing insurance needs, planning for
education expenses, crafting retirement strategies, and formulating estate plans. Within the
spectrum of investment instruments, the Firm offers advisory expertise on various vehicles,
including but not limited to mutual funds, exchange-traded funds ("ETFs"), equities, bonds,
treasuries, options, real estate, and other investment vehicles. As for ETF advisory services, the
Firm currently serves as a sub-adviser to The Meet Kevin Pricing Power ETF.
Plato’s Philosophy, LLC is currently registered with the Securities and Exchange Commission
(“SEC”) as an investment adviser and with the State of California as a limited liability company.
The Firm conducts business primarily in California. Plato’s Philosophy is 100% owned by
Kevin Paffrath.
B. Types of Advisory Services Offered
Plato’s Philosophy offers four types of advisory services: ETF Advisory Services, Personalized
Wealth Plan Services, Fundamental Analysis Services, and Financial Audit Interview Services.
Each of these services is described more fully below.
1. ETF Advisory Services
Plato’s Philosophy serves as the sub-advisor to The Meet Kevin Pricing Power ETF. The Firm
provides advisory services related to trades, fund diversification, and future market planning for
the ETF. This service is not offered to the general public.
2. Personalized Wealth Plan Services
The Firm offers a personalized wealth plan video service in which clients are able to receive a
video that is personally tailored to their financial situation and goals and outlines recommended
action steps for them to take to grow their wealth.
Upon the client signing the required agreement paperwork and paying the applicable flat fee, the
client will receive a financial survey and an upload link to provide information and documents
related to their current financial status to the Firm. This includes providing information
regarding the client’s bank accounts, brokerage accounts, assets, liabilities, debts, properties, etc.
After receiving the requested data, one of the Firm’s investment adviser representatives will
reach out and speak with the client to review his/her financial documents and provided
information and discuss the clients’ goals and timetable. The Firm’s investment adviser
representatives will then meet internally to discuss the client’s financial status and objectives and
develop a cohesive action plan for the client to take with a goal to grow their wealth. One of the
investment advisor representatives will then video-record themselves to explain the various
components and recommended steps of the plan. The client will then be sent that video via an
electronic/digital/online method of the Firm’s choosing for the client to watch and review at the
client’s leisure.
The Firm shall remove and will not include all personally identifiable/confidential information in
the video for cybersecurity, personal security, and other purposes before it is delivered to the
client. The Firm wholly owns the video and reserves the right to use the video in the future for
any purpose, including, but not limited to, marketing, training, new products, etc. The client is
granted a non-exclusive, limited-use license in the video.
3. Fundamental Analysis Services
The Firm offers clients the opportunity to submit a publicly-traded company for the Firm to
perform fundamental analysis on and provide a video to the client, summarizing the analysis.
Once the client signs the required agreement and pays the flat fee, the client will be given a form
to submit a publicly-traded
company’s name to the Firm for it to review. The Firm’s team of
investment adviser representatives will then perform a fundamental analysis of the company.
This analysis shall include a review of the company’s financial reports, news releases, social
media, and other publicly available information. Once the team has completed their analysis of
the company, one of the investment adviser representatives will then record a video, outlining the
analysis and the various findings that the team found regarding this company in its present state
and potential for market growth. The client will then be sent that video via an
electronic/digital/online method of the Firm’s choosing for the client to watch and review at the
client’s leisure.
The Firm shall remove and will not include all personally identifiable/confidential information in
the video for cybersecurity, personal security, and other purposes before it is delivered to the
client. The Firm wholly owns the video and reserves the right to use the video in the future for
any purpose, including, but not limited to, marketing, training, new products, etc. The client is
granted a non-exclusive, limited-use license in the video.
4. Financial Audit Interview Services
The Firm offers clients the opportunity to apply to be featured on a podcast-style interview with
one of the Firm’s investment adviser representatives. During the podcast, the client will meet
with the investment adviser representative, either in-person or virtually, and discuss his/her
financial holdings, goals, risk tolerance, etc. and receive the investment adviser representative’s
feedback and advice based on what is discussed during the interview.
The Firm wholly owns the video/audio recording and broadcast rights of the interview and
reserves the right to use the video/audio recording in the future for any purpose, including, but
not limited to, marketing, training, new products, etc. The client is cautioned prior to the
interview to only share and discuss such information during the interview that he/she is
comfortable with being publicly shared.
C. Client Customization of Plato’s Philosophy’s Advisory Services
Clients are permitted to customize Plato’s Philosophy’s advisory services to a limited extent.
1. ETF Advisory Services
The Firm does not offer the ability to customize this service as this service is rendered to another
investment adviser for the purposes of advising an ETF and is not provided to the public.
2. Personalized Wealth Plan Services
Clients may describe his/her investment goals, objectives, timetables, etc. to guide the type of
financial advice that the Firm provides in the final video. The client can explain what sectors
he/she does not want to invest in or what direction they would like to take their portfolio. The
Firm will not be providing a one-size-fits-all approach to the personalized financial advice that is
rendered to the client in the personalized wealth plan video.
3. Fundamental Analysis Service
The client will be permitted to decide which company it would like the Firm to review along
with additional details he/she believes that the Firm should know to include in its fundamental
analysis of the selected company.
4. Financial Audit Interview Services
The client will be permitted to discuss their finances and real estate holdings along with related
ancillary topics of his/her choosing during the interview with the Firm’s investment adviser
representative.
D. Wrap Fee Programs
Plato’s Philosophy does not provide portfolio management services to any wrap fee programs, as
that term is defined in the instructions to Form ADV Part 2.
E. Managing Client Assets
Plato’s Philosophy does not currently manage any client assets.
However, the Firm is a sub-adviser to Tidal Investments, LLC for The Meet Kevin Pricing
Power ETF. As disclosed in Item 5(D) of the Firm’s Form ADV Part 1, the ETF Fund currently
has approximately $39,440,000 assets under management as of March 20, 2024.