Description of Firm
The Norden Group LLC is a registered investment adviser based in Provo, UT. We are organized as a
limited liability company ("LLC") under the laws of the State of Utah. We are owned by Garen T.
Winn and Seth L. Merrill.
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 The Norden Group LLC and
the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Portfolio Management Services
We offer discretionary portfolio management services. 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 advisory agreement you sign with our
firm, a power of attorney, or trading authorization forms.
You may limit our discretionary authority (for example, limiting the types of securities that can be
purchased or sold for your account) by providing our firm with your restrictions and guidelines in
writing.
We may also offer non-discretionary portfolio management services. If you enter into non-discretionary
arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf
of your account. You have an unrestricted right to decline to implement any advice provided by our firm
on a non-discretionary basis.
As part of our portfolio management services, we may use one or more sub-advisers to manage a
portion of your account on a discretionary basis. The sub-adviser(s) may use one or more of their
model portfolios to manage your account. We will regularly monitor the performance of your accounts
managed by sub-adviser(s), and may hire and fire any sub-adviser without your prior approval. We
may pay a portion of our advisory fee to the sub-adviser(s) we use; however, you will not pay our firm a
higher advisory fee as a result of any sub-advisory relationships.
As part of our portfolio management services, in addition to other types of investments (see
disclosures below in this section), we may invest your assets according to one or more
model portfolios developed by our firm. These 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 not set restrictions on
the specific holdings or allocations within the model, nor the types of securities that can be purchased
in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of
securities in their account. In such cases, this may prevent a client from investing in certain models
that are managed by our firm.
Financial Planning Services
We offer financial planning services which 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. These services can range from broad-based financial planning to consultative or
single subject planning. If you retain our firm for financial planning services, we will meet with you to
gather information about your financial circumstances and objectives. We may also 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.
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.
Types of Investments
We offer advice on equity securities, corporate debt securities (other than commercial paper),
commercial paper, certificates of deposit, municipal securities, variable life insurance, variable
annuities, mutual fund shares, United States government securities, options contracts on securities,
private placements, money market funds, real estate, REITs, structured products, ETFs, interests in
partnerships investing in real estate and interests in partnerships investing in oil and gas interests.
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.
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.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), 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 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 December 31, 2023, we provide continuous management services for $987,200,768 in client
assets on a discretionary basis, and $0 in client assets on a non-discretionary basis. They have 2546
accounts.