Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a corporation formed under the laws of the State of
California in 2019 and has been in business as an investment adviser since 2023. Our firm is wholly
owned by Boulos Michael.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Types of Advisory Services Offered
Asset Management
We offer discretionary and non-discretionary asset management services. As part of our Asset
Management service, a portfolio is created, consisting of individual stocks, bonds, exchange traded funds
(“ETFs”), options, mutual funds and other public and private securities or investments. The client’s
individual investment strategy is tailored to their specific needs and may include some or all of the
previously mentioned securities. Portfolios will be designed to meet a particular investment goal,
determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been
determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based
upon the client’s individual needs, stated goals and objectives.
Comprehensive Portfolio Management
As part of our Comprehensive Portfolio Management service clients will be provided asset
management and financial planning or consulting services. This service is designed to assist clients
in meeting their financial goals through the use of a financial plan or consultation. Our firm conducts
client meetings to understand their current financial situation, existing resources, financial goals, and
tolerance for risk. Based on what is learned, an investment approach is presented to the client,
consisting of individual stocks, bonds, ETFs, options, mutual funds and other public and private
securities or investments. Once the appropriate portfolio has been determined, portfolios are
continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual
needs, stated goals and objectives. Upon client request, our firm provides a summary of observations
and recommendations for the planning or consulting aspects of this service.
Use of Third-Party Investment Advisers
As part of our Asset Management or Comprehensive Portfolio Management services, our firm
may utilize the sub-advisory services of a third-party investment advisory firm or individual
advisor to aid in the implementation of an investment portfolio designed by our firm. We will
regularly monitor the performance of your accounts managed by third-party investment
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adviser(s) and may hire and fire any sub-adviser without your prior approval. Before
selecting a firm or individual, our firm will ensure that the chosen party is properly licensed
or registered. We will provide initial due diligence on third party money managers and ongoing
reviews of their management of client accounts. In order to assist in the selection of a third-party
money manager, our firm will gather client information pertaining to financial situation,
investment objectives, and reasonable restrictions to be imposed upon the management of the
account.
Our firm will periodically review third-party investment advisers’ reports provided to the
client at least annually. Our firm will contact clients from time to time in order to review their
financial situation and objectives; communicate information to third party money managers
as warranted; and assist the client in understanding and evaluating the services provided by
the third party money manager. Clients will be expected to notify our firm of any changes in
their financial situation, investment objectives, or account restrictions that could affect their
financial standing.
Financial Planning & Consulting
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations
for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming
that all the information and documents requested from the client are provided promptly, plans or
consultations are typically completed within 6 months of the client signing a contract with our firm.
Retirement Plan Consulting
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
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• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance on
allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
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 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.
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Tailoring of Advisory Services
Our firm offers individualized investment advice to our Asset Management and Comprehensive
Portfolio Management clients. General investment advice will be offered to our Financial Planning &
Consulting, Retirement Plan Consulting.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2023, we provided continuous management services for $105,988,673 in client
assets on a discretionary basis and $4,441,300 in client assets on a non-discretionary basis.