Description of the Advisory Firm
Constant Guidance Financial LLC (referred to as “CGF Advisor”, “CGF”, the “Advisor”, “we”,
“our”, “us”) is a Registered Investment Adviser with the Securities and Exchange Commission
(“SEC”). CGF Advisor is organized as a Limited Liability Company (LLC) under the laws of the
State of Massachusetts. CGF Advisor was founded in October 2014, and is owned and operated
by its President and CEO, Mitch S. Zides, CFA, CFP®. Mr. Zides also serves as Chief Compliance
Officer and Portfolio Manager.
We hold ourselves to a fiduciary standard, which means our firm has a legal duty to always try to
put the interest of our clients ahead of its own. We are a fee-only investment advisor that doesn’t
charge commissions, sales fees, custody fees or receive any referral fees from third parties. We are
proud to be directly compensated by our clients. We carefully manage, disclose, and minimize all
potential conflicts of interest. Our goal is to provide the highest quality service at a reasonable fee,
which is always fully transparent. We maintain the highest standards of ethics.
A. Types of Advisory Services
CGF Advisor provides wealth management advice, investment advisory, and retirement plan
consulting to individuals, trusts, estates, charitable organizations, corporations, plan sponsors,
and other business entities. Each client’s needs are different and the financial counseling
recommendations and advice are customized to meet the client’s unique objectives. Although
each client may have unique needs, the types of services are similar. These services include asset
allocation, investment planning, retirement planning, estate planning, risk management
strategies, and comprehensive financial counseling.
We manage accounts on a discretionary basis. When we manage your accounts on a discretionary
basis, we have the authority to make purchase and sell decisions for your account(s) consistent
with the goals and objectives. Client’s investment objectives are determined through data
gathering, risk assessment questionnaires and interviews during the initial planning process. In
addition, we may coordinate with attorneys to develop estate plans, insurance agents, and
accountants for tax planning and the preparation of tax returns.
Financial Planning
For individual clients, CGF Advisor begins the relationship with a financial planning overview.
As needed, or as requested by the client, analysis may be offered for areas such as retirement
planning, estate planning, education funding, and other matters specific to each client’s
circumstances.
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CGF Advisor offers a unique planning philosophy that incorporates goal-based planning with full
cash flow after retirement. We meet with our clients regularly, either in person or via telephone,
to discuss progress towards goals and to make necessary changes as needed. This service is offered
at no additional charge to CGF Advisor investment management clients.
On a case-by-case basis, CGF Advisor may accept Financial Planning engagements for individuals
who are not ongoing portfolio management clients. These engagements are standalone, meaning
they are limited in scope and not ongoing, and billed on an hourly rate or on a project basis.
If you engage us to perform these services, you will receive a written agreement detailing the
services, fees, terms and conditions of the relationship. You will also receive this Brochure. You
are under no obligation to implement recommendations through us. CGF Advisor does not manage
or place Client assets into a wrap fee program.
Investment Advisory
CGF Advisor provides investment advice and portfolio management services on an ongoing basis.
We provide in-depth and rigorous analysis of existing investment portfolios and construction of
new portfolios. In performing investment management services, we typically examine and analyze
your overall financial situation, which may include issues such as taxes, insurance needs, overall
debt, credit, business consulting, retirement savings and reviewing your current investment
program. Our services may focus on all or only one of these areas depending upon the scope of
our engagement with you.
In most cases, an Investment Policy Statement is established that summarizes your specific
financial circumstances, including goals and objectives, risk tolerance, and time horizon for
investing. This information is used in the design, implementation and management of a diversified
and risk appropriate investment portfolio. Thereafter, CGF Advisor actively manages your
portfolio on an ongoing basis and will rebalance the portfolio as required by changes in market
conditions and/or changes in your financial circumstances. The Advisor may employ cash
positions and option strategies (if consent is given prior in writing) as possible hedges against
market
movement, which may adversely affect the portfolio.
Our tailored portfolio asset allocations will include but will not be limited to cash, bonds
(corporate debt, certificates of deposit, municipal securities and US Government securities),
stocks, exchange-traded funds, closed-end fund and mutual funds. We will select specific
securities that will provide diversification to help meet each client's stated investment objectives
and risk objectives. The types of Investment Advisory services rendered include asset allocation
strategies and discretionary management of investment strategies.
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Services Limited to Specific Types of Investments
We generally limit our investment advice to Exchange Traded Funds (ETFs), stocks, bonds, and
mutual funds. We will also trade closed end funds (CEFs), equity options, and may use other
securities as well to help diversify a portfolio when applicable.
401K Consulting Services
CGF Advisor offers a range of services to retirement plans governed by the Employee Retirement
Income Security Act of 1974 (“ERISA”) and their participants. CGF Advisor provides investment
advice in the form of mutual fund evaluation and recommendation services to 401k plans and the
plan’s trustees. Our ERISA services include but are not limited to establishing an Investment
policy statement, participant and sponsor education, 404(c) Safe Harbor advice, service provider
due diligence, and investment advice.
Typically, there are one or more trustees (employees of the company sponsoring the plan) who are
the 401k “named fiduciaries” under ERISA supervised by the DOL (Department of Labor). Our
services are provided to, and contracted by the Named Fiduciaries responsible for the overall
administration of the Plan (and their various service providers, including a custodian, plan
administrator, etc.).
We will also monitor the current managed investment line up including the investment’s
performance compared to an applicable benchmark cost. If we determine that a fund no longer
meets our criterion, we will select possible alternatives and present them to the plan sponsor. In
providing services for some 401k plans, CGF Advisor has the discretionary authority to make
changes to the funds within the plan that are made available to plan participants to buy and sell.
We may conduct plan participant meetings when a change is made either to the structure of the
plan or if the investment lineup changes as a result of our decisions. We will detail the changes
being made, how it affects the current participants, review the current investment opportunities,
how participants may make changes to their investment selections, and will answer any questions
a participant may have. We will review with the participants how to select the investments.
Client Tailored Services and Client Imposed Restrictions
We provide investment advisory services and offer the same services to all clients. Each client is
required to enter into an Investment Advisory Agreement with the Advisor that defines the
terms, conditions, authority and responsibilities of the Advisor and the client.
These services may include:
Establishing an Investment Policy Statement – Each specific financial plan and their
implementation are dependent upon the client Investment Policy Statement which outlines each
client’s current situation. This statement outlines the client’s investment goals and objectives
along with the strategy to be employed to meet those objectives. An Investment Policy Statement
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generally includes specific information – goals, investment strategy, risk tolerance, and security
restrictions imposed by the client.
Asset Allocation – We will develop a strategic asset allocation that is customized to each
client’s investment objectives, financial situation, time horizon, values, and risk profile for each
client.
Financial Planning – We will develop a comprehensive plan for each client, helping them to
identify, and quantify, their short-term and long-term financial goals.
Investment Management and Supervision – We will provide investment management and
ongoing oversight of the client’s accounts and overall portfolio, in accordance with the IPS and
Investment Advisory Agreement. We routinely assess account performance and adjust
accordingly.
Wrap Fee Programs
CGF Advisor does not sponsor or participate in third-party wrap fee program.
Amounts Under Management
As of December 31, 2023, CGF Advisor clients have entrusted our firm with the following of their
life savings (assets under management):
Number of
Accounts
Assets under
Management
Discretionary Accounts 565 $128,146,765
Non-discretionary Accounts 0 0
Total 565 $128,146,765