A. Firm Information Signet Financial Management, LLC (“Signet” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). Signet is a limited liability company (“LLC”) formed under the laws of the State of Delaware in 2009. Prior to 2009, the Advisor was an LLC in the State of New Jersey. Signet has been a registered investment advisor with the SEC since January 1988. On March 31, 2017, Krasney Financial, LLC changed its business name to Signet Financial Management, LLC. Signet is owned and operated by Kenneth (“Matt”) M. Etter (Partner and President), Evgeniy (“Eugene”) Y. Yashin (Partner, Chief Executive Officer, and Chief Investment Officer), Shawn Hirsch (Partner, Wealth Management), and Stephen E. Tuttle (Partner, Chief Investment Strategist, and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and advisory services provided by Signet.
Signet offers services through the Advisor’s network of investment advisor representatives (“IARs”). IARs may have their own legal business entities or trade names. The IARs' trade names may be used for marketing purposes and appear on marketing materials or Client statements. The Client should understand that the businesses are legal entities of the IARs and not of Signet. The IARs are under the supervision of Signet, and the advisory services of the IARs are provided through Signet. The Advisor has the arrangement described above with the following IARs:Christopher Berte and Jason Kohut – Signet Financial Management of SWFL.
B. Advisory Services Offered Signet offers investment management and related services to individuals, high-net-worth individuals, trusts, estates, charitable organizations, businesses, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith toward each Client and seeks to mitigate potential conflicts of interest. The Advisor’s fiduciary commitment is further described in its Code of Ethics. For more information regarding Signet’s Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading.
Wealth Management Services Signet provides Clients with wealth management services, which generally include discretionary management of investment portfolios in connection with a broad range of comprehensive financial planning and consulting services. These services are described below.
Internal Investment Management Services – Signet offers investment management as a component of its wealth management services. Signet provides customized investment advisory solutions for its Clients. Signet primarily provides discretionary investment advisory and related services for Clients. Signet works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Signet will then construct a portfolio consisting of diversified mutual funds, exchange-traded funds (“ETFs”), individual equity securities, and individual fixed-income securities, as appropriate, to achieve the Client’s investment goals. The Advisor may also utilize options, independent investment managers, private funds, and other types of investments to meet the unique needs of certain Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
Signet’s investment strategies are primarily long-term focused, but the Advisor may buy, sell, or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Signet will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
Signet evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Signet may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Signet may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against the market movement. Signet may recommend selling positions for reasons that include but are not limited to harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, changes in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
Signet selects, recommends, and/or retains mutual funds on a fund-by-fund basis and seeks to use non-retail or institutional classes when possible. Due to specific custodial or mutual fund company constraints, material tax considerations, and/or systematic investment plans, Signet may select, recommend, and/or retain a mutual fund share class that has a higher expense ratio than an equivalent share class. Signet will seek to select the lowest cost share class available that is in the best interest of each Client and will ensure the selection aligns with the Client’s financial objectives and stated investment guidelines.
Use of Independent Managers – Signet may recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In such instances, the Client will be required to authorize and enter into an investment management agreement with an Independent Manager that defines the terms in which the Independent Manager will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with the Client's investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures) prior to entering into an agreement with an Independent Manager.
At no time will Signet accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian unless otherwise directed by the Client. For additional information, please see Item 12 – Brokerage Practices and Item 15 – Custody.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to the Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA or recommend a similar transaction, including rollovers from one ERISA-sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor earns a new (or increases its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor.
Participant Account Management – As part of the Advisor’s investment management services, when appropriate, the Advisor will use a third-party platform to facilitate the management of held-away assets, such as defined contribution plan participant accounts, with investment discretion. The platform allows the Advisor to avoid being considered to have custody of Client funds since the Advisor does not have direct access to

Client log-in credentials to affect trades. Signet is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the Client, allowing the Client to connect an account[s] to the platform. Once the Client’s account[s] is connected to the platform, the Advisor will review the current account allocations. When deemed necessary, the Advisor will rebalance the account considering the Client’s investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account[s] will be reviewed at least quarterly, and allocation changes will be made as deemed necessary.
Financial Planning and Consulting Services – Signet provides financial planning and/or consulting services included with its wealth management services or pursuant to a written financial planning and consulting agreement. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, and establish education savings and/or charitable giving programs.
Signet may also refer Clients to an accountant, attorney, or other specialist as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of the contract date, assuming all information and documents requested are provided promptly.
Consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client.
For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, there is no guarantee of returns, and the Client is under no obligation to implement the transaction through the Advisor.
Retirement Plan Advisory Services Signet provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: ●Performance Reporting ●Investment Oversight Services (ERISA 3(21)) ●Investment Management Services (ERISA 3(38)) ●Ongoing Investment Recommendations and Assistance ●ERISA 404(c) Assistance These services are provided by Signet serving in the capacity of a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Signet’s fiduciary status, the specific services to be rendered, and all direct and indirect compensation the Advisor reasonably expects under the engagement.
Sub-Advisory Services – Signet provides customized investment models available through the turn-key asset management portfolio and practice management software platform ("TAMP Platform") of Matrix Settlement & Clearance Services, LLC ("MSCS"). MSCS has developed a customized single-source managed account solution that it makes available to its clients and the clients of third-party investment advisors. The MSCA TAMP Platform provides investment advisors with highly intuitive tools and the ability to invest their client’s assets into separately managed accounts (“SMAs”) and unified managed accounts (“UMAs”) portfolios. MSCS provides Signet with the ability to create personalized investment portfolios on its TAMP Platform, trade order management, order aggregation, and other administrative and operational services. Trading on the MSCS TAMP Platform is executed through the client’s custodian.
Signet provides its sub-advisory services on MSCS’s TAMP Platform to unaffiliated third-party investment advisors (the "Primary Investment Advisor"), whereby such third parties engage Signet for the purpose of managing all or a portion of the unaffiliated advisor's clients' assets ("outside accounts"). The Primary Investment Advisor will remain the investment advisor for its clients' accounts (herein the “investor[s]”). Under such arrangements, Signet will provide discretionary investment management services, where the management services provided to the outside accounts are based upon established model portfolios that correlate to specific investment objectives and risk tolerance levels of the Primary Investment Advisor’s investors.
The Primary Investment Advisor will communicate with and assist investors in selecting the appropriate model based on information provided to the Primary Investment Advisor. Signet will monitor the investments contained in the outside accounts in order to provide ongoing supervision as to changes in the investments and/or allocations of such investments, which are necessary to adhere to the desired investment objective.
Subject to any written guidelines the investor may provide, Signet will be granted discretion and authority to manage the outside accounts. Accordingly, Signet is authorized to perform various functions, at the investor's expense, without further approval from the investor. Such functions include the determination of the type and amount of securities to be purchased and/or sold. Signet provides continuous supervision and rebalancing of the outside account portfolios as changes in market conditions occur.
The Primary Advisor will be responsible for determining the initial and ongoing suitability of any of Signet’s investment portfolios on the MSCS TAMP Platform in which to place the investor's assets. Signet will manage the outside accounts in accordance with the chosen portfolio’s stated objectives and will not be responsible for determining the suitability of any chosen strategy/portfolio.
C. Client Account Management Prior to engaging Signet to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the Client. These services may include: ●Identifying an Investment Strategy – Signet, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
●Asset Allocation – Signet will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation, and tolerance for risk for each Client. For sub-advised relationships, the primary advisor shall perform this analysis.
●Portfolio Construction – Signet will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
●Investment Management and Supervision – Signet will provide investment management and ongoing oversight of the Client’s investment portfolio[s].
D. Wrap Fee Programs Signet does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Signet.
E. Assets Under Management As of December 31, 2023, Signet manages $ $949,397,508 in Client assets, all of which are on a discretionary basis. Clients may request more current information at any time by contacting the Advisor.