A. ProVise Management Group, LLC (ProVise) is a limited liability company formed on January
10, 2002 in the state of Florida. ProVise first became registered as an investment adviser in 1988
through our predecessor firm, ProVise Management Group, Inc. V. Raymond Ferrara, CFP® is
ProVise’s Founder and Executive Chair. ProVise is directly owned by Kestra Financial, Inc.,
which is an indirect subsidiary of Kingfisher Holding, LP (Kingfisher), which also owns other
registered investment advisers, broker-dealers, insurance agencies, a trust company and other
product and service providers (ProVise Affiliates). From time to time, ProVise recommends that
you purchase or sell products and services from or through ProVise Affiliates and these ProVise
Affiliates and/or ProVise receives compensation as a result of such recommendations. A
recommendation that you purchase or sell products or services by or through a ProVise Affiliate
creates a conflict of interest since it could result in increased compensation to a ProVise Affiliate
and/or ProVise.
B. As discussed below, ProVise offers investment advisory services to a variety of clients such as
individuals, pension and profit sharing plans, business entities, trusts, estates and charitable
organizations, etc. ProVise also provides financial planning and related consulting services upon
specific request of a client.
INVESTMENT ADVISORY SERVICES
You can engage ProVise to provide discretionary and/or non-discretionary investment advisory
services on a fee basis. ProVise’s negotiable annual advisory fee is based on a percent (%) of
assets placed under ProVise’s management and generally ranges from 0.25% to 1.50%. The
minimum quarterly fee is generally $750.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
ProVise provides financial planning and/or consulting services on a standalone basis. These
services include advice on investment and non-investment related matters, such as retirement
planning, estate planning and insurance planning. We only provide these services upon request
and do not provide them to all clients. We determine in our sole discretion whether to provide
these services or not for a given client. Our planning and consulting fees are negotiable, but
generally range from $2,500 to $15,000 on a fixed fee basis, and from $150 to $750 on an hourly
rate basis. ProVise bases its fees on the level and scope of the services we provide you and
consider other factors such as your specific needs and circumstances and whether other
professionals are needed to render the services. Before we provide any planning or consulting
services, you generally enter into a written Financial Planning and Consulting Agreement with
ProVise setting forth the terms and conditions of the engagement (including termination),
describing the scope of the services we will provide, and indicating whether you must pay any
portion of the fee up front. Upon request, ProVise recommends the services of other
professionals for implementation purposes, including our personnel in their individual capacities
as registered representatives of a ProVise Affiliate broker-dealer and/or licensed insurance
agents. (See more information under Item 10 C.1 and 10 C.8). You are under no obligation to
engage the services of any professional we recommend. You retain discretion over all
implementation decisions and are free to accept or reject any recommendation we make.
RETIREMENT PLANNING CONSULTING SERVICES (ERISA PLAN and 401(k)
INDIVIDUAL ENGAGEMENTS)
Plan Asset Management. When ProVise is engaged to provide investment advisory services to
ERISA retirement plans, ProVise manages plan assets consistent with the investment objective
designated by the plan trustees and/or participants. In such engagements, ProVise will serve as
an investment fiduciary as that term is defined under The Employee Retirement Income Security
Act of 1974 (“ERISA”). ProVise will generally provide services on an “assets under
management” fee basis per the terms and conditions of an Investment Advisory Agreement
between the Plan and the Firm.
Participant-Directed Retirement Plans. ProVise provides investment advisory and consulting
services to participant-directed retirement plans. For such engagements, ProVise can assist the
plan sponsor with the selection of an investment platform and can also provide discretionary
selection and ongoing monitoring of a lineup of investment alternatives, from which plan
participants shall make their respective investment choices.
If engaged to provide this service, ProVise can also provide some or all the following services
to the plan client:
• Implement a multi-step process to help the plan fiduciary carry out the fiduciary
responsibility to monitor the plan’s investments. Establishing a sound fiduciary
governance process is vital to good decision-making and to documenting that prudent
procedural steps are followed in making investment decisions.
• Provide financial education to all levels of employees of the plan sponsor, regardless of
their participation in the plan, to enable them to more confidently accumulate and
manage their savings toward their retirement.
• Consult with the plan fiduciary to make an informed and knowledgeable vendor
selection decision.
Client Retirement Plan Assets. If requested to do so, ProVise can also provide investment
advisory services relative to retirement plan assets maintained by the client in conjunction with
the retirement plan established by the client’s employer. In such event, ProVise shall allocate
(or recommend that the client allocate) the retirement account assets among the investment
options available on the platform. ProVise’s ability shall be limited to the allocation of the assets
among the investment alternatives available through the plan. ProVise will not receive any
communications from the plan sponsor or custodian, and it shall remain the client’s exclusive
obligation to notify ProVise of any changes in investment alternatives, restrictions, etc.
pertaining to the retirement account. Unless expressly indicated by ProVise to the contrary, in
writing, the client’s retirement plan assets shall be included as assets under management for
purposes of ProVise calculating its advisory fee.
When providing the services described above to a plan that is qualified under the Employee
Retirement Income Security Act of 1974 (“ERISA”), or to a participant of such a plan, ProVise
does so as a fiduciary, as that term is defined under Section 3(21) of ERISA. When providing
such services on a discretionary basis, ProVise will also serve as an investment manager, as
defined under ERISA Section 3(38).
MISCELLANEOUS
Non-Investment Consulting/Implementation Services
ProVise can be engaged as a non-fiduciary consultant to conduct a comprehensive review of a
401k plan and then benchmark it against industry averages. The fee for this service is fixed
based on the scope of the engagement.
ProVise also provides consulting services regarding non-investment related matters, such as
estate planning, tax planning, insurance, and as a consultant on fiduciary matters to ERISA
retirement plans. We only provide these services upon request and do not provide them to all
clients. We determine in our sole discretion whether to provide these services or not for a given
client. Neither we, nor any of our representatives/employees, serve as an attorney or accountant.
We do not provide legal or tax advice, except that which is incidental to your financial planning
and/or investments, nor do we prepare legal or tax documents. Upon your request, we
recommend the services of other professionals for certain non-investment implementation
purposes (i.e. attorneys, accountants, insurance, etc.), including representatives of our firm in
their separate registered/licensed capacities. You are under no obligation to engage the services
of any professional we recommend. You retain discretion over all implementation decisions and
are free to accept or reject any recommendation we make.
You should be aware that if you do engage a professional we recommend, you should seek
recourse exclusively and directly from that professional should any dispute arise with that
engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney,
accountant, insurance agent, etc.), and not ProVise, shall be responsible for the quality and
competency of the services provided.
You are responsible for promptly notifying us if there is ever any material change in your
financial situation or investment objectives since it will cause us to review, evaluate, or revise
our previous recommendations and/or services to you.
Custodian Charges-Additional Fees. As discussed in Item 12 below, when requested to recommend
a broker-dealer/custodian for client accounts, ProVise generally recommends that Schwab (and/or NATC
for trust company services) as the broker-dealer/custodian for client investment management assets.
Broker-dealers such as Schwab charge brokerage commissions, transaction, and/or other type fees for
effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds,
and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for
which transaction fees, commissions, and/or other types of fees (as well as the amount of those fees)
shall differ depending upon the broker-dealer/custodian. While certain custodians, including Schwab,
generally do not currently charge fees on individual equity transactions (including ETFs), others
including NATC do. Please Note: there can be no assurance that Schwab or NATC will not change its
transaction fee pricing in the future.
Other Services. ProVise offers both discretionary and non-discretionary investment
management services relative to: (1) variable annuity and/or life insurance products that
clientsown, or (2) your individual employer sponsored retirement plans. In so doing, we either
direct or recommend the allocation of your assets among the various sub-accounts which
comprise the variable annuity and/or life insurance products or the retirement plan. For these
services, our management fee is paid quarterly in advance, based upon the market value of the
assets on the last day of the previous quarter. Your account assets are maintained at either the
specific insurance company that issued your variable annuity and/or life insurance product, or
at the custodian designated by the sponsor of your retirement plan.
Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving
an employer typically has four options regarding an existing retirement plan (and could engage
in a combination of these options): (i) leave the money in the former employer’s plan, if
permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers
are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the
account value (which could, depending upon the client’s age, result in adverse tax
consequences). If ProVise recommends that a client roll over their retirement plan assets into an
account to be managed by ProVise, such a recommendation creates a conflict of interest if
ProVise earns an advisory fee on the rolled over assets. In addition, the costs and fees associated
with an advisory account managed by ProVise generally will be higher than those of a retirement
plan. No client is under any obligation to roll over retirement plan assets to an account managed
by ProVise, whether it is from an employer’s plan or an existing IRA. If ProVise provides a
recommendation as to whether a client should engage in a rollover or not (whether it’s from an
employer’s plan or an existing IRA), ProVise is acting as a fiduciary 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. ProVise’s Chief Compliance
Officer, Shane O’Hara, CFP® remains available to address any questions that a client or
prospective client has regarding the potential for conflict of interest presented by such
rollover recommendation.
Please Note-Use of Mutual Funds and Exchange Traded Funds: Many mutual funds and
exchange traded funds are available directly to the public. Thus, a prospective client can obtain
many of the mutual funds that are recommended and/or utilized by ProVise independent of
engaging ProVise as an investment advisor. However, if a prospective client determines to do
so, he/she will not receive ProVise's initial and ongoing investment advisory services.
In addition to ProVise’s investment advisory fee described below, and transaction and/or
custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange
traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund
expenses).
Portfolio Activity. ProVise has a fiduciary duty to provide services consistent with the client’s
best interest. As part of its investment advisory services, ProVise will review client portfolios
on an ongoing basis to determine if any changes are necessary based upon various factors,
including, but not limited to, investment performance, market conditions, mutual fund manager
tenure, style drift, and/or a change in the client’s investment objective. Based upon these factors,
there will be extended periods of time when ProVise determines that changes to a client’s
portfolio are neither necessary, nor prudent. Clients remain subject to the fees described in Item
5 below during periods of account inactivity. Of course, as indicated below, there can be no
assurance that investment decisions made by ProVise will be profitable or equal any specific
performance level(s).
Please Note: Cash Positions. ProVise continues to treat cash as an asset class. As such, unless
determined to the contrary by ProVise, all cash positions (money markets, etc.) shall continue
to be included as part of assets under management for purposes of calculating ProVise’s
advisory fee. At any specific point in time, depending upon perceived or anticipated market
conditions/events (there being no guarantee that such anticipated market conditions/events will
occur), ProVise maintains cash positions for defensive purposes. In addition, while assets are
maintained in cash, such amounts could miss market advances. Depending upon current yields,
at any point in time, ProVise’s advisory fee could exceed the interest paid by the client’s money
market fund.
Cash Sweep Accounts. Account custodians generally require that cash proceeds from account
transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep
account. The yield on the sweep account is generally lower than those available in money market
accounts. To help mitigate this issue, ProVise shall generally purchase a higher yielding money
market fund available on the custodian’s platform with cash proceeds or deposits, unless
ProVise reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-
day period to purchase additional investments for the client’s account. Exceptions and/or
modifications can and will occur with respect to all or a portion of the cash balances for various
reasons, including, but not limited to, the amount of dispersion between the sweep account and
a money market fund, the size of the cash balance, an indication from the client of an imminent
need for such cash, or the client has a demonstrated history of writing checks from the account.
Please Note: The above does not apply to the cash component maintained within ProVise’s
actively managed investment strategy (the cash balances for which shall generally remain in the
custodian designated cash sweep account), an indication from the client of a need for access to
such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained
for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for
yield dispersion/cash balance decisions and corresponding transactions for cash balances
maintained in any of ProVise’s unmanaged accounts.
Cybersecurity Risk. The information technology systems and networks that ProVise and its
third-party service providers use to provide services to ProVise’s clients employ various
controls, which are designed to prevent cybersecurity incidents stemming from intentional or
unintentional actions that could cause significant interruptions in ProVise’s operations and result
in the unauthorized acquisition or use of clients’ confidential or non-public personal
information. Clients and ProVise are nonetheless subject to the risk of cybersecurity incidents
that could ultimately cause them to incur losses, including for example: financial losses, cost,
and reputational damage to respond to regulatory obligations, other costs associated with
corrective measures, and loss from damage or interruption to systems. Although ProVise has
established its processes to reduce the risk of cybersecurity incidents, there is no guarantee that
these efforts will always be successful, especially considering that ProVise does not directly
control the cybersecurity measures and policies employed by third-party service providers.
Clients could incur similar adverse consequences resulting from cybersecurity incidents that
more directly affect issuers of securities in which those clients invest, broker-dealers, qualified
custodians, governmental and other regulatory authorities, exchange and other financial market
operators, or other financial institutions.
Please Note: Socially Responsible (ESG) Investing Limitations. Socially Responsible
Investing involves the incorporation of Environmental, Social and Governance (“ESG”)
considerations into the investment due diligence process. ESG investing incorporates a set of
criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a
company safeguards the environment); Social (i.e., the manner in which a company manages
relationships with its employees, customers, and the communities in which it operates); and
Governance (i.e., company management considerations). The number of companies that
maintain an acceptable ESG mandate can be limited when compared to those that do not, and
could underperform broad market indices. Investors must accept these limitations, including
potential for underperformance. Correspondingly, the number of ESG mutual funds and
exchange-traded funds are limited when compared to those that do not maintain such a mandate.
As with any type of investment (including any investment and/or investment strategies
recommended and/or undertaken by ProVise), there can be no assurance that investment in ESG
securities or funds will be profitable, or prove successful. While ProVise does not advocate an
ESG investment strategy, it will seek to employ ESG if directed by a cient to do so.
ByAll Accounts. In conjunction with the services provided by ByAll Accounts, ProVise also
provides periodic comprehensive reporting services, which can incorporate all the client’s
investment assets including those investment assets that are not part of the assets managed by
ProVise (the “Excluded/Unsupervised Assets”). ProVise’s service relative to the
Excluded/Unsupervised Assets is limited to reporting services only, which does not include
investment implementation. Because ProVise does not have trading authority for the
Excluded/Unsupervised Assets, to the extent applicable to the nature of the
Excluded/Unsupervised Assets (assets over which the client maintains trading authority vs.
trading authority designated to another investment professional), the client (and/or the other
investment professional), and not ProVise, shall be exclusively responsible for directly
implementing any recommendations relative to the Excluded/Unsupervised Assets. The client
and/or their other advisors that maintain trading authority, and not ProVise, shall be exclusively
responsible for the investment performance of the Excluded/Unsupervised Assets. Without
limiting the above, ProVise shall not be responsible for any implementation error (timing,
trading, etc.) relative to the Excluded/Unsupervised Assets. In the event the client desires that
ProVise provide investment management services with respect to the Excluded/Unsupervised
Assets, the client can engage ProVise to do so pursuant to the terms and conditions of the
Investment Advisory Agreement between ProVise and the client.
Independent Managers. Under certain circumstances, ProVise will allocate, and/or
recommend that you allocate, a portion of your assets among unaffiliated investment managers
(Independent Managers) that meet your designated investment objectives. These Independent
Managers shall be responsible for the active discretionary management of your allocated assets,
however, we shall continue to monitor and review your account performance, asset allocation
and investment objectives. In addition to your designated investment objectives, we also
consider the Investment Manager’s management style, performance, reputation, financial
strength, reporting capabilities, pricing, and other available information and research on the
Investment Manager. The fees that you pay to an Investment Manager, as well as any transaction
related fees of your designated broker-dealer or account custodian, are separate from, and in
addition to, the fees you pay us for investment advisory services as described above.
Non-Discretionary Service Limitations. If you engage ProVise on a non-discretionary
investment advisory basis, you must accept that we cannot affect any account transactions
without obtaining at least your prior verbal consent. This means that if there is a market
correction event during which you are unavailable, we will not be able to take any action on
your account. Without discretionary authority, your account could suffer protracted losses or
forfeit potential gains in these types of situations.
Trade Error Policy. ProVise will reimburse accounts for losses resulting from our trade errors;
however, we reserve the right to retain any gains that arise from correcting a trade error.
Client Obligations. When providing you services, ProVise generally does not verify, nor are
we required to verify, any information you provide us or that we receive from your other
professionals. We are expressly authorized to rely upon any information provided by you or
your other professionals. You are responsible for promptly notifying us if there is ever any
material change in your financial situation or investment objectives since it willcause us to
review, evaluate, or revise our previous recommendations and/or services to you.
Disclosure Brochure. You will receive a copy of ProVise’s written Brochure as set forth on
Part 2A of Form ADV, in addition to our Form CRS (Client Relationship Summary), prior to,
or at the same time, you enter into an Investment Advisory Agreement or Financial Planning
and Consulting Agreement or Retirement Plan Consulting Agreement with us.
C. ProVise shall provide investment advisory services specific to your investment needs by
ascertaining your investment objective prior to providing investment advisory services. We
allocate or recommend that you allocate investment assets consistent with your designated
investment objectives. You can, at any time, impose reasonable restrictions, in writing, on our
services.
D. ProVise does not participate in a wrap fee program.
E. As of December 31, 2023, ProVise had $1,865,732,265 in assets under management on a
discretionary basis and $11,611,877 in assets under management on a non-discretionary basis.