A. Bouchey Financial Group LTD (“Bouchey Financial” or the “Advisor”) is a corporation
formed on August 30, 1995 in the State of New York. Bouchey Financial became a
registered investment advisor in May 1996. Bouchey Financial is owned by Steven B.
Bouchey (President).
Bouchey Financial’s Chief Compliance Officer, David W. Clarke, remains available
to address any questions that a client or prospective client may have regarding any
aspect of this ADV Part 2A, Firm Brochure.
B. As discussed below, Bouchey Financial offers to its clients (individuals, high net worth
individuals, pension and profit-sharing plans, business entities, trusts, estates and charitable
organizations) investment advisory services, and, to the extent specifically requested by a
client, financial planning and related consulting services.
Bouchey Financial 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
towards each client and seeks to mitigate conflicts of interest. Bouchey Financial’s
fiduciary commitment is further described in the Code of Ethics. For more information
regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest
in Client Transactions and Personal Trading.
WEALTH MANAGEMENT SERVICES
Bouchey Financial may provide Clients with wealth management services, which generally
includes a broad range of comprehensive financial planning and consulting services as well
as discretionary management of investment portfolios. Financial planning and consulting
may also be offered as a stand-alone service.
Investment Management Services – Bouchey Financial provides customized investment
advisory solutions for its Clients either as a component of wealth management or on a
stand-alone basis. This is achieved through continuous personal Client contact and
interaction while providing discretionary and/or non-discretionary investment
management and related advisory services. Bouchey Financial works with each Client to
identify their investment goals and objectives as well as risk tolerance and financial
situation.
Bouchey Financial primarily allocates Client assets among various mutual funds,
individual equity securities, fixed income securities and exchange traded funds, and
unaffiliated investment managers or investment platforms (collectively “Independent
Managers”) in accordance with their stated investment objectives.
Bouchey Financial’s investment approach is 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. Bouchey Financial 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.
Bouchey Financial evaluates and selects investments for inclusion in Client portfolios only
after applying its internal due diligence process. Bouchey Financial may recommend
specific positions to increase sector or asset class weightings. The Advisor may recommend
employing cash positions as a possible hedge against market movement. Bouchey
Financial 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,
change in risk tolerance of the Client, generating cash to meet Client needs, or any risk
deemed unacceptable for the Client’s risk tolerance.
At no time will Bouchey Financial 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, pursuant to the
terms of the advisory agreement, please see Item 12 – Brokerage Practices.
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 a 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 will
earn a new (or increase 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.
Use of Independent Managers –
In certain instances, Bouchey Financial will recommend
that Clients utilize one or more Independent Managers for all or a portfolio of a Client’s
investment portfolio. In such instances, the Client will then enter into an advisory
agreement with the Independent Manager[s] that defines the terms in which the
Independent Manager[s] will provide investment management and related services.
Bouchey Financial may also assist in the development of the initial policy
recommendations and managing the ongoing Client relationship. The Advisor will perform
initial and ongoing oversight and due diligence over each Independent Manager to ensure
the strategy remains aligned with Client 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, prior to
entering into an agreement with an Independent Manager, will be provided with the
Independent Manager's Form ADV 2A (or a brochure that makes the appropriate
disclosures).
Financial Planning and Consulting – Bouchey Financial will typically provide a variety
of financial planning services to individuals and families as a component of wealth
management services. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan or
rendering a 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 business planning, investment planning, retirement planning, insurance
planning, personal savings, education savings, cash flow forecasting, large purchase
planning, charitable giving, tax planning, trust/estate planning and other areas of a Client’s
financial situation.
A financial plan developed for 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, establish education savings and/or charitable giving
programs. Bouchey Financial 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 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 months of contract date, assuming all information and documents requested are
provided promptly.
Financial planning 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, 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, the Client is under no obligation to implement
the transaction through the Advisor.
RETIREMENT PLAN ADVISORY SERVICES
Bouchey Financial 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 and its Plan Participants. Each engagement is customized to the
needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Investment Management (ERISA 3(21) and ERISA 3(38))
• Performance Reporting
• Benchmarking Services
These services are provided by Bouchey Financial serving in the capacity as 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 Bouchey Financial’s fiduciary status, the specific services to be rendered
and all direct and indirect compensation the Advisor reasonably expects under the
engagement.
C. Bouchey Financial shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, Bouchey
Financial shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time, impose
reasonable restrictions, in writing, on Bouchey Financial’s services.
D. Bouchey Financial does not participate in a wrap fee program.
E. As of December 31, 2023, Bouchey Financial manages $ 1,160,960,475 in client assets,
$1,151,350,667 of which are managed on a discretionary basis and $9,609,808 on a non-
discretionary basis.