A. Comprehensive Financial Planning, Inc. (the “Registrant” or “CFPI”) is a corporation formed
on February 28, 1984, in the Commonwealth of Pennsylvania. The Registrant became
registered as an Investment Adviser Firm in 1986. The Registrant is owned by Richard J.
Walters, (the “Principal”), CFP®, AIF® - Mr. Walters is also the Registrant’s President.
B. As discussed below, the Registrant offers to its clients (pension and profit-sharing plans,
individuals, business entities, trusts, estates and charitable organizations, etc.) investment
advisory services, and, to the extent specifically requested by a client, financial planning and
related consulting services.
INVESTMENT ADVISORY SERVICES
The client can determine whether to engage the Registrant to provide discretionary and/or
non-discretionary investment advisory services on a fee basis. The Registrant’s annual
investment advisory fee is based upon a percentage (%) of the market value of the assets
placed under the Registrant’s management between 1.75 % and 0.20% for Equity
investments and 0.26% for cash and cash equivalent investments. In certain circumstances, if
pension, profit sharing, or 401k plans have over 500 employees and assets in excess of $50
million dollars in plan assets, Registrant will consider an annual “flat fee” usually between
$155 to $200 per participant, based on the number of plan participants at the beginning of the
plan year.
THE MANAGED PORTFOLIO PROGRAM
The Registrant offers investment advisory service to its clients under its Managed Portfolio
Program. The Managed Portfolio Program is an intermediate to long-term proposition,
designed for clients seeking to participate in intermediate to long-term bull markets, while
avoiding the potential severe declines of intermediate to long-term bear markets. The
investment services under The Managed Portfolio Program are managed on a regular and
continuous basis. The Managed Portfolio Program attempts to coordinate and monitor the
client’s investment portfolio based on the client’s designated investment objectives, risk
tolerance, and goals.
The services offered within the Managed Portfolio Program include: continual asset
management and implementation services, summarized portfolio reports, semi-annual
account reports to clients detailing with account holdings, and a newsletter reviewing the
markets, the economy and the Registrant’s current investment outlook.
RETIREMENT CONSULTING
The Registrant also provides non-discretionary pension consulting services, pursuant to
which it assists sponsors of self-directed retirement plans as well as trustee directed
retirement plans with the selection and/or monitoring of investment alternatives (generally
open-end mutual funds) from which plan participants shall choose in self-directing the
investments for their individual plan retirement accounts if it is a self-directed retirement
plan. In addition, to the extent requested by the plan sponsor, the Registrant shall also
provide participant level education designed to assist participants in identifying the
appropriate investment strategy for their retirement plan accounts. Also, the Registrant
provides participant enrollment meetings to provide education on how the plan sponsor plan
document functions. The terms and conditions of the engagement shall generally be set forth
in a separate agreement between the Registrant and the plan sponsor.
Comprehensive Financial Planning, Inc. shall serve as a “fiduciary” within the meaning of
Section 3(21) under the Employee Retirement Income Security Act of 1974 (ERISA) with
respect to retirement accounts for the plan sponsor. Such advisers provide advice to
retirement plans – they do not take control of the plan assets, so the plan sponsor has the final
decisions regarding implementation of the investment options.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
To the extent specifically requested by a client, the Registrant may determine to provide
financial planning and/or consulting services (including investment and non-investment
related matters, including estate planning, insurance planning, etc.) on a stand-alone separate
fee basis.
The Registrant uses a two-fold approach when providing financial planning and consulting
services to its clients. First, the Registrant takes a broad view of the client’s financial picture.
Second, the Registrant attempts to coordinate and formulate an interrelated plan by working
closely with each client’s other professional advisers.
The Registrant begins each client relationship with a background interview, learning the
client’s current financial positions, income stream, expenditures, retirement position, and
investment portfolio. Thereafter, the client’s individual planner analyzes taxable income
statements, cash flow statements, income tax returns, insurance policies, investment
portfolio, retirement plan, balance sheets, and the client’s investment objectives. After
gathering this information, the individual planner is able, with the cooperation of the client’s
other professionals (attorney, accountant, investment adviser, insurance adviser), to form a
strategic plan of action. A formal plan is delivered to the client for comments and
adjustments, followed by execution. If changes in a client’s financial circumstances warrant
it, the planner may, on an hourly basis, revise and update the client’s financial plan.
The Registrant’s planning and consulting fees are generally rendered at a rate of $250.00 per
hour, but in certain limited circumstances may be negotiable (depending upon the level and
scope of the services required and the professional rendering the services). Prior to engaging
the Registrant to provide planning or consulting services, clients are generally required to
enter into a Financial Planning and Consulting Agreement with Registrant setting forth the
terms and conditions of the engagement (including termination), describing the scope of the
services to be provided, and the portion of the fee that is due from the client prior to
Registrant commencing services.
Subsequent to the completion of a client’s initial financial plan and analysis, the client may
terminate the Registrant’s on-going financial planning agreement upon ten (10) day’s written
notice to the Registrant.
If requested by the client, Registrant may recommend the services of other professionals for
implementation purposes, including the Registrant’s representatives in their individual
capacities as registered representatives of a broker-dealer and/or in their individual capacities
as licensed insurance agents. (See disclosure at Items 10 B and 10 C below). The client is
under no obligation to engage the services of any such recommended professional. The
client retains absolute discretion over all such implementation decisions and is free to accept
or reject any recommendation from the Registrant. Please Note: If the client engages any
such recommended professional, and a dispute arises thereafter relative to such engagement,
the client agrees to seek recourse exclusively from and against the engaged professional.
Please Also Note: It remains
the client’s responsibility to promptly notify the Registrant if
there is ever any change in his/her/its financial situation or investment objectives for the
purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or
services.
MISCELLANEOUS
Non-Investment Consulting/Implementation Services. To the extent requested by the
client, the Registrant may provide consulting services regarding non-investment related
matters, such as estate planning, tax planning, insurance, retirement planning, etc. Neither
the Registrant, nor any of its representatives, serves as an attorney or accountant, and no
portion of the Registrant’s services should be construed as same. To the extent requested by
a client, the Registrant may recommend the services of other professionals for certain non-
investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.),
including representatives of the Registrant in their separate licensed/registered capacities as
discussed below. The client is under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from the
Registrant. Please Note: If the client engages any such recommended professional, and a
dispute arises thereafter relative to such engagement, the client agrees to seek recourse
exclusively from and against the engaged professional. Please Also Note: It remains the
client’s responsibility to promptly notify the Registrant if there is ever any change in
his/her/its financial situation or investment objectives for the purpose of reviewing,
evaluating, or revising Registrant’s previous recommendations and/or services.
Retirement Rollovers - No Obligation/Conflict of Interest: A client leaving an employer typically
has four options (and may engage in a combination of these options): 1.) leave the money in his
former employer’s plan, if permitted, 2.) roll over the assets to his new employer’s plan, if one is
available and rollovers are permitted, 3.) rollover to an IRA, or 4.) cash out the account value (which
could, depending upon the client’s age, result in adverse tax consequences). The Registrant may
recommend an investor roll over plan assets to an Individual Retirement Account (IRA) managed by
the Registrant. As a result, the Registrant and its representatives may earn an asset-based fee. In
contrast, a recommendation that a client or prospective client leave his or her plan assets with his or
her old employer or roll the assets to a plan sponsored by a new employer will generally result in no
compensation to the Registrant (unless you engage the Registrant to monitor and/or manage the
account while maintained at your employer). The Registrant has an economic incentive to encourage
an investor to roll plan assets into an IRA that the Registrant will manage or to engage the Registrant
to monitor and/or manage the account while maintained at your employer. There are various factors
that the Registrant may consider before recommending a rollover, including but not limited to: i) the
investment options available in the plan versus the investment options available in an IRA; ii) fees
and expenses in the plan versus the fees and expenses in an IRA; iii) the services and responsiveness
of the plan’s investment professionals versus the Registrant’s; iv) protection of assets from creditors
and legal judgments; v) required minimum distributions and age considerations, and vi) employer
stock tax consequences, if any. No client is under any obligation to rollover plan assets to an IRA
managed by the Registrant or to engage the Registrant to monitor and/or manage the account while
maintained at your employer. The Registrant follows the guidelines of Department of Labor (DOL)
Prohibited Transaction Exemption 2020-02 (PTE 2020-02).
Please Note: Cash Positions. 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), the Registrant may maintain cash positions for defensive
purposes. All cash positions (money markets, etc.) shall be included as part of assets under
management for purposes of calculating the Registrant’s advisory fee. The Registrant’s
Chief Compliance Officer, Richard J. Walters, CFP®, AIF®, remains available to
address any questions that a client or prospective client may have regarding the above
fee billing practice.
Please Note-Use of Mutual Funds and/or ETFs (Exchange-Traded Funds): Many mutual funds
and/or ETFs are available directly to the public. Thus, a prospective client can obtain many of the
mutual funds and/or ETFs that may be recommended and/or utilized by the Registrant independent of
engaging the Registrant as an investment advisor. However, if a prospective client determines to do
so, he/she will not receive the Registrant's initial and ongoing investment advisory services.
Please Note: Non-Discretionary Service Limitations. Clients that determine to engage the
Registrant on a non-discretionary investment advisory basis must be willing to accept that
the Registrant cannot effect any account transactions without obtaining prior consent to any
such transaction(s) from the client. Thus, in the event of a market correction during which the
client is unavailable or unavailable timely, the Registrant will be unable to effect any account
transactions (as it would for its discretionary clients) without first obtaining the client’s
consent.
Client Obligations. In performing its services, the Registrant shall not be required to verify
any information received from the client or from the client’s other professionals and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains
his/her/its responsibility to promptly notify the Registrant if there is ever any change in
his/her/its financial situation or investment objectives for the purpose of
reviewing/evaluating/revising Registrant’s previous recommendations and/or services.
Disclosure Statement. A copy of the Registrant’s written Brochure as set forth on Part 2A of
Form ADV shall be provided to each client prior to, or contemporaneously with, the
execution of the Managed Portfolio Program Agreement, Advisory Agreement for Defined
Contribution Plans or Financial Planning and Consulting Agreement.
C. The Registrant 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, the Registrant 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 the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of February 29, 2024, the Registrant had $330,172,083 in assets under management on a
discretionary basis and $32,978,414 in assets under management on a non-discretionary
basis.