Firm Description
Compass Financial Advisors, LLC (“Compass” or the “Adviser”) is an investment adviser
registered with the U.S. Securities and Exchange Commission (“SEC”). Registration with the SEC
does not constitute an endorsement of Compass by the SEC, nor does it indicate that Compass has
attained a particular level of skill or ability. Individuals associated with Compass provide the
advisory services on behalf of the firm. These individuals are appropriately licensed, qualified, and
authorized to provide advisory services on Compass’ behalf and are called Investment Adviser
Representatives (“Representatives”). Compass has been offering advisory services since
November 1998. The membership interests in Compass are owned by Cliff Malings, James Bobos,
David Fought, and Lynn Fisel. Compass does not control any other firm. Compass makes both
investment management and counseling services available to a wide variety of clients. Compass
Representatives begin each advisory service by carefully examining the client’s investment
objectives and financial circumstances. During this stage, time is taken to educate clients about the
various features of different types of investments to make them aware that attempting to attain a
higher rate of return entails accepting higher levels of risk. It is the client’s responsibility to ask
questions if there is something the client does not understand. Once this initial evaluation is
complete, Compass Representatives will recommend one or more of the advisory services
described in detail below.
Fundamental Planning Services
This service begins by a Representative evaluating the financial objectives and circumstances of a
client, determining the client’s short and long-term needs, analyzing alternate strategies, then
drafting written financial plans that may be simple or complex. The service may involve a one-time
project or a long-term ongoing engagement. These services are designed for situations where there
is not a large dollar amount of investments to manage or where the planning project issues are
complex or dealing with issues outside the area of portfolio management. General areas addressed
by planning services may include funding retirement income, wealth accumulation and retention,
general cash flow planning, estate planning, business continuation planning, pension planning, and
deferred compensation planning.
In designing a fundamental Plan, regardless of the complexity, Representatives will:
1. Interview the client, analyze the client’s financial needs, and assist the client in developing
realistic goals and objectives based on information provided by the client. The
Representative may also clarify planning problems and outline strategies designed to be
solutions. A client may retain Compass to perform a single nonrecurring project, such as
investment research or specific investment advice, retirement planning or insurance
analysis, rather than preparing a comprehensive plan covering these and other subjects. The
client may also engage a Representative for projects that may take a long period of time if
more complex long-term planning is needed.
2. Prepare a written Financial Plan in the scope requested by a client based on the information
gathered during the client interview and needs evaluation. This Plan may include
establishing a clear set of objectives, an outline of resources, a written investment policy
statement, an asset allocation model, strategy recommendations, product recommendations,
and steps for implementing the Plan.
3. Help the client implement the Plan, including purchasing and/or selling securities and/or
insurance products. Review the Plan periodically, no less than annually, or as agreed upon
with the client.
The Representative may also, as needed, recommend changes to the client’s investment portfolio
or Plan, either in writing or verbally. Changes in the client’s financial condition, personal
circumstances, goals, or general economic conditions may trigger changes in the Plan. To the extent
material changes have occurred to a client’s circumstances or goals or to the extent a client requests
a new project, the client will be asked to sign a new services agreement. The client may initiate
contact with a Representative as often as needed and the Representative will schedule conferences
as needed, usually no less than annually.
All planning is based on information provided by the client. It is the client’s responsibility to be
certain Compass has current and accurate information for the initial plan and it is the client’s
responsibility to inform the Representative of material changes affecting the investments and
planning strategies implemented.
Asset Allocation and Portfolio Supervision Services
Compass and its Representatives can provide asset allocation and portfolio management services
under the firm’s Asset Allocation and Portfolio Supervision program. The services include
investment analysis, allocation of investments, quarterly portfolio statements, ongoing monitoring,
and formal reviews of the portfolio at the times Representatives select.
Through the program, clients receive investment analysis, allocation recommendations, monthly
or quarterly statements reflecting holdings and transactions, quarterly analysis statements, and
ongoing monitoring services for a portfolio which may include stocks, bonds, mutual funds,
exchange-traded funds, private placements, and convertible securities. Compass may also
recommend the use of third-party investment managers and, depending upon the services
agreement signed, the Adviser may have authority from the client to exercise discretion in hiring
and terminating a manager. All eligible securities can be bought in an Asset Allocation and
Portfolio Supervision account or transferred into the account.
Under the program, the initial asset allocation process is based on the financial information
gathered from the client including net worth, risk tolerance, financial goals and objectives and
overall financial conditions. Based on that information, the client is provided with investment
recommendations designed to provide an appropriate asset mix consistent with the client’s
objections. The client’s portfolio and its performance are monitored by the client’s Representative
in light of the client’s stated goals and objectives. The frequency of these reviews is determined by
the Representative. Depending on the type of services agreement signed by the client, Compass may
have discretion to place orders at will, and will do so without first contacting the client for permission
for a transaction. Compass Representatives meet with the client on an as needed basis to discuss the
portfolio or other aspects of the service.
The Adviser typically recommends that investment management clients use the custody services of
Pershing LLC (“Pershing”). Pershing provides custody of client assets, process transaction orders
for client accounts, prepare account activity statements, and facilitate the payment of advisory fees
due Compass and third-party managers.
As a general rule, the Adviser believes that investing is best suited to those who believe in a long-
term buy-and–hold policy. Therefore, clients should not expect frequent investment changes in the
portfolio. However, as a result of monitoring the account, portfolio modifications may occasionally
be advisable and made.
Commissions will be charged for transactions by the brokerage firm processing the transactions.
As of December 31, 2023, Compass had assets of approximately $230,847,427 under discretionary
management and $0 under non-discretionary management.
Independent Investment Manager Services
Representatives may choose to recommend the use of third party managers that perform allocation
modeling, investment selection, monitoring, rebalancing, and reporting. Fees to Compass for such
services, including those for monitoring the other managers’ services, are usually calculated as a
percentage of the assets under management.
Compass may enter into various agreements with unaffiliated investment managers who
independently offer investment management and asset allocation services. Compass will not conduct
a comprehensive search for such advisers, but will usually recommend those it is familiar with and
believes will provide competent investment management services to clients. Other independent
firms may provide services at higher or lower costs and have better or worse performance than
managers recommended by Compass. Once a client has selected
a manager, Compass provides the
manager with information regarding the client’s financial background and objectives. The client
then enters into an agreement with the manager resulting in the manager agreeing to manage the
client’s account on a discretionary basis. Compass, itself, may also enter into such agreements,
provided a client has granted discretion to Compass to do so. Using discretion, the managers
purchase and sell securities without first contacting the client or Compass to do so.
After referring a client to a third party manager, Compass consults periodically with a client
regarding the performance of the client’s managed account and assists the client on an ongoing basis
regarding adjustments to asset allocations and other matters. Compass usually does not recommend
replacement of a manager based upon short-term results but will recommend such changes when it
deems it appropriate to do so.
Plan Participant Account Management
We use a third party platform to facilitate management of held away assets such as defined
contribution plan participant accounts, with discretion. The platform allows us to avoid being
considered to have custody of client funds since we do not have direct access to client log-in
credentials to affect trades. We are not affiliated with the platform in any way and receive no
compensation from them for using their platform. A link will be provided to the client allowing them
to connect an account(s) to the platform. Once client account(s) is connected to the platform, we
will review the current account allocations. When deemed necessary, we will rebalance the account
considering client 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.
Retirement Plan Advisory Services
These Services are provided to plan sponsors needing assistance in selecting and evaluating
investments for their retirement plan and participants. Plan set-up services are available at least semi-
annually, or more frequently if requested by a sponsor, Compass will perform a portfolio evaluation
to determine how well plan investments are performing. Compass Representatives also provide
general advice to plan participants regarding the nature of investments available in the plan and
regarding alternative investment strategies to select to attempt to achieve different investment
objectives.
Compass may enter into agreements with employers that provide qualified retirement plans (the
“Plan”) with various advisory services. Compass can provide the following services:
Investment Advice to the Employer at a Plan Level – annually, or more often if requested by the
client or deemed necessary by Compass, Compass will deliver a written report to the Plan which
includes:
1. Review of the Plan’s Investment Policy Statement, including assessing the following: (a) the
criteria for selecting money managers and the due diligence procedures that the Plan
followed in selecting its money managers and/or mutual funds; (b) the basis for asset mix
and rebalancing limits; (c) the performance measurement criteria; (d) monitoring procedures
of money managers and other investment-related venders; (e) composition and relevancy of
quarterly performance reports; (f) composition of custodial reports; and (g) termination
procedures for money managers.
2. Review of providers (custodians and recordkeeping) available to the Plan including: (a) the
capabilities of various providers; (b) the performance record of various providers; (c) the
scope of investment choices at various providers; and (d) the cost of various providers.
3. Review of the Plan’s overall investment activities for possible conflicts of interests or
prohibited transactions by the fiduciary, money managers, and/or consultants.
4. Review, if applicable, of the Plan’s socially responsible investment objectives.
Periodically as requested by the client, or deemed necessary by Compass, Compass will conduct a
fund/portfolio review (either alone or with the Plan’s investment policy committee) to include:
5. Portfolio design and asset allocation recommendations for at least five various investment
models designed with (a) varying time horizons, (b) risk tolerance, and (c) investment return
objectives;
6. The appropriateness of the managers/funds relative to the Plan’s asset allocation within each
model and relative to the criteria set forth in the Plans Investment Policy Statement;
7. Current performance of each of the managers/funds against their appropriate peer group and
relevant industry benchmark; and
8. Investment education for the participants of the Plan, including having a Representative
available semi-annually, (or more often if agreed upon by the client and Compass) in person
and daily by phone or email for the purpose of providing general investment education to
participants of the Plan. The education will be given based on information about the
participant given voluntarily by the participant to the Representative about (a) the
participant’s goals, (b) the participant’s investment time horizons, (c) the participant’s risk
tolerance and experience with investments, (d) the participant’s resources, and (e) the market
and investment opinions of Compass and the client’s Representative. Participants are required
to make the final investment decisions regarding the choice of investment, amount of
investment and timing of investment that fits their goals.
All advice provided by Compass and its Representatives is based upon the reliability of the data
provided to Compass by the Plan and the Plan participants.
Either the client or Compass may at any time request an audit of the Plan by an independent certified
public accountant, the fee for such audit will be paid by the party making the audit request.
Other Services
Managed Non-Discretionary Assets
In addition to providing investment management of client assets on a discretionary basis, Compass,
for a separate and additional fee, provides certain limited services to clients with respect to
“Managed Non-Discretionary Assets.” These services consist solely of the following:
Compass is available to consult with the client at the times Representatives select (or more often if
requested by the client) regarding the Managed Non-Discretionary Assets. However, the client is
solely responsible for all decisions and consequences on the client’s Managed Non-Discretionary
Assets, including decisions on whether to retain or sell all or a portion of the Managed Non-
Discretionary Assets. This responsibility remains solely with the client regardless of whether any
security is reflected on account reports prepared by the Adviser.
Compass is available to service Managed Non-Discretionary Assets, such as setting up and
monitoring regular distributions and special one-time distribution requests.
The Adviser can process any trades on the Managed Non-Discretionary Assets, but only when
requested to do so by the client. Upon receipt of any client’s written request, Compass will endeavor,
but cannot guarantee, that any such transaction will be effected on the day received or at any specific
time or price.
Limitations for Non-Discretionary Assets
Clients that engage the Adviser on a non-discretionary investment advisory basis must be willing to
accept that Compass 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, Compass will be unable to effect any account transactions (as it would for its
discretionary accounts) without first obtaining the client’s consent.
ERISA Disclosure for Retirement Planning
When Compass provides investment advice to you regarding your retirement plan account or
individual retirement account, Compass is 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. The way Compass makes money creates some conflicts with your
interests, so Compass operates under a special rule that requires Compass to act in your best interest
and not put our interest ahead of yours.