The Advisory Group of San Francisco, LLC (“Advisory Group” or “Firm”) is an SEC-registered investment
adviser based in San Francisco, California. We are organized as a limited liability company under the
laws of the State of Delaware. We have been providing investment advisory services since 1999.
Gregory H. Patterson and Roger B. Patterson are our principal owners with more than 30 years of
collective industry experience.
As used in this brochure, the words "we", "our" and "us" refer to The Advisory Group of San Francisco,
LLC, and the words "you", "your" and "client" refer to you as either a client or prospective client of our
firm. Also, you may see the term Associated Person throughout this Brochure. As used in this Brochure,
our Associated Persons are our firm's officers, employees, and all individuals providing investment
advice on behalf of our firm.
We serve individuals and institutions with comprehensive financial advice through an experienced team
and leading national, institutional-quality resources. We are a fiduciary to all of our clients and accept
the responsibility of holding our firm and our Associated Persons to the highest legal standard of care.
We are a "fee-only" investment advisor. "Fee-only" means we are paid exclusively by our clients and
the amounts of all such compensation are fully disclosed to clients in writing. We do not sell products
and we do not receive commissions or other remuneration from any source.
We provide Investment Advisory Services primarily on a discretionary basis and, on occasion, for certain
institutional clients only, on a non-discretionary basis. We endeavor to recommend or select appropriate
investment vehicles for our clients. If you retain our services, all recommendations or selections are
made exclusively in your best interests, as we have no affiliation with any investment manager.
Investment vehicles generally consist of open-ended mutual funds, commingled funds, exchange-traded
funds (ETFs), separately managed accounts, and unified managed accounts.
Separately managed accounts are only available if you have an account size that meets the separate
account manager's minimum. Generally, the terms and conditions under which you may engage a
separate account manager(s) are set forth in a separate written agreement between you and the
designated separate account manager(s). If, however, you participate in the Callan Unified Managed
Account Program, discussed more fully below, you will not enter into a separate agreement with the
separate account manager. In both types or arrangements, we will continue to render investment
advisory services to you to monitor and review the separate account manager's performance, your asset
allocation and individual investment objectives.
If you enter the relationship with existing securities (e.g., individual stocks, bonds, annuity products,
closed-end funds) or with a unique situation which warrants different investment vehicles, we will make
recommendations accordingly. Factors that we consider in recommending or selecting investments
include your stated investment objectives and risk tolerance; investment manager's style, performance,
reputation, financial strength, reporting, pricing, and research; and taxes.
Selection of Other Advisers
We may recommend that you use the services of a third-party money manager ("TPMM") which includes
third party separate account managers, to manage all, or a portion of, your investment portfolio. After
gathering information about your financial situation and objectives, we may recommend that you engage
a specific TPMM or investment program. Factors that we take into consideration when making our
recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of
analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will
monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with
your investment goals and objectives.
The TPMM(s) will actively manage your portfolio and will assume discretionary investment authority over
your account. TPMM shall be authorized to buy, sell, and trade in securities in accordance with Client's
investment objectives as communicated by Advisor and to give instructions in furtherance of such trading
authority to the broker-dealer and the custodian. The fees payable to the TPMM are separate and
independent of our investment Advisory fees.
INVESTMENT ADVISORY SERVICES
We have formed important strategic relationships for the benefit of our clients. We are a select member
of the Callan Associates Inc. ("Callan") Independent Advisor Group ("IAG"). Callan is one of the largest
independent investment consulting firms in the country and provides research, education, decision
support and advice to a broad array of institutional investors. Through our membership in Callan's IAG,
we make these resources available to our clients that are normally not available to individual investors
or middle-market institutions. This membership gives us access to substantial Callan resources,
including:
• Capital Markets Projections related to Risk, Return and Correlations of Asset Classes;
• Asset simulation software;
• A research list based on objective and in-depth qualitative and quantitative due diligence of
investment management organizations and products (in the form of mutual fund and separate
account vehicles);
• Negotiated institutional custody services through multiple independent custodians;
• Performance measurement reports and software;
• Research related to numerous client needs.
The investment implementation of our Wealth Strategy Services is normally delivered in the form of a
comprehensive five-step investment consulting process:
• An analysis of your investment positioning as it relates to your stated investment objectives and
any fiduciary considerations.
• The design of an asset allocation strategy based on your time horizon, return expectations, risk
tolerance, asset class preferences, tax considerations and liquidity needs.
• The formalization of an investment program in a written investment policy statement.
• The implementation of your investment program.
• The ongoing monitoring of your investment program and the systematic reporting of performance
to you relative to the standards set forth in your investment policy statement.
INDIVIDUALS
We provide holistic Wealth Strategy Services to families and individuals as detailed below. These
services include discretionary Investment Advisory services that serve the needs of the taxable, tax-
deferred, and non-taxable portions of our Clients' portfolios.
Client Access to Exclusive Non-Retail Funds
Through our Investment Advisory Services, you will have access to certain investment benefits that may
not otherwise be available to a retail investor. Such benefits include:
• Access to institutional share classes (i.e., lower cost share classes) of certain fund families;
• Access to certain fund families whose substantial minimums would normally preclude retail client
investment; and
• Access to certain highly-regarded and generally low-cost fund families made available only to a
select group of registered investment advisors.
Discretionary Investment Advisory Services
We have authority to select the investments in your portfolio and make sub-asset class allocation
decisions. However, any such selection must be consistent with your designated portfolio allocation as
indicated in your Investment Policy Statement, as we do not have authorization to change the overall
equity/fixed income allocation of your portfolio without your prior written authorization. We periodically
rebalance your portfolio in accordance with your designated equity/fixed income allocation. We also
perform tax loss harvesting for taxable accounts in the Full-Service and Limited-Service level (described
below), as appropriate.
Custodian
We generally recommend that you maintain your investment account at Charles Schwab & Co.
("Schwab"). If you participate in our WealthStep Portfolio program or utilize the Callan UMA Program
(as described below), you must maintain custody at Schwab. Otherwise, you may direct us to use a
custodian other than Schwab. (We may charge additional fees for use of such other custodians, as
described below). You will enter into a separate custodial agreement with the designated custodian.
Fees charged by the broker-dealer/custodian are exclusive of, and in addition to, our ongoing investment
advisory fee as detailed below at the Fees and Compensation section.
Service Levels
We offer three service levels to individual clients on a discretionary basis:
Full-Service Wealth Strategy
Our Full-Service Wealth Strategy level is generally available to clients with managed assets over
$1,500,000 and/or significant complexity in their financial circumstances and is subject to a minimum
fee of $15,000 annually. This service includes ongoing wealth management and financial advice as well
as coordination of relevant financial issues. These issues may include financial independence planning,
retirement, analysis of insurance needs, estate review, charitable giving, education funding, and special
needs planning as detailed on the Wealth Strategy Services Agreement. In order to implement this
strategy, we provide ongoing discretionary investment management for those assets separately
designated in the Client's Investment Policy Statement. Our discretionary asset management is provided
on a household basis and includes tax-sensitivity in the location of investments within taxable vs. tax-
preferenced accounts and periodic rebalancing. Our full-service investment management includes
customized portfolios with diversification into numerous asset classes and styles. We generally
recommend the use of mutual funds and, in some cases, the use of separate account managers to
implement the portfolio. Although we generally recommend that our clients select Schwab as the
custodian of the managed assets, Full-Service clients may utilize other custodians, with some limitations,
and additional fees as detailed in our Wealth Strategy Services Agreement.
Limited-Service Wealth Strategy
Our Limited-Service Wealth Strategy level is generally available to clients with managed assets over
$750,000 and/or a level of complexity in their financial circumstances which warrants significant financial
analysis. Limited-Service Wealth Strategy level and is subject to a minimum fee of $10,000 annually. In
addition to discretionary investment management, integrated financial planning services are included in
the fee for Limited-Service Wealth Strategy for the first year of our engagement.
Thereafter, Client will receive updates to existing Financial Independence Planning only, as needed, not
more than one time annually within standard scope, at no additional cost. This includes Monte Carlo
scenario analysis of the probability of reaching goals given assumptions specific to client circumstances.
At client's request, advisor will provide additional financial planning services for a minimum project fee
of $5,000, which is payable upon services rendered.
Both our Full-Service and Limited-Service Wealth Strategy services include financial planning advice
relevant to our client's particular circumstances and advice on non-investment related matters. Such
advice may include, but is not limited to financial independence, retirement, estate, insurance, tax,
college savings, wealth transfer, real estate transactions and family business succession. For Full-
Service clients, this advice is included on an ongoing basis; for Limited-Service clients, it is provided
throughout the first year, with annual updates to the financial independence portion only.
Our advisors include Certified Financial Planners (CFP®). In performing our Wealth Strategy Services,
our CFP® professionals adhere to the CFP Board's disclosure requirements, including defining the goals,
needs and objectives of the client; gathering and providing appropriate data from and to the client;
analyzing current course of action in addition to recommended actions; defining the responsibilities of
implementation and monitoring.
Although our fees are calculated based on assets under management, due to the holistic nature of our
Wealth Strategy Services, the benefit and value to the Client is not related solely to the asset
management portion of our services, but to the integrated advice provided.
WealthStep Portfolio
The WealthStep
Portfolio program (previously known as the Personal Managed Portfolio program) is a
limited scope arrangement designed for clients with accounts of $100,000 or more. Clients may convert
to our Premier program at any time, subject to the applicable fees (see below section on Fees and
Compensation.) Clients utilizing the WealthStep Portfolios may choose from one of several standard
portfolios, all of which are managed on a discretionary basis, covering a spectrum of risk and return
characteristics. Clients have no ability to customize the portfolios and may change their portfolio
designation no more than once per year. Investments in the WealthStep Portfolios consist of both
actively and passively managed mutual funds and are rebalanced periodically. Assets must be held in
custody at Schwab and payment of our fee must be by way of deduction from the account. The
WealthStep Portfolio may be utilized for tax-deferred and/or taxable portfolios without householding.
Under this limited scope arrangement, Clients are solely responsible for reviewing the materials provided
by our firm and selecting a suitable WealthStep Portfolio given risk tolerances and time horizon. Our
services under this arrangement do not include personal consultations, analysis
of Client's current position or goals, consideration of Client's other accounts or outside assets, or any
other planning services. We provide this limited scope arrangement for a substantially reduced fee.
INSTITUTIONS
We provide fiduciary services for mid-sized institutions ($10 million to $300 million in investable assets),
including 401(k), profit sharing, defined benefit, and cash balance plans, as well as for foundations and
endowments. We make our services available to participant-directed plans with less than $10 million in
assets through our Select Plan program and to trustee-directed plans with less than $10 million in assets
on a discretionary basis only. We provide mid-sized organizations with a third-party, institutional-quality
approach that is normally only available to those with assets in excess of $500 million. For optimal results
and to eliminate conflicts of interest, we utilize a transparent, objective institutional-quality process, have
no in-house investment products or product ties, do not have soft- dollar arrangements, and we are only
paid by our Clients. At our Client's request, we may also provide Investment Advisory and Spending
Policy Analysis Services to foundations and endowments. Such services may require payment of a fee
separate from and in addition to our Investment Advisory Fees as discussed below at Fees and
Compensation.
Institutional accounts may be trustee-directed pools with a single allocation for each pool, or participant-
directed plans with participants selecting their own individual allocation and/or among several pre-mixed
diversified portfolios with differing equity/fixed income allocations. Trustee-directed pools include
endowments, foundations, pooled profit-sharing plans, defined benefit plans, cash balance plans, and
certain 401(k) plans that do not permit participant investment direction. Participant- directed plans are
generally 401(k) plans but may include profit sharing or other defined contribution plans. Both trustee-
directed pools and participant-directed plans may engage us on either a discretionary or non-
discretionary basis, and our services vary based upon this choice.
Discretionary Investment Advisory Services
For trustee-directed pools that engage our firm to provide services on a discretionary basis, we have
authority to select the investments in our Client's portfolio and make sub-asset class allocation decisions.
However, any such selection must be consistent with Client's designated equity/fixed income allocation,
as we do not change the overall equity/fixed income allocation of Client's portfolio without Client's prior
written authorization. Cash inflows/outflows are deployed in a manner consistent with Client's strategic
asset allocation. For participant-directed plans that engage our firm to provide services on a
discretionary basis, including those plans that are part of our Select Plan program, we have authority to
select the investments in the plan's investment menu and/or within the diversified portfolio investment
options offered within the plan. We also have authority to make sub-asset class allocation decisions
within pre-mixed diversified portfolios. The target equity/fixed income allocations of diversified portfolios
cannot be changed without Client's prior written authorization.
Non-discretionary Investment Advisory Services
For trustee-directed pools that engage us to provide services on a non-discretionary basis, we will
recommend an appropriate asset allocation, including sub-asset classes, and suitable investment
managers and vehicles. Client retains absolute discretion over all investment decisions and is free to
accept or reject any recommendation made by our firm. We generally maintain ongoing responsibility to
make recommendations based upon Client needs, as to the specific mutual funds, ETFs, separate
account managers, or other securities. If such recommendations are accepted by Client, we are
responsible for arranging or effecting the purchase or sale. Periodic rebalancing of the account occurs
only among Client approved designated investments for the purpose of reallocating the account in
accordance with Client approved percentage asset allocations. Cash inflows/outflows are deployed in a
manner consistent with Client's strategic asset allocation. For participant-directed plans that engage us
to provide services on a non-discretionary basis, we recommend the appropriate asset classes to include
in the investment menu. We also recommend the investment managers and the asset allocation,
including sub-asset class allocation, for each pre-mixed diversified portfolio. Rebalancing of pre-mixed
diversified portfolios within participant-directed plans is handled by the plan's third-party administrator.
Custodian
For trustee-directed pools, we generally recommend that investment accounts be maintained at
Schwab. For participant-directed plans, Client selects the preferred custodian based upon its
relationship with the plan's record keeper/third-party administrator. All Clients enter into a separate
custodial agreement with the designated custodian. Clients must also enter into a separate agreement
with the record keeper/third party administrator. Fees charged by record keeper/third party administrator
and/or broker-dealer/custodian are exclusive of, and in addition to, our ongoing Investment Advisory
Fee as detailed below at the Fees and Compensation section.
PLANNING AND OTHER FINANCIAL ADVICE
Planning and Other Financial Advice is included in the Full-Service and Limited-Service as detailed in
the Service Level descriptions. We generally only provide these services to clients to have engaged us
as part of these service levels.
ADVISORY SERVICES TO RETIREMENT PLANS AND PLAN PARTICIPANTS
As disclosed above, we offer various levels of advisory and consulting services to employee benefit
plans ("Plan") and to the participants of such plans ("Participants"). The services are designed to assist
plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee
Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department
of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the
authority to engage us as an investment adviser to the Plan) with a written statement of the services we
provide to the Plan, the compensation we receive for providing those services, and our status (which is
described below).
The services we provide to your Plan are described above, and in the service agreement that you have
previously signed. Our compensation for these services is described below, at Item 5, and also in the
service agreement. We do not reasonably expect to receive any other compensation, direct or indirect,
for the services we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our
fee from the plan or directs the plan recordkeeper to issue payment for our fee out of the plan. If we
receive any other compensation for such services, we will (i) offset the compensation against our stated
fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered for such
compensation and the payer of such compensation to you.
In providing services to the Plan and Participants, our status is that of an investment adviser registered
under the Investment Advisers Act of 1940, and we are not subject to any disqualifications under Section
411 of ERISA. In performing fiduciary services, we are acting as fiduciary of the Plan as defined in
Section 3(21) under ERISA.
TERMINATION INFORMATION
Either party may terminate the Investment Advisory Agreement at any time by one party giving the other
party thirty (30) days' written notice of such termination. You will incur a pro-rata charge for services
rendered prior to the termination of the agreement, which means you will incur advisory fees only in
proportion to the number of days in the quarter for which you are a client. If you have pre-paid advisory
fees that we have not yet earned, you will receive a prorated refund of those fees.
ACCURACY OF CLIENT INFORMATION AND ASSIGNMENT
In providing the contracted services, we are not required to verify any information we receive from you
or from your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to
rely on the information you provide. You must promptly notify our firm if your financial situation, goals,
objectives, or needs change for the purpose of reviewing, evaluating, and/or revising our previous
recommendations and/or services.
Neither party may assign the Investment Advisory Agreement without the consent of the other party.
You acknowledge and agree that transactions that do not result in a change of actual control of
management or our firm shall not be considered an assignment.
Types of Investments
We generally recommend style specific mutual funds, commingled funds, exchange traded funds,
money market funds, separate accounts, and/or a unified managed account for client portfolios.
Additionally, we may recommend other types of investments since each client has different needs and
different tolerances for risk. We may also advise you on any type of investment held in your portfolio at
the inception of our advisory relationship, or on specific types of investments at your request.
If you require an enhanced and/or specialized level of investment consulting services, we may
recommend that you authorize the active discretionary management of a portion of, or your entire,
investment portfolio by and/or among certain Separately Managed Accounts (SMA) consistent with your
stated investment objectives. SMA recommendations are not available to clients in the WealthStep
Portfolio program.
Alternatively, or in addition, we may recommend that you utilize the Callan Unified Managed Account
(UMA) Program. The Callan UMA Program is available to Full-Service and Institutional clients who may
benefit from this specialized investment program and who meet minimum asset requirements to
participate in the program. The Callan UMA Program allows investors to access separate account
portfolios and mutual fund investment strategies via the program's overlay advisor, NGAM Advisors,
("NGAM"), an SEC-registered investment adviser. We have entered into a written agreement with NGAM
in order to be able to provide this service to our clients, as appropriate. If you participate in the UMA
Program, you do so via our agreement with NGAM. Performance reporting for accounts in this program
is provided by Callan. Clients in the Callan UMA Program pay a separate fee to NGAM as set forth in
our written UMA Implementation Agreement, which you must sign prior to participating in the Callan
UMA Program. The NGAM fee is in addition to, and separate from, our Advisory Fee, and is inclusive of
the fee paid to Callan.
You may request that we refrain from investing in particular securities or certain types of securities. You
must provide these restrictions to our firm in writing on the Investment Policy Statement.
Assets Under Management
As of December 31, 2023, we manage a total of $ 831,383,036 and of this amount, we manage all client
assets on a discretionary basis and $0 in client assets on a non-discretionary basis.