Macke Financial Advisory Group, Inc. (the “Firm”) is a Florida corporation first incorporated in
1996. The Firm has been registered as an investment adviser with the United States Securities and
Exchange Commission since February 7, 2000. The Firm is solely owned by Todd Christopher
Macke, who is also the Firm’s President.
As discussed below, the Firm offers to its clients (generally: individuals, high net worth individuals,
related trusts and estates, pensions and profit-sharing plans) investment advisory services along
with financial planning and consulting services upon request.
Comprehensive Financial Planning; Consulting Services; Investment Management
The Firm may provide its clients with a broad range of comprehensive financial planning and
consulting services (including non-investment related matters). The Firm offers comprehensive
advisory services such as financial planning, investment advice, risk management, tax planning,
cash flow management, insurance evaluation, estate and generational planning and life planning.
The Firm maintains strategic partnerships with unaffiliated third parties that may be consulted
regarding, or used to supplement, goal setting, life planning and personal coaching services in the
financial planning process. In some cases, the Firm may offer concierge type services such as
general cash management support to those who request it based on their overall state of health.
The client, upon completion of the initial financial planning services, can subsequently engage the
Firm to provide both ongoing comprehensive financial planning and discretionary or non-
discretionary investment management on a fee-only basis. For ongoing comprehensive financial
planning, the Firm will conduct meetings typically on a quarterly basis, but tailor the frequency to
the needs of the client. Each meeting will have a focused area to review. For example, in the first
quarter, the Firm may review goals and cash flow/budgets, the second quarter may consist of risk
management, insurance and estate planning, the third quarter may consist of investments and long
range planning and the fourth quarter might focus on taxes and investments. There are some clients
that require quarterly meetings as a result of their holdings and special needs whereas others may
only require one meeting per year. Investment management consists of monitoring accounts and
making adjustments in client’s holdings based on various factors. These include, but are not limited
to, client risk profile and liquidity needs, market valuations, fundamental and technical factors,
geopolitical trends, monetary and fiscal policies of the U.S. government and other government
bodies, research provided by outside parties and other indicators that may be relevant for future
asset valuations and trends.
If the client engages the Firm on a fee-only basis, the Firm shall charge an annual fee for financial
planning and investment management services, which fee shall be based upon the percentage of
assets under management with the firm and billed quarterly in arrears based upon the market value
of the assets under management on the last business day of the previous quarter.
The scope of the ongoing financial planning and/or related consultation services to be rendered by
the Firm is intended to generally be limited to reviewing, evaluating, and revising the Firm’s
previous recommendations and/or services relative to a change in the client’s financial situation
and/or investment objectives.
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Before providing investment management services, the Firm ascertains, in conjunction with the
client, the client’s financial situation and investment objective(s). This is the Initial Comprehensive
Financial Plan. The Firm then prepares an initial investment model and implementation schedule
for client approval. Once the model is approved, the Firm will allocate the client’s investment assets
accordingly. The Firm primarily allocates client investment management assets among various
individual debt and equity securities (including exchange traded funds (“ETFs”)) and mutual fund
classes, on a discretionary basis, in accordance with the client’s designated investment objectives.
Once investment assets are allocated, the Firm provides ongoing monitoring and review of account
performance and asset allocation as compared to client investment objectives and may execute
account transactions based upon those reviews. Before engaging the Firm to provide investment
advisory services, clients are required to enter into an investment advisory agreement with us
setting forth the terms and conditions of the engagement (including termination), describing the
scope of the services to be provided, and the fee that is due from the client.
Pension Consulting Services
The Firm also offers pension consulting services to employee benefit plans based upon the needs
of the plan and the services requested by the plan sponsor or plan fiduciaries. The Firm’s services
in this regard may include review of plan features, review of investment selection and asset
allocation, participant education and consultation with respect to the plan’s features and investment
options, and services to assist the plan with employee communication and enrollment. The Firm
offers regular meetings for the plan fiduciary to discuss investment options, and annual and regular
employee education meetings throughout the year as requested by the plan client.
The Firm’s pension consulting services are for the benefit of the plan as a client. Plan participants
who have investment-related questions pertaining to the suitability of any specific plan investment
alternative for their individual investment objective(s) or financial situation are encouraged to
consult with the investment professional of their choosing. Accordingly, no plan participant should
assume that any general informational materials or educational sessions serve as the receipt of, or
as a substitute for, personalized investment advice from the Firm or its representatives.
Greater Gifts Family Office. The Firm offers a separate program, known as the Greater Gifts
Family Office (“GGFO”) that encompasses all of the foregoing investment advisory services, but
also includes access to various lifestyle, health and well-being products, services and/or programs
made available by unaffiliated third party providers. The GGFO program entails a holistic approach
to providing additional resources in the areas of physical, spiritual and mental health, along with
solutions for social and financial well-being. The GGFO platform of products and services is
designed to supplement our investment advisory offering, allowing for a more robust and complete
client engagement. The Firm covers the cost of GGFO services for investment management clients
and investment management clients are not charged any additional fees for access to, or
participation in, the GGFO program. Certain financial planning clients will be responsible for
GGFO program costs as described below at Item 5. GGFO program offerings will typically last for
a specific period of time, or until specific services have been provided. Clients who wish to continue
their engagement with programs initially offered in connection with GGFO participation may
pursue such services independently and at their own expense.
Miscellaneous Information about the Firm’s Services.
Client Obligations. In performing its services, the Firm shall not be required to verify any
information received from the client or from the client’s other professionals, and is expressly
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authorized to rely thereon. If requested by the client, the Firm may recommend the services of other
professionals for implementation purposes. 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 Firm. It
remains each client’s responsibility to promptly notify the Firm if there is ever any change in their
financial situation or investment objective(s) for the purpose of reviewing, evaluating, or revising
the Firm’s previous recommendations and/or services.
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. The
Firm shall generally provide financial planning and related consulting services regarding non-
investment related matters, such as estate planning, tax planning, insurance, etc. Subsequent to the
initial financial planning engagement, the Firm will generally provide such consulting services
inclusive of its advisory fee set forth at Item 5 below. Please Note. The Firm believes that it is
important for the client to address financial planning issues on an ongoing basis. The Firm’s
advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the
client determines to address financial planning issues with the Firm. The Firm does not serve as
an attorney, accountant or insurance agent, and no portion of our services should be construed as
legal, accounting or insurance implementation services. Accordingly, the Firm does not prepare
estate planning documents or tax returns, nor does it sell or offer insurance products. To the extent
requested by a client, the Firm may recommend the services of other professionals for certain non-
investment implementation purpose. 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 Firm and/or
its representatives. Neither the Firm nor its investment adviser representatives assist clients with
the implementation of any financial plan, unless they have agreed to do so in writing. If the client
engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such
engagement, the client agrees to seek recourse exclusively from and against the engaged
professional. If, and when, the Firm is involved in a specific matter (i.e. estate planning, insurance,
accounting-related engagement, etc.), it is the engaged licensed professionals (i.e. attorney,
accountant, insurance agent, etc.), and not the Firm, that is responsible for the quality and
competency of the services provided.
The preceding sentence shall not limit or waive any applicable rights under federal or state law,
including securities laws and fiduciary obligations that cannot be limited or waived.
Retirement Rollovers - Conflict of Interest. A client or prospective client leaving an employer has
four options regarding an existing retirement plan (and may 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 the Firm recommends that a client roll
over their retirement plan assets into an account to be managed by the Firm, the recommendation
creates a conflict of interest if the Firm will earn a new (or increase its current) compensation as a
result of the rollover. If the Firm provides a recommendation as to whether a client should engage
in a rollover or not (whether it is from an employer’s plan or an existing IRA), the Firm 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. No client
is under any obligation to rollover retirement plan assets to an account managed by the Firm,
whether it is from an employer’s plan or an existing IRA. The Firm’s Chief Compliance Officer
remains available to address any questions that a client or prospective client may have regarding
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the potential for conflict of interest presented by such rollover recommendation.
Variable Annuity Management. In the event that the client owns a variable annuity product, the
client can engage the Firm to provide investment management services relative to the investment
subdivisions that comprise the variable annuity product. The Firm’s investment selection shall be
limited to those provided by the variable annuity sponsor. If so engaged, the Firm shall charge an
ongoing advisory fee based upon the market value of the assets per its fee schedule at Item 5 below.
Please Note: Neither the Firm, nor any of its employees, offers to sell variable annuity products to
its clients. Neither Firm, nor any of its employees, are registered as, or associated with, a broker-
dealer or an insurance agency. In the event that the client owns a variable annuity product and/or
seeks to purchase a variable annuity product, the Firm shall refer the client to an unaffiliated broker-
dealer/insurance agency to advise on same, and if agreed upon by the client, engage the unaffiliated
broker-dealer/insurance agency to exchange a current, or purchase a new, variable annuity product.
Neither the Firm, nor any of its employees, shall receive any portion of the fees earned by the
unaffiliated broker-dealer/insurance agency. The Firm’s only compensation shall be limited to the
management of the investment subdivisions that comprise the variable annuity product, should the
client engage the Firm to do so. The client is under no obligation to engage the Firm to provide
such management services, nor is the client under any obligation to consider addressing variable
annuity issues with the unaffiliated broker-dealer/insurance agency that may be recommended by
the Firm. Please Also Note: Because the Firm could earn an advisory fee on the variable annuity
assets, a potential conflict of interest arises in the event that the Firm recommends that the client
should address variable annuity issues with the unaffiliated broker-dealer/insurance agency. Please
Further Note: Variable annuities are long-term investment products. Variable annuity product
sponsors generally impose financial penalties for early withdrawals as set forth in the variable
annuity documents. Thus, the client must consider such potential penalties prior to agreeing to
exchange or purchase a variable annuity product.
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, the Firm shall generally purchase a higher yielding money
market fund available on the custodian’s platform with cash proceeds or deposits, unless the Firm
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 the Firm’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 the Firm’s unmanaged accounts
Cybersecurity Risk. The information technology systems and networks that the Firm and its third-
party service providers use to provide services to the Firm’s clients employ various controls, which
are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions
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that could cause significant interruptions in the Firm’s operations and result in the unauthorized
acquisition or use of clients’ confidential or non-public personal information. Clients and the Firm
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 the Firm 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 the Firm 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 meet 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 the Firm), there
can be no assurance that investment in ESG securities or funds will be profitable, or prove
successful. The Firm does not maintain or advocate an ESG investment strategy, but will seek to
employ ESG if directed by a client to do so. If implemented, the Firm shall rely upon the
assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account
portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a
socially responsible mandate.
Independent Managers. The Firm may allocate (and/or recommend that the client allocate) a portion
of a client’s investment assets among unaffiliated independent investment managers (“Independent
Manager(s)”) in accordance with the client’s designated investment objective(s). In such situations,
the Independent Manager(s) will have day-to- day responsibility for the active discretionary
management of the allocated assets. The Firm will continue to render investment supervisory
services to the client relative to the ongoing monitoring and review of account performance, asset
allocation and client investment objectives. The Firm generally considers the following factors
when recommending Independent Manager(s): the client’s designated investment objective(s),
management style, performance, reputation, financial strength, reporting, pricing, and research.
The investment management fees charged by the designated Independent Manager(s) are exclusive
of, and in addition to, The Firm’s ongoing investment advisory fee, which will be disclosed to the
client before entering into the Independent Manager engagement and/or subject to the terms and
conditions of a separate agreement between the client and the Independent Manager(s).
Fee Dispersion. The Firm, in its discretion, may charge a lesser investment advisory fee, charge a
flat fee, waive its fee entirely, or charge fee on a different interval, based upon certain criteria (i.e.
anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to
be managed, related accounts, account composition, complexity of the engagement, anticipated
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services to be rendered, grandfathered fee schedules, employees and family members, courtesy
accounts, competition, negotiations with client, etc.). Please Note: As result of the above, similarly
situated clients could pay different fees. In addition, similar advisory services may be available
from other investment advisers for similar or lower fees. ANY QUESTIONS: The Firm’s Chief
Compliance Officer, Kevin P. Jordan, remains available to address any questions that a client or
prospective client may have regarding advisory fees.
Please Note: Cash Positions. The Firm continues to treat cash as an asset class. As such, unless
determined to the contrary by the Firm, all cash positions (money markets, etc.) shall continue to
be included as part of assets under management for purposes of calculating the Firm’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), the Firm may maintain 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, the Firm’s advisory fee could exceed the interest paid by the client’s money
market fund. ANY QUESTIONS: The Firm’s Chief Compliance Officer, Kevin Jordan,
remains available to address any questions that a client or prospective may have regarding
the above fee billing practice.
Trustee Directed Plans. The Firm may be engaged to provide discretionary investment advisory
services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the
investment objective designated by the Plan trustees. In such engagements, the Firm will serve as
an investment fiduciary as that term is defined under The Employee Retirement Income Security
Act of 1974 (“ERISA”). The Firm 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.
Unaffiliated Private Investment Funds. The Firm may recommend that certain qualified clients
consider an investment in unaffiliated private investment funds. The Firm’s role relative to the
private investment funds shall be limited to its initial and ongoing due diligence and investment
monitoring services. If a client determines to become a private fund investor, the amount of assets
invested in the fund(s) shall be included as part of “assets under management” for purposes of the
Firm determining its investment advisory fee per Item 5 below. The Firm’s clients are under
absolutely no obligation to consider or make an investment in a private investment fund(s). Private
investment funds generally involve various risk factors, including, but not limited to, potential for
complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of
which is set forth in each fund’s offering documents, which will be provided to each client for
review and consideration. Unlike liquid investments that a client may own, private investment
funds do not provide daily liquidity or pricing. Each prospective client investor will be required to
complete a Subscription Agreement, pursuant to which the client shall establish that he/she is
qualified to invest in the fund, and acknowledges and accepts the various risk factors that are
associated with such an investment. If the Firm bills an investment advisory fee based upon the
value of private investment funds or otherwise references private investment funds owned by the
client on any supplemental account reports prepared the Firm, the value for all private investment
funds owned by the client will reflect the most recent valuation provided by the fund sponsor.
However, if subsequent to purchase, the fund has not provided an updated valuation, the valuation
shall reflect the initial purchase price. If subsequent to purchase, the fund provides an updated
valuation, then the statement will reflect that updated value. The updated value will continue to be
reflected on the report until the fund provides a further updated value. The current value of any
private investment fund could be significantly more or less than the original purchase price or the
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price reflected in any supplemental account report. Unless otherwise indicated, Firm shall calculate
its fee based upon the latest value provided by the fund sponsor.
Availability of Mutual Funds and Exchange Traded Funds. While the Firm may allocate investment
assets to mutual funds and exchange traded funds (“ETFs”) that are not available directly to the
public, the Firm may also allocate investment assets to publicly-available mutual funds and ETFs
that the client could purchase without engaging the Firm as an investment adviser. However, if a
client or prospective client determines to purchase publicly-available mutual funds or ETFs without
engaging the Firm as an investment adviser, the client or prospective client would not receive the
benefit of the Firm’s initial and ongoing investment advisory services with respect to management
of the asset.
Portfolio Activity. The Firm has a fiduciary duty to provide services consistent with the client’s
best interest. As part of its investment advisory services, the Firm 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 may be
extended periods of time when the Firm determines that changes to a client’s portfolio are neither
necessary nor prudent. Of course, as indicated below, there can be no assurance that investment
decisions made by the Firm will be profitable or equal any specific performance level(s). Clients
nonetheless remain subject to the fees described in Item 5 below during periods of account
inactivity.
Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to
recommend a broker-dealer/custodian for client accounts, the Firm generally recommends that
Charles Schwab Co., Inc., and its affiliates (“Schwab”), serve 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 type fees (as well as the amount of those fees) shall differ depending upon the broker-
dealer/custodian (while certain custodians, including Schwab, do not currently charge fees on
individual equity transactions, others do). Please Note: there can be no assurance that Schwab will
not change its transaction fee pricing in the future. Please Also Note: Schwab may also assess fees
to clients who elect to receive trade confirmations and account statements by regular mail rather
than electronically. These fees/charges are in addition to the Firm’s investment advisory fee at Item
5 below. The Firm does not receive any portion of these fees/charges. ANY QUESTIONS: The
Firm’s Chief Compliance Officer, Kevin P. Jordan, remains available to address any
questions that a client or prospective client may have regarding the above.
Margin / Securities Based Loans. Upon client request, the Firm may recommend that a client
establish a margin loan or a securities based loan (collectively, “SBLs”) with the client’s broker-
dealer/custodian or their affiliated banks (each, an “SBL Lender”) to access cash flow. For example,
clients may seek to borrow money on margin to pay bills or other expenses such as financing the
purchase, construction, or maintenance of a real estate project. Unlike a traditional real estate-
backed loan, an SBL has the potential benefit of: enabling borrowers to access to funds in a shorter
period of time, providing greater repayment flexibility, and may also result in the borrower
receiving certain tax benefits. Clients interested in learning more about the potential tax benefits of
borrowing money on margin should consult with an accountant or tax advisor. The terms and
conditions of each SBL are contained in a separate agreement between the client and the SBL
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Lender selected by the client, which terms and conditions may vary from client to client. Borrowing
funds on margin is not suitable for all clients and is subject to certain risks, including but not limited
to: increased market risk, increased risk of loss, especially in the event of a significant downturn;
liquidity risk; the potential obligation to post collateral or repay the SBL if the SBL Lender
determines that the value of collateralized securities is no longer sufficient to support the value of
the SBL; the risk that the SBL Lender may liquidate the client’s securities to satisfy its demand for
additional collateral or repayment / the risk that the SBL Lender may terminate the SBL at any
time. Before agreeing to participate in an SBL program, clients should carefully review the
applicable SBL agreement and all risk disclosures provided by the SBL Lender including the initial
margin and maintenance requirements for the specific program in which the client enrolls, and the
procedures for issuing “margin calls” and liquidating securities and other assets in the client’s
accounts. If the Firm recommends that a client apply for an SBL instead of selling securities that
the Firm manages for a fee to meet liquidity needs, the recommendation presents an ongoing
conflict of interest because selling those securities (instead of leveraging those securities to access
an SBL) would reduce the amount of assets to which the Firm’s investment advisory fee percentage
is applied, and thereby reduce the amount of investment advisory fees collected by the Firm.
Likewise, the same ongoing conflict of interest is present if a client determines to apply for an SBL
on their own initiative. These ongoing conflicts of interest would persist as long as the Firm has an
economic disincentive to recommend that the client terminate the use of SBLs. Clients are therefore
reminded that they are not under any obligation to employ the use of SBLs, and are solely
responsible for determining when to use, reduce, and terminate the use of SBLs. Although the Firm
seeks to disclose all conflicts of interest related to its recommended use of SBLs and related
business practices, there may be other conflicts of interest that are not identified above. Clients are
therefore reminded to carefully review the applicable SBL agreement and all risk disclosures
provided by the SBL Lender as applicable, and contact the Firm’s Chief Compliance Officer with
any questions regarding the use of SBLs.
Third Party Reporting Services. The Firm may provide access to reporting services that can reflect
all of the client’s investment assets, including those investment assets that are not part of the assets
managed by the Firm (the “Excluded Assets”). The Firm’s service relative to the Excluded Assets
is limited to reporting service access only, which does not include investment implementation.
Because the Firm does not have trading authority for the Excluded Assets, the client (and/or another
investment professional), and not the Firm, shall be exclusively responsible for directly
implementing any recommendations relative to the Excluded Assets. Further, the client and/or their
other advisors that maintain trading authority, and not the Firm, shall be exclusively responsible
for the investment performance or related activity (such as timing and trade errors) pertaining to
the Excluded Assets. The third-party reporting platform may also provide access to financial
planning information and applications, which should not be construed as services, advice, or
recommendations provided by the Firm. Accordingly, the Firm shall not be held responsible for
any adverse results a client may experience if the client engages in financial planning or other
functions available on the third party reporting platform without the Firm’s participation or
oversight. Unless also agreed to otherwise, in writing, The Firm does not provide investment
management, monitoring or implementation services for the Excluded Assets. The client can
engage the Firm to provide investment management services for the Excluded Assets pursuant to
the terms and conditions of the Investment Advisory Agreement between the Firm and the client.
Investment Risk. Different types of investments involve varying degrees of risk, and it should not
be assumed that future performance of any specific investment or investment strategy (including
the investments and/or investment strategies recommended or undertaken by the Firm) will be
profitable or equal any specific performance level(s).
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Disclosure Brochure. A copy of this Form ADV Part 2A, our Form CRS Relationship Summary
and Form ADV Part 2B will be provided to each client prior to or contemporaneously with the
execution of the Firm’s financial planning agreement, investment advisory agreement or other
services agreement.
The Firm shall provide investment advisory services tailored specifically to the needs of each client.
Prior to providing investment advisory services, an investment adviser representative will ascertain
each client’s investment objectives. Thereafter, the Firm shall allocate and/or recommend that the
client allocate investment assets consistent with the designated investment objectives. The client
may, at any time, impose reasonable restrictions, in writing, on the Firm’s services.
The Firm does not participate in a wrap fee program.
As of December 31, 2023, the Firm had approximately $146,867,525 in client assets under
management on a discretionary basis.