A. Firm Information
Lowery Thomas, LLC (“LT” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC) under the laws of
the State of California. LT was founded in January 1999, and is owned and operated by Mark Vicencio, President
and CCO as well as Kenneth Cala, Vice President and Director. This Disclosure Brochure provides information
regarding the qualifications, business practices, and the advisory services provided by LT.
B. Advisory Services Offered
LT offers investment advisory services to individuals, high net worth individuals, trusts, estates and corporations.
(each referred to as a “Client”).
The Advisor 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 potential
conflicts of interest. The Advisor’s fiduciary commitment is further described in the Advisor’s 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
Investment Management Services - LT provides customized investment advisory solutions for its Clients. This is
achieved through continuous personal Client contact and interaction while providing discretionary and non-
discretionary investment management and related advisory services. LT works closely with each Client to identify
their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio
strategy. LT will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or
exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual
stocks or bonds to meet the needs of its Clients. The Advisor may retain certain types of investments based on a
Client’s legacy investments based on portfolio fit and/or tax considerations.
LT’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. LT 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.
LT evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. LT may recommend, on occasion, redistributing investment allocations to diversify the portfolio. LT 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. LT 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.
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
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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.
At
no time will LT 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 the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Financial Planning Services - LT will typically provide a variety of financial planning and consulting services to
Clients, 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 involve
preparing a formal financial plan or rendering a specific 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:
PERSONAL: Family records, budgeting, personal liability, estate information and financial goals.
TAX & CASH FLOW: Income tax and spending analysis and planning for past, current and future years. LT will
illustrate the impact of various investments on a Client's current income tax and future tax liability.
DEATH & DISABILITY: Cash needs at death, income needs of surviving dependents, estate planning and
disability income analysis.
RETIREMENT: Analysis of current strategies and investment plans to help the Client achieve his or her
retirement goals.
INVESTMENTS: Analysis of investment alternatives and their effect on a Client's portfolio.
A financial plan developed for, or financial consultation rendered to 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.
LT may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation.
For certain financial planning engagements, the Advisor will provide a written summary of the 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 (6) months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning and consulting 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 with the Advisor, as it would
increase the 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.
C. Client Account Management
Prior to engaging LT to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and
the Client. These services may include:
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● Establishing an Investment Strategy – LT, in connection with the Client, will develop a strategy that seeks
to achieve the Client’s goals and objectives.
● Asset Allocation – LT will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
● Portfolio Construction – LT will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
● Investment Management and Supervision – LT will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
LT does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by LT.
E. Assets Under Management
As of December 31, 2023 , LT manages $289,243,707 in Client assets, $162,618,792 of which are
managed on a discretionary basis and $126,624,915 are managed on a non-discretionary basis. Clients may
request more current information at any time by contacting the Advisor.