A. Description of Advisory Firm
Symmetry® Partners, LLC (“Symmetry”) is an investment adviser registered with the
Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940
(the “Advisers Act”). The firm is located in Glastonbury, Connecticut and was established in
1994. The firm was founded by and is currently owned and operated under the control of
David E. Connelly, Jr. and Patrick A. Sweeny.
As of December 31, 2023, Symmetry had approximately $7.9 billion in assets under
management and advisement. Assets under advisement are those for which Symmetry acts
as a sub-advisor.
B. Types of Advisory Services
Symmetry Partners’ methods of analysis and investment strategies are based on academic
research into optimal investing, with an emphasis on Modern Portfolio Theory (MPT) and
Quantitative Methods of Analysis that extend from MPT. Symmetry’s analysis methods may
include: use of MPT metrics such as return, standard deviation, and Sharpe Ratio, etc.
Please see definitions of these terms in item 8 of the brochure. Symmetry’s investment
strategies consist of equity, fixed income, and alternative components (or one or the other)
and are comprised of open-end mutual funds, exchange traded funds, and sub-advised
accounts.
Symmetry currently creates portfolios utilizing open-end mutual funds and exchange traded
funds. These portfolios are called Symmetry Panoramic Portfolios, PrecisionCore ETF
Portfolios and PrecisionCore Factor ETF Components, Symmetry Bond Portfolios, AltAxis
Portfolio, Symmetry ESG, Symmetry Socially Responsible, and Symmetry Axiom Sector
Momentum. As part of the Symmetry Retirement program, Symmetry offers the Structured
Portfolios, a target date version of the Structured Portfolios called the Evolution Portfolios.
Symmetry also creates customized individual security portfolio solutions under the Axiom
program, designed to give clients exposures similar to several diversified indices, as well as
offering specific factor emphasis. In addition, Symmetry may collaborate with unaffiliated
Registered Investment Advisors (“RIA”), to create a customized suite of portfolios for mutual
clients. Symmetry selects funds suitable and consistent with the firm’s investment
philosophy. Symmetry is not obligated to use any specific security in the creation of the
portfolios, as Symmetry is not affiliated with the sponsor or adviser of any fund or security,
except for the Symmetry Panoramic Models (previously known as Structured Panoramic).
Symmetry does not exclusively recommend portfolios. As part of the Symmetry Retirement
program, Symmetry will recommend a menu of individual mutual funds, known as
IndexElect, to plan sponsors who wish to have a selection of individual funds for the plan’s
participants. Through the Symmetry Retirement program, Symmetry manages assets for
qualified plans such as, but not limited to, 401(k), money purchase, profit sharing, defined
benefit plans and institutional pension plans. As a part of the Axiom program, Symmetry may
provide consultative advice on combinations of Symmetry portfolio offerings for advisors to
consider for a mutual client. Periodically, vetted ETFs or mutual funds may be included in
Axiom recommendation outside of a portfolio sleeve.
Symmetry provides advisory services acting as a strategist/sub-advisor/model manager
to/on various technology, broker-dealer, custodian, and RIA management platforms.
Symmetry offers these portfolios, programs and investment advisory services to clients who
are referred to Symmetry’s services through investment adviser and registered
representatives of unaffiliated independent Broker-Dealers and Registered Investment
Advisers, (labeled “BD/RIA” or “BD/RIAs’’ for this document’s purpose). Symmetry also
provides these services to a limited number of legacy clients obtained directly through its
own investment adviser representatives (“IARs”). Legacy Clients obtained through
Symmetry’s IARs efforts may access financial planning as part of the services provided by
Symmetry.
Symmetry also provides investment advice and due diligence services through its OCIO
(Outsourced Chief Investment Officer) program. OCIO services are contracted on a case-
by-case basis. In most cases, the unaffiliated RIA will pay for these services directly from
the revenue generated from their existing service. In some cases, OCIO relationships may
contract to invest in Symmetry offerings that will incur a basis point charge to the client.
Symmetry also provides investment advisory services to the Symmetry Panoramic Funds
(each a Fund and collectively the “Funds”) which are registered with the SEC under the 1940
Act, (“40 Act’) and the Securities Act of 1933.
Symmetry Panoramic Mutual Funds
Symmetry provides investment advisory services to the Symmetry Panoramic Funds. The
Funds are a series of the Symmetry Panoramic Trust, a Delaware statutory trust (the “Trust).
The Trust is registered as open–end management investment company under the
40 Act, as amended. The presentation of information in this brochure relating to the
Symmetry Panoramic Funds is not intended as an offer or solicitation to invest. Additional
information about the Symmetry Panoramic Funds is available in the Funds’ prospectus and
Statement of Additional Information, (“SAI”), which are available on the Funds’ website,
(www.panoramicfunds.com), or on the SEC’s EDGAR database.
Symmetry Panoramic Models
The Symmetry Panoramic Funds will be used as holdings in the Symmetry Panoramic and
Panoramic + Alts Models. The Panoramic Models will be comprised entirely of Symmetry
Panoramic Funds. Different Panoramic Models may hold different Panoramic Funds at
different weights. Symmetry will maintain other versions of the Structured models that invest
directly in Underlying Funds, in instances where adopting the Panoramic Fund version is
impracticable or undesirable. It should be noted that the Symmetry Panoramic Models will
not be immediately available through all distribution channels. A model comprised of the
Symmetry Panoramic Funds will be labeled Symmetry Panoramic Models.
Symmetry PrecisionFactor ETF Portfolios
The Symmetry PrecisionCore ETF Portfolios are a suite of asset allocation model portfolios
comprised exclusively of ETFs, from unaffiliated fund providers. The PrecisionCore ETF
portfolios, tax-managed and non- tax-managed, are comprised of an equity and fixed income
allocation and vary both in their allocation between equity and fixed income and the relative
risk profile of the fixed income positions. As the risk rating of the models increases, the fixed
income assumes a higher risk posture. The equity portion of each PrecisionCore ETF
Portfolio provides exposure across global equity asset classes to provide a high level of
diversification. Symmetry periodically updates the model allocation to keep it in line with the
current relative capitalization of US, international, developed and emerging markets. Clients
are rebalanced periodically to maintain their desired equity to fixed income allocation and
put all positions back to or near the current target for their model portfolio. Symmetry also
offers component models including US PrecisionEquity, International PrecisionEquity,
PrecisionCore Bond, and PrecisionCore Tax-Managed Bond, which allow advisors to
combine different geographic exposures to their clients specific needs.
Symmetry Bond
The Symmetry Bond Portfolios are two standalone fixed income asset allocation portfolios,
one tax- managed, one non-tax-managed. The Symmetry Bond Portfolios are currently
comprised of open-end mutual funds from DFA and Vanguard. Each of the Symmetry Bond
Portfolios are designed as a standalone fixed income product that takes some fixed income
risks. The tax-managed version of the Symmetry Bond Portfolio features an allocation to
national, short-term, high-quality municipal bonds in addition to other holdings. The non-tax-
managed version holds a short-term bond fund in addition to other holdings. Each of the two
versions of Symmetry Bond Portfolios include an allocation to Treasury Inflation-Protected
Securities (TIPS), in order to provide partial protection of purchasing power.
Symmetry AltAxis
The AltAxis Portfolio is a portfolio of several mutual funds, currently comprised of funds from
AQR Capital Management (“AQR”), designed to diversify traditional equity and fixed income
holdings. The portfolio's underlying funds attempt to access a wide array of alternative
premiums captured by long- short investment strategies across multiple asset classes. The
portfolio is not designed to be 100% of a client's investable assets, in aggregate. Typical
investors in this portfolio are seeking a strategy that diversifies traditional equity and fixed
income portfolios. Alternative strategies have unique risks that may not be reflected in
standard deviation alone. In addition, the funds in this model may make extensive use of
derivatives in order to achieve very specific exposures and apply leverage to the strategy.
Symmetry ESG
The Environmental, Social and Governance (ESG) Portfolios are designed for clients looking
to align their investment portfolios with their values, are seeking a low-cost, tax efficient
portfolio, and are seeking a balanced strategy that can be aligned with a client’s risk
objectives. The ESG portfolios provide a combination of exclusionary screens and best-in-
class optimizations that together achieve a greater focus on industries and companies
deemed more consistent with ESG goals. Generally speaking:
• Environmental considers how companies perform as a steward of nature.
• Social criteria looks at how companies manage relationships with employees,
suppliers, customers, and the communities where they operate.
• Governance considers companies’ leadership, executive pay, audits, internal
controls, and shareholder rights.
Symmetry Socially Responsible
The Symmetry Socially Responsible Portfolios also seek to allow clients to align their
investment portfolios with their values, are seeking a low-cost, tax efficient portfolio, and are
seeking a balanced strategy that can be aligned with a client’s risk objectives. This suite of
portfolios seeks to reduce exposure to companies that do not align with certain social
screens such as production of nuclear weapons, land mines, tobacco, alcohol, cannabis,
and contraceptives, as well as revenue generation from gambling and pornography.
Axiom
Symmetry’s Axiom services includes two distinct separately managed account (SMA)
options. The Investable Index Series targets popular equity indexes, while the Factor
Strategies are designed to capture strategies comprised of individual stocks and ADRs.
Your Financial Advisor may utilize either of these Models to serve several construction
objectives inside your portfolios. Your Financial Advisor may wish to use these Models as a
core module inside of a larger core/satellite portfolio. These Models may also be suitable as
a starting point to express your preferences for sector or security level customizations that
could otherwise not be expressed through a pooled vehicle such as an ETF or Mutual Fund.
Finally, these Models may be utilized as a tax-aware module within your portfolio where
specific tax lots of individual securities may be loss- harvested (see Tax Overlay
Management Services) while at the same time demonstrating index- like tracking
characteristics. While the Models themselves are not managed in a tax sensitive fashion,
the structure does help facilitate more effective tax management from the dispersion among
a sample of the constituent securities of an index as well as the potential for various tax lots
for these securities.
• Investable Index Series
Our Investable Index Series was designed to provide your Financial Advisor with Model
options that behave in a manner similar to a broad-market index while, at the same time,
allowing for customization and active overlay management techniques through individual
security ownership.
• Factor Strategies
Our Factor Strategies are comprised of diversified investment solutions that include
individual stocks and ADRs. These portfolios are constructed based on quantitative
rules-based methods that seek to capture specific factor premiums, such as Value,
Momentum and Profitability, and will rebalance on a regular basis to maintain intended
diversification and factor exposures. Portfolios of individual securities may be the
appropriate solution for clients with tastes and preferences or needs that are better met
by these portfolios. The current multi-factor offering includes strategies that cover the
United States, International, and Global geographies and can include factors such as
Value, Momentum, and Profitability (or Quality). Individual factor strategies are available
in the United States market targeting individual factor strategies such as Value,
Momentum, Yield, and Defensive.
• Axiom Sector Momentum
The Axiom Sector Momentum Portfolio is constructed from ETFs and seeks to provide
exposure to the sectors of the S&P 500 that most recently performed well based on 6
and 12 month momentum signals.
• Custom Model Strategy
The BD/RIA’s investment adviser or registered representatives may also suggest a
Custom Model Strategy portfolio to the clients. A custom allocation combines various
Symmetry portfolios, to create a new portfolio. Symmetry representatives may provide
consultation regarding how to combine its strategies. The combining of the portfolios will
create a new asset allocation, using all the funds that were in the underlying portfolios
used to create the new portfolio. There are no funds added or removed from the target
allocation in the custom portfolio. Please note the Symmetry Evolution Portfolios cannot
be used in the Custom Model Strategy program. The Custom Model Strategy may not
be available at all custodians. Please note with Axiom there are minimum investment
levels.
• Tax Overlay Management Services
If selected by your Financial Advisor, Symmetry can provide Tax Overlay Management
services to your AXIOM account. In providing Tax Overlay Management services, we
consider the tax consequences of transactions in your account and will adjust our AXIOM
services accordingly. We attempt to accomplish tax-aware investment management
through gain-loss matching, harvesting losses and/ or gains, deferring gains until
securities reach preferential tax status, and avoiding imprudent wash sale transactions
to improve the after-tax return while staying as
consistent as possible with the risk/return
characteristics of your account’s Strategy.
Our ability to improve your after-tax return depends on various factors beyond our control
including economic and market conditions, regulatory changes, actions taken by your
custodian broker-dealer, the specifics of your account’s strategy, the starting portfolio in
your account, your tax circumstances and mandates as communicated by your Financial
Advisor. Tax Overlay Management may cause the actual performance in your account
to vary from the "stated" performance of the Strategy’s Manager. Tax Overlay
Management services are provided solely in connection AXIOM services provided to
your account. We do not provide general tax planning advice or services. To provide Tax
Overlay Management services, we rely solely on the information provided by your
Financial Advisor and your custodian broker-dealer. If that information is inaccurate,
incomplete or not timely, our ability to provide Tax Overlay Management may be
adversely affected. We make no guaranty that taxes in your account will be reduced. If
an account contains mutual funds and/or exchange traded funds (“ETFs”), our Tax
Overlay Management services are generally applied on the portion of your account
containing equity securities and not to the portion that consists predominantly of mutual
funds and/or ETFs.
We generally accept tax gain and loss harvesting requests from Financial Advisors for
accounts receiving Tax Overlay Management services, subject to certain limitations,
such as amount, timing and the potential effect on transactions in the accounts. The
details of gain and loss harvesting are agreed to between us and your Financial Advisor.
You should contact your Financial Advisor for specific information.
For clients with pooled investment vehicles, such as mutual fund holdings, acquired prior
to 2012, we will rely on cost basis information provided by the Adviser and/or client as
the basis for our tax analysis. We will make best efforts to realize capital gains within
parameters set by the Adviser and/or client. Noting, however, that due to incomplete or
uncertain cost basis information for pooled investment holdings acquired prior to 2012,
there is no assurance that Symmetry tax overlay or tax loss harvesting programs will be
able to limit capital gains exposure within agreed upon parameters.
By default, accounts are managed without Tax Overlay Management Services unless
specifically elected by your Financial Advisor.
• Referral to Third-Party Products
As part of the Axiom program, Symmetry provides access to third-party investment
solutions in spaces where it does not have a proprietary solution at this time. In some
cases, Symmetry offers Models that wrap third-party solutions with a completion portfolio
to arrive at a fully asset-allocated solution. Third-party solutions may be fully
administered by the third-party provider or managed by Symmetry. Symmetry often
receives a referral fee on third-party solutions.
Symmetry Structured Portfolios
Available through Symmetry’s Retirement Program, the Symmetry Structured Portfolios are
a suite of non-tax-managed and tax-managed asset allocation portfolios comprised of open-
end mutual funds and exchange traded funds. The Symmetry Structured Portfolios are
comprised of an equity and fixed income allocation, which are designed to be systematic,
broadly diversified, low cost and tax efficient.
The equity portion of each Symmetry Structured Portfolio provides exposure across global
equity asset classes to provide a high level of diversification, including allocations to the
United States, international developed markets and emerging markets. Symmetry updates
the allocations from time to time based on strategic long-term considerations. Clients are
rebalanced periodically to maintain their desired equity to fixed income allocation and put
the allocation back to or near the current target for their portfolio.
The goal of each portfolio’s fixed income position is to mitigate the risk taken in the equity
positions, while prudently capturing market-based fixed income returns. Therefore, the bond
positions vary across model allocations.
Symmetry Evolution Portfolio
Offered only within the Symmetry Retirement program, the Evolution Portfolios are target
date versions of the Structured Portfolios that feature an automatic rebalance of the equity
to fixed allocation in the client’s account. Starting out as a 100/0 non-tax-managed Structured
Portfolio, the Evolution Models will ratchet down the equity allocation in five-year increments
until reaching the final stage, at which the model features a 30/70 equity to fixed income mix.
The Evolution Portfolios are designed to accommodate clients as they age, and/or get closer
to withdrawing their assets and, therefore, wish to gradually reduce their equity risk exposure
over time.
IndexElect
IndexElect is a list of asset class funds recommended by Symmetry Partners as suitable
complements to Symmetry Structured Portfolios. The list of funds has been compiled to
provide sponsors of qualified plans with access to broad asset classes; in some cases, they
represent asset classes that are either not available or are underweighted within the
Symmetry Structured Portfolios.
Collaborations with Unaffiliated Registered Investment Advisers
Symmetry may collaborate with unaffiliated RIAs to offer a customized suite of portfolios to
mutual clients. The RIAs that Symmetry may choose to collaborate with are subject to highly
selective criteria. Symmetry utilizes its standard due diligence process, analysis, and
investment principles to select the mutual funds and ETFs used in creating these portfolios.
Please note, as this is a collaborative effort, Symmetry may need to work within additional
constraints and objectives imposed or recommended by the RIA. The unaffiliated RIA’s
services include, but are not limited to, establishing prospective client or client suitability,
periodic contacts with clients, answering client inquiries, meeting with or contacting the client
at least annually to ascertain if there is a change in the client's financial situation, updating
client information, and monitoring client accounts. Symmetry's services include, but are not
limited to, teaming with RIA on portfolio construction, research, trading, back office
operations, account maintenance, and assisting IARs in servicing the clients.
Investment Advisory Services
As noted above, Symmetry provides investment advisory services to clients who are brought
to Symmetry through investment adviser and registered representatives of the BD/RIAs. The
BD/RIAs will either act in a promotor or co-advisor capacity depending on the agreement the
BD/RIA has in place with Symmetry. For additional information about the promotor
relationship please see item 14 of this brochure.
Generally, the BD/RIA representatives introduce and assist the client in establishing a
relationship with Symmetry Partners. The services include periodic contacts, answering
client inquires, updating client information, meeting with or contacting the client at least
annually to determine if there is a change in the client’s financial situation, and assisting the
prospective client in understanding the services provided by Symmetry. Symmetry’s internal
and external wholesalers assist the BD/RIA representatives with these services. The client
suitability is determined through the use of various documents that may include, but are not
limited to, the BD/RIA representative’s communication, correspondence, suitability
documentation, and Symmetry’s Investment Policy Statement or Statement of Investment
Selection. All forms of suitability are used to determine the client’s investment objectives,
time horizon, tax considerations, income needs, and risk tolerance in order to determine the
Symmetry Portfolio appropriate for the client.
Symmetry offers investment advisory services to clients that have come to the firm through
the efforts of the firm’s own IARs, labeled “direct clients.” The firm’s IARs assist Symmetry’s
clients in determining which of Symmetry’s model portfolios is most appropriate, including
customized portfolios to fit unique client needs and circumstances. Symmetry’s services may
include the following: reviewing the client’s investment portfolio at the commencement of its
relationship; assessing the client’s investment needs and objectives; investment policy
planning and suitability; developing an asset allocation strategy designed to meet client
objectives; ongoing monitoring of the performance of the accounts; reviewing accounts to
ensure adherence to policy guidelines and rebalancing asset allocations when Symmetry, in
its discretion, deems such re-balancing appropriate; answering client inquiries; updating
client information; and, interviewing the client at least annually to determine if there has been
a change in the client’s financial situation. Symmetry permits clients to maintain certain
securities in their advisory account(s) that are not recommended by Symmetry. For these
securities, Symmetry IARs will provide consultation services, which consist of general
guidance on how those assets fit into the client’s overall financial objectives.
Financial Planning
Symmetry also provides advice in the form of a financial plan to a limited number of legacy
clients. This service is not a standalone service for a separate fee, but part of the established
bundle of services and an agreed upon fee charged to each client. The direct client may
receive a written financial plan, designed to achieve the client’s stated financial goals and
objectives. Implementation of financial plan recommendations is entirely at the client’s
discretion.
In general, the financial plan may address any or all of the following areas of concern:
• PERSONAL: Family records, budgeting, personal liability, estate and financial
goals.
• TAX & CASH FLOW: Income tax and spending analysis and planning for past,
current and future years.
• 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 the
portfolio.
Symmetry Retirement Program
Symmetry is an Investment Manager as defined in Section 402(c)(3) and 3(38) of the
Employment Retirement Income Security Act of 1974 (“ERISA”) Symmetry works with a
select group of third-party administrators (“TPAs”), referred to as Symmetry’s QP Partners.
Symmetry offers its investment management services to 401(k) and qualified plans through
the Symmetry Retirement program.
Symmetry will review investment options, recommend a portfolio structure, recommend
appropriate changes in portfolio holdings and advise the Plan Sponsor in support of the Plan
Sponsor’s fiduciary role under the Plan. Symmetry may also provide the following:
• Quarterly portfolio review and performance analysis;
• Review of asset allocation rebalancing; and/or
• Periodic discussion of changes in weightings of the asset allocations.
Symmetry also makes available the Symmetry IndexElect Funds. The IndexElect Funds are
a menu of index mutual funds that are available for a Plan Sponsor to include in addition to
Symmetry’s Structured Portfolios. Symmetry’s oversight responsibility extends to the
IndexElect Fund menu and Symmetry’s portfolios.
Symmetry also provides services to plans which fall outside the scope of the Symmetry
Retirement Program by providing investment advisory services for accounts called Outside
Qualified Plans. These are individual participant accounts where the plan document allows
participants to select an investment adviser or investments outside of those selected by the
plan. In addition, Symmetry’s portfolios and advisory services can be accessed through
custodial and RIA retirement platforms.
In addition, Symmetry provides investment management services to defined benefit plans.
For these plans, Symmetry is an investment manager as defined in Sections 402(c)(3) and
3(38) of ERISA.
The Institutional Pension Plans
The Firm offers investment management services to municipalities and corporate pension
plans. These services include Investment policy design and review, standard and
customized performance reporting, meeting presentations, asset allocation, analysis and
design, and investment oversight, monitoring and evaluation, on a regular and continuous
basis.
Sub-Advisor/Model Manager Advisory Services
Symmetry provides investment advisory services acting as a sub-advisor/model manager
to/on various technology, broker-dealer, custodian, and RIA management platforms. The
services Symmetry provides are as follows: portfolio design, asset allocation, and securities
selection for investment portfolios/models to be used in advisor accounts. Based on
investment analysis, Symmetry will monitor and recommend changes to portfolio models.
Symmetry also provides wholesaling, marketing, and sales support to investment adviser
and registered representatives who have access to these respective platforms.
C. Individually Tailored Services and Reasonable Restrictions
Clients may place reasonable restrictions on their accounts. In some cases, Symmetry will
also customize portfolios to fit the unique needs and situations for clients. However, a
restriction request may not be honored if it is fundamentally inconsistent with Symmetry’s
investment philosophy, is counter to the client’s stated investment objectives, or would
prevent the firm from properly servicing client accounts. It should be noted as relates to the
Funds, Symmetry’s management cannot not be tailored to the individual needs of any
particular investor. As such, those investors do not have the ability impose restrictions on
Symmetry’s management.
D. Wrap Fee Programs
In addition to the advisory business described above, we also participate as a portfolio
manager in wrap fee programs. Under the wrap fee programs, investment advice and costs
of trade executions are provided to clients for an all-inclusive wrap fee. Under the existing
wrap fee program, Symmetry’s management fee is separate from the advisor fee, with
trading and custodial costs paid out of the advisory fee charged by the client’s financial
advisor.
There is no difference in the way clients’ assets are managed as described in this document,
due to the wrap fee program.
E. Assets Under Management
Symmetry’s discretionary assets under management were approximately $5.8 billion as of
12/31/2023.