Matthew Goff Investment Advisor, LLC (the "company” or “advisor"), which primarily conducts business
under the name The Goff Financial Group, is an investment advisor providing investment management
and financial planning services (the “Services”) to individuals, small business, and retirement plans. The
company was founded in 1994 by Matthew Goff, Chief Investment Officer (“CIO”). To this day, Matthew
Goff remains the sole owner and principal, owning 100% of the company and remaining committed to
providing the highest standard of Service to clients. The company spends 100% of its time engaged in
providing Investment Advisory Services to clients.
As of December 31, 2023, the company managed approximately $497,183,975 on a discretionary basis
and $3,704,912 on a non-discretionary basis for total assets under management of approximately
$500,888,887.
The company offers its Services on a fee-only basis which is charged based upon assets under
management. Prior to engaging the company to provide any of the foregoing Services, the client will be
required to enter into one or more written agreements setting forth the terms and conditions under which
the company shall render its Services (collectively the “Agreement”).
Because of the company’s fee-only model, the company has the autonomy to act in the best interest of the
client. The company takes the time to analyze the situation of each client and develop solutions tailored to
each client’s needs. The company bases its portfolio strategy on the objectives, income needs and other
special circumstances of each client. The company seeks to create the optimal balance between reducing
risk, asset growth, income, and preservation of capital.
The company provides discretionary and/or non-discretionary investment advisory services on a fee basis
as discussed at Item 5 below. Before engaging the company to provide investment advisory services,
clients are generally required to enter into an Investment Advisory Agreement with the company 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. To commence the investment advisory
process, the company will ascertain each client’s investment objective(s) and then allocate the client’s
assets consistent with the client’s designated investment objective(s). Once allocated, the company
provides ongoing supervision of the account(s). The specifics of each client’s portfolio are described in the
Agreement executed between the client and the company. In all cases the company utilizes its expertise
to build customized portfolios using securities including, but not limited to, the following:
• Exchange Listed Stocks and Funds
• Securities Traded Over the Counter
• Mutual Fund Shares
• Corporate Bonds
• US Government Bonds
• Commercial Paper
• Certificate of Deposits
• Options on Securities
The company’s main strategy is providing optimal investment advisory service to clients, including
rigorously addressing each individual’s specific needs. Because these needs evolve over time, clients are
advised to promptly notify the company if there are any changes in their financial situation that could
materially impact the management of their portfolio.
Please Note: Non-Discretionary Service Limitations. Clients that determine to engage the company
on a non-discretionary investment advisory basis must be willing to accept that the company cannot effect
any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus,
in the event that the company would like to make a transaction for a client’s account, and client is
unavailable, the company will be unable to effect the account transaction (as it would for its discretionary
clients) without first obtaining the client’s consent.
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the
extent requested and engaged by the client to do so, The company will generally provide financial planning
and related consulting services regarding matters such as tax and estate planning, insurance, etc. per the
terms and conditions of a separate agreement and a separate fee as discussed at Item 5 below, the fee
for which shall generally be based upon the individual providing the service and the scope of the services
to be provided. Prior to engaging the company to provide planning or consulting services, clients are
generally required to enter into a Financial Planning and Consulting Agreement with The company setting
forth the terms and conditions of the engagement (including termination), describing the scope of the
services to be provided, and the portion of the fee that is due from the client prior to The company
commencing services.
Retirement Rollovers – Potential for Conflict of Interest: A client or prospective client leaving an employer
typically 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 company recommends that a client roll over their retirement plan assets
into an account to be managed by the company, such a recommendation creates a conflict of interest if
the company will earn new (or increase its current) compensation as a result of the rollover. If the company
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 company 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 roll over retirement plan assets to
an account managed by the company, whether it is from an employer’s plan or an existing IRA.
Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to
recommend a broker-dealer/custodian for client accounts, The company generally recommends that
Fidelity or Schwab serve as the broker-dealer/custodian for client investment management assets. Broker-
dealers such as Fidelity and 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 Fidelity and
Schwab, generally (with exceptions) do not currently charge fees on individual equity transactions
(including ETFs), others do. Please Note: there can be no assurance that Fidelity or Schwab will not
change its transaction fee pricing in the future. Please Also Note: Fidelity and Schwab may also assess
fees to clients who elect to receive trade confirmations and account statements by regular mail rather than
electronically.
Cash Positions: The company continues to treat cash as an asset class. As such, unless determined to
the contrary by the company, all cash positions (money markets, etc.) shall continue to be included as part
of assets under management for purposes of calculating the company’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 company 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 company’s advisory fee could exceed
the interest paid by the client’s money market fund.
Cybersecurity Risk: The information technology systems and networks that the company and its third-
party service providers use to provide services to the company’s clients employ various controls, which
are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that
could cause significant interruptions in the company’s operations and result in the unauthorized acquisition
or use of clients’ confidential or non-public personal information. Clients and the company 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
company has established its systems to reduce the risk of cybersecurity
incidents from coming to fruition,
there is no guarantee that these efforts will always be successful, especially considering that the company
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.
Portfolio Activity. The company has a fiduciary duty to provide services consistent with the client’s best
interest. The company 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, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time when the company
determines that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees
described in Item 5 below during periods of portfolio inactivity. Of course, as indicated below, there can be
no assurance that investment decisions made by the company will be profitable or equal any specific
performance level(s).
Other Assets. A client may:
• hold securities that were purchased at the request of the client or acquired prior to the
client’s engagement of the company. Generally, with potential exceptions, the company
does not/would not recommend nor follow such securities, and absent mitigating tax
consequences or client direction to the contrary, would prefer to liquidate
such securities. Please Note: If/when liquidated, it should not be assumed that the
replacement securities purchased by the company will outperform the liquidated
positions. To the contrary, different types of investments involve varying degrees of risk,
and there can be no assurance that future performance of any specific investment or
investment strategy (including the investments and/or investment strategies
recommended or undertaken by the company) will be profitable or equal any specific
performance level(s)In addition, there may be other securities and/or accounts
owned by the client for which the company does not maintain custodian access and/or
trading authority; and,
• hold other securities and/or own accounts for which the company does not maintain
custodian access and/or trading authority.
Corresponding Services/Fees: When agreed to by the company, the company shall: (1) remain
available to discuss these securities/accounts on an ongoing basis at the request of the client; (2) monitor
these securities/accounts on a regular basis, including, where applicable, rebalancing with client
consent;(3) shall generally consider these securities as part of the client’s overall asset allocation; and, (4)
report on such securities/accounts as part of regular reports that may be provided by the
company; and, (5) include the market value of all such securities for purposes of calculating advisory fee.
ESG: We don’t have or recommend a strategy:
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. As with any type of investment (including any investment and/or investment
strategies recommended and/or undertaken by the company), there can be no assurance that investment
in ESG securities or funds will be profitable, or prove successful. The company 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 company shall rely upon the assessments undertaken by the unaffiliated mutual fund,
exchange traded fund or separate account manager to determine that the fund’s or portfolio’s underlying
company securities meet a socially responsible mandate.
WE DON’T RECOMMEND Cryptocurrency: For clients who want exposure to cryptocurrencies, including
Bitcoin, the company, will advise the client to consider a potential investment in corresponding exchange
traded securities, or an allocation to separate account managers and/or private funds that provide
cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services, but
uses an online ledger with strong cryptography (i.e., a method of protecting information and
communications through the use of codes) to secure online transactions. Unlike conventional currencies
issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price
is determined by the supply and demand of their market. Because cryptocurrency is currently considered
to be a speculative investment, the company will not exercise discretionary authority to purchase a
cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of
the cryptocurrency investment. Please Note: The company does not recommend or advocate the
purchase of, or investment in, cryptocurrencies. The company considers such an investment to be
speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment must
be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of
principal.
Reporting Services: The company can also provide account reporting services, which can incorporate
client investment assets that are not part of the assets that the company manages (the “Excluded Assets”).
Unless agreed to otherwise, the client and/or his/her/its other advisors that maintain trading authority, and
not the company, shall be exclusively responsible for the investment performance of the Excluded Assets.
Unless also agreed to otherwise, the company does not provide investment management, monitoring or
implementation services for the Excluded Assets. If the company is asked to make a recommendation as
to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and
the company shall not be responsible for any implementation error (timing, trading, etc.) relative to the
Excluded Assets. The client can engage the company to provide investment management services for the
Excluded Assets pursuant to the terms and conditions of the Investment Advisory Agreement between the
company and the client.
eMoney. In the event that the company provides the client with access to an unaffiliated vendor’s
website such as
eMoney, and the site provides access to information and/or concepts, including
financial planning, the client, should not, in any manner whatsoever, infer that such access is a
substitute for services provided by the company. Rather, if the client utilizes any such content, the
client does so separate and independent of the company.
Client Obligations. In performing our services, the company shall not be required to verify any information
received from the client or from the client’s other professionals, and is expressly authorized to rely thereon.
Moreover, it remains each client’s responsibility to promptly notify the company if there is ever any change
in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising
our previous recommendations and/or services.
Please Note: 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 company) will be
profitable or equal any specific performance level(s).
Disclosure Brochure. A copy of the company’s written Brochure as set forth on Part 2A of Form ADV and
Form CRS (Client Relationship Summary) shall be provided to each client prior to, or contemporaneously
with, the execution of an agreement between the client and the company.