A. Fountainhead Financial, LLC (the “Registrant”) is a limited liability company formed in
2003 in the State of Illinois. The Registrant has been registered as an investment adviser
with the SEC since July 2009. The Registrant is owned and operated by its Managing
Member, Dominick J. Vetrano, CFP, CLU, ChFC, CFA, RHU.
B.
INVESTMENT ADVISORY SERVICES
The Registrant provides non-discretionary (see MISCELLANEOUS below) investment
advisory services on a fee basis. Registrant's annual investment advisory fee shall include
investment advisory services, and, to the extent specifically requested by the client,
financial planning and consulting services. In the event that the client requires
extraordinary planning and/or consultation services (to be determined in the sole discretion
of the Registrant), the Registrant may determine to charge for such additional services, the
dollar amount of which shall be set forth in a separate written notice to the client. In
addition, as discussed at Item 5 below, the client can also engage the Registrant for fixed
fee and/or hourly consulting services.
To commence the investment advisory process, the Registrant will ascertain each client’s
investment objectives and then allocate assets consistent with the client’s designated
investment objectives. Once allocated, the Registrant provides ongoing monitoring and
review of account performance and asset allocation as compared to client investment
objectives, and may rebalance the client’s accounts as necessary. Before engaging the
Registrant to provide investment advisory services, clients are required to enter into an
Investment Advisory Agreement with Registrant 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.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
The Registrant may provide financial planning and/or consulting services (including
investment and non-investment related matters, including estate planning, insurance
planning, etc.) on a stand-alone fee basis. Prior to engaging the Registrant to provide
planning or consulting services, clients are generally required to enter into a Financial
Planning and Consulting Agreement with Registrant 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 Registrant
commencing services. If requested by the client, Registrant may recommend the services
of other professionals for implementation purposes, including its Managing Member,
Dominick J. Vetrano, in his separate individual capacity as a licensed insurance agent (See
disclosure at Items 10.C). 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
Registrant. Please Note: Moreover, each client is advised that it remains their
responsibility to promptly notify the Registrant if there is ever any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating or revising
Registrant’s previous recommendations and/or services. Please Also Note: If the client
engages any such recommended professional, and a dispute arises thereafter relative to
such engagement, the client agrees to seek recourse exclusively from and against the
engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney,
accountant, insurance agent, etc.), and not the Registrant, shall be responsible for the
quality and competency of the services provided.
MISCELLANEOUS
Please Note: Non-Discretionary Service Limitations. The registrant provides services
on a non-discretionary basis. Clients that determine to engage the Registrant on a non-
discretionary investment advisory basis must be willing to accept that the Registrant cannot
affect any account transactions without obtaining prior consent to any such transaction(s)
from the client. Thus, in the event that Registrant would like to make a transaction for a
client’s account, and client is unavailable, the Registrant will be unable to effect the account
transaction without first obtaining the client’s consent.
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by the client, Registrant may provide
financial planning and related consulting services regarding non-investment related
matters, such as estate planning, tax planning, insurance, etc. Registrant does not serve as
a law firm or accounting firm, and no portion of its services should be construed as legal
or accounting services. Accordingly, Registrant does not prepare estate planning
documents or tax returns. To the extent requested by a client, Registrant may recommend
the services of other professionals for certain non-investment implementation purposes (i.e.
attorneys, accountants, insurance agents, etc.), including its Managing Member, Dominick
J. Vetrano, in his separate individual capacity as a licensed insurance agent (See disclosure
at Items 10.C). 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
Registrant and/or its representatives. Please Note: 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. At all
times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.),
and not the
Registrant, shall be responsible for the quality and competency of the services
provided. Conflict of Interest: The recommendation by Registrant’s representatives that
a client purchase an insurance product from Mr. Vetrano his separate individual capacity
as a licensed insurance agent presents a conflict of interest, as the receipt of commissions
may provide an incentive to recommend investment products based on commissions to be
received, rather than on a particular client’s need. No client is under any obligation to
purchase any securities or insurance commission products through Mr. Vetrano. Clients
are reminded that they may purchase securities and insurance products recommended by
Registrant through other, non-affiliated broker-dealers.
Retirement Rollovers-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 Registrant recommends that a client roll over their retirement plan
assets into an account to be managed by Registrant, such a recommendation creates a
conflict of interest if Registrant will earn new (or increase its current) compensation as a
result of the rollover. Registrant’s Chief Compliance Officer, Dominick Vetrano,
remains available to address any questions that a client or prospective client may have
regarding the conflict of interest presented by such rollover recommendation.
Use of Mutual Funds/Exchange Traded Funds: Most mutual funds and exchange traded
funds are available directly to the public. Thus, a prospective client can obtain many of the
mutual funds that may be recommended and/or utilized by Registrant independent of
engaging Registrant as an investment advisor. However, if a prospective client determines
to do so, he/she will not receive Registrant’s initial and ongoing investment advisory
services.
Participant Directed Retirement Plans. Registrant may also provide investment advisory
and consulting services to participant directed retirement plans per the terms and conditions
of a Retirement Plan Services Agreement between Registrant and the plan. For such
engagements, Registrant shall assist the Plan sponsor with the selection of an investment
platform from which Plan participants shall make their respective investment choices
(which may include investment strategies devised and managed by Registrant), and, to the
extent engaged to do so, may also provide corresponding education to assist the participants
with their decision making process.
Custodian Charges-Additional Fees: As discussed below at Item 12 below, when
requested to recommend a broker-dealer/custodian for client accounts, the Registrant
generally recommends that Schwab serve as the broker-dealer/custodian for client
investment management assets. Broker-dealers such as Schwab charge transaction fees for
effecting securities transactions. In addition to the Registrant’s investment advisory fee
referenced in Item 5 below, the client will also incur transaction fees to purchase securities
for the client’s account (i.e., mutual funds exchange traded funds, individual equity and
fixed income securities, etc.) ANY QUESTIONS: Registrant’s Chief Compliance
Officer, Dominick Vetrano, remains available to address any questions that a client
or prospective client may have regarding the above.
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Registrant 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, mutual 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 Registrant 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 Registrant will be profitable or equal any specific performance level(s).
Client Obligations. In performing its services, Registrant 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, each client is advised that it remains their
responsibility to promptly notify the Registrant if there is ever any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating or revising
Registrant’s previous recommendations and/or services.
Disclosure Brochure. A copy of the Registrant’s written Brochure as set forth on Part 2A
of Form ADV shall be provided to each client prior to, or contemporaneously with, the
execution of the Investment Advisory Agreement or Financial Planning and Consulting
Agreement.
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at anytime, impose
reasonable restrictions, in writing, on the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2023, the Registrant had $342.5 million of assets under management
on a non-discretionary basis.