A. AdvisorNet Financial, Inc. operates its registered investment advisory division under the assumed name of AdvisorNet Wealth
Partners (“AdvisorNet Wealth Partners”). Therefore, when this Brochure refers to “AdvisorNet Wealth Partners” or
“AdvisorNet” it is referring to AdvisorNet Financial, Inc. AdvisorNet has been in the investment advisory business since 1984,
has been continually incorporated in the State of Minnesota since 1980, and traces its direct roots in the financial services
business to 1959. AdvisorNet is owned by a network of approximately 50 individuals, many of whom are investment adviser
representatives of the firm.
Trade Names. Trade Names. AdvisorNet and/or its representatives may use the following trade names in association with
providing the services set forth in this Brochure: ADVANCED RETIREMENT RESOURCES, ADVANCED WEALTH MANAGEMENT,
ADVISORNET FINANCIAL PARTNERS, ADVISORNET WEALTH MANAGEMENT, AJW FINANCIAL, ALIGNED WEALTH PLANNING
GROUP, BOX FINANCIAL, BRUMBAUGH WEALTH MANAGEMENT, CALCULATED WEALTH MANAGEMENT, CARSON CHOICE
RETIREMENT SOLUTIONS, CROWN CAPITAL ADVISORY, DRACH FINANCIAL, EMPIRE ASSET MANAGEMENT GROUP, EXECUTIVE
FINANCIAL SERVICES INC, EPOCH FINANCIAL GROUP, FINANCIAL CONSULTANTS OF RAPID CITY, FINANCIAL PLAN PARTNERS, FSA
ADVISORS, LLP, JOSH WEBSKOWSKI, KESHEMBERG ADVISORY, LEWIS FINANCIAL ADVISORS, LLC, LIFELONG WEALTH ADVISORS,
MATTSON WEALTH MANAGEMENT, MCCABE & ASSOCIATES, MICHAEL D. PETERSEN, PEAK ADVISORY, PLANVISER FINANCIAL,
RICE CREEK WEALTH MANAGEMENT, ROBERT J. MCHATTIE, STILL WATERS PLANNING, STERLING RETIREMENT RESOURCES, INC,
STONEBRIDGE WEALTH PARTNERS, WALTER R. BOMGREN, WEINBACH INVESTMENT MANAGEMENT, LLC.
Please Note: The above trade names are not an exhaustive list of the trade names that AdvisorNet and/or its representatives
may use in association with providing the services set forth in this Brochure. The list of trade names set forth above will be
revised on a periodic basis as trade names are added and/or deleted. Please also Note: All such trade name entities are not
affiliated with AdvisorNet or with any custodian or broker-dealer utilized by AdvisorNet. All investment management services
provided under an agreement with AdvisorNet by the individuals associated with the trade name entities listed above are
provided in their respective individual capacities as investment adviser representatives of AdvisorNet Financial, Inc., a registered
investment adviser, with principal offices located at 110 Cheshire Lane, Suite 200, Minnetonka, MN 55305 (Phone
612.347.8600). AdvisorNet’s Chief Compliance Officer is available to address any questions that a client or prospective client
may have regarding the above Trade Names.
To conduct its everyday business, AdvisorNet may enter into service agreements with third party firms to provide various
technology and administrative services for your account. These services include but may not be limited to transaction
processing, account maintenance and performance reporting. Such third-party firms include but may not be limited to
custodians and broker-dealers (see Item 12) and companies which provide portfolio reporting and rebalancing services.
Clients’ account data and other nonpublic personal information may be shared with, between and/or by such third-party
firms (see also, AdvisorNet’s Privacy Notice, distributed upon account opening, annually, and any time upon request).
B. AdvisorNet offers its clients investment management services, and, to the extent specifically requested by a client, financial
planning, and related consulting services.
INVESTMENT MANAGEMENT SERVICES
ADDITIONAL INVESTMENT MANAGEMENT INFORMATION
For individual clients, investment management will often occur at a household level, and will be based on personal
information provided by the client.
Regarding trading authorization, “discretionary” and “non-discretionary” are financial industry terms. “Discretionary trading
authorization” allows AdvisorNet to make trading decisions and execute trades without a client’s prior verbal consent. “Non-
discretionary trading authorization” requires a client’s prior verbal consent as to the purchase or sale of a definite amount of
a particular security. Again, AdvisorNet provides investment management services, both “wrap” and “non-wrap” on a wholly
discretionary or wholly non-discretionary basis.
Please Note: Non-Discretionary Service Limitations. Clients that determine to engage AdvisorNet on a non-discretionary
investment management basis must be willing to accept that AdvisorNet cannot effect any account transactions without
obtaining prior verbal consent from the client as to the purchase or sale of a definite amount of a particular security. Thus,
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in the event of a market correction during which the client is unavailable, AdvisorNet will be unable to effect any account
transactions (as it would for its discretionary clients) without first obtaining the client’s verbal consent.
Wrap Program-Conflict of Interest. AdvisorNet Wealth Partners also provides service to a small percentage of its clients on
a wrap fee basis as a wrap program sponsor. Under AdvisorNet Wealth Partners’ wrap program, the client generally receives
investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single
specified fee. Participation in a wrap program may cost the client more or less than purchasing such services separately. The
terms and conditions of a wrap program engagement are also discussed in AdvisorNet Wealth Partners’ Wrap Fee Program
Brochure. Conflict of Interest. Because wrap program transaction fees and/or commissions are being paid by AdvisorNet
Wealth Partners to the account custodian/broker-dealer, AdvisorNet Wealth Partners could have an economic incentive to
maximize its compensation by seeking to minimize the number of trades and/or transaction fees incurred for the client's
account. See separate Wrap Fee Program Brochure. AdvisorNet Wealth Partners’ Chief Compliance Officer remains available
to address any questions that a client or prospective client may have regarding a wrap fee arrangement and the corresponding
conflict of interest.
Types of Managed (Supervised) Investments / Qualified Plan Participant Account Limitations. AdvisorNet manages a wide
range of various types of investments according to a client’s goals and objectives. Some of these investments may include,
but are not limited to: mutual funds, general securities, fixed income securities, collateralized mortgage obligations, exchange
traded funds, sub-advisors, independent investment managers and/or programs, and select alternative investments.
AdvisorNet will have some limitations on the types of investments it agrees to manage, but these will generally be investment
types which are not known to be widely held.
Investments which AdvisorNet manages may be held in various types of accounts. These include but are not limited to
brokerage accounts which AdvisorNet may recommend (see Item 12, below), or qualified plan accounts. In regard to
qualified plan accounts: AdvisorNet may provide investment management services and various advice, including but not
necessarily limited to specific investment advice to qualified plan participants. Regardless whether a client enters into a
“discretionary” or “non-discretionary” investment management agreement, AdvisorNet’s services under the agreement
related to qualified plan assets are limited to providing various investment recommendations to a client which must then be
implemented solely by the client. However, in limited circumstances as described under Item 8.B below, a third-party
platform may be used by advisers to manage and trade on held-away qualified plan accounts at the participant level. In
addition, AdvisorNet may not receive any communications from the plan sponsor or custodian, and it shall remain the client’s
exclusive obligation to provide AdvisorNet with current account information, as well as notify AdvisorNet of any changes in
investment alternatives, restrictions, etc. pertaining to the client’s qualified plan account. AdvisorNet is not responsible for
any costs, damages, penalties, or otherwise, resulting from the client’s failure to so notify AdvisorNet. In addition, AdvisorNet
will not have, nor will it accept, any authority to effect any type of transactions or changes via the plan web site, telephone,
email or otherwise, including but not limited to changing beneficiaries or effecting account disbursements or transfers to any
individual or entity. Alternatively, AdvisorNet can provide discretionary investment management related to qualified plan
participants’ accounts. Such activity is facilitated through a third-party vendor and requires a specific advisory agreement to
be signed by the plan participant.
Please Note: On its client portfolio performance reports, AdvisorNet may also refer to managed investments as “supervised”
investments. These are investments which are managed for a fee as agreed upon in AdvisorNet’s investment management
agreement. While AdvisorNet may also agree to report on “unsupervised” investments, this would be offered as a
convenience only. While AdvisorNet may consider such “unsupervised” investments in the overall picture of providing advice
on managed or “supervised” investments, or in regard to separately agreed-upon financial planning or consulting services,
AdvisorNet has no legal responsibility to manage, monitor, or otherwise supervise a client’s “unsupervised” investments,
even if they appear on a client’s portfolio performance reports.
Please Also Note: AdvisorNet may recommend the services of one or more third party money managers to serve as a sub-
advisor, in order to provide certain clients with third party money management for some or all of the assets held in such
clients’ accounts. Services by such sub-advisors will generally include, for additional fees, (along with other services described
in the sub-advisor’s disclosure documents), portfolio analysis, asset allocation modeling and analysis, trading execution and
other services. Unless the client’s investment management agreement states otherwise, such sub-advisors will generally
have discretion to execute transactions on the client’s behalf. In such sub-advisor programs, AdvisorNet and the sub-advisor
are co-fiduciaries. This means that AdvisorNet, along with the sub-advisor, are jointly responsible for the ongoing
management of the client’s account.
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Independent Managers. AdvisorNet may allocate (and/or recommend that the client allocate) a portion of a client’s
investment assets among unaffiliated independent investment managers in accordance with the client’s designated
investment objective(s). In such situations, the Independent Manager[s] shall have day-to-day responsibility for the active
discretionary management of the allocated assets. AdvisorNet shall continue to render investment advisory services to the
client relative to the ongoing monitoring and review of account performance, asset allocation and client investment
objectives. Factors which AdvisorNet shall consider in recommending Independent Manager[s] include the client’s designated
investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research.
Please Note: The investment management fee charged by the Independent Manager[s]is separate from, and in addition to,
AdvisorNet’s advisory fee (including the wrap advisory fee) as set forth in the fee schedule at Item 5 below.
Mutual and 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 funds that may be utilized by AdvisorNet Wealth Partners independent of
engaging AdvisorNet Wealth Partners as an investment adviser. However, if a prospective client determines to do so, he/she
will not receive AdvisorNet Wealth Partners’ initial and ongoing investment advisory services. Please Note-Use of DFA Mutual
Funds: AdvisorNet Wealth Partners utilizes mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are
generally only available through registered investment advisers approved by DFA. Thus, if the client was to terminate
AdvisorNet Wealth Partners’ services, and transition to another adviser who has not been approved by DFA to utilize DFA
funds, restrictions regarding additional purchases of, or reallocation among other DFA funds, will generally apply. Please Also
Note: In addition to AdvisorNet Wealth Partners’ investment advisory fee described below, and transaction and/or custodial
fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed
at the fund level (e.g., management fees and other fund expenses). AdvisorNet Wealth Partners’ Chief Compliance Officer
remains available to address any questions that a client or prospective client may have regarding the above.
Custodian Charges-Additional Fees: As discussed at Item 12 below, when requested to recommend a broker-
dealer/custodian for client accounts, AdvisorNet Wealth Partners generally recommends that Schwab, Pershing, Fidelity and
Betterment (collectively the “Custodians”) serve as the broker-dealer/custodian for client
investment management assets.
These Custodians generally charge transaction fees for effecting securities transactions. In addition to AdvisorNet Wealth
Partners’ investment advisory fee referenced in Item 5 below, the client (unless it engages AdvisorNet Wealth Partners on a
wrap fee basis per the above) 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.) AdvisorNet Wealth Partners’ Chief Compliance
Officer remains available to address any questions that a client or prospective client may have regarding the above.
Portfolio Activity. AdvisorNet Wealth Partners has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, AdvisorNet Wealth Partners 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, 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 AdvisorNet Wealth Partners determines
that changes to a client’s portfolio are neither necessary nor prudent. Clients are still subject to the fees described in Item 5
below, even during periods of account inactivity. Of course, as indicated below, there can be no assurance that investment
decisions made by AdvisorNet Wealth Partners will be profitable or equal any specific performance level(s).
Portfolio Partners-Conflict of Interest. AdvisorNet may allocate and/or recommend that a client allocate assets to Portfolio
Partners, an internal investment management team within AdvisorNet, in accordance with the client’s designated investment
objective(s). In such situations, AdvisorNet shall pay a portion of the investment advisory fee received for these allocated
assets to the Portfolio Partners team for its investment management services. Since AdvisorNet’s representatives who are a
part of the Portfolio Partners team shall receive a portion of the advisory fee charged to the client in such situations, a material
conflict of interest arises for the members of the Portfolio Partners team, as the recommendation to utilize the services of
the Portfolio Partners team could be made on the basis of compensation to be received, rather than a client or prospective
client’s best interests. AdvisorNet’s Chief Compliance Officer remains available to address any questions regarding Portfolio
Partners and the corresponding conflict of interest.
RETIREMENT PLAN AND PARTICIPANT CONSULTING (STAND-ALONE)
In addition to providing investment management services for a client’s qualified plan account as part of an investment
management agreement, as described above, AdvisorNet provides other non-discretionary qualified plan/pension consulting
services on a stand-alone, separate fee basis. These services include assisting sponsors of self-directed retirement plans in
various ways, including but not limited to, the selection and/or monitoring of investment alternatives (generally open-end
mutual funds) from which plan participants choose in self-directing the investments for their individual plan retirement
accounts. In addition, to the extent requested by the plan sponsor, AdvisorNet will provide participant education designed
to assist participants in identifying the appropriate investment strategy for their retirement plan accounts. Under certain
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arrangements, AdvisorNet will also provide specific investment advice to qualified plan participants regarding plan assets.
The terms and conditions of these services will be set forth in an agreement between AdvisorNet and the plan sponsor. In
all cases, clients, including qualified plan participants, are free to accept or reject any advice or recommendations provided
to them, and are further solely responsible for making any and all changes to, or effecting any and all transactions in, their
qualified plan. AdvisorNet accepts no such responsibility in this regard. Please Note: Any such retirement plan and participant
consulting services are provided on a “one-time”, “as requested”, or “regular/periodic” basis. Any services performed on an “as
requested” or “regular/periodic” basis are not “on-going and continuous” in nature, as are AdvisorNet’s investment
management services described above. Rather, services provided on a “regular/periodic” basis will only be based on client
circumstances as of a specific date (i.e., a “snapshot in time”).
Please Note: 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 AdvisorNet recommends that a client roll over their
retirement plan assets into an account to be managed by AdvisorNet, such a recommendation creates a conflict of interest if
AdvisorNet will earn an advisory fee on the rolled over assets. In addition, the advisory fees associated with accounts that are
managed by AdvisorNet will typically be more expensive than the fees incurred under most employer retirement plans. No
client is under any obligation to rollover retirement plan assets to an account managed by AdvisorNet. AdvisorNet’s Chief
Compliance Officer remains available to address any questions that a client or prospective client may have regarding the
potential for conflict of interest presented by such rollover recommendation.
ERISA / IRC Fiduciary Acknowledgment. If the client is: (i) a retirement plan (“Plan”) organized under the Employee Retirement
Income Security Act of 1974 (“ERISA”); (ii) a participant or beneficiary of a Plan subject to Title I of ERISA or described in section
4975(e)(1)(A) of the Internal Revenue Code, with authority to direct the investment of assets in his or her Plan account or to take
a distribution; (iii) the beneficial owner of an Individual Retirement Account (“IRA”) acting on behalf of the IRA; or (iv) a Retail
Fiduciary with respect to a plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code:
then AdvisorNet represents that it and its representatives are fiduciaries under ERISA or the Internal Revenue Code, or both,
with respect to any investment advice provided by AdvisorNet or its representatives or with respect to any investment
recommendations regarding an ERISA Plan or participant or beneficiary account.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
To the extent requested by a client, AdvisorNet may determine to provide financial planning and/or consulting services on a
stand-alone, separate fee basis. These services may include both investment and non-investment related matters. These
services may also consist of planning and consulting on a “one-time”, “as requested”, or “regular/periodic” basis. Please Note:
Any services performed on an “as requested” or “regular/periodic” basis are not “on-going and continuous” in nature, as are
AdvisorNet’s investment management services described above. Rather, services provided on a “regular/periodic” basis will
only be based on client circumstances as of a specific date (i.e., a “snapshot in time”). AdvisorNet also occasionally provides
general financial planning information to businesses and other organizations, as well as workshops and seminars to the public
related to financial and investment planning. AdvisorNet offers Estate Planning services included as part of our ongoing
financial planning services to our clients that consists of education on estate planning topics and the collection of general
information necessary to complete a new estate plan or review a current estate plan. AdvisorNet utilizes the services of Trust
& Will, a third-party digital estate planning service for clients who have the need for estate planning review, creation or
updates.
Prior to engaging AdvisorNet to provide financial planning or consulting services, clients are generally required to enter into
a written agreement with AdvisorNet setting forth the scope of the services to be provided, and other terms and conditions
of the engagement (including termination).
Recommending the Services of Other Professionals. If requested by the client, AdvisorNet may recommend the services of
other professionals for the purpose of implementing various investment-related planning or consulting recommendations.
This may include recommending AdvisorNet’s own representatives in their individual capacities as registered representatives
or investment adviser representatives of Cetera Advisor Networks LLC, (“Cetera Advisor Networks”, “Cetera”) and/or as
licensed insurance agents. (See disclosure at Item 10). 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 AdvisorNet. Please 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
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agent, investment banking associate, etc.), and not AdvisorNet Wealth Partners, shall be responsible for the quality and
competency of the services provided.
In addition, to the extent requested by the client, AdvisorNet may provide consulting services regarding non-investment
related matters, such as estate planning, tax planning, insurance, etc. Neither AdvisorNet, nor any of its representatives,
serves as an attorney or accountant under an AdvisorNet agreement, and no portion of AdvisorNet’s services should be
construed to offer such services. To the extent requested by a client, AdvisorNet may recommend the services of other
professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, certain insurance, etc.),
including certain representatives of AdvisorNet in their separate registered/licensed capacities as discussed below. 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 AdvisorNet. Please 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 AdvisorNet Wealth Partners, shall be responsible
for the quality and competency of the services provided.
Client Obligations. In performing any of its services, AdvisorNet will not be required to verify any information received from
the client or from the client’s other professionals and is expressly authorized to rely on such information. Moreover, each
client is advised that it remains his/her/its responsibility to promptly notify AdvisorNet if there is ever any change in
his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising AdvisorNet’s previous
recommendations and/or services.
C. AdvisorNet will provide investment management services specific to the needs of each client. Prior to providing investment
management services, an investment adviser representative will ascertain each client’s investment objective(s). AdvisorNet will
then allocate and/or recommend that the client allocate investment assets consistent with the client’s investment objective(s).
The client may, at any time, impose reasonable restrictions, in writing, on AdvisorNet’s services.
D. There is no significant difference between how AdvisorNet manages wrap fee accounts and non-wrap fee accounts. However,
as stated above, if a client determines to engage AdvisorNet on a wrap fee basis the client will pay a single fee for bundled
services (i.e., investment advisory, brokerage, custody) (See also Item 4.B.). The services included in a wrap fee agreement
will depend upon each client’s particular need. If the client determines to engage AdvisorNet on a non-wrap fee basis the
client will select individual services on an unbundled basis, paying for each service separately (i.e., investment advisory,
brokerage, custody). Please Note: When managing a client’s account on a wrap fee basis, AdvisorNet shall receive as payment
for its investment management services, the balance of the wrap fee after all other costs incorporated into the wrap fee have
been deducted.
E. As of December 31, 2023, AdvisorNet managed approximately $2,266,125,330 on a discretionary basis and $1,521,453 on a
non-discretionary basis.