Brite Advisors USA, Inc. (“Brite USA” or the “Firm”) is a registered investment adviser with the
U.S. Securities and Exchange Commission (“SEC”). The Firm’s advisory clients (“Clients”)
consist primarily of United Kingdom (“U.K.”) expatriates residing in the United States (“U.S.”)
who have pension assets located overseas.
Brite USA provides customized, non-discretionary investment advisory services to Clients based
upon such factors as their age, income, assets and debts, education, need for cash flow,
investment goals and experience, and risk tolerance. The Firm collects this information during
Client meetings, interviews, and telephone calls, as well as written communications. Brite USA
Investment Adviser Representatives (“IARs”) analyze each Client’s financial situation and
formulate an investment strategy using a combination of investments that is tailored for, and in
the best interest of, the Client. The IARs are persons who, for compensation, (a) make any
recommendation or otherwise render advice regarding securities; (b) manage accounts or
portfolios of clients; or (c) determine which recommendations or advice regarding securities
should be given.
Prior to engaging Brite USA to provide investment advisory services, each Client is required to
enter into one or more written agreements with the Firm setting forth the terms and conditions
under which Brite USA renders such services (collectively, the “Agreement”).
The Firm has been operational in the U.S. since September 2012. Effective December 19, 2023,
Martin A. Byrne, Chief Executive Officer, acquired Brite USA from David McKenna, the Firm’s
prior owner. As a result of the change of ownership, Mr. Byrne directly wholly-owns the Firm
and is the sole control person of the Firm. Mr. McKenna no longer has any ownership interest,
directly or indirectly, in the Firm.
This disclosure brochure (“brochure”) describes the business of Brite USA. Certain sections also
describe the activities of supervised persons of Brite USA, including its officers, directors (or
other persons occupying a similar status or performing similar functions), or employees, or
another person who provides investment advice on the Firm’s behalf and who is subject to Brite
USA’s supervision or control.
Description of Investment Advisory Services
Clients engage the Firm to manage all or a portion of their assets on a non-discretionary basis
only. The Firm does not act on a discretionary basis for Clients.
The Firm’s investment advisory services primarily focus on the use of International Pension
(including both SIPP and QROPS) schemes, described below, and the allocation of Client assets
among mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities,
Undertakings for Collective Investment in Transferable Securities (“UCITS”), and currency,
consistent with the investment objectives of each Client.
Clients may elect to allocate their assets according to model portfolios utilized by the Firm.
Portfolios of Clients on the Brite Platform (described in Section E below) are automatically
rebalanced to their starting allocations approximately annually. For Clients invested in a Brite
Platform model portfolio, investments will be automatically rebalanced in order to maintain
recommended asset allocations. On average, model portfolios are rebalanced annually, but
rebalancing may occur more or less frequently depending on the circumstances. There may be
substitutions of different underlying securities over time within an asset class, but there will be
no change in asset allocations without prior notice and written consent obtained from Client.
In addition to the Firm’s focus on International Pension schemes, the Firm’s investment advisory
services include the management of Client assets custodied in the U.S. These services include the
allocation of Client assets among mutual funds, ETFs, and individual debt and equity securities,
consistent with the investment objectives of each Client. When recommending mutual funds,
Brite will generally seek to recommend the lowest overall cost share class of mutual funds
available to clients under the circumstances.
The Firm tailors its investment advisory services to the individual needs of Clients. The Firm
consults with Clients initially and on an ongoing basis to evaluate their financial situation, risk
profile and recent developments that may impact their investment goals. Brite USA utilizes a
number of technologies to assist with the process of providing advisory services to its clients.
The Firm seeks investments that it believes are in the best interest of each of its Clients. Clients
are advised to promptly notify the Firm if there are changes in their financial situation or
investment objectives or if they wish to impose any reasonable restrictions upon the Firm’s
investment advisory services.
Use of International Pension Schemes
The Firm’s business model focuses on advising Clients with respect to their U.K.-based pension
plans and the investments held within those plans.
A. Qualifying Recognised Overseas Pension Scheme (“QROPS”)
In 2017, the U.K. Chancellor of the Exchequer announced that pension transfers requested on or
after March 9, 2017, to certain QROPS, a type of international pension scheme, could be subject
to an overseas tax charge of 25% on the value of the pension transfer. In light of this
announcement, the Firm has determined to cease accepting any new advisory business from
persons residing in the United States who seek to transfer their U.K. pension assets to a QROPS.
Additional investments cannot be added to existing QROPS arrangements. The Firm currently
intends to continue to service existing Clients who have QROPS arrangements.
B. Self-Invested Personal Pension (“SIPP”)
If in the best interest of the Client, Brite USA IARs may recommend that Clients transfer their
U.K. pension assets to a SIPP, which is a type of personal pension plan offered by third party
providers. A SIPP, subject to any applicable restrictions, allows Clients to invest in a range of
assets. The value of SIPP retirement benefits is determined by, among other things, (i) the
amount of contributions made, (ii) the period that each contribution has been invested, and (iii)
investment performance over the period.
C. General
Brite USA does not maintain pension assets. All International Pension assets are administered by
an overseas third-party pension trustee (regulated by the relevant financial services regulator
where the pension plan is held) and custodied by a third-party custodian. International Pension
assets are subject to the terms and conditions of a separate agreement between Client and the
pension trustee. The QROPS pension trustees with which Clients currently have agreements
include STM Malta Trust and Company Management Ltd (“STM Malta”), Trireme Pension
Services (“Trireme”), and MC Trustees (MC) each an overseas financial services company. The
pension trustees for the SIPPs that the Firm recommends currently include London and Colonial
Services Limited (“L&C”), and the Pension Solutions Group SIPP Limited (“PSG”). L&C and
PSG are each companies authorized and regulated by the U.K. Financial Conduct Authority
(“FCA”). L&C is wholly owned by STM Group Plc, which also owns STM Malta. PSG is
indirectly wholly owned by Brite Advisory Group Limited, a Hong Kong company (“BAG”) via
its controlling interest in Basi & Basi Financial Planning Limited (“B&B”), a financial advisory
firm based in the United Kingdom. See “E. The Brite Platform,” below.
Other International Pension providers may be available through other investment advisers under
different arrangements, including but not limited to applicable fees and charges, and residency
requirements.
Clients are strongly encouraged to review their agreements with their pension trustees and any
and all other disclosure materials provided by the pension trustees or other parties for a full
understanding of the services provided by the pension trustees and any associated costs therein.
The pension trustees generally send account statements on at least an annual basis directly to
Clients. The pension trustees also make account information available online to Clients through
the investment platforms utilized in connection with International Pension arrangements. Clients
are strongly encouraged to review such
material carefully for more information about the
services offered by the pension trustees, the costs associated with the management of such
pension plans, and the activity in their accounts.
Questions regarding Brite USA’s services and fees may be addressed directly with Firm
personnel.
D. Tax Matters
Brite USA does not provide any tax advice including, without limitation, in relation to any U.S.
tax reporting requirements and/or other tax implications arising in relation to Clients’ pension
transfers. Although, from time to time, the Firm may inform Clients of tax developments, the
Firm recommends that Clients seek their own tax advice, including advice on procedures under
tax treaties between the U.S. and the U.K. (or other applicable jurisdiction) for the avoidance of
double taxation on their respective pension arrangements.
E. The Brite Platform
(Brite USA no longer recommends the Brite Platform)
The Firm has entered into a platform agreement with BAG (the “Platform Provider”), pursuant to
which BAG, through one or more of its direct and indirect wholly-owned companies, has agreed
to make available to Clients an end-to-end retirement solution that is tailored for U.K. expatriates
residing in the U.S. who desire to transfer their U.K. pension assets out of the U.K. (“Brite
Platform”). The Brite Platform also is available to Clients with existing International Pension
accounts. The Brite Platform integrates the U.K. pension asset transfer process with overseas
pension trusteeship, asset management, trading, custody, and reporting, as follows:
Service Provider
Pension Transfer Analysis Onvestor Reporting, a trading name of Basi &
Basi Financial Planning Limited.
Pension Trustees SIPPs: L&C and PSG
QROPS: MC Trustees (Malta) Ltd. (“MC
Trustees Malta”) Trireme Pension Services
and STM Malta
Investment Adviser Brite Advisors USA, Inc.
Trading and Custody Interactive Brokers (Australia) Pty. Ltd (“IB”)
Custody and Reporting Brite Advisors Pty. Ltd (Australia) (“PTY”)
Onvestor Reporting is a trading name of Basi & Basi Financial Planning Limited (“B&B”),
which is authorized and regulated by the FCA. Michael Basi, managing director of B&B, owns
a non-controlling interest in BAG. B&B is directly wholly owned by BAG. In turn, B&B directly
wholly owns PSG. Brite Advisors Pty Ltd (Pty) is directly wholly owned by Brite Advisory
Group Limited (BAG). BAG indirectly owns a non-controlling interest in MC Trustees Malta.
As consideration to BAG for making the Brite Platform available to Firm Clients, the Firm has
agreed to pay BAG a quarterly fee at the annual rate of 0.10% of the Clients’ pension assets on
the Platform (“Platform Fee”). The Firm pays the Platform Fee out of the 1% advisory fee it
charges Clients, as discussed in “Item 5. Fees and Compensation,” below. It is not a separate or
additional charge. For performing the Pension Transfer Analysis required by FCA regulation,
Onvestor Reporting charges a fee that is described in “U.K. Appropriate Pension Transfer
Advice Fee” under “Item 5 – Fees and Compensation – Additional Compensation, below.”
For existing Clients who are currently utilizing a QROPS or a SIPP from one of the pension
trustees discussed above in “C. General” under “International Pension Schemes,” the Brite
Platform is expected to offer cost savings. Accordingly, it may be in the best interest of Clients
to transfer their pension assets to the Brite Platform. To help determine whether a transfer to the
Brite Platform is in a Client’s best interest, the Firm’s IARs will provide the Client with a
comparative analysis of the fees and costs, available investment alternatives, and other features
of the Client’s current International Pension arrangement as compared to those available under
the Brite Platform (“Comparative Analysis”).
In October 2023, the Company learned of an interim consent order (“Interim Order”) by the
Australian Securities & Investments Commission (“ASIC”) involving Pty, the custodian of the
Brite Platform. See Australian Securities & Investments Commission v. Brite Advisors Pty Ltd,
ACN 135 024 412, No. WAD262/2023, Federal Court of Australia, Western District Registry
(“Australia Action”). The Interim Order and subsequent orders (“Orders”) of the Federal Court
of Australia place limitations on Pty’s ability to remove property, incur new liabilities, and
withdraw or transfer monies. The Orders apply to all property of Pty, including assets held in
accounts at Interactive Brokers (Australia) Pty. Ltd. Further, ASIC appointed “Corporate
Receivers and Managers” namely, McGrath Nicol, over Pty and its property. The Firm has
retained counsel in Australia for advice and assistance regarding the Australia Action.
F. Brite Transfer Program for Clients with Existing International Pension
Accounts
Existing Clients who wish to transfer their current International Pension to the Brite Platform
generally will incur exit fees charged by their existing pension trustees and platforms. The
amount of the exit fees will vary depending on such factors as the pension trustee, the platform,
and how long the International Pension account has been in existence. In addition, the platform
exit fees are generally a percentage of assets and can be as high as 10% of the original pension
assets invested. The specifics of the arrangement with your International Pension provider may
be different. Please review the terms and conditions of your arrangement or ask the Firm IAR
who handles your advisory account for more information, including information regarding
pension trustee fees.
To help mitigate the cost of such exit fees for Clients who decide to transfer to the Brite
Platform, PTY has agreed, for a limited time, to advance the cost of any platform exit fees
(related to the establishment fee of the life bond) imposed on transfer, subject to reimbursement
of the fees over an agreed period not exceeding 10 years. Please ask your IAR for a
Comparative Analysis and for more information.
This transfer program (“Transfer Program”) allows Clients to transfer 100% of their pension
assets to the Brite Platform. To participate in the Transfer Program, Clients must submit a
completed application to the applicable Pension Trustee and PTY for approval, which the
Pension Trustees and PTY may or may not approve in their sole discretion. PTY may modify or
terminate the Transfer Program at any time and in any manner in its sole discretion without prior
notice, except for applications it has already approved.
Non-International Advisory Services
In managing a Client’s non-international assets, Brite USA does not follow a specific investment
strategy but rather utilizes strategies driven by and tailored to each Client’s needs and specific
circumstances. In developing investment recommendations, the Firm’s IARs principally will
employ an analysis of a Client’s financial and other information regarding such matters as the
Client’s age, investment objectives, annual income, assets and debts, tax status, investment
experience, liquidity needs, risk tolerance, and employment/retirement status. For some Clients,
the Firm’s IARs may determine to seek more information in order to get a clearer picture of the
client’s overall financial situation. The Firm’s IARs do not provide tax advice regarding Client
non-international pension assets. See Item 8 below for more information regarding the types of
securities used in these Client portfolios and related supervision.
Assets Under Management
As of December 31, 2022, Brite USA had $468,148,435.00 of assets under management on a
non-discretionary basis. The Firm does not manage assets under management on a discretionary
basis.
For assets under management custodied on the Brite Platform, due to the current liquidation of
PTY (see further information at Item. 4 above) Brite USA is unable, at this time, to accurately
state the assets under management custodied on the Brite Platform for the reasons outlined by
McGrathNicol in their reports to the Federal Court of Australia. Brite USA is awaiting further
information in this regard and will update its ADV, accordingly. Please reach out to your
investment adviser representative if you have any questions.
Sponsor / Manager of Wrap Program
Brite USA does not sponsor or participate in wrap fee programs.