Our firm manages assets for many different types of clients to help meet their financial goals while
remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is our duty to always act in
the client’s best interest. This is accomplished in part by knowing the client. Our firm has established
a service-oriented advisory practice with open lines of communication. Working with clients to
understand their investment objectives while educating them about our process, facilitates the kind
of working relationship we value.
Our firm sponsors and offers a wrap fee program, which allows clients to pay a single fee for
investment advisory services and associated custodial transaction costs. Transaction fees will be paid
by our firm based on a percentage of the dollar amount of assets in the account(s).
Our recommended custodians, Charles Schwab & Co., Inc. and Interactive Brokers, LLC, however, do
not charge transaction fees to our firm or to clients for U.S. listed equities and exchange traded funds.
Since we pay the transaction fees charged by the custodian to clients participating in our wrap fee
program, this presents a conflict of interest because we are incentivized to recommend equities and
exchange traded funds over other types of securities in order to reduce our costs. However, we have
always generally recommended clients invest in equities and exchange traded funds over other types
of securities.
Our Wrap Advisory Services
Wrap Asset Management:
We emphasize continuous and regular account supervision. As part of our asset management service,
we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”),
options, mutual funds and other public and private securities or investments. The client’s individual
investment strategy is tailored to their specific needs and may include some or all of the previously
mentioned securities. Each portfolio will be initially designed to meet a particular investment goal,
which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been
determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based
upon the client’s individual needs, stated goals, and objectives. Each client has the opportunity to place
reasonable restrictions on the types of investments to be held in the portfolio.
We may utilize Independent Money Managers, where we design an investment portfolio on a fee-only
basis for a percentage of assets in conjunction with another investment advisory firm. Before
selecting other advisers, we make sure that the other advisers are properly licensed or registered.
Fee Schedule:
Assets Under Management Annual Percentage of Assets Charge
Any Assets Up to 2.00%
Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of
your account on the last day of the previous quarter. Our fees are generally negotiable. Fees will
generally be automatically deducted from your managed account. In rare cases, we will agree to
direct bill clients. Please note that fees will be adjusted for deposits and withdrawals made during
the quarter. Unless otherwise noted in writing, our firm bills on cash. As part of this process, you
understand and acknowledge the following:
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 Fluent Financial, LLC
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Wrap Comprehensive Portfolio Management:
Our comprehensive portfolio management service encompasses asset management as well as
providing financial planning/financial consulting to clients. It is designed to assist clients in meeting
their financial goals through the use of financial investments. We conduct at least one, but sometimes
more than one meeting (in person if possible,
otherwise via telephone conference) with clients in
order to understand their current financial situation, existing resources, financial goals, and
tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may
propose an investment portfolio, consisting of exchange traded funds, mutual funds, individual
stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan,
we work with the client to establish or transfer investment accounts so that we can manage the
client’s portfolio. Once the relevant accounts are under our management, we review such accounts
on a regular basis and at least quarterly. We may periodically rebalance or adjust client accounts
under our management. If the client experiences any significant changes to his/her financial or
personal circumstances, the client must notify us so that we can consider such information in
managing the client’s investments.
We may utilize Independent Money Managers, where we design an investment portfolio on a fee-only
basis for a percentage of assets in conjunction with another investment advisory firm. Before
selecting other advisers, we make sure that the other advisers are properly licensed or registered.
Fee Schedule
Assets Under Management Annual Percentage of Assets Charge
Any Assets Up to 2.00%
Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of
your account on the last day of the previous quarter. Our fees are generally negotiable. Fees will
generally be automatically deducted from your managed account. In rare cases, we will agree to
directly bill clients. Please note that fees will be adjusted for deposits and withdrawals made during
the quarter. Unless otherwise noted in writing, our firm bills on cash. As part of this process, you
understand and acknowledge the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 Fluent Financial, LLC
A wrap fee program allows our clients to pay a specified fee for investment advisory services and the
execution of transactions. The advisory services may include portfolio management and/or advice
concerning selection of other advisers, and the fee is not based directly upon transactions in your
account.
Other Types of Fees & Expenses:
In addition to our advisory fees above, you may pay custodial fees, charges imposed directly by a
mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus
(i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to
market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities
transactions. Our firm does not receive a portion of these fees.
Clients may be charged on margin balances held in client accounts should the client request to
borrow on margin.
Wrap Fee Program Recommendations:
We do not recommend or offer the wrap program services of other providers. Our investment
advisory representatives receive a portion of the advisory fee that you pay us, either directly as a
percentage of your overall fee or as their salary from our firm. In cases where our investment
advisory representatives are paid a percentage of your overall advisory fee, this may create an
incentive to recommend that you participate in a wrap fee program rather than a non-wrap fee
program (where you would pay for trade execution costs) or brokerage account where commissions
are charged. This is because, in some cases, we may stand to earn more compensation from advisory
fees paid to us through a wrap fee program arrangement if your account is not actively traded.