A. Description of the Advisory Firm
This firm has been in business since 12/31/2010, and the principal owner is Daniel Scott
McLeod.
B. Types of Advisory Services
Brown Financial Advisory (hereinafter “BFA”) offers the following services to advisory
Clients:
Wealth Management
Wealth Management is the holistic combination of Investment Supervisory Services
and a multi-disciplined approach to Financial Life Planning. Wealth Management
Services, as outlined below, are available to every Client who meets the minimum
annual fee (see Item 5 below):
Investment Supervisory Services
For Wealth Management clients, BFA offers ongoing portfolio management services
based on the individual goals, objectives, time horizon, and risk tolerance of each
Client. BFA creates an investment strategy that outlines the Client’s current
situation (income needs, tax levels, and risk tolerance levels) and then constructs a
plan (the Investment Policy Statement) to aid in the selection of a portfolio that
matches each Client’s specific situation. Investment Supervisory Services include,
but are not limited to, the following:
• Investment Strategy • Personal Investment Policy
• Asset Allocation • Asset Selection
• Personal Risk Assessment • Portfolio Monitoring
• Periodic Rebalancing • Tax-Sensitive Asset Location
• Income Sourcing • Behavioral Coaching
BFA evaluates each Client’s investments with respect to their risk tolerance levels
and time horizon. BFA will request discretionary authority from Clients to select
securities and execute transactions without permission from the Client prior to each
transaction. Clients may elect not to provide discretionary authority. Risk tolerance
levels are documented in the Investment Policy Statement, which is given to each
Client.
Retirement Rollovers-No Obligation/Conflict of Interest
A client leaving an employer typically has four options (and may engage in a
combination of these options): 1) leave the money in his former employer’s plan,
if permitted, 2) roll over the assets to his/her new employer’s plan, if one is
available and rollovers are permitted, 3) rollover to an Individual Retirement
Account (IRA), or 4) cash out the account value (which could, depending upon the
client’s age, result in adverse tax consequences).
BFA may recommend an investor roll over plan assets to an IRA managed by
BFA. As a result, BFA may earn an asset-based fee; however, a recommendation
that a client or prospective client leave their plan assets with their old employer
will result in no compensation. BFA has an economic incentive to encourage an
investor to roll plan assets into an IRA that BFA will manage.
There are various factors that BFA may consider before recommending a rollover,
including but not limited to: i) the investment options available in the plan versus
the investment options available in an IRA, ii) fees and expenses in the plan
versus the fees and expenses in an IRA, iii) the services and responsiveness of
the plan’s investment professionals versus those of BFA, iv) required
minimum
distributions and age considerations, and vi) employer stock tax consequences, if
any. No client is under any obligation to roll over plan assets to an IRA managed
by BFA.
Financial Life Planning
Each Wealth Management engagement utilizes Financial Life Planning, a multi-
disciplined approach to helping families and individuals achieve their personal
financial goals. The Financial Life Planning process may include, but is not limited
to: goal setting, data organization, investment planning, insurance planning and risk
management, tax concerns, retirement planning, estate plan summaries, college
planning and spending plan strategies. Financial Life Planning services are
available as part of a Wealth Management engagement and the cost is included
in the Wealth Management engagement fee schedule.
Hourly Financial Planning
Financial Planning services may be provided based on an hourly fee arrangement
(see below). When provided separate from the Wealth Management engagement,
the final fee structure is documented in Exhibit I of the Financial Planning Services
Agreement.
Pension Consulting Services
BFA offers ongoing consulting services to pension or other employee benefit plans
(including but not limited to 401(k) plans) based on the demographics, goals, objectives,
time horizon, and/or risk tolerance of the plan’s participants. Pension consulting
services may be provided on a non-discretionary basis (when serving as a 3(21) advisor)
or a discretionary basis (when serving as a 3(38) advisor) and BFA only places trades
on behalf of the participants as part of its 3(38) pension consulting services.
Services Limited to Specific Types of Investments
BFA limits its investment advice and/or money management to mutual funds, equities,
bonds, fixed income, debt securities, ETFs, real estate, hedge funds, private equity,
third-party money managers, REITs, insurance products including annuities, and
government securities. BFA may use other securities as well to help diversify a portfolio
when applicable.
C. Client-Tailored Services and Client-Imposed Restrictions
BFA offers the same suite of services to all its Clients. However, specific Client financial
plans and their implementation are dependent upon the Client Investment Policy
Statement which outlines each Client’s strategy and is used to construct a Client specific
plan to aid in the selection of a portfolio that matches restrictions, needs, and targets.
Clients may impose restrictions in investing in certain securities or types of securities in
accordance with their values or beliefs. However, if the restrictions prevent BFA from
properly servicing the Client account, or if the restrictions would require BFA to deviate
from its standard suite of services, BFA reserves the right to end the relationship.
D. Wrap Fee Programs
BFA does not participate in any wrap fee programs.
E. Amounts Under Management
BFA has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$248,380,102 $2,673,309 12/31/2022