Crumly and Associates, Incorporated was founded in 2011 and is primarily owned by Kevin W.
Crumly, Chairman of the Board and Chief Compliance Officer.
We provide portfolio management services to individuals, high net worth individuals, pension
and profit-sharing plans, charitable organization and corporations or other business entities.
We also provide financial planning services to individuals.
Portfolio Management Services
We provide continuous investment advice and portfolio management services based on the
individual needs of its clients. Through personal discussions in which goals and objectives based
on a client’s particular circumstances are established, we develop and manage a portfolio based
on the client’s needs. We will ensure that each client’s investments are suitable for that client
and consistent with their investment needs, goals, objectives and risk tolerance. Account
supervision is guided by the stated objectives of the client (i.e., capital preservation, income
with moderate growth, growth and income, growth, and aggressive growth, etc.). It is our
practice to tailor our advisory services to the individual needs of clients.
Clients will have the opportunity to place reasonable restrictions on the types of investments
which will be made on the client’s behalf. Clients will retain individual ownership of all
securities.
We will make investment decisions for clients and allocate our clients’ investment management
assets, on a discretionary or a non-discretionary basis among mutual funds, exchange traded
funds, individual debt and equity securities, real estate investment trusts (REITs) and other
investments in accordance with the investment objectives of the client. Some or all of these
investments may have limited or no liquidity for a period of time. Some investments may
require additional minimum net worth and/or net income. We may also provide advice about
any type of investment held in a client’s portfolio.
Our clients are advised to promptly notify us if there are ever any changes in their financial
situation or investment objectives or if they wish to impose any reasonable restrictions upon
our management services.
Retirement Plan Services
We are held to the prudent expert standard of care under ERISA, accepting the fiduciary
responsibility of providing advice as the plan’s Investment Manager (providing discretionary
advice) or Investment Advisor (non-discretionary advice) services to defined contribution and
benefit plans. Bundled under our fiduciary roles we develop, review and continually maintain
the plan’s investment policy statement (IPS), prepare periodic investment monitoring reports,
provide a broad range of investment options consistent with ERISA section 404c-1, select
investment to serve as the qualified default investment alternative (QDIA), if applicable and
periodically conduct and record trustee review meetings.
Supplemental plan services may include fiduciary education for the plan sponsor, assist in
managing the plan’s service providers, provide fee and service analysis to ensure reasonable
expenses are paid within the plan and the cost is consistent with all service agreements,
assist/or provide participant enrollment and education meetings, develop and maintain risk-
based investment portfolios, provide participant-level investment assistance, risk analysis and
retirement projection calculations.
Financial Planning
We offer integrated financial planning services which include a review of all aspects of a client’s
current financial situation or limited to certain areas of financial planning (al a carte financial
planning). Areas of analysis that may be included in an integrated financial plan are: retirement
planning, education planning, major purchase planning, life insurance needs, disability income
insurance needs, long-term care needs and estate planning needs. A description of each area of
financial planning is described below:
Retirement Planning: A written analysis will be prepared which will evaluate a client’s
retirement readiness. Retirement readiness is defined as one’s ability to replace a percentage
of pre-retirement income throughout retirement. Important factors include but are not limited
to: desired retirement age, assets available for retirement, inflation, investment rate of return,
lifestyle expenses, tax rates and minimum asset level required at death. Approximate time
needed to complete Retirement Planning is 2 to 10 hours.
Education Planning: A written analysis will be prepared that will project future college
education expenses and the required savings to meet those expenses. Important factors
include but are not limited to: number of children attending college, school of choice, existing
assets available for future college expenses, projected number of years of attending college,
inflation, investment rate of return. Approximate time needed to complete Education Planning
is estimated to be 1 to 5 hours.
Major Purchase Planning: A written analysis will be prepared that will project the future
savings required to achieve a major purchase goal such as a second home or start a business.
Important factors include but are not limited to: desired future goal amount, existing assets
available for future goal, inflation and investment rate of return. Approximate time needed to
complete Major Purchase Planning is estimated to be 1 to 5 hours.
Life Insurance Needs: A written analysis will be prepared that will calculate the desired amount
of life insurance a client should presently own. Important factors include but are not limited to:
Family size, family income, age, percentage of income to replace, lifestyle expenses, amount of
existing life insurance, current assets, health, funding for future college expenses, net worth,
emergency fund requirements, liabilities, inflation and investment rate of return. Approximate
time needed to complete Life Insurance Needs Planning is 4 to 12 hours.
Disability Income Insurance Needs: A written analysis will be prepared that will calculate the
desired
amount of disability income insurance a client should own. Important factors include
but are not limited to: Family income, age, health, years to retirement, lifestyle expenses,
percentage of income to replace, current assets, inflation and investment rate of return.
Approximate time needed to complete Disability Income Insurance Needs Planning is estimated
to be 1 to 5 hours.
Long Term Care Needs: A written analysis will be prepared that will estimate the future cost of
potential long-term care expenses and the effect those expenses may have on a client’s net
worth and lifestyle. Important factors include but are not limited to: Age, health, income,
current assets, desired percentage of LTC expenses to cover, inflation and investment rate of
return. Approximate time needed to complete Long-Term Care Needs Planning is estimated to
be 1 to 5 hours.
Estate Planning Needs: A written analysis will be prepared that will: estimate future federal and
state estate taxes, provide strategies to minimize estate taxes and provide recommended
action steps to implement desired estate planning goals. Clients will obtain a report to share
with their estate planning attorney in order for the creation of estate planning documents.
Important factors include but are not limited to: composition of net worth, income, taxes,
current estate planning documents, inflation and investment rate of return. Approximate time
needed to complete Estate Planning is estimated to be 4 to 15 hours.
Clients understand that when we are asked to perform an al a carte financial planning
engagement, the client’s overall financial status may not be taken into consideration. A signed
engagement letter will be used to establish and define the client / planner relationship.
In order to perform the financial planning engagement, we may request financial and personal
information such as sources of income, assets/investments, liabilities, insurance policies,
income tax returns, wills, trusts and personal and family obligations.
After analyzing and evaluating a client’s financial status goals and objectives, a written financial
plan with recommendations will be presented to the client. We will then assist in the
implementation of agreed upon strategies. The client is under no obligation to utilize our
additional services and is under no obligation to implement the advice or plan. Clients may
choose all, none or certain specific components of advice and recommendations and may
implement recommendations through service providers of their choice.
Use of Independent Managers
We may recommend that you authorize the active discretionary management of a portion of
your assets by independent investment manager(s) (“Independent Manager(s)”). The terms and
conditions under which you will engage the Independent Manager(s) will be set forth in a
separate written agreement between you and the Independent Manager(s). We will continue
to provide you with advice about the selection of Independent Manager(s) as well as
monitoring and review of your investment objectives and account performance.
When selecting an Independent Manager for you, we will review information about them from
their Form ADV, materials which they may supply and/or information from independent third
parties. Factors that we consider in selecting Independent Manager(s) include your investment
objective(s), and the Independent Manager’s investment style, performance, risks, reputation,
financial strength, reporting, pricing, and research.
We do not receive compensation for the recommendation of Independent Managers.
Sponsor and Manager of Wrap Program
We do not participate in a Wrap Fee Program.
Fiduciary Statement
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act,
(“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing
retirement accounts.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Client Assets
As of December 31, 2023, we managed $840,908,605 in assets under management;
$530,795,785 on a discretionary basis, and $310,112,820 on a non-discretionary basis.