Firm Description
Plotkin Financial Advisors, LLC (PFA) is an SEC- registered investment adviser with our principal place
of business located in Chevy Chase, Maryland. The firm was established in 2003 by Shimshon
Plotkin. Effective January 2, 2024 Oceanview Consultants, LLC became the owner of the firm. We
became registered with the SEC in 2015.
As used in this brochure, the words "we," "our," and "us" refer to Plotkin Financial Advisors, LLC (PFA)
and our Investment Adviser Representatives and the words "you," "your," and "client" refer to you as
either a client or prospective client of our firm.
PFA is the portfolio manager to and sponsor of a wrap fee program to provide portfolio management
services to individuals through Charles Schwab and Co. (Schwab). A wrap-fee program is a type of
investment program that provides clients with asset management and brokerage services for one all-
inclusive fee. If you participate in our wrap fee program, you will pay our firm a single fee, which
includes money management fees, certain transaction costs, and custodial and administrative costs.
You are not charged separate fees for the respective components of the total services. We receive a
portion of the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee
program may be higher or lower than you might incur by separately purchasing the types of securities
available in the Program.
Prior to becoming a client under the Program, you will be required to enter into a separate written
agreement with us that sets forth the terms and conditions of the engagement and describes the scope
of the services to be provided, and the fees to be paid.
Schwab's Brokerage Services
In addition to the foregoing portfolio management, the program includes brokerage services of Charles
Schwab & Co., Inc. ("Schwab"), a broker/dealer registered with the Securities and Exchange
Commission and a member of FINRA and SIPC. Plotkin Financial Advisors is independently owned
and operated and is not affiliated with Schwab. Schwab will act solely as a custodian and not as an
investment adviser to you. It will have no discretion over your account and will act solely on instructions
it receives from us or you. Schwab has no responsibility for our services and undertakes no duty to you
to monitor our management of your account or other services we provide to you. Schwab will hold your
assets in a brokerage account and buy and sell securities and execute other transactions when we or
you instruct them to. While we recommend that you use Schwab as custodianto participate in our
program, you will decide whether to do so and open your account with Schwab by entering into an
account agreement directly with them. If you do not wish to place your assets with Schwab, then we
cannot manage your account in the program. Not all advisers require their clients to use a particular
broker/dealer or other custodian selected by the adviser. Even though your account is maintained at
Schwab, we can still use other brokers to execute trades for your account as described below.
Schwab executes trades, settles securities transactions and maintains custody of client assets for
advisory accounts on behalf of PFA. Client's portfolio will be allocated among cash, stocks, bonds,
exchange traded funds (ETFs), alternative investment products and other securities.
PFA's compensation in a wrap account is the balance of the wrap fee after all other costs incorporated
into the wrap fee have been deducted (i.e. transaction costs). There is no significant difference
between how PFA manages wrap fee accounts and non-wrap fee accounts.
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We tailor the advisory services we offer to the individual needs of our clients. A client interested in any
of our company's services will begin by having one or more meetings with one of our investment
advisory representatives. We use these meetings to gather information such as: retirement and
financial goals, investment objectives, risk tolerance, time horizon, financial needs, cash flow needs,
estate planning objectives, and additional information to help us review a client's current financial and
investment situation and expectations of a relationship with PFA. We will then evaluate a client's
current investment strategy and financial situation and develop recommendations including investment
strategies, asset allocation, and insurance and estate planning if applicable. The investment advisory
representative will then present the recommendations to the client. The decision to implement any of
the recommendations is entirely up to you as the client. You may also impose restrictions and/or
limitations on investing in certain securities or types of securities.
Portfolio Management Services
Each client's portfolio is customized to the client. For clients interested in portfolio management
services an investment advisor representative (IAR) will gather information about the client's financial
condition, investment objectives, risk tolerance, time frame, and other information in the PFA Client
Profile Form. PFA will examine a client's entire investment portfolio, including taking into consideration
the client's employer retirement accounts, if possible, and design an asset allocation specific to the
client. PFA provides its IARs with model portfolios that may be utilized as guidelines. Advisors can use
the models, modify them or not use them at all. PFA's objective is to establish a suitable allocation for
the client across all the client's investment holdings in an attempt to reduce risk and market volatility.
PFA offers asset management services on a discretionary and nondiscretionary basis. If discretionary
authority is granted, PFA may purchase or sell investments on behalf of the client without obtaining
prior consent for each transaction. Discretionary authority will be granted to PFA by execution of the
Investment Advisory Agreement. If nondiscretionary service is elected, no changes will be made to the
allocation of the account without prior consultation and expressed agreement. PFA will provide
continuous and ongoing management of your account.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent
advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest.
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Additional Services
Based on a client's individual needs, PFA provides the following additional services:
Estate Planning - Coordinate estate planning documents. Assist others in implementation of
recommendations that minimize tax consequences and create a more efficient disposition of assets.
PFA and its investment adviser representatives do not prepare estate planning documents or provide
legal advice. Fees for this service are in addition to legal fees from third parties, all of which will be
borne by the client.
Insurance Counseling - Identify life insurance needs, evaluate and coordinate existing insurance
coverage. All insurance selections are the responsibility of the client. Investment adviser
representatives may be compensated in their separate capacity as insurance agents for any policies
that are sold, in addition to the fee for this service. Any other incidental insurance costs or legal fees
from third parties are the responsibility of the client.
Tax Planning - Provide general information on tax consequences and strategies. PFA and its
investment adviser representatives do not prepare tax returns or provide tax advice. Client will need to
refer to their tax professional for specific advice and any incidental fees charged are in addition to the
fees for this service. Clients are advised to consult with their tax professionals and attorneys for all
specific tax and legal matters.
Clients with fee-based assets under management of $1 million or more with PFA are eligible for the
PFA Signature Services Program. Limits are negotiable for clients with fee-based assets under
management with PFA of $5 million or more. Upon an eligible client's request, PFA will agree to pay a
portion of the preparation fees for the following:
•Preparation and/or amendment of U.S. person wills. (not to exceed
$2,000 every 5
years)
•Preparation of U.S. personal tax returns. (not to exceed $1500 per year)
We offer financial planning services which may be comprehensive or limited in scope depending on a
client's particular needs. The financial plan may include, but is not limited to, review and prioritization of
a client's goals and objectives, development of a net worth statement, cash flow summary and
insurance analysis, review of investment holdings, and development of an investment management
strategy. A financial plan may also include financial projections and analysis, in addition to education
funding, tax, retirement and estate planning analyses.
Plans are based on your financial situation at the time and are based on financial information disclosed
by you to PFA. Clients are advised to consult with their tax professional and attorneys for all specific
tax and legal matters. Clients are also advised to notify us immediately of changes to their financial
status, goals, risk tolerance, or any other items of relevance that could impact the advice provided in
their financial plan.
You do not have to implement the financial plan or advice provided by PFA. However, if you do utilize
our services in implementing all or a portion of the financial plan, PFA and/or its advisory
representatives will receive additional compensation.
Fees
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Plotkin Financial Advisors is compensated though an annualized asset-based fee, which will be paid
quarterly in advance, as indicated in the table below.
Portfolio ValueAnnual Wrap Advisory Fee
$0 - $2,500,0001.10%
$2,500,000 - $5,000,0001.00%
Over $5,000,000Negotiable
The advisory fee is debited directly from advisory accounts by the custodian (Schwab) and remitted to
PFA per the client's advisory contract and provided the client has given PFA written authorization.
Fees are negotiable and are not based on a share of capital gains upon or capital appreciation of the
funds or any portion of the funds. The management fee is a percentage of the market value of the
assets in the account and is agreed upon with the client in the asset management contract prior to the
onset of service. The account management fee will be payable quarterly in advance and will be
calculated as a percentage of the market value of all assets in the account on the last business day of
each calendar quarter. The initial advisory fee for accounts established during a calendar quarter will
be stated and charged the first full calendar quarter unless the account is opened within the first 10
days of the quarter during which it will be charged a prorated portion of the fee for the current quarter.
Fees are calculated on margin accounts by using the value of the account which includes the margin.
The value will be higher than the market value of the account resulting in an increased fee.
PFA, its advisors, or the client may terminate this fee-based relationship at any time by providing
written notification to the other. In such a circumstance, the quarterly fee will be pro-rated based on the
number of days the account was open during the current quarter and the client will be refunded any
pre-paid, unearned fees. No fee adjustments will be made for additional deposits to the account or
partial withdrawals from the account or for account appreciation or depreciation during the calendar
quarter. PFA aggregates all your managed accounts together to determine your annual wrap advisory
fee. PFA can change the above fee schedule upon 30-days prior written notice to you. An account
statement will be provided reflecting the deduction of the advisory fee direct from the account
custodian. If the account does not contain sufficient funds to pay advisory fees, PFA has limited
authority to sell or redeem securities in sufficient amounts to pay advisory fees. The client may
reimburse the account for advisory fees paid to PFA, except for ERISA and IRA accounts.
Fees for financial planning services are covered by the fees charged for portfolio management
services described above. PFA does not charge additional fees for financial planning services.
Relative Cost of Wrap Fee Program to You
The program will cost you more or less than purchasing our investment advice and Schwab's
brokerage services separately. The relative cost of our wrap fee program to you is influenced by
various factors, including the cost of our investment advice, other wealth management services and
Schwab's brokerage services if you purchased them separately, the types of investments held in your
account, and the frequency and size of trades we make for your account. In addition to the costs
described above, we pay Schwab certain other fees that it would otherwise charge you. These fees
include (a) flat dollar per trade fees for Schwab's prime brokerage and trade away services (through
which we can have trades for your account at Schwab executed by broker- dealers other than
Schwab), (b) custody and setup fees for alternative investments (such as non- standard assets, non-
publicly traded limited partnership interests, foreign securities, non- marketable securities, etc.).
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Additional Investment Fees: Clients will indirectly incur certain fees and expenses for investments
made for the Account in mutual funds, ETFs, money market funds, and other Assets. The fees and
expenses are paid by the respective fund and are borne by all fund shareholders owning the same
class of share which can include, but are not limited to, mutual fund servicing fees, sub-accounting
fees, management fees, custody, portfolio transaction execution costs, administration fees, distribution
fees, and shareholder servicing fees. Fees and expenses charged by these securities are deducted
from each fund's net asset value and as such, are an indirect expense of the client. Finally, these types
of investments can be purchased directly, without being managed by PFA pursuant to this Agreement
which may cost the client more or less.
Additional Fees and Expenses:Other administrative fees charged for wire transfers and check writing
services are not included in PFA's advisory fee. By investing with certain third-party money managers
and/or by making direct investments, client may incur fees, brokerage commissions, transaction fees,
manager's fees, custody fees, and other related costs and expenses. Such third-party charges, fees
and commissions are exclusive of and in addition to PFA's Advisory Fee.
Commission Assets Excluded from Advisory Fees: Advisory accounts may hold assets or products that
were sold to the client by PFA representatives in their separate capacity as registered representatives
and therefore charged a commission. The commissions are charged by our selected Broker-Dealer,
currently Independent Financial Group ("IFG"), and a portion of these commissions gets paid to PFA
representatives in their separate capacities as registered representatives. These commissions are
exclusive of, and in addition to, PFA's portfolio management fees. This means assets that were
charged the commission, will not be charged the ongoing asset management fee. The commissions
and fees assessed by our chosen Broker- Dealer may be higher or lower than what is otherwise
available through other broker-dealers.
Advisory Representatives of PFA are dually registered representatives of Independent Financial
Group, LLC ("IFG"), a registered broker/dealer, member of the Financial Industry Regulatory Authority
(FINRA) and SIPC. Advisory Representatives of PFA, who are Registered Representatives, receive
trail commissions (i.e. 12b-1 fees) for a period of time as a result of directing securities transactions
through IFG. Certain load and no-load mutual funds pay annual distribution charges, sometimes
referred to as 12b-1 fees. 12b-1 fees come from fund assets, therefore, indirectly from the client's
assets. 12b-1 fees are be initially paid to IFG and a portion passed to the Advisory Representatives.
The receipt of such fees represents an incentive for the Advisory Representatives to recommend funds
with 12b-1 fees over funds that have no fees or lower fees.
Advisory Fees in General: Clients should note that similar advisory services may (or may not) be
available from other registered (or unregistered) investment advisers for similar or lower fees.
Depending on the trading activity and the transactions costs we incur, we may receive more
compensation from your participation in our wrap fee program than if you purchased our investment
advisory services and Schwab's (or another broker/custodian's) services separately.
These practices and our arrangement with Schwab present a conflict of interest and give PFA an
incentive to recommend our services and Schwab's services, regardless of a client's needs. PFA will
attempt to mitigate conflicts of interest by:
•Informing you of conflict of interest in this Disclosure Brochure.
•Maintaining and abiding by our Code of Ethics which requires us to place your
interest first and foremost.
•Routine review of transactions and our relationship with the broker/custodian
•Advising you of the right to decline to implement our recommendations and the
right to choose other financial professionals for implementation.
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•Recognizing and advising you that PFA is a fiduciary and has an obligation to
conduct its business in the best interest of its clients and not in PFA's interest.