A. Summit Place Financial Advisors, LLC (the “Registrant”) is a limited liability company
formed on October 6, 2008 in the state of Delaware. The Registrant became registered as
an Investment Adviser Firm in October 2008. The Registrant is owned by Elizabeth
Miller, the Registrant’s Principal.
B. As discussed below, the Registrant offers to its clients (individuals, high net worth
individuals, etc.) investment advisory services, and, to the extent specifically requested
by the client, financial planning and consulting services.
INVESTMENT ADVISORY SERVICES
The Registrant provides discretionary investment advisory services on a fee-only basis.
Registrant's annual investment advisory fee shall include both discretionary investment
advisory services and financial planning and consulting services. In the event that the
client requires extraordinary planning and/or consultation services (to be determined in
the sole discretion of the Registrant), the Registrant may determine to charge for such
additional services, the dollar amount of which shall be set forth in a separate written
notice to the client.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by a client, Registrant generally
provides financial planning and consulting services inclusive of its advisory fee, as set
forth at Item 5 below (exceptions may occur based upon assets under management,
special projects, etc. for which Registrant may charge a separate fee).
Neither the Registrant nor its investment adviser representatives assist clients with the
implementation of any financial plan, unless they have agreed to do so in writing. The
Registrant does not monitor a client’s financial plan, and it is the client’s responsibility to
revisit the financial plan with the Registrant, if desired.
Furthermore, although the Registrant may provide recommendations regarding non-
investment related matters, such as estate planning, tax planning, and insurance, etc., the
Registrant does not serve as a law firm, accounting firm, or insurance agency, and no
portion of Registrant’s services should be construed as legal, accounting, or insurance
implementation services. Accordingly, the Registrant does not prepare estate planning
documents, tax returns, or sell insurance products.
To the extent requested by a client, the Registrant may recommend the services of other
professionals for certain non-investment implementation purposes (i.e. attorneys,
accountants, insurance, etc.). The client is under no obligation to engage the services of
any such recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from
Registrant and/or its representatives.
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional(s)
(i.e. attorney, accountant, insurance agent, etc.), and not the Registrant, shall be
responsible for the quality and competency of the services provided.
Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client
leaving an employer typically has four options regarding an existing retirement plan (and
may engage in a combination of these options): (i) leave the money in the former
employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is
available and rollovers are permitted, (iii) roll over to an Individual Retirement Account
(“IRA”), or (iv) cash out the account value (which could, depending upon the client’s
age, result in adverse tax consequences). If Registrant recommends that a client roll over
their retirement plan assets into an account to be managed by Registrant, such a
recommendation creates a conflict of interest if Registrant will earn new (or increase its
current) compensation as a result of the rollover. If Registrant provides a
recommendation as to whether a client should engage in a rollover or not, Registrant is
acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets
to an account managed by Registrant.
Account Aggregator Services. Registrant, in conjunction with the services provided by
ByAllAccounts, Inc., may provide its clients with access to an online platform of account
aggregation. Account aggregation services allow clients to view their complete asset
allocation, including those assets that Registrant does not manage (the “Excluded
Assets”). Registrant does not provide investment management, monitoring, or
implementation services for the Excluded Assets. Therefore, Registrant shall not be
responsible for the investment performance of the Excluded Assets. The client may
choose to engage Registrant to manage some or all of the Excluded Assets pursuant to the
terms and conditions of an Investment Advisory Agreement between Registrant and the
client.
Unaffiliated Private Investment Funds. Registrant may recommend that certain
qualified clients consider an investment in unaffiliated private investment funds.
Registrant’s role relative to the private investment funds shall be limited to its initial and
ongoing due diligence and investment monitoring services. Registrant’s clients are under
absolutely no obligation to consider or make an investment in a private investment
fund(s).
Risk Factors: Private investment funds generally involve various risk factors, including,
but not limited to, potential for complete loss of principal, liquidity constraints and lack
of transparency, a complete discussion of which is set forth in each fund’s offering
documents, which will be provided to each client for review and consideration. Unlike
liquid investments that a client may own, private investment funds do not provide daily
liquidity or pricing. Each prospective client investor will be required to complete a
Subscription Agreement, pursuant to which the client shall establish that he/she is
qualified for investment in the fund, and acknowledges and accepts the various risk
factors that are associated with such an investment.
Valuation: If Registrant bills an investment advisory fee based upon the value of private
investment funds or otherwise references private investment funds owned by the client on
any supplemental account reports prepared by Registrant, the value for all private
investment funds owned by the client will reflect the most recent valuation provided by
the fund sponsor. The current value of any private investment fund could be significantly
more or less than the original purchase price or the price reflected in any supplemental
account report.
Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded
funds are available directly to the public. Therefore, a prospective client can obtain many
of the funds that may be
utilized by Registrant independent of engaging Registrant as an
investment advisor. However, if a prospective client determines to do so, they will not
receive Registrant’s initial and ongoing investment advisory services.
In addition to Registrant’s investment advisory fee described below, and transaction
and/or custodial fees discussed below, clients will also incur, relative to all mutual fund
and exchange traded fund purchases, charges imposed at the fund level (e.g. management
fees and other fund expenses).
Socially Responsible Investing Limitations. Socially Responsible Investing involves
the incorporation of Environmental, Social and Governance considerations into the
investment due diligence process (“ESG). There are potential limitations associated with
allocating a portion of an investment portfolio in ESG securities (i.e., securities that have
a mandate to avoid, when possible, investments in such products as alcohol, tobacco,
firearms, oil drilling, gambling, etc.). The number of these securities may be limited
when compared to those that do not maintain such a mandate. ESG securities could
underperform broad market indices. Investors must accept these limitations, including
potential for underperformance. Correspondingly, the number of ESG mutual funds and
exchange traded funds are few when compared to those that do not maintain such a
mandate. As with any type of investment (including any investment and/or investment
strategies recommended and/or undertaken by Registrant), there can be no assurance that
investment in ESG securities or funds will be profitable, or prove successful. The
Registrant does not maintain or advocate an ESG investment strategy, but will seek to
employ ESG if directed by a client to do so.
Cash Positions. Registrant continues to treat cash as an asset class. As such, unless
determined to the contrary by Registrant, all cash positions (money markets, etc.) shall
continue to be included as part of assets under management for purposes of calculating
Registrant’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated
market conditions/events will occur), Registrant may maintain cash positions for
defensive purposes. In addition, while assets are maintained in cash, such amounts could
miss market advances. Depending upon current yields, at any point in time, Registrant’s
advisory fee could exceed the interest paid by the client’s money market fund.
Cash Sweep Accounts. Account custodians generally require that cash proceeds from
account transactions or cash deposits be swept into and/or initially maintained in the
custodian’s sweep account. The yield on the sweep account is generally lower than those
available in money market accounts. To help mitigate this issue, Registrant generally
purchases a higher yielding money market fund available on the custodian’s platform
with cash proceeds or deposits, unless Registrant reasonably anticipates that it will utilize
the cash proceeds during the subsequent 30-day period to purchase additional
investments for the client’s account. Exceptions and/or modifications can and will occur
with respect to all or a portion of the cash balances for various reasons, including, but not
limited to, the amount of dispersion between the sweep account and a money market
fund, an indication from the client of an imminent need for such cash, or the client has a
demonstrated history of writing checks from the account.
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Registrant will review
client portfolios on an ongoing basis to determine if any changes are necessary based
upon various factors, including, but not limited to, investment performance, fund
manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time
when Registrant determines that changes to a client’s portfolio are neither necessary nor
prudent. Clients nonetheless remain subject to the fees described in Item 5 below during
periods of account inactivity.
Client Obligations. In performing its services, Registrant shall not be required to verify
any information received from the client or from the client’s other professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify the Registrant if there is ever any change in their
financial situation or investment objectives for the purpose of reviewing, evaluating or
revising Registrant’s previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that Registrant
and its third-party service providers use to provide services to Registrant’s clients employ
various controls, which are designed to prevent cybersecurity incidents stemming from
intentional or unintentional actions that could cause significant interruptions in
Registrant’s operations and result in the unauthorized acquisition or use of clients’
confidential or non-public personal information. Clients and Registrant are nonetheless
subject to the risk of cybersecurity incidents that could ultimately cause them to incur
losses, including for example: financial losses, cost and reputational damage to respond
to regulatory obligations, other costs associated with corrective measures, and loss from
damage or interruption to systems. Although Registrant has established its systems to
reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee
that these efforts will always be successful, especially considering that Registrant does
not directly control the cybersecurity measures and policies employed by third-party
service providers. Clients could incur similar adverse consequences resulting from
cybersecurity incidents that more directly affect issuers of securities in which those
clients invest, broker-dealers, qualified custodians, governmental and other regulatory
authorities, exchange and other financial market operators, or other financial institutions.
Disclosure Statement. A copy of the Registrant’s written Brochure and Client
Relationship Summary, as set forth on Part 2A of Form ADV and Form CRS
respectively, shall be provided to each client prior to, or contemporaneously with, the
execution of the Investment Advisory Agreement.
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time,
impose reasonable restrictions, in writing, on the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2022, the Registrant had $208,017,150 in assets under management
on a discretionary basis.