Firm Description
Black Diamond Financial, LLC (“BDF” or “Advisor”) has been in business since August 9,
2007, and the principal owners are Matthew P. Goette and Lindsay D. Dryden, IV through
his control of the Dryden Capital Management Trust.
Black Diamond Financial, LLC is a fee-only registered investment adviser with a unique
and holistic focus on preserving and enhancing wealth. Our mission is to help you
achieve your financial goals through the use of low cost, tax-efficient investment
strategies. We create individualized investment portfolios for each client that are risk-
appropriate, return optimized, and tax-efficient. Where appropriate, we incorporate
institutional quality private investments to capture illiquidity premiums or yield
opportunities. Furthermore, we believe cost is a critical factor in any successful
investment strategy and therefore offer fully transparent pricing that is below industry
standard. As an employee-owned firm focused on our fiduciary duty, we make our
clients’ interests our highest priority.
Types of Advisory Services
ASSET MANAGEMENT
Black Diamond Financial’s principal offering is providing investment advisory services
based on each Client’s specific investment objectives, goals, and financial situation. Black
Diamond Financial creates customized portfolios, on a discretionary and non-
discretionary basis, according to each Client’s objectives. Black Diamond Financial will
consider mutual funds, exchange traded funds, stocks, foreign issuers, options,
municipal, government and corporate debt securities, real estate, CDs, and other
investments when tailoring a Client’s Investment Policy Statement (“IPS”).
FINANCIAL PLANNING AND CONSULTING
If extensive financial planning services are applicable, the Client will compensate Black
Diamond Financial on an hourly fee or negotiable fixed fee basis described in detail
under the “Fees and Compensation” section of this brochure. The advisor may
recommend selling positions for reasons that include, but are not limited to, harvesting
capital gains or losses, business or sector risk exposure to a specific security or class of
securities, overweighting of the position(s) in the portfolio, change in risk tolerance of
the Client or any risk deemed unacceptable for the Client’s risk tolerance.
Representatives of Black Diamond Financial may also provide general non-securities
advice on topics including estate planning, retirement planning, social security, taxes,
insurance, and mortgage consulting.
PRIVATE POOLED INVESTMENT VEHICLES
We provide specialized advisory services to private pooled investment vehicles herein
referred to as "the Funds" (or if individually, "the Fund"). The Funds are unregistered
investment companies organized as limited partnerships. Investments in the Funds are
not registered under the Securities Act of 1933, as amended, and are only offered after
delivery of a private placement memorandum and execution of the subscription
agreement and other offering documents. Investments in the Funds are offered only to
accredited investors within the meaning of SEC Rule 501 of Regulation D of the
Securities Act of 1933. Some Funds are offered only to qualified clients as defined within
the meaning of Rule 205-3 under the Advisers Act. Investments in the Funds are offered
by private offering memorandum which provides investors with full disclosure
regarding the objectives of the Funds, the risks involved with the offering and the
minimum initial capital contribution or commitment required.
Different strategies may be carried out for each Fund and therefore, there should be no
expectation that the performance of any individual Fund would or should be similar to
that of any other Fund. You should refer to the subscription agreement and other
offering documents for a complete description of the fees, investment objectives, risks,
and other relevant information associated with investing in the Funds. The Funds
undergo an independent audit annually by a Public Company Accounting Oversight
Board ("PCAOB") registered firm.
BDF does not use its discretionary trading authority to authorize purchases of the Funds.
Instead, clients must complete and sign the required paperwork before the purchase is
processed. BDF charges advisory fees each quarter for the sale of the Funds.
ERISA PLAN SERVICES
Black Diamond Financial offers service to qualified and non-qualified retirement plans
including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance
plans, and deferred compensation plans. Black Diamond Financial may act as a 3(38)
advisor:
3(38) Investment Manager. Black Diamond Financial can also act as an ERISA 3(38)
Investment Manager in which it has discretionary management and control of a given
retirement plan’s assets. Black Diamond Financial would then become solely responsible
and liable for the selection, monitoring and replacement of the plan’s investment
options.
1. Fiduciary Services include:
Advisor has discretionary authority and will make the final decision
regarding the initial selection, retention, removal and addition of investment
options in accordance with the Plan’s investment policies and objectives.
Assist the Plan Sponsor with the selection of a broad range
of investment
options consistent with ERISA Section 404(c) and the regulations
thereunder.
Assist the Plan Sponsor in the development of an investment policy
statement. The IPS establishes the investment policies and objectives for the
Plan.
Provide discretionary investment advice to the Plan Sponsor with respect to
the selection of a qualified default investment alternative for participants
who are automatically enrolled in the Plan or who have otherwise failed to
make investment elections. The Plan Sponsor retains the sole responsibility
to provide all notices to the Plan participants required under ERISA Section
404(c) (5).
Assist in monitoring investment options by preparing periodic investment
reports that document investment performance, consistency of fund
management and conformance to the guidelines set forth in the IPS and make
recommendations to maintain, remove or replace investment options.
Meet with Plan Sponsor on a periodic basis to discuss the reports and the
investment recommendations.
2. Non-fiduciary Services include:
Assist in the education of Plan participants about general investment
information and the investment alternatives available to them under the
Plan. The Advisor’s assistance in education of the Plan participants shall be
consistent with and within the scope of the Department of Labor’s definition
of investment education (Department of Labor Interpretive Bulletin 96-1). As
such, the Advisor is not providing fiduciary advice as defined by ERISA to the
Plan participants. Advisor will not provide investment advice concerning the
prudence of any investment option or combination of investment options for
a particular participant or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial
understanding by the employees.
Black Diamond Financial may provide these services or, alternatively, may arrange for
the Plan’s other providers to offer these services, as agreed upon between Advisor and
Plan Sponsor.
3. Black Diamond Financial has no responsibility to provide services related to the
following types of assets (“Excluded Assets”):
a. Employer securities;
b. Real estate (except for real estate funds or publicly traded REITs);
c. Stock brokerage accounts or mutual fund windows;
d. Participant loans;
e. Non-publicly traded partnership interests;
f. Other non-publicly traded securities or property (other than collective
trusts and similar vehicles); or
g. Other hard-to-value or illiquid securities or property.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objective. Clients may impose
restrictions on investing in certain securities or types of securities. However, if the
restrictions prevent Black Diamond Financial from properly servicing the Client’s
account, or if the restrictions would require Black Diamond Financial to deviate from its
standard suite of services, Black Diamond Financial reserves the right to end the
relationship. Agreements may not be assigned without written Client consent.
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.
We benefit financially from the rollover of your assets from a retirement account to an
account that we manage or provide investment advice, because the assets increase our
assets under management and, in turn, our advisory fees. As a fiduciary, we only
recommend a rollover when we believe it is in your best interest.
Wrap Fee Programs
Black Diamond Financial does not participate in any wrap fee programs.
Client Assets under Management
As of December 31, 2023, Black Diamond Financial had the following regulatory assets
under management:
Type of Account Regulatory Assets Under Management
Discretionary $623,843,614
Non-Discretionary $77,583,597
Total: $701,427,211