DESCRIPTION OF ADVISORY FIRM
Financial Perspectives, Inc. (also referred to as “FP”, us, we, our and “Investment Adviser” through this Brochure) is a corporation
formed under the laws of the State of Minnesota. FP was registered with the SEC from 1986 to 2005; state-registered from 2005 to
early 2015 and is currently a registered investment adviser with the United States Securities and Exchange Commission. The principal
owner & President is Daniel J. Dugan, who is also a representative of FP.
We offer personalized services including: Investment Advisory, Financial Planning, Retirement Plan Consulting, Aggregation Services,
and Independent Managers services.
DESCRIPTION OF ADVISORY SERVICES AND TAILORING TO INDIVIDUAL NEEDS OF CLIENTS
The following are descriptions of our primary services:
Investment Advisory Services
FP offers Investment Advisory Services, providing clients with ongoing management over client accounts. Before engaging FP to
provide Investment Advisory Services, clients are required to enter into an Investment Advisory Agreement with FP setting forth the
terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that
is due from the client. We then begin the arrangement with an initial interview and data-gathering process to determine the client’s
individual needs, investment objectives, and risk tolerance. For individual clients, advisory services will often occur at a household
level and based on the information provided by the client. FP will tailor its Investment Advisory Services to the client’s particular need
by making investment recommendations consistent with the designated goals and objectives and identifying a mix of investments for
a diversified portfolio. The client may, at any time, impose reasonable restrictions in writing, relative to investing in certain securities
or types of securities. Clients should understand that the imposition of portfolio restrictions any affect performance of the affected
portfolio(s), either positively or negatively.
Investment Advisory Services, when appropriate, may include the acceptance of a transfer-in-kind of securities for purposes of
liquidation and reallocation and may also accept a transfer-in-kind of securities to be held as a part of the client’s overall portfolio.
Investment Advisory Services also include periodic monitoring and review of portfolio assets by FP. Such reviews are performed by
your IAR and/or CSR at times they deem appropriate to determine if investment options in the portfolio continue to match your goals
and investment objectives. If changes to the mix of investments are recommended, FP will complete the changes according to the
trading authority as granted by the Investment Advisory Agreement (see Item 16 of this Brochure for more information regarding
Investment Discretion).
Clients should also note that while Investment Advisory Services are provided with the intention of clients implementing services
through FP or through our IARs, clients are not required to do so. Clients have the option to purchase investment products that FP
recommends through other brokers or agents not affiliated with FP.
Financial Planning Services
FP may offer Financial Planning Services, which do not involve ongoing management of client accounts, but rather focus on a client’s
overall financial situation. The Financial Planning Agreement between the client and FP sets forth the terms and conditions of the
engagement (including termination), describes the scope of the services to be provided, whether the services will include advice
and/or a written financial plan, and the portion of the fee that is due from the client prior to FP commencing services.
FP may also provide advice regarding estate planning, tax planning, insurance, etc. Neither FP nor any of its IARs serve as an attorney
or accountant under an FP agreement, and no portion of FP’s services should be construed to offer such services. To the extent
requested by a client, FP may recommend the services of other professionals for certain non-investment implementation purposes
(i.e., attorneys, accountants, other insurance, etc.) including representatives of FP in their separate capacities as registered
representatives of a broker-dealer, accounting firm, and/or licensed insurance agents (see Conflict of Interest disclosures in Item 5
and Item 10). 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 FP. Note: If the
client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to
seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify us if there
is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising our previous
recommendations and/or services.
Retirement Plan Consulting Services
FP also offers Retirement Plan Consulting Services. These services include assisting sponsors of self-directed retirement plans in various
ways, including but not limited to, the selection and/or monitoring of investment alternatives (generally open-end mutual funds) from
which plan participants choose in self-directing the investment for their individual retirement plan accounts. In addition, to the extent
requested by the plan sponsor and/or under certain arrangements, FP will also provide specific investment advice to plan participants
regarding plan assets. The terms and conditions of these services will be set forth in the Retirement Plan Consulting Agreement
between FP and the plan sponsor.
FP will act as a fiduciary to the retirement plan only to the extent of FP’s provision of services and not as a retirement plan administrator
or in any other capacity. FP will not act as a named fiduciary to a retirement plan. FP acknowledges that certain services that it may
perform may constitute investment advice to the retirement plan for compensation and, as a consequence, FP may be deemed a
fiduciary as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”). FP will act
in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services
cause FP to be a fiduciary as a matter of law. Unless stated otherwise in the agreement, the parties will agree that FP (a) has no
responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management or disposition of
assets of the retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of the retirement
plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of the retirement plan or the
interpretation of the Retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does
not have the power to manage, acquire or dispose of any retirement plan assets, and (c) is not the “Administrator” of the Retirement
plan as defined in ERISA. The plan sponsor also acknowledges its status as a "named fiduciary" with respect to the control and
management of the assets held in the Account and agrees to notify FP promptly of any change in the identity of the named fiduciary
with respect to the Account. The plan sponsor will acknowledge in an executed agreement that the retirement plan account is only a
part of the retirement plan's assets, and that FP is not responsible for overall compliance of such investments with the requirements
of ERISA or any other governing law or documents.
It is the Plan Sponsor’s responsibility to provide FP, through Service Provider, with a copy of the Plan document, its accompanying
trust agreement, the summary plan description, and any amendments to the Plan document or trust agreement promptly after
adoption. Plan Sponsor will provide FP, through Service Provider, such information about the Plan as FP reasonably may request,
including without limitation, the amount and frequency of Participant and Plan Sponsor contributions, and contribution/withdrawal
rules and restrictions.
The Plan Sponsor must obtain and maintain for the term of this agreement appropriate ERISA bond coverage that satisfy the
requirements of Section 412 of ERISA, which must include coverage for FP and its IARs, and any of their respective officers, directors,
and employees, whose inclusion is required by law. It is the Plan Sponsor’s responsibility to provide evidence of the bond to FP upon
execution
of an agreement.
Account Aggregation Services
FP, in conjunction with the services provided by ByAllAccounts, Inc. and eMoney, may also provide periodic comprehensive reporting
services which can incorporate all of the client’s assets, including those investment assets that are not part of the assets managed by
FP (“Excluded Assets”). The client and/or their other advisers that maintain trading authority, and not FP, shall be exclusively
responsible for the investment performance of the Excluded Assets. FP’s service relative to the Excluded Assets is limited to reporting
and non-discretionary consulting services only, which does not include investment implementation.
Clients may also establish and hold Individual-Directed Accounts (“IDA”) at Fidelity Clearing & Custody Solutions. In some cases, the
client will have an advisory account(s) managed by FP and an IDA. The IDAs are Excluded Assets. The client, not FP, will maintain
trading authority, and shall be exclusively responsible for the investment performance of the Excluded Assets. FP’s service relative to
the Excluded Assets is limited to reporting and non-discretionary consulting services only, which does not include investment
implementation. Clients place trades themselves on Account View, existing Fidelity Retail electronic channels (Fidelity.com®, FAST®,
or wireless devices), or through a dedicated team of Fidelity phone representatives.
FP does not have trading authority for the Excluded Assets. As such, to the extent applicable to the nature of the Excluded Assets
(assets over which the client maintains trading authority vs. trading authority designated to the client or another investment
professional), the client (and/or the other investment professional), and not FP, shall be exclusively responsible for directly
implementing any recommendations relative to the Excluded Assets. FP shall not be responsible for any implementation error (timing,
trading, etc.) relative to the Excluded Assets. In the event the client desires that FP provide advisory services (whereby FP would have
trading authority) with respect to the Excluded Assets, the client may engage FP to do so pursuant to the terms and conditions of the
applicable client agreement between FP and the client.
Independent Managers
For those clients that require an enhanced and/or specialized level of investment management services, FP may also recommend that
certain clients authorize FP to allocate the active discretionary management of a portion of their assets by and/or among certain
independent investment manager(s) to be selected by FP (the “Independent Manager(s)”), based upon the stated investment
objectives of the client. FP will continue to render ongoing and continuous advisory services to the client relative to the monitoring
and review of account performance, client investment objectives, and asset allocation, for which FP shall receive an annual advisory
fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Manager(s).
Factors which FP will consider in recommending Independent Manager(s) include the client’s stated investment objective(s),
management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees
charged by the designated Independent Manager(s), together with the fees charged by the corresponding designated broker-
dealer/custodian of the client’s assets, are exclusive of, and in addition to, FP’s ongoing investment advisory fee. Please refer to Item
5 below with respect to the fees clients will incur relative to Independent Manager allocation.
MISCELLANEOUS DISCLOSURES
Client Obligations
In performing its services, FP shall not be required to verify any information received from the client or from the client’s other
designated professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify FP if there is ever any change in their financial situation or investment objectives for the purpose of
reviewing, evaluating or revising FP’s previous recommendations and/or services.
Investment Risk
Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific
investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by FP) will
be profitable or equal any specific performance level(s).
Non-Discretionary Service Limitations
Clients that determine to engage FP on a non-discretionary investment advisory basis must be willing to accept that FP cannot effect
any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that FP would
like to make a transaction for a client’s account, and client is unavailable, FP will be unable to effect the account transaction (as it
would for its discretionary clients) without first obtaining the client’s consent.
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 FP recommends that a
client roll over their retirement plan assets into an account to be managed by FP, such a recommendation creates a conflict of interest
if FP will earn new (or increase its current) compensation as a result of the rollover. If FP provides a recommendation as to whether a
client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), FP 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 FP,
whether it is from an employer’s plan or an existing IRA.
Use of Mutual Funds
While FP may recommend allocating investment assets to mutual funds that are not available directly to the public, FP may also
recommend that clients allocate investment assets to publically-available mutual funds that they could obtain without engaging FP as
an investment adviser. However, if a client or prospective client determines to allocate investment assets to publically-available mutual
funds without engaging FP as an investment adviser, they would not receive the benefit of FP’s initial and ongoing Investment Advisory
Services.
Socially Responsible (ESG) Investing Limitations
Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the
investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments:
Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages
relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management
considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not
and 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 limited 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 FP), there can be no assurance that investment in ESG securities or funds will be profitable or prove
successful. FP does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so.
If implemented, FP shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate
account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible
mandate.
WRAP FEE PROGRAM
FP does not provide portfolio management services as part of a wrap fee program.
CLIENT ASSETS UNDER MANAGEMENT
As of February 1, 2024, FP maintained $864,619,491 in regulatory assets under management. Discretionary assets were $863,515,780
and Non-Discretionary assets are $1,103,711.