This Disclosure document is being offered to you by The Advisory Resource Group, LLC,
d.b.a. Compass Pointe Financial, LLC (“ARG” or “Firm”) about the investment advisory
services we provide. It discloses information about our services and the way those services
are made available to you, the client.
We are an investment management firm located in Tulsa, OK. We make our advisory
services available to a wide variety of clients including, but not limited to, individuals,
pension and profit sharing plans, trusts, estates, charitable organizations, corporations and
business entities. Our Firm became a registered investment adviser in October 2017.
Benjamin Steele owns 100% of the firm.
We are committed to helping clients build, manage, and preserve their wealth, and to
provide assistance that helps clients to achieve their stated financial goals. We will offer an
initial complimentary meeting upon our discretion; however, investment advisory services
are initiated only after you and our firm executes an Investment Management Agreement.
Investment and Wealth Management and Supervision Services
We manage advisory accounts on a discretionary and non-discretionary basis. For
discretionary accounts, once we have determined a profile and investment plan with a
client, we will execute the day to day transactions without seeking prior client consent.
Account supervision is guided by the written profile and investment plan of the client. We
primarily allocate client assets among various mutual funds, exchange-traded funds
(“ETFs”), and individual debt (bonds) and equity securities in accordance with their stated
investment objectives. All of which are considered asset allocation categories for the
client’s investment strategy.
During personal discussions with clients, we determine the client’s objectives, time
horizons, risk tolerance and liquidity needs. As appropriate, we also review a client’s prior
investment history, as well as family composition and background. Based on client needs,
we develop and document in writing, a client’s personal profile and investment plan. We
then create and manage the client’s investments based on that policy and plan.
It is the client’s obligation to notify us immediately if circumstances have changed with
respect to their goals.
Once we have determined the types of investments to be included in your portfolio and
allocated them, we will provide ongoing investment review and management services.
This approach requires us to periodically review your portfolio.
If a discretionary relationship is in place, we will rebalance the portfolio, as we deem
appropriate, to meet your financial objectives. We trade these portfolios and rebalance
them based on the combination of our market views and your objectives, using our
investment process. We tailor our advisory services to meet the needs of our clients and
seek to ensure that your portfolio is managed in a manner consistent with those needs and
objectives
In all cases, you have a direct and beneficial interest in your securities, rather than an
undivided interest in a pool of securities. We do have limited authority to direct the
Custodian to deduct our investment advisory fees from your accounts, but only with the
appropriate written authorization from you.
Where appropriate, we provide advice about any type of legacy position held in client
portfolios. Typically, these are assets that are ineligible to be custodied at our primary
custodian. Clients will engage us to advise on certain investment products that are not
maintained at their primary custodian, such as variable life insurance, annuity contracts
and assets held in employer sponsored retirement plans and qualified tuition plans (i.e.,
529 plans).
You are advised and are expected to understand that our past performance is not a
guarantee of future results. Certain market and economic risks exist that adversely affect
an account’s performance. This could result in capital losses in your account.
Disclosure Regarding Rollover Recommendations
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 and/or the Internal Revenue Code, 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.
A client or prospect 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) rollover 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). Our Firm may recommend an investor
roll over plan assets to an IRA for which our Firm provides investment advisory services.
As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a
recommendation that a client or prospective client leave their plan assets with their
previous employer or roll over the assets to a plan sponsored by a new employer will
generally result in no compensation to our Firm. Our Firm therefore has
an economic
incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various
factors that our Firm will consider before recommending a rollover, including but not
limited to: (i) the investment options available in the plan versus the investment options
available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an
IRA, (iii) the services and responsiveness of the plan’s investment professionals versus
those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required
minimum distributions and age considerations, and (vi) employer stock tax consequences,
if any. Our Firm’s Chief Compliance Officer remains available to address any questions that
a client or prospective client has regarding the oversight.
ERISA Section 3(21) Investment Advisory Services
For employer-sponsored retirement plans with participant-directed investments, ARG
provides its advisory services as an investment advisor as defined under Section 3(21) of
the Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
When serving as an ERISA 3(21) investment advisor, the plan sponsor and ARG share
fiduciary responsibility. The plan sponsor retains ultimate decision-making authority for
the investments and may accept or reject the recommendations in accordance with the
terms of a separate ERISA 3(21) Investment Advisor Agreement between ARG and the plan
sponsor. ARG provides the following services to the plan sponsor:
• Screen investments and make recommendations.
• Monitor the investments and suggests replacement investments when
appropriate.
• Provide a quarterly monitoring report.
• Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
Our goal in identifying the plan’s investment options is to provide a range of options that
will enable plan participants to invest according to varying risk tolerances, savings time
horizons or other financial goals. The plan's investment options may consist of ETFs, CITs,
mutual funds, model portfolios, or other similar investment funds. The investment funds
from which our Firm will select from will be those that are available on the plan record-
keeper’s investment platform.
We will prepare an IPS for the plan. The purpose of the IPS is to provide guidelines for
making investment-related decisions in a prudent manner. It outlines the underlying
philosophies and processes for the selection, evaluation, monitoring, and, if necessary,
replacement of the investment options offered by the plan. We will perform on-going
monitoring of the investment options within the plan. The ongoing monitoring of
investments is a regular and disciplined process. Monitoring confirms that the criteria
remain satisfied and that an investment option continues to be appropriate. The process
of monitoring investment performance relative to specified guidelines will be consistently
applied.
We will make available to participants, either through the provider’s recordkeeping
platform, a stand-alone form, or a third-party web-site, a risk tolerance questionnaire. The
questionnaire’s sole purpose is to provide participants with general assistance in order to
identify their risk tolerance and investment objectives and, based on this information, help
determine which investment is most aligned with their risk tolerance/investment
objectives.
Consulting Services
We also provide clients investment advice on a more-limited basis on one-or-more isolated
areas of concern such as legacy positions, otherwise non-commissionable assets, estate
planning, real estate, retirement planning, or any other specific topic. Additionally, we
provide advice on non-securities matters about the rendering of estate planning,
insurance, real estate, and/or annuity advice or any other business advisory / consulting
services for equity or debt investments in privately held businesses. In these cases, you will
be required to select your own investment managers, custodian and/or insurance
companies for the implementation of consulting recommendations. If your needs include
brokerage and/or other financial services, we will recommend the use of one of several
investment managers, brokers, banks, custodians, insurance companies or other financial
professionals ("Firms"). You must independently evaluate these Firms before opening an
account or transacting business and have the right to effect business through any firm you
choose. You have the right to choose whether to follow the consulting advice that we
provide.
Wrap Fee Program
We are the sponsor and manager of The Advisory Resource Group Wrap Program (the
“Program”), a wrap fee program (i.e., an arrangement where brokerage commissions and
transaction costs are absorbed by the Firm). The fee covers transaction costs or commis-
sions resulting from the management of your accounts, however, most investments trade
without transaction fees today, so our payment of these and other incidental custodial
related expenses should not be considered a significant factor in determining the relative
value of our wrap program. Participants in the Program may pay a higher aggregate fee
than if brokerage services are purchased separately. Additional information about the Pro-
gram is available in The Advisory Resource Group’s Wrap Brochure, which appears as Part
2A Appendix 1 of the Firm’s Form ADV.
Assets
As of December 31, 2023, we have $546,877,508 discretionary assets under management
and $168,624,011 non-discretionary assets under management.