Who We Are
Avantax Planning Partners, Inc. (“APP” or “Firm”), also doing business as Avantax Planning PartnersSM and Avantax
Retirement Plan Services (“RPS”), was established in 1996
1 and is an investment adviser registered with the
Securities and Exchange Commission (“SEC”) that offers a variety of investment advisory services primarily to
individuals, pension and profit-sharing plans, charitable organizations and businesses, as more fully described in this
Brochure. The Firm conducts business throughout the United States through collaborative, referral arrangements
with independent, nonaffiliated certified public accounting firms (“CPA firms”) and their accounting professionals
(“CPAs”), many of whom are registered with APP as investment adviser representatives (“Advisor Representatives”).
In turn, the Firm’s employees, such as Financial Planning Consultants (“FPCs”), internal analysts, financial planners,
and traders (collectively, “Financial Professionals”), work with the Advisor Representatives to provide investment
advisory services to you (the “client” or “prospective client”).
As of December 31, 2023, APP had $6,377,152,299 in client assets under management, of which $6,372,259,257 was
managed on a discretionary basis and$4,893,042 was managed on a non-discretionary basis.
APP is an affiliate of Avantax Investment Services, Inc. (“AIS”), a broker-dealer and government securities dealer or
broker registered with the SEC and a member of FINRA/SIPC. APP is also affiliated with Avantax Insurance AgencySM
and Avantax Insurance ServicesSM (collectively, “Avantax Insurance”) and Avantax Advisory Services, Inc. (“AAS”), an
affiliated investment adviser registered with the SEC.
APP is directly owned by Spirit Acquisitions, LLC, a wholly-owned of subsidiary of Avantax WM Holdings, Inc. that is
wholly owned by Project Baseball Sub, Inc., that is directly owned by Avantax Holdings, LLC. Avantax Holdings, LLC is
directly owned by Avantax, Inc. As a result, APP is an indirect subsidiary of Avantax, Inc. that is directly owned by
Aretec Group, Inc. DBA Cetera Holdings (“Aretec”). Aretec is a wholly-owned subsidiary of GC Two Intermediate
Holdings, Inc., and an indirect wholly-owned subsidiary of GC Three Holdings, Inc. Through common ownership by
Aretec, APP is affiliated with Cetera Financial Group, Inc. (“Cetera Financial Group”). For more information on APP’s
corporate structure, other financial industry activities and affiliations, se
e Item 10.
You, Your Advisor Representative and Our Financial Professionals
Most of APP’s client relationships originate from referrals from CPA firms and Advisor Representatives. From there,
the Firm’ FPCs work with CPA firms and Advisor Representatives by assessing each client’s investment history, goals,
objectives, and risk tolerance and determining the investment advisory products services that will meet each client’s
needs.
The investment advisory services provided by APP depend largely on the personal information you, the client,
provide to APP. For APP to provide appropriate investment advice to, or, in the case of discretionary accounts, make
appropriate investment decisions for, the client, it is very important that clients provide accurate and complete
information about their financial condition, needs and objectives. Clients may request reasonable restrictions be
applied to the investments bought, sold, or held in or on the types of investment strategies utilized in the client’s
investment advisory account(s). It is the client’s responsibility to inform APP of any changes in their financial
condition, investment objectives, personal circumstances, and such restrictions, if any, which may affect the client’s
overall investment goals and strategies.
Other employees working behind the scenes help to support our Advisor Representatives and FPCs in delivering
services and advice. Financial Services Assistants (“FSAs”) process paperwork and client service requests. Internal
analysts help assemble, review, and monitor the individual components of client investment portfolios. Financial
planners design investment proposals and financial plans, especially for those clients with unique needs. Traders
perform transaction activity for clients’ advisory accounts as a centralized trading desk. Additionally, APP’s
investment advisory committee (“IAC” or “Committee”), chaired by the Firm’s Chief Investment Officer, monitors
the current state of the economy and markets, researches and selects the various investments and investment
strategies for APP, and analyzes and reports on the performance of such investment strategies.
1 Avantax Planning Partners, Inc. was formerly known as Honkamp Krueger Financial Services, Inc. or HK Financial
Services (“HKFS”).
March 28, 2024 Form ADV Part 2A Disclosure Brochure Page 5 of 28
The exact products and services you will receive and the fees you will be charged are dependent upon, and
negotiated between, you, your Advisor Representative and/or our Financial Professionals. Advisor Representatives
and Financial Professionals, in their capacity as APP advisors, are restricted to providing investment advisory services
and charging fees in accordance with the descriptions detailed in this Brochure and are instructed to consider the
individual needs of each client when recommending any investment advisory product or service and negotiating fees
for such. However, as more fully described in
Item 10, many of APP’s Advisor Representatives and Financial
Professionals are also registered representatives of APP’s affiliated broker-dealer, AIS, and/or licensed insurance
agents with Avantax Insurance. Depending on such factors, there are restrictions on and conflicts of interest related
to the types of financial products and/or services that APP can or is willing to offer to you.
It is important that you understand the differing products and fees available in investment advisory, brokerage
and insurance services. APP encourages you to discuss this with your Financial Professionals. Additionally, there are
free and simple tools available to research firms and financial professionals
at Investors.gov/CRS, which also provides
educational materials about broker-dealers, investment advisers, and investing.
An Overview of Investment Advisory Services
Prior to engaging APP to provide investment advisory services, each client will be required to enter into a written
agreement setting forth the terms and conditions of services, including client specific fee information. Clients
obtaining asset (portfolio) management services will also be required to enter into a separate custodial agreement
with Charles Schwab & Co., Inc. (“Schwab”), whereas clients obtaining certain retirement planning services (“RPS”)
will be required to enter into a separate custodial agreement with Fidelity Brokerage Services, LLC. (“Fidelity”) (each
a ”custodian” and collectively, “custodians”).
Most clients engage APP on a discretionary basis, which means APP will make investment decisions without the
client’s prior authorization. Clients who engage APP on a non-discretionary basis are responsible for making all final
investment decisions and, in some instances, the implementation of any recommendation. For example, under a
non-discretionary agreement APP will be unable to affect any investment transactions (as it would for its
discretionary investment advisory clients) without first obtaining the client’s consent. Some investment advisory
services are only available on a discretionary or non-discretionary basis, as further described below.
For certain investment advisory services, APP utilizes custodian-sponsored programs and services and third-party
investment manager programs. These services may be offered as a separately managed account (commonly referred
to as “SMAs”). APP will provide such custodians and investment managers, as applicable, client-specific information
to enable that custodian or investment manager to provide the elected services. Custodian-sponsored programs,
third-party investment managers, and other third-parties may require different account eligibility requirements
and/or minimum asset levels. These additional requirements will be set forth in the information provided by your
Financial Professionals, including, but not limited to, the applicable third-party’s disclosures or agreement(s).
Some of APP’s investment advisory services are subject to conditions, such as a minimum account size (or asset level)
or minimum annual fee, and/or restrictions, such as being available only to certain types of clients (e.g., retirement
plans or accredited investors). APP does not participate in nor sponsor any wrap fee programs. Additional information
about APP’s investment advisory services is provided below.
Asset (Portfolio) Management Services
Managed Account Services
Most of APP’s investment advisory clients are invested in one or more of APP’s style allocation model strategies
(“SAMs” or “investment strategies”) through its managed account services, that are overseen by APP’s investment
advisory committee (“IAC” or “Committee”), chaired by the Firm’s Chief Investment Officer. The IAC monitors the
current state of the economy and markets, researches and selects the various investments and investment strategies
for APP, and analyzes and reports on the performance of such investment strategies.
Prior to participating in any of APP’s SAMs, the client and Financial Professionals complete an Investment Policy
Statement (“IPS”) in order to establish the client’s investment objectives and potential constraints to achieving those
objectives, as well as cover any reasonable restrictions imposed by the client. The IPS documents the client’s 1)
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overall investment objectives, 2) overall risk tolerances, and 3) investment time horizon, among other factors.
Generally, APP’s SAMs are mapped to a client’s overall risk tolerance based on the client’s overall asset allocation
(by account) to equities (stocks), as follows:
Overall Risk
Tolerance
Equity (Stock)
Asset Allocation Range
Income 0 – 20%
Conservative 10 – 30%
Moderately Conservative 30 – 50 %
Moderate 50 – 70%
Growth 70 – 90%
Aggressive 80 – 100%
Using this information, APP’s Financial Professionals determine the most appropriate SAM(s) for the client’s account.
APP then uses the discretionary authority granted by you (the client) to manage the account. From time to time,
market conditions, withdrawals and deposits, and other factors cause investment allocations to vary from the
recommended allocations aligned with each particular SAM (or account). To remain consistent with the target
investment allocations established for each particular SAM, rebalancing of investments will be performed by APP’s
Financial Professionals. Additionally, the Committee may recommend strategic adjustments to style allocations
based on changing market conditions. In addition, the Committee monitors and adjusts investment vehicles that
represent each style based on style weighting changes or relative performance to peers. Internal analysts then
regularly monitor these investments to verify that they continue to meet the performance criteria set forth by the
IAC.
Note: In the event a client has assets (in an APP managed account) held outside of APP’s SAM(s), your Financial
Professionals/Advisor Representative may use differing methods of analysis and investment strategies in formulating
investment advice or managing assets and those assets may be subject to differing or additional risks. APP
encourages you to discuss this with your Financial Professionals/Advisor Representative.
The IPS is considered a dynamic document that changes over time to reflect your changing life circumstances. Such
changes naturally affect your goals, objectives, time horizon and feelings about risk in your account. Your Financial
Professional will meet with you to review your IPS at least annually. S
ee Item 13 for additional information on review
of accounts.
Under the APP’s managed account services, generally, the client is separately assessed and pays for investment
advisory, portfolio management and trade execution. S
ee Item 5 for additional information regarding fees, expenses
and costs.
Tax-Intelligent Investing: If elected by the client and/or Financial Professional, a tax-intelligent investment strategy
(also referred to
as a tax-managed investment strategy or tax overlay strategy) may be applied to a taxable account.
A tax-managed investment strategy considers tax implications related to after-tax returns while staying as consistent
as possible with the risk/return characteristics of the selected investment strategy or SAM. There are no guarantees
as to the effectiveness of the tax-managed investing strategy and clients will be impacted differently. The client is
solely responsible for ensuring that all positions and tax lots in the account have complete and accurate cost basis
information at all times. APP does not (itself) provide legal or tax advice or services and clients should discuss any
questions with or request further information from the Financial Professional and/or legal and tax professionals prior
to engaging in a tax overlay strategy. See
Item 8 for additional considerations and risks related to employing a tax
overlay strategy.
Retirement Investors: When we (APP and your Financial Professional) provide investment advice to you (the client)
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 of 1974, as amended (“ERISA”) and/or the Internal Revenue
Code, as amended (“IRC”), as applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests. We have a conflict of interest with you when we recommend a rollover /
transfer of retirement assets and receive more compensation as a result. We mitigate this conflict of interest by
providing you with relevant information, reviewing that information with you, answering your questions, and
recommending only alternatives that we believe are in your best interest. We have provided you with other required
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disclosures, along with your account terms and conditions and/or advisory agreement that describe the specific
services we will perform and/or terms and conditions of our relationship with you. This is important information so
please read it carefully.
Compass
In addition to APP’s SAMs, APP offers Compass an automated investment program through which clients are
invested in a range of investment strategies that APP has constructed and managed, each consisting of a portfolio
of ETFs and a cash allocation.
APP is solely responsible for determining the appropriateness of Compass for the client, choosing a suitable
investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an
ongoing basis. APP have contracted with Schwab Performance Technologies (“SPT”), a software provider and an
affiliate of Schwab, to provide APP with access to the Institutional Intelligent Portfolios® platform (“IIP Platform”),
which consists of technology and account management services for Compass. The IIP Platform enables APP to make
Compass available to clients online and includes a system that automates certain key parts of our investment process
(the “System”). The System also includes an automated investment engine through which APP manages the client’s
portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and
elects).
Generally, APP’s Compass investment strategies are mapped to a client’s overall risk tolerance based on the client’s
overall asset allocation (by account) to equities (stocks) and fixed income (bonds), as follows:
Overall Risk
Tolerance
Equity (Stock) / Fixed Income (Bond)
Asset Allocations
Conservative (P1) 0% / 100%
Conservative (P2) 10% / 90%
Conservative (P3) 20% / 80%
Conservative (P4) 30% / 70%
Conservative (P5) 40% / 60%
Moderate (P6) 50% / 50%
Moderate (P7) 60% /40%
Moderate (P8) 70% / 30%
Moderate (P9) 75% / 25%
Moderate (P10) 80% / 20%
Aggressive (P11) 90% / 10%
The client may indicate an interest in a portfolio that is one level less or more conservative or aggressive than the
recommended portfolio, but APP then makes the final decision and selects a portfolio based on all the information
provided by the client. Additionally, clients may instruct APP to exclude up to three (3) ETFs from the client’s Compass
portfolio.
Collateralized, Non-Purpose Loan Program
APP offers a collateralized, non-purpose loan program made available through its affiliate broker-dealer (AIS), the
affiliate’s custodian (NFS), and a lender, currently Goldman Sachs Bank USA (the “Bank”). The minimum account
valuation, as determined by the Bank, to participate in the program is currently $125,000. S
ee Item 7 for additional
information regarding program minimums.
Under the collateralized, non-purpose loan program, borrowers may use the securities in an advisory account as
collateral for an extension of credit, the proceeds of which may be used for any (legal) purpose except purchasing or
trading new securities in the collateralized account. In exchange, the borrower pays a fee (interest rate) and gives the
Bank a first priority (perfected) security interest in the collateral. APP’s affiliate, AIS, receives a referral fee from the
fee (interest rate) paid by the borrower. Additional information about the fees, including related conflicts of interest,
is described in
Item 14.
There are specific risks involved when participating in a collateralized, non-purpose loan program. For example, if
the collateralized securities decrease in value below the contract threshold, borrowers may have to pay down the
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loan, deposit more collateral or sell holdings without recourse. Such actions would generally trigger tax consequences
and eliminate the potential for future returns from the securities sold. Additionally, some lenders charge variable
interest, others may offer a range of terms and conditions based on the diversification and holdings of each client’s
collateralized portfolio. For example, under APP’s collateralized, non-purpose loan program, the interest rate is
calculated by adding your spread to 1-Month Term Secured Overnight Financing Rate (“SOFR” as published by CME
Group Benchmark Administration Limited, also known as Term SOFR. Term SOFR is a forward-looking measurement
of the SOFR published by the Federal Reserve Bank of New York. More information about Term SOFR may be found
at: https://www.cmegroup.com/market-data/cme-groupbenchmark-administration/term-sofr.html.
The requirements to participate in the collateralized, non-purpose loan program, including approval (or denial) of
credit, and additional terms and restrictions are determined at the sole discretion of the Bank. For additional
information, refer to the Bank’s disclosure(s) and the applicable agreement(s).
APP may offer other collateralized, non-purpose loan programs available through Schwab. For additional information,
please contact your Financial Professional.
Financial Planning and Other Investment Consulting Services
To the extent requested by a client, APP may provide financial planning and/or investment consulting services. Such
services may be on a stand-alone basis or included in APP’s asset management services. APP’s financial planning and
investment consulting fees are negotiable, depending upon the level and scope of the service(s) required and the
Financial Professional(s) rendering the service(s).
The advice you receive from APP’s financial planning and other investment consulting services is intended for your
use only. You are responsible for making all final decisions and, in some instances, the implementation of any
recommendations, unless otherwise agreed to in writing. Before implementing any recommendations, you should
carefully consider the ramifications of purchasing products or services, and you may want to seek further advice
from your lawyer and/or accountant, particularly in connection with estate planning, taxes, or business financial
planning issues.
The recommendations provided may be implemented through APP, its affiliates or other financial services providers
through separate written agreement(s). However, you are not obligated to implement any of the recommendations
provided by APP.
Retirement Plan Services
APP’s Avantax Retirement Plan Services (“RPS”) is a managed account platform specifically designed for qualified
retirement plans including, but not limited to, 401(k), profit sharing, defined benefit, and 403(b) (each the “plan”
and “client”). Note: APP does not offer retirement plan services to non-qualified plans, Solo(k), SEP IRAs or SIMPLE
IRAs and does not design its programs, including RPS, for municipal or other government entities as these are
prohibited account types under APP’s policies. Se
e Item 7 for additional information about types of clients APP and
its Financial Professionals generally provide investment advisory services too.
To the extent requested by a client, through the RPS Agreement, APP and its Financial Professionals may perform all
or some of the following services:
• Plan Investment Management Services: Under APP’s investment management services for plans, APP may
provide such services as investment menu design and review, investment policy statement guidance,
contract review for re-pricing and product enhancements. Generally, these services will constitute
“investment advice” under Section 3(21)(A)(ii) of ERISA with respect to ERISA retirement plans. Additionally,
under APP’s investment management services for plans, APP offers investment strategies, which provide
plans with access to a wide variety of mutual funds. The investment strategies are managed by APP as an
“investment manager” under Section 3(38) of ERISA with respect to ERISA retirement plans.
• Other Plan-Related Services: A Financial Professional may provide other plan-related services, such as plan
participant education, enrollment assistance, or service provider analysis, whereby neither APP nor its
Financial Professionals are acting as an “investment manager” or a “fiduciary” under ERISA with respect to
ERISA retirement plans.
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To participate in APP’s RPS services, a plan (client) must open an account through Fidelity (custodian). Under APP’s
RPS services, APP is responsible for providing recordkeeping and administrative services to the plan (and its
participants).
APP in its sole discretion may add or remove custodians; however, the final decision to utilize Fidelity is made by the
clients. Before selecting a custodian, a client should discuss with their Financial Professionals the differing services
(including, but not limited to directed trustees, custodians, clearing and execution services), fees and costs. For more
information about Fidelity’s services, clients should refer to the custodian’s disclosure(s) and applicable
agreement(s). S
ee Item 5 an
d Item 12 for additional information on fees, compensation, brokerage practices and
related conflicts of interest.
ERISA Section 408(b)(2) Disclosure: When APP is engaged to provide investment advisory services for a client that is
subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), APP is a “covered service
provider” to the plan for purposes of ERISA Section 408(b)(2) and the applicable regulations. This Brochure, the ERISA
Section 408(b)(2) Disclosure, and the disclosures included in the written agreement between the ERISA client and APP
are intended to provide fee disclosures in accordance with the requirements of ERISA Section 408(b)(2).
Plan Participant Disclosure: Unless directly engaged by the plan participant (individually) to do so through a separate
written agreement, APP does not provide individualized investment advice to plan participants. If you, a plan
participant, engage APP to provide individualized investment advice for your retirement plan accounts (e.g., 401(k) or
403(b)), APP’s advice (for that account) is generally limited to the investment options approved by the plan.