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A D V B R O C H U R E
2100 Georgetown Drive
Suite 600
Sewickley, PA 15143
Telephone: 412-630-6000
Email: jjones@billfew.com
www.billfew.com
March 31, 2025
This brochure provides information about the qualifications and business practices of Bill Few
Associates, Inc. If you have any questions about the contents of this brochure, please contact John
Jones at 412-630-6000 or jjones@billfew.com. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any state
securities authority.
Bill Few Associates, Inc. is a registered investment advisor. Registration does not imply a certain
level of skill or training.
Additional information about Bill Few Associates, Inc. is also available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD
number. The CRD for Bill Few Associates, Inc. is 133561.
Part 2A of Form ADV and other important information relating to accounts with Bill Few
Associates, Inc. can be found at www.billfew.com/bfa-disclosures.
ITEM 2: MATERIAL CHANGES
The last annual update of the Form ADV Part 2A was March 1, 2024
The following material changes occurred since the last Form ADV update:
• Bill Few Associates, Inc. main office has moved to 2100 Georgetown Drive, Suite 600, Sewickley, PA 15143.
• Updated Item 8 Methods of Analysis to reflect currently used methodologies.
• Updated Item 8 to include Risks of Leveraged and Inverse ETFs and Penny Stocks. Bill Few Associates, Inc. does
not recommend these types of investments.
• Updated Item 8 to include Market Disruptions and other Impacts of Force Majeure Events.
Additional minor updates and clarifications occur throughout this document and we encourage you to read the entire Brochure.
We may, at any time, update this Brochure. We will send you a copy or offer you a copy (either by electronic means or
in hard copy form), as required by regulations.
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TABLE OF CONTENTS
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ITEM 1:
COVER PAGE
ITEM 2:
MATERIAL CHANGES
ITEM 3:
TABLE OF CONTENTS
ITEM 4:
ADVISORY BUSINESS
ITEM 5:
FEES AND COMPENSATION
ITEM 6:
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
ITEM 7:
TYPES OF CLIENTS
ITEM 8:
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
ITEM 9:
DISCIPLINARY INFORMATION
ITEM 10:
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
ITEM 11:
CODE OF ETHICS
ITEM 12:
BROKERAGE PRACTICES
ITEM 13:
REVIEW OF ACCOUNTS
ITEM 14:
CLIENT REFERRALS AND OTHER COMPENSATION
ITEM 15:
CUSTODY
ITEM 16:
INVESTMENT DISCRETION
ITEM 17:
VOTING CLIENT SECURITIES
ITEM 18:
FINANCIAL INFORMATION
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SCHEDULE A
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ITEM 4: ADVISORY BUSINESS
Bill Few Associates, Inc. is a SEC-registered investment adviser with its principal place of business located in Pittsburgh,
Pennsylvania. Bill Few Associates, Inc. began conducting business in 1987.
Bill Few Associates, Inc. is a wholly owned subsidiary of Bill Few Financial Group, Inc. (BFFG), which is owned by the Bill
Few Associates, Inc. Employee Stock Ownership Trust.
Bill Few Associates, Inc. offers the following advisory services to our clients:
INDIVIDUAL PORTFOLIO MANAGEMENT
Our firm provides continuous advice to clients regarding the investment of client funds based on the individual needs of the
client. Through personal discussions in which goals and objectives, based on a client's particular circumstances are
established, we help develop a client's personal investment strategy and create and manage a portfolio based on those findings.
During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity
needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and
background.
We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the
client's stated objectives (i.e., capital appreciation, growth, income, or growth and income), as well as tax considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors.
Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance
company and will generally include advice regarding the following types of securities:
Common Stock
Commercial Paper
Certificates of Deposit
Corporate Bonds
Government Bonds
Municipal Bonds
Mutual Funds/ETF's
Options
Preferred Stock
Variable Annuities
Because some types of investments involve certain additional degrees of risk, they will only be implemented or recommended
when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability.
MUTUAL FUND MODEL PORTFOLIOS
Our firm provides portfolio management services to clients through our Managed Mutual Fund Account program. We manage
these accounts on a discretionary or non-discretionary basis. Each model portfolio is designed to meet a particular investment
goal.
Through personal discussions with the client in which the client’s goals and objectives are established, a client’s base
allocation is determined (i.e., equities/fixed income/cash). Account supervision is guided by the client’s stated objectives as
well as tax considerations, where appropriate.
In the program, our base asset allocation is determined through ongoing fundamental and technical research. The allocation
is also discussed at our firm’s Investment Policy Committee meetings. Through this research and discussions, it is determined
how much we allocate to each investment category (ex. large-cap, small-cap, international, short-term bond, high-yield bond,
etc.). At this point, we match our firm’s base allocation with the client’s investment needs to form a model created specifically
to meet a particular client’s investment goals. The accounts are managed to that individual model, although our firm may
change the allocation as market conditions change. The accounts are rebalanced periodically as performance moves them
away from the appropriate percentages.
Mutual funds are the primary investment vehicle, although our investment recommendations are not limited to any specific
product or service offered by a broker-dealer or insurance company and will generally include advice regarding the same
security types identified earlier in this section under Individual Portfolio Management.
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Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended
when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability.
To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be
managed in a manner consistent with the client's financial circumstances, we will periodically send reminders to clients
requesting them to review their account information and to provide us with any updated information regarding changes in
their financial situation and investment objectives.
We also conduct periodic meetings with clients to review their accounts and to update their objectives and risk tolerance as
well as their suitability profile.
AMERICAN FUNDS F-2 DIRECT PROGRAM
The American Funds F-2 Direct Program is a non-discretionary, fee-based program that facilitates investments into American
Funds F-2 share class offerings directly held at the American Funds. Monies invested in this program are limited to the
American Funds family, unlike our other fee-based programs which have an extensive list of available securities. Generally,
the F-2 share class offerings have a higher cost than the F-3 that are available in the BFA Wrap Fee program when held at
Pershing Advisory Solutions. Other differences of this program include account related fees, billing, and account minimums.
The minimum fund investment is $250 per fund ($1,000 for money market or tax-exempt funds) as specified in the funds’
prospectus. Currently American Funds charges a one-time $10 set up fee and a $10 per annum custodial fee for IRAs and
Coverdell ESA accounts.
Through personal discussions with the client in which the client’s goals and objectives are established, a client’s base
allocation is determined (i.e., equities/fixed income/cash). Account supervision is guided by the client’s stated objectives as
well as tax considerations, where appropriate.
Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended
when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability.
To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be
managed in a manner consistent with the client's financial circumstances, we will periodically send reminders to clients
requesting them to review their account information and to provide us with any updated information regarding changes in
their financial situation and investment objectives.
We also conduct periodic meetings with clients to review their accounts and to update their objectives and risk tolerance as
well as their suitability profile.
FINANCIAL PLANNING
We provide financial planning services, which entails a comprehensive evaluation of a client’s current and future financial
state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial
planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial
and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed
financial plan designed to assist the client to achieve his or her financial goals and objectives.
In general, the financial plan can address any or all of the following areas:
Personal Financial Planning: We review family records, budgeting, personal liability, estate information and financial
goals.
Tax & Cash Flow Analysis: We analyze the client’s income tax, spending and planning for past, current and future years;
then illustrate the impact of various investments on the client’s current income tax and future tax liability.
Investment Planning: We analyze investment alternatives and their effect on the client's portfolio.
Insurance Needs Analysis: We review existing policies to ensure proper coverage for life, health, disability, and long-term
care.
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Retirement Planning: We analyze current strategies and investment plans to help the client achieve his or her retirement
goals.
Death & Disability Needs Analysis: We review the client’s cash needs at death, income needs of surviving dependents,
estate planning and disability income.
Estate Planning: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts,
wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law.
As part of the planning process, we gather required information through in-depth personal interviews. Information gathered
may include the client's current financial status, tax status, future goals, performance objectives and attitudes towards risk.
We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written
report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely
with his/her attorney, accountant, insurance agent, and/or investment professional. Implementation of financial plan
recommendations is entirely at the client's discretion.
We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and
business planning.
Typically, the financial plan is presented to the client within three months of the contract date, provided that all information
needed to prepare the financial plan has been promptly provided. Please note, we are not a law firm, attorney, accounting or
tax adviser. Our financial planning services should not be interpreted as legal or tax advice.
CONSULTING SERVICES
Clients can also receive investment advice on a more focused basis. This may include advice on only an isolated area(s) of
concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and
administrative services regarding investment and financial concerns of the client.
As some individuals of Bill Few Associates, Inc. are licensed as insurance agents of various insurance companies, insurance
recommendations are limited to only those products offered through these companies.
RETIREMENT ACCOUNTS
Clients, and prospective clients, considering a rollover from a qualified employer sponsored retirement plan (“Employer
Retirement Plan”) to an Individual Retirement Account (“IRA”) are encouraged to consider the advantages and disadvantages
of an IRA rollover from their existing Employer Retirement Plan.
A plan participant leaving an employer typically has four options (and may engage in a combination of these options): 1)
Leave the money in the former Employer Retirement Plan, if permitted; 2) Transfer the assets to the new employer’s plan, if
one is available and if rollovers are permitted; 3) Rollover the assets to an IRA; 4) Cash out (or distribute) the assets and pay
the taxes due.
Investors may face increased fees when they transfer retirement savings from their current Employer Retirement Plan to an
IRA. Investors are advised that even if there are no costs associated with the IRA rollover itself, there will be costs associated
for account administration, investment management or both. In addition to the fees charged by Bill Few Associates, Inc., the
underlying investments (mutual fund, ETF, annuity, or other investment) typically also charge management fees. Custodial
fees may also apply. Investing in an IRA managed by Bill Few Associates, Inc. is typically more expensive than the current
Employer Retirement Plan. Investors should inquire with their retirement plan sponsor about the costs and other fees
associated with their current plan in order to compare their options.
While individuals of Bill Few Associates endeavor at all times to put the interests of the clients first as part of our fiduciary
duty, clients should be aware that the additional compensation paid to Bill Few Associates and their financial professional
when the choice is made to distribute and rollover the proceeds of an Employer Retirement Plan account to an IRA with our
firm is a conflict of interest. Conflicts of interest are mitigated through discussions between the investor and the financial
professional.
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When we provide investment advice to you regarding your retirement accounts, 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 certain conflicts with your interests, so we operate under PTE 2020-
02, where applicable, a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under
PTE 2020-02, when providing individualized investment advice to retirement investors, we must also:
• Meet a professional standard of care (give prudent advice);
• Not put our financial interests ahead of yours (give loyal advice);
• Avoid misleading statements about our 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 our conflicts of interest.
AMOUNT OF MANAGED ASSETS
As of December 31, 2024, we were actively managing assets of $2,035,163,666 on a discretionary basis and an additional
$607,806,332 of assets on a non-discretionary basis for a total of $2,642,969,998.
ITEM 5: FEES AND COMPENSATION
The advisory fee will be disclosed prior to services being provided and agreed upon in a written investment advisory
agreement.
Our advisory fees for portfolio management are based upon a percentage of assets under management and generally range
from .25% to 1.25%.
Our Standard Fee Schedule is a tiered schedule and is billed as follows:
Tier
First
Next
Next
Above
Asset Level
$ 500,000
500,000
500,000
1,500,000
Annual Rate
1.25%
1.00%
.75%
.50%
Generally, advisory fees are billed quarterly in advance and calculated based on the account’s market value (including cash
and cash equivalents) on the last business day of the prior quarter. Fees for new accounts, and for new deposits into existing
accounts, will be pro-rated based on the remaining number of days left in the quarter. Accounts within the same household,
and set to the same tiered fee schedule, can be combined for breakpoint purposes.
Fees are debited directly from the client’s Pershing account unless the client requests to pay by invoice in which an invoice
will be sent to the client detailing the advisory fees for the upcoming quarter.
For advisory accounts in which the management fee is directly deducted from their account, the client's custodian is advised
by Bill Few Associates, Inc. of the fee amount that is to be deducted. On at least a quarterly basis, the custodian is required
to send to the client a statement showing all transactions within the account during the reporting period, including the fee
amount.
Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review
their account statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if
they believe that there may be an error in their statement.
Generally, a minimum of $250,000 of assets under management is required for portfolios comprised mainly of individual
equities or individual bonds. The minimum account size for portfolios predominantly comprised of mutual funds is $50,000.
The account size may be negotiable under certain circumstances. Bill Few Associates, Inc. may group certain related client
accounts for the purposes of achieving the minimum account size and determining the annualized fee.
Although Bill Few Associates, Inc. has established the aforementioned fee schedule, we retain the discretion to negotiate
alternative fees on a client-by-client basis which represents a conflict of interest. Client facts, circumstances and needs are
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considered in determining the fee schedule. These include the complexity of the client assets to be placed under management;
anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The
specific annual fee schedule is identified in the contract between the financial professional and each client.
Discounts, not generally available to our advisory clients, may be offered to family members and friends of associated persons
of our firm.
AMERICAN FUNDS F-2 DIRECT PROGRAM
American Funds F-2 Direct Program fees are calculated and debited by American Funds quarterly in arrears in the second
month of each calendar quarter and is based upon the accounts average daily balance. The program’s advisory fee is a flat fee
that ranges between .25% - 1.25%. Billing is handled by American Funds and fees are deducted from the client account.
Assets are held directly with American Funds in the F-2 share class, which have no 12b-1 fees but have a higher cost than
their F-3 share class equivalent. There is a $10 set up fee charged by the American Funds and an annual $10 custodial fee for
IRAs and Coverdell ESAs. We do not receive any compensation from the setup and custodial fees. The client must
acknowledge and agree to allow American Funds to liquidate shares of the funds held in order to cover any applicable advisory
or account service fees.
Although Bill Few Associates, Inc. has established the aforementioned fee schedule, we retain the discretion to negotiate
alternative fees on a client-by-client basis which represents a conflict of interest.
FINANCIAL PLANNING FEES
Bill Few Associates, Inc.'s Financial Planning fee is determined based on the nature of the services being provided and the
complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client.
Our Financial Planning fees are calculated and charged on a fixed fee basis, typically ranging from $500 to $5,000, depending
on the specific arrangement reached with the client.
We may request a retainer upon completion of our initial fact-finding session with the client; however, advance payment will
never exceed $500 for work that will not be completed within six months. The balance is due upon completion of the plan.
CONSULTING SERVICES FEES
Bill Few Associates, Inc.'s Consulting Services fee is determined based on the nature of the services being provided and the
complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client.
Our Consulting Services fees are calculated and charged on an hourly basis, ranging from $200 to $300 per hour. An estimate
for the total hours is determined at the start of the advisory relationship.
OTHER REVENUE
Bill Few Associates Inc. is licensed to sell insurance products in addition to its advisory business. Certain investment
personnel of our firm are agents for various insurance companies. As such, these individuals are able to receive separate, yet
customary commission compensation resulting from implementing product transactions on behalf of advisory clients. Clients,
however, are not under any obligation to engage these individuals when considering the implementation of advisory
recommendations. The implementation of any or all recommendations is solely at the discretion of the client.
Bill Few Associates, Inc. permits third party payments/reimbursements for advisor education, seminars and entertainment.
While these individuals endeavor at all times to put the interest of the clients first as part of Bill Few Associates, Inc.'s
fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and may
affect the judgment of these individuals when making recommendations.
GENERAL INFORMATION
Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either party, for any reason
upon receipt of written notice. As disclosed above, certain fees are paid in advance of services provided. Upon termination of
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any account, any prepaid, unearned fees will be promptly refunded. In calculating a client’s reimbursement of fees, we will
pro-rate the reimbursement according to the number of days remaining in the billing period after the effective date of the
termination.
Mutual Fund Fees: All fees paid to Bill Few Associates, Inc. for investment advisory services are separate and distinct from
the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in
each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution
fee. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services
provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds
are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees
charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate
the advisory services being provided.
Mutual Fund Share Classes: Many mutual fund companies currently offer multiple share classes of their funds, each with
a different expense structure. Often, financial institutions, such as investment advisers, are eligible to buy for their advisory
clients lower cost shares than are available to retail customers. Bill Few Associates annually performs a review of the mutual
funds held (and/or recommended) in its advisory accounts to ensure that its advisory clients are holding the lowest cost shares
available to them. If during the annual review, a lower cost share class mutual fund is identified, Bill Few Associates, Inc.
will convert the shares to the lowest cost share class for the client. As Bill Few Associates, Inc. uses the services of Pershing
Advisory Solutions, LLC, not all securities or share classes are available on their platform.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses
charged by custodians and imposed by broker-dealers (see Schedule A), including, but not limited to, margin interest,
statement, delivery, transfer and other fees.
For investors that participate in the Bill Few Associates Wrap Fee Program, transactions costs for clearing and execution of
trades are paid by Bill Few Associates, Inc. Additional information can be found in the BFA Wrap Fee Program Brochure.
Please refer to the "Brokerage Practices" section under Item 12 of this brochure for additional information.
ERISA Accounts: Bill Few Associates, Inc. is deemed to be a fiduciary to advisory clients that are employee benefit plans
pursuant to the Employee Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code
of 1986 (the "Code"), respectively. As such, our firm is subject to specific duties and obligations under ERISA and the Internal
Revenue Code that include among other things, restrictions concerning certain forms of compensation.
Advisory Fees in General: Clients should note that similar advisory services may or may not be available from other
registered or unregistered investment advisers for similar or lower fees. In addition, fee-based accounts are typically more
expensive over time versus commission-based accounts due to a higher level of service and ongoing management delivered.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1,200 more
than six months in advance of services rendered.
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Bill Few Associates, Inc. does not charge performance-based fees.
ITEM 7: TYPES OF CLIENTS
Bill Few Associates, Inc. provides advisory services to the following types of clients:
Individuals
Charitable organizations
High net worth individuals
Corporations or other businesses
Pension and profit sharing plans
As previously disclosed in Item 5, our firm has established certain initial minimum account requirements, based on the nature
of the services being provided. For a more detailed understanding of those requirements, please review the disclosures
provided in Item 5.
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ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
METHODS OF ANALYSIS
We use the following methods of analysis in formulating our investment advice and/or managing client assets:
Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic and financial factors
(including the overall economy, industry conditions, and the financial condition and management of the company itself) to
determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to
sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security
can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating
the stock.
Qualitative Analysis: We subjectively evaluate non-quantifiable factors such as quality of management, labor relations, and
strength of research and development factors not readily subject to measurement and predict changes to share price based on
that data.
A risk in using qualitative analysis is that our subjective judgment may prove to be incorrect.
Asset Allocation: Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of
equities, fixed income, and cash suitable to the client’s investment goals and risk tolerance.
A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market
sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market
movements and, if not corrected, will no longer be appropriate for the client’s goals.
Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual fund or ETF
in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic
conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant
overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in
an attempt to determine if they are continuing to follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future
results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not
control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same
security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate
from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the
client’s portfolio.
Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the companies whose securities
we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information
about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect,
there is always a risk that our analysis may be compromised by inaccurate or misleading information.
INVESTMENT STRATEGIES
We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the
client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations:
Long-term purchases: We purchase securities with the intention of holding them in the client's account for a year or longer.
Typically, we employ this strategy when we believe the securities to be currently undervalued, and/or we want exposure to a
particular asset class over time, regardless of the current projection for this class.
A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of
short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply
in value before we make the decision to sell.
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Short-term purchases: When utilizing this strategy, we purchase securities with the intention of selling them within a
relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will
soon result in a price swing in the securities we purchase.
A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are then left with the option
of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss.
In addition, this strategy involves more frequent trading than does a longer-term strategy and will result in less favorable tax
treatment of short-term capital gains.
Margin transactions: We will purchase stocks for your portfolio with money borrowed from your brokerage account. This
allows you to purchase more stock than you would be able to with your available cash and allows us to purchase stock without
selling other holdings. Managing accounts on Margin is only done with prior client consent and authorization and represents
a limited number of accounts under active management.
Option writing: We may use options as an investment strategy. An option is a contract that gives the buyer the right, but not
the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. An option, just
like a stock or bond, is a security. An option is also a derivative, because it derives its value from an underlying asset. The
use of Option writing is only done with prior client consent and authorization and represents a limited number of accounts
under active management.
The two types of options are calls and puts:
A call gives us the right to buy an asset at a certain price within a specific period of time. We will buy a call if we anticipate
the stock will increase substantially before the option expires.
A put gives the holder the right to sell an asset at a certain price within a specific period of time. We will buy a put if we
anticipate the price of the stock will fall before the option expires.
We will use options to speculate on the possibility of a sharp price swing. We will also use options to "hedge" a purchase of
the underlying security; in other words, we will use an option purchase to limit the potential upside and downside of a security
we have purchased for your portfolio.
We use "covered calls", in which we sell an option on a security you own. In this strategy, you receive a fee for making the
option available, and the person purchasing the option has the right to buy the security from you at an agreed-upon price.
We use a "spreading strategy", in which we purchase two or more option contracts (for example, a call option that you buy
and a call option that you sell) for the same underlying security. This effectively puts you on both sides of the market, but
with the ability to vary price, time and other factors.
Risk of Loss: Securities investments are not guaranteed, and you may lose money on your investments. Clients should
understand that investing in any securities, including mutual funds, involves a risk of loss of both income and principal.
We ask that you work with us to help us understand your tolerance for risk.
Leveraged and Inverse Funds/ETF Risks: Bill Few Associates, Inc. does not recommend Leveraged and Inverse
Funds/ETFs. However, clients may direct us to purchase or hold these investments in their accounts. While Leveraged and
Inverse ETFs offer potential for amplified returns, they also carry significant risks. There is the possibility of significant
losses in short periods of time including the risk that you could lose most or all of your investment, especially in volatile
markets. These funds generally have a daily investment objective and are not designed to track their benchmark for longer
periods of time. The effects of volatility and compounding could cause their returns to diverge materially from the benchmark
when held longer than a single trading day. Investors should review the investment prospectus and principal risks described
therein prior to investing.
Penny Stock Risks: Penny stocks are low-priced shares of small companies. Bill Few Associates, Inc. does not recommend
investing in Penny stocks. However, clients may direct us to purchase or hold these investments in their accounts. Penny
stocks may trade infrequently, which means that it may be difficult to sell penny stock shares. Because it may be difficult to
find quotations for penny stocks, they may be impossible to accurately price. Penny stocks generally have lower liquidity,
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are subject to volatile price fluctuations and often have large bid/ask spreads. Penny stocks are considered speculative
investments and investors may lose some or all of their investment.
Market Disruptions and other Impacts of Force Majeure Events: Financial markets may be impacted by the outbreak of
a contagious disease, a terrorist act or threat, acts of war or severe weather incidents. An outbreak of a contagious disease
with the potential to become a pandemic, or the measure taken by the governments of affected countries against such potential
outbreaks, could seriously disrupt financial markets, which could have an adverse effect on investment performance. The
spread of such disease can quickly and negatively impact business operations, supply chains, business and leisure travel,
stores, restaurants, sports events and other venues. These sudden changes in business and consumer behaviors can cause
instability in the world financial markets and may generate localized or even global economic instability. The outbreak of a
contagious disease, a terrorist act or threat, acts of war or severe weather incidents can lead to increased volatility in
investments securities.
ITEM 9: DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that may
be material to your evaluation of a firm or the integrity of its management.
In 2018, Bill Few Associates, Inc. elected to participate in the Securities and Exchange Commission’s Mutual Fund Share
Class Selection Disclosure Initiative (“SCSD Initiative”). The SCSD Initiative provided investment advisers with the
opportunity to voluntarily self-report to the SEC’s Division of Enforcement possible inadequacies with their disclosures
concerning mutual fund share class selection and the fees pursuant to Rule 12b-1 under the Investment Company Act of 1940.
As part of the SCSD Initiative, BFA reviewed their disclosures and activities related to mutual fund share class selection. At
the conclusion of the SCSD Initiative, BFA consented to a settlement agreement to reimburse accounts the amount of 12b-1
fees received ($2,201,454.07) along with prejudgment interest ($191,850.74). The SEC did not impose a fine or civil
monetary penalty in recognition of the fact that BFA self-reported.
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Certain investment personnel of our firm are agents for various insurance companies. As such, these individuals are able to
receive separate, yet customary commission compensation resulting from implementing product transactions on behalf of
advisory clients. Clients, however, are not under any obligation to engage these individuals when considering implementation
of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client.
While Bill Few Associates, Inc. and these individuals endeavor at all times to put the interest of the clients first as part of our
fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and may
affect the judgment of these individuals when making recommendations.
The following procedures are employed to address this conflict:
• We disclose to clients the existence of all material conflicts of interest, including the potential for our firm and our
employees to earn compensation from advisory clients in addition to our firm's advisory fees;
• We disclose to clients that they are not obligated to purchase recommended investment products from our employees
or affiliated companies;
• We collect, maintain and document accurate, complete and relevant client background information, including the
client’s financial goals, objectives and risk tolerance;
• Our firm's management conducts regular reviews of each client account to verify that all recommendations made to
a client are suitable to the client’s needs and circumstances;
• We require that our employees seek prior approval of any outside employment activity so that we may ensure that
any conflicts of interests in such activities are properly addressed;
• We periodically monitor these outside employment activities to verify that any conflicts of interest continue to be
properly addressed by our firm; and
• We educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable
and independent basis for the investment advice provided to clients.
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ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our
employees, including compliance with applicable federal securities laws.
Bill Few Associates, Inc. and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an
obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial
and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of
Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an
initial public offering. Our code also provides for oversight, enforcement and recordkeeping provisions.
Bill Few Associates, Inc.'s Code of Ethics further includes the firm's policy prohibiting the use of material non-public
information. While we do not believe that we have any particular access to non-public information, all employees are
reminded that such information may not be used in a personal or professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email
sent to jjones@billfew.com or by calling us at 412-630-6000.
Bill Few Associates, Inc. and individuals associated with our firm are prohibited from engaging in principal transactions.
Our Code of Ethics is designed to assure that the personal securities transactions, outside business activities and interests of
our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such
decisions while, at the same time, allowing employees to invest for their own accounts.
Our firm and/or individuals associated with our firm buy or sell for their personal accounts securities identical to or different
from those recommended to our clients. Such transactions occur at or about the same time as client transactions. In addition,
any related person may have an interest or position in a certain securities which may also be recommended to a client.
ITEM 12: BROKERAGE PRACTICES
Broker Selection: As an investment advisory client, it is your choice to select a broker-dealer to execute your trades and to
custody the assets that will be held in your account. As a means of streamlining the overall administration and management
of your investment accounts, we recommend clients choose the brokerage services of Pershing Advisory Solutions, LLC
(PAS).
PAS is registered with the U.S. Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory
Authority (“FINRA”). By working with PAS, your trades will be executed, cleared and custodied at Pershing LLC, a broker-
dealer and clearing firm that is registered with the SEC and FINRA.
Soft Dollar Arrangements: Soft dollars is a term used when payments for research services by an investment adviser to a
brokerage firm is made through commission revenue, as opposed to normal direct payments of cash. Bill Few Associates,
Inc. does not have any soft dollar arrangements and does not receive any soft dollar benefits. The majority of our research is
generated by our team of experienced research analysts utilizing generally available research reports and subscriptions that
are paid for directly by Bill Few Associates, Inc.
Directed Brokerage: If a client directs us to use a broker-dealer other than Pershing Advisory Solutions, LLC (PAS) to
execute some or all account transactions, the client must understand that it is his or her responsibility to negotiate the terms
and conditions of such services. Under these circumstances, Bill Few Associates, Inc. has no authority to negotiate prices and
commissions or obtain volume discounts on behalf of the client. This “directed brokerage” arrangement may impair our ability
to obtain the best qualitative trade execution for you. In fact, in some cases you may pay higher transaction prices and
commissions than those paid by clients who use the brokerage services of PAS.
Brokerage for Client Referrals: We do not recommend broker-dealers to clients based on our interest in receiving client
referrals from the broker-dealer.
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Block Trading: We will place block trades where possible and when advantageous to clients. Block trading is typically done
for equities in which the total quantity of shares to be bought or sold is a significant amount. This blocking of trades permits
the trading of aggregate blocks of securities composed of assets from multiple client accounts, so long as transaction costs are
shared equally between all accounts included in any such block.
Block trading may allow us to execute equity trades in a timelier, more equitable manner, at an average share price. Bill Few
Associates, Inc. will typically aggregate trades among clients whose accounts can be traded at a given broker.
Bill Few Associates, Inc.'s block trading policy and procedures are as follows:
Transactions for any client account may not be aggregated for execution if the practice is prohibited by or inconsistent with
the client's advisory agreement with Bill Few Associates, Inc., or our firm's order allocation policy.
The trading desk or trader, in concert with the portfolio manager, must determine that the purchase or sale of the particular
security involved is appropriate for the client and consistent with the client's investment objectives and with any investment
guidelines or restrictions applicable to the client's account.
The portfolio manager must reasonably believe that the order aggregation will benefit, and will enable Bill Few Associates,
Inc. to seek best execution for each client participating in the aggregated order. This requires a good faith judgment at the
time the order is placed for the execution. It does not mean that the determination made in advance of the transaction must
always prove to have been correct in the light of a "20-20 hindsight" perspective. Best execution includes the duty to seek the
best quality of execution, as well as the best net price.
Prior to entry of an aggregated order, a written order ticket must be completed which identifies each client account
participating in the order and the proposed allocation of the order, upon completion, to those clients.
If the order cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each
business day must be allocated pro rata among the participating client accounts in accordance with the initial order ticket or
other written statement of allocation. However, adjustments to this pro rata allocation may be made to participating client
accounts in accordance with the initial order ticket or other written statement of allocation. Furthermore, adjustments to this
pro rata allocation may be made to avoid having odd amounts of shares held in any client account, or to avoid excessive ticket
charges in smaller accounts.
Generally, each client that participates in the aggregated order must do so at the average price for all separate transactions
made to fill the order and must share in the commissions/execution charge on a pro rata basis in proportion to the client's
participation. Under the client’s agreement with the custodian/broker, transaction costs may be based on the number of shares
traded for each client.
If the order will be allocated in a manner other than stated in the initial statement of allocation, a written explanation of the
change must be provided to and approved by the Chief Compliance Officer no later than the morning following the execution
of the aggregate trade.
Bill Few Associates, Inc.'s client account records separately reflect, for each account in which the aggregated transaction
occurred, the securities which are held by, and bought and sold for, that account.
Funds and securities for aggregated orders are clearly identified on Bill Few Associates, Inc.'s records and to the broker-
dealers or other intermediaries handling the transactions, by the appropriate account numbers for each participating client.
No client or account will be favored over another.
Trading Errors: It is Bill Few Associates policy to identify and correct any errors as promptly as possible without
disadvantaging the client. Any losses incurred from a firm trading error is the responsibility of the firm. Any gains where it
is not feasible to pass the gain to the client will be retained by the firm and used to offset losses.
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ITEM 13: REVIEW OF ACCOUNTS
INDIVIDUAL PORTFOLIO MANAGEMENT
Reviews: While the underlying securities within Individual Portfolio Management Services accounts are monitored, these
accounts are reviewed at least annually. Accounts are reviewed in the context of each client's stated investment objectives
and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual
circumstances, or market, political or economic environment.
These accounts are reviewed by Bill Few Associates financial analysts and/or the financial professional for each account.
Reports: In addition to the statements and confirmations of transactions that clients receive from their broker-dealer or
custodian, we provide reports summarizing account performance, balances and holdings during regular review meetings with
clients.
These reports will also remind the client to notify us if there have been changes in the client's financial situation or investment
objectives and whether the client wishes to impose investment restrictions or modify existing restrictions.
MUTUAL FUND MODEL PORTFOLIO MANAGEMENT
Reviews: While the underlying securities within the Mutual Fund Model Portfolio Management accounts are continually
monitored, these accounts are reviewed at least annually. Accounts are reviewed in the context of the investment objectives
and guidelines of each model portfolio as well as any investment restrictions provided by the client. More frequent reviews
may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or
economic environment.
These accounts are reviewed by Bill Few Associates financial analysts and/or the financial professional for each account.
Reports: In addition to the statements and confirmations of transactions that clients receive from their broker-dealer or
custodian, we may provide reports summarizing account performance, balances and holdings during regular review meetings
with clients.
These reports will also remind the client to notify us if there have been changes in the client's financial situation or investment
objectives and whether the client wishes to impose investment restrictions or modify existing restrictions.
AMERICAN FUNDS F-2 DIRECT PROGRAM
Reviews: While the underlying securities within the American Funds F-2 Direct Program are monitored, these accounts are
reviewed at least annually. Accounts are reviewed in the context of the investment objectives. More frequent reviews may
be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic
environment.
These accounts are reviewed by the financial professional for each account.
Reports: In addition to the statements and confirmations of transactions that clients receive from their custodian, we may
provide reports summarizing account performance, balances and holdings during regular review meetings with clients.
These reports will also remind the client to notify us if there have been changes in the client's financial situation or investment
objectives and whether the client wishes to impose investment restrictions or modify existing restrictions.
FINANCIAL PLANNING SERVICES
Reviews: While reviews may occur at different stages depending on the nature and terms of the specific engagement,
typically no formal reviews will be conducted for Financial Planning clients unless otherwise contracted for. Such reviews
will be conducted by the financial professional.
Reports: Financial Planning clients will receive a completed financial plan. Additional reports will not typically be provided
unless otherwise contracted for.
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CONSULTING SERVICES
Reviews: While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically
no formal reviews will be conducted for Consulting Services clients unless otherwise contracted for. Such reviews will be
conducted by the client's account representative.
Reports: These client accounts will receive reports as contracted for at the inception of the advisory engagement.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
It is Bill Few Associates, Inc.'s policy not to accept or allow our related persons to accept any form of compensation, including
cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. We
believe these practices would create an unacceptable conflict of interest.
Bill Few Associates, Inc. does not compensate any third party for client referrals.
ITEM 15: CUSTODY
Bill Few Associates, Inc. does not maintain physical custody of client funds or securities. However, we are deemed to have
custody of client assets under certain circumstances such as allowing clients to execute standing letters of authorization for
asset movement, where we have authority to obtain temporary possession of client funds for deposit into their accounts and
directly debiting advisory fees from client accounts. In the instances where Bill Few Associates is deemed to have custody,
we will follow the requirements of rule 206(4)-2 including any required audits.
Clients will receive, at least quarterly, statements from their qualified custodian, detailing the activity, account holdings and
balances of their investment account. It is extremely important for clients to carefully review their custodial statements to
verify the accuracy of the fee calculations, deposits, withdrawals, and asset movements among other things. Clients should
contact us directly if they believe that there may be an error in their statement.
We urge clients to compare the account statements from their qualified custodian(s) with the reports they receive from Bill
Few Associates, Inc.
ITEM 16: INVESTMENT DISCRETION
Clients may hire us to provide discretionary asset management services, in which case we place trades in a client's account
without contacting the client prior to each trade to obtain the client's permission.
Our discretionary authority includes the ability to determine the specific securities to buy or sell, the amount of the securities
to buy or sell and the timing of when to buy or sell.
Clients give us discretionary authority when they sign a discretionary agreement with our firm and may limit this authority
by giving us written instructions. Clients may also change or amend such limitations by providing us with written instructions.
ITEM 17: VOTING CLIENT SECURITIES
As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, clients maintain exclusive responsibility
for directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and
making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events
pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets to forward to
the client copies of all proxies and shareholder communications relating to the client’s investment assets.
Upon the client’s request, we may provide clients with consulting assistance regarding proxy issues if they contact us with
questions at our principal place of business.
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ITEM 18: FINANCIAL INFORMATION
Registered investment advisers that maintain discretionary authority are required to disclose any financial condition that is
reasonably likely to impair their ability to meet their contractual obligations.
Bill Few Associates, Inc. has no financial circumstances to report that may impair our ability to meet our contractual
obligations.
Under no circumstances do we require or solicit payment of fees six months or more in advance of services rendered.
Therefore, we are not required to include a financial statement.
Bill Few Associates, Inc. has not been the subject of a bankruptcy petition at any time during the past ten years.
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Schedule A
Client Account Fees and Expenses
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The following lists various fees and expenses that may be applicable to your Bill Few Associates, Inc. accounts. Certain fees may not apply or may be
absorbed by Bill Few Associates, Inc. Other fees are only charged when the associated services are requested or when special processing is required.
Description
Fees
Account Fees and Expenses (as of 1/1/2024):
Description
Fees
Inactivity Fee (Retail Accounts Only)
Asset Management Accounts (Resource Checking/ProCash/Corestone)
Mutual Fund Only
Waived
Platinum
Waived
Mixed Account
Waived
Gold
N/A
Dividend Reinvestment
1.00
Silver Plus
N/A
Bond Redemption Notification Fee
1.00
Silver
N/A
Margin Extension
10.00
Corporate Gold
N/A
Corporate Platinum
Waived
Asset Management Accounts
Reorganization Items:
Voluntary Transfers
Accommodation Transfers
Register and Ship Certificate
20.00
60.00
25.00
Checking Fees:
Safekeeping (per position per month)
2.00
Other Checking/Debit-related Fees
Direct Registration (Transfer In)
Waived
Initial Personal Check Order
Waived
Direct Registration (Transfer Out)
10.00
Check Reorder
7.50
Legal, GNMA and Restricted Transfers
60.00
Initial Personal Check Order
(Carbon Copy)
15.00
Check Reorder (Carbon Copy)
25.00
Business Checks
50.00
Business Style Reorder
40.00
Limited Partnership/Alternative Investments
Subscription Fee
Redemption Fee
Reregistration Fee
Annual Administration Fee (registered positions)
Annual Administration (unregistered positions)
50.00
50.00
50.00
35.00
125.00
Business Style Check Binder
20.00
Overnight Check Reorder
20.00
Annual Retirement Plan Maintenance Fees
Returned Checks or ACH Debits
25.00
Stop Payment
Waived
Waived
Waived
View Copy of Paid Check Online
Waived
Retrieve Copy of aid Checks
2.50
Waived
Letter with Checking Account Information
Waived
Waived
Debit Card Fees:
ATM Withdrawal Fee (In-network
and Out-of-network)
Waived
IRA, Roth IRA, SEP, Education Savings
(Mutual Fund Only)
IRA, Roth IRA, SEP, Education Savings (Mixed)
Qualified Retirement Plan–SIMPLE, 403(b)
(Mutual Fund Only)
Qualified Retirement Plan – SIMPLE, 403(b)
(Mixed)
Individual and Simplified 401(k), Profit Sharing
and Money Purchase Plan
Flex 401(k), Profit Sharing/Money Purchase Plan
Waived
Waived
ATM Surcharge Fee (charged by an ATM)
Various
($10 maximum reimbursement per month)
Cash Advance Fee (non-ATM)
0.25%
of principal ($2.50 minimum)
2.50
Retrieve Copy of Paid Debit Card Draft
Foreign Transaction Fee 1% of the transaction
Paper Delivery Fee (if not enrolled in e-delivery)
2.00/month
Trade Processing Ticket Charges and Commissions
Stocks and ETFs ticket charges 1,2
Options ticket charges
Bond ticket charges
Mutual Fund ticket charges
Commissions up to 2%; non-fee paying accts
NTF Early Redemption Fee
Waived
Waived
Waived
Waived
N/A
50.00
Paper Delivery Fee-Tax Documents (Fee is waived if these 10.00/year
are sent via e-delivery or if you subscribe to Paper Delivery Fee)
Varies
Account Transfer
25.00
Interest Expenses on Margin Debits
(Charge over Prime Base Lending Rate) 3
Interest Expense on Non Purpose Loans
(Charge over Fed Fund Target Rate) 3
Varies
Retirement and Education
Account Termination Fee
75.00
Asset Movement Charges
Certified Check Delivery
12.00
Returned Checks for Insufficient
Funds (Deposits)
25.00
1The common stock and ETF ticket charges do not apply for foreign
securities transactions. Instead, Pershing foreign execution, clearance
and settlement service fees, which may also include a currency
conversion spread and, in some cases, a foreign tax, are charged for all
foreign stock transactions. Fees and expenses will vary depending on
which country (market) the stock is being traded in.
Returned Checks for Insufficient Funds
(Checks Written)
25.00
2A transaction charge by the market exchanges will be assessed.
Profit Sharing Loan Processing
50.00
Stop Payment
10.00
Overnight Check Delivery
12.00
Overnight Check Delivery (Overseas)
25.00
3The Pershing Base Lending and the Prime Lending rates are set with
reference to recognized interest rates, industry conditions related to the
extension of credit, and general credit market conditions. All interest
over these rates is credited to Bill Few Associates, Inc.
Overnight Check Delivery (Saturday)
18.00
Wire Fee
20.00
ACH Returns
20.00
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