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Form ADV 2A
March 2025
Item 1: Cover Page
Beacon Investment Advisory Services, Inc.
Form ADV Part 2A
(“The Brochure”)
March 2025
163 Madison Avenue
Suite 600
Morristown, NJ 07960
(973) 206-7100
www.beacontrust.com
This Brochure provides information about the qualifications and business practices of Beacon Investment
Advisory Services, Inc. (hereinafter “BIAS,” “Beacon Trust,” or the “Firm”). If you have any questions
about the contents of this Brochure, please contact BIAS at this telephone number listed above or your
financial professional. The information in this Brochure has not been approved or verified by the United
States Securities and Exchange Commission (“SEC”) or by any state securities authority. Any reference to
BIAS as a “registered investment adviser” or as being “registered” with the SEC or a state securities
authority does not imply a certain level of skill or training.
Additional information about Beacon Investment Advisory Services also is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Item 2. Material Changes
This update includes material and non-material changes that have occurred since the
annual amendment of Form ADV filed in March of 2024.
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Item 3. Table of Contents
Item 2. Material Changes .............................................................................................................................................. 2
Item 3. Table of Contents .............................................................................................................................................. 3
Item 4. Advisory Business ............................................................................................................................................ 4
Item 5. Fees and Compensation ................................................................................................................................... 12
Item 6. Performance-Based Fees and Side-by-Side Management ................................................................................. 16
Item 7. Types of Clients .............................................................................................................................................. 16
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss .......................................................................... 17
Item 9. Disciplinary Information ................................................................................................................................. 23
Item 10. Other Financial Industry Activities and Affiliations ....................................................................................... 23
Item 11. Code of Ethics ............................................................................................................................................... 24
Item 12. Brokerage Practices ....................................................................................................................................... 24
Item 13. Review of Accounts ...................................................................................................................................... 32
Item 14. Client Referrals and Other Compensation ...................................................................................................... 33
Item 15. Custody ......................................................................................................................................................... 35
Item 16. Investment Discretion .................................................................................................................................... 35
Item 17. Voting Client Securities ................................................................................................................................ 36
Item 18. Financial Information.................................................................................................................................... 37
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Item 4. Advisory Business
Beacon Investment Advisory Services, Inc. (“BIAS” or “Beacon Trust”) has been in
business as a registered investment adviser since April 2015. BIAS does business
under the name, Beacon Trust. Beacon Trust is owned by Beacon Trust Company
which is a New Jersey Limited Purpose Trust Company. Beacon Trust Company is
owned by Provident Bank, which is owned by Provident Financial Services, Inc. a
publicly traded company (NYSE: PFS). The firm seeks to guide its clients through the
lifecycle of wealth creation, wealth management, and intergenerational wealth
transfer.
Beacon Trust provides financial planning, tax preparation, and asset management
services to its clients. Prior to engaging Beacon Trust to provide any investment
advisory services, the client is required to enter into one or more written agreements
with Beacon Trust setting forth the terms and conditions under which Beacon Trust
renders its services (collectively the “Agreement”).
When we provide investment advice to you regarding your retirement plan account, we
are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws
governing retirement accounts. The way we make money creates some conflicts with
your interests, so we operate under a special rule that requires us to act in your best
interest and not put our interests ahead of yours. Some aspects of the rule are
included throughout this document.
In addition, under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment
recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making
recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice
that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
As of December 31, 2024, Beacon Trust managed approximately $4.3 billion of
regulatory assets under management on a discretionary basis.
This Disclosure Brochure describes the business of Beacon Trust. Certain sections
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will also describe the activities of Supervised Persons. Supervised Persons are any of
Beacon Trust’s officers, directors (or other persons occupying a similar status or
performing similar functions), or employees, or any other person who provides
investment advice on Beacon Trust’s behalf and is subject to Beacon Trust’s
supervision or control.
Financial Planning and Tax Preparation
Beacon Trust may provide its clients with a broad range of comprehensive financial
planning and tax related services. Beacon Trust works to lead each of its clients
through the firm’s holistic planning process in an organized series of steps. Specific
disciplines addressed in the planning process include:
• Family governance
• Compensation and benefits
•
Income tax minimization
• Cash flow planning
• Net worth analysis
• Education/goal planning
• Long-term retirement planning
• Estate planning
• Charitable giving
• Risk exposure analysis & management
• Asset allocation planning
• Portfolio design
Beacon Trust may recommend the products and services of itself and/or other
professionals to implement its recommendations. Clients are advised that a conflict
of interest exists if Beacon Trust recommends its own products and/or services, for
which the client may pay more or less compared to other non-affiliated products and
services. As described further in this brochure, Beacon Trust may recommend
products or services of its affiliate, Beacon Trust Company.
However, this conflict is mitigated since the client is under no obligation to act upon
any of the recommendations made by Beacon Trust under a financial planning or
consulting engagement or to engage the services of any such recommended
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professional, including Beacon Trust itself. The client retains absolute discretion over
all such implementation decisions and is free to accept or reject any of Beacon Trust’s
recommendations. Clients are advised that it remains their responsibility to promptly
notify Beacon Trust if there is ever any change in their financial situation or investment
objectives for the purpose of reviewing, evaluating, or revising Beacon Trust’s
previous recommendations and/or services.
Investment and Wealth Management Services
Clients can engage Beacon Trust to manage all or a portion of their assets on a
discretionary basis. As detailed in Item 8, Beacon Trust allocates clients’ investment
management assets in both in-house equity and fixed income strategies, as well as
with Independent Managers (as defined below), mutual funds (including Beacon Trust
managed funds), exchange-traded funds (“ETFs”), individual debt and equity
securities, options, investment limited partnerships, or other investments in accordance
with the objectives of the client. If appropriate, Beacon Trust may provide advice
about any type of investment held in clients' portfolios.
Beacon Trust will, on occasion, render non-discretionary investment management
services to clients relative to variable life/annuity products that they may own, their
individual employer-sponsored retirement plans, and/or 529 plans or other products that
may not be held by the client’s primary custodian. In so doing, Beacon Trust either
directs or recommends the allocation of client assets among the various investment
options that are available. Client assets are maintained at the specific insurance
company or custodian designated by the service.
Beacon Trust tailors its advisory services to the individual needs of clients. Beacon
Trust consults with clients initially and on an ongoing basis to determine risk tolerance,
time horizon and other factors that may impact the clients’ investment needs. Beacon
Trust ensures that clients’ investments are suitable for their investment needs, goals,
objectives, and risk tolerance. This would include ensuring clients are invested in the
most advantageous mutual fund share class, at the time of investment, as well as at the
time which client assets may be transferred to Beacon Trust, and on an ongoing basis.
At times, a more advantageous share may exist, however, the client may not be
eligible for inclusion, due to the size of investment or mutual fund company
contractual agreements with the custodian or Beacon Trust.
Clients are advised to promptly notify Beacon Trust if there are changes in their
financial situation or investment objectives or if they wish to impose any
reasonable restrictions upon Beacon Trust’s management services. Clients may
impose reasonable restrictions or mandates on the management of their account (e.g.,
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require that a portion of their assets be invested in socially responsible funds) if, in
Beacon Trust’s sole discretion, the conditions will not materially impact the performance
of a portfolio strategy or prove overly burdensome to its management efforts. If it is
determined that it has a material impact, Beacon Trust will work with the client to tailor
the desired restriction into the investment management services.
Use of Independent Managers
As mentioned above, Beacon Trust recommends that certain clients authorize the
active discretionary management of a portion of their assets by and/or among certain
independent investment managers (“Independent Managers”), based upon the stated
investment objectives of the client. When independent managers are selected, the terms
and conditions under which the client engages the Independent Managers are set forth
in a separate written agreement between Beacon Trust or the client and the designated
Independent Managers. Beacon Trust renders services to the client relative to the
discretionary selection of Independent Managers. Beacon Trust also monitors and
reviews the account performance and the client’s investment objectives. Beacon
Trust receives an annual advisory fee which is based upon a percentage of the
market value of the assets being managed by the designated Independent
Managers.
When selecting an Independent Manager for a client, Beacon Trust reviews information
about the Independent Manager such as its disclosure brochure and/or material supplied
by the Independent Manager or independent third parties for a description of the
Independent Manager’s investment strategies, past performance and risk results to the
extent available. Factors that Beacon Trust considers in recommending an Independent
Manager include the client’s stated investment objectives, as well as the manager’s
management style, performance, reputation, financial strength, reporting, pricing, and
Beacon’s research of the manager. The investment management fees charged by the
designated Independent Managers, together with the fees charged by the
corresponding designated broker- dealer/custodian of the client’s assets, may be
exclusive of, and in addition to, Beacon Trust’s investment advisory fee set forth
above. As discussed above, the client may incur additional fees separate from those
charged by Beacon Trust, the designated Independent Managers, and
corresponding broker-dealer and custodian.
In addition to Beacon Trust’s written disclosure brochure, the client also receives the
written disclosure brochure of the designated Independent Managers. Certain
Independent Managers may impose more restrictive account requirements and varying
billing practices than Beacon Trust.
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Management of the Proprietary Mutual Fund
Beacon Planned Return Strategy Fund (“BPRLX”)
This Fund’s investment objectives are capital preservation and capital appreciation.
The Fund aims to achieve its investment objective of capital preservation by
purchasing put options against the U.S. equity indices. The Fund aims to achieve its
investment objective of capital appreciation by purchasing call options on U.S. equity
indices and collecting premium income from selling call and put options against the
U.S. equity indices. The Fund aims to achieve its investment objective through the
systematic purchase of rolling investments or “tranches”. Each tranche is made up of
long and short options traded on the performance of a broad market index. Index
exposure may be gained using additional options, a basket of securities, ETFs, or other
means.
You may pay more in fees if you are invested in the Beacon Fund than if
invested in other funds available through the Wrap Program.
All clients are invested in the most advantageous share class available in both funds. This creates a
conflict of interest since we have a financial incentive to recommend the Beacon Funds to you.
Beacon mitigates this conflict by not charging advisory fees on top of Fund management fee as the
Beacon Funds are excluded from fee calculations.
The Fund is registered under the Investment Company Act of 1940 and the interests
of which are registered pursuant to the Securities Act of 1933.
Wrap Program
Beacon Trust offers the Beacon Trust wrap program (“Wrap Program”) through
Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”), a
registered broker-dealer, member SIPC, as described below. Beacon Trust offers the
Wrap Program, if deemed appropriate, to interested prospects and advisory clients.
Beacon Trust is the sponsor of the Wrap Program and the party responsible for
marketing it. Generally, the clients in the Wrap Program include high net worth
individuals and trusts. The fees for the program are listed later in the document.
Beacon Trust does not offer different tiers of fees for these accounts. If a client wants
an account that is non-discretionary, that can be accommodated, if reasonable to the
firm, and suitable to the client, at a different fee structure.
The summary of the Wrap Program is provided below. A copy of the Beacon Trust wrap
fee brochure (Form ADV Part 2A Appendix 1) is available to clients upon request
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without charge.
The Beacon Trust portfolio management group pursues investment strategies as follows:
• The Core Strategy portfolio seeks to provide long-term capital appreciation by
investing in the common stock of companies that have compelling financial
characteristics and disruptive catalysis to drive growth. The strategy focuses on
companies with above-average return on invested capital (ROIC), free cash
flow margins, and revenue growth. Valuation measures such as the
price/earnings ratio relative to the strategy’s benchmark, the S&P 500, are
considered but are not a driving factor in the management of the strategy.
Core’s managers are financial analysts that use quantitative screens and a
qualitative review to select companies that have the potential to compound their
capital value at an above-average rate over a five-year period, without incurring
above average risk.
• The Income and Appreciation portfolio is comprised of highly rated stocks
according to Beacon Trust’s multifactor models. A blend of growth and value,
the portfolio holds about 40 stocks with a minimum capitalization of $2
billion. There is an emphasis to generate a dividend yield significantly higher
than the S&P 500. The Income and Appreciation portfolio is actively managed
with constant portfolio manager oversight, risk management and a process-
driven trading strategy. It includes current income, capital appreciation and
total return. In stock selection, the portfolio tries to be cognizant of portfolio
risk characteristics.
• The ‘FIRM’ portfolio, an acronym for Factor Information Return Model,
utilizes factors in the portfolio construction process. Factors are underlying
exposures that explain and drive stock returns. The factor approach provides
opportunity to replicate the best parts of the market, can provide
diversification, avoids overexposure to growth and large-cap biases, and avoids
poorly compensated risks. It utilizes three transparent factors that have
historically driven above-average stock returns: Quality: Low volatility in
earnings per share (EPS) and low debt to equity; Valuation: Low price to
earnings (P/E) ratio; and Size: Small market capitalization. The portfolio is
constructed from the S&P 500 universe by ranking the aforementioned factors
independently utilizing a screening process. The monthly reconstitution
process replaces stocks falling short of the factor standards with higher ranking
stocks in each quartile. The process is predominantly quantitative, thereby
reducing fundamental judgments and portfolio manager biases in stock
selection.
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•
In addition, Beacon Trust constructs household level portfolios of mutual funds,
ETFs and managed accounts, for its clients.
• The ETF model portfolios’ process was developed by our investment
committee based upon the principles of behavioral finance. The result is a
portfolio that is specifically matched to a client’s risk tolerance. Beacon Trust
does this by optimizing the portfolio based upon the expected return, volatility
and correlation of the underlying components. Beacon Trust considers the
following factors rooted in behavioral finance when determining a client’s
economic and emotional risk tolerances:
1. Investment objective
2. Portfolio risk definition
3. Reaction to levels of loss
4. The risk/return trade off
5. Potential losses vs. potential gains
6. Anxiety of losses vs. the satisfaction of gains
7. Investment performance time horizon
8. Stability of potential returns
9. Personal goals vs. benchmark comparison
10. Spending or gifting levels
Conservative ETF Strategy: tends to hold a larger percentage of
fixed income assets compared to equity and alternative assets;
Balanced ETF Strategy: tends to hold similar amounts of equity and fixed
income assets, although this may change depending on our
macroeconomic outlook;
Aggressive ETF Strategy: tends to hold a larger percentage of equity
assets compared to fixed income and alternative assets.
• Additionally, Beacon Trust’s fixed income strategies invest individual client
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portfolios using direct ownership of bonds and other fixed income securities in
an individual account, allowing for customized restrictions and tax
management. Beacon Trust’s philosophy in trading fixed income for our
clients is to minimize risk and find safety in big names with high credit quality.
Taxable Fixed Income: Beacon Trust focuses on active portfolio management
to construct and manage limited duration, high quality taxable portfolios, while
seeking to produce income and preserve principal. Portfolios are managed in a
separate account for full transparency and income predictability. The team
analyzes the interest rate forecast for 12-24 months and attempts to determine
the optimal point on the yield curve for mature structure, and then identifies
attractive sectors within the taxable marketplace, and then opportunistically
trade in the marketplace to purchase bonds at institutional levels.
Tax Exempt Fixed Income: Beacon Trust focuses on active portfolio
management in an effort to construct and manage limited duration, high quality
tax-exempt portfolios, while seeking to maximize after-tax income while
preserving principal. Portfolios are managed in a separate account for full
transparency and income predictability. The team analyzes the interest rate
forecast for 12-24 months and attempts to determine the optimal point on the
yield curve for mature structure and then identifies attractive sectors within the
tax- exempt marketplace, and then opportunistically trade in the marketplace to
purchase bonds at institutional levels.
Clients may elect to pursue these strategies through the Wrap Program, under
which clients will pay a single fee (i.e., wrap fee) to Beacon Trust, and Beacon
Trust will then be responsible for all brokerage expenses. By enrolling in the
Wrap Program, clients are choosing the brokerage services of Schwab. Assets
placed in the Wrap Program are managed on a fully discretionary basis by
Beacon Trust.
Review & Reports of Account
Beacon Trust’s Wrap Fee Program accounts will be formally reviewed at least
annually, in addition to the regular contact with clients for investment discussions
specific to account needs and services, to determine that the account holdings are
consistent with the investor profile, investment restrictions and risk objectives. More
frequent reviews may be triggered by material changes in variables such as the client’s
individual circumstances, the market, and political or economic environment. Program
clients will receive account statements, at least quarterly, and transaction
confirmations directly from their custodian(s). Beacon Trust may arrange for periodic
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performance reports to be delivered to the client or made available to the client in other
electronic forms. This would include a review of positions transferred in-kind from
other financial institutions. You should ensure that you compare these reports to those
provided by the custodian.
401k Plan Advisory
At times, Beacon Trust may enter into an agreement to provide advice to the individual
participants of 401k plans. The advice given is specific to the plan itself and only
affects those participants in the plan under contract. This advice does not involve
specific security or portfolio selection; therefore, no conflict should exist.
Item 5. Fees and Compensation
Beacon Trust offers its services on a fee basis, which may include fixed fees, or fees
based upon assets under management, depending upon the nature of the investment
advisory service being provided by the firm.
Financial Planning and Tax Preparation Fees
Beacon Trust may charge a fixed fee for financial planning and tax preparation. These
fees are negotiable but generally range from $5,000 to $15,000 on a fixed fee basis,
depending upon the level and scope of the services and the professional rendering the
financial planning and/or the consulting services. For Clients with less than
$1,000,000 of AUM, the financial planning fee component will be equal to the
difference between the AUM Fee and $5,000. The financial planning fee component
will be waived for Clients whose AUM is in excess of $1,000,000 Beacon may at its
discretion provide discounted rates on these fees for existing clients. There is a
separate charge for tax preparation services.
Investment Management Fees
Beacon Trust provides investment management services for an annual fee based upon
a percentage of the market value of the assets being managed by Beacon Trust. Beacon
Trust’s annual fee does not cover certain fees and costs imposed by the custodian
which apply to the account. These additional costs could include among other things:
other broker-dealer fees, mutual fund fees, markup & markdown, bid- ask spreads etc.,
margin interest, account activity fees and miscellaneous fees & costs, if applicable.
Beacon Trust does not receive any portion of these commissions, fees, and costs, if
applied; they are paid directly to the custodian.
Beacon Trust’s fee is charged monthly, in arrears, based upon the average daily
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market value of the assets being managed by Beacon Trust during the previous month.
The annual fee varies up to 1.25%, (less for accounts originated through Tirschwell,
Loewy & Friedner Investments (TLFI), yet charged in advance, and 1.50% for Special
Needs Trusts) depending upon the market value of the assets under management and
the type of investment management services to be rendered. (This annual fee could be
2.50% for accounts below the stated account minimum.) In addition, trusts in the state
of New Jersey require additional fees to be paid by the trust, based on the trust itself.
Beacon Trust’s service may be terminated by either party upon written notification in
accordance with the applicable contractual notice of termination. Upon termination, the
fees charged for advisory services will be pro-rated and a refund for any unearned fees
will be issued.
Certain supervised persons of Beacon Trust accept compensation for the referral of a
new client or account, and/or the sale of investment products including mutual funds
sponsored by Beacon Trust. Such compensation includes expenses of proprietary
mutual funds that are sponsored by Beacon. This practice presents a conflict of interest
as Beacon Trust personnel may be incentivized to recommend investment products
based on the expenses associated to the fund, rather than on a client’s needs. Beacon
Trust mitigates such conflicts through disclosure of this arrangement in this brochure
and in other disclosure documents provided at the onset of our relationship with
prospective clients as well as exclusion of fund values from advisory fees. Clients
have the option to purchase certain investment products that Beacon Trust
recommends through other brokers or agents that are not affiliated with Beacon Trust.
Fee Discretion
Beacon Trust may, in its sole discretion, negotiate to charge a lesser fee with clients
based upon certain criteria, such as anticipated future earning capacity, anticipated
future additional assets, dollar amount of assets to be managed, related accounts
(households), account composition, pre-existing/legacy client relationship, account
retention, vendor or business relationships and pro bono activities.
Wrap Program Fees
The fee schedule for the Wrap Program is set forth below, however each month fees
are payable by the client in the middle of each month. The wrap fee is computed on
the last day of the month, based on the average daily market value of each of the
securities in the account during the prior month, and as follows.
A) For Beacon Trust Wrap Fee Program clients, the following fee schedule applies:
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Equity Strategies
for the first
to
to
to
$2,000,000
$5,000,000
$10,000,000
$15,000,000
1.25%
1.00%
0.90%
0.75%
Negotiated
$2,000,001
for
for
$5,000,001
for $10,000,001
for $15,000,001 and above
Fixed Income
for the first
$3,000,000
0.65%
0.55%
for
$3,000,001
and above
Special Needs Trusts
for the first
to
$3,000,000
$5,000,000
1.50%
1.00%
0.50%
for
for
$3,000,001
$5,000,001
and above
B) The total amount paid using this schedule may be more or less than the
amount charged by Beacon Trust if implemented differently.
C) Fees are subject to negotiation in certain cases and may be discounted at Beacon Trust’s
discretion.
D) 100% of the wrap fee is paid to Beacon Trust, which then pays any
brokerage charges incurred by the client. Brokerage charges can vary widely
from period to period and client to client based on market events,
contributions and withdrawals by a client.
Beacon Trust mutual funds are charged at a flat 1% regardless of the agreed
upon fee schedule for the rest of the client’s AUM, and this could present a
conflict of interest as it could result in more revenue to Beacon Trust or it
could result in less because it is technically lower than our stated 1.25% wrap
fund fee). Beacon mutual funds are excluded from the assets under
management balance when calculating the client’s asset management fee.
Cash and cash equivalents are included in fee calculations.
E) For accounts that were managed by TLFI prior to its acquisition by BIAS,
TLFI charges clients a monthly advisory fee, payable in advance at mid-month in
the month that services are provided. The fee for each month is annualized at
1.00% and is based on the average daily market of the total assets being managed
by TLFI for the prior month, with a minimum quarterly fee of $250.
F) Accounts that are subject to partial months’ due to an account opening or
liquidation during the month will have prorated billing based on average daily
balance.
G) Householding discounts apply to clients’ accounts based on the client fee
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schedule above of all accounts held at BIAS.
Fees Charged by Financial Institutions
As further discussed in response to Item 12 (below), Beacon Trust generally
recommends that clients utilize the brokerage and clearing services of Schwab for
wrap fee accounts and/or Fidelity Institutional Wealth Services (“Fidelity”) for a
certain limited number of investment management accounts.
Beacon Trust may only implement its investment management recommendations after the
client has arranged for and furnished Beacon Trust with all information and authorization
regarding accounts with appropriate financial institutions. Financial institutions include, but are
not limited to, Schwab, Fidelity, any other broker-dealer recommended by Beacon Trust, a broker-
dealer directed by the client, trust companies, banks, etc. (collectively referred to herein as the
“Financial Institutions”).
Clients may incur certain charges imposed by the Financial Institutions and other third
parties such as fees charged by Independent Managers (as defined below), custodial fees,
charges imposed directly by a mutual fund or ETF in the account, which are disclosed in
the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred
sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund
fees, and other fees and taxes on brokerage accounts and securities transactions.
Additionally, for assets held outside of any wrap fee programs, clients may incur
brokerage commissions and transaction fees. Such charges, fees and commissions
are exclusive of and in addition to Beacon Trust’s fee.
The Beacon Trust Services Agreement and the separate agreement with any Financial
Institutions may authorize Beacon Trust or Independent Managers to debit the client’s
account for Beacon Trust’s fee and to directly remit that management fee to Beacon
Trust or the Independent Managers. Any Financial Institutions recommended by
Beacon Trust have agreed to send a statement to the client, at least quarterly, indicating
all amounts disbursed from the account including the amount of management fees
paid directly to Beacon Trust. Alternatively, clients may elect to have Beacon Trust
send an invoice for payment.
Additional Information Relating to Fees
For the initial period of investment management services, fees are strictly based on the
average daily balance of the account, beginning the first day that assets are transferred
to the Beacon Trust account, or the first day that Beacon Trust is linked to the account
as investment manager, whichever comes first. The Agreement between Beacon Trust
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and the client will continue in effect until terminated by either party pursuant to the
terms of the Agreement. Beacon Trust assesses advisory fees for cash and cash
equivalent holdings. Fees are also be assessed on discretionary and non-discretionary
accounts. Fees are calculated based on total assets in the client’s household as outlined
in the Beacon Trust Services Agreement. Fees will be debited from the clients account
upon proper authorization. Clients may make additions to and withdrawals from their
account at any time, subject to Beacon Trust’s right to terminate an account that falls
below its minimum portfolio size. Additions may be in cash or securities provided that
Beacon Trust reserves the right to liquidate any transferred securities or decline to
accept particular securities into a client’s account. Clients may withdraw account
assets on notice to Beacon Trust, subject to the usual and customary securities
settlement procedures. However, Beacon Trust designs its portfolios as long-term
investments, and the withdrawal of assets may impair the ability to meet a client’s
investment objectives. Beacon Trust may consult with its clients about the options and
ramifications of transferring securities. However, clients are advised that when
transferred securities are liquidated, they are subject to market valuation and are
subject to transaction fees, fees assessed at the mutual fund level (i.e., contingent
deferred sales charge) and/or tax ramifications.
Item 6. Performance-Based Fees and Side-by-Side Management
Beacon Trust does not provide its investment advisory services for a performance-
based fee (i.e., a fee based upon capital appreciation achieved in an account).
Item 7. Types of Clients
Beacon Trust generally provides its services to individuals. However, Beacon Trust may
also provide advice to pension and profit-sharing plans, trusts, estates, charitable
organizations, corporations and business entities.
Minimum Account Size
As a condition for starting and maintaining a relationship, Beacon Trust generally
imposes a minimum portfolio size of $500,000. Beacon Trust, in its sole discretion,
may accept clients with smaller portfolios based upon certain criteria including
anticipated future earning capacity, anticipated future additional assets, dollar amount
of assets to be managed, related accounts, account composition, pre-existence of a
relationship, account retention, and pro bono activities. Beacon Trust only accepts
clients with less than the minimum portfolio size if, in the sole opinion of Beacon
Trust, the smaller portfolio size will not cause a substantial increase of investment risk
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beyond the client’s identified risk tolerance.
Minimum Annual Fee
When Beacon Trust does waive its minimum portfolio size, the firm generally imposes
a minimum annual fee of $5,000. This minimum fee may have the effect of making
Beacon Trust’s service impractical for clients with smaller investment portfolios.
Beacon Trust, in its sole discretion, may waive its minimum annual fee based upon
certain criteria including anticipated future earning capacity, anticipated future
additional assets, account composition, related accounts, and pre-existing client
relationships.
Additionally, certain Independent Managers may impose more restrictive account
requirements and varying billing practices than Beacon Trust.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Financial Planning, Investment Strategies & Methods of Analysis
Financial Planning
Beacon Trust may provide its clients with a broad range of comprehensive financial
planning and consulting services. Beacon Trust works to lead each of its clients
through the firm’s holistic planning process in an organized series of steps. Specific
disciplines addressed in the planning process include:
• Family governance
• Compensation and benefits
•
Income tax minimization
• Cash flow planning
• Net worth analysis
• Education/goal planning
• Long-term retirement planning
• Estate planning
• Charitable giving
• Risk exposure analysis & management
• Asset allocation planning
• Portfolio design
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• Portfolio monitoring and reporting
Asset Management
Clients who engage Beacon Trust for asset management services have a variety of
different options. Beacon Trust’s portfolio program seeks to provide clients with
access to several investment strategies in a variety of asset classes. Beacon Trust’s
approach aims to maximize the liquidity, transparency, tax efficiency, and adaptability
of its portfolios while preserving wealth and delivering attractive return potential.
Rather than focus on traditional asset allocation techniques, Beacon Trust
diversifies across risk exposures and places risk first in building client portfolios.
Beacon Trust’s assessment management process includes an open-architecture
investment platform of managers and strategies including but not limited to large, mid
and small cap portfolios, as well as exposure to international bond, and high yield
securities. Beacon Trust evaluates investment opportunities and seeks to identify
market voids with the goal of developing unique solutions for its clients. Beacon
Trust builds portfolios diversified across multiple risk exposures (e.g., equity market
risk, credit risk, duration risk, currency risk, global macro risk, liquidity risk, etc.). As
Beacon Trust’s market outlook changes, it may adapt risk exposure allocations with
the goal of ensuring that clients continue to meet their financial goals.
Separate Account Management
This investment vehicle offers the flexibility of direct security ownership relative to
Beacon Trust’s efforts to customize strategies for its clients, harvest losses, etc.
Beacon Trust may employ these securities to access strategies for smaller allocations
or if a given strategy is otherwise unavailable to investors. Mutual funds may also be
used for tactical allocations due to the ease of trading funds and the liquidity associated
with mutual funds relative to commitments to separately managed accounts or other
investment vehicles.
Alternative Investments
Beacon Trust is also committed to a more client-centric model of alternative investing.
If appropriate, Beacon Trust offers access to unaffiliated hedge funds and funds of
funds with a special focus on transparency, liquidity, and low fees. Beacon Trust’s
goal relative to this allocation is to further diversify portfolios with non-correlated
strategies and to reduce overall volatility.
Active Tax Management and Loss Harvesting
Beacon Trust subscribes to the thinking that it's not what investors earn, but what they
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keep that is important. For this reason, Beacon Trust strives to be tax aware in its
manager selection and portfolio development process. In addition, Beacon Trust may
actively harvest losses where opportunities exist to create tax advantages for clients.
Ongoing Portfolio Monitoring
Beacon Trust's investment committees continually monitor client portfolios relative to
changing circumstances and the achievement of goals and objectives. Beacon Trust
also employs a comprehensive process of quantitative and qualitative due diligence to
proactively hire and fire Independent Managers. Beacon Trust does not make rash
decisions to fire managers for short periods of underperformance, but Independent
Managers not meeting Beacon Trust’s expectations will ultimately be replaced.
Please note: the Wrap Fee program is designed to provide all services provided by the
firm for one fee, regardless of the volume of trading. This fee does cover all costs
imposed from the firm, however, there will be times when Beacon Trust portfolios,
and in turn your account, may go through periods of low activity. This in no way
indicates your portfolio is not being actively managed as Beacon Trust portfolio
managers are constantly reviewing the aspects of the portfolio that impact its
management. These periods may give the appearance that the Wrap Program may not
be appropriate.
Risk of Loss
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal.
Mutual fund and ETF shareholders are subject to the risks stemming from the
individual issuers of the fund’s underlying portfolio securities. Such shareholders are
also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are
required by law to distribute capital gains in the event securities are sold for a profit
and cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by
the fund itself or a broker acting on its behalf. The trading price at which a share is
transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any
shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share
NAV of a mutual fund is calculated at the end of each business day, although the actual
NAV fluctuates with intraday changes to the market value of the fund’s holdings. The
trading prices of a mutual fund’s shares may differ significantly from the NAV during
periods of market volatility, which may, among other factors, lead to the mutual fund’s
shares trading at a premium or discount to NAV.
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Shares of ETFs are listed on securities exchanges and transacted at negotiated prices
in the secondary market. Generally, ETF shares trade at or near their most recent NAV,
which is generally calculated at least once daily for indexed-based ETFs and more
frequently for actively managed ETFs. However, certain inefficiencies may cause the
shares to trade at a premium or discount to their pro rata NAV. The client will receive
a prospectus and/or other documents explaining such risks.
Options
Options allow investors to buy or sell a security at a contracted “strike” price (not
necessarily the current market price) at or within a specific period of time. Clients
may pay or collect a premium for buying or selling an option. Investors transact in
options to either hedge (limit) losses in an attempt to reduce risk or to speculate on
the performance of the underlying securities. Options transactions contain a number
of inherent risks, including the partial or total loss of principal in the event that the
value of the underlying security or index does not increase/decrease to the level of the
respective strike price. Holders of options contracts are also subject to default by the
option writer which may be unwilling or unable to perform its contractual obligations.
Market Risks
The profitability of a portion of Beacon Trust’s recommendations may depend to a
great extent upon correctly assessing the future course of price movements of stocks
and bonds. There can be no assurance that Beacon Trust will be able to predict those
price movements accurately.
Use of Independent Managers
Beacon Trust recommends the use of Independent Managers for certain clients. Beacon
Trust will continue to do ongoing due diligence of such managers, but such
recommendations rely, to a great extent, on the Independent Managers ability to
successfully implement their investment strategy.
Use of Private Collective Investment Vehicles
Beacon Trust may recommend certain clients to invest in privately placed collective
investment vehicles (some of which may be hedge funds or funds of funds). The
managers of these vehicles will have broad discretion in selecting the investments.
There are few limitations on the types of securities or other financial instruments which
may be traded and no requirement to diversify. The hedge funds may trade on margin
or otherwise leverage positions, thereby potentially increasing the risk to the vehicle.
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There are numerous other risks in investing in these securities. The client will receive a
private placement memorandum and/or other documents explaining such risks.
Management Through Separately Managed Accounts
For certain clients, Beacon Trust may manage portfolios by allocating portfolio assets
among various mutual funds or other securities on a discretionary basis using one or
more of its proprietary investment strategies (collectively referred to as “investment
strategy”). In so doing, Beacon Trust buys, sells, exchanges and/or transfers shares of
mutual funds or other securities based upon the investment strategy. While Beacon
Trust may manage accounts in a similar fashion, Beacon Trust ensures that the
management of portfolios complies with the requirements of Rule 3a-4 of the
Investment Company Act of 1940, as amended. Rule 3a-4 provides similarly managed
accounts, such as the investment strategy, with a safe harbor from the definition of an
investment company.
The investment strategy may involve a higher portfolio turnover that could negatively
impact the net after- tax gain experienced by an individual client. Securities in the
investment strategy are usually exchanged and/or transferred without regard to a
client’s individual tax ramifications.
Certain investment opportunities that become available to Beacon Trust’s clients may
be limited. As further discussed in response to Item 12 (below), Beacon Trust allocates
investment opportunities among its clients on a fair and equitable basis.
Cybersecurity Risk
Beacon Trust and its service providers are subject to risks associated with a breach in
cybersecurity. Cybersecurity is a generic term used to describe the technology,
processes and practices designed to protect networks, systems, computers, programs
and data from both intentional cyber-attacks and hacking by other computer users as
well as unintentional damage or interruption that, in either case, can result in damage
or interruption from computer viruses, network failures, computer and
telecommunications failures, infiltration by unauthorized persons and security
breaches, usage errors by their respective professionals, power outages and
catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. A
cybersecurity breach could expose both Beacon Trust and its client accounts to
substantial costs (including, without limitation, those associated with forensic analysis
of the origin and scope of the breach, increased and upgraded cybersecurity, identity
theft, unauthorized use of proprietary information, litigation, adverse investor
reaction, the dissemination of confidential and proprietary information and
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reputational damage), civil liability as well as regulatory inquiry and/or action. While
Beacon Trust has established a business continuity plan in the event of, and risk
management strategies, systems, policies, and procedures to seek to prevent,
cybersecurity breaches, there are inherent limitations in such plans, strategies,
systems, policies and procedures including the possibility that certain risks have not
been identified. Furthermore, Beacon Trust cannot control the cybersecurity plans,
strategies, systems, policies and procedures put in place by other service providers
and/or the issuers in which the clients invest.
General Risk of Loss
Investing in securities involves the risk of loss, including a loss of principal. Clients
should be prepared to bear such loss.
General Economic and Market Conditions
The success of the clients’ activities is affected by general economic and market
conditions such as interest rates, availability of credit, inflation rates, economic
uncertainty, changes in laws, trade barriers, currency exchange controls, national and
international political circumstances. These factors can affect the level and volatility
of the prices of securities, commodities, or other financial instruments and the
liquidity of the clients’ investments. Volatility or illiquidity could impair profitability
or result in losses.
Force Majeure
The Firm may be affected by force majeure events (i.e., events beyond the control of
the party claiming that the event has occurred, including, without limitation, acts of
God, fire, flood, earthquakes, outbreaks of an infectious disease, pandemic or any
other serious public health concern, war, terrorism, labor strikes, major plant
breakdowns, pipeline or electricity line ruptures, failure of technology, defective
design and construction, accidents, demographic changes, government
macroeconomic policies, social instability, etc.). Some force majeure events may
adversely affect the ability of a party to perform its obligations until it is able to
remedy the force majeure event. These risks could cause personal injury or loss of
life, damage property, or instigate disruptions of service. In addition, the cost to the
Firm of repairing or replacing damaged assets resulting from such force majeure event
could be considerable. Force majeure events that are incapable of or are too costly to
cure can have a permanently adverse effect on the Firm. Certain force majeure events
(such as war or an outbreak of an infectious disease) could also have a broader
negative impact on the world economy and international business activity.
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Geopolitical Risk
Risks outside of the financial markets, affect the markets and investments, often at
times significantly. The occurrence of geopolitical events in recent years such as (but
not limited to): Middle East instability; military conflict in Ukraine and surrounding
areas, alleged cyber-attacks by Russia, China, and North Korea; ongoing epidemics of
infectious diseases that can be spread within a country, region or globally; terrorist
attacks in the U.S. and around the world; social and political discord; governmental
debt crises, and strains on international relations between the U.S. and a number of
foreign countries, including traditional allies; new and continued political unrest in
various countries; changes in the U.S. Presidency and federal administration; can
result in market volatility, have long-term effects on the U.S. and worldwide financial
markets, and cause further economic uncertainties in the U.S. and worldwide.
Item 9. Disciplinary Information
Beacon Trust is required to disclose the facts of any legal or disciplinary events that are
material to a client’s evaluation of its advisory business or the integrity of management.
Beacon Trust does not have any required disclosures to this Item.
Item 10. Other Financial Industry Activities and Affiliations
Beacon Trust is required to disclose any relationship or arrangement that is material to
its advisory business or to its clients with certain related persons.
Affiliated Trust Company
Beacon Investment Advisory Services, Inc. (Beacon Trust) is owned by Beacon Trust
Company. Beacon Trust Company is a New Jersey Limited Purpose Trust Company,
providing full-service trust services to clients. There is a conflict of interest where
Beacon Trust recommends the services of Beacon Trust Company to clients. Beacon
Trust will only make such a recommendation if it is in the best interest of that client.
Affiliated Bank
Beacon Trust is owned by Provident Bank which provides a full suite of banking
solutions to businesses and individuals. There is a conflict of interest where Beacon
Trust recommends the services of Provident Bank to clients. Beacon Trust will only
make such a recommendation if it is in the best interest of that client.
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Item 11. Code of Ethics
Beacon Trust and persons associated with Beacon Trust (“Associated Persons”) are
permitted to buy or sell securities that it also recommends to clients consistent with
Beacon Trust’s policies and procedures.
Beacon Trust has adopted a code of ethics that sets forth the standards of conduct
expected of its associated persons and requires compliance with applicable securities
laws (“Code of Ethics”). In accordance with Section 204A of the Investment Advisers
Act of 1940 (the “Advisers Act”), its Code of Ethics contains written policies
reasonably designed to prevent the unlawful use of material non-public information.
Beacon Trust or any of its associated persons. The Code of Ethics also requires that
certain of Beacon Trust’s personnel (called “Access Persons”) report their personal
securities holdings and transactions and obtain pre-approval of certain investments
such as initial public offerings and limited offerings. The Chief Compliance Officer
does not grant preclearance (when required) where it would appear that an employee’s
trading could disadvantage its clients.
Clients and prospective clients may contact Beacon Trust to request a copy of its Code of Ethics.
Item 12. Brokerage Practices
Beacon Trust does not maintain custody of your assets that we manage, although we
may be deemed to have custody of your assets if you give us authority to withdraw
assets from your account (see Item 15— Custody, below). Your assets must be
maintained in an account at a “qualified custodian,” generally a broker-dealer or bank.
We recommend that our clients use Charles Schwab & Co., Inc. (Schwab), a
registered broker-dealer, member SIPC, as the qualified custodian.
We are independently owned and operated and are not affiliated with Schwab.
Schwab will hold your assets in a brokerage account and buy and sell securities when
we instruct them to. While we recommend that you use Schwab as custodian/broker,
you will decide whether to do so and will open your account with Schwab by entering
into an account agreement directly with them. Conflicts of interest associated with this
arrangement are described below as well as in Item 14 -- Client Referrals and Other
Compensation. You should consider these conflicts of interest when selecting your
custodian.
We do not open a custodial account for you, although we may assist you in doing so. If
you do not wish to place your assets with Schwab, then we may not be able to manage
your account. Even though your account is maintained at Schwab, and we anticipate
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that most trades will be executed through Schwab, we can still use other brokers to
execute trades for your account as described below (see “Your brokerage and custody
costs”).
How we select brokers/custodians
We use Schwab, a custodian/broker, to hold your assets and execute transactions.
When considering whether the terms that Schwab provides are, overall, most
advantageous to you when compared with other available providers and their services,
we take into account a wide range of factors, including:
• Combination of transaction execution services and asset custody services
(generally without a separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire
transfers, check requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded
funds, etc.)
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest
rates, other fees, etc.) and willingness to negotiate the prices
• Reputation, financial strength, security and stability
• Prior service to us and our clients
• Services delivered or paid for by Schwab
• Availability of other products and services that benefit us, as discussed below
(see “Products and services available to us from Schwab”)
Your brokerage and custody costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you
separately for custody services but is compensated by charging you commissions or
other fees on trades that it executes or that settle into your Schwab account. Schwab is
also compensated by earning interest on the uninvested cash in your account in
Schwab’s Cash Features’ Program. This commitment benefits clients generally because
the overall fees you pay are lower than they would be otherwise.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if
that broker provides execution quality comparable to other brokers or dealers. Although we are
not required to execute all trades through Schwab, we have determined that having Schwab
execute most trades is consistent with our duty to seek “best execution” of your trades. Best
execution means the most favorable terms for a transaction based on all relevant factors,
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including those listed above (see “How we select brokers/custodians”). By using another broker
or dealer you may pay lower transaction costs.
Products and services available to us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms
like us. They provide us and our clients with access to their institutional brokerage services
(trading, custody, reporting, and related services), many of which are not typically available to
Schwab retail customers. However, certain retail investors may be able to get institutional
brokerage services from Schwab without going through us. Schwab also makes available various
support services. Some of those services help us manage or administer our clients’ accounts,
while others help us manage and grow our business. Schwab’s support services are generally
available on an unsolicited basis (we don’t have to request them) and at no charge to us.
Following is a more detailed description of Schwab’s support services:
Services that benefit you
Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of client assets.
The investment products available through Schwab include some to which we might
not otherwise have access or that would require a significantly higher minimum initial
investment by our clients. Schwab’s services described in this paragraph generally
benefit you and your account.
Services that do not directly benefit you
Schwab also makes available to us other products and services that benefit us but do
not directly benefit you or your account. These products and services assist us in
managing and administering our clients’ accounts and operating our firm. In addition,
Schwab also makes available software and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and account
statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us
Schwab also offers other services intended to help us manage and further develop our
business enterprise. These services include:
• Educational conferences and events
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• Consulting on technology and business needs
• Consulting on legal and compliance related needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing consulting and support
Schwab provides some of these services itself. In other cases, it will arrange for third-
party vendors to provide the services to us. Schwab also discounts or waives its fees
for some of these services or pays all or a part of a third party’s fees. Schwab also
provides us with other benefits, such as occasional business entertainment of our
personnel. If you did not maintain your account with Schwab, we would be required to
pay for those services from our own resources.
Our Interest In Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to
produce or purchase them. We don’t have to pay for Schwab’s services. Schwab has
also agreed to pay for certain technology, research, marketing, and compliance
consulting products and services on our behalf once the value of our clients’ assets in
accounts at Schwab reaches certain thresholds. The fact that we receive these benefits
from Schwab is an incentive for us to recommend the use of Schwab rather than
making such a decision based exclusively on your interest in receiving the best value
in custody services and the most favorable execution of your transactions. This is a
conflict of interest. We believe, however, that taken in the aggregate our
recommendation of Schwab as custodian and broker is in the best interests of our
clients. Our selection is primarily supported by the scope, quality, and price of
Schwab’s services (see “How we select brokers/ custodians”) and not Schwab’s
services that benefit only us.
Beacon Trust mitigates such conflicts noted above through disclosure of these
arrangements in this brochure and in other disclosure documents provided at the onset
of our relationship with prospective clients. Clients have the option to purchase certain
investment products that Beacon Trust recommends through other brokers or agents
that are not affiliated with Beacon Trust.
The commissions, if appropriate, paid by Beacon Trust’s clients comply with Beacon
Trust’s duty to obtain “best execution.” Clients may pay commissions that are higher
than another qualified Financial Institution might charge to affect the same transaction
for which Beacon Trust determines that the commissions are reasonable in relation to
the value of the brokerage and research services received. In seeking best execution,
the determinative factor is not the lowest possible cost, but whether the transaction
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represents the best qualitative execution, taking into consideration the full range of a
Financial Institution’s services, including among others, the value of research
provided, execution capability, commission rates, and responsiveness. Beacon Trust
seeks competitive rates but may not necessarily obtain the lowest possible commission
rates for client transactions. In addition, Beacon Trust may benefit from directing
trades to a certain executing broker who carries out that order for Beacon Trust, and
the client. These benefits do not increase the cost to the client, and yet may benefit the
client indirectly, through better and more research, and educational programs for
Beacon Trust.
Transactions may be cleared through other Financial Institutions with whom Beacon
Trust and the Financial Institutions have entered into agreements for prime brokerage
clearing services. Beacon Trust may periodically and systematically review its
policies and procedures regarding its recommendation of Financial Institutions in light
of its duty to obtain best execution.
The client may direct Beacon Trust in writing to use a particular Financial Institution
to execute some or all transactions for the client. In that case, the client will negotiate
terms and arrangements for the account with that Financial Institution, and Beacon
Trust will not seek better execution services or prices from other Financial Institutions
or be able to “batch” client transactions for execution through other Financial
Institutions with orders for other accounts managed by Beacon Trust (as described
below). As a result, the client may pay higher commissions or other transaction costs
or greater spreads, or receive less favorable net prices, on transactions for the account
than would otherwise be the case. Subject to its duty of best execution, Beacon Trust
may decline a client’s request to direct brokerage if, in Beacon Trust’s sole discretion,
such directed brokerage arrangements would result in additional operational
difficulties.
Transactions for each client generally will be affected independently, unless Beacon
Trust decides to purchase or sell the same securities for several clients at
approximately the same time. Beacon Trust may (but is not obligated to) combine or
“batch” such orders to obtain best execution, to negotiate more favorable commission
rates, or to allocate equitably among Beacon Trust’s client’s differences in prices and
commissions or other transaction costs that might have been obtained had such orders
been placed independently. Under this procedure, transactions will generally be
averaged as to price and allocated among Beacon Trust’s clients pro rata to the
purchase and sale orders placed for each client on any given day.
To the extent that Beacon Trust determines to aggregate client orders for the purchase
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or sale of securities, including securities in which Beacon Trust’s Supervised Persons
may invest, Beacon Trust generally does so in accordance with applicable rules
promulgated under the Advisers Act and no-action guidance provided by the staff of
the U.S. Securities and Exchange Commission. Beacon Trust does not receive any
additional compensation or remuneration as a result of the aggregation. In the event
that Beacon Trust determines that a prorated allocation is not appropriate under the
particular circumstances, the allocation will be made based upon other relevant
factors, which may include: (i) when only a small percentage of the order is executed,
shares may be allocated to the account with the smallest order or the smallest position
or to an account that is out of line with respect to security or sector weightings relative
to other portfolios, with similar mandates; (ii) allocations may be given to one account
when one account has limitations in its investment guidelines which prohibit it from
purchasing other securities which are expected to produce similar investment results
and can be purchased by other accounts; (iii) if an account reaches an investment
guideline limit and cannot participate in an allocation, shares may be reallocated to
other accounts (this may be due to unforeseen changes in an account’s assets after an
order is placed); (iv) with respect to sale allocations, allocations may be given to
accounts low in cash; (v) in cases when a pro rata allocation of a potential execution
would result in a de minimis allocation in one or more accounts, Beacon Trust may
exclude the account(s) from the allocation; the transactions may be executed on a pro
rata basis among the remaining accounts; or (vi) in cases where a small proportion of
an order is executed in all accounts, shares may be allocated to one or more accounts
on a random basis.
From time-to-time, Beacon Trust may make an error in submitting a trade order on
your behalf. When this occurs, the Firm may place a correcting trade with the broker-
dealer which has custody of your account. Any losses incurred by the client will be
paid for by the Firm, and the client will be made whole based on the circumstances of
the original trade. Schwab, as the custodian will donate the amount of any gain $100
and over to charity. If a loss occurs greater than $100, the Advisor will pay for the
loss. Schwab will maintain the loss or gain if it is under $100 to minimize and offset
its administrative time and expense. Generally, if related trade errors result in both
gains and losses in your account, they may be netted.
Wrap Program
Beacon Trust may recommend/require that clients establish brokerage accounts with
the Schwab Advisor Services to maintain custody of clients’ assets and to effect trades
for their accounts. The final decision to custody assets with Schwab is at the discretion
of the Advisor’s clients, including those accounts under ERISA or IRA rules and
regulations, in which case the client is acting as either the plan sponsor or IRA
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accountholder. Beacon Trust is independently owned and operated and not affiliated
with Schwab. Schwab provides Beacon Trust with access to its institutional trading
and custody services, which are typically not available to Schwab retail investors.
These services generally are available to independent investment advisors on an
unsolicited basis, at no charge to them so long as a total of at least $10 million of the
advisor’s clients’ assets are maintained in accounts at Schwab Advisor Services.
Schwab’s services include brokerage services that are related to the execution of
securities transactions, custody, research, including that in the form of advice,
analyses and reports, and access to mutual funds and other investments that are
otherwise generally available only to institutional investors or would require a
significantly higher minimum initial investment.
For Beacon Trust client accounts maintained in its custody, Schwab generally does
not charge separately for custody services but is compensated by account holders
through commissions or other transaction- related or asset-based fees for securities
trades that are executed through Schwab or that settle into Schwab accounts.
Schwab also makes available to Beacon Trust, other products and services that benefit
Beacon Trust but may not benefit its clients’ accounts. These benefits may include
national, regional or Beacon Trust specific educational events organized and/or
sponsored by Schwab Advisor Services. Other potential benefits may include
occasional business entertainment of personnel of Beacon Trust by Schwab Advisor
Services personnel, including meals, invitations to sporting events, including golf
tournaments, and other forms of entertainment, some of which may accompany
educational opportunities.
Other of these products and services assist Beacon Trust in managing and
administering clients’ accounts. These include software and other technology (and
related technological training) that provide access to client account data (such as trade
confirmations and account statements), facilitate trade execution (and allocation of
aggregated trade orders for multiple client accounts), provide research, pricing
information and other market data, facilitate payment of Beacon Trust’s fees from its
clients’ accounts, and assist with back-office training and support functions,
recordkeeping and client reporting. Many of these services generally may be used to
service all or some substantial number of Beacon Trust’s accounts, including accounts
not maintained at Schwab Advisor Services. Schwab Advisor Services also makes
available to Beacon Trust other services intended to help Beacon Trust manage and
further develop its business enterprise. These services may include professional
compliance, legal and business consulting, publications and conferences on practice
management, information technology, business succession, regulatory compliance,
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employee benefits providers, human capital consultants, insurance and marketing.
In addition, Schwab may make available, arrange and/or pay vendors for these types
of services rendered to Beacon Trust by independent third parties. Schwab Advisor
Services may discount or waive fees it would otherwise charge for some of these
services or pay all or a part of the fees of a third-party providing these services to
Beacon Trust. While, as a fiduciary, Beacon Trust endeavors to act in its clients’ best
interests, Beacon Trust’s recommendation/requirement that clients maintain their
assets in accounts at Schwab may be based in part on the benefit to Beacon Trust of
the availability of some of the foregoing products and services and other arrangements
and not solely on the nature, cost or quality of custody and brokerage services
provided by Schwab, which may create a potential conflict of interest.
Soft Dollars
Beacon Trust currently does not have any formal soft dollar arrangements. In other
words, Beacon Trust does not have any commitments or understandings to trade with
specific brokers or trading counterparties or to generate a specified level of business
with a particular broker or trading counterparty in order to receive certain goods or
services. Even so, Beacon Trust may and does use broker-dealers that provide
(without being requested to do so) research or other products or services provided by
these broker-dealers. Beacon Trust thereby receives a benefit because it does not have
to produce or pay for the research or other products or services.
This research is used for all client accounts. This research may include a wide variety
of reports, charts, publications, or proprietary data on economic and political strategy,
credit analysis, or stock and bond market conditions and projections. In addition to
research, certain counterparties may provide invitations to attend conferences and
meetings with management representatives of issuers or with other analysts and
specialists.
The receipt of such research creates a possible conflict of interest. Beacon Trust may
have an incentive to select broker-dealers based on its interest in receiving the research
or other products or services, even though no soft dollar arrangements are in place,
rather than on clients’ interest in receiving the most favorable execution.
Software and Support Provided by Financial Institutions
In addition to the research products and/or services discussed above, Beacon Trust
may receive from Schwab or Fidelity, or other custodians, without cost, computer
software, related systems support and other services. Beacon Trust may receive the
software, related support and other services without cost because Beacon Trust renders
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asset management services to clients that, in the aggregate, maintain a certain level of
assets at Schwab, Fidelity or other custodians. Clients should be aware that Beacon
Trust’s receipt of economic benefits from a broker-dealer creates a conflict of interest
since these benefits may influence Beacon Trust’s choice of custodian over another
custodian that does not furnish similar software, systems support, or services.
Beacon Trust may receive the following benefits from Schwab or Fidelity or other
custodians: receipt of duplicate client confirmations and bundled duplicate statements;
access to a designated trading desks institutional participants; access to block trading
which provides the ability to aggregate securities transactions and then allocate the
appropriate shares to client accounts; and access to an electronic communication
network for client order entry and account information.
In addition, Beacon Trust receives from Fidelity the following: financial support for
Beacon Trust to use research, marketing, and other services. Beacon Trust will only
accept these services when it feels that Fidelity represents best execution and for
which Beacon Trust believes that the recommendation to use Fidelity at the rates
negotiated is in the best interest of its clients per Beacon Trust’s fiduciary duty to its
clients.
Brokerage for Client Referrals
Beacon Trust does not consider, in selecting or recommending broker/dealers,
whether Beacon Trust receives client referrals from the Financial Institutions or other
third party.
Item 13. Review of Accounts
For those clients to whom Beacon Trust provides investment management services,
Beacon Trust monitors those portfolios as part of an ongoing process with regular
account reviews. For those clients to whom Beacon Trust provides financial planning
and/or consulting services clients will receive reports from Beacon Trust summarizing
its analysis and conclusions as requested by the client or otherwise agreed to in writing
by Beacon Trust. Such reviews are conducted by one of Beacon Trust’s investment
adviser representatives. All investment advisory clients are encouraged to discuss their
needs, goals, and objectives with Beacon Trust and to keep Beacon Trust informed of
any changes thereto. Beacon Trust contacts ongoing investment advisory clients at least
annually to review its previous services and/or recommendations and to discuss the
impact resulting from any changes in the client’s financial situation and/or investment
objectives and whether the client wishes to impose any reasonable investment
restrictions.
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Unless otherwise agreed upon, clients are provided with transaction confirmation
notices and regular summary account statements directly from the broker-dealer or
custodian for the client accounts.
Those clients to whom Beacon Trust provides financial planning and/or consulting
services will receive reports from Beacon Trust summarizing its analysis and
conclusions as requested by the client or otherwise agreed to in writing by Beacon
Trust.
Item 14. Client Referrals and Other Compensation
Other Economic Benefit
Beacon Trust may receive economic benefits from non-clients for providing advice or
other advisory services to clients. This type of relationship poses a conflict of interest,
and any such relationship is disclosed in response to Item 12 (above). We receive an
economic benefit from Schwab in the form of the support products and services it
makes available to us and other independent investment advisors whose clients
maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for
certain products and services for which we would otherwise have to pay once the
value of our clients’ assets in accounts at Schwab reaches a certain size. You do not
pay more for assets maintained at Schwab because of these arrangements. However,
we benefit from the arrangement because the cost of these services would otherwise
be borne directly by us. You should consider these conflicts of interest when selecting
a custodian. The products and services provided by Schwab, how they benefit us, and
the related conflicts of interest are described above (see Item 12 – Brokerage
Practices.)
Client Referrals
If a client is introduced to Beacon Trust by either an unaffiliated or an affiliated
promoter, Beacon Trust in most instances will pay that promoter a referral fee in
accordance with the requirements of the Advisers Act and any corresponding state
securities law requirements. Any such referral fee is paid solely from Beacon Trust’s
investment management fee and does not result in any additional charge to the client.
Schwab Advisor Network
Beacon Trust receives client referrals from Schwab through Beacon Trust’s
participation in Schwab Advisor Network® (“the Service”). The Service is designed
to help investors find an investment advisor. Schwab is a broker-dealer independent of
and unaffiliated with Beacon Trust. Schwab does not supervise Beacon Trust and has
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no responsibility for Beacon Trust’s management of clients’ portfolios or Beacon
Trust’s other advice or services. Beacon Trust pays Schwab fees to receive client
referrals through the Service. Beacon Trust’s participation in the Service may raise
potential conflicts of interest described below.
Beacon Trust pays Schwab a Participation Fee on all referred clients’ accounts that are
maintained in custody at Schwab and a Non-Schwab Custody Fee on all accounts that
are maintained at, or transferred to, another custodian. The Participation Fee paid by
Beacon Trust is a percentage of the fees the client owes to Beacon Trust or a
percentage of the value of the assets in the client’s account, subject to a minimum
Participation Fee. Beacon Trust pays Schwab the Participation Fee for so long as the
referred client’s account remains in custody at Schwab. The Participation Fee is billed
to Beacon Trust quarterly and may be increased, decreased, or waived by Schwab
from time to time. The Participation Fee is paid by Beacon Trust and not by the client.
Beacon Trust has agreed not to charge clients through the Service fee or costs greater
than the fees or costs Beacon Trust charges clients with similar portfolios who were
not referred by the Service.
Beacon Trust generally pays Schwab a Non-Schwab Custody Fee if custody of a
referred client’s account is not maintained by, or assets in the account are transferred
from Schwab. This Fee does not apply if the client was solely responsible for the
decision not to maintain custody at Schwab. The Non-Schwab Custody Fee is a one-
time payment equal to a percentage of the assets placed with the custodian other than
Schwab. The Non-Schwab Custody fee is higher than the Participation Fees Beacon
Trust generally would pay in a single year. Thus, Beacon Trust will have an incentive
to recommend that client accounts be held in custody at Schwab.
The Participation and Non-Schwab Custody Fees will be based on assets in accounts
of Beacon Trust’s clients who were referred by Schwab and those referred clients’
family members living in the same household. Thus, Beacon Trust will have
incentives to encourage household members of clients referred through the Service to
maintain custody of their accounts and execute transactions at Schwab and to instruct
Schwab to debit Beacon Trust’s fees directly from the accounts.
For accounts of Beacon Trust’s clients maintained in custody at Schwab, Schwab will
not charge the client separately for custody but will receive compensation from
Beacon Trust’s clients in the form of commissions or other transaction-related
compensation on securities trades executed through Schwab. Schwab also will receive
a fee (generally lower than the applicable commission on trades it executes) for
clearance and settlement of trades executed through broker-dealers other than Schwab.
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Schwab’s fees for trades executed at other broker-dealers are in addition to the other
broker-dealer’s fees. Thus, Beacon Trust may have an incentive to cause trades to be
executed through Schwab rather than another broker-dealer. Beacon Trust,
nevertheless, acknowledges its duty to seek best execution of trades for client
accounts. Trades for client accounts held in custody at Schwab may be executed
through a different broker-dealer than the trades for Beacon Trust’s other clients.
Thus, trades for accounts custodied at Schwab may be executed at different times and
prices than trades for other accounts that are executed at other broker- dealers.
Item 15. Custody
BIAS is deemed to have custody over a client’s assets when it is authorized to directly
debit a client’s account for payment of the Firm’s management fee. Aside from being
able to directly debit fees, the Firm has custody of certain client accounts because of
executed standing letters of authorization (“SLOA”) for distributions to third parties.
Surprise Independent Examination
As BIAS is deemed to have custody over clients’ cash, bank accounts or securities
(for reasons other than those discussed above), the Firm is required to engage an
independent accounting Firm to perform a surprise annual examination of certain
assets and accounts over which it maintains custody. Any related opinions issued by
an independent accounting Firm are filed with the SEC and are publicly available on
the SEC’s Investment Adviser Public Disclosure website. BIAS does not have direct
access to client funds as they are maintained with an independent qualified custodian.
In addition to the reports provided by BIAS to all clients (as described in Item 13
above), clients will receive account statements directly from their custodian at least
quarterly. We urge you to compare the account statements received from the qualified
custodian and the account reports provided by BIAS.
Item 16. Investment Discretion
Beacon Trust is given the authority to exercise discretion on behalf of clients. Beacon
Trust is considered to exercise investment discretion over a client’s account if it can
affect transactions for the client without first having to seek the client’s consent.
Beacon Trust is given this authority through a limited power-of- attorney included in
the agreement between Beacon Trust and the client. Clients may request a limitation
on this authority (such as certain securities not to be bought or sold), or clients may a
have a joint discretionary arrangement, which would require clients to approve
activities. Beacon Trust may take discretion over the following activities:
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• The securities to be purchased or sold;
• The amount of securities to be purchased or sold;
• Raising cash to cover fees;
• When transactions are made;
• The Financial Institutions to be utilized; and
• The Independent Managers to be hired or fired.
Item 17. Voting Client Securities
Beacon Trust may vote client securities (proxies) on behalf of its clients. When
Beacon Trust accepts such responsibility through its Wealth Management Services’
Agreement, it will only cast proxy votes in a manner consistent with the best interest of
its clients through a vendor, ProxyTrust. Beacon Trust has opted to allow Proxy Trust
to facilitate voting. Proxy Trust will allow ISS to act in the voting capacity regarding
Beacon Trust’ client proxy voting. All proxies will be voted consistent with
guidelines established and described in Beacon Trust’s Proxy Voting Policies and
Procedures, as they may be amended from time-to- time. Clients may contact Beacon
Trust to request information about how Beacon Trust voted proxies for that client’s
securities or to get a copy of Beacon Trust’s Proxy Voting Policies and Procedures.
A brief summary of Beacon Trust’s Proxy Voting Policies and Procedures is as
follows:
• Beacon Trust retains Proxy Trust to facilitate the making of voting decisions
in the best interest of clients and ensuring that proxies are submitted in a
timely manner. Currently, Proxy Trust relies on ISS to vote proxies.
• Although the Proxy Voting Guidelines are followed as a general policy, certain
issues are considered on a case-by-case basis based on the relevant facts and
circumstances.
• Clients may direct Beacon Trust’s vote on a particular solicitation, subject to
Beacon Trust’s discretion, and clients can revoke Beacon Trust’s authority to
vote proxies.
In situations where there may be a conflict of interest in the voting of proxies due to
business or personal relationships that Beacon Trust maintains with persons having an
interest in the outcome of certain votes, Beacon Trust takes appropriate steps to ensure
that its proxy voting decisions are made in the best interest of its clients and are not the
product of such conflict. If the Chief Compliance Officer detects a conflict of interest,
Beacon Trust will, at its expense, engage the services of an outside proxy voting
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service or outside counsel who will provide an independent recommendation and/ or
advice on the direction in which Beacon Trust should vote on the proposal.
Class Actions
If a class action arises regarding securities held in the Funds’ portfolios, the Investment
Committee will determine whether Clients will (a) participate in a recovery achieved
through class actions, or (b) opt out of the class action and separately pursue their own
remedy.
Item 18. Financial Information
Beacon Trust is not required to disclose any financial information due to the following:
• Beacon Trust does not require or solicit the prepayment of more than $1,200
in fees six months or more in advance of services rendered;
• Beacon Trust does not have a financial condition that is reasonably likely to
impair its ability to meet contractual commitments to clients; and
• Beacon Trust has not been the subject of a bankruptcy petition at any time during the past
ten years.
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