Overview

Assets Under Management: $974 million
Headquarters: SAN DIEGO, CA
High-Net-Worth Clients: 161
Average Client Assets: $6 million

Services Offered

Services: Portfolio Management for Individuals, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (CASCADE ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $1,000,000 0.95%
$1,000,001 $2,000,000 0.80%
$2,000,001 $5,000,000 0.70%
$5,000,001 $10,000,000 0.50%
$10,000,001 and above 0.40%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $9,500 0.95%
$5 million $38,500 0.77%
$10 million $63,500 0.64%
$50 million $223,500 0.45%
$100 million $423,500 0.42%

Clients

Number of High-Net-Worth Clients: 161
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 97.98
Average High-Net-Worth Client Assets: $6 million
Total Client Accounts: 1,000
Discretionary Accounts: 988
Non-Discretionary Accounts: 12

Regulatory Filings

CRD Number: 326620
Last Filing Date: 2024-03-28 00:00:00
Website: https://www.cascadefinancialpartners.com/

Form ADV Documents

Primary Brochure: CASCADE ADV PART 2A (2025-03-31)

View Document Text
Part 2A of Form ADV: Firm Brochure Form ADV, Part 2A, Item 1 Cover Page Cascade Financial Partners, LLC 3579 Valley Centre Drive Suite 125 San Diego, CA 92130 Tel: (858) 379-6701 https://www.cascadefinancialpartners.com/ March 31, 2025 FORM ADV PART 2 FIRM BROCHURE This brochure provides information about the qualifications and business practices of Cascade Financial Partners, LLC. If you have any questions about the contents of this brochure, please contact us at (858) 379-6701. 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. Additional information about Cascade Financial Partners, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Cascade Financial Partners, LLC is 326620. Cascade Financial Partners, LLC is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1 Form ADV, Part 2A, Item 2 Material Changes Annual Update Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual updating amendment dated March 28, 2024, we have the following material changes to report: • We have moved our principal place of business from 11975 El Camino Real, Suite 100, San Diego, CA 92130 to 3579 Valley Centre Drive, Suite 125, San Diego, CA 92130. No changes to phone numbers. • We no longer offer annual flat fees to our clients. Please see Item 5 “Fees and Compensation” for more detailed information. • Please refer to Item 15 “Custody” for updates surrounding trustee arrangements. • We clarified our Financial Information under Item 18 to include no bankruptcies filed for Cascade. • We added additional disclosures under Item 19 involving privacy, trade errors, and class action lawsuits. 2 Form ADV, Part 2A, Item 3 Table of Contents Advisory Business .................................................................................................... 4 Fees and Compensation........................................................................................... 5 Performance-Based Fees and Side-By-Side Management ................................ 7 Types of Clients ................................................................................................ 7 Methods of Analysis, Investment Strategies, and Risk of Loss ...................... 7 Disciplinary Information ....................................................................................... 10 Other Financial Industry Activities and Affiliations .......................................... 10 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............................................................................................................. 10 Brokerage Practices ................................................................................................. 11 Review of Accounts ............................................................................................. 12 Client Referrals and Other Compensation ........................................................... 13 Custody ................................................................................................................. 13 Investment Discretion .......................................................................................... 14 Voting Client Securities ........................................................................................... 14 Financial Information ........................................................................................... 15 Addition Information ............................................................................................. 15 3 Form ADV Part 2A, Item 4 Advisory Business Cascade Financial Partners, LLC (hereinafter called “Cascade”) is a Registered Investment Adviser based in San Diego, California, and incorporated under the laws of the State of California. Cascade’s majority owners are Brian Krause and Jeffrey McCulloch. Cascade is registered with the SEC and subject to the rules and regulations of the US Advisers Act. Founded in May 2023, Cascade provides investment advisory services, which may include, but are not limited to, the review of client investment objectives and goals, recommending asset allocation strategies of managed assets among investment products such as cash, stocks, mutual funds and bonds, annuities, and/or preparing written investment strategies. Our investment advice is tailored to meet our clients’ needs and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.) by providing a signed and dated written notification, of which an e-mail is also an acceptable form of notification. Cascade provides investment advisory and other financial services through its Investment Advisory Representatives ("IAR") to accounts opened with Cascade. Managed Accounts are available to individuals and high net worth individuals. Cascade provides discretionary or non-discretionary investment advisory services to some of its clients through various managed account programs. Cascade will assist clients in determining the suitability of the Managed Account Programs for the client. Our process begins with financial planning that ranges from broad evaluations of a client’s financial affairs to more focused consultations based upon the needs of each client. Our advisors conduct thorough interviews and review pertinent documents obtained from the client and their respective advisors, such as CPA’s or estate planning attorneys. After careful review, Cascade will provide recommendations and a plan of action. While the planning process described may include review and recommendations related to tax and estate plan, Cascade does not provide legal or tax advice and does not prepare legal documents or complete tax returns. Clients should consult with their own legal and tax advisors. Written financial plans are included with our asset management services but may not be provided to all clients. Cascade and its IARs, as appropriate, will be responsible for the following: • Performing due diligence • Recommending strategic asset and style allocations • Providing research on investment product options, as needed • Development of Investment Policy Statement • Obtaining investment advisory contract from client with required financial, risk tolerance, suitability and investment vehicle selection information for each new account • Performing client suitability check on account documentation, review the investment objectives and evaluate the investment vehicle selections • Providing Firm Brochure (this document) Cascade may from time-to-time, research and recommend unaffiliated private funds to clients. The types of private funds include, but are not limited to hedge funds, real estate funds, private equity funds, and venture capital funds. 4 Investing in private funds involves various risks, which an investor should be aware of, including, but not limited to, the potential for complete loss of initial investment. A complete discussion of risks and other important information is set forth in each private fund’s offering documents, which are provided to clients for review prior to investing. Please also refer to Item 8 below for further information on risks surrounding these types of securities. We only make recommendations to private investing consulting clients that meet the qualification requirements mandated by the private fund and where we have determined that the investment is suitable and in line with the clients’ investment objectives and risk tolerances. Our policy and practice for private investments is to allocate fairly and equitably among our clients according to a specific and consistent basis so as not to advantage any firm, personal or related account and so as not to favor or disfavor any client, or group of clients, over any other. As of December 31, 2024, the firm has assets under management of Discretionary: $1,133,056,179 AUM and Non-Discretionary: $27,539,250 AUM. Form ADV, Part 2A, Item 5 Fees and Compensation The following types of fees will be assessed: Asset Management – Fees are charged quarterly in arrears and are based primarily on the average daily balance of the assets and the level of complexity of the services provided. In individual cases, Cascade has the sole discretion to negotiate fees that are lower than the standard fee shown or to waive fees. Fees are not based on the share of capital gains or capital appreciation of the funds or any portion of the funds. Comparable services for lower fees may be available from other sources. Fees for the initial quarter will be prorated based upon the number of calendar days in the calendar quarter that the advisory agreement is in effect. Fees are based on the average daily market value of the assets for the previous quarter. Annual fees range from 0.40% - 0.95%, depending on the amount of assets under management (“AUM”) – See chart below. Consulting services are included in these fees for asset management services. Fee Schedule for Asset Management: Total Account Value First $1,000,000 Next $1,000,000 Next $3,000,000 Next $5,000,000 Above $10,000,000 Maximum Annual Advisory Fee 0.95% 0.80% 0.70% 0.50% 0.40% As authorized in the client agreement, the account custodian withdraws Cascade Financial Partners, LLC’s advisory fees directly from the clients’ accounts according to the custodian’s policies, practices, and procedures. The custodial statement includes the amount of any fees paid to Cascade for advisory services. You should carefully review the statement from your custodian/broker-dealer’s statement and verify the calculation of fees. Your custodian/broker- dealer does not verify the accuracy of fee calculations. 5 Fees are charged in arrears on a quarterly basis, meaning that advisory fees for a quarter are charged on the first day of the following quarter. We may utilize margin accounts, when this happens, we typically assess fees on your “gross” assets. Clients may terminate investment advisory services obtained from Cascade without penalty upon written notice within five (5) business days after entering into the advisory agreement with Cascade. The client is responsible for any fees and charges incurred by the client from third parties as a result of maintaining the account such as transaction fees for any securities transactions executed and account maintenance or custodial fees. Thereafter, the client may terminate advisory services upon written notice delivered to and received by Cascade. Clients who terminate investment advisory services during a quarter are charged a prorated advisory fee based on the date of Cascade’s receipt of client’s written notice to terminate. Any earned but unpaid fees are immediately due and payable, and any prepaid and unearned fees will be immediately refunded. Additional Fees and Expenses In addition to advisory fees paid to Cascade as explained above, clients may pay custodial service, account maintenance, transaction, and other fees associated with maintaining the account. These fees vary by broker and/or custodian. Clients should ask Cascade for details on transaction fees or other custodial fees specific to their account, as these fees are not included in the annual advisory fee. Cascade does not share any portion of such fees. Additionally, for any mutual funds purchased, the client may pay their proportionate share of the funds’ distribution, internal management, investment advisory and administrative fees. Such fees are not shared with Cascade and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus prior to investing. As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual funds and exchange-trade funds. The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker- dealer or custodian through whom your account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, please refer to the Brokerage Practices section of this brochure. 6 Form ADV, Part 2A, Item 6 Performance-Based Fees and Side-By-Side Management Cascade Financial Partners, LLC, does not charge performance-based fees or participate in side- by-side management. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Performance-based fees are fees that are based on a share of capital gains or appreciation of the assets of a client. Our fees are calculated as described in Fees and Compensation section above and are not charged on the basis of performance of your advisory account. Form ADV, Part 2A, Item 7 Types of Clients Cascade offers investment advisory services to individuals and high net worth individuals. There is a $1,000,000 minimum account size to open and maintain an advisory account. Form ADV, Part 2A, Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss Cascade’s methods of analysis and investment strategies incorporate the client’s needs and investment objectives, time horizon, and risk tolerance. Cascade is not bound to a specific investment strategy for the management of investment portfolios but rather consider the risk tolerance levels pre-determined gathered at the account opening, as well as on an on-going basis. Examples of methodologies that our investment strategies may incorporate include: Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix of asset classes and the efficient allocation of capital to those assets by matching rates of return to a specified and quantifiable tolerance for risk. Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount of securities at regularly scheduled intervals, regardless of the price per share. This will gradually, over time, decrease the average share price of the security. Dollar-cost averaging lessens the risk of investing a large amount in a single investment at the wrong time. Technical Analysis – involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. Long-Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Short-Term Purchases – securities purchased with the expectation that they will be sold within a 7 relatively short period of time, generally less than one year, to take advantage of the securities’ short term price fluctuations. Our strategies and investments may have unique and significant tax implications. Regardless of your account size or other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Investing in securities involves risk of loss that clients should be prepared to bear. Although we manage your portfolio with strategies and in a manner consistent with your risk tolerances, there can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of loss. All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends, and other distributions), and the loss of future earnings. Regardless of the methods of analysis or strategies suggested for your particular investment goals, you should carefully consider these risks, as they all bear risks. Cascade’s primary goal for investing is to help the client maintain purchasing power over the long term. This may result in short-term variability and loss of principal. Time horizon and risk tolerance are key determinates of the proper asset allocation. Cascade’s approach focuses on taking appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or eliminate risks that do not provide compensation over the long term (i.e. individual stock risk or lack of portfolio risk). Below are some more specific risks of investing: Market Risk. The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by the client or an underlying fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. Management Risk. Cascade’s investment approach may fail to produce the intended results. If our perception of the performance of a specific asset class or underlying fund is not realized in the expected time frame, the overall performance of client’s portfolio may suffer. Equity Risk. Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower 8 rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may be affected by adverse political, legislative and tax changes, as well as by financial developments that affect the municipal issuers. Because many municipal obligations are issued to finance similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.), conditions in the sector related to the project can affect the overall municipal market. Payment of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue generated by a specific project, the operator of the project, or government appropriation or aid. There is a greater risk if investors can look only to the revenue generated by the project. In addition, municipal bonds generally are traded in the “over-the-counter” market among dealers and other large institutional investors. From time to time, liquidity in the municipal bond market (the ability to buy and sell bonds readily) may be reduced in response to overall economic conditions and credit tightening. Margin Transactions Risk. A margin transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. If the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a "margin call." An investor's overall risk includes the amount of money invested plus the amount that was loaned to them. Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Cascade has no control over the risks taken by the underlying funds. Private funds are investment vehicles that pool capital from a number of investors and invest in securities and other instruments. Private funds include many hedge funds and private equity funds. In almost all cases, private funds are structured as a private investment vehicle that is typically not registered under federal or state securities laws. To qualify to avoid registration, issuers make the funds available only to certain sophisticated or accredited investors and do not make the funds available to the general public. Many but not all private funds use leverage as part of their investment strategies. The fees for private funds typically include a management fee plus a performance fee like a share of the profits. In many cases, the mangers of the private funds can become partners with their clients by making personal investments of their own assets in the fund. Most private funds offer their securities by providing an offering memorandum or private placement memorandum known as “PPM” for short. The PPM covers important information. Investors should review this document carefully, including the risk factors, and 9 should consider conducting additional due diligence before investing. The primary risks of private funds include illiquidity and the risks associated with the underlying investments. Private equity is an asset class consisting of equity securities and debt in operating companies that are not publicly traded on a stock exchange. It is available to institutional investors and accredited investors who can commit large sums of money for long periods of time. Private equity often demands long holding periods. It includes a high degree of risk of loss, including but not limited to, the possibility of a complete loss of the entire investment. Form ADV, Part 2A, Item 9 Disciplinary Information Cascade Financial Partners, LLC or its Principal Executive Officers have not had any reportable disclosable events in the past ten years. Form ADV, Part 2A, Item 10 Other Financial Industry Activities and Affiliations Neither Cascade nor its representatives are registered with any broker dealer. Neither Cascade nor its representatives are registered as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. Neither Cascade nor its representatives have any other outside business activities. Form ADV, Part 2A, Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Cascade’s Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect client interests at all times and to demonstrate our commitment to fiduciary duties of honesty, good faith, and fair dealing. All of Cascade’s Associated Persons are expected to strictly adhere to these guidelines. Persons associated with Cascade Financial Partners, LLC, are also required to report any violations to the Code of Ethics. Additionally, the firm maintains and enforces written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about our clients or client accounts by persons associated with our firm. Participation or Interest in Client Transactions Neither our firm nor any persons associated with our firm have any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. 10 Personal Trading Practices Our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons associated with our firm buy or sell such securities for our own account. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, we have established the following restrictions in order to ensure our fiduciary responsibilities should this issue ever arise: 1. A director, officer or employee of the advisor shall not buy or sell a security for their personal portfolio(s) where their decision is substantially derived, in whole or part, by reason of his or her employment, unless the information is also available to the investing public. No owner/employee of Cascade shall prefer their own interest to that of the client. 2. The advisor maintains a list of all securities held by the company and all directors, officers, and employees. These holdings are reviewed on a quarterly basis by the principal of the firm. 3. The advisor requires that all employees must act in accordance with all applicable Federal and State regulations governing registered investment advisors. 4. The advisor may block personal trades with those of clients but will ensure that clients are not at a disadvantage. Cascade’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by contacting our CCO, Brian Krause at (858) 379-6701. Form ADV, Part 2A, Item 12 Brokerage Practices In order for Cascade to provide asset management services, we request you utilize the brokerage and custodial services of Fidelity Investments, and/or Raymond James & Associates, Inc., member New York Stock Exchange/SIPC and/or Charles Schwab & Co., Inc. (“Fidelity” and/or “RJ” and/or “Schwab”), for which we have existing relationships. Cascade is not an affiliated company with Fidelity nor RJ nor Schwab. In considering which independent qualified custodian will be the best fit for Cascade’s business model, we are evaluating the following factors, which is not an all-inclusive list:  Financial strength  Reputation  Reporting capabilities  Execution capabilities  Pricing, and  Types and quality of research While you are free to choose any broker-dealer or other service provider, we recommend that 11 you establish an account with a brokerage firm with which we have an existing relationship. Such relationships may include benefits provided to our firm, including, but not limited to research, market information, and administrative services that help our firm manage your account(s). We believe that recommended broker-dealers provide quality execution services for our clients at competitive prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the brokerage services provided by the recommended broker-dealers, including the value of research provided, the firm’s reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. You may direct us in writing to use a particular broker-dealer to execute some or all of the transactions for your account. If you do so, you are responsible for negotiating the terms and arrangements for the account with that broker-dealer. We may not be able to negotiate commissions, obtain volume discounts, or best execution. In addition, under these circumstances a difference in commission charges may exist between the commissions charged to clients who direct us to use a particular broker or dealer and other clients who do not direct us to use a particular broker or dealer. Cascade does not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Cascade does not have any formal soft dollar arrangements. When Cascade buys or sells the same security for two or more clients (including our personal accounts), we may place concurrent orders to be executed together as a single “block” in order to facilitate orderly and efficient execution. Each client account will be charged or credited with the average price per unit. We receive no additional compensation or remuneration of any kind because we aggregate client transactions. No client is favored over any other client. If an order is not completely filled, it is allocated pro-rata based on an allocation statement prepared by Cascade prior to placing the order. Because of an order’s aggregation, some clients may pay higher transaction costs, or greater spreads, or receive less favorable net prices on transactions than would otherwise be the case if the order had not been aggregated. Form ADV, Part 2A, Item 13 Review of Accounts Client accounts are reviewed at least quarterly by Brian Krause, Principal Executive Officer of the firm. Brian Krause reviews clients’ accounts with regards to their investment policies and risk tolerance levels. All accounts at Cascade are assigned to this reviewer. Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). Each client will receive at least quarterly a written report that details the clients’ account which may come from the custodian. Clients are encouraged to review these statements to verify accuracy and calculation correctness. 12 Form ADV, Part 2A, Item 14 Client Referrals and Other Compensation Cascade does not compensate any individual or firm for client referrals. In addition, Cascade does not receive compensation for referring clients to other professional service providers. Form ADV, Part 2A, Item 15 Custody Cascade does not have physical custody of any client funds and/or securities and does not take custody of client accounts at any time. Client funds and securities will be held with a bank, broker dealer, or other independent qualified custodian. However, by granting Cascade written authorization to automatically deduct fees from client accounts, Cascade is deemed to have limited custody. You will receive account statements from the independent, qualified custodian holding your funds at least quarterly. The account statement from your custodian will indicate the amount of advisory fees deducted from your account(s) each billing cycle. Clients should carefully review statements received from the custodian. Our firm, or persons associated with our firm, may affect wire transfers, such as certain ACH (Automated Clearing House) and Journal transfers, from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, as long as the client has provided us with written authorization to do so. Such written authorization is known as a Standing Letter of Authorization or SLOA. An adviser with authority to conduct such third- party wire transfers have access to the client's assets and therefore has custody of the client's assets in any related accounts. However, we do not have to obtain a surprise annual audit, as we otherwise would be required to by reason of having custody, as long as we meet the following criteria: 1. You provide a written, signed instruction to the qualified custodian that includes the third party’s name and address or account number at a custodian; 2. You authorize us in writing to direct transfers to the third party either on a specified schedule or from time to time; Your qualified custodian verifies your authorization (e.g., signature review) and 3. provides a transfer of funds notice to you promptly after each transfer; 4. You can terminate or change the instruction; 5. We have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party; 6. We maintain records showing that the third party is not a related party to us nor located at the same address as us; and 7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. 13 We hereby confirm that we meet the above criteria. Cascade may at their discretion serve as trustee to certain accounts for which we provide investment advisory services provided a successor trustee is also identified. Cascade has the right to accept or reject the trustee role. If the trustee’s role is rejected by Cascade, then the successor trustee would take its place. If the trustee’s role is accepted by Cascade, then you are required to sign a separate agreement with us and as such our capacity as trustee opens our firm to custody over the advisory accounts for which the individual serves as trustee. These accounts will be held with a bank, broker-dealer, or other qualified custodian. If Cascade acts as trustee for any of your advisory accounts, you will receive account statements from the qualified custodian(s) holding your funds and securities at least quarterly. You should carefully review account statements for accuracy. Form ADV, Part 2A, Item 16 Investment Discretion Before Cascade can buy or sell securities on your behalf, you must first sign our discretionary management agreement, a limited power of attorney, and/or trading authorization forms. By choosing to do so, you may grant the firm discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. Clients may impose limitations on discretionary authority for investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.), as well as other limitations as expressed by the client. Limitations on discretionary authority are required to be provided to the IAR in writing. Please refer to the “Advisory Business” section of this Brochure for more information on our discretionary management services. Form ADV, Part 2A, Item 17 Voting Client Securities We do not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitation to vote proxies. 14 Form ADV, Part 2A, Item 18 Financial Information Cascade is not required to provide financial information to our clients because we do not require or solicit the prepayment of more than $1,200 six or more months in advance. Additionally, Cascade has not filed a bankruptcy petition at any time. Form ADV, Part 2A, Item 19 Additional Information Your Privacy We view protecting your private information as a top priority. Pursuant to applicable privacy requirements, we have instituted policies and procedures to ensure that we keep your personal information private and secure. We do not disclose any nonpublic personal information about you to any nonaffiliated third parties, except as permitted by law. In the course of servicing your account, we may share some information with our service providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and attorneys. We restrict internal access to nonpublic personal information about you to employees who need that information in order to provide products or services to you. We maintain physical and procedural safeguards that comply with regulatory standards to guard your nonpublic personal information and to ensure our integrity and confidentiality. We will not sell information about you or your accounts to anyone. We do not share your information unless it is required to process a transaction, at your request, or required by law. You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Please contact our main office at the telephone number on the cover page of this brochure if you have any questions regarding this policy. Trade Errors In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. If a trade error results in a profit, the trade error will be corrected in the trade error account of the executing broker-dealer, and you will not keep the profit. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. 15