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Item 1: Cover Page
Crumly and Associates, Incorporated
d/b/a
Troxell Financial
and
Evergreen Wealth
Form ADV Part 2A
Investment Adviser Brochure
Troxell Financial
Evergreen Wealth
214 South Grand Avenue West
Springfield, IL 62704
(217) 321-3210
www.troxellfinancial.com
2400 Tamiami Trail N
Suite 403
Naples, FL 34103
(239) 944-2988
www.egwadvisors.com
March 2025
This Brochure provides information about the qualifications and business practices of Crumly
and Associates, Incorporated (“we,” “us,” “our”). If you have any questions about the contents
of this Brochure, please contact Bridget K. Johnson, Chief Compliance Officer, at (217) 321-3210
or info@troxellfinancial.com.
Additional information about our Firm is also available on the SEC’s website at
www.adviserinfo.sec.gov. 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.
We are a registered investment adviser. Please note that use of the term “registered
investment advisor” and a description of the Firm and/or our employees as “registered” does
not imply a certain level of skill or training. For more information on the qualifications of the
Firm and our employees who advise you, we encourage you to review this Brochure and the
Brochure Supplement(s).
Item 2: Summary of Material Changes
Annual Update
In this Item of Crumly and Associates, Incorporated dba Troxell Financial and Evergreen Wealth
(collectively referred to as the “Firm”) Form ADV 2, the Firm is required to discuss any material
changes that have been made to Form ADV since the Firm’s last Annual Amendment filing.
Material Changes since the Last Update
Since the last Annual Amendment filing on March 25, 2024, we have the following material
change to report:
• Our Firm has appointed Bridget K. Johnson as Chief Compliance Officer, and Kevin W.
Crumly as Chief Investment Officer.
Full Brochure Available
The Firm’s Form ADV may be requested at any time, without charge by contacting Bridget K.
Johnson Chief Compliance Officer at (217) 321-3210 or info@troxellfinancial.com.
Additional information about our Firm is also available on the SEC’s website at
www.adviserinfo.sec.gov. 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.
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Item 3: Table of Contents
Item 1: Cover Page ........................................................................................................................ 1
Item 2: Summary of Material Changes .......................................................................................... 2
Item 4: Advisory Business ............................................................................................................. 4
Item 5: Fees and Compensation .................................................................................................... 8
Item 6: Performance-Based Fees and Side-by-Side Management............................................... 13
Item 7: Types of Clients ............................................................................................................... 14
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 15
Item 9: Disciplinary Information.................................................................................................. 17
Item 10: Other Financial Industry Activities and Affiliations ....................................................... 18
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .. 19
Item 12: Brokerage Practices ...................................................................................................... 21
Item 13: Review of Accounts ....................................................................................................... 24
Item 14: Client Referrals and Other Compensation .................................................................... 25
Item 15: Custody ......................................................................................................................... 26
Item 16: Investment Discretion ................................................................................................... 27
Item 17: Voting Client Securities ................................................................................................. 28
Item 18: Financial Information .................................................................................................... 29
Form ADV Part 2B – Investment Adviser Brochure Supplement ................................................. 30
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Item 4: Advisory Business
Crumly and Associates, Incorporated was founded in 2011 and is primarily owned by Kevin W.
Crumly, Chairman of the Board, and Chief Investment Officer, and Wealth Advisor.
We provide portfolio management services to individuals, high net worth individuals, pension
and profit-sharing plans, charitable organization and corporations or other business entities.
We also provide financial planning services to individuals.
Portfolio Management Services
We provide continuous investment advice and portfolio management services based on the
individual needs of its clients. Through personal discussions in which goals and objectives based
on a client’s particular circumstances are established, we develop and manage a portfolio based
on the client’s needs. We will ensure that each client’s investments are suitable for that client
and consistent with their investment needs, goals, objectives, and risk tolerance. Account
supervision is guided by the stated objectives of the client (i.e., capital preservation, income
with moderate growth, growth and income, growth, and aggressive growth, etc.). It is our
practice to tailor our advisory services to the individual needs of clients.
Clients will have the opportunity to place reasonable restrictions on the types of investments
which will be made on the client’s behalf. Clients will retain individual ownership of all
securities.
We will make investment decisions for clients and allocate our clients’ investment management
assets, on a discretionary or a non-discretionary basis among mutual funds, exchange traded
funds, individual debt and equity securities, real estate investment trusts (REITs) and other
investments in accordance with the investment objectives of the client. Some or all of these
investments may have limited or no liquidity for a period of time. Some investments may
require additional minimum net worth and/or net income. We may also provide advice about
any type of investment held in a client’s portfolio.
Our clients are advised to promptly notify us if there are ever any changes in their financial
situation or investment objectives or if they wish to impose any reasonable restrictions upon
our management services.
Retirement Plan Services
We are held to the prudent expert standard of care under ERISA, accepting the fiduciary
responsibility of providing advice as the plan’s Investment Manager (providing discretionary
advice) or Investment Advisor (non-discretionary advice) services to defined contribution and
benefit plans. Bundled under our fiduciary roles we develop, review and continually maintain
the plan’s investment policy statement (IPS), prepare periodic investment monitoring reports,
provide a broad range of investment options consistent with ERISA section 404c-1, select
investment to serve as the qualified default investment alternative (QDIA), if applicable and
periodically conduct and record trustee review meetings.
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Supplemental plan services may include fiduciary education for the plan sponsor, assist in
managing the plan’s service providers, provide fee and service analysis to ensure reasonable
expenses are paid within the plan and the cost is consistent with all service agreements,
assist/or provide participant enrollment and education meetings, develop and maintain risk-
based investment portfolios, provide participant-level investment assistance, risk analysis and
retirement projection calculations.
Financial Planning
We offer integrated financial planning services which include a review of all aspects of a client’s
current financial situation or limited to certain areas of financial planning (al a carte financial
planning). Areas of analysis that may be included in an integrated financial plan are: retirement
planning, education planning, major purchase planning, life insurance needs, disability income
insurance needs, long-term care needs and estate planning needs. A description of each area of
financial planning is described below:
Retirement Planning: A written analysis will be prepared which will evaluate a client’s
retirement readiness. Retirement readiness is defined as one’s ability to replace a percentage
of pre-retirement income throughout retirement. Important factors include but are not limited
to: desired retirement age, assets available for retirement, inflation, investment rate of return,
lifestyle expenses, tax rates and minimum asset level required at death. Approximate time
needed to complete Retirement Planning is 2 to 10 hours.
Education Planning: A written analysis will be prepared that will project future college
education expenses and the required savings to meet those expenses. Important factors
include but are not limited to: number of children attending college, school of choice, existing
assets available for future college expenses, projected number of years of attending college,
inflation, investment rate of return. Approximate time needed to complete Education Planning
is estimated to be 1 to 5 hours.
Major Purchase Planning: A written analysis will be prepared that will project the future
savings required to achieve a major purchase goal such as a second home or start a business.
Important factors include but are not limited to: desired future goal amount, existing assets
available for future goal, inflation and investment rate of return. Approximate time needed to
complete Major Purchase Planning is estimated to be 1 to 5 hours.
Life Insurance Needs: A written analysis will be prepared that will calculate the desired amount
of life insurance a client should presently own. Important factors include but are not limited to:
Family size, family income, age, percentage of income to replace, lifestyle expenses, amount of
existing life insurance, current assets, health, funding for future college expenses, net worth,
emergency fund requirements, liabilities, inflation, and investment rate of return. Approximate
time needed to complete Life Insurance Needs Planning is 4 to 12 hours.
Disability Income Insurance Needs: A written analysis will be prepared that will calculate the
desired amount of disability income insurance a client should own. Important factors include
but are not limited to: Family income, age, health, years to retirement, lifestyle expenses,
percentage of income to replace, current assets, inflation and investment rate of return.
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Approximate time needed to complete Disability Income Insurance Needs Planning is estimated
to be 1 to 5 hours.
Long Term Care Needs: A written analysis will be prepared that will estimate the future cost of
potential long-term care expenses and the effect those expenses may have on a client’s net
worth and lifestyle. Important factors include but are not limited to: Age, health, income,
current assets, desired percentage of LTC expenses to cover, inflation and investment rate of
return. Approximate time needed to complete Long-Term Care Needs Planning is estimated to
be 1 to 5 hours.
Estate Planning Needs: A written analysis will be prepared that will: estimate future federal and
state estate taxes, provide strategies to minimize estate taxes and provide recommended
action steps to implement desired estate planning goals. Clients will obtain a report to share
with their estate planning attorney in order for the creation of estate planning documents.
Important factors include but are not limited to: composition of net worth, income, taxes,
current estate planning documents, inflation, and investment rate of return. Approximate time
needed to complete Estate Planning is estimated to be 4 to 15 hours.
Clients understand that when we are asked to perform an al a carte financial planning
engagement, the client’s overall financial status may not be taken into consideration. A signed
engagement letter will be used to establish and define the client / planner relationship.
In order to perform the financial planning engagement, we may request financial and personal
information such as sources of income, assets/investments, liabilities, insurance policies,
income tax returns, wills, trusts and personal and family obligations.
After analyzing and evaluating a client’s financial status goals and objectives, a written financial
plan with recommendations will be presented to the client. We will then assist in the
implementation of agreed upon strategies. The client is under no obligation to utilize our
additional services and is under no obligation to implement the advice or plan. Clients may
choose all, none or certain specific components of advice and recommendations and may
implement recommendations through service providers of their choice.
Use of Independent Managers
We may recommend that you authorize the active discretionary management of a portion of
your assets by independent investment manager(s) (“Independent Manager(s)”). We will
engage the Independent Manager(s) on your behalf. We will continue to monitor and review
your investment objectives and account performance.
When selecting an Independent Manager for you, we will review information about them from
their Form ADV, materials which they may supply and/or information from independent third
parties. Factors that we consider in selecting Independent Manager(s) include your investment
objective(s), and the Independent Manager’s investment style, performance, risks, reputation,
financial strength, reporting, pricing, and research.
We do not receive compensation for the recommendation of Independent Managers.
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Sponsor and Manager of Wrap Program
We do not participate in a Wrap Fee Program.
Fiduciary Statement
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act,
(“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing
retirement accounts.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Client Assets
As of December 31, 2024, we managed $969,825,114 in assets under management;
$606,680,081 on a discretionary basis, and $363,145,033 on a non-discretionary basis.
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Item 5: Fees and Compensation
We, depending upon the engagement, offer our services on a fee basis which may include
hourly and/or fixed fees as well as fees based upon assets under management.
In certain circumstances, fees, account minimums and payment terms are negotiable
depending on a client’s unique situation – such as the size of the aggregate related party
portfolio size, family holdings, low-cost basis securities, or certain passively advised investments
and pre-existing relationships with clients. Certain clients may pay more or less than others
depending on the amount of assets, type of portfolio, or the time involved, the degree of
responsibility assumed, complexity of the engagement, special skills needed to solve problems,
and application of experience and knowledge of the client’s situation.
Compensation – Portfolio Management Services
Annual portfolio management fees are as follows:
Household Assets Under Management
$25,000,000 - OVER
$5,000,000 - $24,999,999
$3,500,000 - $4,999,999
$2,500,000 - $3,499,999
$1,750,000 - $2,499,999
$1,250,000 - $1,749,999
$750,000 - $1,249,999
$500,000 - $749,999
$250,000 - $499,999
$150,000 - $249,999
$100,000 - $149,999
Advisory Fee
0.40%
0.50%
0.60%
0.70%
0.80%
0.90%
1.00%
1.10%
1.20%
1.30%
1.40%
Advisory fees are debited or billed quarterly in advance and are calculated based on the market
value of the account on the last day of the previous quarter. For the first quarter during which
the account is opened, the fee is charged in arrears. It is prorated based on the market value at
the time cash is deposited or assets are transferred into the account and the number of days
remaining in the quarter. Fees are negotiable. Fees will be debited from the account in
accordance with the client authorization in the client agreement. As noted in Item 7: Types of
Clients, for any household below our minimum of $100,000 each account will be assessed a $55
annual maintenance fee.
The advisory fee is deducted from the account by the custodian of the assets based on a
written authorization from the client.
If the agreement is terminated before the end of the billing quarter, the client is entitled to a
prorated refund of any pre-paid advisory fee based on the number of days remaining in the
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quarter after the termination date. In addition, the investment advisory contract may be
terminated by the client within five (5) business days of signing the contract without incurring
any advisory fees if the client has not received the firm’s disclosure brochure at least 48 hours
prior to signing the investment advisory contract.
Compensation – Retirement Plan Services
Annual fees for Retirement Plan Services range from 0.03% to 1.00%, charged quarterly in
arrears. Alternatively, Retirement Plan Services may be offered on a flat fee basis ranging from
$2,500 - $100,000 annually.
Compensation – Financial Planning
Financial Planning Services are available to all clients. Fees will be charged in one of two ways:
• On an hourly basis of $50 per hour (for clerical or paraprofessional work) or $300 per
hour (for all work handled by the adviser); or
• As a fixed fee, typically ranging from $1,000 to $7,000, depending on the nature and
complexity of each client’s circumstances, and the number of areas of analysis the client
chooses. Financial Planning areas of analysis may include:
$2,500 or less
$5,000 or less
$2,500 or less
$1,000 or less
$1,000 or less
$1,000 or less
$1,000 or less
Retirement Goal Planning
Estate Planning and Estate Tax Analysis
Life Insurance Needs Analysis
Long Term Care Needs Analysis
Disability Insurance Needs Analysis
Major Purchase Goal Planning
Education Planning
It is the client’s choice to be billed on an hourly basis or fixed fee basis. Typically, fees are
quoted on an hourly basis for ala carte engagements – one or two areas of analysis and on a
fixed fee basis for integrated engagements – three or more areas of analysis. Fees are
influenced by such factors as the scope of work performed, complexity of a client’s situation
and amount of data to be gathered. Fees are negotiable and will be documented in the client’s
financial planning engagement agreement. Fees include all client meetings necessary to
complete and present/deliver the financial plan. All financial planning fees are due in arrears
upon presentation of the financial plan or engagement with the client. Each integrated plan
takes approximately 21 hours to complete.
For ongoing services, there may be a negotiated annual maintenance fee. Ongoing services
include:
• Annual Client Update and Financial Plan Review Meeting
• Financial Account and Rewards Program Aggregation
• Asset Allocation Consulting
• Personal Financial Statement
• Virtual Vault
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Annual maintenance fees are paid in advance.
If a Financial Planning agreement is terminated before the end of the billing period, the client is
entitled to a prorated refund of any pre-paid fee based upon the total fee less the time and
services spent on the engagement prior to the termination. In addition, the financial planning
contract may be terminated by the client within five (5) business days of signing the contract
without incurring any advisory fees if the client has not received the firm’s disclosure brochure
at least 48 hours prior to signing the investment advisory contract.
Cash Balances
Some of your assets may be held as cash and remain uninvested. Holding a portion of your
assets in cash and cash alternatives, i.e., money market fund shares, may be based on your
desire to have an allocation to cash as an asset class, to support a phased market entrance
strategy, to facilitate transaction execution, to have available funds for withdrawal needs or to
pay fees or to provide for asset protection during periods of volatile market conditions. Your
cash and cash equivalents will be subject to our investment advisory fees unless otherwise
agreed upon. You may experience negative performance on the cash portion of your portfolio if
the investment advisory fees charged are higher than the returns you receive from your cash.
Retirement Plan Rollover Recommendations
As part of our investment advisory services to our clients, we may recommend that clients roll
assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account
(collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP
IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will advise on the
client’s behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from
Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts.
If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge
the client an asset-based fee as set forth in the advisory agreement the client executed with our
firm. This creates a conflict of interest because it creates a financial incentive for our firm to
recommend the rollover to the client (i.e., receipt of additional fee-based compensation).
Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover,
if clients do complete the rollover, clients are under no obligation to have the assets in an IRA
advised on by our firm. Due to the foregoing conflict of interest, when we make rollover
recommendations, we operate under a special rule that requires us to act in our clients’ best
interests and not put our interests ahead of our clients.’
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 our clients’ when making recommendations
(give loyal advice);
• avoid misleading statements about conflicts of interest, fees, and investments;
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•
follow policies and procedures designed to ensure that we give advice that is in our
clients’ best interests;
• charge no more than a reasonable fee for our services; and
• give clients basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company
plan. Also, current employees can sometimes move assets out of their company plan before
they retire or change jobs. In determining whether to complete the rollover to an IRA, and to
the extent the following options are available, clients should consider the costs and benefits of
a rollover. Note that an employee will typically have four options in this situation:
1. leaving the funds in the employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance
of understanding the differences between these types of accounts, we will provide clients with
an explanation of the advantages and disadvantages of both account types and document the
basis for our belief that the rollover transaction we recommend is in your best interests.
Other Fees
Clients may incur certain charges imposed by the Financial Institution(s) and other third parties
such as custodial fees, charges imposed directly by a mutual fund or exchange traded fund in
the account, which shall be 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.
Our Agreement and/or the separate agreement with the Financial Institution(s) may authorize
us, through the Financial Institution(s), to debit the client’s account for our fee and to directly
remit that management fee to us in accordance with applicable custody rules. The Financial
Institution(s) we recommend 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 us.
As part of our services, clients have the ability to contract with a third party (Broadridge Global
Class Action Services) who will research and file, on their behalf, class action litigation claims.
For this service, the client’s settlement will be reduced by a 20% contingency fee charged by the
third-party firm, if and when a settlement disbursement is made. Any non-lump sum payments
will be assessed a fee for each payment, not to exceed $1.25.
Broadridge does not withhold Fair Funds Program related contingency fees. Fair Funds were
established by the SEC. The Fair Funds Program provides compensation to investors who have
suffered losses due to securities violations. Broadridge will invoice the Firm directly for Fair
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Funds related contingency fees. The Firm will then deduct the fees from clients’ accounts and
remit payment to Broadridge.
Fees and Expenses (Mutual Funds Share Class Selection)
Funds generally offer multiple share classes available for investment based upon certain
eligibility and/or purchase requirements. For instance, in addition to retail share classes
(typically referred to as class A, class B and class C shares), funds may also offer institutional
share classes or other share classes that are specifically designed for purchase by investors who
meet certain specified eligibility criteria, including, for example, whether an account meets
certain minimum dollar amount thresholds or is enrolled in an eligible fee-based investment
advisory program. Institutional share classes usually have a lower expense ratio than other
share classes.
The Firm conducts periodic reviews of client holdings in mutual fund investments to ensure the
appropriateness of mutual fund share class selections and whether alternative mutual fund
share class selections are available that might be more appropriate given the client’s
particularized investment objectives and any other appropriate considerations relevant to
mutual fund share class selection. Regardless of such considerations, clients should not assume
that they will be invested in the share class with the lowest possible expense ratio.
The appropriateness of a particular fund share class selection is dependent upon a range of
different considerations, including but not limited to: the asset-based advisory fee that is
charged, whether transaction charges are applied to the purchase or sale of funds, operational
considerations associated with accessing or offering particular share classes (including the
presence of selling agreements with the fund sponsors and the Firm’s ability to access
particular share classes through the custodian), share class eligibility requirements; and the
availability of revenue sharing, distribution fees, shareholder servicing fees or other
compensation associated with offering a particular class of shares.
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Item 6: Performance-Based Fees and Side-by-Side Management
Neither we, nor any of our Supervised Persons (employees), accept performance-based fees
(fees based on a share of capital gains on or capital appreciation of the assets of a client).
We do not use a performance-based fee structure because of the potential conflict of interest.
Performance-based compensation may create an incentive for the adviser to recommend an
investment that may carry a higher degree of risk to the client.
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Item 7: Types of Clients
Portfolio management services are offered to individuals, high net worth individuals, pension
and profit-sharing plans, charitable organizations and corporations or other business entities.
Financial planning services are offered to individuals.
We require a minimum account size of $100,000 for portfolio management services, although
this may be negotiable under certain circumstances. We may group certain related client
accounts for the purposes of achieving the minimum account size. As noted above, for any
household below our minimum of $100,000 each account will be assessed a $55 annual
maintenance fee.
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Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
We often utilize fundamental analysis which attempts to measure the intrinsic value of a
security by looking at economic and financial factors (including the overall economy, industry
conditions, and the financial condition and management of the company itself) to determine if
the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating
it may be time to sell). Fundamental analysis does not attempt to anticipate market
movements. This presents a potential risk, as the price of a security can move up or down along
with the overall market regardless of the economic and financial factors considered in
evaluating the securities.
The investment strategy for a specific client is based upon the objectives stated by the client
during consultations. The client may change these objectives at any time.
We may recommend the use of Independent Manager(s) for certain clients. We will continue to
perform ongoing due diligence of such managers, but such recommendations rely, to a great
extent, on the Independent Manager(s)’ ability to successfully implement their investment
strategy. In addition, we do not have the ability to supervise the Independent Manager(s) on a
day-to-day basis, if at all.
We may recommend the use of options for certain clients. Options allow us to hedge (limit)
certain losses on positions clients hold. The option allows us to buy or sell a security at a certain
price (not the current market price). Clients pay a fee for the option. If the option falls outside
the money (i.e., the market price of the security does not justify repurchasing/selling the
security at the option price), the client will lose the fee for that option.
We may recommend the use of alternative investments for certain clients, including but not
limited to Real Estate Investment Trusts (REITs), Energy Master Limited Partnerships (MLPs),
commodities, high yield bonds, private equity, and emerging markets. These investments can
offer diversification and the potential for higher returns, but they also come with unique risks
such as higher volatility and lower liquidity compared to traditional investments. Clients should
be aware that the value of these investments can be highly sensitive to economic and market
changes, and there is a risk of loss, including the potential loss of principal.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
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. Although we manage assets in a manner consistent with your investment
objectives and risk tolerance, there can be no guarantee that our efforts will be successful.
You should be prepared to bear the following risks of loss:
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•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
•
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s underlying circumstances. For example, political,
economic, and social conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar next year will not buy as
much as a dollar today, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also referred
to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to
be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily
relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding oil
and then refining it, a lengthy process, before they can generate a profit. They carry a
higher risk of profitability than an electric company, which generates its income from a
steady stream of customers who buy electricity no matter what the economic
environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties are
not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk
of profitability, because the company must meet the terms of its obligations in good
times and bad. During periods of financial stress, the inability to meet loan obligations
may result in bankruptcy and/or a declining market value.
• Cybersecurity Risk: A breach in cyber security refers to both intentional and
unintentional events that may cause an account to lose proprietary information, suffer
data corruption, or lose operational capacity. This in turn could cause an account to
incur regulatory penalties, reputational damage, and additional compliance costs
associated with corrective measures, and/or financial loss.
• Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase
morbidity and mortality over a wide geographic area, crossing international boundaries,
and causing significant economic, social, and political disruption.
• Custodial Risk: This risk is the probability that a party to a transaction will be unable or
unwilling to fulfill its contractual obligations either due to technological errors, control
failures, malfeasance, or potential regulatory liabilities.
16
Item 9: Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of us, or the integrity of our
management. We have no information to disclose applicable to this Item.
17
Item 10: Other Financial Industry Activities and Affiliations
Financial Industry Activities
We are not registered as a broker-dealer, and none of our management persons are registered
representatives of a broker-dealer. We are not registered as and do not have an application
pending as a securities broker-dealer, futures commission merchant, commodity pool operator
or commodity trading advisor.
Accountant or Accounting Firm
Certain of our supervised persons are Certified Public Accountants (CPAs). They do not practice
traditional accounting outside of their roles at the Firm.
Insurance Company or Agency
We are a licensed insurance producer in the state of Illinois. Certain of our Investment Advisor
Representatives (IARs) are appointed with several insurance companies and receive separate
compensation for transactions implemented through various insurance companies. Clients are
not obligated to use any company for insurance product purchases and may work with any
insurance agent they choose. Insurance compensation will be separate and distinct from our
financial planning and portfolio management fees.
Lawyer or Law Firm
Bridget K. Johnson is an attorney but does not practice law either within or outside of her role
at the Firm.
Other Industry Activities or Affiliations
As noted above, we may recommend the use of Independent Manager(s) for certain clients. We
do not receive compensation for these recommendations.
18
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Our employees must comply with a Code of Ethics and Statement for Insider Trading. The Code
describes our high standard of business conduct, and fiduciary duty to its clients. The Code’s
key provisions include:
• Statement of General Principles
• Policy on and reporting of Personal Securities Transactions
• A prohibition on Insider Trading
• Restrictions on the acceptance of significant gifts
• Procedures to detect and deter misconduct and violations
• Requirement to maintain confidentiality of client information
Our employees must acknowledge the terms of the Code at least annually, and any employee
not in compliance with the Code may be subject to termination. We will provide a copy of our
Code upon request.
Participation or Interest in Client Transactions – Personal Securities Transactions
We may buy or sell securities identical to those recommended to clients for their personal
accounts. The Code of Ethics, described above, is designed to assure that the personal
securities transactions, activities and interests of our employees will not interfere with (i)
making decisions in the best interest of advisory clients and (ii) implementing such decisions
while, at the same time, allowing employees to invest for their own accounts. Under the Code
certain classes of securities, primarily mutual funds, have been designated as exempt
transactions, based upon a determination that these would materially not interfere with the
best interest of our clients. In addition, the Code requires pre-clearance of certain transactions.
Nonetheless, because the Code of Ethics in some circumstances would permit employees to
invest in the same securities as clients, there is a possibility that employees might benefit from
market activity by a client in a security held by an employee. Employee trading is continually
monitored under the Code of Ethics and designed to reasonably prevent conflicts of interest
between the Firm and our clients.
Participation or Interest in Client Transactions – Financial Interest and Principal/Agency Cross
We do not recommend to clients, or buy or sell for client accounts, securities in which they
have a material financial interest.
We will not affect any principal or agency cross securities transactions for client accounts. We
will also not cross trades between client accounts.
Participation or Interest in Client Transactions – Aggregation
We may trade in the same securities with client accounts on an aggregated basis when
consistent with our obligation of best execution. In such circumstances, the affiliated and client
19
accounts receive securities at a total average price. We will retain records of the trade order
(specifying each participating account) and its allocation, which will be completed prior to the
entry of the aggregated order. Completed orders will be allocated as specified in the initial
trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be
explained on the order.
20
Item 12: Brokerage Practices
Soft Dollar Arrangements
We have no written or verbal arrangements whereby it receives soft dollars.
Referrals from Broker/Dealers
We do not receive client referrals from broker/dealers.
Client Directed Brokerage
While not routine, the client may direct us to use a particular broker-dealer to execute some or
all transactions for the client. This brokerage direction must be requested by the client in
writing. In that case, the client will negotiate terms and arrangements for the account with that
broker-dealer, and we will not seek better execution services or prices from other broker-
dealers or be able to “batch” client transactions for execution through other broker-dealers
with orders for other accounts managed by us. By directing brokerage, 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. Not all advisers
require or allow their clients to direct brokerage. Subject to our duty of best execution, we may
decline a client’s request to direct brokerage if, in our sole discretion, such directed brokerage
arrangements would result in additional operational difficulties.
If the client requests that we arrange for the execution of securities brokerage transactions for
the client’s account, we shall direct such transactions through broker-dealers that we
reasonably believe will provide best execution. We periodically and systematically review our
policies and procedures regarding recommending broker-dealers to our client in light of our
duty to obtain best execution.
Directed Brokerage (Schwab)
We generally recommend Charles Schwab & Co., Inc. (“Schwab”), a member FINRA/SIPC, an
independent and unaffiliated broker-dealer. Schwab provides us 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 and
are not otherwise contingent upon our commitment to Schwab for any specific amount of
business (assets in custody or trading). Schwab’s services include the execution of securities
transactions, custody, research, 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 our client accounts maintained there, Schwab is compensated through commissions or
other transaction-related fees for securities trades that are executed through Schwab or that
settle into Schwab accounts. The brokerage commissions and/or transaction fees charged by
Schwab, or any other designated broker-dealer are exclusive of and in addition to our fees.
Directed Brokerage – Other Economic Benefits (Schwab)
21
We may receive from Schwab, at no cost to us, professional services, computer software and
related systems support, enabling us to better monitor client accounts maintained at Schwab.
We may receive this support without cost because of the portfolio management services
rendered to clients that maintain assets at Schwab. The support provided may benefit us, but
not our clients directly. In fulfilling our duties to our clients, we endeavor at all times to put the
interests of our clients first. Clients should be aware, however, that our receipt of economic
benefits from a broker-dealer may create a conflict of interest since these benefits may
influence our choice of broker-dealer over another broker-dealer that does not furnish similar
services, software, and systems support.
The commissions paid by our clients shall comply with our duty to obtain “best execution.”
However, a client may pay a commission that is higher than another qualified broker-dealer
might charge to effect the same transaction where we determine, in good faith, that the
commission is 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 represents the best qualitative execution, taking into consideration the
full range of a broker-dealer’s services, including among others, the value of research provided,
execution capability, commission rates, and responsiveness. Consistent with the foregoing,
while we will seek competitive rates, we may not necessarily obtain the lowest possible
commission rates for client transactions.
Schwab also makes available to us other products and services that benefit us but may not
directly benefit our clients’ accounts. Many of these products and services may be used to
service all or some substantial number of our accounts, including accounts not maintained at
Schwab.
Schwab’s products and services that assist us in managing and administering clients’ accounts
include software and other technology that (i) provide access to client account data (such as
trade confirmations and account statements); (ii) facilitate trade execution and allocate
aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other
market data; (iv) facilitate payment of our fees from our clients’ accounts; and (v) assist with
back-office functions, recordkeeping and client reporting.
Support Provided by Financial Institutions
We may receive the following benefits from the custodian: receipt of duplicate client
confirmations and bundled duplicate statements; access to a trading desk that exclusively
services its registered investment advisor group 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.
Trade Aggregation
We may aggregate trades for multiple accounts. Orders for the same security entered on behalf
of more than one client may be aggregated (i.e., blocked or bunched) subject to the
aggregation being in the best interests of all participating clients. If the order is filled at
different prices during the day, the prices are averaged for the day so that all participating
22
accounts receive the same price. If an order has not been filled completely so that there are not
enough shares to allocate among all the clients equally, shares will be allocated in good faith,
based on the following considerations: amount of cash in the account, existing asset allocation
and industry exposure, risk profile, and type of security. If a partial execution is attained at the
end of the trading day, we will generally allocate shares on a pro rata basis but may fill small
orders entirely before applying the pro rata allocation. All clients participating in each
aggregated order shall receive the average price and subject to minimum ticket charges, pay a
pro-rata portion of commissions.
Our allocation procedure seeks to be fair and equitable to all clients with no particular group or
client(s) being favored or disfavored over any other clients.
Accounts for the Firm or its employees may be included in a block trade with client accounts.
23
Item 13: Review of Accounts
Reviews
We monitor client portfolios as part of an ongoing process. Formal account reviews are typically
conducted on an annual basis. Reviews could also occur at the time of new deposits, material
changes in the client’s financial information, changes in economic cycles, at our discretion or as
often as the client directs. Reviews entail analyzing securities, sensitivity to overall markets,
economic changes, investment results, asset allocation, etc., to ensure the investment strategy
and expectations are structured to continue to meet the client’s objectives. These reviews are
conducted by one of our Investment Advisor Representatives.
Clients are encouraged to discuss their needs, goals, and objectives with us and to inform us of
any changes.
Reporting
At least quarterly, the custodian provides clients with an account statement for each client
account, which may include individual holdings, cost basis information, deposits and
withdrawals, accrued income, dividends, and performance. We may also provide clients with
periodic reports regarding their holdings, allocations, and performance.
Financial Planning – Reviews and Reporting
The initial financial plan is included as a component of the financial planning service. Clients
may receive updated financial plans for a separate fee.
24
Item 14: Client Referrals and Other Compensation
We do not receive any economic benefits (other than normal compensation and benefits
described in Item 12) from any firm or individual for providing investment advice.
Compensation – Client Referrals
We have been fortunate to receive many client referrals over the years. The referrals came
from current clients, estate planning attorneys, accountants, employees, personal friends of
employees, and other similar sources. We do not compensate referring parties for these
referrals.
25
Item 15: Custody
Fee Debiting
Clients may authorize us (in the client agreement) to debit fees directly from the client’s
account at the Custodian(s). The Custodian(s) is/are advised in writing of the limitation of our
access to the account. The Custodian(s) sends a statement to the client, at least quarterly,
indicating all amounts disbursed from the account including the amount of advisory fees paid
directly to us.
Custody – First Party Money Transfers
Clients may provide us with written ongoing authorization to wire money between the client’s
accounts held with the custodian directly to an outside financial institution (i.e., a client’s bank
account). A copy of this authorization is provided to the custodian. The authorization includes
the client’s account number(s) at the outside financial institution(s) as required.
Account Statements
As described above and in Item 13, clients receive at least quarterly statements from the
Custodian(s) that holds and maintains client’s investment assets. Clients are urged to carefully
review such statements and compare such official custodial records to the reports that we may
provide. Our reports may vary from custodial statements based on accounting procedures,
reporting dates, or valuation methodologies of certain securities.
Check Signing/Bill Payments
We are deemed to have custody over certain client assets as the Firm or a related person has
check signing (i.e., authority to pay bills) authority over client accounts. This form of custody is
offered on a limited basis. We comply with the SEC’s Custody Rule with regard to the check
signing authority; annually the Firm is subject to a Surprise Examination by an independent
accountant.
26
Item 16: Investment Discretion
We may accept limited power of attorney to act on a discretionary basis on behalf of clients. A
limited power of attorney allows us to execute trades on behalf of clients.
When such limited powers exist between the Firm and the client, we have the authority to
determine, without obtaining specific client consent, both the amount and type of securities to
be bought to satisfy client account objectives. Additionally, we may accept any reasonable
limitation or restriction to such authority on the account placed by the client. All limitations and
restrictions placed on accounts must be presented to us in writing.
If we have not been given discretionary authority, we consult with the client prior to each
trade.
27
Item 17: Voting Client Securities
Proxy Voting
Unless otherwise agreed to in writing, we do not have any authority to, nor do we, vote proxies
on behalf of clients, nor do we make any express or implied recommendation with respect to
voting proxies. Clients retain the sole responsibility for receiving and voting proxies that they
receive directly from either their custodian or transfer agents. Clients may contact us for
information about proxy voting.
28
Item 18: Financial Information
We have no financial commitment that impairs our ability to meet contractual and fiduciary
commitments to clients and have not been the subject of a bankruptcy proceeding.
We do not require prepayment of fees of both more than $1,200 per client, and more than six
months in advance; and therefore, are not required to provide a balance sheet to clients.
29
Form ADV Part 2B – Investment Adviser Brochure Supplement
Crumly and Associates, Incorporated
d/b/a
Troxell Financial
and
Evergreen Wealth
Form ADV Part 2B
Investment Adviser Brochure Supplement
Troxell Financial
Evergreen Wealth
214 South Grand Avenue West
Springfield, IL 62704
(217) 321-3210
www.troxellfinancial.com
2400 Tamiami Trail N
Suite 403
Naples, FL 34103
(239) 944-2988
www.egwadvisors.com
Kevin W. Crumly
March 2025
This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees
that supplements our Brochure. You should have received a copy of that Brochure. Please
contact Bridget K. Johnson, Chief Compliance Officer, at (217) 321-3210 or
info@troxellfinancial.com if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
30
Item 2: Educational Background and Business Experience
We generally require that employees involved in making investment decisions and providing
investment advice have a college degree and/or significant experience in the investment
management or financial services industries.
Born 1957
Kevin W. Crumly
CRD #: 2447307
Business Background:
Crumly & Assoc., Inc.
d/b/a Troxell Financial and Evergreen Wealth
Chairman of the Board, Chief Investment
Officer, and Wealth Advisor
President and Chief Compliance Officer
2024 to Present
2011 to 2024
2018 to 2020
Mutual Securities
Registered Representative
1998 to 2018
LPL Financial
Registered Representative
Formal Education after High School:
University of Illinois Springfield
Master of Business Administration
Western Illinois University
Bachelor of Business
Professional Designations:
Certified Public Accountant (CPA)
CERTIFIED FINANCIAL PLANNER (CFP®)
Accredited Investment Fiduciary® (AIF®)
IL Life and Health Insurance Licenses
Professional Certifications
Kevin W. Crumly maintains professional designations, which require the following minimum
requirements:
Certified Public Accountant (CPA)
Issued By
State Boards of Accountancy
Candidate must meet the following requirements:
Prerequisites
• Minimum experience levels (most states require at least one
year of experience providing services that involve the use of
accounting, attest, compilation, management advisory,
financial advisory, tax or consulting skills, all of which must
be achieved under the supervision of or verification by a
CPA);
• Successful passing of the Uniform CPA Examination
Education
Requirements
Exam Type
Continuing Education
Requirements
At minimum, a college education (typically 150 credit hours with at
least a baccalaureate degree and a concentration in accounting)
Uniform CPA Examination
Completion of 40 hours of continuing professional education each
year (or 80 hours over a two-year period) in order to maintain a CPA
license
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Issued By
Certified Financial Planner Board of Standards, Inc.
Candidate must meet the following requirements:
• A bachelor’s degree (or higher) from an accredited college or
Prerequisites
university, and
• 3 years of full-time personal financial planning experience
Candidate must complete a CFP®-board registered program, or hold
one of the following:
Education
Requirements
CPA
ChFC®
Chartered Life Underwriter® (CLU®)
CFA®
Ph.D. in business or economics
Doctor of Business Administration
Attorney's License
•
•
•
•
•
•
•
CFP® Certification Examination
30 hours every 2 years
Exam Type
Continuing Education
Requirements
Accredited Investment Fiduciary® (AIF®)
Issued By
fi360 (Fiduciary 360)
The AIF designation prerequisites are based on a point system – an
AIF Designation candidate must earn a minimum of three (3) points
per the valuation framework, which may include the following:
• Bachelor’s, Master’s, or Doctoral/JD Degree
• Maintenance of certain securities license(s) - Series 7, 65,
and/or 66, and/or
• Maintenance of the AAMS, CRPS, PPC, or other comparable
Prerequisites
credential
• Maintenance of the CFA, CFP®, CIMA®, CPA, CLU®, or ChFC®
designation
• Relevant Industry Experience of more than 2 years
• Meet the prerequisites and qualification and conduct
standards
32
• Attest to a code of ethics
• Maintain current contact information in fi360's designee
database
• Remit $325 in annual dues
None
None
6 hours every year with at least 4 hours coming from fi360-produced
sources
Education
Requirements
Exam Type
Continuing Education
Requirements
Item 3: Disciplinary Information
Kevin W. Crumly has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Kevin W. Crumly is a licensed insurance agent and may offer insurance products to advisory
clients which pay a commission. The receipt of a commission is generally considered to be a
conflict of interest due to the contingent nature of the compensation and this can conflict with
the fiduciary duties of a registered investment adviser. The Firm always acts in the best interest
of the client including in the sale of commission-based products to advisory clients. Clients are
not required to utilize any insurance service offered by Kevin W. Crumly.
Item 5: Additional Compensation
Kevin W. Crumly does not receive any economic benefit outside of regular salaries or bonuses
except as described in Form ADV Part 2A Items 10 and 12.
Item 6: Supervision
Kevin W. Crumly, Chairman of the Board, Chief Investment Officer, and Wealth Advisor, and
Scott M. Norris, Chief Executive Officer and Wealth Advisor, supervise the person named in this
Form ADV Part 2B Investment Adviser Brochure Supplement. Kevin W. Crumly and Scott M.
Norris supervise this person by holding regular staff, investment, and other ad hoc meetings. In
addition, Kevin W. Crumly and Scott M. Norris regularly review client reports, emails, and
trading, as well as employees’ personal securities transaction and holdings reports. Kevin W.
Crumly and Scott M. Norris may be reached at (217) 321-3210.
33
Form ADV Part 2B – Investment Adviser Brochure Supplement
Crumly and Associates, Incorporated
d/b/a
Troxell Financial
and
Evergreen Wealth
Form ADV Part 2B
Investment Adviser Brochure Supplement
Troxell Financial
Evergreen Wealth
214 South Grand Avenue West
Springfield, IL 62704
(217) 321-3210
www.troxellfinancial.com
2400 Tamiami Trail N
Suite 403
Naples, FL 34103
(239) 944-2988
www.egwadvisors.com
Scott M. Norris
March 2025
This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees
that supplements our Brochure. You should have received a copy of that Brochure. Please
contact Bridget K. Johnson, Chief Compliance Officer, at (217) 321-3210 or
info@troxellfinancial.com if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
34
Item 2: Educational Background and Business Experience
We generally require that employees involved in making investment decisions and providing
investment advice have a college degree and/or significant experience in the investment
management or financial services industries.
Born 1977
Scott M. Norris
CRD #: 4153601
Business Background:
Crumly & Assoc., Inc.
d/b/a Troxell Financial and Evergreen Wealth
Chief Executive Officer and Wealth Advisor
Vice President and Wealth Advisor
2024 to Present
2011 to 2024
2018 to 2020
Mutual Securities
Registered Representative
2004 to 2018
LPL Financial
Registered Representative
Formal Education after High School:
Western Illinois University
Bachelor of Business in Finance
Professional Designations:
CERTIFIED FINANCIAL PLANNER (CFP®)
Accredited Investment Fiduciary® (AIF®)
IL Life and Health Insurance Licenses
Professional Certifications
Scott M. Norris maintains professional designations, which require the following minimum
requirements:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Issued By
Certified Financial Planner Board of Standards, Inc.
Candidate must meet the following requirements:
• A bachelor’s degree (or higher) from an accredited college or
Prerequisites
university, and
• 3 years of full-time personal financial planning experience
Candidate must complete a CFP®-board registered program, or hold
one of the following:
Education
Requirements
CPA
ChFC
Chartered Life Underwriter (CLU)
•
•
•
CFA
Ph.D. in business or economics
Doctor of Business Administration
Attorney’s License
•
•
•
•
CFP® Certification Examination
30 hours every 2 years
Exam Type
Continuing Education
Requirements
Accredited Investment Fiduciary® (AIF®)
Issued By
fi360 (Fiduciary 360)
The AIF designation prerequisites are based on a point system – an
AIF Designation candidate must earn a minimum of three (3) points
per the valuation framework, which may include the following:
• Bachelor’s, Master’s, or Doctoral/JD Degree
• Maintenance of certain securities license(s) – Series 7, 65,
and/or 66, and/or
• Maintenance of the AAMS, CRPS, PPC, or other comparable
credential
• Maintenance of the CFA, CFP®, CIMA®, CPA, CLU, or ChFC
Prerequisites
designation
• Relevant Industry Experience of more than 2 years
• Meet the prerequisites and qualification and conduct
standards
• Attest to a code of ethics
• Maintain current contact information in fi360’s designee
database
• Remit $325 in annual dues
None
None
6 hours every year with at least 4 hours coming from fi360-produced
sources
Education
Requirements
Exam Type
Continuing Education
Requirements
Item 3: Disciplinary Information
Scott M. Norris has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Scott M. Norris is a licensed insurance agent and may offer insurance products to advisory
clients which pay a commission. The receipt of a commission is generally considered to be a
conflict of interest due to the contingent nature of the compensation and this can conflict with
the fiduciary duties of a registered investment adviser. The Firm always acts in the best interest
36
of the client including in the sale of commission-based products to advisory clients. Clients are
not required to utilize any insurance service offered by Scott M. Norris.
Item 5: Additional Compensation
Scott M. Norris does not receive any economic benefit outside of regular salaries or bonuses
except as described in Form ADV Part 2A Items 10 and 12.
Item 6: Supervision
Kevin W. Crumly, Chairman of the Board, Chief Investment Officer, and Wealth Advisor and
Scott M. Norris, Chief Executive Officer and Wealth Advisor, supervise the person named in this
Form ADV Part 2B Investment Adviser Brochure Supplement. Kevin W. Crumly and Scott M.
Norris supervise this person by holding regular staff, investment, and other ad hoc meetings. In
addition, Kevin W. Crumly and Scott M. Norris regularly review client reports, emails, and
trading, as well as employees’ personal securities transaction and holdings reports. Kevin W.
Crumly and Scott M. Norris may be reached at (217) 321-3210.
37
Form ADV Part 2B – Investment Adviser Brochure Supplement
Crumly and Associates, Incorporated
d/b/a
Troxell Financial
and
Evergreen Wealth
Form ADV Part 2B
Investment Adviser Brochure Supplement
Troxell Financial
Evergreen Wealth
214 South Grand Avenue West
Springfield, IL 62704
(217) 321-3210
www.troxellfinancial.com
2400 Tamiami Trail N
Suite 403
Naples, FL 34103
(239) 944-2988
www.egwadvisors.com
Ryan T. Davlin
March 2025
This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees
that supplements our Brochure. You should have received a copy of that Brochure. Please
contact Bridget K. Johnson, Chief Compliance Officer, at (217) 321-3210 or
info@troxellfinancial.com if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
38
Item 2: Educational Background and Business Experience
We generally require that employees involved in making investment decisions and providing
investment advice have a college degree and/or significant experience in the investment
management or financial services industries.
Born 1983
Ryan T. Davlin
CRD #: 5442481
2011 to Present
Business Background:
Crumly & Assoc., Inc.
d/b/a Troxell Financial and Evergreen Wealth
Wealth Advisor
2018 to 2020
Mutual Securities
Registered Representative
2010 to 2018
LPL Financial
Registered Representative
Formal Education after High School:
University of Illinois Springfield
Bachelor of Arts in Business Administration
Professional Designations:
CERTIFIED FINANCIAL PLANNER (CFP®)
Accredited Investment Fiduciary® (AIF®)
PPC™ (Professional Plan Consultant)
IL Life and Health Insurance Licenses
Professional Certifications
Ryan T. Davlin maintains professional designations, which requires the following minimum
requirements:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Issued By
Certified Financial Planner Board of Standards, Inc.
Candidate must meet the following requirements:
• A bachelor’s degree (or higher) from an accredited college or
Prerequisites
university, and
• 3 years of full-time personal financial planning experience
Candidate must complete a CFP®-board registered program, or hold
one of the following:
Education
Requirements
CPA
ChFC®
Chartered Life Underwriter® (CLU®)
•
•
•
CFA®
Ph.D. in business or economics
Doctor of Business Administration
Attorney's License
•
•
•
•
CFP® Certification Examination
30 hours every 2 years
Exam Type
Continuing Education
Requirements
Accredited Investment Fiduciary® (AIF®)
Issued By
fi360 (Fiduciary 360)
The AIF designation prerequisites are based on a point system – an
AIF Designation candidate must earn a minimum of three (3) points
per the valuation framework, which may include the following:
• Bachelor’s, Master’s, or Doctoral/JD Degree
• Maintenance of certain securities license(s) - Series 7, 65,
and/or 66, and/or
• Maintenance of the AAMS®, CRPS®, PPC™, or other
comparable credential
• Maintenance of the CFA®, CFP®, CIMA®, CPA, CLU®, or ChFC®
Prerequisites
designation
• Relevant Industry Experience of more than 2 years
• Meet the prerequisites and qualification and conduct
standards
• Attest to a code of ethics
• Maintain current contact information in fi360's designee
database
• Remit $325 in annual dues
None
None
6 hours every year with at least 4 hours coming from fi360-produced
sources
Education
Requirements
Exam Type
Continuing Education
Requirements
Professional Plan Consultant (PPC™)
Issued By
Prerequisites
Financial Service Standards, LLC
Candidate must have three years of direct financial plan industry
sales, service, and/or support experience
Candidate must complete a 16-hour 401k Service Training Program
Education
Requirements
Exam Type
Final certification exam (50-question, multiple choice, closed-book
exam)
12 hours every 2 years
Continuing Education
Requirements
40
Item 3: Disciplinary Information
Ryan T. Davlin has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Ryan T. Davlin is a licensed insurance agent and may offer insurance products to advisory
clients which pay a commission. The receipt of a commission is generally considered to be a
conflict of interest due to the contingent nature of the compensation and this can conflict with
the fiduciary duties of a registered investment adviser. The Firm always acts in the best interest
of the client including in the sale of commission-based products to advisory clients. Clients are
not required to utilize any insurance service offered by Ryan T. Davlin.
Item 5: Additional Compensation
Ryan T. Davlin does not receive any economic benefit outside of regular salaries or bonuses
except as described in For ADV Part 2A Items 10 and 12.
Item 6: Supervision
Kevin W. Crumly, Chairman of the Board, Chief Investment Officer, and Wealth Advisor, and
Scott M. Norris, Chief Executive Officer and Wealth Advisor, supervise the person named in this
Form ADV Part 2B Investment Adviser Brochure Supplement. Kevin W. Crumly and Scott M.
Norris supervise this person by holding regular staff, investment, and other ad hoc meetings. In
addition, Kevin W. Crumly and Scott M. Norris regularly review client reports, emails, and
trading, as well as employees’ personal securities transaction and holdings reports. Kevin W.
Crumly and Scott M. Norris may be reached at (217) 321-3210.
41
Form ADV Part 2B – Investment Adviser Brochure Supplement
Crumly and Associates, Incorporated
d/b/a
Troxell Financial
and
Evergreen Wealth
Form ADV Part 2B
Investment Adviser Brochure Supplement
Troxell Financial
Evergreen Wealth
214 South Grand Avenue West
Springfield, IL 62704
(217) 321-3210
www.troxellfinancial.com
2400 Tamiami Trail N
Suite 403
Naples, FL 34103
(239) 944-2988
www.egwadvisors.com
Ward D. Cantrall, Jr.
March 2025
This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees
that supplements our Brochure. You should have received a copy of that Brochure. Please
contact Bridget K. Johnson, Chief Compliance Officer, at (217) 321-3210 or
info@troxellfinancial.com if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
42
Item 2: Educational Background and Business Experience
We generally require that employees involved in making investment decisions and providing
investment advice have a college degree and/or significant experience in the investment
management or financial services industries.
Born 1987
Ward D. Cantrall, Jr.
CRD #: 7015740
Business Background:
Crumly & Assoc., Inc.
d/b/a Troxell Financial and Evergreen Wealth
Wealth Advisor
2018 to Present
2010 to 2018
Marine Bank
Vice President of Trust and Investment Management
Formal Education after High School:
Southern Illinois University
Bachelor of Science in Mathematics
Lincoln Land Community College
Associate of Science in Applied Science
Professional Designations:
CERTIFIED FINANCIAL PLANNER (CFP®)
IL Life and Health Insurance Licenses
Professional Certifications
Ward D. Cantrall, Jr. maintains a professional designation, which requires the following
minimum requirements:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Issued By
Certified Financial Planner Board of Standards, Inc.
Candidate must meet the following requirements:
• A bachelor’s degree (or higher) from an accredited college or
Prerequisites
university, and
• 3 years of full-time personal financial planning experience
Candidate must complete a CFP®-board registered program, or hold
one of the following:
Education
Requirements
CPA
ChFC®
Chartered Life Underwriter® (CLU®)
CFA®
Ph.D. in business or economics
•
•
•
•
•
Doctor of Business Administration
Attorney’s License
•
•
CFP® Certification Examination
30 hours every 2 years
Exam Type
Continuing Education
Requirements
Item 3: Disciplinary Information
Ward D. Cantrall, Jr. has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Ward D. Cantrall, Jr. is a licensed insurance agent and may offer insurance products to advisory
clients which pay a commission. The receipt of a commission is generally considered to be a
conflict of interest due to the contingent nature of the compensation and this can conflict with
the fiduciary duties of a registered investment adviser. The Firm always acts in the best interest
of the client including in the sale of commission-based products to advisory clients. Clients are
not required to utilize any insurance service offered by Ward D. Cantrall, Jr.
Item 5: Additional Compensation
Ward D. Cantrall, Jr. does not receive any economic benefit outside of regular salaries or
bonuses except as described in Form ADV Part 2A Items 10 and 12.
Item 6: Supervision
Kevin W. Crumly, Chairman of the Board, Chief Investment Officer, and Wealth Advisor, and
Scott M. Norris, Chief Executive Officer and Wealth Advisor, supervise the person named in this
Form ADV Part 2B Investment Adviser Brochure Supplement. Kevin W. Crumly and Scott M.
Norris supervise this person by holding regular staff, investment, and other ad hoc meetings. In
addition, Kevin W. Crumly and Scott M. Norris regularly review client reports, emails, and
trading, as well as employees’ personal securities transaction and holdings reports. Kevin W.
Crumly and Scott M. Norris may be reached at (217) 321-3210.
44
Form ADV Part 2B – Investment Adviser Brochure Supplement
Crumly and Associates, Incorporated
d/b/a
Troxell Financial
and
Evergreen Wealth
Form ADV Part 2B
Investment Adviser Brochure Supplement
Troxell Financial
Evergreen Wealth
214 South Grand Avenue West
Springfield, IL 62704
(217) 321-3210
www.troxellfinancial.com
2400 Tamiami Trail N
Suite 403
Naples, FL 34103
(239) 944-2988
www.egwadvisors.com
Erin M. Crumly
March 2025
This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees
that supplements our Brochure. You should have received a copy of that Brochure. Please
contact Bridget K. Johnson, Chief Compliance Officer, at (217) 321-3210 or
info@troxellfinancial.com if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
45
Item 2: Educational Background and Business Experience
We generally require that employees involved in making investment decisions and providing
investment advice have a college degree and/or significant experience in the investment
management or financial services industries.
Born 1987
Erin M. Crumly
CRD #: 5573170
Business Background:
Crumly & Assoc., Inc.
d/b/a Troxell Financial and Evergreen Wealth
President and Wealth Advisor
Wealth Advisor
Associate Wealth Advisor
2024 to Present
2020 to 2024
2013 to 2020
Formal Education after High School:
Illinois State University
Bachelor of Science in Finance and Insurance
Professional Designations:
CERTIFIED FINANCIAL PLANNER (CFP®)
IL Life and Health Insurance Licenses
Professional Certifications
Erin M. Crumly maintains a professional designations, which requires the following minimum
requirements:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Issued By
Certified Financial Planner Board of Standards, Inc.
Candidate must meet the following requirements:
• A bachelor’s degree (or higher) from an accredited college or
Prerequisites
university, and
• 3 years of full-time personal financial planning experience
Candidate must complete a CFP®-board registered program, or hold
one of the following:
Education
Requirements
CPA
ChFC®
Chartered Life Underwriter® (CLU®)
CFA®
Ph.D. in business or economics
Doctor of Business Administration
Attorney's License
•
•
•
•
•
•
•
CFP® Certification Examination
Exam Type
30 hours every 2 years
Continuing Education
Requirements
Item 3: Disciplinary Information
Erin M. Crumly has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Erin M. Crumly is a licensed insurance agent and may offer insurance products to advisory
clients which pay a commission. The receipt of a commission is generally considered to be a
conflict of interest due to the contingent nature of the compensation and this can conflict with
the fiduciary duties of a registered investment adviser. The Firm always acts in the best interest
of the client including in the sale of commission-based products to advisory clients. Clients are
not required to utilize any insurance service offered by Erin M. Crumly.
Item 5: Additional Compensation
Erin M. Crumly does not receive any economic benefit outside of regular salaries or bonuses
except as described in Form ADV Part 2A Items 10 and 12.
Item 6: Supervision
Kevin W. Crumly, Chairman of the Board, Chief Investment Officer, and Wealth Advisor, and
Scott M. Norris, Chief Executive Officer and Wealth Advisor, supervise the person named in this
Form ADV Part 2B Investment Adviser Brochure Supplement. Kevin W. Crumly and Scott M.
Norris supervise this person by holding regular staff, investment, and other ad hoc meetings. In
addition, Kevin W. Crumly and Scott M. Norris regularly review client reports, emails, and
trading, as well as employees’ personal securities transaction and holdings reports. Kevin W.
Crumly and Scott M. Norris may be reached at (217) 321-3210.
47
Form ADV Part 2B – Investment Adviser Brochure Supplement
Crumly and Associates, Incorporated
d/b/a
Troxell Financial
and
Evergreen Wealth
Form ADV Part 2B
Investment Adviser Brochure Supplement
Troxell Financial
Evergreen Wealth
214 South Grand Avenue West
Springfield, IL 62704
(217) 321-3210
www.troxellfinancial.com
2400 Tamiami Trail N
Suite 403
Naples, FL 34103
(239) 944-2988
www.egwadvisors.com
Timothy S. Nash
March 2025
This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees
that supplements our Brochure. You should have received a copy of that Brochure. Please
contact Bridget K. Johnson, Chief Compliance Officer, at (217) 321-3210 or
info@troxellfinancial.com if you did not receive our Brochure or if you have any questions
about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
48
Item 2: Educational Background and Business Experience
We generally require that employees involved in making investment decisions and providing
investment advice have a college degree and/or significant experience in the investment
management or financial services industries.
Born 1979
Timothy S. Nash
CRD #: 4555054
2025 to Present
Business Background:
Crumly & Assoc., Inc.
d/b/a Troxell Financial and Evergreen Wealth
Wealth Advisor
2019 to 2025
J.P. Morgan Securities
Vice President, Banker
Formal Education after High School:
University of Missouri; Columbia, Missouri
Bachelor of Science in Human Environmental Sciences, Consumer & Family Economics
Professional Designations:
Chartered Alternative Investment Analyst (CAIA)
Life and Health Insurance licenses
NMLS License
Professional Certifications
Timothy S. Nash maintains a professional designation, which requires the following minimum
requirements:
Chartered Alternative Investment Analyst (CAIA)
Issued By
Charted Alternative Investment Analyst Association (CAIA)
Candidate must meet one the following requirements:
Prerequisites
• A bachelor’s degree (or higher) from an accredited
college or university and more than one year of business
experience in the financial industry, or
• Four years of experience in the financial industry.
Self-study certification program requires the successful completion of
the Level I and Level II examinations
Two CAIA Examinations
Complete self-evaluation tool every three years
Education
Requirements
Exam Type
Continuing Education
Requirements
Item 3: Disciplinary Information
Timothy S. Nash has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Timothy S. Nash is a licensed insurance agent and may offer insurance products to advisory
clients which pay a commission. The receipt of a commission is generally considered to be a
conflict of interest due to the contingent nature of the compensation and this can conflict with
the fiduciary duties of a registered investment adviser. The Firm always acts in the best interest
of the client including in the sale of commission-based products to advisory clients. Clients are
not required to utilize any insurance service offered by Timothy S. Nash.
Item 5: Additional Compensation
Timothy S. Nash does not receive any economic benefit outside of regular salaries or bonuses
except as described in For ADV Part 2A Items 10 and 12.
Item 6: Supervision
Kevin W. Crumly, Chairman of the Board, Chief Investment Officer, and Wealth Advisor, and
Scott M. Norris, Chief Executive Officer and Wealth Advisor, supervise the person named in this
Form ADV Part 2B Investment Adviser Brochure Supplement. Kevin W. Crumly and Scott M.
Norris supervise this person by holding regular staff, investment, and other ad hoc meetings. In
addition, Kevin W. Crumly and Scott M. Norris regularly review client reports, emails, and
trading, as well as employees’ personal securities transaction and holdings reports. Kevin W.
Crumly and Scott M. Norris may be reached at (217) 321-3210.
50