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F O R M A D V P A R T 2 A
D I S C L O S U R E B R O C H U R E
Fiduciary Financial Group, LLC
Office Address:
1101 Fifth Avenue
Suite 305
San Rafael, CA 94901
Tel: 415-352-1100
cmoore@ffgwealth.com
www.ffgwealth.com
MARCH 6, 2025
This brochure provides information about the qualifications and business practices of Fiduciary
Financial Group, LLC. Being registered as a registered investment adviser does not imply a certain
level of skill or training. If you have any questions about the contents of this brochure, please
contact us at 415-352-1100. 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 Fiduciary Financial Group, LLC (CRD #285681) is available on the
SEC’s website at www.adviserinfo.sec.gov
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Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
•
This updated is in accordance with the annual filing requirements for investment
advisors. Since the previous filing on December 17 2024, the changes are as follows:
•
Christopher Moore is now our Chief Compliance Officer.
•
Item 4 has been updated with the firm’s current ownership, the most recent assets
under management calculation and our policy on investing in digital assets for
clients.
•
Item 5 has been updated to disclose our current fees for financial planning services.
•
We are no longer offering one-time planning services for an hourly fee.
Item 7 has been updated to disclose our account minimum.
Full Brochure Available
Whenever you would like to receive a complete copy of our Firm Brochure, please
contact us by telephone at: 415-352-1100 or by email at: cmoore@ffgwealth.com.
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Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................................... ii
Material Changes since the Last Update.................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Full Brochure Available .................................................................................................................................................. ii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions ............................................................................... 5
Wrap Fee Programs ......................................................................................................................................................... 5
Item 5: Fees and Compensation ....................................................................................................... 5
Client Assets Under Management .............................................................................................................................. 5
Method of Compensation and Fee Schedule .......................................................................................................... 5
Client Payment of Fees ................................................................................................................................................... 7
Additional Client Fees Charged ................................................................................................................................... 8
Prepayment of Client Fees ............................................................................................................................................ 8
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 8
External Compensation for the Sale of Securities to Clients ........................................................................... 8
Item 7: Types of Clients ....................................................................................................................... 8
Sharing of Capital Gains ................................................................................................................................................. 8
Description .......................................................................................................................................................................... 8
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 8
Account Minimums .......................................................................................................................................................... 8
Methods of Analysis ......................................................................................................................................................... 8
Investment Strategy ........................................................................................................................................................ 9
Item 9: Disciplinary Information ................................................................................................... 11
Security Specific Material Risks .................................................................................................................................. 9
Criminal or Civil Actions ............................................................................................................................................. 11
Administrative Enforcement Proceedings .......................................................................................................... 11
Self-Regulatory Organization Enforcement Proceedings ............................................................................. 11
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Item 10: Other Financial Industry Activities and Affiliations ............................................. 11
Broker-Dealer or Representative Registration ................................................................................................. 11
Futures or Commodity Registration ...................................................................................................................... 11
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 12
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 12
Trading ................................................................................................................................................... 12
Code of Ethics Description ......................................................................................................................................... 12
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 13
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 13
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Item 12: Brokerage Practices ......................................................................................................... 14
Transactions and Conflicts of Interest .................................................................................................................. 13
Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 14
Item 13: Review of Accounts ........................................................................................................... 15
Aggregating Securities Transactions for Client Accounts ............................................................................. 14
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 15
Review of Client Accounts on Non-Periodic Basis ........................................................................................... 15
Item 14: Client Referrals and Other Compensation ................................................................ 15
Content of Client Provided Reports and Frequency ........................................................................................ 15
Economic benefits provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 15
Item 15: Custody .................................................................................................................................. 16
Advisory Firm Payments for Client Referrals .................................................................................................... 15
Item 16: Investment Discretion ..................................................................................................... 16
Account Statements ...................................................................................................................................................... 16
Item 17: Voting Client Securities ................................................................................................... 16
Discretionary Authority for Trading...................................................................................................................... 16
Item 18: Financial Information ...................................................................................................... 16
Proxy Votes ...................................................................................................................................................................... 16
Balance Sheet .................................................................................................................................................................. 16
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 16
Bankruptcy Petitions during the Past Ten Years .............................................................................................. 17
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Brochure Supplement (Part 2B of Form ADV) .......................................................................... 19
®
Principal Executive Officer - Richard L. Davey, CPA, CFP
........................................................................... 19
Item 2 Educational Background and Business Experience .......................................................................... 19
Professional Certifications ......................................................................................................................................... 19
Item 3 Disciplinary Information .............................................................................................................................. 21
Item 4 Other Business Activities ............................................................................................................................. 21
Item 5 Performance Based Fee Description ....................................................................................................... 21
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 23
Item 6 Supervision ........................................................................................................................................................ 21
®
®
Trevor P. Scotto, CPA, CFP
, CEPA
....................................................................................................................... 23
Item 2 Educational Background and Business Experience .......................................................................... 23
Professional Certifications ......................................................................................................................................... 23
Item 3 Disciplinary Information .............................................................................................................................. 25
Item 4 Other Business Activities ............................................................................................................................. 25
Item 5 Performance Based Fee Description ....................................................................................................... 25
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 27
Item 6 Supervision ........................................................................................................................................................ 25
Thomas “Tom” Vogelheim, CPA, JD ........................................................................................................................ 27
Item 2 Educational Background and Business Experience .......................................................................... 27
Professional Certifications ......................................................................................................................................... 27
Item 3 Disciplinary Information .............................................................................................................................. 28
Item 4 Other Business Activities ............................................................................................................................. 28
Item 5 Performance Based Fee Description ....................................................................................................... 28
Item 6 Supervision ........................................................................................................................................................ 28
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Item 4: Advisory Business
Firm Description
Fiduciary Financial Group, LLC (“Fiduciary Financial Group”) was founded in 2016.
Richard Lloyd Davey is 36.75% owner, Trevor Scotto is 36.75% owner, and Cooper &
Vogelheim LLP is 26.5% owner.
Fiduciary Financial Group is a fee-based financial planning and investment advisory firm.
The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited
partnerships, or other commissioned products.
Fiduciary Financial Group does not act as a custodian of client assets. The client always
maintains asset control.
An evaluation of each client's initial situation is provided to the client, often in the form of
a net worth statement, risk analysis or a similar document. Periodic reviews are also
communicated to provide reminders of the specific courses of action that need to be
taken. More frequent reviews occur but are not necessarily communicated to the client
unless immediate changes are recommended.
Types of Advisory Services
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged
directly by the client on an as-needed basis.
ASSET MANAGEMENT
Fiduciary Financial Group offers discretionary direct asset management services to
advisory clients. Fiduciary Financial Group will offer clients ongoing portfolio
management services through determining individual investment goals, time horizons,
objectives, and risk tolerance. Investment strategies, investment selection, asset
allocation, portfolio monitoring and the overall investment program will be based on the
above factors. The client will authorize Fiduciary Financial Group discretionary authority
to execute selected investment program transactions as stated within the Investment
Advisory Agreement.
Model Program
Fiduciary Financial Group’s Model Program will consist of portfolios that vary in
level of risk. All of the portfolios will be invested in ETFs, Mutual Funds, individual
stocks and closed end funds.
Individual Account Program
Fiduciary Financial Group’s Individual Account Program may include investments
such as: individual stocks, mutual funds, ETFs, evergreen funds and utilization of
covered call contracts.
Fiduciary Financial Group will not advise or recommend clients to invest in digital assets.
Upon the explicit request of the Client, Fiduciary Financial Group may invest in GBTC,
BTC or ETHE for clients for a maximum of 1-2% of the total portfolio value.
Asset Management services also include Ongoing Financial Planning services as disclosed
below.
Fiduciary Financial Group will offer tax planning and tax return preparation services to
asset management clients. If the client chooses to engage us for tax preparation services,
they will enter into a separate agreement. An additional fee may be assessed depending
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on complexity of the tax situation and client asset level. If an additional fee is to be
assessed, it will be communicated to the client in advance to it being incurred.
When deemed appropriate for the Client, Fiduciary Financial Group may hire Sub-
Advisors to manage all or a portion of the assets in the Client account. Fiduciary Financial
Group has full discretion to hire and fire Sub-Advisors as they deem suitable. Sub-
Advisors will maintain the models or investment strategies agreed upon between Sub-
Advisor and Fiduciary Financial Group. Sub-Advisors execute trades on behalf of
Fiduciary Financial Group in Client accounts. Fiduciary Financial Group will be
responsible for the overall direct relationship with the Client. Fiduciary Financial Group
retains the authority to terminate the Sub-Advisor relationship at Fiduciary Financial
Group’s discretion.
PRIVATE PLACEMENTS
Fiduciary Financial Group may provide investment advice and due diligence about certain
privately issued securities for those Clients who represent they are accredited investors
or who otherwise meet certain investor standards. (To qualify as an accredited investor,
you must have a net worth, not including your primary residence of at least $1 million; or
have an income exceeding $200,000 in each of the two most recent years or joint income
with a spouse exceeding $300,000 for those years and a reasonable expectation of the
same income level in the current year.) Fiduciary Financial Group will meet with the
Client as agreed upon per the client agreement.
The fees for these services will be based on a percentage of the value of the investments
detailed in Item 5 of this brochure.
ONGOING FINANCIAL PLANNING SERVICES
Ongoing Financial Planning services are included for all Asset Management Clients and
also offered as a stand-alone service. Services may include but are not limited to
discussion and analysis of all applicable topics including; potential and current
investments, beneficiary designations on client's assets, review and selection of
appropriate tax-advantaged retirement plans, retirement income projections, social
security elections, education planning, employee benefits, tax planning, insurance
planning, business consultative services, and/or transaction planning/consulting.
Services will be detailed in the Scope of Services section in the agreement. The client is
under no obligation to act upon the investment advisor’s recommendations. If the client
elects to act on any of the recommendations, the client is under no obligation to effect
transactions through Advisor.
ERISA PLAN SERVICES
Fiduciary Financial Group provides service to qualified and non-qualified retirement
plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance
plans, and deferred compensation plans. Fiduciary Financial Group may act as either a
Limited Scope ERISA 3(21) Fiduciary.
3(21) or 3(38) advisor:
Fiduciary Financial Group typically acts as a
limited scope ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with
their investment decisions on a non-discretionary basis. As an investment advisor,
Fiduciary Financial Group has a fiduciary duty to act in the best interest of the client. The
plan sponsor is still ultimately responsible for the decisions made in their plan, though
using Fiduciary Financial Group can help the plan sponsor delegate liability by following a
diligent process.
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1.
Fiduciary Services are:
Provide non-discretionary investment advice to the Client about asset classes
and investment alternatives available for the Plan in accordance with the Plan’s
investment policies and objectives. Client will make the final decision regarding
the initial selection, retention, removal and addition of investment options.
Assist the Client in the development of an investment policy statement (“IPS”).
The IPS establishes the investment policies and objectives for the Plan. Client
shall have the ultimate responsibility and authority to establish such policies and
objectives and to adopt and amend the IPS.
Provide non-discretionary investment advice to the Plan Sponsor with respect to
the selection of a qualified default investment alternative for participants who
are automatically enrolled in the Plan or who have otherwise failed to make
investment elections. The Client retains the sole responsibility to provide all
notices to the Plan participants required under ERISA Section 404(c) (5) and
404(a)-5.
Meet with Client on a periodic basis to discuss the reports and the
investment recommendations.
Assist in monitoring investment options by preparing periodic investment
reports that document
investment performance, consistency of fund
management and conformance to the guidelines set forth in the IPS and make
recommendations to maintain, remove or replace investment options.
2.
Non-fiduciary Services are:
in the education of Plan participants about general
Assist
investment
information and the investment alternatives available to them under the Plan.
Client understands the Fiduciary Financial Group’s assistance in education of the
Plan participants shall be consistent with and within the scope of the
Department of Labor’s definition of investment education (Department of Labor
Interpretive Bulletin 96-1). As such, Fiduciary Financial Group is not providing
fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants.
Fiduciary Financial Group will not provide investment advice concerning the
prudence of any investment option or combination of investment options for a
particular participant or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding
by the employees.
Fiduciary Financial Group may provide these services or, alternatively, may arrange for
the Plan’s other providers to offer these services, as agreed upon between Fiduciary
Financial Group and Client.
3.
Fiduciary Financial Group has no responsibility to provide services related to the
following types of assets (“Excluded Assets”):
1.
2.
3.
4.
Employer securities;
Real estate (except for real estate funds or publicly traded REITs);
Stock brokerage accounts or mutual fund windows;
Participant loans;
3
5.
6.
7.
Non-publicly traded partnership interests;
Other non-publicly traded securities or property (other than collective trusts
and similar vehicles); or
Other hard-to-value or illiquid securities or property.
not
be included in calculation of Fees paid to the Fiduciary Financial
Excluded Assets will
Group under this Agreement.
3(38) Investment Manager.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
Fiduciary Financial Group can also act as an ERISA 3(38)
Investment Manager in which it has discretionary management and control of a given
retirement plan’s assets. Fiduciary Financial Group would then become solely responsible
and liable for the selection, monitoring and replacement of the plan’s investment options.
1.
Fiduciary Services are:
Fiduciary Financial Group has discretionary authority and will make the final
decision regarding the initial selection, retention, removal and addition of
investment options in accordance with the Plan’s investment policies and
objectives.
Assist the Client with the selection of a broad range of investment options
consistent with ERISA Section 404(c) and the regulations thereunder.
Provide discretionary investment advice to the Client with respect to the
selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make
investment elections. The Client retains the sole responsibility to provide all
notices to the Plan participants required under ERISA Section 404(c) (5).
2.
Non-fiduciary Services are:
in the education of Plan participants about general
Assist
investment
information and the investment alternatives available to them under the Plan.
Client understands the Fiduciary Financial Group’s assistance in education of the
Plan participants shall be consistent with and within the scope of the
Department of Labor’s definition of investment education (Department of Labor
Interpretive Bulletin 96-1). As such, Fiduciary Financial Group is not providing
fiduciary advice as defined by ERISA to the Plan participants. Fiduciary Financial
Group will not provide investment advice concerning the prudence of any
investment option or combination of investment options for a particular
participant or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding
by the employees.
Fiduciary Financial Group may provide these services or, alternatively, may arrange for
the Plan’s other providers to offer these services, as agreed upon between Fiduciary
Financial Group and Client.
3.
Fiduciary Financial Group has no responsibility to provide services related to the
following types of assets (“Excluded Assets”):
4
a.
b.
c.
d.
e.
f.
not
g.
Employer securities;
Real estate (except for real estate funds or publicly traded REITs);
Stock brokerage accounts or mutual fund windows;
Participant loans;
Non-publicly traded partnership interests;
Other non-publicly traded securities or property (other than collective trusts
and similar vehicles); or
Other hard-to-value or illiquid securities or property.
be included in calculation of Fees paid to Fiduciary Financial
Excluded Assets will
Group under the ERISA Agreement.
Client Tailored Services and Client Imposed Restrictions
SEMINARS
Fiduciary Financial Group may hold seminars to educate the public on different types of
investments and the different services they offer. The seminars are educational in nature
and no specific investment or tax advice is given. Fiduciary Financial Group does not
charge a fee for attendance to these seminars.
Wrap Fee Programs
The goals and objectives for each client are documented in our client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities. Agreements may not
be assigned without written client consent.
Client Assets Under Management
Fiduciary Financial Group does not sponsor any wrap fee programs.
Fiduciary Financial Group has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$
$
2,629,870
Date Calculated:
December 31, 2024
695,397,850
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
Assets Under Management
Annual Fee
ASSET MANAGEMENT
Fiduciary Financial Group offers discretionary asset management and ongoing financial
planning services to advisory clients are typically based on the table below or a minimum
annual fee of $7,200.
First $1,000,000
Next $1,000,000
Next $3,000,00
Next $5,000,000
Next $20,000,001
Over $30,000,000
0.95%
0.85%
0.75%
0.60%
0.50%
0.35%
*US Treasury only accounts are billed at 0.30% if total assets are $1,000,000 or greater
and 0.50% of total assets are less than $1,000,000.
5
This is a tiered/blended fee schedule, the asset management fee is calculated by applying
different rates to different portions of the portfolio. Fiduciary Financial Group may group
certain related Client accounts for the purposes of achieving the minimum account size
and determining the annualized fee.
The annual fee may be negotiable. Accounts within the same household may be combined
for a reduced fee and Fiduciary Financial Group may at its discretion reduce fees based on
potential future assets or fees from affiliated businesses. In some cases, Fiduciary
Financial Group may negotiate a flat percentage rate for these services. Fees are billed
monthly in advance. For fees charged on a percentage of assets managed, they will be
based on the average daily balance of the account for the previous month. Fees for the
first month will be based on the initial amount invested with Fiduciary Financial Group.
The calculation for the average daily balance is based on the formula (A/D) x (F/P).
A = the sum of the daily balances in the billing period
D = number of days in the billing period
F = annual management fee
For example (based on a monthly billing period)
P = number of billing periods per year
: the first step taken using the average-
daily-balance calculation method would be to take the average of the values of the Client’s
account over the course of the entire month. For instance, 25 days at $2,000,000 plus five
days at $1,500,000 averages out to approximately $1,916,666.67. This account would be
charged $1,440.98 for the month.
AUM
Monthly Fee
x .07916667% =
First $1,000,000
Next $916,666.67 x .07083333% =
Grand total for the month
Total
$791.67
$649.31
$1,440.98
Lower fees for comparable services may be available from other sources. Clients may
terminate their account within five (5) business days of signing the Investment Advisory
Agreement for a full refund. Clients may terminate advisory services with thirty (30) days
written notice. Client will be entitled to a pro rata refund for the days service was not
provided in the final month. The refund will either be refunded back to the account or a
check will be mailed to the client if the account has moved prior to refund. Client shall be
given thirty (30) days prior written notice of any increase in fees, and client will
acknowledge, in writing, any agreement of increase in said fees.
Investors meeting certain regulatory criteria have the option to invest in a few private
placement programs. Fiduciary Financial Group does not have any financial arrangement
with these firms. The fees charged to the client are assessed like any other investment
when calculating the total fee as described in the “Investment Advisory Agreement”.
Fiduciary Financial Group may also utilize the services of a Sub-Advisor to manage
Clients’ investment portfolios. Fiduciary Financial Group will enter into Sub-Advisor
agreements with other registered investment advisor firms. When using Sub-Advisors,
6
the Client will not pay additional fees. The Sub-Advisors fees are inclusive of the fees
charged by Fiduciary Financial Group.
PRIVATE PLACEMENTS
For investors that meet the accredited investor standards or other appropriate regulatory
standards, clients have the option to invest in a few private placement programs.
Fiduciary Financial Group does not have any financial arrangement with these firms. The
fees charged to the client are assessed like any other investment when calculating the
total fee as described above in the Asset Management section of Item 5. The asset may be
priced by the provider of the asset according to their pricing policy or may also involve
independent pricing services for assets that are priced in that manner. The Advisor itself,
does not price any investment or security for which it charges a management fee or that is
included in the portfolio return.
ONGOING FINANCIAL PLANNING SERVICES
For Asset Management Clients, the fees for both services are combined and charged as
one fee. For stand-alone Ongoing Financial Planning Services, fees are based on an annual
negotiable fixed fee between $7,200 and $100,000 depending on the client’s needs and
the complexity of the plan. Fees are billed in equal installments at the beginning of each
month. Client has the right to cancel within 5 business days of signing the agreement
without penalty. After the initial 5 business days, either party may cancel by providing 30
day written notice to the other party.
ERISA PLAN SERVICES
The annual fees are based on the market value of the Included Assets and will not exceed
1%. The annual fee may be negotiable. Fees may be charged quarterly or monthly in
arrears or in advance based on the assets as calculated by the custodian or record keeper
of the Included Assets (without adjustments for anticipated withdrawals by Plan
participants or other anticipated or scheduled transfers or distribution of assets) on the
last business day of the previous quarter/month. If the services to be provided start any
time other than the first day of a quarter/month, the fee will be prorated based on the
number of days remaining in the quarter/month. If this Agreement is terminated prior to
the end of the fee period, Fiduciary Financial Group shall be entitled to a prorated fee
based on the number of days during the fee period services were provided or the Plan or
Plan Sponsor will be entitled to a pro rata refund for the days service was not provided in
the final period.
Client Payment of Fees
The fee schedule, which includes compensation of Fiduciary Financial Group for the
services is described in detail in Schedule A of the ERISA Plan Agreement. The Plan is
obligated to pay the fees; however, the Plan Sponsor may elect to pay the fees. Client may
elect to be billed directly or have fees deducted from Plan Assets. Fiduciary Financial
Group does not reasonably expect to receive any additional compensation, directly or
indirectly, for its services under this Agreement. If additional compensation is received,
Fiduciary Financial Group will disclose this compensation, the services rendered, and the
payer of compensation. Fiduciary Financial Group will offset the compensation against the
fees agreed upon under this Agreement.
Investment management fees are billed monthly in advance, meaning we bill you at the
beginning of the month. Fees are usually deducted from a designated client account to
7
facilitate billing. The client must consent in advance to direct debiting of their investment
account.
Additional Client Fees Charged
Fees for financial plans are billed in equal installments at the beginning of each month.
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, and exchange-traded funds. These charges may
include Mutual Fund
transactions fees, postage and handling and miscellaneous fees (fee levied to recover
costs associated with fees assessed by self-regulatory organizations).
Prepayment of Client Fees
Fiduciary Financial Group, in its sole discretion, may waive its minimum fee and/or
charge a lesser investment advisory fee based upon certain criteria (e.g., historical
relationship, type of assets, anticipated future earning capacity, anticipated future
additional assets, dollar amounts of assets to be managed, related accounts, account
composition, negotiations with clients, etc.). For more details on the brokerage practices,
see Item 12 of this brochure.
External Compensation for the Sale of Securities to Clients
Fiduciary Financial Group charges asset management fees monthly in advance.
Fiduciary Financial Group does not receive any external compensation for the sale of
securities to clients, nor do any of the investment advisor representatives of Fiduciary
Financial Group.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
Fiduciary Financial Group does not use a performance-based fee structure because of the
conflict of interest. Performance based compensation may create an incentive for the
advisor to recommend an investment that may carry a higher degree of risk to the client.
Item 7: Types of Clients
Description
Fiduciary Financial Group generally provides investment advice to individuals, pension
and profit sharing plans, high net worth individuals and corporations or business entities.
Account Minimums
Fiduciary Financial Group requires an account minimum of $1,500,000. Fiduciary
Financial Group reserves the right to waive or lower this minimum at their sole
discretion.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Fiduciary Financial Group may utilize fundamental analysis, technical analysis, and
cyclical analysis when managing client’s assets. Investing in securities involves risk of loss
8
that clients should be prepared to bear. Past performance is not a guarantee of future
returns.
Fundamental analysis involves evaluating a stock using real data such as company
revenues, earnings, return on equity, and profits margins to determine underlying value
and potential growth. Technical analysis involves evaluating securities based on past
prices and volume. Cyclical analysis involves analyzing the movement of a security against
the cycles of the market.
Fundamental analysis may involve interest rate risk, market risk, business risk, and
financial risk. Risks involved in technical analysis are inflation risk, reinvestment risk, and
market risk. Cyclical analysis involves inflation risk, market risk, and currency risk.
information
The main sources of
include financial newspapers and magazines,
Morningstar, annual reports, prospectuses, and filings with the Securities and Exchange
Commission.
Investment Strategy
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. Each
client is encouraged to complete an Investment Policy Statement or Risk Tolerance that
documents their objectives and their desired investment strategy.
Security Specific Material Risks
Other strategies may include long-term purchases, short-term purchases, trading, and
option writing (including covered options, uncovered options or spreading strategies).
All investment programs have certain risks that are borne by the investor. Fundamental
analysis may involve interest rate risk, market risk, business risk, and financial risk. Risks
involved in technical analysis are inflation risk, reinvestment risk, and market risk.
Cyclical analysis involves inflation risk, market risk, and currency risk.
Interest-rate Risk
•
Our investment approach constantly keeps the risk of loss in mind. Investors face the
following investment risks and should discuss these risks with Fiduciary Financial Group:
• Market 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.
•
: 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 particular underlying circumstances.
For example, political, economic and social conditions may trigger market
Inflation Risk
events.
: When any type of inflation is present, a dollar today will buy more
than a dollar next year, because purchasing power is eroding at the rate of
• Currency Risk
inflation.
: 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.
9
• Reinvestment Risk
• Business 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.
• Liquidity 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.
• Financial 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.
• Private Equity/Placement 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.
• REIT Risk:
Because offerings are exempt from registration
requirements, no regulator has reviewed the offerings to make sure the risks
associated with the investment and all material facts about the entity raising
money are adequately disclosed. Securities offered through private placements
are generally illiquid, meaning there are limited opportunities to resell the
security. Risk of the underlying investment may be significantly higher than
publicly traded investments.
• Long-term purchases
To the extent that a Client invests in REITs, it is subject to risks
generally associated with investing in real estate, such as (i) possible declines in
the value of real estate, (ii) adverse general and local economic conditions, (iii)
possible lack of availability of mortgage funds, (iv) changes in interest rates, and
(v) environmental problems. In addition, REITs are subject to certain other risks
related specifically to their structure and focus such as: dependency upon
management skills; limited diversification; the risks of locating and managing
financing for projects; heavy cash flow dependency; possible default by
borrowers; the costs and potential losses of self-liquidation of one or more
holdings; the possibility of failing to maintain exemptions from securities
registration; and, in many cases, relatively small market capitalization, which
may result in less market liquidity and greater price volatility.
• Short-term purchases
: Long-term investments are those vehicles purchased with
the intention of being held for more than one year. Typically, the expectation of
the investment is to increase in value so that it can eventually be sold for a profit.
In addition, there may be an expectation for the investment to provide income.
One of the biggest risks associated with long-term investments is volatility, the
fluctuations in the financial markets that can cause investments to lose value.
: Short-term investments are typically held for one year or
less. Generally, there is not a high expectation for a return or an increase in
value. Typically, short-term investments are purchased for the relatively greater
10
• Trading risk
degree of principal protection they are designed to provide. Short-term
investment vehicles may be subject to purchasing power risk — the risk that
your investment’s return will not keep up with inflation.
• Options Trading
: Investing involves risk, including possible loss of principal. There is
no assurance that the investment objective of any fund or investment will be
achieved.
: The risks involved with trading options are that they are very
time sensitive investments. An options contract is generally a few months. The
buyer of an option could lose his or her entire investment even with a correct
prediction about the direction and magnitude of a particular price change if the
price change does not occur in the relevant time period (i.e., before the option
expires). Additionally, options are less tangible than some other investments. An
option is a “book-entry” only investment without a paper certificate of
• Cryptocurrency
ownership.
: Crypto-assets are high-risk
• Cryptocurrency trusts
investments. The price of
cryptocurrency can go up and down quickly in a short amount of time. Some
platforms are more secure than others and may not be protected from being
hacked and having your digital wallet stolen. The value depends on popular
opinion and is affected by things like media hype and investor opinion.
: Cryptocurrency trusts only trade during regular stock
market hours, coin trusts trade like over the counter stocks and may trade at a
discount or premium to the underlying cryptocurrency. ETF and Trust providers
may charge a management fee.
Item 9: Disciplinary Information
Criminal or Civil Actions
Administrative Enforcement Proceedings
Fiduciary Financial Group and its management have not been involved in any criminal or
civil action required to be reported.
Self-Regulatory Organization Enforcement Proceedings
Fiduciary Financial Group and its management have not been involved in administrative
enforcement proceedings required to be reported.
Fiduciary Financial Group and its management have not been involved in legal or
disciplinary events related to past or present investment clients required to be reported.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Futures or Commodity Registration
Fiduciary Financial Group is not registered as a broker-dealer and no affiliates are
registered representatives of a broker-dealer.
Neither Fiduciary Financial Group nor its employees are registered or has an application
pending to register as a futures commission merchant, commodity pool operator, or a
commodity trading advisor.
11
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Richard Davey is a licensed real estate agent. He spends less than 5% of his time in this
capacity. He may offer Clients services from this business. As a real estate agent, he may
receive separate yet typical compensation for these services.
These practices represent conflicts of interest because it gives an incentive to recommend
services for a fee. This conflict is mitigated by disclosures, procedures and the firm’s
fiduciary obligation to place the best interest of the Client first and the Clients are not
required to purchase any products. Clients have the option to purchase these services
through another agent of their choosing.
Tom Vogelheim is an owner and Certified Public Accountant for Cooper & Vogelheim LLP.
Approximately 60% of his time is spent working in this practice.
He is also the owner of the law firm, FFG Law, A Professional Corporation. Approximately
15% of his time is spent on this practice.
He is also an investment advisor representative with EFS Associates. This entity is
affiliated with Fiduciary Financial Group. Approximately 5% of his time is spent on this
business.
These practices represent conflicts of interest because it gives Mr. Vogelheim the
opportunity to solicit these services to clients of Fiduciary Financial Group. This conflict is
mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to act in the
client’s best interest. Clients have the right to purchase these services through another
Recommendations or Selections of Other Investment Advisors and Conflicts of
CPA, attorney or investment advisor representative of their choosing.
Interest
Fiduciary Financial Group may hire Sub-Advisors to manage all or a portion of the assets
in the Client account. This creates a conflict of interest as Fiduciary Financial Group may
select sub-advisors who charge a lower fee than other sub-advisors. This conflict is
mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to act in the
client’s best interest. Prior to hiring a Sub-Advisor, Fiduciary Financial Group will ensure
the Sub-Advisor is properly registered/notice filed in the appropriate jurisdictions.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
The employees of Fiduciary Financial Group have committed to a Code of Ethics (“Code”).
The purpose of our Code is to set forth standards of conduct expected of Fiduciary
Financial Group employees and addresses conflicts that may arise. The Code defines
acceptable behavior for employees of Fiduciary Financial Group. The Code reflects
Fiduciary Financial Group and its supervised persons’ responsibility to act in the best
interest of their client.
One area the Code addresses is when employees buy or sell securities for their personal
accounts and how to mitigate any conflict of interest with our clients. We do not allow any
employees to use non-public material information for their personal profit or to use
internal research for their personal benefit in conflict with the benefit to our clients.
Fiduciary Financial Group’s policy prohibits any person from acting upon or otherwise
misusing non-public or inside information. No advisory representative or other employee,
12
officer or director of Fiduciary Financial Group may recommend any transaction in a
security or its derivative to advisory clients or engage in personal securities transactions
for a security or its derivatives if the advisory representative possesses material, non-
public information regarding the security.
Fiduciary Financial Group’s Code is based on the guiding principle that the interests of the
client are our top priority. Fiduciary Financial Group’s officers, directors, advisors, and
other employees have a fiduciary duty to our clients and must diligently perform that
duty to maintain the complete trust and confidence of our clients. When a conflict arises,
it is our obligation to put the client’s interests over the interests of either employees or
the company.
to clients, or who have access
The Code applies to “access” persons. “Access” persons are employees who have access to
non-public information regarding any clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in
to such
making securities recommendations
recommendations that are non-public.
Fiduciary Financial Group will provide a copy of the Code of Ethics to any client or
Investment Recommendations Involving a Material Financial Interest and Conflict of
prospective client upon request.
Interest
Fiduciary Financial Group and its employees do not recommend to clients securities in
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
which we have a material financial interest.
Interest
Fiduciary Financial Group and its employees may buy or sell securities that are also held
by clients. In order to mitigate conflicts of interest such as front running, employees are
required to disclose all reportable securities transactions as well as provide Fiduciary
Financial Group with copies of their brokerage statements.
The Chief Compliance Officer of Fiduciary Financial Group is Christopher Moore. He
reviews all employee trades each quarter. Managing Member Richard Davey reviews
Christopher Moore’s personal trades. The personal trading reviews helps mitigate that
the personal trading of employees does not affect the markets and that clients of the firm
Client Securities Recommendations or Trades and Concurrent Advisory Firm
have received preferential treatment over employee trades.
Securities Transactions and Conflicts of Interest
Fiduciary Financial Group does not maintain a firm proprietary trading account and does
not have a material financial interest in any securities being recommended and therefore
no conflicts of interest exist. However, employees may buy or sell securities at the same
time they buy or sell securities for clients. In order to mitigate conflicts of interest such as
front running, employees are required to disclose all reportable securities transactions as
well as provide Fiduciary Financial Group with copies of their brokerage statements.
The Chief Compliance Officer of Fiduciary Financial Group is Christopher Moore. He
reviews all employee trades each quarter. Managing Member Richard Davey reviews
Christopher Moore’s personal trades. The personal trading reviews ensure that the
personal trading of employees does not affect the markets and that clients of the firm
receive preferential treatment over employee transactions.
13
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
• Directed Brokerage
Fiduciary Financial Group may recommend the use of a particular broker-dealer or may
utilize a broker-dealer of the client's choosing. Fiduciary Financial Group will select
appropriate brokers based on a number of factors including but not limited to their
relatively low transaction fees and reporting ability. Fiduciary Financial Group relies on
its broker to provide its execution services at the best prices available. Lower fees for
comparable services may be available from other sources. Clients pay for any and all
custodial fees in addition to the advisory fee charged by Fiduciary Financial Group.
In circumstances where a client directs Fiduciary Financial Group to use a certain
broker-dealer, Fiduciary Financial Group still has a fiduciary duty to its clients. The
following may apply with Directed Brokerage: Fiduciary Financial Group 's inability
to negotiate commissions, to obtain volume discounts, there may be a disparity in
commission charges among clients, and conflicts of interest arising from brokerage
• Best Execution
firm referrals.
• Soft Dollar Arrangements
Investment advisors who manage or supervise client portfolios have a fiduciary
obligation of best execution. The determination of what may constitute best
execution and price in the execution of a securities transaction by a broker involves
a number of considerations and is subjective. Factors affecting brokerage selection
include the overall direct net economic result to the portfolios, the efficiency with
which the transaction is effected, the ability to effect the transaction where a large
block is involved, the operational facilities of the broker-dealer, the value of an
ongoing relationship with such broker and the financial strength and stability of the
broker. The firm does not receive any portion of the trading fees.
The Securities and Exchange Commission defines soft dollar practices as
arrangement under which products or services other than execution services are
obtained by an advisor from or through a broker-dealer in exchange for directing
client transactions to the broker-dealer. As permitted by Section 28(e) of the
Securities Exchange Act of 1934, an advisor that receives economic benefits as a
result of commissions generated from securities transactions by the broker-dealer
from the accounts of the advisor. These benefits include both proprietary research
from the broker and other research written by third parties.
Fiduciary Financial Group does not have any soft dollar arrangements at this time.
Aggregating Securities Transactions for Client Accounts
Fiduciary Financial Group will aggregate purchases and sales and other transactions
made for the account with purchases and sales and transactions in the same securities for
other Clients of Fiduciary Financial Group. All clients participating in the aggregated order
shall receive an average share price with all other transaction costs shared on a pro-rated
basis. If aggregation is not allowed or infeasible and individual transactions occur (e.g.,
withdrawal or liquidation requests, odd-lot trades, etc.) an account may potentially be
assessed higher costs or less favorable prices than those where aggregation has occurred.
14
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Review of Client Accounts on Non-Periodic Basis
Account reviews are performed monthly by Trevor Scotto, Richard Davey, Tom
Vogelheim, and Christopher Moore of Fiduciary Financial Group. Account reviews are
performed more frequently when market conditions dictate.
Content of Client Provided Reports and Frequency
Other conditions that may trigger a review of clients’ accounts are changes in the tax laws,
new investment information, and changes in a client's own situation.
Clients receive written account statements no less than monthly for managed accounts.
Account statements are issued by the Fiduciary Financial Group’s custodian. Client
receives confirmations of each transaction in account from Custodian and an additional
statement during any month in which a transaction occurs. Client will also receive
quarterly written reports provided through Black Diamond to show their account
performance.
Item 14: Client Referrals and Other Compensation
Economic benefits provided to the Advisory Firm from External Sources and
Conflicts of Interest
Fiduciary Financial Group receives an economic benefit from Schwab in the form of the
Item 12
support products and services it makes available to us. These products and services, how
Brokerage Practices
they benefit us, and the related conflicts of interest are described above under
Advisory Firm Payments for Client Referrals
. The availability to us of Schwab’s products and services is not based
on us giving particular investment advice, such as buying particular securities for our
clients.
Fiduciary Financial Group may, from time to time, enter into agreements with individuals
and organizations (“referring party”) that refer Clients to Fiduciary Financial Group in
exchange for compensation. This activity will either be considered an endorsement or
testimonial, depending on if the referring party is a Client of Fiduciary Financial Group.
For all Clients introduced by a referring party, Fiduciary Financial Group may pay that
referring party a fee pursuant to a previously executed agreement. While the specific
terms of each agreement may differ, the compensation will be based upon Fiduciary
Financial Group’s engagement of new Clients and is calculated using a fixed fee, or a
varying percentage of the fees paid to Fiduciary Financial Group by such Clients. Any such
fee shall be paid solely from Fiduciary Financial Group’s investment management fee and
shall not result in any additional charge to the Client. Fiduciary Financial Group ensures
that referring parties are registered with all appropriate jurisdictions or exempt from
registration as investment advisers or investment adviser representatives.
Each referred Client to Fiduciary Financial Group under such an arrangement will receive
a copy of this brochure and a written disclosure clearly and prominently disclosing if the
referring party is a current Client or investor, the compensation that will be paid by
Fiduciary Financial Group to the referring party and any material conflicts of interest. The
referring party is required provide this disclosure at the time the endorsement or
15
testimonial is disseminated and will obtain the Client’s signature acknowledging receipt
of Fiduciary Financial Group’s disclosure brochure and the written disclosure.
Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at their address of record at least quarterly. Clients are
urged to compare the account statements received directly from their custodians to the
performance report statements prepared by Fiduciary Financial Group. Fiduciary
Financial Group has custody of the funds and securities solely as a consequence of its
authority to make withdrawals from client accounts to pay its advisory fee.
Item 16: Investment Discretion
Discretionary Authority for Trading
Fiduciary Financial Group accepts discretionary authority to manage securities accounts
on behalf of clients. Fiduciary Financial Group has the authority to determine, without
obtaining specific client consent, the securities to be bought or sold, and the amount of the
securities to be bought or sold. Fiduciary Financial Group will allow clients to place
restrictions or limitations on accounts. These restrictions or limitations will be discussed
during the initial meeting and will be recorded in the client file. The client will authorize
Fiduciary Financial Group discretionary authority to execute selected investment
program transactions as stated within the Investment Advisory Agreement.
The client approves the custodian to be used and the commission rates paid to the
custodian. Fiduciary Financial Group does not receive any portion of the transaction fees
or commissions paid by the client to the custodian on certain trades.
Item 17: Voting Client Securities
Proxy Votes
Fiduciary Financial Group does not vote proxies on securities. Clients are expected to vote
their own proxies. The client will receive their proxies directly from the custodian of their
account or from a transfer agent.
When assistance on voting proxies is requested, Fiduciary Financial Group will provide
recommendations to the client. If a conflict of interest exists, it will be disclosed to the
client.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because Fiduciary Financial Group does
not serve as a custodian for client funds or securities and Fiduciary Financial Group does
not require prepayment of fees of more than $1200 per client and six months or more in
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
advance.
Commitments to Clients
Fiduciary Financial Group has no condition that is reasonably likely to impair our ability
to meet contractual commitments to our clients.
16
Bankruptcy Petitions during the Past Ten Years
No bankruptcy petitions to report.
17
S U P E R V I S E D P E R S O N B R O C H U R E
ITEM 1 COVER LETTER
F O R M A D V P A R T 2 B
®
Richard Lloyd Davey, CPA,
CFP
Fiduciary Financial Group, LLC
Main Office Address:
1101 Fifth Avenue
Suite 305
San Rafael, CA 94901
Office Address:
2601 N bogus Basin Rd.
Boise, ID 83702
Tel: 208-957-6922
rdavey@ffgwealth.com
www.ffgwealth.com
MARCH 6, 2025
This brochure supplement provides information about Richard Lloyd Davey and supplements the
Fiduciary Financial Group LLC’s brochure. You should have received a copy of that brochure. Please
contact Richard Lloyd Davey if you did not receive the brochure or if you have any questions about the
contents of this supplement.
Additional information about Richard Lloyd Davey (CRD #6009302) is available on the SEC’s website
at www.adviserinfo.sec.gov.
18
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer - Richard L. Davey, CPA, CFP®
•
Item 2 Educational Background and Business Experience
Year of birth: 1987
•
Educational Background:
University of San Diego; Bachelor of Science in Accounting; 2009
•
Business Experience:
•
•
•
•
•
•
•
•
Inc;
Investment Advisor Representative/Registered
•
•
•
Professional Certifications
Fiduciary Financial Group, LLC; Managing Member/Investment Advisor
Representative; 12/2016 – Present
Richard Davey; Real Estate Agent; 03/2020 – Present
Fiduciary Financial Group, LLC; Chief Compliance Officer; 12/2016 – 11/2021
Munc & Cooper CPAs LLP dba Fiduciary Financial Group; Minority Partner/CPA;
10/2019 – 07/2020
Richard Davey CPA, Sole Proprietor; Contractor; 04/2017 – 06/2017
Richard Davey, Sole Proprietor; Insurance Agent; 03/2012 – 09/2018
Bruce Davey D.D.S.; Office Assistant and Business Advisor; 03/2010 – 06/2017
Marin Wealth Advisors LLC; Investment Advisor Representative/Registered
Representative; 04/2014 – 12/2016
Waddell & Reed,
Representative; 12/2011 – 04/2014
Grant Thornton, LLP; Senior Auditor; 10/2010 – 11/2011
Fireman’s Fund Insurance; Accounting Intern; 05/2010 – 10/2010
Solar Turbines; Accounting Intern; 01/2008 – 05/2010
Employees have earned certifications and credentials that are required to be explained in
further detail.
•
CERTIFIED PUBLIC ACCOUNTANT (CPA): A Certified Public Accountant is licensed by
their state boards of accountancy. While state laws and regulations vary, the education,
experience and testing requirements for licensure as a CPA generally include:
•
•
•
Bachelor’s degree from an accredited college or university with a concentration in
accounting.
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 completion of the CPA Certification Exam.
Follow a rigorous Code of Professional Conduct which requires they act with
integrity, objectivity, due care, competence, and fully disclose conflicts of interest.
19
•
In order to maintain a CPA license, states generally require the completion of 40
hours of continuing professional education (CPE) each year (or 80 hours over a two-
year period, or 120 hours over a three-year period).
®
®
, CFP
™
™
CERTIFIED FINANCIAL PLANNER
, and
, CFP
: Certified Financial Planner
®
federally registered CFP (with flame design) marks (collectively, the “CFP
marks”) are
professional certification marks granted in the United States by Certified Financial
Planner Board of Standards, Inc. (“CFP Board”).
®
®
®
The CFP
certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP
certification. It is recognized in the United States
and a number of other countries for its (1) high standard of professional education; (2)
stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with clients. Currently, more than 62,000 individuals
have obtained CFP
certification in the United States.
®
marks, an individual must satisfactorily fulfill the
•
To attain the right to use the CFP
following requirements:
•
®
•
Standards of Professional Conduct
•
®
, a set
professionals.
Education – Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board’s studies have determined as
necessary for the competent and professional delivery of financial planning
services, and attain a Bachelor’s Degree from a regionally accredited United
States college or university (or its equivalent from a foreign university). CFP
Board’s financial planning subject areas include insurance planning and risk
management, employee benefits planning, investment planning, income tax
planning, retirement planning, and estate planning;
Certification Examination. The
Examination – Pass the comprehensive CFP
examination, administered in 10 hours over a two-day period, includes case
studies and client scenarios designed to test one’s ability to correctly diagnose
financial planning issues and apply one’s knowledge of financial planning to real
world circumstances;
Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
Ethics – Agree to be bound by CFP Board’s
of documents outlining the ethical and practice standards for CFP
®
•
Individuals who become certified must complete the following ongoing education and
ethics requirements in order to maintain the right to continue to use the CFP
marks:
Code of Ethics
Continuing Education – Complete 30 hours of continuing education hours every
Standards of Professional Conduct
and other parts of the
two years, including two hours on the
, to maintain competence and keep up with
Standards of Professional
•
Standards
developments in the financial planning field; and
Conduct.
Ethics – Renew an agreement to be bound by the
®
The
professionals provide
®
®
®
prominently require that CFP
financial planning services at a fiduciary standard of care. This means CFP
professionals must provide financial planning services in the best interests of
their clients.
CFP
professionals who fail to comply with the above standards and
requirements may be subject to CFP Board’s enforcement process, which could
result in suspension or permanent revocation of their CFP
certification.
20
Item 3 Disciplinary Information
None to report.
Criminal or Civil Action:
Administrative Proceeding:
Self-Regulatory Proceeding:
Item 4 Other Business Activities
None to report.
None to report.
Mr. Davey is also partner of an online learning program called Marriage Money Bootcamp.
Less than 5% of his time is spent on this activity. He will offer Clients services from this
business.
Item 5 Performance Based Fee Description
Mr. Davey is also a licensed real estate agent. He spends less than 5% of his time in this
capacity. He may offer Clients services from this business. As a real estate agent, he may
receive separate yet typical compensation for these services. These practices represent
conflicts of interest because it gives Mr. Davey an incentive to recommend products or
services based on the compensation amount received. This conflict is mitigated by
disclosures, procedures, and the firm’s Fiduciary obligation. Mr. Davey has a fiduciary
responsibility to place the best interest of the client first and the clients are not required
to purchase any products or services. Clients have the option to purchase these products
or services through another agent/online learning program respectively.
Item 6 Supervision
Mr. Davey does not receive performance-based fees.
Richard Davey is supervised by Christopher Moore, Chief Compliance Officer. He reviews
Richard’s work through client account reviews, quarterly personal transaction reports as
well as face-to-face and phone interactions.
can be
contacted at 208-957-6922 or by email at
Christopher Moore
cmoore@ffgwealth.com.
21
S U P E R V I S E D P E R S O N B R O C H U R E
ITEM 1 COVER LETTER
F O R M A D V P A R T 2 B
®
®
,
CEPA
Trevor Patrick Scotto, CPA, CFP
Fiduciary Financial Group, LLC
Main Office Address:
1101 Fifth Avenue
Suite 305
San Rafael, CA 94901
Tel: 415-352-1100
tscotto@ffgwealth.com
www.ffgwealth.com
MARCH 6, 2025
This brochure supplement provides information about Trevor Patrick Scotto and supplements the
Fiduciary Financial Group LLC’s brochure. You should have received a copy of that brochure. Please contact
Trevor Patrick Scotto if you did not receive the brochure or if you have any questions about the contents of
this supplement.
Additional information about Trevor Patrick Scotto (CRD #6736091) is available on the SEC’s website at
www.adviserinfo.sec.gov.
22
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Trevor P. Scotto, CPA, CFP®, CEPA®
•
Item 2 Educational Background and Business Experience
Year of birth: 1987
•
Educational Background:
Sonoma State University; Bachelor of Science in Business Administration with an
emphasis in Accounting; 2009
•
Business Experience:
•
Fiduciary Financial Group, LLC; Principal; 01/2019 – Present
•
Fiduciary Financial Group, LLC; Operations Manager/Investment Advisor
Representative; 12/2016 – Present
•
Fiduciary Financial Group, LLC; Chief Compliance Officer; 11/2021 – 02/2025
®
•
East Bay CDFA
, LLC; Member; 03/2020 – 02/2023
•
Trevor Scotto, Real Estate Agent; Owner; 01/2020 – 12/2021
•
Qualified QDRO; Owner; 01/2019 – 02/2020
®
•
Trevor Scotto, CDFA
; Owner; 07/2018 – 02/2020
•
•
Munc & Cooper CPAs LLP dba Fiduciary Financial Group; Minority Partner/CPA;
10/2019 – 07/2020
Trevor Scotto, Sole Proprietor; Insurance Agent; 08/2016 – 10/2018
•
Marin Wealth Advisors; Financial Planner; 08/2016 – 12/2016
•
DataBricks; Accounting Contractor; 07/2016 – 01/2017
•
Glassdoor; Senior Accountant; 08/2013 – 07/2016
•
Ghirardo CPA; Tax Associate; 01/2012 – 08/2013
•
Fireman’s Fund Insurance; Accountant; 06/2008 – 01/2012
•
Enterprise; Intern; 01/2008 – 06/2008
Professional Certifications
Sonoma State University; Student; 08/2005 – 05/2009
Employees have earned certifications and credentials that are required to be explained in
further detail.
•
CERTIFIED PUBLIC ACCOUNTANT (CPA): A Certified Public Accountant is licensed by
their state boards of accountancy. While state laws and regulations vary, the education,
experience and testing requirements for licensure as a CPA generally include:
•
Bachelor’s degree from an accredited college or university with a concentration in
accounting.
Minimum experience levels (most states require at least one year of experience
involve the use of accounting, attest, compilation,
providing services that
23
•
•
•
management advisory, financial advisory, tax or consulting skills, all of which must
be achieved under the supervision of or verification by a CPA.
Successful completion of the CPA Certification Exam.
Follow a rigorous Code of Professional Conduct which requires they act with
integrity, objectivity, due care, competence, and fully disclose conflicts of interest.
In order to maintain a CPA license, states generally require the completion of 40
hours of continuing professional education (CPE) each year (or 80 hours over a two-
year period, or 120 hours over a three-year period).
®
®
, CFP
™
™
CERTIFIED FINANCIAL PLANNER
, CFP
, and
: Certified Financial Planner
®
marks”) are
federally registered CFP (with flame design) marks (collectively, the “CFP
professional certification marks granted in the United States by Certified Financial
Planner Board of Standards, Inc. (“CFP Board”).
®
®
®
certification is a voluntary certification; no federal or state law or regulation
The CFP
requires financial planners to hold CFP
certification. It is recognized in the United States
and a number of other countries for its (1) high standard of professional education; (2)
stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with clients. Currently, more than 62,000 individuals
have obtained CFP
certification in the United States.
®
marks, an individual must satisfactorily fulfill the
•
To attain the right to use the CFP
following requirements:
•
®
•
Standards of Professional Conduct
•
®
, a set
professionals.
Education – Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board’s studies have determined as
necessary for the competent and professional delivery of financial planning
services, and attain a Bachelor’s Degree from a regionally accredited United
States college or university (or its equivalent from a foreign university). CFP
Board’s financial planning subject areas include insurance planning and risk
management, employee benefits planning, investment planning, income tax
planning, retirement planning, and estate planning;
Certification Examination. The
Examination – Pass the comprehensive CFP
examination, administered in 10 hours over a two-day period, includes case
studies and client scenarios designed to test one’s ability to correctly diagnose
financial planning issues and apply one’s knowledge of financial planning to real
world circumstances;
Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
Ethics – Agree to be bound by CFP Board’s
of documents outlining the ethical and practice standards for CFP
®
•
Individuals who become certified must complete the following ongoing education and
ethics requirements in order to maintain the right to continue to use the CFP
marks:
Code of Ethics
Continuing Education – Complete 30 hours of continuing education hours every
Standards of Professional Conduct
and other parts of the
two years, including two hours on the
, to maintain competence and keep up with
Standards of Professional
•
Standards
developments in the financial planning field; and
Conduct.
Ethics – Renew an agreement to be bound by the
®
The
professionals provide
®
prominently require that CFP
financial planning services at a fiduciary standard of care. This means CFP
24
®
®
professionals must provide financial planning services in the best interests of
their clients.
CFP
professionals who fail to comply with the above standards and
requirements may be subject to CFP Board’s enforcement process, which could
result in suspension or permanent revocation of their CFP
certification.
®
®
is issued by the Exit Planning Institute
marks, an individual must satisfactorily fulfill all the
•
The Certified Exit Planning Advisor, CEPA
To attain the right to use the CEPA
following requirements:
•
•
Prerequisites-Five years of full-time or equivalent experience working directly with
business owners as a financial advisor, attorney, CPA, business broker, investment
banker, commercial lender, estate planner, insurance professional, business
consultant or in a related capacity. Undergraduate degree from a qualifying
institution; if no qualifying degree, must submit additional professional work
experience (two years of relevant professional experience may be substituted for
each year of required undergraduate studies). Exit Planning Institute member in
good standing.
Education – Five-day education program.
Examination – Pass the multiple choice, proctored, closed book final exam.
®
Individuals who become certified must complete the following ongoing education
requirements in order to maintain the right to continue to use the CEPA
designation:
Item 3 Disciplinary Information
None to report.
Continuing Education – Complete 40 hours of continuing education hours every three
years.
Criminal or Civil Action:
Administrative Proceeding:
Self-Regulatory Proceeding:
Item 4 Other Business Activities
None to report.
None to report.
Mr. Scotto does not have any outside business activities to report.
Item 5 Performance Based Fee Description
Mr. Scotto does not have signatory authority over Fiduciary Financial Group’s clients.
Item 6 Supervision
Mr. Scotto does not receive performance-based fees.
Trevor Scotto is supervised by Christopher Moore, Chief Compliance Officer. He reviews
Trevor’s work through client account reviews, quarterly personal transaction reports as
well as face-to-face and phone interactions.
can be
contacted
at 208-957-6922 or by
email
at
Christopher Moore
cmoore@ffgwealth.com.
25
S U P E R V I S E D P E R S O N B R O C H U R E
ITEM 1 COVER LETTER
F O R M A D V P A R T 2 B
Thomas Vogelheim, CPA, JD
Fiduciary Financial Group, LLC
Main Office Address:
1101 Fifth Avenue
Suite 305
San Rafael, CA 94901
Tel: 415-352-1100
tvogelheim@ffgwealth.com
www.ffgwealth.com
MARCH 6, 2025
This brochure supplement provides information about Thomas Vogelheim and supplements the Fiduciary
Financial Group, LLC’s brochure. You should have received a copy of that brochure. Please contact Thomas
Vogelheim if you did not receive the brochure or if you have any questions about the contents of this
supplement.
Additional information about Thomas Vogelheim (CRD #1855108) is available on the SEC’s website at
www.adviserinfo.sec.gov.
26
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Thomas “Tom” Vogelheim, CPA, JD
•
Year of birth: 1962
Item 2 Educational Background and Business Experience
•
Educational Background:
•
San Francisco Law School; Juris Doctorate in Law; 1997
University of California, Berkeley; Bachelor of Science in Accounting and Finance;
1984
•
Business Experience:
•
FFG Law, A Professional Corporation; Sole Shareholder; 01/2021 - Present
•
Fiduciary Financial Group, LLC; Principal/Investment Advisor Representative;
08/2020 – Present
•
Numi, Inc.; Legal Counsel/Secretary; 01/2001 - Present
•
Cooper & Vogelheim LLP; Owner/Partner; 01/2000 – Present
•
EFS Associates; Principal/Investment Advisor Representative; 01/1992 – Present
•
Nelson, Vogelheim & Phillips, L.L.P.; Owner/Partner; 01/2000 – 01/2021
Nelson & Vogelheim, L.L.P.; Owner/Partner; 01/1997 – 12/2020
Professional Certifications
Tom Vogelheim has earned certifications and credentials that are required to be explained
in further detail.
•
Certified Public Accountant (CPA): A Certified Public Accountant is licensed by their state
boards of accountancy. While state laws and regulations vary, the education, experience
and testing requirements for licensure as a CPA generally include:
•
Bachelor’s degree from an accredited college or university with a concentration in
accounting.
•
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 completion of the CPA Certification Exam.
•
Follow a rigorous Code of Professional Conduct which requires they act with
integrity, objectivity, due care, competence, and fully disclose conflicts of interest.
In order to maintain a CPA license, states generally require the completion of 40
hours of continuing professional education (CPE) each year (or 80 hours over a two-
year period, or 120 hours over a three-year period).
27
Juris Doctorate (JD): A Juris Doctorate degree or JD Degree. This is the highest education
available in the legal profession in the United States and is considered a professional
degree.
The Juris Doctorate degree is obtained by going to a law school that has been approved by
the American Bar Association.
Item 3 Disciplinary Information
There are continuing education requirements in order to maintain the state license.
None to report.
Criminal or Civil Action:
Administrative Proceeding:
Self-Regulatory Proceeding:
None to report.
None to report.
Item 4 Other Business Activities
Tom Vogelheim is an owner and Certified Public Accountant for Cooper & Vogelheim LLP.
Approximately 60% of his time is spent working in this practice.
He is also the owner of the law firm, FFG Law, A Professional Corporation. Approximately
15% of his time is spent on this practice.
He is also an investment advisor representative with EFS Associates. This entity is
affiliated with Fiduciary Financial Group. Approximately 5% of his time is spent on this
business.
Item 5 Performance Based Fee Description
These practices represent conflicts of interest because it gives Mr. Vogelheim the
opportunity to solicit these services to clients of Fiduciary Financial Group. This conflict is
mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to act in the
client’s best interest. Clients have the right to purchase these services through another
CPA, attorney or investment advisor representative of their choosing.
Item 6 Supervision
Tom Vogelheim receives additional compensation in his capacity as a CPA, an attorney
and an investment advisor representative but does not receive any performance-based
fees.
Tom Vogelheim is supervised by Christopher Moore, Chief Compliance Officer. He reviews
Tom’s work through client account reviews, quarterly personal transaction reports as
well as face-to-face and phone interactions.
can be
contacted at 208-957-6922 or by email at
Christopher Moore
cmoore@ffgwealth.com.
28
S U P E R V I S E D P E R S O N B R O C H U R E
ITEM 1 COVER LETTER
F O R M A D V P A R T 2 B
Christopher Joseph Moore
Fiduciary Financial Group, LLC
Office Address:
2601 N Bogus Basin Rd.
Boise, ID 83702
Tel: 208-957-6922
Main Office Address:
1101 Fifth Avenue
Suite 305
San Rafael, CA 94901
Tel: 208-957-6922
cmoore@ffgwealth.com
www.ffgwealth.com
MARCH 6, 2025
This brochure supplement provides information about Christopher Moore and supplements the
Fiduciary Financial Group LLC’s brochure. You should have received a copy of that brochure. Please
contact Christopher Moore if you did not receive the brochure or if you have any questions about
the contents of this supplement.
Additional information about Christopher Moore (CRD #6536527) is available on the SEC’s website
at www.adviserinfo.sec.gov.
29
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Christopher Joseph Moore
•
Year of birth: 1995
Item 2 Educational Background and Business Experience
•
Educational Background:
Boise State University; Bachelor of Science, Health Science Studies with a Health
Policy and Leadership Emphasis; 2017
•
Business Experience:
•
Fiduciary Financial Group, LLC; Chief Compliance Officer; 02/2025 – Present
•
Fiduciary Financial Group, LLC; Investment Advisor Representative; 03/2021 –
Present
•
Fiduciary Financial Group; Administrative Employee; 01/2021 – 03/2021
•
Unemployed; 10/2020 – 12/2020
•
RW Investment Management LLC dba RW Investment Management; Investment
Advisor Representative; 08/2017 – 09/2020
•
Rathbone Warwick Investment Management; Intern; 09/2016 – 08/2017
•
Full-Time Student; 08/2006 – 08/2017
Wells Fargo Advisors; Intern; 01/2015 – 07/2016
Item 3 Disciplinary Information
None to report.
Criminal or Civil Action:
Administrative Proceeding:
Self-Regulatory Proceeding:
Item 4 Other Business Activities
None to report.
None to report.
Christopher Moore has no outside business activities to disclose.
Item 5 Performance Based Fee Description
Christopher Moore does not receive any performance-based fees.
Item 6 Supervision
Christopher Moore is the Chief Compliance Officer of Fiduciary Financial Group, LLC. He is
solely responsible for all supervision and formulation and monitoring of investment
advice offered to clients. He will adhere to the policies and procedures as described in the
firm’s compliance manual.
can be
contacted at 208-957-6922 or by email at
Christopher Moore
cmoore@ffgwealth.com.
30