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Item 1: Cover Page
Form ADV Part 2A
Investment Adviser Brochure
March 31, 2025
1551 Broadway, Suite 600
Tacoma, WA 98402
(P) (253) 627-6010
(F) (253) 627-6097
www.financialinsights.com
This Brochure provides information about the qualifications and business practices of Financial Insights,
Inc. If you have any questions about the contents of this Brochure, please contact Alexandria A. Kemp,
Chief Compliance Officer at (253) 627-6010 or ali@financialinsights.com.
Additional information about our Firm is also available on the SEC’s website at
https://www.adviserinfo.sec.gov/Firm/108797. 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 representatives who advise you, we encourage you to
review this Brochure and their respective Brochure Supplement(s).
Item 2: Material Changes
The Firm is required to discuss any material changes that have been made to Form ADV since the last
Annual Amendment, dated March 27, 2024. Material changes relate to Financial Insight’s policies,
practices, or conflicts of interests.
Since the last Annual Amendment filing, the Firm have made the following material changes:
● We have added a new service, Bridge Program for Retired Financial Professionals. Please see Item
4 & 5 for more information.
● We have added a wrap fee program. If applicable, please refer to our separate Form ADV Part 2A,
Appendix 1, Wrap Fee Program Brochure for more information.
Financial Insights’ Form ADV may be requested at any time, without charge by contacting Alexandria A.
Kemp, Chief Compliance Officer at (253) 627-6010 or ali@financialinsights.com. We will further provide
you with a new Brochure as necessary based on changes or new information, at any time, without charge.
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Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes
Item 3: Table of Contents
Item 4: Advisory Business
Item 5: Fees and Compensation
Item 6: Performance-Based Fees and Side-By-Side Management
Item 7: Types of Clients and Account Requirements
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Item 9: Disciplinary Information
Item 10: Other Financial Industry Activities and Affiliations
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12: Brokerage Practices
Item 13: Review of Accounts
Item 14: Client Referrals and Other Compensation
Item 15: Custody
Item 16: Investment Discretion
Item 17: Voting Client Securities
Item 18: Financial Information
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Item 4: Advisory Business
Financial Insights, Inc. is an SEC-registered investment advisor with its principal place of business located
in Tacoma, Washington. Financial Insights began conducting business as a registered investment advisor
in 1984. Dorothy A. Lewis is Financial Insights’ founder and Alexandria A. Kemp serves as Chief Executive
Officer and Chief Compliance Officer.
Financial Insights, Inc. also uses the business name, Financial Insights Wealth Management. As used in this
brochure, the words “Financial Insights”, "we", "our firm", “Advisor” and "us" refer to Financial Insights,
Inc. and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm.
Description of the Types of Advisory Services We Offer
Financial Insights offers the following advisory services to our clients:
Financial Planning and Retirement Planning Services:
We offer advice in the form of comprehensive financial and retirement planning. Clients engaging us to
provide this service will receive a written report, presenting the client with a detailed financial plan
designed to assist clients to achieve their stated financial goals and objectives.
In general, the financial and/or retirement plan will address any or all of the following areas of concern:
● Business: Assist business owner with exit planning, tax strategies and cash flow analysis.
● Charitable Gifting: Assist client with yearly gifting strategy.
● Death and Disability: Review of cash needs at death, income needs of surviving dependents,
estate planning and disability income analysis.
● Divorce: Identify short-term and long-term effects of dividing property; analyzing pension and
retirement plan issues; evaluating insurance needs and identifying tax issues.
● Education: Review of education IRAs, financial aid, 529 plans, grants and general assistance in
preparing to meet dependent’s continuing educational needs through development of an
education plan.
● Estate: Assistance in assessing and developing long-term strategies, including as appropriate,
living trusts, wills, tax strategies, powers of attorney, asset protection plans, nursing homes,
assisted living environments, elder law, while working closely with the estate planning attorney.
●
Insurance: Review of existing policies to ensure proper coverage for life, health, disability,
long-term care, home and auto.
●
Investments: Analysis of investment holdings including employer plans, stock options, and
personal investment accounts in relation to stated goals. Client will be given risk areas showing
broad recommendations on asset allocation driven by assessed risk tolerance, liquidity needs and
timeline. We will not provide buy/sell instructions for assets not managed in house.
● Personal: Review of current and future financial/life goals, family records, cash flow, and net
worth.
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● Retirement: Analysis of current strategies and investment plans to help the client determine
whether they are likely to achieve his or her retirement goals.
● Tax Analysis: Review of income tax to include planning for current and future years. Financial
Insights will illustrate the impact of various investments on a client's current income tax and
future tax liability as we work closely with the client’s tax advisor.
insurance agent.
Implementation of
We gather necessary information through in-depth personal interviews. Information gathered includes a
client's current financial status, tax status, future goals, liquidity needs, return objectives and attitudes
towards risk. Related documents supplied by the client are carefully reviewed, including a questionnaire
completed by the client, followed by preparation of a written plan. Should a client choose to implement the
recommendations contained in the plan, Financial Insights suggests that the client work closely with
financial planning
his/her attorney, accountant, and
recommendations is entirely at the client's discretion.
Financial planning recommendations are not limited to any specific product or service offered by a
broker-dealer or insurance company and our clients are not bound to follow our suggestions.
Wealth Management Services:
We provide Wealth Management Services to clients based on the individual needs of each client. Through
personal discussions in which the client’s goals and objectives are established based on the client’s
particular circumstances, Financial Insights assesses a client’s risk tolerance to guide the development and
management of the client’s portfolio. Financial Insights will manage accounts on a discretionary or
non-discretionary basis. Account supervision is guided by the stated objectives of the client, which are the
following strategies: Very Conservative, Moderately Conservative, Conservative, Moderate, Moderately
Aggressive, Aggressive, and Very Aggressive.
Depending on the investment objectives of the client and the terms of the engagement, Financial Insights
will create a portfolio. The types of securities used to create the client’s portfolio will generally consist of
one or more of the following: individual equities, bonds, CD’s, no-load or load-waived mutual funds or
exchange-traded funds (ETFs) and other investment products. Financial Insights will allocate the client’s
assets among various investments, taking into consideration the overall management style selected by the
client. Mutual funds, individual equities, municipal, and taxable bonds, and ETFs are selected on the basis
of any or all of the following criteria: the fund's performance history; the industry sector in which the fund
invests; the track record of the fund’s manager; the fund’s investment objectives; the fund’s management
style and philosophy; the fund’s management fee structure and/or tax efficiency. Portfolio weighting
between funds and market sectors will be determined by each client’s individual needs and circumstances.
Financial Insights may also provide advice with regard to certain investment products not maintained at
our primary custodian (see Item 12 of this Brochure), such as assets held in employer sponsored
retirement plans and qualified tuition plans (529’s), or other similar accounts (“Held Away Accounts”). In
these situations, Financial Insights either (i) recommends the allocation of client assets within the various
options available and clients decide whether to implement our recommendation; or (ii) we utilize an
Order Management tool that allows us to rebalance and implement our strategies in the same way we do
other accounts under our management.
Financial Insights caters its advisory services in a manner consistent with the clients’ risk tolerance,
timeline, and liquidity needs. Financial Insights consults with clients on an ongoing basis and requests that
clients notify the firm if there are changes in their financial situation.
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Financial Insights may utilize one or more unaffiliated investment managers or investment platforms
(collectively “Independent Managers”) to manage all or a portion of a client’s investment portfolio. In such
instances, the client may be required to authorize and/or enter into an agreement with the Independent
Managers that defines the terms in which the Independent Managers will provide investment
management and related services. Financial Insights assists in the development of the initial policy
recommendations and managing the ongoing client relationship. Financial Insights will perform initial and
ongoing oversight and due diligence over the selected Independent Managers to ensure the Independent
Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and
overall best interests.
We also provide pension consulting services to employee benefit plans and their fiduciaries based upon
the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these
services may include an existing plan review, formulation of the investment policy statement, asset
allocation advice, vendor selection advice, portfolio management services, investment performance
monitoring/benchmarking services, ongoing consulting, communication, and participant education
services/seminars.
Bridge Program for Retired Financial Professionals:
Retired financial professionals and sophisticated investors often reach a point where they either no longer
wish to manage their investments or need a seamless transition plan for their families. Our Bridge
Program is designed to provide guidance and continuity, ensuring that your financial legacy remains
secure and well-managed.
Our Bridge Program offers a structured yet flexible approach, including:
● Four Annual Meetings (in-person or virtual) with unlimited communication and ad-hoc meetings
as needed. Discussions may cover:
Investment oversight and performance
○
○ Annual tax planning and preparation
○ Charitable giving and gifting strategies
○ Estate planning in coordination with your attorney
●
Investment Oversight & Support, including performance reporting, research, and trading
assistance
● Operational Assistance to streamline financial management
● Estate Planning Guidance for Washington State and federal estate tax considerations
● Seamless Transition to Full Wealth Management when the time is right for your family
● Relationship Building with Family Members to ensure continuity and preparedness for future
financial responsibilities
Any assets we oversee will be managed on a non-discretionary basis, meaning, the client is ultimately
responsible for researching, buying, and selling, their own securities including rebalancing. Financial
Insights will monitor performance and review the accounts prior to each meeting. With prior client
consent, we may place transactions for cash needs on your behalf.
When the primary client either passes away or chooses to step back from managing investments, the
accounts will transition into our full-service wealth management services, which is managed on a
discretionary basis as further described above and in Item 16 of this Brochure.
Educational Seminars / Workshops:
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We may provide seminars for groups seeking general advice on investments and other areas of personal
finance. These seminars are purely educational in nature and do not involve the sale of any investment
products. Information presented will not be based on any individual’s need, nor does Financial Insights
provide individualized investment advice to attendees during these seminars and workshops.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Wealth Management Services.
Additionally, we offer general investment advice to clients utilizing our Financial and Retirement Planning
Services.
Our firm does not usually allow clients to impose restrictions on investing in certain securities or types of
securities due to the level of difficulty this would entail in managing their account. Exceptions will be
made on a case-by-case basis.
Participation in Wrap Fee Programs
For certain accounts and when appropriate, Financial Insights may offer our wrap fee program. The wrap
fee program is intended for clients who would prefer to have advisory fees and brokerage commissions
bundled into a singular fee based on a percentage of assets under management (“wrap fee”). Financial
Insights receives a portion of the wrap fee and remits any transaction fees to the custodian. For Clients
whose accounts are appropriate and suitable for such fee structure, we will provide the Form ADV Part 2A,
Appendix 1, Wrap Fee Program Brochure. Please refer to that Wrap Fee Program Brochure for more
information.
The strategies employed under a wrap fee program may differ from the strategy employed for regular
investment management services, where advisory fees and brokerage commissions are paid separately
(“non-wrap”). A wrap fee may be appropriate for accounts that incur larger sums of brokerage
commissions due to larger amounts of trading activity. This strategy is not appropriate for all accounts,
such as those under a more passive investment strategy.
ERISA Fiduciary Statement
When we provide investment advice to you regarding whether to rollover your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours.
Under this special rule’s provisions, we must:
● Meet a professional standard of care when making investment recommendations (give prudent
advice);
● Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
● Avoid misleading statements about conflicts of interest, fees, and investments;
● Follow policies and procedures designed to ensure that we give advice that is in your best interest;
● Charge no more than is reasonable for our services; and
● Give you basic information about conflicts of interest.
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Regulatory Assets Under Management
As of December 31, 2024, we manage $662,711,005 in assets under management, $635,886,096 of which
are discretionary and $26,824,909 are non-discretionary.
Item 5: Fees and Compensation
How We Are Compensated for Our Advisory Services
Financial and Retirement Planning:
Wealth Management clients receive financial and retirement planning consulting services as a component
of their ongoing services. For clients who are not Wealth Management clients, we charge an hourly fee
based on the type of service and personnel. Our hourly fee is determined as follows:
Fee
Service
In Person or Virtual Meeting
Lead Advisor - $500/hour
Associate Advisor - $300/hour
Research & Analysis
General Administrative Services
$200/hour
$150/hour
There is a $500 minimum financial planning fee. The hourly rate may be negotiable depending on the
nature and complexity of each client's circumstances and financial planning projects. If appropriate, an
estimate for total hours may be determined at the start of the advisory relationship. Financial Insights
requires one half of the financial planning fee payable upon execution of the agreement and balance due
upon completion. We may charge $200 per account for opening a 529 Account.
Wealth Management Services:
Our annual wealth management fee is based on a percentage of assets under management according to the
following fee schedule:
Total Assets Under Management
First $1,000,000
Next $4,000,000
Next $5,000,000
Over $10,000,000
Annual Fee
1.00%
0.75%
0.50%
0.25%
Clients must maintain a minimum account balance of $500,000 for our Wealth Management Services. This
minimum may be reduced or waived at our discretion.
Our firm’s annualized fees are billed in advance based on the value of your account on the last day of the
previous quarter. Fees may vary based upon the complexity of a client’s situation and the level of service
given to each client. In certain circumstances, all fees may be negotiable. A lower fee may be charged for a
fixed income and/or cash portfolio. For non-profit organizations, Financial Insights offers a discount rate
of 0.50% for Simple IRAs, 403b plans and endowments. For Held Away Accounts in which the Client has
authorized us to place trades on behalf of the Client, Financial Insights charges a fee of 0.50% billed in
advance based on the value of the Held Away Account(s) on the last day of the previous quarter. Fees for
Held Away Accounts are deducted from a taxable account held under our management.
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As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from
that client's account. On at least a quarterly basis, the custodian is required to send to the client a
statement showing all transactions within the account during the reporting period.
Wealth management fees are calculated based on an annual rate and paid in quarterly increments in
advance. The initial quarterly fee is prorated based on the number of days in the calendar quarter after
inception of the account, as specified in the terms of the Wealth Management Agreement. To calculate the
quarterly fee, the aggregate dollar amount of the client’s account(s) based on the quarter ending values on
the last business day of the months of March, June, September and December is multiplied by the Annual
Wealth Management Fee (listed above) then divided by four.
For purposes of determining fees, accounts that meet the criteria for related accounts may be aggregated
to determine if a lower fee will apply. Related accounts are: (i) accounts of an individual, their household
members, and trusts; (ii) business under common ownership; or (iii) other accounts at the discretion of
the Advisor.
No fee will be credited to the client for the current calendar quarter should any withdrawals from the
Investment Account occur in the same calendar quarter. Clients may terminate the services of Financial
Insights upon 30 days written notification and will be entitled to a prorated refund, based on the number
of calendar days remaining in the billing period. Fees will be debited from the account in accordance with
the client authorization in the Wealth Management Agreement by the custodian(s).
Because mutual funds and ETFs pay advisory fees to their managers and such fees are therefore indirectly
charged to all holders of mutual fund shares, clients with mutual funds in their portfolios are effectively
paying both our advisory fee and their mutual fund manager for the management of their assets. Certain
mutual funds, in which clients may invest, distribute payments to broker-dealers or custodians. Such
payments may be distributed pursuant to a 12b-1 distribution plan or other such plan as compensation for
administrative services and are distributed from the fund’s total assets. Neither Financial Insights nor any
of its officers and employees will receive, nor may they legally receive, any such payments.
Custodians of client’s assets may receive expense reimbursements from some mutual fund companies in
an amount equal to the 12b-1 fees. Receipt of this revenue may directly offset some of the custodial and
transaction costs that otherwise could have been charged to Financial Insights or the clients. Any such
relief from the payment of custodial and transaction charges by Financial Insights will not result in a credit
to clients.
In certain circumstances, fees, account minimums and payment terms are negotiable depending on the
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, the application of experience and knowledge of the client’s situation.
In certain cases, when Independent Managers are used to manage all or a portion of a client’s investment
portfolio, the client may pay the Independent Manager directly based on the executed agreement the client
has with the Independent Manager or Financial Insights may pay Independent Managers based on the
agreement between Financial Insights and the Independent Manager. Any additional fees paid by the client
will be agreed upon by all parties and disclosed to the client prior to any fee deduction. On a case-by-case
basis, Financial Insights may choose to absorb fees paid to Independent Managers depending on which
Independent Manager is selected and/or the strategy utilized.
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Bridge Program for retired Financial Professionals:
We charge a flat 0.25% on all assets under management for our Bridge Program. Our firm’s annualized
fees are billed in advance based on the value of your account on the last day of the previous quarter. Fees
may be negotiable.
As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from
that client's account. On at least a quarterly basis, the custodian is required to send to the client a
statement showing all transactions within the account during the reporting period.
Fees are calculated based on an annual rate and paid in quarterly increments in advance. The initial
quarterly fee is prorated based on the number of days in the calendar quarter after inception of the
account, as specified in the terms of the Agreement. To calculate the quarterly fee, the aggregate dollar
amount of the client’s account(s) based on the quarter ending values on the last business day of the
months of March, June, September and December is multiplied by the Annual Fee (listed above) then
divided by four.
Clients may terminate the services of Financial Insights upon 30 days written notification and will be
entitled to a prorated refund, based on the number of calendar days remaining in the billing period.
Educational Seminars / Workshops:
Educational seminars and workshops hosted by Financial Insights and their personnel are
complementary.
Termination and Refunds
We charge our advisory fees quarterly in advance. Either party, for any reason upon 30 days written notice,
may cancel a client agreement at any time. Upon termination of any account, any prepaid, unearned fees
will be promptly refunded, and any earned, unpaid fees will be due and payable. The client has the right to
terminate an agreement without penalty within five business days after entering into the agreement.
Other Fees and Expenses
All fees paid to Financial Insights are separate and distinct from the fees and expenses charged by mutual
funds and ETFs to their shareholders. In the case of mutual funds, these fees and expenses are described in
each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a
possible distribution fee. A client could invest in a mutual fund directly, without the services of Financial
Insights. In that case, the client would not receive the services provided by Financial Insights, which are
designed, among other things, to assist the client in determining which mutual fund or funds are most
appropriate to each client's financial condition and objectives. Accordingly, the client should review both
the fees charged by the funds and the fees charged by Financial Insights to fully understand the total
amount of fees to be paid by the client and to thereby evaluate the advisory services being provided.
Financial Insights, in determining the amount of the fee it would charge the client, will factor in the
indirect benefit of the custodian’s receipt of this revenue. Such payments are made from the assets of the
mutual funds and, therefore, reduce overall fund performance. Financial Insights uses such investments in
client's portfolios where it reasonably believes the overall performance of the fund, after accounting for
such charges, merits inclusion.
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In addition to Financial Insights’ advisory fees, clients are responsible for the fees and expenses charged or
imposed by custodians or imposed by third party service providers, broker-dealers, including, but not
limited to, any spreads, transaction charges, commissions, transfer or processing fees and revenue sharing
fees regardless of whether Financial Insights or an independent investment manager effects transactions
for the client's account(s).
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 wealth management program. Institutional share classes usually have a lower expense
ratio than other share classes.
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.
Item 6: Performance-Based Fees and Side-By-Side Management
Financial Insights does not charge performance-based fees to any client nor do we engage in side-by-side
management.
Financial Insights will not be compensated on the basis of a share of capital gains or capital appreciation of
any account’s investments other than as such capital gains and appreciation increase the value of the
account on which Financial Insights’ fee is calculated each quarter.
Item 7: Types of Clients and Account Requirements
Financial Insights provides advisory services to the following types of clients: individuals, including high
net worth individuals, employee benefit plans, trusts, estates, charitable organizations, and corporations
or other businesses.
Our requirements for opening and maintaining accounts or otherwise engaging us:
● We require a minimum account balance of $500,000 for our Wealth Management Services.
Generally, this minimum account balance requirement is negotiable.
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing client
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assets:
Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic
and financial factors (including the overall economy, industry conditions, and the financial condition and
management of the company itself) to determine if the company is underpriced (indicating it may be a
good time to buy) or overpriced (indicating it may be time to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as
the price of a security can move up or down along with the overall market regardless of the economic and
financial factors considered in evaluating the stock.
Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager of the
mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over
a period of time and in different economic conditions. We also look at the underlying assets in a mutual
fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in
other funds in the client’s portfolio. In addition, we monitor the funds or ETFs in an attempt to determine
if they are continuing to follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does
not guarantee future results. A manager who has been successful may not be able to replicate that success
in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of
different funds held by the client may purchase the same security, increasing the risk to the client if that
security were to fall in value. There is also a risk that a manager may deviate from the stated investment
mandate or strategy of the fund or ETF, which could make the fund or ETF less suitable for the client’s
portfolio.
Legacy Holdings. Investment advice may be offered on any investments held by a client at the start of the
advisory relationship. In general, depending on tax considerations and client sentiment, these investments
may be sold over time and the assets invested in the appropriate Financial Insights investment strategy. As
with any investment decision, there is the risk that Financial Insights’ timing with respect to the sale and
reinvestment of these assets will be less than ideal or even result in a short term or long-term loss to the
client.
Independent Manager Analysis. We may refer clients to Independent Managers, where suitable. Our
analysis of Independent Managers involves the examination of the experience, expertise, investment
philosophies, and past performance of the Independent Managers in an attempt to determine if that
Independent Manager has demonstrated an ability to invest over a period of time and in different
economic conditions. We monitor the Independent Manager's underlying holdings, strategies,
concentrations, and leverage as part of our overall periodic risk assessment. Additionally, as part of our
due diligence process, we survey the Independent Manager's compliance and business enterprise risks. A
risk of investing with third party Independent Managers who has been successful in the past is that they
may not be able to replicate that success in the future. In addition, as we do not control the underlying
investments in an Independent Manager's portfolio. There is also a risk that Independent Managers may
deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable
investment for our clients. Moreover, as we do not control the Independent Manager's daily business and
compliance operations, we may be unaware of the lack of internal controls necessary to prevent business,
regulatory or reputational deficiencies.
Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the funds or
companies whose securities we purchase and sell, the rating agencies that review these securities, and
other publicly available sources of information about these securities, are providing accurate and unbiased
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data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis
may be compromised by inaccurate or misleading information.
Investment Strategies
We use the following strategies in managing client accounts, provided that such strategies are appropriate
to the needs of the client and consistent with the client's investment objectives, risk tolerance, liquidity
needs and time horizons, among other considerations:
Asset Allocation. In implementing our clients’ investment strategy, we begin by attempting to identify an
appropriate ratio of equities, fixed income, and cash (i.e. “asset allocation”) suitable to the client’s
investment goals and risk tolerance.
A risk of asset allocation is that the client may not participate in sharp increases in a particular security,
industry or market sector. Another risk is that the ratio of equities, fixed income, and cash will change over
time due to stock and market movements and, if not corrected, will no longer be appropriate for the
client’s goals. We attempt to closely monitor our asset allocation models and make changes periodically to
keep in line with the target risk tolerance model.
Long-term/Short-term purchases. We purchase securities and generally hold them in the client's account
for a year or longer. Short-term purchases may be employed as appropriate when:
● We believe the securities to be currently undervalued, and/or
● We want exposure to a particular asset class over time, regardless of the current projection for this
class.
A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not
take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are
incorrect, a security may decline sharply in value before we make the decision to sell.
Socially Responsible Investing. We may utilize various socially conscious investment approaches if a
client desires. Financial Insights may construct portfolios that utilize mutual funds, ETFs, or individual
securities with the purpose of incorporating socially conscious principles into a client’s portfolio. These
portfolios may sometimes also be customized to reflect the personal values of each individual, family, or
organization. This allows our clients to invest in a way that aligns with their values. Financial Insights may
rely on mutual funds and ETFs that incorporate Environmental, Social and Governance (“ESG”) research as
well as positive and negative screens related to specific business practices to determine the quality of an
investment on values-based merits. Additionally, Financial Insights may construct portfolios of individual
securities in order to provide clients with a greater degree of control over the socially conscious strategies
they are utilizing. Financial Insights relies on third-party research when constructing portfolios of
individual securities with socially conscious considerations.
If you request your portfolio to be invested according to socially conscious principles, you should note that
returns on investments of this type may be limited and because of this limitation you may not be able to be
as well diversified among various asset classes. The number of publicly traded companies that meet
socially conscious investment parameters is also limited, and due to this limitation, there is a probability of
similarity or overlap of holdings, especially among socially conscious mutual funds or ETFs. Therefore,
there could be a more pronounced positive or negative impact on a socially conscious portfolio, which
could be more volatile than a fully diversified portfolio.
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Risks applicable to all strategies. Securities investments are not guaranteed and you may lose money on
your investments. We ask that you work with us to help us understand your tolerance for risk.
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 risk 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 particular 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.
● Cybersecurity Risk: Investment advisers, including Financial Insights, must rely in part on
digital and network technologies (“cyber networks”) to maintain substantial computerized
data about activities for client accounts and otherwise conduct their businesses. Such cyber
networks might in some circumstances be subject to a variety of possible cybersecurity
incidents or similar events that could potentially result in the inadvertent disclosure of
confidential computerized data or client data to unintended parties, or the intentional
misappropriation or destruction of data by malicious hackers seeking to compromise sensitive
information, corrupt data, or cause operational disruption. Cyberattacks might potentially be
carried out by persons using techniques that could range from efforts to electronically
circumvent network security or overwhelm websites to intelligence gathering and social
engineering functions aimed at obtaining information necessary to gain access. Financial
Insights maintains policies and procedures on information technology security, has
implemented certain technical and physical safeguards intended to protect the confidentiality
of its internal data, and takes other reasonable precautions to limit the potential for
cybersecurity incidents and to protect data from inadvertent disclosure or wrongful
misappropriation or destruction. Nevertheless, despite reasonable precautions, the risk
remains that cybersecurity incidents could potentially occur, and such incidents, in some
circumstances, might result in unauthorized access to sensitive information about Financial
Insights or its clients. Financial Insights will seek to notify affected clients of any known
cybersecurity incident that may pose a substantial risk of exposing confidential personal data
about such clients to unintended parties.
● 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
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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 (i.e. Non-traded REITs and other
alternative investments) 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.
● 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. In addition, many businesses have
encouraged or mandated that their personnel work from home in an effort to help slow the
spread of infectious diseases. As a result of working remotely, personnel whether at Financial
Insights or at third-party service providers may utilize home networks and share workspace
with individuals who are not personnel, that leave businesses more vulnerable to
cybersecurity incidents and cyberattacks or other information leakages. Financial Insights has
sought to mitigate these risks through firewalls and other technology tools, as well as staff
training.
● Securities Transactions at the Direction of Clients: Irrespective of whether you engage us
on a discretionary or non-discretionary basis, you always maintain the concurrent ability to
direct transactions within your account held at the Custodian. We are not responsible for the
consequences of your self-directed investment decisions or the costs and fees they generate
within your account.
It is important that you understand the risks associated with investing in the stock market, are
appropriately diversified in your investments, and ask us any questions you may have.
Item 9: Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's or prospective
client's evaluation of our advisory business or the integrity of our management.
Neither our firm nor our management personnel have any reportable disciplinary events to disclose.
Item 10: Other Financial Industry Activities and Affiliations
Financial Insights does not allow any supervised persons nor does the firm sell or accept compensation for
the sale of insurance products. However, certain supervised persons of Financial Insights may be licensed
insurance agents. The purpose of an insurance license is for the intent of providing insurance advice in
jurisdictions where required and/or acting as a service agent in order to assist in the servicing of
insurance policies for our clients.
Financial Insights provides tax preparation services to advisory clients of the firm. Fees for tax preparation
services are separate and in addition to the advisory fees discussed in Item 5 of this Brochure. Such
services are performed by supervised persons of Financial Insights. For Clients whose assets are $250,000
or more under management with our firm, Financial Insights will waive its tax preparation fees. This is a
conflict of interest in that Clients may be incentivized to transfer or move assets under our management in
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order to receive complementary tax preparation services. Clients are not obligated to utilize the tax
preparation services of Financial Insights. In addition, similar tax preparation services for comparable
prices may be available through other sources. Neither Financial Insights nor supervised persons of our
firm have signatory authority over any clients’ accounts either through advisory services the firm offers or
through its tax preparation services.
Neither Financial Insights or its management persons is registered, or have an application pending to
register, as a broker-dealer or a registered representative of a broker-dealer. Financial Insights is not
registered and does not have an application pending as a securities broker-dealer, futures commission
merchant, commodity pool operator or commodity trading advisor.
As referenced in Item 4 of this brochure, Financial Insights recommends clients to Independent Managers
to manage their accounts. In the event that we recommend an Independent Manager, we do not share in
their advisory fee. Our fee is separate and in addition to their compensation. In addition, you will be
provided a copy of the Independent Managers’ Form ADV 2A, Firm Brochure, which also describes the
Independent Manager’s fee. You are not obligated, contractually or otherwise, to use the services of any
Independent Manager we recommend. Moreover, Financial Insights will only recommend Independent
Managers who are properly licensed or registered as an investment adviser.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Our firm has adopted a Code of Ethics, which sets forth high ethical standards of business conduct that we
require of our employees, including compliance with applicable federal securities laws.
Financial Insights claims compliance with the CFA Institute’s Code of Ethics and Standards of Professional
Conduct. This claim has not been verified by the CFA Institute. More information can be provided upon
request. Financial Insights also claims compliance with the CFP Board’s Code of Ethics and Standards of
Professional Conduct. This claim has not been verified by the CFP Board of Standards. More information
can be provided upon request.
Financial Insights and our personnel owe a duty of loyalty, fairness, and good faith towards our clients, and
have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general
principles that guide the Code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions
reports as well as initial and annual securities holding reports that must be submitted by the firm’s access
persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of
securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides
for oversight, enforcement and recordkeeping provisions.
Financial Insights’ Code of Ethics further includes the firm's policy prohibiting the use of material
non-public information. While we do not believe that we have any particular access to non-public
information, all employees are reminded that such information may not be used in a personal or
professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a
copy by email sent to ali@financialinsights.com, or by calling us at 253-627-6010.
Financial Insights and individuals associated with our firm are prohibited from engaging in principal or
agency cross transactions.
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Our Code of Ethics 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.
Our firm and/or individuals associated with our firm may buy or sell for their personal account’s
securities identical to or different from those recommended to our clients. In addition, any related
person(s) may have an interest or position in a certain security which may also be recommended to a
client.
As these situations present potential conflicts of interest, we have established the following restrictions
in order to ensure our fiduciary responsibilities:
● No principal or employee of Financial Insights may put his or her own interest above the interest
of an advisory client.
● No director, officer or employee of Financial Insights shall buy or sell securities for their personal
portfolio(s) when their decision is substantially derived, in whole or in part, by reason of his or
her employment unless the information is also available to the investing public on reasonable
inquiry. No person of Financial Insights shall prefer his or her own interest to that of the advisory
client.
● Financial Insights has established procedures for the maintenance of all required books and
records.
● Clients can decline to implement any advice rendered, except in situations where Financial Insights
is granted discretionary authority and has not received prior written instructions from the client.
● Financial Insights maintains a list of all securities holdings for itself, and anyone associated with
this advisory practice with access to advisory recommendations. These holdings are reviewed on
a regular basis by the investment team.
● Financial Insights requires delivery and acknowledgement of the Code of Ethics by each
supervised person of our firm.
● Financial Insights has established policies requiring the reporting of Code of Ethics violations to
our senior management.
● Financial Insights emphasizes the unrestricted right of the client to decline to implement any
advice rendered.
● Financial Insights requires that all individuals must act in accordance with all applicable Federal
and State regulations governing registered wealth management practices.
● Any individual not in observance of the above may be subject to disciplinary action up to and
including termination.
Item 12: Brokerage Practices
Factors Used to Select Custodians and/or Broker-Dealers
The criteria considered by Financial Insights when making custodian/broker recommendations are the
broker's ability to provide professional services, Financial Insights’ experience with the broker, the
broker's reputation, the broker's quality of execution services and costs of such services, among other
factors.
While the term Best Execution typically defines the investment advisor as having a fiduciary duty to
execute “securities transactions for clients in such a manner that the clients’ total cost or proceeds in each
transaction is the most favorable under the circumstances,” best execution does not always mean the
lowest possible price. Although this is considered, Financial Insights has reviewed and considered the full
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range and quality of the services of the custodian of its client accounts. For clients seeking a
recommendation for brokerage or custodial services, Financial Insights may suggest the use of one or
more custodians/broker-dealers, which have been evaluated by the firm. Due to its ability to meet the
criteria established by Financial Insights, Inc., as set forth above, and depending on client circumstances
and needs, we most typically recommend the use of Raymond James & Associates, Inc., member New York
Stock Exchange/SIPC (“Raymond James”) and/or Charles Schwab & Co., Inc., a registered broker-dealer,
member SIPC (“Schwab”). Financial Insights is not affiliated with either Raymond James or Schwab.
Raymond James monitors execution prices that are provided to clients from the trading desk by
performing several daily, weekly, and monthly quality of execution reviews. Raymond James is able to
perform in-depth execution quality reviews as a result of numerous system enhancements that Raymond
James has made in the last several years. As part of Raymond James’ commitment to provide timely,
efficient, and superior pricing to client order flow, Raymond James utilizes advanced technology from
order handling and execution system vendors. Please note that best execution practices may be different in
the event of severe market turbulence, or internal or external system failures.
Clients are not under any obligation to direct the use of any recommended broker. Clients are free to select
the custodian/broker-dealer of his or her choice, however, Financial Insights reserves the right to decline
acceptance of any client account if Financial Insights believes that the directed custodian/broker would
hinder Financial Insights’ fiduciary duty to the client and/or its ability to service the account. Not all
advisors require clients to direct the use of a particular broker.
Research and Other Soft Dollar Benefits
We do not receive formal soft dollar benefits where we pay for research and brokerage services with
commission dollars generated by client accounts. However, we do receive certain economic benefits from
broker-dealers we recommend.
Other Economic Benefits
Raymond James provides general access to research and perhaps discounts on research products. Any
research received is used for the benefit of all clients. From time to time, Raymond James may offer our
employees the ability to attend industry-related conferences or other benefits; however, we do not believe
that such incentives impair our independence.
We may have the opportunity to receive traditional “non-cash benefits” from Raymond James, such as
customized statements; receipt of duplicate client confirmations and bundled duplicate statements; access
to a trading desk servicing investment advisors exclusively; access to block trading which provides the
ability to aggregate securities transactions and then allocate the appropriate shares to client accounts;
ability to have wealth management fees deducted directly from client accounts; access to an electronic
communication network for client order entry and account information; access to mutual funds which
generally require significantly high minimum initial investments or those that are otherwise only generally
available to institutional investors; reporting features; receipt of industry communications; and perhaps
discounts on business-related products.
Pursuant to advice provided by Financial Insights, we may receive research services from brokers paid for
by 12b-1 fees received by the brokers from funds in which client accounts have been invested. This
arrangement creates a conflict of interest, which has the potential to influence recommendations made to
clients regarding which mutual funds would be most appropriate for the client’s portfolio.
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Schwab Advisor ServicesTM is Schwab’s business serving independent investment advisory firms like us.
They provide our clients and us with access to their institutional brokerage services (trading, custody,
reporting and related services), many of which are not typically available to Schwab retail customers.
Schwab also makes available various support services. Some of those services help us manage or
administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support
services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to
us.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for using that broker-dealer.
Trade Aggregation
When block trading, we trade an aggregate block of securities composed of assets from multiple client
accounts. Depending on the security traded, failure to aggregate a trade may result in clients paying a
different price for the same security on the same or a different trading day.
Financial Insights will only be able to block trade for client accounts who direct the use of the same broker.
Financial Insights’ block trading policy and procedures are as follows:
● Financial Insights’ policies for the aggregation of transactions shall be fully disclosed in this Form
ADV;
● Financial Insights will not aggregate transactions unless it believes that aggregation is consistent
with our fiduciary duty to our clients and is consistent with the terms of Financial Insights’ Wealth
Management agreement with each client for which trades are being aggregated.
● No advisory client will be favored over any other client; each client that participates in an
aggregated order will participate at the average share price for all Financial Insights’ transactions
in a given security on a given business day. Depending on the client’s agreement with the
custodian/broker, transaction costs will be based on the number of shares traded for each client.
● Transactions for each client generally will be affected independently unless Financial Insights
decides to purchase or sell the same securities for several clients at approximately the same time.
Financial Insights may (but is not obligated to) combine or “batch” such orders to obtain best
execution, or to allocate equitably among Financial Insights’ client differences in prices and
commissions or other transaction costs that might have been obtained had such orders have been
placed independently. In this situation, transactions will generally be averaged as to price and
allocated among Financial Insights clients pro rata to the purchase and sale orders placed for each
client on any given day.
● To the extent that Financial Insights determines to aggregate client orders for the purchase or sale
of securities, Financial Insights generally does so in accordance with applicable rules and
regulations. Financial Insights does not receive any additional compensation or remuneration as a
result of the aggregation. In the event that Financial Insights determines that a prorated allocation
is not appropriate under the particular circumstances, the allocation will be made upon other
relevant factors.
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● Before entering an aggregated order, Financial Insights will prepare a written allocation statement
specifying the participating client accounts and how it intends to allocate the order among those
clients;
●
If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with
the allocation statement; if the order is partially filled, orders for each account will be filled based
upon random number generation.
● Notwithstanding the foregoing, the order may be allocated on a basis different from that specified
in the Allocation Statement if all client accounts receive fair and equitable treatment and the
reason for different allocation is explained in writing and is approved by Financial Insights’
compliance officer no later than one hour after the opening of the markets on the trading day
following the day the order was executed;
● Financial Insights,’ books and records will separately reflect, for each client account, the orders of
which are aggregated, the securities held by, and bought and sold for that account;
● Funds and securities of clients whose orders are aggregated will be deposited with one or more
banks or broker-dealers, and neither the clients' cash nor their securities will be held collectively
any longer than is necessary to settle the purchase or sale in question on a delivery versus
payment basis; cash or securities held collectively for clients will be delivered out to the custodian
bank or broker-dealer as soon as practicable following the settlement;
● Financial Insights will receive no additional compensation or remuneration of any kind as a result
of the proposed aggregation; and
●
Individual advice and treatment will be accorded to each advisory client and no client or account
will be favored over another.
Item 13: Review of Accounts
Wealth Management Services. Client accounts are reviewed by the investment advisor representative(s)
primarily responsible for that account. Clients will receive a Form ADV Part 2B, Brochure Supplement for
each investment adviser representative responsible for their account. In addition, accounts are supervised
and monitored by Financial Insight’s executive team.
REVIEWS: The underlying securities within these accounts are continuously monitored; accounts are
reviewed regularly, based on client needs. Accounts are reviewed in the context of each client's stated
investment objectives and guidelines. More frequent reviews may be triggered by material changes in
variables such as the client's individual circumstances, or the market, political or economic environment.
REPORTS: In addition to at least monthly and/or quarterly custodial statements, Financial Insights will
provide clients with Performance Reporting and Asset Management Reports upon request and during
annual reviews.
Financial Planning clients will receive a complete, written financial plan. Additional reports will be
determined by the client and Financial Insights.
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Item 14: Client Referrals and Other Compensation
Except as disclosed in Item 12, we do not receive any economic benefit, directly or indirectly, from any
third party for advice rendered to our Clients. Nor do we, directly or indirectly, compensate any person
who is not advisory personnel for Client referrals.
Item 15: Custody
Clients may authorize the custodian (via the agreement signed with Financial Insights) to debit fees
directly from the client’s account at the broker dealer, bank or other qualified custodian (custodian). Client
investment assets will be held with a custodian agreed upon by the client and Financial Insights. The
custodian is advised in writing of the limitation of Financial Insights’ access to the account. The custodian
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 Financial Insight.
Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to
carefully review their custodial statements to verify the accuracy of the calculation, among other things.
Clients should contact us directly if they believe that there may be an error in their statement.
Item 16: Investment Discretion
We provide our Wealth Management Services on a discretionary and non-discretionary basis.
Discretionary authority means that we will place trades in a client's account, as we deem appropriate
based on the information previously gathered with or without contacting the client prior to each trade to
obtain the client's permission. Under these circumstances, our discretionary authority includes the ability
to do the following without contacting the client:
● Determine the security to buy or sell; and/or
● Determine the amount of the security to buy or sell.
Clients give us discretionary authority when they sign a discretionary investment management agreement
with our firm and may reasonably limit this authority by giving us written instructions. Clients may also
change/amend such limitations by once again providing us with written instructions.
If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the
execution of any transactions for your account(s). You have an unrestricted right to decline to implement
any advice provided by our firm on a non-discretionary basis. Clients electing not to grant us discretionary
authority over their account may not be aggregated with other clients’ trades due to the time involved in
obtaining the client’s approval for each trade.
Item 17: Voting Client Securities
As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our firm may
provide Wealth Management Services relative to client investment assets, clients maintain exclusive
responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially
owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions,
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tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets.
Clients are responsible for instructing each custodian of the assets, to forward to the client, along with
copies of all proxies and shareholder communications relating to the client’s investment assets.
We may provide clients with consulting assistance regarding proxy issues if they contact us with
questions.
Item 18: Financial Information
Financial Insights has no adverse financial circumstances to report.
Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client more than
six months or more in advance of services rendered. Therefore, we are not required to include a financial
statement. Financial Insights has not been the subject of a bankruptcy petition at any time during the past
ten years.
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