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Item 1
Cover Page
Fountainhead Financial, LLC
515 North State Street
14th Floor
Chicago, IL 60654
Phone (312) 222-9840
Fax (312) 222-9834
3/31/2025
FORM ADV PART 2
BROCHURE
information about the qualifications and business practices of
This brochure provides
Fountainhead Financial, LLC. If you have any questions about the contents of this brochure, please
contact us at (312) 222-9840. 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 Fountainhead Financial, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Fountainhead Financial, LLC is
150813.
Fountainhead Financial, LLC a Registered Investment Adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain
level of skill or training.
Item 2
Material Changes
Since our last update, March 30, 2024, Fountainhead Financial, LLC’s (the “Registrant”) there have been
no material changes. ANY QUESTIONS: The Registrant’s Chief Compliance Officer, Dominick Vetrano,
remains available to address any questions regarding this Part 2A, including the disclosure additions and
enhancements below
Item 3
Table of Contents
Item 1 Cover Page .................................................................................................................................... 1
Item 2 Material Changes .......................................................................................................................... 2
Item 3
Table of Contents .......................................................................................................................... 2
Item 4 Advisory Business ........................................................................................................................ 3
Fees and Compensation ................................................................................................................ 6
Item 5
Performance-Based Fees and Side-by-Side Management ............................................................ 8
Item 6
Item 7
Types of Clients ............................................................................................................................ 8
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 8
Item 9 Disciplinary Information .............................................................................................................. 9
Item 10 Other Financial Industry Activities and Affiliations .................................................................... 9
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.............. 10
Item 12 Brokerage Practices .................................................................................................................... 11
Item 13 Review of Accounts .................................................................................................................... 13
Item 14 Client Referrals and Other Compensation .................................................................................. 13
Item 15 Custody ....................................................................................................................................... 13
Investment Discretion ................................................................................................................. 14
Item 16
Item 17 Voting Client Securities .............................................................................................................. 14
Item 18 Financial Information ................................................................................................................. 14
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Item 4
Advisory Business
A. Fountainhead Financial, LLC (the “Registrant”) is a limited liability company formed in
2003 in the State of Illinois. The Registrant has been registered as an investment adviser
with the SEC since July 2009. The Registrant is owned and operated by its Managing
Member, Dominick J. Vetrano, CFP, CLU, ChFC, CFA, RHU.
B.
INVESTMENT ADVISORY SERVICES
The Registrant provides non-discretionary (see MISCELLANEOUS below) investment
advisory services on a fee basis. Registrant's annual investment advisory fee shall include
investment advisory services, and, to the extent specifically requested by the client,
financial planning and consulting services. In the event that the client requires
extraordinary planning and/or consultation services (to be determined in the sole discretion
of the Registrant), the Registrant may determine to charge for such additional services, the
dollar amount of which shall be set forth in a separate written notice to the client. In
addition, as discussed at Item 5 below, the client can also engage the Registrant for fixed
fee and/or hourly consulting services.
To commence the investment advisory process, the Registrant will ascertain each client’s
investment objectives and then allocate assets consistent with the client’s designated
investment objectives. Once allocated, the Registrant provides ongoing monitoring and
review of account performance and asset allocation as compared to client investment
objectives, and may rebalance the client’s accounts as necessary. Before engaging the
Registrant to provide investment advisory services, clients are required to enter into an
Investment Advisory Agreement with Registrant setting forth the terms and conditions of
the engagement (including termination), describing the scope of the services to be
provided, and the fee that is due from the client.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
The Registrant may provide financial planning and/or consulting services (including
investment and non-investment related matters, including estate planning, insurance
planning, etc.) on a stand-alone fee basis. Prior to engaging the Registrant to provide
planning or consulting services, clients are generally required to enter into a Financial
Planning and Consulting Agreement with Registrant setting forth the terms and conditions
of the engagement (including termination), describing the scope of the services to be
provided, and the portion of the fee that is due from the client prior to Registrant
commencing services. If requested by the client, Registrant may recommend the services
of other professionals for implementation purposes, including its Managing Member,
Dominick J. Vetrano, in his separate individual capacity as a licensed insurance agent (See
disclosure at Items 10.C). The client is under no obligation to engage the services of any
such recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from the
Registrant. Please Note: Moreover, each client is advised that it remains their
responsibility to promptly notify the Registrant if there is ever any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating or revising
Registrant’s previous recommendations and/or services. Please Also Note: If the client
engages any such recommended professional, and a dispute arises thereafter relative to
such engagement, the client agrees to seek recourse exclusively from and against the
engaged professional. At all times, the engaged licensed professional[s] (i.e. attorney,
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accountant, insurance agent, etc.), and not the Registrant, shall be responsible for the
quality and competency of the services provided.
MISCELLANEOUS
Please Note: Non-Discretionary Service Limitations. The registrant provides services
on a non-discretionary basis. Clients that determine to engage the Registrant on a non-
discretionary investment advisory basis must be willing to accept that the Registrant cannot
affect any account transactions without obtaining prior consent to any such transaction(s)
from the client. Thus, in the event that Registrant would like to make a transaction for a
client’s account, and client is unavailable, the Registrant will be unable to effect the account
transaction without first obtaining the client’s consent.
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by the client, Registrant may provide
financial planning and related consulting services regarding non-investment related
matters, such as estate planning, tax planning, insurance, etc. Registrant does not serve as
a law firm or accounting firm, and no portion of its services should be construed as legal
or accounting services. Accordingly, Registrant does not prepare estate planning
documents or tax returns. To the extent requested by a client, Registrant may recommend
the services of other professionals for certain non-investment implementation purposes (i.e.
attorneys, accountants, insurance agents, etc.), including its Managing Member, Dominick
J. Vetrano, in his separate individual capacity as a licensed insurance agent (See disclosure
at Items 10.C). The client is under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from
Registrant and/or its representatives. Please Note: If the client engages any recommended
unaffiliated professional, and a dispute arises thereafter relative to such engagement, the
client agrees to seek recourse exclusively from and against the engaged professional. At all
times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.),
and not the Registrant, shall be responsible for the quality and competency of the services
provided. Conflict of Interest: The recommendation by Registrant’s representatives that
a client purchase an insurance product from Mr. Vetrano his separate individual capacity
as a licensed insurance agent presents a conflict of interest, as the receipt of commissions
may provide an incentive to recommend investment products based on commissions to be
received, rather than on a particular client’s need. No client is under any obligation to
purchase any securities or insurance commission products through Mr. Vetrano. Clients
are reminded that they may purchase securities and insurance products recommended by
Registrant through other, non-affiliated broker-dealers.
Retirement Rollovers-Conflict of Interest: A client or prospective client leaving an
employer typically has four options regarding an existing retirement plan (and may engage
in a combination of these options): (i) leave the money in the former employer’s plan, if
permitted, (ii) roll over the assets to the new employer’s plan, if one is available and
rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv)
cash out the account value (which could, depending upon the client’s age, result in adverse
tax consequences). If Registrant recommends that a client roll over their retirement plan
assets into an account to be managed by Registrant, such a recommendation creates a
conflict of interest if Registrant will earn new (or increase its current) compensation as a
result of the rollover. Registrant’s Chief Compliance Officer, Dominick Vetrano,
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remains available to address any questions that a client or prospective client may have
regarding the conflict of interest presented by such rollover recommendation.
Use of Mutual Funds/Exchange Traded Funds: Most mutual funds and exchange traded
funds are available directly to the public. Thus, a prospective client can obtain many of the
mutual funds that may be recommended and/or utilized by Registrant independent of
engaging Registrant as an investment advisor. However, if a prospective client determines
to do so, he/she will not receive Registrant’s initial and ongoing investment advisory
services.
Participant Directed Retirement Plans. Registrant may also provide investment advisory
and consulting services to participant directed retirement plans per the terms and conditions
of a Retirement Plan Services Agreement between Registrant and the plan. For such
engagements, Registrant shall assist the Plan sponsor with the selection of an investment
platform from which Plan participants shall make their respective investment choices
(which may include investment strategies devised and managed by Registrant), and, to the
extent engaged to do so, may also provide corresponding education to assist the participants
with their decision making process.
Custodian Charges-Additional Fees: As discussed below at Item 12 below, when
requested to recommend a broker-dealer/custodian for client accounts, the Registrant
generally recommends that Schwab serve as the broker-dealer/custodian for client
investment management assets. Broker-dealers such as Schwab charge transaction fees for
effecting securities transactions. In addition to the Registrant’s investment advisory fee
referenced in Item 5 below, the client will also incur transaction fees to purchase securities
for the client’s account (i.e., mutual funds exchange traded funds, individual equity and
fixed income securities, etc.) ANY QUESTIONS: Registrant’s Chief Compliance
Officer, Dominick Vetrano, remains available to address any questions that a client
or prospective client may have regarding the above.
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Registrant will review
client portfolios on an ongoing basis to determine if any changes are necessary based upon
various factors, including, but not limited to, investment performance, mutual fund
manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time
when Registrant determines that changes to a client’s portfolio are neither necessary nor
prudent. Of course, as indicated below, there can be no assurance that investment decisions
made by Registrant will be profitable or equal any specific performance level(s).
Client Obligations. In performing its services, Registrant shall not be required to verify
any information received from the client or from the client’s other professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify the Registrant if there is ever any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating or revising
Registrant’s previous recommendations and/or services.
Disclosure Brochure. A copy of the Registrant’s written Brochure as set forth on Part 2A
of Form ADV shall be provided to each client prior to, or contemporaneously with, the
execution of the Investment Advisory Agreement or Financial Planning and Consulting
Agreement.
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to providing
investment advisory services, an
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior
investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at anytime, impose
reasonable restrictions, in writing, on the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2024, the Registrant had $453.5 million of assets under management
on a non-discretionary basis.
Item 5
Fees and Compensation
A.
INVESTMENT ADVISORY SERVICES
The Registrant can be compensated for its services in four ways, based upon the type of engagement:
Securities Advisory/Supervisory Services: This is the primary manner in which the Registrant is
engaged. This annual fee is based upon a percentage of the assets under the Registrant’s
management (between 0.30% and 1.00%), as follows:
Percentage
Dollar Value of Assets under Management
of the first $ 500,000*
1.0%
of the next $ 500,000
0.8%
0.6%
of the next $ 4,000,000
0.4% of the next $ 15,000,000
0.3% Over $ 20,000,000
*subject to a minimum annual fee of $5,000.
The fee will be pro-rated, and paid quarterly, in arrears, based upon the market value of the assets on
the last day of the previous quarter. Unless the client gives the Registrant authority to debit the account
for its advisory fee, the Registrant’s fee shall be due and payable upon receipt of the Registrant’s
quarterly invoice. The terms and conditions of the engagement shall generally be set forth in an
Investment Advisory Agreement to be executed by both the Registrant and the client. The Registrant’s
investment advisory fee is negotiable at Registrant’s discretion, depending upon objective and
subjective factors including but not limited to: the amount of assets to be managed; portfolio
composition; the scope and complexity of the engagement; the anticipated number of meetings and
servicing needs; related accounts; future earning capacity; anticipated future additional assets; the
professional(s) rendering
the Registrant and/or its
the service(s); prior relationships with
representatives, competition, and negotiations with the client. As a result of these factors, similarly
situated clients could pay different fees, and the services to be provided by the Registrant to any
particular client could be available from other advisers at lower fees, and certain clients may have fees
different than those specifically set forth above. Please Also Note: If you maintain less than $500,000
of assets under Fountainhead Financial, LLC’s management, and are subject to the $1,250 per quarter
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minimum fee, you will pay a higher percentage Annual Fee than the 1.00% referenced in the above fee
schedule.
Non-Supervisory/Financial Planning Consulting Services: This engagement is consulting only.
The fee does not include the implementation of any advice. If desired, the client can implement
the investment/financial planning consulting advice on his/her own or under the Registrant’s
Supervisory Services engagement discussed directly above (the client is under absolutely no
obligation to implement any of the Registrant’s advice, neither on his/her own, nor through the
Registrant Supervisory Services, or the engagement of Mr. Vetrano for insurance services as
discussed above at Item 4 and below at Item 10). The terms and conditions of the engagement,
including the fully disclosed amount of the fee and payment thereof (generally 50%, in advance,
for a formal written financial plan) shall be set forth in either a Financial Planning Agreement or
an Investment Consulting Agreement to be executed by both the Registrant and the client. The
amount of the fee shall vary depending upon the nature and scope of the services to be provided,
and the professional providing the services.
Hourly Financial Consultation: This engagement is hourly limited consulting only. The hourly
fee does not include the implementation of any advice. If desired, the client can implement the
investment/financial planning consulting advice on his/her own or under the Registrant’s
Supervisory Services engagement discussed directly above (the client is under absolutely no
obligation to implement any of the Registrant’s advice, neither on his/her own, nor through the
Registrant Supervisory Services, or the engagement of Mr. Vetrano for insurance services as
discussed above at Item 4 and below at Item 10). The terms and conditions of the engagement,
including the fully disclosed amount of the fee, shall be set forth in either a Financial Planning
Agreement or an Investment Consulting Agreement to be executed by both the Registrant and the
client. The amount of the hourly fee shall vary depending upon the individual providing the
services, currently, as follows.
Dominick J. Vetrano, CFP, CLU CFC, CFA, RHU- $750 per hour.
$550 per hour.
Kevin E. Wozniak, CFP -
$100 per hour.
Shelley Frank-
The hourly fee will generally be paid upon completion of the service.
Participant Directed Retirement Plan Services. As indicated above, The Registrant also
offers non-discretionary retirement plan consulting services, on a fee basis, to participant
directed retirement plans. Generally, the Registrant’s plan advisory fees shall be based on
a percentage of plan assets, payable on a quarterly basis, in arrears, similar to the above
Supervisory Services schedule, but could also be provided on a mutually agreeable fixed
fee or on an hourly rate basis. The factors that may determine the fees will include, but are
not limited to, the amount of the assets placed under the Registrant’s advisement, the level
and scope of the overall investment advisory services to be rendered, and the complexity
of the engagement. The services to be provided by the Registrant to any plan client could
be available from other advisers at a higher or lower fee. The terms and conditions of the
engagement shall generally be set forth in a Retirement Plan Services Agreement to be
executed by both the Registrant and the client.
B. As discussed below, unless the client directs otherwise or an individual client’s
circumstances require, the Registrant shall generally recommend that Charles Schwab &
Co., Inc. (“Schwab”) serve as the broker-dealer/custodian for client investment
management assets. Broker-dealers such as Schwab charge brokerage commissions and/or
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transaction fees for effecting certain securities transactions (i.e. transaction fees are charged
for certain no-load mutual funds, commissions are charged for individual equity and fixed
income securities transactions). In addition to Registrant’s investment management fee,
brokerage commissions and/or transaction fees, the client will also incur, relative to all
mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g.
management fees and other fund expenses).
Item 6
Performance-Based Fees and Side-by-Side Management
Neither the Registrant, nor any employee of the Registrant, accepts performance-based
fees.
Item 7
Types of Clients
The Registrant’s clients shall generally include individuals, business entities, and retirement plans. The
Registrant’s investment advisory fee is negotiable at Registrant’s discretion, depending upon objective
and subjective factors including but not limited to: the amount of assets to be managed; portfolio
composition; the scope and complexity of the engagement; the anticipated number of meetings and
servicing needs; related accounts; future earning capacity; anticipated future additional assets; the
professional(s) rendering
the Registrant and/or its
the service(s); prior relationships with
representatives, competition, and negotiations with the client. Please Note: As result of the above,
similarly situated clients could pay different fees. In addition, similar advisory services may be
available from other investment advisers for similar or lower fees. As a result of these factors, similarly
situated clients could pay different fees, the services to be provided by the Registrant to any particular
client could be available from other advisers at lower fees, and certain clients may have fees different
than those specifically set forth above. Please Also Note: If you maintain less than $500,000 of assets
under Fountainhead Financial, LLC’s management, and are subject to the $1,250 per quarter minimum
fee, you will pay a higher percentage Annual Fee than the 1.00% referenced in the above fee schedule.
ANY QUESTIONS: The Registrant’s Chief Compliance Officer, Dominick Vetrano, remains
available to address any questions that a client or prospective client may have regarding advisory fees.
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
A. The Registrant may utilize the following methods of security analysis:
Charting - (analysis performed using patterns to identify current trends and trend
reversals to forecast the direction of prices)
Fundamental - (analysis performed on historical and present data, with the goal of
making financial forecasts)
Technical – (analysis performed on historical and present data, focusing on price
and trade volume, to forecast the direction of prices)
The Registrant may utilize the following investment strategies when implementing
investment advice given to clients:
Long Term Purchases (securities held at least a year)
Short Term Purchases (securities sold within a year)
Trading (securities sold within thirty (30) days)
Options (contract for the purchase or sale of a security at a predetermined price
during a specific period of time)
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Please Note: Investment Risk. Different types of investments involve varying degrees of
risk, and it should not be assumed that future performance of any specific investment or
investment strategy (including the investments and/or investment strategies recommended
or undertaken by the Registrant) will be profitable or equal any specific performance
level(s).
B. The Registrant’s methods of analysis and investment strategies do not present any
significant or unusual risks.
However, every method of analysis has its own inherent risks. To perform an accurate
market analysis the Registrant must have access to current/new market information. The
Registrant has no control over the dissemination rate of market information; therefore,
unbeknownst to the Registrant, certain analyses may be compiled with outdated market
information, severely limiting the value of the Registrant’s analysis. Furthermore, an
accurate market analysis can only produce a forecast of the direction of market values.
There can be no assurances that a forecasted change in market value will materialize into
actionable and/or profitable investment opportunities.
The Registrant’s primary investment strategies-Long Term Purchases, Short Term
Purchases, and Trading-are fundamental investment strategies. However, every investment
strategy has its own inherent risks and limitations. For example, longer term investment
strategies require a longer investment time period to allow for the strategy to potentially
develop. Shorter term investment strategies require a shorter investment time period to
potentially develop but, as a result of more frequent trading, may incur higher transactional
costs when compared to a longer-term investment strategy. Trading, an investment strategy
that requires the purchase and sale of securities within a thirty (30) day investment time
period involves a very short investment time period but will incur higher transaction costs
when compared to a short-term investment strategy and substantially higher transaction
costs than a longer term investment strategy.
In addition to the fundamental investment strategies discussed above, the Registrant has
(but rarely will) engage in options transactions. Prior to do doing, the Registrant shall
disclose, in writing, the risks corresponding to such strategy(ies).
C. Currently, the Registrant allocates client investment assets on a non-discretionary basis
primarily among unaffiliated mutual funds and exchange traded funds, and individual
equity and fixed income securities consistent with the client’s designated investment
objective(s).
Item 9
Disciplinary Information
The Registrant has not been the subject of any disciplinary actions.
Item 10
Other Financial Industry Activities and Affiliations
A. Neither the Registrant, nor its representatives, are registered or have an application pending
to register, as a broker-dealer or a registered representative of a broker-dealer.
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B. Neither the Registrant, nor its representatives, are registered or have an application pending
to register, as a futures commission merchant, commodity pool operator, a commodity
trading advisor, or a representative of the foregoing.
Licensed Insurance Agent. As indicated above at Item 4, the Registrant’s Managing
Member, Dominick J. Vetrano, in his separate individual capacity, is a licensed insurance
agent, and in such capacity may offer insurance products on a commission basis. Conflict
of Interest: The recommendation by Registrant’s representatives that a client purchase an
insurance product from Mr. Vetrano his separate individual capacity as a licensed insurance
agent presents a conflict of interest, as the receipt of commissions may provide an
incentive to recommend investment products based on commissions to be received, rather
than on a particular client’s need. No client is under any obligation to purchase any
securities or insurance commission products through Mr. Vetrano. Clients are reminded
that they may purchase securities and insurance products recommended by Registrant
through other, non-affiliated broker-dealers.
C. The Registrant does not receive, directly or indirectly, compensation from investment
advisors that it recommends or selects for its clients.
Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. The Registrant maintains an investment policy relative to personal securities transactions.
This investment policy is part of Registrant’s overall Code of Ethics, which serves to
establish a standard of business conduct for all of Registrant’s representatives that is based
upon fundamental principles of openness, integrity, honesty and trust, a copy of which is
available upon request.
In accordance with Section 204A of the Investment Advisers Act of 1940, the Registrant
also maintains and enforces written policies reasonably designed to prevent the misuse of
material non-public information by the Registrant or any person associated with the
Registrant.
B. Neither the Registrant nor any related person of Registrant recommends, buys, or sells for
client accounts, securities in which the Registrant or any related person of Registrant has a
material financial interest.
C. The Registrant and/or representatives of the Registrant may buy or sell securities that are
also recommended to clients. This practice may create a situation where the Registrant
and/or representatives of the Registrant are in a position to materially benefit from the sale
or purchase of those securities. Therefore, this situation creates a conflict of interest.
Practices such as “scalping” (i.e., a practice whereby the owner of shares of a security
recommends that security for investment and then immediately sells it at a profit upon the
rise in the market price which follows the recommendation) could take place if the
Registrant did not have adequate policies in place to detect such activities. In addition, this
requirement can help detect insider trading, “front-running” (i.e., personal trades executed
prior to those of the Registrant’s clients) and other potentially abusive practices.
The Registrant has a personal securities transaction policy in place to monitor the personal
securities transactions and securities holdings of each of the Registrant’s “Access Persons”.
The Registrant’s securities transaction policy requires that Access Person of the Registrant
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must provide the Chief Compliance Officer or his/her designee with a written report of the
their current securities holdings within ten (10) days after becoming an Access Person.
Additionally, each Access Person must provide the Chief Compliance Officer or his/her
designee with a written report of the Access Person’s current securities holdings at least
once each twelve (12) month period thereafter on a date the Registrant selects; provided,
however that at any time that the Registrant has only one Access Person, he or she shall
not be required to submit any securities report described above.
D. The Registrant and/or representatives of the Registrant may buy or sell securities, at or
around the same time as those securities are recommended to clients. This practice creates
a situation where the Registrant and/or representatives of the Registrant are in a position to
materially benefit from the sale or purchase of those securities. Therefore, this situation
creates a conflict of interest. As indicated above in Item 11 C, the Registrant has a personal
securities transaction policy in place to monitor the personal securities transaction and
securities holdings of each of Registrant’s Access Persons.
Item 12
Brokerage Practices
A. In the event that the client requests that the Registrant recommend a broker-
dealer/custodian for execution and/or custodial services (exclusive of those clients that may
direct the Registrant to use a specific broker-dealer/custodian), Registrant generally
recommends that investment management accounts be maintained at Schwab. Prior to
engaging Registrant to provide investment management services, the client will be required
to enter into a formal Investment Advisory Agreement with Registrant setting forth the
terms and conditions under which Registrant shall manage the client's assets, and a separate
custodial/clearing agreement with each designated broker-dealer/custodian.
Factors that the Registrant considers in recommending Schwab (or any other broker-
dealer/custodian to clients) include historical relationship with the Registrant, financial
strength, reputation, execution capabilities, pricing, research, and service. Although the
commissions and/or transaction fees paid by Registrant's clients shall comply with the
Registrant's duty to seek best execution, a client may pay a commission that is higher than
another qualified broker-dealer might charge to effect the same transaction where the
Registrant determines, in good faith, that the commission/transaction fee is reasonable. In
seeking best execution, the determinative factor is not the lowest possible cost, but whether
the transaction represents the best qualitative execution, taking into consideration the full
range of broker-dealer services, including the value of research provided, execution
capability, commission rates, and responsiveness. Accordingly, although Registrant will
seek competitive rates, it may not necessarily obtain the lowest possible commission rates
for client account transactions. The brokerage commissions or transaction fees charged by
the designated broker-dealer/custodian are exclusive of, and in addition to, Registrant's
investment management fee. The Registrant’s best price execution responsibility is
qualified if securities that it purchases for client accounts are mutual funds that trade at net
asset value as determined at the daily market close.
1. Non-Soft Research and Support Benefits
Although not a material consideration when determining whether to recommend that a
client utilize the services of a particular broker-dealer/custodian, Registrant receives
from Schwab, (or another broker-dealer/custodian, investment platform, unaffiliated
investment manager, vendor, unaffiliated product/fund sponsor, or vendor) without
cost (and/or at a discount) support services and/or products, certain of which assist the
11
Registrant to better monitor and service client accounts maintained at such institutions.
Included within the support services that may be obtained by the Registrant may be
investment-related research, pricing information and market data, software and other
technology that provide access to client account data, compliance and/or practice
management-related publications, discounted or gratis consulting services, discounted
and/or gratis attendance at conferences, meetings, and other educational and/or social
events, marketing support, computer hardware and/or software and/or other products
used by Registrant in furtherance of its investment advisory business operations.
There is no corresponding commitment made by the Registrant to Schwab or any other
entity to invest any specific amount or percentage of client assets in any specific mutual
funds, securities or other investment products as a result of the above arrangement.
The Registrant’s Chief Compliance Officer, Dominick Vetrano, remains available
to address any questions that a client or prospective client may have regarding
the above arrangements and the conflict of interest presented by such
arrangements.
2. The Registrant does not receive referrals from broker-dealers.
3. The Registrant does not generally accept directed brokerage arrangements (when a
client requires that account transactions be effected through a specific broker-dealer).
In such client directed arrangements, the client will negotiate terms and arrangements
for their account with that broker-dealer, and Registrant will not seek better execution
services or prices from other broker-dealers or be able to "batch" the client's
transactions for execution through other broker-dealers with orders for other accounts
managed by Registrant. As a result, client may pay higher commissions or other
transaction costs or greater spreads, or receive less favorable net prices, on transactions
for the account than would otherwise be the case.
Please Note: In the event that the client directs Registrant to effect securities
transactions for the client's accounts through a specific broker-dealer, the client
correspondingly acknowledges that such direction may cause the accounts to incur
higher commissions or transaction costs than the accounts would otherwise incur had
the client determined to effect account transactions through alternative clearing
arrangements that may be available through Registrant. Higher transaction costs
adversely impact account performance. Please Also Note: Transactions for directed
accounts will generally be executed following the execution of portfolio transactions
for non-directed accounts.
The Registrant’s Chief Compliance Officer, Dominick Vetrano, remains available
to address any questions that a client or prospective client may have regarding
the above arrangement.
B. Registrant may (but is not obligated to) combine or “batch” client orders to obtain “best
execution,” to negotiate more favorable commission rates or to allocate equitably among
Registrant’s clients differences in prices and commissions or other transaction costs that
might have been obtained had such orders been placed independently. Under this
procedure, transactions will be averaged as to price and will be allocated among
Registrant's clients in proportion to the purchase and sale orders placed for each client
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account on any given day. The Registrant shall not receive any additional compensation or
remuneration as a result of such aggregation.
Item 13
Review of Accounts
A. For those clients to whom Registrant provides investment supervisory services, account
reviews are conducted on an ongoing basis by the Registrant's Principal and/or
representatives. All investment supervisory clients are advised that it remains their
responsibility to advise the Registrant of any changes in their investment objectives and/or
financial situation. All clients (in person or via telephone) are encouraged to review
financial planning issues (to the extent applicable), investment objectives and account
performance with the Registrant on an annual basis.
B. The Registrant may conduct account reviews on an other than periodic basis upon the
occurrence of a triggering event, such as a change in client investment objectives and/or
financial situation, market corrections and client request.
C. Clients are provided, at least quarterly, with written transaction confirmation notices and
regular written summary account statements directly from the broker-dealer/custodian
and/or program sponsor for the client accounts. The Registrant may also provide a written
periodic report summarizing account activity and performance.
Item 14
Client Referrals and Other Compensation
A. As referenced in Item 12.A.1 above, the Registrant receives an economic benefit from
Schwab (and/or others). The Registrant, without cost (and/or at a discount), receives
support services and/or products from Schwab. There is no corresponding commitment
made by the Registrant to Schwab or any other entity to invest any specific amount or
percentage of client assets in any specific mutual funds, securities or other investment
products as a result of the above arrangement. The Registrant’s Chief Compliance
Officer, Dominick Vetrano, remains available to address any questions that a client
or prospective client may have regarding the above arrangements and the conflict of
interest presented by such arrangements
B. The Registrant does not maintain solicitor arrangements. The Registrant does not
compensate third parties for client introductions.
Item 15
Custody
The Registrant shall have the ability to deduct its advisory fee from the client’s custodial account.
Clients are provided with written transaction confirmation notices, and a written summary account
statement directly from the custodian (i.e., Schwab, etc.) at least quarterly. Please Note: To the
extent that the Registrant provides clients with periodic account statements or reports, the client is
urged to compare any statement or report provided by the Registrant with the account statements
received from the account custodian. Please Also Note: The account custodian does not verify the
accuracy of the Registrant’ advisory fee calculation.
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to address
any questions
Custody Situations: As the result of client password possession, the Registrant indicates that it does not
have custody of the corresponding assets at Item 9 of Part 1 of its Form ADV, and is not required to undergo
an annual surprise CPA examination pertaining to those assets. In addition, certain clients have established
asset transfer authorizations that permit the qualified custodian to rely upon instructions from the Registrant
to transfer client funds or securities to third parties. These arrangements are disclosed at Item 9 of Part 1 of
Form ADV. However, in accordance with the guidance provided in the SEC’s February 21, 2017 Investment
Adviser Association No-Action Letter, the affected accounts are not subject to an annual surprise CPA
examination. ANY QUESTIONS: Fountainhead’s Chief Compliance Officer, Dominick Vetrano,
that a client or prospective client may
remains available
have regarding custody-related issues.
Item 16
Investment Discretion
The client can determine to engage the Registrant to provide investment advisory services
on a discretionary basis. Prior to engaging Registrant to provide investment management
services, the client will be required to enter into a formal Investment Advisory Agreement
with Registrant setting forth the terms and conditions under which Registrant shall manage
the client's assets, and a separate custodial/clearing agreement with each designated broker-
dealer/custodian.
Clients who engage the Registrant on a discretionary basis may, at anytime, impose
restrictions, in writing, on the Registrant’s discretionary authority. (i.e. limit the
types/amounts of particular securities purchased for their account, exclude the ability to
purchase securities with an inverse relationship to the market, limit or proscribe the
Registrant’s use of margin, etc.).
Item 17
Voting Client Securities
A. The Registrant does not vote client proxies. Clients maintain exclusive responsibility for:
(1) directing the manner in which proxies solicited by issuers of securities owned by the
client shall be voted, and (2) making all elections relative to any mergers, acquisitions,
tender offers, bankruptcy proceedings or other type events pertaining to the client’s
investment assets.
B. Clients will receive their proxies or other solicitations directly from their custodian. Clients
may contact the Registrant to discuss any questions they may have with a particular
solicitation.
Item 18
Financial Information
A. The Registrant does not require clients pay fees more than six months in advance.
B. The Registrant is unaware of any financial condition that is reasonably likely to impair its
ability to meet its contractual commitments relating to its discretionary authority over
certain client accounts.
C. The Registrant has not been the subject of a bankruptcy petition.
ANY QUESTIONS: The Registrant’s Chief Compliance Officer, Dominick
Vetrano, remains available to address any questions that a client or prospective client
may have regarding the above disclosures and arrangements.
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