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Item 1 – Cover Page
Form ADV Part 2A Brochure
LexAurum Advisors, LLC
16010 Metcalf Avenue, Suite 101
Overland Park, KS 66085
(913) 261-9316
www.lex-aurum.com
March 26, 2025
This Brochure provides information about the qualifications and business practices of
LexAurum Advisors, LLC (LexAurum). If you have any questions about the contents of this
Brochure, please contact us at (913) 261-9316. 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.
LexAurum is a registered investment adviser. Registration as an investment adviser does
not imply any level of skill or training. The oral and written communications of an adviser
provide you with information from which you can determine whether to hire or retain an
adviser.
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Item 2 – Material Changes
This Brochure dated March 26, 2025, represents an amendment to the Brochure for
LexAurum Advisors, LLC.
Since the filing of the annual amendment on February 18, 2025, we have made the
following material changes to the Brochure: added Sub-Advisory Services as a service
offered (see Item 4) and added additional fee disclosures related to Sub-Advisory Services
(see Item 5).
Pursuant to regulatory requirements, we will deliver to you a summary of any material
changes to this and subsequent Brochures within 120 days of the close of our fiscal year.
We may further provide other ongoing disclosure information about material changes, as
necessary. All such information will be provided to you free of charge.
Currently, our Brochure may be requested by contacting us at (913) 261-9316.
Additional information about LexAurum is also available via the SEC’s website
www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons
affiliated with LexAurum who are registered as investment adviser representatives of the
firm.
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Item 3 - Table of Contents
Item 1 – Cover Page ....................................................................................................................................... i
Item 2 – Material Changes ............................................................................................................................ ii
Item 3 - Table of Contents ........................................................................................................................... iii
Item 4 – Advisory Business ........................................................................................................................... 1
Item 5 – Fees and Compensation ................................................................................................................. 4
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................. 7
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 ............................................................................................................................. 10
Item 12 – Brokerage Practices .................................................................................................................... 11
Item 13 – Review of Accounts..................................................................................................................... 13
Item 14 – Client Referrals and Other Compensation .................................................................................. 14
Item 15 – Custody ....................................................................................................................................... 15
Item 16 – Investment Discretion ................................................................................................................ 16
Item 17 – Voting Client Securities ............................................................................................................... 16
Item 18 – Financial Information .................................................................................................................. 16
Brochure Supplement(s)
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Item 4 – Advisory Business
LexAurum Advisors, LLC (CRD # 283653) (LexAurum) is registered as an investment
adviser with the Securities Exchange Commission. LexAurum is based in Kansas and is
organized as a limited liability company under the laws of the State of Kansas. The firm
was formed in 2016 and currently has ten (10) employees working with the principal
office.
LexAurum’s principal office and place of business is located at 16010 Metcalf Avenue, Suite
101, Overland Park, KS, 66085. Regular business hours are Monday through Friday by
appointment. The firm can be contacted by phone at (913) 261-9316 and by fax at (844)
853-0766.
Peter W. Hughes is the firm’s majority owner and Chief Executive Officer. Jon M. Stanfield
is the firm’s Chief Compliance Officer.
Services Offered:
Investment Management Services
LexAurum provides ongoing discretionary and non-discretionary portfolio
management services to individuals, families, and businesses. For investment
management engagements, accounts may be managed by the client’s investment
adviser representative, by the firm’s Chief Investment Officer, or by sub-advisers or
third-party managers to whom investment management responsibility may be
delegated.
For accounts managed by the client’s investment adviser representative, the firm
representative not only makes recommendations related to investments, but also
implements these recommendations and provides ongoing monitoring and
reporting. Clients may elect to give the firm discretion to make all decisions
(discretionary management) or may prefer to approve all decisions before
implementation (non-discretionary management).
For an account managed by the firm’s Chief Investment Officer, LexAurum provides
a standardized managed account service known as the Golden Rule Program (GRP).
GRP is a diversified asset-allocation program which offers eight different models,
ranging from “Capital Preservation” on one end of the risk spectrum to “Aggressive”
on the other. Client accounts are positioned in one of these models based on their
investment objective, risk tolerance, time horizon, and other characteristics. GRP
accounts are invested primarily in low-cost ETFs, but mutual funds, closed-end
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funds or other investment vehicles may be used in certain situations. The Golden
Rule Program is managed by Peter Hughes, CFA, President and Chief Investment
Officer of LexAurum.
When accounts are managed by a sub-adviser or third-party manager, the sub-
adviser or third-party manager is generally responsible for security selection, and
LexAurum is responsible for general oversight. Engagements can either be
discretionary or non-discretionary in nature.
Investment Advisory Services
LexAurum also provides ongoing investment advisory services to individuals,
families and businesses where the firm makes ongoing investment
recommendations, but the client is responsible for determining whether to
implement recommendations, and if they decide to do so, are responsible for actual
implementation.
Financial Planning Services
Additionally, the firm provides project-oriented and ongoing financial planning
services to individuals and families where the firm offers advice or other strategic
assistance in areas such as education funding, retirement planning, estate planning,
risk management, employee benefits planning, tax planning, etc. When engaged to
provide financial planning assistance, clients are responsible for determining
whether to implement a recommendation, and if they decide to do so, are
responsible for actual implementation. The actual details of an engagement vary on
a case-by-case basis depending on the complexity of the client’s financial situation.
Generally, however, an engagement involves identification of goals and objectives,
collection and analysis of data, formulation of a strategy, and preparation of a
written plan. Engagements may be one-time, annual, or ongoing.
Retirement Plan Services
LexAurum also provides retirement plan services to businesses which may include
plan level services such as discretionary management services, non-discretionary
management services, and investment advisory services related to different types of
retirement plans. When providing management services, the firm is responsible for
implementing recommendations. When the firm is providing advisory services, the
client is responsible for the implementation of recommendations.
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Department of Labor Acknowledgement of Fiduciary Duty. As a registered
investment adviser, the firm is required to meet certain fiduciary standards when
providing investment advice to clients. Additionally, when the firm provides
investment advice related to a retirement plan account or an individual retirement
account (IRA) we are considered 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. As such, we are required
to act in your best interest and not put our interest ahead of yours, even though our
compensation creates some conflicts with your interests in that the more money
you have us manage, the more we can earn. In summary, under this special rule 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;
• Adopt and follow policies and procedures designed to ensure that we give
advice that is in a client’s best interest;
• Charge a reasonable fee for our services; and
• Offer basic information about any conflicts of interest.
Investment Management Services (Discretionary) Using Pontera
LexAurum also provides a service for accounts not held in our custody, but where
we do have discretionary authority. These are primarily 401(k) accounts, 403(b)
accounts, 401(a), Thrift Savings Plan (TSP), HSAs, and other assets held at other
custodians. LexAurum will never have direct access to Client log-in credentials.
Pontera and LexAurum are not affiliates and LexAurum receives no compensation
from Pontera for using its platform. Clients will receive a link allowing them to
connect their account(s) to the platform. Once established, LexAurum will review
the current allocations. As required, LexAurum will rebalance the account
considering the client’s investment goals, objectives, risk tolerance, and current
economic and market factors.
Clients will pay the specific quarterly fee for services indicated on the written
management agreement. A certain percentage of this fee, 25 bps, will be paid to
Pontera for the use of its platform. Although this fee is not directly passed along to
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the client, its presence may affect LexAurum’s willingness to negotiate its fees, and
therefore impact the overall fee to the client.
Sub-Advisory Services
Lex-Aurum makes investment management sub-advisory services available to other
investment advisory firms under its sub-advisory program. In these engagements,
the other investment management firm is responsible for assessing their clients’
financial situation, risk tolerance, investment goals, etc., and for selecting from
various LexAurum GRP model portfolios that LexAurum makes available as part of
the program. (GRP model portfolios generally consist of exchange traded funds,
mutual funds and, in some cases , stocks and bonds). Based on model selections by
the other investment advisory firm, LexAurum is responsible for trading and
rebalancing each client’s account accordingly. LexAurum also makes account billing
services available as part of the program.
Regardless of the services provided, each is tailored to the individual needs of a particular
client (whether an individual, a family, or a business) through an assessment conducted
prior to an engagement. Clients may impose restrictions related to the level of discretion
granted, the types of investments used, etc. Terms of an actual engagement, including
description of service, limitations and restrictions, fees, etc., are all detailed before any
engagement begins in a written client agreement.
The firm does not provide a “wrap fee” program, although sub-advisors or third-party
managers recommended by the firm may do so. For information regarding such programs
provided by outside managers, please refer to the applicable outside manager’s ADV Part 2
Disclosure Brochure which is available upon request.
As of 12/31/2024, the firm had approximately $1,006,435,215 in assets under
management, $903,242,550 of which was managed on a discretionary basis and
$103,192,665 was managed on a non-discretionary basis.
Item 5 – Fees and Compensation
Investment Management Services
Fees charged for discretionary and non-discretionary investment management services
may be charged in arrears or in advance and are generally based on total assets under
management at a rate negotiated on a case-by-case basis depending on the engagement.
The firm’s maximum fee schedule is as follows:
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Market Value of Assets Under Management
Annual Fee
Up to $2,000,000
2.00%
$2,000,001 - $5,000,000
1.50%
Assets over $5,000,000
1.25%
As mentioned in Item 4 above, the firm provides a standardized managed account program
(GRP), and in these cases, accounts are assessed a fee by both the firm and the investment
adviser representative. The combined GRP fee however will be at or below the firm’s fee
schedule reference in the preceding paragraph. For GRP managed accounts, the firm does
not retain any fee from the investment adviser representative’s portion of the overall
expense as the firm would for non-GRP accounts. This creates a conflict of interest, as
accounts managed by the investment adviser representative, or by a third-party manager,
are subject to a lower payout ratio. However, clients are made aware of fee options in
advance and are not obligated to use any particular management option.
Fees are generally deducted directly from client accounts on a quarterly basis (when
possible), but clients may elect to alternatively pay fees by check, ACH or directly from
another client account. For advanced billing, subject to the discretion of the firm, if assets
are deposited into an account after the beginning of a billing period, the fee payable with
respect to such assets will generally be prorated based on the number of days remaining in
the quarter. Conversely, in the event of client partial withdrawals, no fee adjustments will
be made.
Services may be terminated at any time by either party with 30 days’ written notice to the
other party, and fees will be prorated accordingly. Any payments made in advance will
then be prorated and refunded to the client, unless the total refund is less than $5.00 or the
account remains under LexAurum management by a successor in interest.
All management fees paid to LexAurum are separate and unrelated to any fees or expenses
assessed by mutual funds or exchange traded funds, or to any trade commission charged by
an account custodian. Sub-advisory fees and third-party management fees are generally
collected by the third-party firm. They remit a portion of the fee to LexAurum. All fee
details however are provided in the client agreement and/or other applicable
documentation. Information pertaining to fund-generated fees and expenses can be found
in mutual fund and exchange traded fund prospectuses.
In instances where clients are referred to a third-party manager, the client will pay the
third-party manager for services and LexAurum may receive a referral fee. The receipt of
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referral fees creates a conflict of interest in that LexAurum and or its representatives may
have an incentive to make a referral based on its own financial interests. In these cases,
however, the client will receive additional information about the referral arrangement and
fees paid in advance and will not be obligated to use the manager’s services.
In instances where LexAurum is functioning as a Sub-Advisor for another investment
advisory firm, the client will pay a fee to the other investment advisory firm and LexAurum
will receive a portion of that fee based on the Sub-Advisory Agreement with the other
investment advisory firm. In some engagements, Lex-Aurum will deduct the total fee from
the client’s account, retain its portion and send the remainder to the other investment
advisory firm.
LexAurum fees related to assets managed using Pontera will not be below 0.25%. Fees
charged for these services will be based on a flat or tiered percentage of assets under
management, usually billed in advance on a quarterly basis and calculated on the fair
market value of the account on the last business day of the billing period. Fees will be
prorated if opened mid-quarter. Clients will authorize LexAurum to debit the fees directly
from one or more of the Client’s taxable accounts, on a pro-rata basis. LexAurum will
invoice the client directly in the event of insufficient funds in the account(s).
Investment Advisory Services
Fees charged for advisory services may be charged in advance or in arrears depending on
the service provided. Fees are quoted in advance, generally range from .50% to 1.50%
annually and may be negotiable. Fees are based on a percentage of assets under
management, or the actual services provided. Fees may be deducted directly from client
accounts and sometimes are billed directly.
Services may be terminated at any time by either party with 30 days’ written notice to the
other party, and fees will be prorated accordingly. Any payments made in advance will
then be prorated and refunded to the client, unless the total refund is less than $5.00 or the
account remains under LexAurum management by a successor in interest.
All advisory fees paid to LexAurum are separate and unrelated to any fees or expenses
assessed by any broker, custodian, or other outside party.
Financial Planning Services
Fees charged for financial planning services are quoted in advance and charged at a fixed
amount or are based on an estimated number of hours at a fixed hourly rate. Quoted fees
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will be based on the complexity and level of service provided on a case-by-case basis. As
mentioned above, services may include planning in areas such as education funding,
retirement planning, estate planning, risk management, employee benefits planning, tax
planning, etc. Since each of these areas can vary in complexity depending on the
complexity of the client’s financial situation, cost will vary as well. Fees are negotiable
depending on the circumstances of the engagement, location, etc.
Fees are generally billed directly to the client in advance, although a portion of which may
be billed in arrears.
Services may be terminated at any time by either party with 30 days’ written notice to the
other party, and fees will be prorated accordingly. Any payments made in advance will
then be prorated and refunded to the client, unless the total refund is less than $5.00 or the
account remains under LexAurum management by a successor in interest.
All financial planning fees paid to LexAurum are separate and unrelated to any fees or
expenses assessed by any broker, custodian, or other outside party.
Retirement Plan Services
Fees charged for retirement plan services may be charged in advance or in arrears
depending on the service provided. Fees may be fixed, or asset based (not to exceed 1.50%
annually) and are negotiable depending on the complexity of the service. Fee levels
(whether fixed or asset based) are primarily based on actual services to be provided.
Fees may be deducted directly from client accounts on a quarterly basis, or clients may
elect to alternatively pay fees by check or wire transfer.
Services may be terminated at any time by either party with 30 days’ written notice to the
other party, and fees will be prorated accordingly. Any payments made in advance will
then be prorated and refunded to the client, unless the total refund is less than $5.00 or the
account remains under LexAurum management by a successor in interest.
All retirement plan fees paid to LexAurum are separate and unrelated to any fees or
expenses assessed by any broker, custodian, or other outside party.
Item 6 – Performance-Based Fees and Side-By-Side Management
LexAurum does not charge performance-based fees (fees based on a share of capital gains
or on capital appreciation of the assets of a client), and consequently does not
simultaneously manage performance based and non-performance-based accounts.
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Item 7 – Types of Clients
LexAurum provides services to individuals and institutional investors including businesses,
retirement plans, foundations, endowments, etc.
For its services, LexAurum does not require a minimum dollar value of assets for
establishing or maintaining a client’s account, but the firm reserves the right to decline
engagements for various reasons including account size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
When providing investment management services, investment strategies may be
established by LexAurum’s Chief Investment Officer, may be established by representatives
of LexAurum under the oversight of LexAurum’s Chief Investment Officer, or may be
established by outside managers to whom management may be delegated.
LexAurum’s general investment strategy, whether accounts are managed by the firm’s
Chief Investment Officer or by the firm’s investment adviser representatives, is to attempt
to reduce risk and volatility by building diversified portfolios in a manner consistent with
the tenets of modern portfolio theory. To implement this strategy, LexAurum and its
representatives may use fundamental security methods of analysis, market trend analysis,
and economic cycle analysis. While mutual funds, exchange traded funds, stocks and bonds
are the primary investment vehicles used in or recommended for client accounts, we may
also use or recommend various other investment vehicles in the implementation of our
strategies, including long-term purchases (securities held at least a year), short-term
purchases (securities sold within a year), trading (securities sold within 30 days), margin
and options.
For information regarding investment strategies and methods of analysis used by outside
managers, please refer to the applicable outside manager’s ADV Part 2 Disclosure
Brochure, which is available upon request.
Investing in securities involves risk of loss that clients should be prepared to bear. Such
risks include market risk, interest rate risk, currency risk, political risk, government
regulations, environmental issues, natural disasters and pandemics, and loss of capital,
among others. Additionally, certain trading strategies can affect investment performance
through increased brokerage and other transaction fees. Each client’s propensity for risk,
however, is thoroughly evaluated, documented, and considered throughout the portfolio
implementation process.
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As requested by a client, some portfolios may utilize value-based investments or
Environmental, Social and Governance Funds (ESGs). Clients are reminded that ESG fund
managers consider ESG factors to varying degrees and not every fund incorporates ESG
factors in the same manner or degree which can make it hard to accurately compare funds.
There is also no benchmark upon which ESG factors impacting investment performance
can be compared. Utilizing ESG funds can adversely impact performance, fund expenses
and investment risk. Any ESG recommendations are made solely using information
provided by issuers.
Clients seeking exposure to cryptocurrencies, including Bitcoin, are encouraged to use
traded securities whenever possible and to invest only in moderation after thorough
personal due diligence. Unlike conventional currencies regulated by a monetary authority,
cryptocurrencies are unregulated and highly speculative. Clients purchasing these digital
assets must be prepared for potential liquidity constraints, extreme price volatility, and the
complete loss of principal.
Although LexAurum intends to manage risk through the careful selection of investments,
no investment strategy can assure a profit or avoid a loss. For more information about
risks associated with any particular investment, please contact LexAurum directly.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to the evaluation of the firm or the
integrity of its management. LexAurum is currently not subject to, nor has ever been
subject to, any legal or disciplinary events of a material nature.
Item 10 – Other Financial Industry Activities and Affiliations
Some associated persons of LexAurum may also be registered representatives of Integrity
Alliance LLC (formerly known as Brokers International Financial Services, LLC), a
securities broker-dealer regulated by the Financial Industry Regulatory Authority, Inc.
(FINRA). As such, these individuals, in their separate capacities as registered
representatives, will be able to affect securities transactions and will receive separate
customary compensation for affecting any securities transactions. They may also from time
to time receive 12b-1 distribution fees from investment companies in connection with the
placement of client funds into investment companies. They do not, however, receive these
fees for investments placed in accounts which LexAurum manages.
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LexAurum may also offer clients advice or recommendations related to insurance products.
Some associated persons of LexAurum are licensed insurance agents and may represent
various insurance companies. Any insurance product placed through LexAurum or
LexAurum associated persons may generate standard and customary insurance
commissions and other compensation, a portion of which may be received by LexAurum or
associated persons of LexAurum.
While LexAurum will endeavor at all times to put the interest of clients first as part of its
fiduciary duty, clients should be aware that the receipt of additional compensation creates
a conflict of interest and may affect the judgment of individuals who make
recommendations. However, our clients are under no obligation to purchase products
recommended by our associated persons or to purchase products through LexAurum or
LexAurum associated persons. We believe that our recommendations are in the best
interests of our clients and are consistent with our clients’ needs.
Item 11 – Code of Ethics
Code of Ethics
LexAurum has adopted a Code of Ethics expressing the firm's commitment to ethical
conduct. The LexAurum Code of Ethics describes the firm's fiduciary duties and
responsibilities to clients, and details practices for reviewing the personal securities
transactions of supervised persons with access to client information. The Code also
requires compliance with applicable securities laws, addresses insider trading, and details
possible disciplinary measures for violations. LexAurum will provide a complete copy of its
Code of Ethics to any client upon request to the Chief Compliance Officer.
Trading Conflicts of Interest
Individuals associated with LexAurum are permitted to buy or sell securities for their
personal accounts identical to or different than those recommended to clients. However, no
person employed by LexAurum is allowed to favor his or her own interest over that of a
client or make personal investment decisions based on the investment decisions of
advisory clients.
In order to address potential conflicts of interest, LexAurum requires that associated
persons with access to advisory recommendations provide annual securities holdings
reports and quarterly transaction reports to the firm's Chief Compliance Officer. LexAurum
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also requires prior approval from the Chief Compliance Officer for investing in any IPOs or
private placements (limited offerings).
Item 12 – Brokerage Practices
The Custodian and Brokers We Use
We do not maintain custody of client assets. Instead, we require all client assets be
maintained in an account at a non-affiliated “qualified custodian,” generally a broker-dealer
or bank. The custodian will hold your assets in a brokerage account and will be able to buy
and sell securities on your behalf.
While we may recommend that you use a particular custodian/broker, you will ultimately
decide whether to do so and will open your account by entering into an account agreement
directly with them. We cannot open accounts for you, but we can assist you in opening an
account at whatever custodian/broker you decide to use. We recommend that our clients
use Charles Schwab & Co., Inc. (Schwab) or SEI Investment Distribution Co. (SEI), both are
registered broker dealers, SIPC members, and qualified custodians. We are independently
owned and operated and are not affiliated with Schwab or SEI.
How We Select Custodians and Brokers
When recommending a custodian or broker for our clients, we consider many different
factors including quality of service, types of services offered, overall capability, execution
quality, competitiveness of transaction costs, availability of investment research,
reputation of the firm, and financial resources, among other things. In determining the
reasonableness of a broker’s compensation, we consider the overall cost to you relative to
the benefits you receive, both directly and indirectly, from the broker.
Your Brokerage and Custody Costs
Our clients receive various services directly from our custodians. For our clients’ accounts
that they maintain, our custodians generally do not charge separately for custody services
but instead are compensated by charging commissions or other fees on trades that they
execute or trades that are executed by other brokers to and from custodial accounts.
Custodians also receive revenue from money market funds that it makes available to clients
as a cash sweep option and for accounts that choose to invest cash in such a money market
fund. Fees applicable to our client accounts are sometimes negotiated based on the
condition that our clients collectively maintain a certain level of assets at a particular
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custodian. We feel this commitment benefits you because we expect the overall rates you
pay will be lower than they might be otherwise.
Since custodians often charge clients a fee for each trade that we have executed by a
different broker-dealer, we have the primary custodian execute most trades in order to
minimize your trading costs.
We have determined that having custodians execute most trades is consistent with our
duty to seek “best execution” of your trades. Best execution means seeking the most
favorable terms for a transaction based on all relevant factors, including those listed above.
Products and Services Available to Us from Brokers/Custodians
Our primary custodians provide us and our clients with access to its institutional brokerage
services like trading, custody, reporting, and related services, many of which are not
typically available to retail customers. Our custodians also make available various support
services, some of which may help us manage or administer our clients’ accounts, while
others may help us manage and grow our business.
Other institutional brokerage services which benefit you directly include access to a broad
range of investment products, execution of securities transactions, and asset custody. The
investment products available through our custodians include some to which we might not
otherwise have access or that would require a significantly higher minimum initial
investment by our clients.
Our custodians also make available to us other products and services that benefit us but
may not directly benefit you or your account. These products and services assist us in
managing and administering our clients’ accounts. They include investment research, both
from custodians/brokers and from third parties. We may use this research to service all or
a substantial number of our clients’ accounts, including accounts not maintained at a
particular custodian. In addition to investment research, our custodians may also make
available software and other technology that provide access to client account data,
facilitate trade execution for multiple client accounts, provide pricing and other market
data, facilitate payment of our fees from our clients’ accounts, and assist with back-office
functions, recordkeeping, and client reporting.
Our custodians also offer other services intended to help us manage and further develop
our business. These services include educational conferences and events, consulting on
technology, compliance, legal, and business needs, publications and conferences on
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practice management and business succession, and access to employee benefits providers,
human capital consultants, and insurance providers.
The availability of these services from our custodians benefits us because we do not have to
produce or purchase them. Of course, this may give us an incentive to recommend that you
maintain your account with a custodian based on our interests rather than yours, which is a
conflict of interest. We believe, however, that our selection of our custodians and brokers is
in the best interests of our clients, and is primarily supported by the scope, quality, and
price of services provided and not the custodians’ services that benefit only us.
Aggregation of Transactions
LexAurum may, from time to time, aggregate client orders into blocks to facilitate more
efficient account management and execution. When aggregating orders, an average price is
given to all participants in the block, or other measures are taken, to treat all accounts
fairly.
Item 13 – Review of Accounts
Review of Accounts
Account holdings are typically reviewed on a continuous basis by the portfolio manager.
Accounts are subject to a more general review on a periodic basis (i.e. monthly, quarterly,
semi-annually, etc.) depending on the type of account. Account reviews typically involve
addressing investment objectives, risk tolerance or asset allocations, but may be more
detailed in scope, depending on circumstances. The level of detail of the review is generally
triggered by factors such as market, political, or economic conditions, or the client's
individual financial situation. Clients should notify the firm of any material personal
financial changes.
Information about reviews conducted by outside managers may be found in the outside
manager’s Form ADV Part 2 Disclosure Brochure, which is available upon request.
Regular Reports Provided to Clients
In addition to the monthly statements and confirmations of transaction that clients receive
from the custodian, LexAurum may provide other reports directly to the client from time to
time depending on the type of engagement. Investment management clients, for example,
may receive periodic performance-related reports. Financial planning clients may receive
a planning analysis but do not receive regular reports from LexAurum. LexAurum urges
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clients to carefully review custodial statements and compare them with the reports which
we may provide.
Information about reports provided by outside managers may be found in the outside
manager’s Form ADV Part 2 Disclosure Brochure, which is available upon request.
Item 14 – Client Referrals and Other Compensation
LexAurum does engage outside parties (promoters) for client referrals, but in doing so, is
required to structure such referral arrangements to comply with applicable regulatory
requirements, including Rule 206(4)-1 under the Advisors Act (the “Marketing Rule”). For
example, the firm is required to provide referred clients with a disclosure statement which
provides details, including compensation, related to the referral arrangement, and our
Form ADV Part 2 brochure as well. Compensation for these arrangements is typically
sharing a percentage of the client advisory fees generated. This sharing will not result in
any charges to clients in addition to the normal advisory fees that would have applied.
LexAurum may also utilize testimonials and endorsements. A “testimonial” includes any
statement by a current client about the client’s experience with the investment advisor or
its supervised persons. An “endorsement” includes any statement by a person other than a
current client indicating approval, support, or recommendation of the investment advisor
or its supervised persons or describes that person’s experience with the advisor or its
supervised persons. These marketing activities create a conflict of interest in that cash or
non-cash compensation provided may motivate a person to provide a positive statement
about, solicit an investor for, or refer an investor to, LexAurum. Any compensation paid
will be prominently disclosed and clients are encouraged to rely only on the public
disclosures provided by LexAurum and their own judgement and not the opinion of any
third party in deciding whether to engage our services.
LexAurum does not receive any sales award or prizes in connection with providing
advisory services to clients. LexAurum does however receive economic benefits from our
custodian in the form of the support products and services that are made available to us
and to other independent investment advisors. These products and services, how they
benefit us, and the related conflicts of interest are described in Item 12 above. The
availability to us of our custodian’s products and services is not based on us giving
particular investment advice, such as buying particular securities for our clients.
LexAurum and its representatives may also qualify for referral fees when referring clients
to outside managers. These referral arrangements would be required to be structured to
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comply with applicable regulatory requirements, including providing clients with a
solicitor’s disclosure statement. Acceptance of referral fees creates a conflict of interest
because the firm or its representatives may have an incentive to recommend which outside
manager to use based on referral fees received. However, when referring clients to an
outside manager, the firm will not only disclose the compensation received but will also
strive to be cognizant of the client’s best interest at all times. Moreover, the engagement of
an outside manager is always at the client’s discretion.
LexAurum may accept discounted or free travel to attend due diligence conferences or to
attend or host professional conferences or client meetings. Although this support is not a
material source of firm revenue, this represents a conflict of interest as LexAurum may be
more likely to recommend securities from firms providing these economic benefits.
LexAurum and the law firm of Rees, Kincaid and Stanfield (RKS) have a common part
owner in Jon Stanfield. He is a partner with RKS and a minority member of LexAurum.
Clients of LexAurum may be referred to RKS for estate planning and other legal services.
The common ownership presents a conflict of interest as one member of LexAurum has an
economic interest in RKS and may benefit from such referrals in lieu of referring clients to
other law firms or financial professionals. Although LexAurum and its independent
advisors may recommend RKS, you are never obligated or required to use its services.
There are other law firms that provide legal services like RKS and may charge lower rates.
You are encouraged to consider other law firms before hiring RKS. The legal services
provided by RKS are separate and distinct from LexAurum and the two entities do not
share revenue with one another but may share certain expenses.
Some of LexAurum’s associated persons, that are insurance agents and/or own insurance
agencies receive commissions and other incentive awards for the recommendation or sale
of insurance products. This compensation may affect the judgment of our associated
people when recommending products to our clients. While these insurance agents attempt
to put the interest of the clients first as a part of our fiduciary duty, the receipt of
commissions and additional compensation creates a conflict of interest and may affect the
judgement of insurance agents when making insurance product recommendations.
Item 15 – Custody
As noted in Item 12, LexAurum recommends that clients’ assets be held by a qualified
custodian. Although we do not maintain actual custody of your assets, we may have limited
control (a form of custody under securities regulations) in some instances to trade on your
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behalf, to deduct our advisory fees from your account with your authorization, or to
request disbursements to you or another person’s account.
You will receive account statements directly from your custodian at least quarterly, which
will be sent to the email or postal mailing address you provide. LexAurum urges clients to
carefully review custodial statements and compare them to any account reports that we
might provide. You should inform LexAurum and the custodian of any change in contact
information.
Item 16 – Investment Discretion
LexAurum will accept discretionary authority to manage securities accounts on behalf of
clients, although we will also accept non-discretionary accounts.
When granted authority to manage accounts, LexAurum customarily has the authority to
determine which securities and the amounts that are bought or sold or may delegate such
authority to outside managers. Any discretionary authority accepted by LexAurum,
however, is subject to the client’s risk profile and investment objectives and may be limited
by any other limitations provided by the client in writing.
LexAurum will not exercise any discretionary authority until it has been given authority to
do so in writing. Such authority is granted in the written agreement between LexAurum
and the client, and in the written agreement with the third-party custodian.
Item 17 – Voting Client Securities
LexAurum does not vote proxies on behalf of clients.
Item 18 – Financial Information
Registered investment advisers are required in some cases to provide certain financial
information and or disclosures about their financial condition. For example, if the firm
requires prepayment of fees for six months in advance, has custody of client funds, or has a
condition that is reasonably likely to impair its ability to meet it contractual commitments
to its clients, it must provide financial information and make disclosures.
LexAurum has no financial or operating conditions which trigger such additional reporting
requirements.
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