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Item 1: Cover Page
Moment Private Wealth,
LLC
Form ADV Part 2A Brochure
Address:
2 CityPlace Drive - 2nd Floor
Saint Louis, MO 63141
Phone:
(636) 591-1050
Email:
luke@momentprivatewealth.com
Website:
https://www.momentprivatewealth.com
This brochure provides information about the qualifications and business practices of Moment Private
Wealth, LLC. If you have any questions about the contents of this brochure, please contact us at the
telephone number or email address listed above. 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.
Moment Private Wealth, LLC is a registered investment adviser, but registration does not imply a certain
level of skill or training.
Additional information about Moment Private Wealth, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov and by searching for CRD# 313223.
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Date of Brochure: March 23, 2025
Item 2: Material Changes
In this Item, Moment Private Wealth, LLC is required to identify and discuss material changes since filing
its last annual amendment. Since filing its last amendment on March 15, 2024, there have been no
material changes.
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Date of Brochure: March 23, 2025
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 & Side-By-Side Management
Item 7: Types of Clients
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Item 9: Disciplinary Information
Item 10: Other Financial Industry Activities & Affiliations
Item 11: Code of Ethics, Participation or Interest in Client Transactions & 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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Date of Brochure: March 23, 2025
Item 4: Advisory Business
A. Moment Private Wealth, LLC (“Adviser”) is an investment adviser founded in 2021, registered
with the U.S. Securities and Exchange Commission (“SEC”), and co-owned by Luke Turner and
Jacob Turner.
B. Adviser offers the following types of advisory services:
i.
Investment Management: Adviser provides ongoing discretionary and non-discretionary
investment management services to its clients based upon each client’s current financial
condition, goals, risk tolerance, income, liquidity requirements, investment time horizon,
and other information that is relevant to the management of clients’ account(s). This
information will then be used to make investment decisions and recommendations that
reflect clients’ individual needs and objectives on an initial and ongoing basis. Adviser’s
goal is to create and manage strategic portfolios designed for clients’ liquidity and
income needs in the long-term.
Adviser’s recommendations will allocate portions of clients’ account(s) to various asset
classes. For non-discretionary accounts, Adviser will review all such recommendations
with clients, and clients will have the opportunity to accept or reject any
recommendations. Clients with non-discretionary accounts are under no obligation to
accept or implement any recommendation made by Adviser. For discretionary accounts,
Adviser will retain the discretion to buy, sell, or otherwise transact in securities and other
investments in a client’s accounts without first receiving the Client’s specific approval for
each transaction. Such discretionary authority is granted by a client in his or her
investment management agreement with Adviser. Clients may impose restrictions on
investing in certain securities or types of securities so long as such restrictions may
reasonably be implemented by Adviser.
ii.
Financial Planning: In connection with its investment management services, Adviser also
provides holistic financial planning services that can take the form of (a) the preparation
and delivery of a one-time financial plan, or (b) ongoing financial planning
recommendations and assistance with the implementation of such recommendations.
Depending on the particular needs of a client, financial planning services may include the
following topics:
Incorporation of outside assets and business interests
i. Budgeting and spending analysis
ii. Loan procurement and advisement
iii. Cash flow modeling
iv. Daily monitoring for rebalancing and tax loss harvesting
v.
vi. Access to private equity opportunities
vii. CPA, estate planning attorney, and risk management professional coordination
viii. Tax-efficient strategic asset location
ix. Tax-sheltered investment opportunities
x. Non-legal review of estate planning documents
xi. Creation of an estate planning flowchart
xii. Risk management and mitigation
xiii.
Insurance solution assessment
Clients are free to accept or reject Adviser’s financial planning recommendations in their
sole discretion, and are under no obligation to implement Adviser’s financial planning
recommendations through Adviser or any of its personnel.
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Date of Brochure: March 23, 2025
iii.
Selection of Other Investment Advisers: Adviser’s discretionary authority explicitly
includes the authority to retain one or more independent and unaffiliated third-party
investment advisers to manage and execute the day-to-day implementation of Adviser’s
investment management decisions (a “Third-Party Adviser”). Alternatively, Adviser may
recommend the retention of a Third-Party Adviser, and client may accept or reject such
a recommendation as it deems fit. The Third-Party Adviser may be retained on Client’s
behalf or on Adviser’s behalf for so long as Adviser and/or the client deems fit, but in
either case the Third-Party Adviser will be disclosed to the client in writing in advance of
such retention. Depending on the Third-Party Adviser’s requirements and the negotiated
agreement between the Third-Party Adviser and Adviser, the client may be asked to sign
a separate agreement with such Third-Party Adviser.
iv.
Pension Consulting Services. To the extent Adviser is retained by a pension or profit
sharing plan (a “Plan”), Adviser shall review the Plan’s investment objectives, risk
tolerance, and goals, and shall work in partnership with applicable third-parties (such as
the Plan’s recordkeeper, third-party administrator, and/or discretionary investment
manager) to establish an appropriate investment policy statement and deploy applicable
investment options into the Plan’s account. Adviser will also generally provide advice
with respect to asset classes, diversification, and investment alternatives available to the
plan, and annually reevaluate available investment options under the Plan. Adviser may
also educate participants in the Plan with respect to general investment concepts and
the investment options available within the Plan. In connection with Plans subject to the
Employee Retirement Income Security Act of 1974 (“ERISA”) and applicable provisions
of the Internal Revenue Code of 1986, as amended (the “Code”) Adviser acknowledges
that it is a fiduciary under ERISA and the Code, shall render prudent investment advice
that is in Plan’s best interest, shall avoid making misleading statements, and shall
receive no more than reasonable compensation.
C. Adviser tailors its advisory services to the individual needs of its clients by taking the time to
understand clients’ current financial condition, goals, risk tolerance, income, liquidity
requirements, investment time horizon, and other information that is relevant to the management
of clients’ account(s). This information will then be used to make investment recommendations
that reflect clients’ individual needs and objectives on an initial and ongoing basis. Adviser’s
recommendations will allocate portions of clients’ account(s) to various asset classes classified
according to historical and projected risks and rates of return. Adviser will review all such
recommendations with clients, and clients will have the opportunity to accept or reject any
recommendations. Clients are under no obligation to accept or implement any recommendation
made by Adviser. Clients may impose restrictions on investing in certain securities or types of
securities so long as such restrictions may reasonably be implemented by Adviser.
D. Adviser does not participate in any wrap fee programs.
E. As of December 31, 2024, Adviser manages $156,748,390 in client assets on a discretionary
basis and $0 on a non-discretionary basis.
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Date of Brochure: March 23, 2025
Item 5: Fees and Compensation
A. Adviser is compensated for its advisory services primarily by fees charged based on a client’s
assets under management with Adviser as described below, or by flat fees that typically range
from $2,500 - $250,000 per annum charged monthly or quarterly in arrears. Fees are
negotiable, and each client’s specific fee schedule is included as part of the investment advisory
agreement signed by Adviser and the client.
Adviser’s standard blended fee schedules are included below, subject to negotiation with a client,
and dependent on the amount of assets under Adviser’s management:
For clients with less than $10 million under Adviser’s management
Client Assets Under Management
$0 - $1,999,999
$2,000,000 - $3,999,999
$4,000,000 - $5,999,999
$6,000,000 - $9,999,999
Annual Fee Percentage
(paid quarterly)
1.00%
0.80%
0.70%
0.65%
For clients with $10 million or more under Adviser’s management
Client Assets Under Management
$0 - $2,999,999
$3,000,000 - $4,999,999
$5,000,000 - $9,999,999
$10,000,000 - $14,999,999
$15,000,000 - $19,999,999
$20,000,000 - $29,999,999
$30,000,000 - $49,999,999
$50,000,000 - $74,999,999
$75,000,000 - $99,999,999
$100,000,000 and above
Annual Fee Percentage
(paid quarterly)
0.75%
0.70%
0.65%
0.55%
0.50%
0.45%
0.40%
0.30%
0.25%
Negotiable
Retirement plan clients will be charged an asset-based fee up to 1% per annum, charged quarterly
in advance, or flat fees that generally range from $2,500 to $10,000 per annum, charged quarterly
in advance.
B.
Initial fees are prorated based on the number of days that a client’s account was open during the
applicable billing period. Asset-based fees are deducted in advance on a quarterly basis from
clients’ assets and based upon the market value of such assets managed by Adviser as of the
last day of the prior calendar quarter. Fixed fees are deducted in arrears on a monthly or quarterly
basis from clients’ assets and based on the nature and complexity of the services to be provided
to the client. Alternatively, clients may elect to be invoiced for services rendered and pay via
check, ACH, or other electronic means.
C.
In addition to the fees charged by Adviser, clients will incur brokerage and other transaction
costs. Please refer to Item 12: Brokerage Practices, for further information on such brokerage
and other transaction-related practices. Clients will also typically incur additional fees and
expenses imposed by independent and unaffiliated third-parties, which can include qualified
custodian fees, mutual fund or exchange traded fund fees and expenses, mark-ups and
mark-downs, spreads paid to market makers, wire transfer fees, check-writing fees,
early-redemption charges, certain deferred sales charges on previously-purchased mutual funds,
margin fees, charges or interest, IRA and qualified retirement plan fees, and other fees and taxes
on brokerage accounts and securities transactions. These additional charges are separate and
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Date of Brochure: March 23, 2025
apart from the fees charged by Adviser.
D.
If Adviser or a client terminates the advisory agreement before the end of a quarterly billing
period, Adviser’s fees will be prorated through the effective date of the termination. The pro rata
fees for the remainder of the quarterly billing period after the termination will be refunded to the
client.
E. Neither Adviser nor any of
its supervised persons accepts compensation for the sale of
securities or other investment products.
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Date of Brochure: March 23, 2025
Item 6: Performance-Based Fees & Side-By-Side
Management
Neither Adviser nor any of its supervised persons accepts performance-based fees (fees based on a
share of capital gains or capital appreciation of the assets of a client).
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Date of Brochure: March 23, 2025
Item 7: Types of Clients
Adviser generally provides its services to individuals, high-net-worth individuals, pension and profit sharing
plans, and charitable organizations. The minimum account value required to open an account with Adviser
is $500,000, subject to negotiation.
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Date of Brochure: March 23, 2025
Item 8: Methods of Analysis, Investment Strategies & Risk
of Loss
A. The investment strategies used by Adviser when formulating investment advice or managing
assets include long-term, low-cost, diversified asset-allocation that is typically based on Modern
Portfolio Theory. Portfolios are developed based on initial financial planning analyses and risk
tolerance assessments undertaken at the inception of a client relationship, and portfolios are
primarily comprised of mutual funds, exchange traded-funds (“ETFs”) and, when appropriate,
real estate investment trusts (“REITs”). Investing in securities involves risk of loss that clients
should be prepared to bear. Past performance does not guarantee future returns.
B. Like any investment strategy, the implementation of long-term, low-cost, diversified asset-
allocation portfolios based on Modern Portfolio Theory involves material risks. Such material
risks are described in further detail below:
i.
Investing for the long term means that a client’s account will be exposed to short-term
fluctuations in the market and the behavioral impulse to make trading decisions based on
such short-term market fluctuations. Adviser does not condone short-term trading in an
attempt to “time” the market, and instead coaches clients to remain committed to their
financial goals. However, investing for the long term can expose clients to risks borne out
of changes to interest rates, inflation, general economic conditions, market cycles,
geopolitical shifts, and regulatory changes. Interest rate risk is the risk associated with
the value of a bond relative to increases or decreases in interest rates (interest rates
tend to be inversely related to bond prices). Inflation risk is the risk that the value of a
client’s portfolio will not appreciate at least in an amount equal to inflation over time.
General micro- and macro-economic conditions may also affect the value of the
securities held in a client’s portfolio, and general economic downturns can trigger
corresponding losses across various asset classes and security types. Market cycles
may cause overall volatility and fluctuations in a portfolio’s value, and may increase the
likelihood that securities are purchased when values are comparatively high and/or that
securities are sold when values are comparatively low. Geopolitical shifts may result in
market uncertainty, lowered expected returns, and general volatility in both domestic and
international securities. Regulatory changes may have a negative impact on capital
formation and increase the costs of doing business, and therefore result in decreased
corporate profits and corresponding market values of securities.
ii.
Investing in mutual funds does not guarantee a return on investment, and shareholders
of a mutual fund may lose the principal that they’ve invested into a particular mutual fund.
Mutual funds invest into underlying securities that comprise the mutual fund, and as such
clients are exposed to the risks arising from such underlying securities. Mutual funds
charge internal expenses to their shareholders (which can include management fees,
administration fees, shareholder servicing fees, sales loads, redemption fees, and other
fund fees and expenses, e.g.), and such internal expenses subtract from its potential for
market appreciation. Shares of mutual funds may only be traded at their stated net asset
value (“NAV”), calculated at the end of each day upon the market’s close.
iii.
Investing in ETFs bears similar risks and incurs similar costs to investing in mutual funds
as described above. However, shares of an ETF may be traded like stocks on the open
market and are not redeemable at an NAV. As such, the value of an ETF may fluctuate
throughout the day and investors will be subject to the cost associated with the bid-ask
spread (the difference between the price a buyer is willing to pay (bid) for an ETF and
the seller's offering (asking) price).
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Date of Brochure: March 23, 2025
Clients are encouraged to carefully read the prospectus of any mutual fund or ETF to be
purchased for investment to obtain a full understanding of its respective risks and costs.
iv.
Investing in REITs means that clients will be subject to the risks associated with
investments in mortgages and their related activities in addition to the general risk of
equity and financial markets. Among the factors that the REIT industry is vulnerable to
are: (1) change in government regulation, primarily the pass-through tax treatment of
REIT income, (2) the market for residential mortgage assets, (3) the general level and
term structure for interest rates. The common equity prices of REITs have historically
been more closely correlated with changes in interest rates than other non-REIT
equity securities. Additionally, REITs tend to be more illiquid in nature, may contain
additional fees, and may experience disruptions in distributions in comparison to other
types of securities.
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Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of
Adviser’s advisory business or the integrity of Adviser’s management.
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Date of Brochure: March 23, 2025
Item 10: Other Financial Industry Activities & Affiliations
A. Neither Adviser nor any of its management persons are registered, or have an
application pending to register, as a broker-dealer or a registered representative of a
broker-dealer.
B. Neither Adviser nor any of its management persons are registered, or have an application
pending to register, as a futures commission merchant, commodity pool operator, a commodity
trading advisor, or an associated person of the foregoing entities.
C. Neither Adviser nor any of its management persons have any relationship or arrangement
with any related person listed below that is material to its advisory business or to its clients:
i.
ii.
iii.
iv.
v.
vi.
vii.
viii.
ix.
x.
xi.
broker-dealer, municipal securities dealer, or government securities dealer or broker
investment company or other pooled investment vehicle (including a mutual fund, closed-
end investment company, unit investment trust, private investment company or “hedge
fund,” and offshore fund)
other investment adviser or financial planner
futures commission merchant, commodity pool operator, or commodity trading advisor
banking or thrift institution
accountant or accounting firm
lawyer or law firm
insurance company or agency
pension consultant
real estate broker or dealer
sponsor or syndicator of limited partnerships
D. As described earlier in Item 4 of this brochure, from time to time Adviser will retain or recommend
one or more Third-Party Advisers to provide investment advisory, administrative, and other back-
office services to Adviser for the benefit of Adviser and its clients. Adviser does not receive any
compensation directly from any Third-Party Adviser, but Third-Party Advisers do offer services
that are intended to directly benefit Adviser, clients, or both. Such services include (a) an online
platform through which Adviser can monitor and review client accounts, create model portfolios,
and perform other client account maintenance matters, (b) access to technology that allows for
client account aggregation, (c) quarterly client statements, (d) invitations to educational
conferences, (e) practice management consulting, (f) full or partial sponsorship of client
appreciation or education events, and (g) occasional business meals and entertainment. The
availability of such services from a Third-Party Adviser creates a conflict of interest, to the extent
Adviser may be motivated to retain a particular Third-Party Adviser as opposed to an alternative
service provider. Adviser addresses this potential conflict of interest by performing appropriate
due diligence on all Third-Party Advisers to confirm their services are in the best interests of
clients, periodically evaluating alternatives, and evaluating the merit of Third-Party Advisers
without consideration for the benefits received by Adviser.
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Date of Brochure: March 23, 2025
Item 11: Code of Ethics, Participation or Interest in Client
Transactions & Personal Trading
A. Adviser has adopted a code of ethics that will be provided to any client or prospective client upon
request. Adviser’s code of ethics describes the standards of business conduct that Adviser
requires of its supervised persons, which is reflective of Adviser’s fiduciary obligations to act in
the best interests of its clients. The code of ethics also includes sections related to compliance
with securities laws, reporting of personal securities transactions and holdings, reporting of
violations of the code of ethics to Adviser’s Chief Compliance Officer, pre-approval of certain
investments by access persons, and the distribution of the code of ethics and any amendments
to all supervised persons followed by a written acknowledgement of their receipt.
B. Neither Adviser nor any of its related persons recommends to clients, or buys or sells for
client accounts, securities in which Adviser or any of its related persons has a material
financial interest.
C. From time to time, Adviser or its related persons will invest in the same securities (or related
securities such as warrants, options or futures) that Adviser or a related person recommends to
clients. This has the potential to create a conflict of interest because it affords Adviser or its
related persons the opportunity to profit from the investment recommendations made to clients.
Adviser’s policies and procedures and code of ethics address this potential conflict of interest
by prohibiting such trading by Adviser or its related persons if it would be to the detriment of any
client and by monitoring for compliance through the reporting and review of personal securities
transactions. In all instances Adviser will act in the best interests of its clients.
D. From time to time, Adviser or its related persons will buy or sell securities for client accounts at or
about the same time that Adviser or a related person buys or sells the same securities for its own
(or the related person’s own) account. This has the potential to create a conflict of interest
because it affords Adviser or its related persons the opportunity to trade either before or after the
trade is made in client accounts, and profit as a result. Adviser’s policies and procedures and
code of ethics address this potential conflict of interest by prohibiting such trading by Adviser or
its related persons if it would be to the detriment of any client and by monitoring for compliance
through the reporting and review of personal securities transactions. In all instances Adviser will
act in the best interests of its clients.
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Date of Brochure: March 23, 2025
Item 12: Brokerage Practices
A. Adviser considers several factors when recommending a custodial broker-dealer for client
transactions and determining the reasonableness of such custodial broker-dealer’s
compensation. Such factors include the custodial broker-dealer’s industry reputation and
financial stability, service quality and responsiveness, execution price, speed and accuracy,
reporting abilities, and general expertise. Assessing these factors as a whole allows Adviser to
fulfill its duty to seek best execution for its clients’ securities transactions. However, Adviser does
not guarantee that the custodial broker-dealer recommended for client transactions will
necessarily provide the best possible price, as price is not the sole factor considered when
seeking best execution. After considering the factors above, Adviser recommends Fidelity
Custody & Clearing (“Fidelity”) as the custodial broker-dealer for client accounts.
i.
Adviser does not receive research and other soft dollar benefits in connection with client
securities transactions, which are known as “soft dollar benefits”. However, the custodial
broker-dealer(s) recommended by Adviser do provide certain products and services that
are intended to directly benefit Adviser, clients, or both. Such products and services
include (a) an online platform through which Adviser can monitor and review client
accounts, (b) access to proprietary technology that allows for order entry, (c) duplicate
statements for client accounts and confirmations for client transactions, (d) invitations to
the custodial broker-dealer(s)’ educational conferences, (e) practice management
consulting, and (f) occasional business meals and entertainment. The receipt of these
products and services creates a conflict of interest to the extent it causes Adviser to
recommend Fidelity as opposed to a comparable broker-dealer. Adviser addresses this
conflict of interest by fully disclosing it in this brochure, evaluating Fidelity based on the
value and quality of its services as realized by clients, and by periodically evaluating
alternative broker-dealers to recommend.
ii.
Adviser does not consider, in selecting or recommending custodial broker-dealers,
whether Adviser or a related person receives client referrals from a custodial broker-
dealer or third-party.
iii.
Adviser does not routinely recommend, request, or require that a client direct Adviser to
execute transactions through a specified custodial broker-dealer.
B. Adviser retains the ability to aggregate the purchase and sale of securities for clients’ accounts
with the goal of seeking more efficient execution and more consistent results across accounts.
Aggregated trading instructions will not be placed if it would result in increased administrative and
other costs, custodial burdens, or other disadvantages. If client trades are aggregated by Adviser,
such aggregation will be done so as to not to disadvantage any client and to treat all clients as
fairly and equally as possible.
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Date of Brochure: March 23, 2025
Item 13: Review of Accounts
A. Luke Turner and Jacob Turner, Adviser’s co-owners, monitor client accounts on an ongoing
basis, and typically reviews client accounts on at least an annual basis. Such reviews are
designed to ensure that the client is still on track to achieve his or her financial goals, and that
the investments remain appropriate given the client’s risk tolerance, investment objectives, major
life events, and other factors. Clients are encouraged to proactively reach out to Adviser to
discuss any changes to their personal or financial situation.
B. Other factors that may trigger a review include, but are not limited to, material developments in
market conditions, material geopolitical events, and changes to a client’s personal or financial
situation (the birth of a child, preparing for a home purchase, plans to attend higher education,
a job transition, impending retirement, death or disability among family members, etc.).
C. The custodial broker-dealer will send account statements and reports directly to clients no less
frequently than quarterly. Such statements and reports will be mailed to clients at their address of
record or delivered electronically, depending on the client’s election. If agreed to by Adviser and
client, Adviser or a third-party report provider will also send clients reports to assist them in
understanding their account positions and performance, as well as the progress toward achieving
financial goals.
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Item 14: Client Referrals and Other Compensation
A. Nobody other than clients provides an economic benefit to Adviser for providing
investment advice or other advisory services to clients. However, as described above in
Item 12, the custodial broker-dealer(s) recommended for client accounts provides certain
products and services that are intended to directly benefit Adviser, clients, or both.
B. Neither Adviser nor a related person directly or indirectly compensates a person who is
not Adviser’s supervised person for client referrals.
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Date of Brochure: March 23, 2025
Item 15: Custody
For clients that do not have their fees deducted directly from their account(s) and have not provided
Adviser with any standing letters of authorization to distribute funds from their account(s), Adviser will not
have any custody of client funds or securities. For clients that have their fees deducted directly from their
account(s) or that have provided Adviser with discretion as to amount and timing of disbursements
pursuant to a standing letter of authorization to disburse funds from their account(s), Adviser will typically
be deemed to have custody over such clients’ funds or securities pursuant to the SEC’s custody rule and
subsequent guidance thereto. With respect to Adviser’s standing letters of authorization that permit the
distribution of client funds to third parties, Adviser endeavors to comply with the SEC no-action letter to
the Investment Adviser Association dated February 21, 2017 in this regard. At no time will Adviser accept
full custody of client funds or securities in the capacity of a custodial broker-dealer, and at all times client
accounts will be held by a third-party qualified custodian as described in Item 12, above.
If a client receives account statements from both the custodial broker-dealer and Adviser or a third-party
report provider, client is urged to compare such account statements and advise Adviser of any
discrepancies between them.
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Date of Brochure: March 23, 2025
Item 16: Investment Discretion
Adviser accepts discretionary authority to manage securities accounts on behalf of clients only pursuant
the mutual written agreement of Adviser and the client through a limited power-of-attorney, which is
typically contained in the advisory agreement signed by Adviser and the client. Clients may place
reasonable limitations on this discretionary authority so long as it is contained in a written agreement
and/or limited power-of-attorney.
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Date of Brochure: March 23, 2025
Item 17: Voting Client Securities
A. Adviser does not have and will not accept authority to vote client securities.
B. Clients will receive their proxies or other solicitations directly from their custodial broker-dealer or
a transfer agent, as applicable, and should direct any inquiries regarding such proxies or other
solicitations directly to the sender.
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Date of Brochure: March 23, 2025
Item 18: Financial Information
A. Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months
or more in advance.
B. Adviser does not have discretionary authority or custody of client funds or securities, require or
solicit prepayment of more than $1,200 in fees per client, six months or more in advance.
Adviser has no financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients.
C. Adviser has not been the subject of a bankruptcy petition at any time during the past ten years.
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Date of Brochure: March 23, 2025