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Item 1 – Cover Page
Form ADV, Part 2A
Firm Brochure
THE FAIRMAN GROUP LLC
1200 Liberty Ridge Drive, Suite 320
Chesterbrook, PA 19087
Phone: 610-889-7300
Fax: 610-889-7326
www.fairmanfinancial.com
This brochure provides information about the qualifications and business
practices of The Fairman Group. If you have any questions about the
contents of this brochure, please contact us at: 610-899-7300, or by email
at: serviceteam@fairmanfinancial.com. 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.
The Fairman Group is a registered investment advisor. Registration of an
investment advisor does not imply any level of skill or training. The oral and
written communications of an advisor provide you with important information
for determining whether to hire or retain an advisor.
Additional information about The Fairman Group is available on the SEC’s
website at www.adviserinfo.sec.gov. You can search this site by a unique
identifying number, known as a CRD number. Our firm's CRD number is 121492.
This brochure was last updated on March 27, 2025
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The Fairman Group, LLC
Item 2 – Material Changes
This Firm Brochure is our disclosure document prepared according to the
SEC’s current requirements and rules. The Brochure provides you with a
summary of The Fairman Group’s services and fees, professionals, certain
business practices and policies, as well as actual or potential conflicts of
interest, among other things. This Item is used to provide our clients with a
summary of new and/or updated information; we will inform clients of any
revision(s) based on the nature of the information as follows:
- Annual Update: We are required to update certain information at least
annually, within 90 days of our firm’s fiscal year end (FYE) of December
31. We will provide you with either a summary of the revised information
with an offer to deliver the full revised Brochure within 120 days of our
FYE or we will provide you with our revised Brochure that will include a
summary of the changes in this Item.
- Material Changes: Should a material change in our operations occur,
depending on its nature, we will promptly communicate this change to
clients (and it will be summarized in this Item). “Material changes”
requiring prompt notification will include changes of ownership or control,
location, disciplinary proceedings, significant changes to our advisory
services or advisory affiliates – any information that is critical to a client’s
full understanding of who we are, how to find us, and how we do business.
Material Changes since the Last Update
None
Full Brochure Available
We will provide you with a new Brochure as necessary based on changes or
new information, at your request, at any time, without charge. Currently, our
Brochure may be requested by contacting our service team at 610-889-7300,
or by email to: serviceteam@fairmanfinancial.com.
The SEC’s website also provides information about any persons affiliated with
The Fairman Group who are registered, or are required to be registered, as
investment adviser representatives of The Fairman Group.
www.adviserinfo.sec.gov.
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The Fairman Group, LLC
Item 3 – Table of Contents
Item 1 – Cover Page ....................................................................................................... i
Item 2 – Material Changes ............................................................................................ ii
Material Changes since the Last Update ....................................................................ii
Full Brochure Available ...............................................................................................ii
Item 3 – Table of Contents .......................................................................................... iii
Item 4 – Advisory Business ......................................................................................... 1
Firm Description......................................................................................................... 1
Principal Owners........................................................................................................ 1
Types of Advisory Services ....................................................................................... 1
Tailored Relationships ............................................................................................... 4
Participation in Wrap Fee Programs .......................................................................... 4
Assets Under Management ....................................................................................... 4
Item 5 – Fees and Compensation ................................................................................ 4
Fees for Investment Advisory Services ...................................................................... 4
Fee Payment ............................................................................................................. 6
Fees for Financial Planning and Other Services ........................................................ 7
Other Fees ................................................................................................................. 7
Termination of Agreement ......................................................................................... 8
Product Related Compensation ................................................................................. 8
Item 6 – Performance-Based Fees ............................................................................... 8
Sharing of Capital Gains ............................................................................................ 8
Item 7 – Types of Clients .............................................................................................. 9
Description ................................................................................................................. 9
Account Minimums .................................................................................................... 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................. 9
Methods of Analysis ................................................................................................... 9
Investment Strategies .............................................................................................. 11
Risk of Loss ............................................................................................................. 11
Item 9 – Disciplinary Information ............................................................................... 13
Legal and Disciplinary .............................................................................................. 13
Item 10 – Other Financial Industry Activities and Affiliations ................................. 13
Financial Industry Activities ..................................................................................... 13
Affiliations ................................................................................................................ 13
Recommendation and Selection of Other Investment Advisors ............................... 14
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Item 11 – Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading ......................................................................................................... 14
Code of Ethics ......................................................................................................... 14
Participation or Interest in Client Transactions ........................................................ 15
Personal Trading ..................................................................................................... 15
Item 12 – Brokerage Practices ................................................................................... 15
Brokers and Custodians That We Use ..................................................................... 15
Soft Dollars .............................................................................................................. 19
Brokerage for Client Referrals ................................................................................. 19
Directed Brokerage and Order Aggregation ............................................................ 19
Item 13 – Review of Accounts .................................................................................... 19
Periodic Reviews ..................................................................................................... 19
Review Triggers ....................................................................................................... 20
Regular Reports....................................................................................................... 20
Item 14 – Client Referrals and Other Compensation ................................................ 20
Client Referrals ........................................................................................................ 20
Other Compensation ................................................................................................ 20
Item 15 – Custody ....................................................................................................... 21
Custody of Client Assets and Account Statements .................................................. 21
Item 16 – Investment Discretion ................................................................................ 22
Discretionary Authority for Trading .......................................................................... 22
Item 17 – Voting Client Securities.............................................................................. 23
Proxy Votes ............................................................................................................. 23
Item 18 – Financial Information ................................................................................. 23
Financial Condition .................................................................................................. 23
Other Items .................................................................................................................. 24
Business Continuity Plan ......................................................................................... 24
Information Security ................................................................................................. 24
Document Retention ................................................................................................ 24
Privacy Notice .......................................................................................................... 25
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The Fairman Group, LLC
Item 4 – Advisory Business
Firm Description
The Fairman Group LLC, (“The Fairman Group” or “TFG”) was founded in 2002 by
professionals from the Private Client Services Group of Arthur Andersen’s
Philadelphia office. We are 100% owned by Fairman Group Family Office LLP dba
Fairman Financial (“Fairman Financial”).
This brochure is provided to potential and existing clients (“Client” or “You”) to
provide an understanding of the services we provide, our potential conflicts of
interest and the qualifications of certain TFG personnel. Our clients include high
net worth individuals, families and their related trusts and business entities. For
certain accounts designated by clients as discretionary accounts in their
Investment Advisory Agreement, TFG will manage accounts on a discretionary
basis, while maintaining its customary quarterly and other communications with
clients and requests for client authorization prior to executing trades.
The Fairman Group is strictly a fee-only professional service firm. We do not sell
annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other
commissioned products. The firm is not affiliated with entities that sell financial
products or securities. We do not accept commissions or finder’s fees.
Through both The Fairman Group and Fairman Financial, we provide a variety of
services that we define collectively as comprehensive wealth management and tax
services. These services include investment advisory services, financial planning,
tax planning, tax return preparation and other accounting services.
We provide investment advisory and personal financial planning services to you
through individuals registered as investment advisor representatives of TFG. You
can learn more about the background and qualifications of our investment advisor
representatives in the Part 2B Supplement of this brochure.
We offer a free initial consultation for prospective clients. This meeting is generally
considered an exploratory interview to determine the extent to which our services
may be beneficial to the client.
Principal Owners
Marianne Coccia Inforzato is a 33 1/3% partner.
Shawn P. Kindt is a 33 1/3% partner.
Douglas E. Morisoli is a 33 1/3% partner.
Types of Advisory Services
The Fairman Group provides ongoing investment supervisory services for our
clients based on their individual needs. Additionally, we furnish advice on personal
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financial planning matters such as cash flow management, retirement planning, tax
planning, insurance analysis, education funding and estate planning.
Description of Investment Supervisory Services: We begin our process by
making sure we understand your investment goals, time horizon, liquidity needs,
asset class preferences and risk tolerance. We will examine how your current
investments fit in relation to your goals and discuss relevant investment concepts
such as historical performance of various asset classes and the fundamentals of
risk, return and diversification. We will typically model your future cash flow and
wealth accumulation to determine the sufficiency of assets to maintain your desired
standard of living. This model can also provide insights toward identifying a
required portfolio return and your financial ability to tolerate risk. A series of
meetings are often needed to thoroughly review and analyze your current and
projected financial situation. If you designated your account(s) as discretionary on
your Investment Advisory Agreement, we may exercise discretion over your
investment assets but will also communicate with you our recommendations and
seek authorization prior to executing any trades.
Asset Allocation Strategy: With an understanding of your financial situation, we
will help you identify an individualized, strategic asset allocation that is consistent
with your investment objectives, risk tolerance, time horizon, asset class
preferences and other criteria you may impose. At your direction, the allocation
strategy may encompass broad coordination of multiple accounts at multiple
custodians (i.e., developing a master asset allocation plan for multiple taxable
accounts and tax-advantaged retirement accounts such as your 401(k), 403(b) and
IRA plans) or a more narrow focus on asset allocation for specific accounts you
select to place under our supervision. Once the investment strategy is formulated,
we work with you to develop an investment policy statement, assist with
implementation with your selected custodian, make investment management
recommendations and provide ongoing review and reporting of the strategy. We do
not engage in market timing strategies.
Tax Specialization: Taxes play a significant role in your portfolio’s overall return
and are an important consideration in implementation and rebalancing decisions.
Unlike many advisors who avoid responsibility for tax planning, we bring extensive
experience in assessing the tax implications of investment decisions and can help
you maximize the after-tax return on your portfolio.
Custodian: We will identify and coordinate custodial/brokerage services.
However, we will not take actual custody of your investment assets. We generally
recommend Charles Schwab & Co., Inc. (“Schwab”) as a custodian for client
assets. We have no affiliation with Schwab, and you are under no obligation to
select them as your custodian.
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Using a custodian such as Schwab provides third-party reporting and valuation of
your assets. It allows us to help you implement a centralized investment program
that incorporates multiple money managers, mutual fund families and investment
styles at a competitive cost. This arrangement may also allow you to gain access
to money managers and mutual funds at lower account minimums or reduced fees
than generally are available to individual investors. Because we do not participate
in any fee sharing agreements, any savings pass directly to you.
For clients that choose to custody assets outside of Schwab, we utilize a custodial
aggregation service for valuation and reporting. This third-party service is provided
by Morningstar ByAllAccounts (“MBAA”), Inc. (see Valuation section below). MBAA
allows performance reporting on held-away accounts using client account login
credentials (username and password) without us taking possession of the
credentials. Clients opting to use the MBAA aggregation service maintain their
login credentials directly with MBAA. Some financial institutions allow for an API
connection to MBAA that enables the connection to be maintained without storing
client login credentials in MBAA.
Investment Management: We will assist you in selecting and monitoring
appropriate investment vehicles that are consistent with your chosen asset
allocation and investment policy. The decision to utilize a specific vehicle (i.e.,
separate account manager, mutual fund or exchange traded fund) is based on the
total dollar amount of the deployment, available selections within the asset class,
the overall costs (custody fees, annual management fees and transaction costs)
and client preferences. The primary purpose is to identify professional asset
management that is reasonably suited to represent each particular asset class
within the target asset allocation. We generally suggest both active and passive
(i.e., index) management styles. Any manager or fund suggestions we make are
subject to your selection preferences and final approval. You are under no
obligation to implement any recommendations that we provide.
Ongoing Supervision and Reporting: We will provide ongoing review and
reporting of the accounts you place under our supervision. The scope of our
periodic review and reporting may include but is not limited to:
• Comparison of the portfolio allocation to stated target for rebalancing
• Monitoring the performance of selected money managers or mutual funds
• Providing advice regarding the retention or dismissal of money managers or
mutual funds
• Arranging or effecting any purchase, sale or transfer related to any of our
recommendations accepted and approved for implementation by clients
• Comparisons of the portfolio against selected benchmarks
• Analysis of the estimated portfolio annual income and current yield
• Analysis of realized and unrealized gains and losses
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Tailored Relationships
As described above, our services are tailored to the unique needs and financial
situation of each client. We do not utilize standardized asset allocation models that
are generically mapped from responses to a risk questionnaire. We create
investment policy statements that reflect the mutually agreed upon goals,
objectives, and portfolio guidelines. Clients may impose restrictions on investing in
certain securities or types of securities.
Participation in Wrap Fee Programs
The Fairman Group does not sponsor or participate in any wrap fee programs.
Clients may choose to implement assets with wrap fee programs sponsored by
third parties such as Schwab, UBS, Merrill Lynch, etc. In a wrap fee program, it is
not uncommon for fees to be shared with advisors. As an independent advisor, we
do not receive any fees from wrap fee programs. If you choose to participate in a
wrap program, you should obtain and read the related disclosure information.
Assets Under Management
As of December 31, 2024, The Fairman Group managed approximately
$851,000,605 total assets for approximately 145 clients. Approximately
$496,150,160 was managed on a discretionary basis and $354,850,445 was
managed on a non-discretionary basis.
Item 5 – Fees and Compensation
Fees for Investment Advisory Services
Our fees for investment advisory services are determined on either an asset-based
fee or a fixed fee arrangement.
Asset-based Fees
Asset-based management fees are generally billed quarterly in advance of one
fourth of the annual rate based on a percentage of the client's assets under
management at the end of the calendar quarter. Fees are calculated as follows:
(Account value x Annual Fee %) ÷ 4 = Quarterly Fee
Current Fee Schedule
Fairman Group Investment Advisory Service fee schedule for asset-based fees:
Assets Under Management
First $2.0 million
Next $3.0 million
Next $5.0 million
Next $10.0 million
Over $20.0 million
Annual Fee %
1.00%
0.75%
0.50%
0.35%
0.25%
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Fixed Annual Fees
Fixed fee arrangements are generally determined using the table above as the
valuation guideline for an initial annual fee that is billed quarterly. We revisit this
fee amount with you on an annual basis to ensure the amount is equitable to all
parties with respect to services rendered and value received.
Minimum Annual Fee
TFG assesses a minimum annual fee of $15,000 to accounts receiving ongoing
investment advisory services. As a result, accounts with a small balance may pay
a higher annual fee than those normally charged by other investment advisors.
Lower fees for comparable services may be available from other sources.
Limited Exceptions to Current Fee Schedule/Fees Negotiable
Fees may vary from the applicable schedule above due to particular circumstances
of the client or as otherwise negotiated with particular clients. Factors we consider
when determining fees may include, but are not limited to, the following:
• Size of portfolio/assets under management
• Types of securities to be purchased, sold, or held within the portfolio
• The custodian used to hold your assets (assets held outside of our
recommended custodians typically increase our costs of doing business)
• The extent of additional services to be provided
• Certain family members of affiliated persons of the Fairman Group may receive
services at a discounted rate which is not available to advisory clients generally
• Historical fee schedules or negotiated annual fixed fee schedules may differ from
the asset-based fee schedule listed above (historical fee schedules/terms are not
available to new client relationships)
• In no event will asset-based fees be billed at a higher rate than the fee table
listed above
Effective Date
Investment advisory services begin with the effective date of the Agreement, which
is the date the client signs the Investment Advisory Agreement. For that calendar
quarter, fees will be adjusted pro rata based upon the number of calendar days in
the quarter that the Agreement was effective.
Valuation
We primarily use your custodian to price the securities in your investment
accounts. If Schwab is your custodian, we are able to interface with their system to
access daily valuation and transaction data. For accounts and investment positions
not held at Schwab, we rely on you to provide or authorize your custodian to send
us copies of your account statements for valuation and performance reporting. In
the event we are not timely provided with data, we will attempt to make a
reasonable estimate calculation based on your last provided statement share
holdings and current market price. For us to provide accurate reporting and billing,
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we rely on you to provide or authorize transmission of data for accounts not held at
our recommended custodian (currently Schwab).
For this purpose, we accept copies of your account statements forwarded by either
you or your custodian or electronic transmission of compatible data from your
custodian.
Clients may also authorize the use of a third-party data aggregation service to
electronically gather daily valuation data for their third-party online accounts.
Presently, we utilize the custodial aggregator service provided by MBAA, Inc.
(“MBAA”) for this purpose. MBAA stores client information in a secure data
warehouse at Amazon Web Services, which is SOC 1/SSAE 16/ISAE 3402
compliant. All risks must be documented, including the safeguards and procedures
for dealing with those risks. SOC compliance requires an audit by a third-party that
includes testing and monitoring. Participation in the MBAA aggregation service is
optional and extended to you at no additional cost. We do not receive any fees
from MBAA.
For billing purposes, the value of your account as of the last business day of the
previous quarter is used to determine the fees charged. The total portfolio value on
which fees are based may vary from the value on the custodian statement (the
valuation may be higher or lower) due to such factors as the timing and posting of
dividends, settlement dates for trades and accrued interest. Accordingly, we utilize
the value reflected in our portfolio accounting system which contains the most
timely information available to us.
All valuation information is based on sources that The Fairman Group believes to
be reliable. Clients should regularly consult their custodial account statements for
confirmation of balances and account activity. Clients should promptly notify The
Fairman Group when there are any material changes to their financial situation or
discrepancies in our reporting.
Fee Payment
If authorized, we will deduct your fees directly from your account on a quarterly
basis. If direct debiting is not selected, an invoice will be sent to you. We request
payment in full within 30 days of receipt. Fairman Financial clients may choose
direct debiting but may not authorize the writing of checks from checking accounts
to pay for advisory services.
In the event we collect our fee by debiting your custodial account, you will receive
an informational invoice setting forth the fee amount and the basis for the
calculation. Statements provided by your custodian will detail the total amount of
the fees that were deducted each quarter. You are responsible to verify the
accuracy of the fee calculation as the custodian will not determine whether the fee
has been properly calculated. Accordingly, you should review your account
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statement to compare your invoiced fee to the amount deducted. You may
terminate a fee-debiting arrangement at any time and we will bill you directly.
Fees for Financial Planning and Other Services
The Fairman Group provides investment advisory services and personal financial
planning services. Our related accounting firm, Fairman Financial, provides tax,
accounting, and bookkeeping services. For Fairman Group clients who utilize the
check writing services of Fairman Financial, an independent accountant will verify
client checking account assets on at least an annual basis.
Fees for any separate financial planning and other accounting services are based
on an hourly fee or fixed fee arrangement. Hourly charges will vary depending
upon the nature of the work and the professional level of our personnel required. In
this regard, hourly charges for our professional staff will generally range from $100
to $685 per hour. We reserve the right to provide services on a fixed fee basis in
lieu of an hourly fee. The fixed fee will be negotiated with the client prior to
performing any service. A separate fee will not be charged for investment advice
that is incidental to providing tax and financial planning services.
As described under Item 10, tax, accounting, and other non-investment advisory
related services are rendered by Fairman Financial.
Other Fees
Mutual Fund Fees: Our advisory fees are separate and distinct from fees and
expenses charged by mutual funds that may be recommended to you. These fees
will generally include a management fee, other fund expenses and a possible
distribution fee. A description of these fees and expenses is contained in each
fund's prospectus. We encourage you to read each fund prospectus carefully. The
custodian or fund sponsor will send a prospectus when trades are placed or upon
request. Clients are obligated to notify us if they do not receive a prospectus.
Separate Account Manager Fees: Our fees are also separate and distinct from
the advisory fee charged by any Separate Account Managers that may be
recommended to you. Such managers may be contracted by you directly or as part
of a third-party wrap fee program.
Brokerage, Custodial and Miscellaneous Fees: Your selected broker, custodian
or other financial institution may charge transactional, custody or other
miscellaneous fees. Please refer to the disclosure documents provided by your
selected broker or custodian. As part of our ongoing supervisory service, we strive
to assist you in identifying and evaluating your overall investment fees and helping
identify opportunities to reduce costs. However, there may be lower cost
alternatives available in the marketplace.
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The Fairman Group, LLC
Margin Fees: To the extent that a client authorizes the use of margin, and margin
is thereafter employed in the client’s portfolio, the market value of the client’s
account and corresponding fee payable by the client to TFG may be increased. As
a result, in addition to understanding and assuming the additional principal risks
associated with the use of margin, clients authorizing margin are advised of the
potential conflict of interest whereby the client’s decision to employ margin may
correspondingly increase the management fee payable to the TFG. Accordingly,
the decision to employ margin is left to the sole discretion of client.
Termination of Agreement
All advisory agreements can be terminated by either party at any time upon thirty
(30) days written notice.
The client is responsible to pay for services rendered until the termination of the
agreement. The client can cancel the Agreement without penalty within the first
five days after the signing of the Agreement.
Upon termination, you will receive a refund of any prepaid and unearned advisory
fees prorated for the balance of the quarter. If investment advisory services have
been provided, fees are therefore due and payable, and you will receive an invoice
with the amount due. Any transactional or custodial charges levied by your
custodian after the termination of the advisory agreement are your responsibility.
We have no obligation to refund fees charged by your custodian to you.
Product Related Compensation
We do not sell products, earn commissions, or participate in any type of revenue
sharing. The only fees we earn are the direct fees paid by our clients.
We generally recommend only no-load or load-waived mutual funds. Some mutual
funds may impose an initial or deferred sales charge. You may own some of these
funds when you transition your account to us. In addition, our fees do not include
any applicable transaction fees, commissions or other management fees charged
by money managers recommended to you.
You are under no obligation to purchase any investment product or service that we
recommend to you.
Item 6 – Performance-Based Fees
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of
managed securities. The Fairman Group does not offer a performance-based fee
structure because of the potential conflict of interest. Performance-based
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compensation may create an incentive for the advisor to recommend an
investment that may carry a higher degree of risk than is suitable for the client.
Item 7 – Types of Clients
Description
The Fairman Group primarily provides investment advice to individuals. We may
also provide advice to entities related to our individual clients such as trusts,
estates, charitable funds, or business entities.
Account Minimums
We generally require a minimum account size of $1,500,000 of investable assets
to be placed under our supervision. We have discretion to waive the account
minimum. Accounts that do not meet the account minimum may be set up when
the client anticipates adding additional funds to the accounts to meet the
$1,500,000 within a reasonable time. As noted under Fees above, our minimum
advisory fee is $15,000. Other exceptions will apply to our personnel, their
relatives, and relatives of existing clients.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Our process is designed to help you articulate and quantify goals, organize
financial data, identify needs and opportunities, and evaluate alternative courses of
action. It includes an analysis of current net worth, income taxes, cash flow,
investments, employee benefits, insurance, and estate planning needs. Analysis is
primarily based on Modern Portfolio Theory, academic and industry research that
focuses on structuring portfolio assets to achieve your financial objectives in
consideration of your risk tolerance.
We design custom asset allocation plans using mean variance optimization
analysis software from Morningstar, Inc. This tool allows us to research, create and
analyze optimal asset allocation strategies tailored to your unique return
requirement, asset class preferences and risk tolerance. We utilize forward looking
long-term capital market assumptions that are constructed by Callan Associates
Inc. (more details on the formulation of these assumptions can be found at
https://www.callan.com/capital-markets-assumptions/).
We are a member of Callan Associates Inc.'s (“Callan”) Independent Advisor
Group (“IAG”). Callan is one of the largest investment consulting firms in the United
States, providing research, due diligence, education, decision support, and advice
to institutional investors. Through its relationship with Callan's IAG division, we
have access to the research resources of one of the world's largest investment
consulting firms.
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The Fairman Group, LLC
To help you implement your asset allocation plan we consider a wide universe of
investment vehicles primarily consisting of mutual funds, exchange traded funds
(“ETF”s) and separate account money managers. Research indicates that the
primary determinant of your portfolio return is the result of your asset class
composition. Accordingly, a major focus of our analysis is to identify vehicles
reasonably suited to represent a desired asset class within the portfolio.
With respect to mutual funds and ETFs, we will identify categories of funds that are
compatible with your investment objectives, risk tolerance and other client criteria.
We utilize internal processes and procedures to identify a search list of selected
mutual funds and ETFs. We utilize information obtained from rating and research
providers (e.g., Morningstar, Callan, YCharts, etc.), business publications, fund
prospectuses and other sources. As a general matter, the funds included in the
search lists will be based upon the following factors: performance relative to peers
and indices, risk, cost efficiency, style consistency, manager tenure, fund size and
tax efficiency.
For separate account money managers, we select and recommend managers
based on factors that may include, but are not limited to, analysis of management,
investment philosophy, investment style, historical performance, historical risk
relationships, modern portfolio approaches and other factors with the client's
investment objectives, risk tolerance and other client criteria.
For money manager research and due diligence, we primarily utilize managers that
have been screened through Callan's due diligence process, Schwab's Managed
Account Select Program, and our own internal due diligence.
Schwab’s “Managed Account Select” program is Schwab’s wrap fee program that
enables you to choose institutional quality money managers that have been
prescreened and researched by the Charles Schwab Investment Advisory, Inc.
Charles Schwab Investment Advisory, Inc. (“CSIA”) provides the analysis and
insight behind the core investment research at Charles Schwab & Co., Inc. Its
research is responsible for many Schwab research products, such as Schwab
Equity Ratings®, Schwab Industry Ratings and the Schwab Mutual Fund
OneSource® Select List.
Money managers are evaluated and monitored no less than quarterly for the
Managed Account Select program by a team of investment professionals within
CSIA who specialize in investment manager research. This team also chooses
mutual funds for Schwab’s Mutual Fund OneSource Select List®. For more
detailed information, refer to Schwab’s disclosure brochure entitled Schwab
Managed Account Services for Clients of Independent Investment Advisors.
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The Fairman Group, LLC
Investment Strategies
Our primary investment strategy is founded on building a strategic asset allocation
that is tailored to the unique needs, risk tolerance and financial situation of each
client. Asset allocation is the process of dividing a portfolio among broad
investment market categories called asset classes. This emphasis on asset
allocation is based on research that indicates asset allocation policy is the primary
determinant of your aggregate portfolio return.
We work individually with each client to model various asset allocation possibilities
to help them identify the allocation mix that best balances their expected return
needs with their willingness and ability to tolerate risk.
The portfolio allocation is generally implemented with passively managed core
investments and actively managed investments that meet our screening policies
described above. Portfolios are also diversified within each of the major traditional
asset classes to reduce risk.
We may also use alternative assets to improve the risk-return characteristics and
diversification of a portfolio. The strategies used generally focus on specific
themes: low correlation to traditional assets, reduced beta, and inflation protection.
These strategies are primarily implemented using mutual funds. Where
appropriate, clients may also opt for an allocation to less liquid investments to seek
potential return enhancement in private equity and private credit funds. Total
portfolio allocations to alternative assets range from 0-25% based on client
suitability and comfort with specific strategies or alternative assets in general.
Individuals typically face long-term yet multi-staged time horizons (accumulation,
distribution, and transfer to future generations). Accordingly, we assist clients over
this dynamic horizon with the process of monitoring and rebalancing their portfolio
to stated allocation targets for the purpose of controlling risk.
The risks associated with our asset allocation strategy include the following:
• Future market results may differ from those expected in the allocation model
• The relationship of underlying economic assumptions may change over time
• Asset allocation may not result in a profit or prevent loss
• Behavioral dynamics can lead investors to abandon an allocation strategy when
the strategy may be most beneficial
Risk of Loss
Investing in securities involves risk, including possible loss of principal, that clients
should be prepared to bear. Investors generally face the following investment risks:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices
to fluctuate. For example, when interest rates rise, yields on existing bonds
become less attractive, causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in
reaction to tangible and intangible events and conditions. This type of risk is
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The Fairman Group, LLC
caused by external factors independent of a security’s particular underlying
circumstances. For example, political, economic, and social conditions may
trigger market events.
• Correlation risk: Correlation risk is the risk that two assets will not move up or
down in value as predicted. Correlation between stock price movements can
also compound uncertainties. News pertaining to some stocks can trigger
fluctuations in other stocks with a high correlation.
•
Inflation Risk: When any type of inflation is present, a dollar today will not buy
as much as a dollar next year, because purchasing power is eroding at the
rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value
of the dollar against the currency of the investment’s originating country. This
is also referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments
may have to be reinvested at a potentially lower rate of return (i.e., interest
rate). This primarily relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a
particular company within an industry. For example, oil-drilling companies
depend on finding oil and then refining it, a lengthy process, before they can
generate a profit. They carry a higher risk of profitability than an electric
company, which generates its income from a steady stream of customers who
buy electricity no matter what the economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into
cash. Generally, assets are more liquid if many traders are interested in a
standardized product. For example, Treasury Bills are highly liquid, while real
estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations
increases the risk of profitability, because the company must meet the terms
of its obligations in good times and bad. During periods of financial stress, the
inability to meet loan obligations may result in bankruptcy and/or a declining
market value.
• Margin Risk: Margin transactions are securities transactions in which an
investor borrows money to purchase a security, and the security serves as
collateral on the loan. If the value of the shares drops sufficiently, the investor
may be required to either deposit more cash into the account or sell a portion
of the stock in order to maintain the margin requirements of the account. This
is known as a “margin call.” An investor’s overall risk includes the amount of
money invested plus the amount that was loaned to them.
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Item 9 – Disciplinary Information
Legal and Disciplinary
We are required to disclose any legal or disciplinary event that is material to a
client’s (or prospective client’s) evaluation of the integrity of the advisor or its
management personnel.
- TFG has no disclosure information applicable to this item.
Item 10 – Other Financial Industry Activities and Affiliations
Financial Industry Activities
Due to the potential conflicts of interest that may arise in certain financial industry
activities, we are required to disclose if our firm or any of our management
personnel are registered or have an application pending to register as any of the
following:
- broker-dealer or registered representative of a broker-dealer
- futures commission merchant
- commodity pool operator
- commodity trading advisor
- or an associated person with the foregoing entities
The Fairman Group and its management personnel are not registered (and do not
have any applications pending) for any of the above activities. We have no
intention to register in the future.
Affiliations
Due to the potential conflicts of interest which may impair the objectivity of
investment advice rendered, we are required to disclose if we have any
arrangements that are material to our advisory business or its clients with a related
person who is a:
- broker-dealer, municipal securities dealer or government securities dealer or
broker
- investment company or other pooled investment vehicle
- other investment advisor
- financial planning firm
- commodity pool operator, commodity trading advisor or futures commission
merchant
- banking or thrift institution
- law firm, insurance company or agency
- pension consultant, real estate broker or dealer
- or an entity that creates or packages limited partnerships.
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The Fairman Group, LLC
The firm and its management personnel are not affiliated with and do not have
financial arrangements related to any of the entities and activities listed above.
As of March 31, 2012, we formally segregated our investment advisory business
from our accounting practice by separating the accounting practice into a separate
entity.
This separate entity, Fairman Group Family Office LLP dba Fairman Financial, is
owned by its partners as set forth in Item 4 and is the 100% owner of our
investment advisory business entity, The Fairman Group LLC. As a result, our tax,
accounting, and other noninvestment advisory related services are rendered by
Fairman Financial.
This reorganizational change separated our service lines for compliance and
supervisory purposes. There were no other changes to our business practices or
fee arrangements. Both entities remain 100% fee-only and are not affiliated with
any other product or service providers. Accordingly, we do not believe this change
created any material conflict of interest for our clients.
Recommendation and Selection of Other Investment Advisors
We may recommend or select other investment advisors for our clients. However,
we do not receive compensation from those advisors. We do not have any
relationships with other advisors that would create a material conflict of interest.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics
The Fairman Group has adopted a written Code of Ethics as required under Rule
204A-1 of the Investment Advisers Act of 1940. This code was developed to
provide formal ethical guidelines regarding our duties to our clients. It also
establishes standards of professional conduct and personal trading policies. A
copy of our Code of Ethics may be requested by contacting us at 610-889-7300.
Our Code of Ethics and Compliance Manual requires all personnel of The Fairman
Group and Fairman Financial to:
• Act with integrity, competence, diligence, respect, and in an ethical manner with
the public, clients, prospective clients, employers, employees, colleagues in the
investment profession, and other participants in the global capital markets;
• Place the integrity of the investment profession, the interest of clients, and the
interests of the employer above one’s own personal interests;
• Adhere to the fundamental standard that you should not take inappropriate
advantage of your position;
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The Fairman Group, LLC
• Avoid any actual or potential conflicts of interest;
• Conduct all personal securities transactions consistent with our Personal Trading
Policy;
• Use reasonable care and exercise independent professional judgment when
conducting investment analysis, making investment recommendations, taking
investment actions, and engaging in other professional activities;
• Practice and encourage others to practice in a professional and ethical manner
that will reflect credit on yourself and the profession;
• Promote the integrity of, and uphold the rules governing, capital markets;
• Maintain and improve professional competence and strive to maintain and
improve the competence of other investment professionals;
• Comply with applicable provisions of the Federal securities laws.
Participation or Interest in Client Transactions
We do not possess a financial interest in the securities that are recommended to
clients. We do not receive commissions, distribution fees, mark-ups or other
compensation for transactions in the securities that we may recommend.
Personal Trading
We may own, buy and sell for our own personal accounts the same securities that
may be recommended to clients. These transactions are unlikely to result in a
conflict of interest as the transactions typically involve mutual funds or ETFs that
are widely held and publicly traded. Additionally, such transactions are not of a
size to impact the securities markets. If the possibility of a conflict of interest
occurs, the client's interest will prevail. It is our policy that priority will always be
given to the client's orders over the orders of our own personnel.
Our personnel are required to comply with the provisions of The Fairman Group
Compliance Manual. These provisions require pre-clearance authorization by the
Managing Partner and/or the Compliance Officer for certain individual securities
trading. TFG requires all personnel to report, at least quarterly, all security
transactions made during the quarter and an annual statement of current beneficial
investment holdings to the Compliance Officer.
Item 12 – Brokerage Practices
Brokers and Custodians That We Use
The Fairman Group does not maintain custody of your assets on which we advise,
although we may be deemed to have custody of your assets if you give us
authority to withdraw assets from your account or if you utilize the check writing
services of Fairman Financial (see Item 15 – Custody, below). Your assets must
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The Fairman Group, LLC
be maintained in an account at a “qualified custodian,” generally a broker-dealer or
bank. We recommend that Fairman Group clients use Charles Schwab & Co., Inc.,
a registered broker-dealer, member SIPC, as the qualified custodian. We are
independently owned and operated and are not affiliated with Schwab. Schwab will
hold your assets in a brokerage account and buy and sell securities when
instructed. While we recommend that you use Schwab as custodian/broker, you
will decide whether to do so and will open your account with Schwab by entering
into an account agreement directly with them. We do not open an account for you,
although we may assist you in doing so. Even though an account is maintained at
Schwab, we can still use other brokers to execute trades for your account as
described below (see “Your Brokerage and Custody Costs”).
Selection of Brokers/Custodians and Best Trade Execution
We seek to recommend a custodian/broker who will hold your assets and execute
transactions on terms that are, overall, most advantageous when compared to
other available providers and their services. Best trade execution practices include
gathering relevant information, monitoring trading activities and periodically
reviewing and evaluating the services provided by broker/dealers, research,
commission rates, and overall relationships as well as the best overall qualitative
execution. Costs are important in trading, we also consider a wide range of factors,
including, among others:
• Combination of transaction execution services and asset custody services
(generally without a separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your
account)
• Capability to facilitate transfers and payments to and from accounts (wire
transfers, check requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds,
exchange-traded funds [ETFs], etc.)
• Availability of investment research and tools that assist us in making investment
decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest
rates, other fees, etc.) and willingness to negotiate the prices
• Reputation, financial strength, and stability
• Prior service to us and our other clients
• Availability of other products and services that benefit us, as discussed below
(see “Research, Products, and Services Available to Us”)
Your Brokerage and Custody Costs
For our clients’ accounts that Schwab maintains, Schwab generally does not
charge you separately for custody services but is compensated by charging you
commissions or other fees on trades that it executes or that settle into your
Schwab account. Certain trades (for example, many mutual funds and ETFs) may
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The Fairman Group, LLC
not incur Schwab commissions or transaction fees. Schwab is also compensated
by earning interest on the uninvested cash in your account in Schwab’s Cash
Features Program. For some accounts, Schwab charges a percentage of the dollar
amount of assets in the account in lieu of commissions. Schwab’s commission
rates and asset-based fees applicable to our client accounts were negotiated
between The Fairman Group and Schwab. This benefits you because the overall
commission rates you pay are lower than they would be otherwise.
In addition to commissions and asset-based fees, Schwab charges a flat dollar
amount as a “prime broker” or “trade away” fee for each trade that is executed by a
different broker-dealer but where the securities bought or the funds from the
securities sold are deposited (settled) into your Schwab account. These fees are in
addition to the commissions or other compensation you pay the executing broker-
dealer. Because of this, in order to minimize your trading costs, it may be beneficial
to have Schwab execute most trades for your account. We have determined that
having Schwab execute most trades is consistent with our duty to seek “best
execution” of your trades, with a blend of execution services, commission costs
and professionalism that will assist TFG in meeting our fiduciary obligations. Best
execution means the most favorable terms for a transaction based on all relevant
factors, including those listed above (see “How We Select Brokers/Custodians”).
By using another broker or dealer you may pay lower transaction costs.
Research, Products, and Services Available to Us
TFG receives unsolicited research (broker-created or developed by a third-party) to
aid us in investment decision-making. Receipt of these unsolicited reports is not
contingent upon any level of brokerage business and TFG has not entered into any
contract or agreement concerning these reports. TFG does not receive any
research or products or services from any broker-dealer or third-party in
connection with client securities transactions (“soft dollar benefits”).
Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s
business serving independent investment advisory firms like us. They provide us
and our clients with access to its institutional brokerage—trading, custody,
reporting, and related services—many of which are not typically available to
Schwab retail customers. However, certain retail investors may be able to get
institutional brokerage services from Schwab without going through us. Schwab
also makes available various support services. Some of those services help us
manage or administer our clients’ accounts, while others help us manage and grow
our business. Schwab’s support services generally are available on an unsolicited
basis (we do not have to request them) and at no charge to us. Following is a more
detailed description of Schwab’s support services:
Services That Benefit You
Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of client
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The Fairman Group, LLC
assets. The investment products available through Schwab include some to which
we might not otherwise have access or that would require a significantly higher
minimum initial investment by our clients. Schwab’s services described in this
paragraph generally benefit you and your account.
Services That May Not Directly Benefit You
Schwab also makes 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 and operating our firm.
They include investment research, both Schwab’s own and that of third parties. We
may use this research to service all or a substantial number of our clients’
accounts, including accounts not maintained at Schwab. In addition to investment
research, Schwab also makes available software and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and
account statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
Services That Generally Benefit Only Us
Schwab also offers other services intended to help us manage and further develop
our business enterprise. These services include:
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance
providers
Schwab may provide some of these services itself. In other cases, it will arrange
for third-party vendors to provide the services to us. Schwab may also discount or
waive its fees for some of these services or pay all or a part of a third-party’s fees.
Schwab may also provide us with other benefits, such as occasional business
entertainment for our personnel. If you did not maintain your account with Schwab,
we would be required to pay for these services from our own resources.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have
to produce or purchase them. We do not have to pay for Schwab’s services. These
services are not contingent upon us committing any specific amount of business to
Schwab in trading commissions or assets in custody. We may have an incentive to
recommend that you maintain your account with Schwab, based on our interest in
receiving Schwab’s services that benefit our business rather than based on your
interest in receiving the best value in custody services and the most favorable
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The Fairman Group, LLC
execution of your transactions. This is a potential conflict of interest. We believe,
however, that our selection of Schwab as custodian and broker is in the best
interests of our clients. Our selection is primarily supported by the scope, quality,
and price of Schwab’s services (see “How We Select Brokers/Custodians”) and not
Schwab’s services that benefit only us.
Soft Dollars
The term ‘soft dollar arrangement’ describes a brokerage practice in which
investment advisors use client brokerage commissions to pay for goods or
services. This practice can create a conflict of interest when an incentive exists to
select a broker-dealer based on an advisor’s interest in receiving the research or
product, rather than on best trade execution for the client.
- TFG has no soft-dollar arrangements.
Brokerage for Client Referrals
We do not pay for client referrals, and we do not participate in any sponsored
referral program. Schwab offers such a program where advisors can pay them for
referrals. To avoid potential conflict of interest, we have opted not to participate in
Schwab’s advisor referral program and have no intentions to participate in the
future.
Directed Brokerage and Order Aggregation
The Fairman Group does not have discretion in the selection of broker-dealers. For
operational and other efficiencies, we recommend that clients use Schwab for
brokerage and custody services. Separate Account Managers directing trades of
individual securities are responsible for aggregation, allocation of trades and block
trading. The Fairman Group may assist clients with trade execution of mutual
funds, ETFs and other securities. In any accounts for which the Fairman Group
has discretionary authority, TFG does not combine multiple orders for shares of the
same securities (commonly referred to as “block trading”) or aggregate trades as it
would not garner any material client benefit for such transactions.
Clients may direct us to assist them with execution of trades at their selected
broker-dealers. In this event, clients may pay higher transaction costs and may not
receive certain benefits afforded to transactions executed at Schwab.
Item 13 – Review of Accounts
Periodic Reviews
All client accounts are reviewed regularly and at least quarterly by a Partner or
Manager investment adviser representative. Changes may be recommended for a
client's asset allocation or the decision to retain or dismiss a money manager,
mutual fund or ETF. Account reviews are performed by:
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Douglas E. Morisoli, Partner
Andrew R. Green, Senior Manager
Marianne Inforzato, Partner
Patrick R. Gorgonzola, Senior Manager
Shawn P. Kindt, Managing Partner
Kelley R. Taylor, Senior Manager
Review Triggers
Management of accounts is continuous so review may also be undertaken due to
certain triggers internal or external to a client’s account(s). Factors triggering
reviews or recommendations include changes in the client's situation, changes in
market conditions, deposits or withdrawals of funds and changes in status of a
manager, mutual fund or ETF held in an account.
Other conditions that may trigger a review are changes in the tax laws, new
investment information, and changes in a client's own situation.
Regular Reports
Clients are provided account statements directly from each respective custodian/
broker-dealer on a monthly or quarterly basis. TFG prepares reports as agreed
upon with each client. We generally prepare a quarterly report detailing and
comparing:
• Current allocation against the stated target allocation
• Actual performance of the portfolio against benchmarks
• Actual performance of money managers and mutual funds against indices and
peers
Item 14 – Client Referrals and Other Compensation
Client Referrals
The Fairman Group does not engage solicitors or promoters and does not pay for
referrals of potential clients to our firm. Pursuant to our Code of Ethics, we do not
accept or allow our personnel to accept any form of compensation, including cash,
awards, or other prizes, from a non-client in conjunction with the advisory services
we provide to our clients.
Other Compensation
We receive an economic benefit from Schwab in the form of the support products
and services it makes available to us and other independent investment advisors
whose clients maintain their accounts at Schwab. You do not pay more for assets
maintained at Schwab as a result of these arrangements. These products and
services, how they benefit us, and the related conflicts of interest are described
above (see Item 12 – Brokerage Practices). The availability to us of Schwab’s
products and services is not contingent upon TFG giving particular investment
advice, such as buying particular securities for our clients.
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The Fairman Group, LLC
Item 15 – Custody
Custody of Client Assets and Account Statements
All client assets are held by qualified custodians; the Fairman Group does not take
actual custody of client assets. However, The Fairman Group may be deemed by
regulators to have custody of client assets through the debiting of advisory fees,
utilization of check writing services of Fairman Financial, or because clients have
granted general powers of attorney or other authority over their accounts to
persons affiliated with The Fairman Group.
As disclosed in the ‘Fees and Compensation’ section (Item 5), you have the option
to authorize your custodian to debit our advisory fees directly from your accounts.
If you elect this fee payment method, under government regulations, we are
deemed to have custody of your assets. However, your custodian maintains actual
custody of your assets.
As part of our billing process, we advise the custodian of the amount of the fee to
be deducted from each client account. You will receive an account statement
directly from your custodian at least quarterly. These statements will be sent to the
address you provided to your custodian (or to your email address if you opted for
electronic delivery). You should carefully review your custodial statements
promptly to verify their accuracy including any fee withdrawals.
We also urge you to compare the account statements you receive from your
custodian with any performance reports, net worth statements or other reports that
you receive from us.
In addition, as disclosed in Item 5 above, to the extent clients of The Fairman
Group also utilize the check writing services of Fairman Financial, regulators deem
The Fairman Group to have custody of the assets maintained in the checking
accounts. The bank/custodian maintains actual custody of such checking account
assets and will submit regular account statements directly to the client. Fairman
Group Financial does not have check writing authority to debit checking accounts
for advisory fees.
Finally, when an investment advisor representative of The Fairman Group acts as
a trustee for client trusts, an executor of a client estate, or exercises a General
Power of Attorney over client accounts, The Fairman Group is deemed to have
custody of client assets in those accounts.
As a protection for clients whose assets are deemed to be under the custody of
The Fairman Group, Rule 206(4)-2 of the Investment Advisers Act of 1940 requires
the firm to be subject to an annual surprise examination by a qualified accounting
firm. On at least an annual basis, an independent PCAOB accountant, Fischer
Cunnane & Associates Ltd, performs a surprise examination to inspect and verify
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The Fairman Group, LLC
the assets in accounts over which The Fairman Group is deemed to have custody.
The Accountant Surprise Examination Report is then filed with the SEC. The most
recent report was filed on August 28, 2024, and is available upon request.
As always, you should contact us directly if you believe that there may be an error
in any statements or reports.
Standing Letters of Authorization
When The Fairman Group has written authorization from the client, The
Fairman Group may effect money transfers from a client's account to one or
more third-parties designated by the client without obtaining consent for
each individual transaction. This written authorization is commonly referred
to as a Standing Letter of Authorization (“SLOA”). An adviser with the
authority to conduct such transfers is deemed to have custody over the
client's assets in the related accounts. The Fairman Group is not required to
undergo a surprise annual audit, which is otherwise necessary for custody,
as long as we meet the following conditions:
1. You provide signed written instructions to your qualified custodian (typically,
Schwab) including the third party’s name, the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
2. You authorize us in writing to direct transfers to the third party either on a
specific schedule or from time to time.
3. Your qualified custodian confirms your authorization (e.g., by reviewing the
signature or other verification method) and provides a transfer of funds notice to
you promptly after each transfer.
4. You can terminate or change the instruction to your custodian.
5. The Fairman Group has no authority or ability to change the identity of the third
party, the address, or any other information about the third party.
6. The Fairman Group maintains records showing that the third party is not related
to us and is not located at the same address as us.
7. Your qualified custodian sends you a written initial notice confirming the
instruction and a written annual notice reconfirming the instruction.
We confirm that The Fairman Group works with your qualified custodian to
meet all the above conditions.
Item 16 – Investment Discretion
Discretionary Authority for Trading
The Fairman Group has discretionary authority only over those client accounts
specifically designated as discretionary accounts in the Investment Advisory
Agreement. TFG intends to continue its practice of consulting the Client and
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The Fairman Group, LLC
obtaining written authorization prior to executing any trades in accounts designated
as discretionary. TFG may select the identity and amount of securities to be bought
or sold, in a manner consistent with the written investment objectives and any
written investment restrictions for the particular client account.
In all non-discretionary accounts, as part of our supervisory responsibility, we help
you arrange or effect purchases, sales or transfers with your custodian/broker or
other financial institution. All transactions must be authorized by you. In the event
transactions must be authorized by you with a signed Letter of Authorization
(LOA), we may assist you in the preparation of such LOAs and deliver them for
execution with your custodian/broker or other financial institution.
Item 17 – Voting Client Securities
Proxy Votes
The Fairman Group does not vote proxies on behalf of our clients. Therefore,
although we may provide investment advisory services relative to your investment
assets, you maintain exclusive responsibility for directing the manner in which
proxies are voted and responding to all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other types of events
pertaining to your investment assets. You should instruct each of your custodians
to forward to you copies of all proxies and shareholder communications relating to
your investment assets. If any separate account money managers are engaged for
your portfolio, they will have their own proxy voting policy which will be discussed
in their Form ADV disclosure.
Item 18 – Financial Information
Financial Condition
The Fairman Group does not have any financial impairment that will preclude the
firm from meeting contractual commitments to clients.
A balance sheet is not required to be provided because The Fairman Group does
not serve as a custodian for client funds or securities and does not require
prepayment of fees of more than $1,200 per client, and six months or more in
advance.
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The Fairman Group, LLC
Other Items
Business Continuity Plan
General
The Fairman Group has a Business Continuity Plan under Fairman Financial that
provides detailed steps to mitigate and recover from the loss of office space,
power, communications, services, and key personnel.
Disasters
The Business Continuity Plan covers natural disasters such as snowstorms,
hurricanes, and flooding. The plan also covers other disasters such as loss of
electrical power, water damage, fire, bomb threat, telecommunications outage,
internet outage, or other disruptive incident. Electronic files are backed up daily
and archived offsite.
Alternate Offices
Alternate work sites would be used to support ongoing operations in the event the
main office is unavailable. It is our intention to contact all clients within five days in
the event of a circumstance that dictates moving our office to an alternate location.
With respect to data recovery, all electronic files are backed up daily to a secure
offsite location.
Information Security
Fairman Financial maintains an information security program to reduce the risk that
personal and confidential information may be breached. This program, which is
also applicable to Fairman Group, employs firewalls, secure data encryption
techniques and authentication procedures in our computer environment.
Document Retention
The Fairman Group and Fairman Financial will maintain all client documentation
for the required period that records are required to be maintained by federal and
state authorities. After that time, information may be destroyed.
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The Fairman Group, LLC
Privacy Notice
Fairman Financial respects our clients’ privacy and treats their privacy
concerns seriously. As a trusted advisor to our clients, respecting privacy
and confidentiality is vital to our business.
This notice describes the current privacy policy and practices of both
Fairman Group Family Office LLP dba Fairman Financial and its wholly
owned registered investment advisory firm, The Fairman Group LLC
(collectively, “Fairman Financial”), with respect to information we acquire
about individuals who obtain or seek to obtain Fairman Financial’s
assistance for personal, family or business purposes.
Information We Collect About You
We collect nonpublic personal information about you from:
Information we receive from you, including financial, investment and tax-
related information;
Information we receive from you about business holdings, real estate and
other entities or enterprises in which you may hold an interest;
Information we receive with your authorization from third parties, such as
your other advisers and financial institutions where you have accounts;
and
Information relating to your transactions with us, our affiliates and others.
This information may include personal information such as your address,
social security number and bank and other financial account numbers.
How We Handle Your Personal Information
We use your nonpublic personal information solely for the purpose of
providing tax consulting, compliance and other professional advisory
services to you. We take reasonable steps to keep confidential the
information acquired. Our right to disclose the information is limited by our
Code of Ethics, Regulation S-P (or other applicable regulations) and the
Certified Financial Planner Board of Standards, Inc. (CFP Board). Fairman
Financial does not disclose any nonpublic personal information about you,
as our client or as a former client, to anyone without your permission, except
as permitted or required by law. Where appropriate, information provided by
us to nonaffiliated third parties who perform services for us, is subject to
contractual agreements which prohibit these parties from disclosing or using
the information other than for the purposes for which the information was
disclosed.
General Restrictions on Disclosure of Nonpublic Personal Information
to Nonaffiliated Third Parties
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The Fairman Group, LLC
As tax preparers, we are prohibited by Internal Revenue Code Section 7216
from disclosing your income tax return information without your consent,
other than for the specific purpose of preparing, assisting in preparing or
obtaining and providing services in connection with the preparation of an
income tax return for you. Furthermore, as a firm complying with Regulation
S-P and engaged in income tax preparation or financial planning and
investment advice, we are generally prohibited from disclosing confidential
client information about you to nonaffiliated third parties without your
specific consent, other than for the purposes for which the information was
disclosed to us.
Some of the Reasons We May Disclose Information to Third Parties
Include:
Initiating a complaint or responding to an inquiry made by the professional
ethics division or trial board of the AICPA or duly constituted investigative
or disciplinary body of another State CPA Society or Board of
Accountancy.
A review of a professional practice of our firm in conjunction with a
prospective purchase, sale, or merger of all or part of our practice,
provided that we take appropriate precautions (for example, through a
written confidentiality agreement) so the prospective purchaser does not
disclose information obtained in the course of the review.
Participating in actual or threatened legal proceedings or alternative
dispute resolution proceedings either initiated by or against us, provided
we disclose only the information necessary to file, pursue, or defend
against the lawsuit, and take reasonable precautions to ensure that the
information disclosed does not become a matter of public record.
Providing information to third parties who perform services or functions for
us pursuant to a contractual agreement which prohibits the third party from
disclosing or using the information other than for the purposes for which
the information was disclosed.
Information Gathered By Notetaking Software
With your consent, we may utilize AI driven notetaking software, Jump AI
("Jump"), during meetings to better manage our client service and
regulatory needs to document meetings, identify follow-up actions, and
prepare meeting summaries. We also believe this tool will enhance client
service by enabling our advisers to be more client-focused by reducing the
burden of manual note taking.
Jump captures audio from your in-person and virtual meetings, then uses
speech-to-text technology to transcribe these meetings. Jump then uses a
type of generative AI technology called large language models (LLMs) to
summarize raw meeting data into meeting notes, tasks, email drafts, and
more. We will always seek your consent prior to activating Jump during a
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meeting. You may also request to stop recording at any time Jump is
enabled.
With respect to information security, Jump complies with SOC2 standards,
and uses modern security practices including end-to-end encryption for data
in transit and at rest, multi-factor authentication, and more. Jump engages in
regular security audits including SOC2 Type II, continuous monitoring of our
controls via Vanta, third party penetration testing, and regular software
updates. Jump hosts data on servers located in the United States in Iowa.
Safeguarding Your Personal Information
We restrict access to nonpublic personal information about you to those
individuals who need to know that information to provide products or
services to you and perform their respective duties. We maintain physical,
electronic, and procedural security measures to safeguard confidential client
information. Examples of how we safeguard client information digitally
include the use of password protected systems, multi-factor authentication,
updated anti-virus and anti-spyware software, and encrypted storage
devices and software firewalls. When transmitting confidential personally
identifiable information (PII), we offer and require the use of point-to-point
encrypted portals or encrypted email.
Children's Privacy
We do not knowingly market to or solicit personal information from children
under the age of 18. If we learn that we have received information directly
from a child who is under the age of 18, we will delete the information in
accordance with applicable law.
Keeping You Informed
As required by federal law, we will notify our clients of our privacy policy
annually. We reserve the right to modify this privacy policy at any time, but
we will provide you a revised notice incorporating any material changes
before we implement such changes.
You may receive more than one of these notices from Fairman Financial
depending on the services Fairman Financial provides for you. If you have
any questions about this notice or Fairman Financial’s information practices,
please contact the senior member of your Fairman Financial service team
by email or call our office at (610) 889-7300.
We Value Your Trust In Our Firm
We cannot emphasize enough how much we value the trust you place in
our firm and in our employees. We understand that protecting your privacy
is essential to maintaining your trust; and we commit that Fairman Financial
will adhere to the above policies and practices.
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