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Serenus Wealth Advisors ℠
Form ADV Part 2A – Disclosure Brochure
Effective March 13, 2025
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and
business practices of Serenus Wealth Advisors ℠ (“Serenus” or the “Advisor”). If you have any
questions about the contents of this Disclosure Brochure, please contact Lonny Elfenbein, Chief
Compliance Officer at 513-977-8330
Serenus is a registered investment advisor with the U.S. Securities and Exchange Commission
(“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC
or by any state securities authority. Registration of an investment advisor does not imply any
specific level of skill or training.
Additional information about Serenus and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or with CRD# 332034.
1299 Ocean Ave, Suite 710
Santa Monica, CA 90401
310-708-1706
www.serenusadvisors.com
Item 2: Material Changes
Form ADV Part 2A requires registered investment advisers to amend their brochure when
information becomes materially inaccurate. If there are any material changes to an adviser’s
disclosure brochure, the adviser is required to notify you and provide you with a description of the
material changes.
Since the release of our initial ADV Part 2A Brochure in July 2024 we have made the following
material changes:
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•
•
•
•
Item 4 has been updated to indicate that Serenus offers Comprehensive Portfolio
Management to all clients who engage with Serenus for investment management services.
Item 4 has been updated to include verbiage pertaining to the potential conflicts involved
with providing advice to Retirement Plan Accounts and Individual Retirement Accounts.
Item 5 has been updated to clarify our fee structure including minimum and maximum
charges
Item 13 has been updated to clarify the process Serenus follows as well as our ongoing
obligation to review client accounts.
Serenus has updated Item 15 to reflect the types of relationships in which Advisers of
Serenus do/may act as trustee for client accounts.
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Item 3: Table of Contents
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Item 2: Material Changes
Item 3: Table of Contents
Item 4: Advisory Business
Item 5: Fees & Compensation
Item 6: Performance-Based Fees & Side-By-Side Management
Item 7: Types of Clients & Account Requirements
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
Item 12: Brokerage Practices
Item 13: Review of Accounts or Financial Plans
Item 14: Client Referrals & Other Compensation
Item 15: Custody
Item 16: Investment Discretion
Item 17: Voting Client Securities
Item 18: Financial Information
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Serenus Wealth Advisors℠, LLC
Item 4: Advisory Business
Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company formed under the laws of the
State of Delaware in 2024 and has been in business as an investment adviser since that time. Our firm
is owned/managed by Kara Boccella, Managing Partner (through KaraCo Holdings, LLC), Devon
Galindo, Partner (through the Galindo-Druger Living Trust) and Graham Mandl, Partner (through
GrahamCo Holdings, LLC).
Types of Advisory Services Offered
Comprehensive Portfolio Management:
As part of our Comprehensive Portfolio Management service clients will be provided asset
management and financial planning or consulting services. This service is designed to assist clients
in meeting their financial goals through the use of a financial plan or consultation. Our firm conducts
client meetings to understand their current financial situation, existing resources, financial goals, and
tolerance for risk. Based on what is learned, an investment approach is presented to the client,
consisting of individual stocks, bonds, ETFs, options, mutual funds and other public and private
securities or investments. Once the appropriate portfolio has been determined, portfolios are
continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual
needs, stated goals and objectives.
Our firm utilizes the sub-advisory services of a third-party investment advisory firm or individual
advisor to aid in the implementation of an investment portfolio designed by our firm. Before selecting
a firm or individual, our firm will ensure that the chosen party is properly licensed or registered. Our
firm will not offer advice on any specific securities or other investments in connection with this service.
We will provide initial due diligence on third party money managers and ongoing reviews of their
management of client accounts. In order to assist in the selection of a third-party money manager, our
firm will gather client information pertaining to financial situation, investment objectives, and
reasonable restrictions to be imposed upon the management of the account.
Note for IRA and Retirement Plan Clients
: When Serenus provides investment advice to you
regarding your retirement plan account or individual retirement account, Serenus is a fiduciary
within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal
Revenue Code, as applicable, which are laws governing retirement accounts. The way Serenus makes
money creates some conflicts with your interests, so Serenus operates under a special rule that
requires Serenus to act in your best interest and not put Serenus’ interest ahead of yours.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning and consulting services will typically involve preparing a financial plan or
rendering a financial consultation for clients based on the client’s financial goals and objectives. This
planning or consulting may encompass Investment Planning, Retirement Planning, Estate Planning,
Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation
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Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines
of Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming
that all the information and documents requested from the client are provided promptly, plans or
consultations are typically completed within 6 months of the client signing a contract with our firm.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Comprehensive Portfolio Management
clients. General investment advice will be offered to our Financial Planning & Consulting and
Referrals to Third Party Money Management clients.
Each Comprehensive Portfolio Management client has the opportunity to place reasonable restrictions
on the types of investments to be held in the portfolio. Restrictions on investments in certain securities
or types of securities may not be possible due to the level of difficulty this would entail in managing
the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
Our firm manages $1,006,937,206 on a discretionary basis and $315,664,676 on a non-discretionary
basis as of December 31, 2024.
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Serenus charges fees based on a percentage of assets under management and/or a flat fee for various
Financial Planning & Consulting Relationships. These fees are described below and shall be set forth
in each client’s Agreement.
Comprehensive Portfolio Management:
Serenus charges an annual advisory fee that is agreed upon with each client and set forth in an
agreement signed and executed between Serenus and the client. Our maximum annual fee for
Comprehensive Portfolio Management is 2% and is based on several factors including, but not limited
to: the services offered to the Client, the complexity of the services to be provided, the level of Client
assets managed by the Advisor, and/or the overall relationship with the advisor.
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Please note: Serenus generally has a minimum account size of $1,000,000 and minimum annual fee
of $10,000 which may also vary based on the factors listed above. In circumstances where the
minimum account size is waived or there is decline in market value the management fee could
potentially be greater than 2%.
Fees to be assessed will be outlined in the advisory agreement to be signed by the Client. Our firm
bills on cash unless indicated otherwise in writing. Annualized fees are billed on a pro-rata basis
quarterly in advance based on the value of the account(s) on the last day of the previous quarter. Fees
are negotiable and will be deducted from client account(s). Adjustments may be made for material
deposits and withdrawals during the quarter. In rare cases, our firm will agree to directly invoice.
Unless specifically noted in the advisory agreement, fees for new Comprehensive Portfolio
Management clients are based upon the date that the accounts values are reflected in Serenus’
portfolio management system.
As part of this process, Clients understand the following:
a)
b)
c)
The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Fees charged for third party manager services shall be in addition to our advisory fees. The third
party money managers we recommend will not directly charge you a higher fee than they would have
charged without us introducing you to them. Third party money managers establish and maintain
their own separate billing processes over which we have no control. In general, they will directly bill
you and describe how this works in their separate written disclosure documents.
Financial Planning & Consulting:
Our firm charges on a flat fee basis for financial planning and consulting services. The total estimated
fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with
the client. Flat fees range from $5,000 to $100,000. The fee-paying arrangements will be determined
on a case-by-case basis and will be detailed in the signed consulting agreement. Our firm will not
require a retainer exceeding $1,200 when services cannot be rendered within 6 months.
Other Types of Fees & Expenses
Clients will incur transaction fees for trades executed by their chosen custodian, either based on a
percentage of the dollar amount of assets in the account(s) or via individual transaction charges.
These transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen
custodian.
Fidelity Brokerage Services (“Fidelity”) eliminated transaction fees for U.S. listed equities and
exchange traded funds for clients who opt into electronic delivery of statements or maintain at least
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$1 million in assets at Fidelity. Clients who do not meet either criteria will be subject to transaction
fees charged by Fidelity for U.S. listed equities and exchange traded funds.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), distribution
fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, mark-ups and
mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire
transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm
does not receive a portion of these fees.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm Comprehensive Portfolio
Management services in writing at any time. Upon notice of termination our firm will process a pro-
rata refund of the unearned portion of the advisory fees charged in advance.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
•
•
Individuals and High Net Worth Individuals;
Trusts, Estates or Charitable Organizations;
Our requirements for opening and maintaining accounts or otherwise engaging us:
•
Our firm generally requires a minimum account balance of $1,000,000.00 for our
Comprehensive Portfolio Management service. Our firm reserves the right to waive the
minimum account balance at our firm’s discretion based on factors such as but not limited to:
the services offered to the Client, the complexity of the services to be provided, the level of
Client assets managed by the Advisor, and/or the overall relationship with the advisor.
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•
Written financial plans are generally assessed at a minimum fee of $5,000.
Clients who opt into electronic delivery of statements or maintain at least $1 million in assets at
Fidelity will not be charged transaction fees for U.S. listed equities and exchange traded funds.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Charting:
In this type of technical analysis, our firm reviews charts of market and security activity in
an attempt to identify when the market is moving up or down and to predict how long the trend may
last and when that trend might reverse.
Cyclical Analysis:
Statistical analysis of specific events occurring at a sufficient number of relatively
predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical
forces drive price movements in the financial markets. Risks include that cycles may invert or
disappear and there is no expectation that this type of analysis will pinpoint turning points, instead
be used in conjunction with other methods of analysis.
Duration Constraints:
Our firm adhere to a discipline of generally maintaining duration within a
narrow band around benchmark duration in order to limit exposure to market risk. Our portfolio
management team rebalances client portfolios to their current duration targets on a periodic basis.
The risk of constraining duration is that the client may not participate fully in a large rally in bond
prices.
Fundamental Analysis:
The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the
intrinsic value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can
be made by purchasing the mispriced security and then waiting for the market to recognize its
"mistake" and reprice the security.; and (b) Technical analysis maintains that all information is
reflected already in the price of a security. Technical analysts analyze trends and believe that
sentiment changes predate and predict trend changes. Investors' emotional responses to price
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movements lead to recognizable price chart patterns. Technical analysts also analyze historical
trends to predict future price movement. Investors can use one or both of these different but
complementary methods for stock picking. This presents a potential risk, as the price of a security
can move up or down along with the overall market regardless of the economic and financial factors
considered in evaluating the stock.
Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis:
Analysis of the experience and
track record of the manager of the mutual fund or ETF in an attempt to determine if that manager
has demonstrated an ability to invest over a period of time and in different economic conditions. The
underlying assets in a mutual fund or ETF are also reviewed in an attempt to determine if there is
significant overlap in the underlying investments held in another fund(s) in the Client’s portfolio. The
funds or ETFs are monitored in an attempt to determine if they are continuing to follow their stated
investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments,
past performance does not guarantee future results. A manager who has been successful may not be
able to replicate that success in the future. In addition, as our firm does not control the underlying
investments in a fund or ETF, managers of different funds held by the Client may purchase the same
security, increasing the risk to the Client if that security were to fall in value. There is also a risk that
a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which
could make the holding(s) less suitable for the Client’s portfolio.
Technical Analysis:
A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the history
of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are mathematical
transformations of price, often including up and down volume, advance/decline data and other
inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
probability of its direction and of continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among traders
and financial professionals and is very often used by active day traders, market makers and pit
traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
Third-Party Money Manager Analysis:
The analysis of the experience, investment philosophies,
and past performance of independent third-party investment managers in an attempt to determine
if that manager has demonstrated an ability to invest over a period of time and in different economic
conditions. Analysis is completed by monitoring the manager’s underlying holdings, strategies,
concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of
the due-diligence process, the manager’s compliance and business enterprise risks are surveyed and
reviewed. A risk of investing with a third-party manager who has been successful in the past is that
they may not be able to replicate that success in the future. In addition, as our firm does not control
the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager
may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable
investment for our clients. Moreover, as our firm does not control the manager’s daily business and
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compliance operations, our firm may be unaware of the lack of internal controls necessary to prevent
business, regulatory or reputational deficiencies.
Qualitative Analysis:
A securities analysis that uses subjective judgment based on unquantifiable
information, such as management expertise, industry cycles, strength of research and development,
and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on
numbers that can be found on reports such as balance sheets. The two techniques, however, will often
be used together in order to examine a company's operations and evaluate its potential as an
investment opportunity. Qualitative analysis deals with intangible, inexact concerns that belong to
the social and experiential realm rather than the mathematical one. This approach depends on the
kind of intelligence that machines (currently) lack, since things like positive associations with a
brand, management trustworthiness, customer satisfaction, competitive advantage and cultural
shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative
analysis is that subjective judgment may prove incorrect.
Quantitative Analysis:
The use of models, or algorithms, to evaluate assets for investment. The
process usually consists of searching vast databases for patterns, such as correlations among liquid
assets or price-movement patterns (trend following or mean reversion). The resulting strategies may
involve high-frequency trading. The results of the analysis are taken into consideration in the
decision to buy or sell securities and in the management of portfolio characteristics. A risk in using
quantitative analysis is that the methods or models used may be based on assumptions that prove to
be incorrect.
Security Analysis
: Analysis of tradeable financial instruments called securities. These can be
classified into debt securities, equities, or some hybrid of the two. More broadly, futures contracts
and tradeable credit derivatives are sometimes included. Security analysis is typically divided into
fundamental analysis, which relies upon the examination of fundamental business factors such as
financial statements, and technical analysis, which focuses upon price trends and momentum.
Quantitative analysis may use indicators from both areas.
Sector Analysis
: Sector analysis involves identification and analysis of various industries or
economic sectors that are likely to exhibit superior performance. Academic studies indicate that the
health of a stock's sector is as important as the performance of the individual stock itself. In other
words, even the best stock located in a weak sector will often perform poorly because that sector is
out of favor. Each industry has differences in terms of its customer base, market share among firms,
industry growth, competition, regulation and business cycles. Learning how the industry operates
provides a deeper understanding of a company's financial health. One method of analyzing a
company's growth potential is examining whether the amount of customers in the overall market is
expected to grow. In some markets, there is zero or negative growth, a factor demanding careful
consideration. Additionally, market analysts recommend that investors should monitor sectors that
are nearing the bottom of performance rankings for possible signs of an impending turnaround.
Technical Analysis:
A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the history
of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are mathematical
transformations of price, often including up and down volume, advance/decline data and other
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inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
probability of its direction and of continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among traders
and financial professionals and is very often used by active day traders, market makers and pit
traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
Investment Strategies We Use
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Alternative Investments:
Hedge funds, commodity pools, Real Estate Investment Trusts (“REITs”),
Business Development Companies (“BDCs”), and other alternative investments involve a high degree
of risk and can be illiquid due to restrictions on transfer and lack of a secondary trading market. They
can be highly leveraged, speculative and volatile, and an investor could lose all or a substantial
amount of an investment. Alternative investments may lack transparency as to share price, valuation
and portfolio holdings. Complex tax structures often result in delayed tax reporting. Compared to
mutual funds, hedge funds and commodity pools are subject to less regulation and often charge
higher fees and may require “capital calls” which would require additional investment. Alternative
investment managers typically exercise broad investment discretion and may apply similar
strategies across multiple investment vehicles, resulting in less diversification.
Asset Allocation:
The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the
investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle
that different assets perform differently in different market and economic conditions. A fundamental
justification for asset allocation is the notion that different asset classes offer returns that are not
perfectly correlated, hence diversification reduces the overall risk in terms of the variability of
returns for a given level of expected return. Although risk is reduced as long as correlations are not
perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation
and variance) that existed over some past period. Expectations for return are often derived in the
same way.
An asset class is a group of economic resources sharing similar characteristics, such as riskiness and
return. There are many types of assets that may or may not be included in an asset allocation strategy.
The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of
any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic,
foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally:
investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long-
term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these
three provides a starting point. Usually included are hybrid instruments such as convertible bonds
and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be
considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others.;
Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps;
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insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products,
etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and
futures; foreign currency; venture capital; private equity; and/or distressed securities.
There are several types of asset allocation strategies based on investment goals, risk tolerance, time
frames and diversification. The most common forms of asset allocation are: strategic, dynamic,
tactical, and core-satellite.
●
●
●
●
Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset
mix that seeks to provide the optimal balance between expected risk and return for a long-
term investment horizon. Generally speaking, strategic asset allocation strategies are
agnostic to economic environments, i.e., they do not change their allocation postures relative
to changing market or economic conditions.
Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in
that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance
between expected risk and return for a long-term investment horizon. Like strategic
allocation strategies, dynamic strategies largely retain exposure to their original asset
classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust
their postures over time relative to changes in the economic environment.
Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a
more active approach that tries to position a portfolio into those assets, sectors, or individual
stocks that show the most potential for perceived gains. While an original asset mix is
formulated much like strategic and dynamic portfolio, tactical strategies are often traded
more actively and are free to move entirely in and out of their core asset classes
Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core'
strategic element making up the most significant portion of the portfolio, while applying a
dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this
way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical
allocation strategies mentioned above.
Exchange Traded Funds (“ETFs”):
An ETF is a type of Investment Company (usually, an open-end
fund or unit investment trust) whose primary objective is to achieve the same return as a particular
market index. The vast majority of ETFs are designed to track an index, so their performance is close
to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference
between the returns of a fund and the returns of the index, can arise due to differences in
composition, management fees, expenses, and handling of dividends. ETFs benefit from continuous
pricing; they can be bought and sold on a stock exchange throughout the trading day. Because ETFs
trade like stocks, you can place orders just like with individual stocks - such as limit orders, good-
until-canceled orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are
bought and redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought
and sold at the market prices on the exchanges, which resemble the underlying NAV but are
independent of it. However, arbitrageurs will ensure that ETF prices are kept very close to the NAV
of the underlying securities. Although an investor can buy as few as one share of an ETF, most buy in
board lots. Anything bought in less than a board lot will increase the cost to the investor. Anyone can
buy any ETF no matter where in the world it trades. This provides a benefit over mutual funds, which
generally can only be bought in the country in which they are registered.
One of the main features of ETFs are their low annual fees, especially when compared to traditional
mutual funds. The passive nature of index investing, reduced marketing, and distribution and
accounting expenses all contribute to the lower fees. However, individual investors must pay a
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brokerage commission to purchase and sell ETF shares; for those investors who trade frequently,
this can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost
brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient.
Long-Term Purchases:
Our firm may buy securities for your account and hold them for a relatively
long time (more than a year) in anticipation that the security’s value will appreciate over a long
horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that
could have been profitable to your account, or it’s possible that the security’s value may decline
sharply before our firm makes a decision to sell.
Margin Transactions:
Our firm may purchase securities for your portfolio with money borrowed
from your brokerage account. This allows you to purchase more stock than you would be able to with
your available cash and allows us to purchase securities without selling other holdings. Margin
accounts and transactions are risky and not necessarily appropriate for every client. It should be
noted that our firm bills advisory fees on securities purchased on margin which creates a financial
incentive for us to utilize margin in client accounts.
The potential risks associated with these transactions are (1) You can lose more funds than are
deposited into the margin account; (2) the forced sale of securities or other assets in your account;
(3) the sale of securities or other assets without contacting you; (4) you may not be entitled to choose
which securities or other assets in your account(s) are liquidated or sold to meet a margin call; and
(5) custodians charge interest on margin balances which will reduce your returns over time.
Mutual Funds
: A mutual fund is a company that pools money from many investors and invests that
money in a variety of differing security types based on the objectives of the fund. The portfolio of the
fund consists of the combined holdings it owns. Each share represents an investor’s proportionate
ownership of the fund’s holdings and the income those holdings generate. The price that investors
pay for mutual fund shares are the fund’s per share net asset value (“NAV”) plus any shareholder fees
that the fund imposes at the time of purchase (such as sales loads). Investors typically cannot
ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence
which securities the fund manager buys and sells or the timing of those trades. With an individual
stock, investors can obtain real-time (or close to real-time) pricing information with relative ease by
checking financial websites or by calling a broker or your investment adviser. Investors can also
monitor how a stock’s price changes from hour to hour—or even second to second. By contrast, with
a mutual fund, the price at which an investor purchases or redeems shares will typically depend on
the fund’s NAV, which is calculated daily after market close.
The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an
investing strategy that generally sums up as “Don’t put all your eggs in one basket.” Spreading
investments across a wide range of companies and industry sectors can help lower the risk if a
company or sector fails. Some investors find it easier to achieve diversification through ownership of
mutual funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual
fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed
on redemption.
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Serenus Wealth Advisors℠, LLC
Mutual funds also have features that some investors might view as disadvantages: (a) Investors must
pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending
on the timing of their investment, investors may also have to pay taxes on any capital gains
distributions they receive. This includes instances where the fund performed poorly after purchasing
shares.; (b) Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given
time, nor can they directly influence which securities the fund manager buys and sells or the timing
of those trades.; and (c) With an individual stock, investors can obtain real-time (or close to real-
time) pricing information with relative ease by checking financial websites or by calling a broker or
your investment adviser. Investors can also monitor how a stock’s price changes from hour to hour—
or even second to second. By contrast, with a mutual fund, the price at which an investor purchases
or redeems shares will typically depend on the fund’s NAV, which the fund might not calculate until
many hours after the investor placed the order. In general, mutual funds must calculate their NAV at
least once every business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any
capital gains tax until the investor actually sells and makes a profit. Mutual funds, however, are
different. When an investor buys and holds mutual fund shares, the investor will owe income tax on
any ordinary dividends in the year the investor receives or reinvests them. Moreover, in addition to
owing taxes on any personal capital gains when the investor sells shares, the investor may have to
pay taxes each year on the fund’s capital gains. That is because the law requires mutual funds to
distribute capital gains to shareholders if they sell securities for a profit, and cannot use losses to
offset these gains.
Options
: An option is a financial derivative that represents a contract sold by one party (the option
writer) to another party (the option holder, or option buyer). The contract offers the buyer the right,
but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the
strike price) during a certain period of time or on a specific date (exercise date). Options are
extremely versatile securities. Traders use options to speculate, which is a relatively risky practice,
while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option
buyers and writers have conflicting views regarding the outlook on the performance of a:
• Call Option
: Call options give the option to buy at certain price, so the buyer would want the
stock to go up. Conversely, the option writer needs to provide the underlying shares in the
event that the stock's market price exceeds the strike due to the contractual obligation. An
option writer who sells a call option believes that the underlying stock's price will drop
relative to the option's strike price during the life of the option, as that is how he will reap
maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes
that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock
for a lower price and then sell it for a profit. However, if the underlying stock does not close
above the strike price on the expiration date, the option buyer would lose the premium paid
for the call option.
• Put Option
: Put options give the option to sell at a certain price, so the buyer would want the
stock to go down. The opposite is true for put option writers. For example, a put option buyer
is bearish on the underlying stock and believes its market price will fall below the specified
strike price on or before a specified date. On the other hand, an option writer who sells a put
option believes the underlying stock's price will increase about a specified price on or before
the expiration date. If the underlying stock's price closes above the specified strike price on
the expiration date, the put option writer's maximum profit is achieved. Conversely, a put
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option holder would only benefit from a fall in the underlying stock's price below the strike
price. If the underlying stock's price falls below the strike price, the put option writer is
obligated to purchase shares of the underlying stock at the strike price.
The potential risks associated with these transactions are that (1) all options expire. The closer the
option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move
very quickly. Depending on factors such as time until expiration and the relationship of the stock
price to the option’s strike price, small movements in a stock can translate into big movements in the
underlying options.
Short-Term Purchases:
When utilizing this strategy, our firm may also purchase securities with the
idea of selling them within a relatively short time (typically a year or less). Our firm does this in an
attempt to take advantage of conditions that our firm believes will soon result in a price swing in the
securities our firm purchase.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, and that their assets are appropriately diversified in
investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance.
Capital Risk:
Capital risk is one of the most basic, fundamental risks of investing; it is the risk that
you may lose 100% of your money. All investments carry some form of risk and the loss of capital is
generally a risk for any investment instrument.
Company Risk:
When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk
and can be reduced through appropriate diversification. There is the risk that the company will
perform poorly or have its value reduced based on factors specific to the company or its industry.
For example, if a company’s employees go on strike or the company receives unfavorable media
attention for its actions, the value of the company may be reduced.
Economic Risk:
The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country that
experiences wide swings from an economic standpoint or in situations where certain elements of an
investment instrument are hinged on dealings in such countries, the investment instrument will
generally be subject to a higher level of economic risk.
Financial Risk:
Financial risk is represented by internal disruptions within an investment or the
issuer of an investment that can lead to unfavorable performance of the investment. Examples of
financial risk can be found in cases like Enron or many of the dot com companies that were caught
up in a period of extraordinary market valuations that were not based on solid financial footings of
the companies.
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Serenus Wealth Advisors℠, LLC
Inflation Risk
: Inflation risk involves the concern that in the future, your investment or proceeds
from your investment will not be worth what they are today. Throughout time, the prices of resources
and end-user products generally increase and thus, the same general goods and products today will
likely be more expensive in the future. The longer an investment is held, the greater the chance that
the proceeds from that investment will be worth less in the future than what they are today. Said
Manager Risk:
another way, a dollar tomorrow will likely get you less than what it can today.
There is always the possibility that poor security selection will cause your
investments to underperform relative to benchmarks or other funds with a similar investment
objective.
Market Risk:
The value of your portfolio may decrease if the value of an individual company or
multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is
incorrect. Further, regardless of how well individual companies perform, the value of your portfolio
could also decrease if there are deteriorating economic or market conditions. It is important to
understand that the value of your investment may fall, sometimes sharply, in response to changes in
the market, and you could lose money. Investment risks include price risk as may be observed by a
drop in a security’s price due to company specific events (e.g. earnings disappointment or downgrade
in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock values fall in
general). For fixed-income securities, a period of rising interest rates could erode the value of a bond
since bond values generally fall as bond yields go up. Past performance is not a guarantee of future
returns.
Past Performance:
Charting and technical analysis are often used interchangeably. Technical
analysis generally attempts to forecast an investment’s future potential by analyzing its past
performance and other related statistics. In particular, technical analysis often times involves an
evaluation of historical pricing and volume of a particular security for the purpose of forecasting
where future price and volume figures may go. As with any investment analysis method, technical
analysis runs the risk of not knowing the future and thus, investors should realize that even the most
diligent and thorough technical analysis cannot predict or guarantee the future performance of any
particular investment instrument or issuer thereof.
Strategy Risk:
There is no guarantee that the investment strategies discussed herein will work under
all market conditions and each investor should evaluate his/her ability to maintain any investment
he/she is considering in light of his/her own investment time horizon. Investments are subject to
risk, including possible loss of principal.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to our
Comprehensive Portfolio Management services, as applicable.
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Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Our firm has no other financial industry activities and affiliations to disclose.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
transaction and insider trading. Our firm requires all representatives to conduct business with the
highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
1
. In order to monitor compliance with our personal
our representatives for their personal accounts
trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
1
For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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Serenus Wealth Advisors℠, LLC
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling securities that will be bought or sold in client accounts unless done so after the client execution
or concurrently as a part of a block trade.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
Item 15
While our firm does not maintain physical custody of client assets, we are deemed to have custody of
Custody
certain client assets if given the authority to withdraw assets from client accounts (see
, below). Client assets must be maintained by a qualified custodian. Our firm seeks to
recommend a custodian who will hold client assets and execute transactions on terms that are overall
most advantageous when compared to other available providers and their services. The factors
considered, among others, are these:
•
•
•
•
•
•
•
•
•
•
•
•
•
Timeliness of execution
Timeliness and accuracy of trade confirmations
Research services provided
Ability to provide investment ideas
Execution facilitation services provided
Record keeping services provided
Custody services provided
Frequency and correction of trading errors
Ability to access a variety of market venues
Expertise as it relates to specific securities
Financial condition
Business reputation
Quality of services
Our firm has an arrangement with National Financial Services LLC and Fidelity Brokerage Services LLC
(collectively, and together with all affiliates, "Fidelity") through which Fidelity provides our firm with
"institutional platform services." Our firm is independently operated and owned and is not affiliated with
Fidelity. The institutional platform services include, among others, brokerage, custody, and other related
services. Fidelity's institutional platform services that assist us in managing and administering clients'
accounts include software and other technology that (i) provide access to client account data (such as
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Serenus Wealth Advisors℠, LLC
trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated
trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv)
facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions,
recordkeeping and client reporting.
Fidelity may make certain research and brokerage services available at no additional cost to our firm.
include: research reports on
Research products and services provided by Fidelity may
recommendations or other information about particular companies or industries; economic surveys,
data and analyses; financial publications; portfolio evaluation services; financial database software and
services; computerized news and pricing services; quotation equipment for use in running software
used in investment decision-making; and other products or services that provide lawful and appropriate
assistance by Fidelity to our firm in the performance of our investment decision-making responsibilities.
The aforementioned research and brokerage services qualify for the safe harbor exemption defined in
Section 28(e) of the Securities Exchange Act of 1934.
Fidelity does not make client brokerage commissions generated by client transactions available for
our firm’s use. The aforementioned research and brokerage services are used by our firm to manage
accounts for which our firm has investment discretion. Without this arrangement, our firm might be
compelled to purchase the same or similar services at our own expense.
As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of
our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm
or our related persons creates a potential conflict of interest and may indirectly influence our firm’s
choice of Fidelity as a custodial recommendation. Our firm examined this potential conflict of interest
when our firm chose to recommend Fidelity and have determined that the recommendation is in the
best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best
execution.
Our clients may pay a transaction fee or commission to Fidelity that is higher than another qualified
broker dealer might charge to effect the same transaction where our firm determines in good faith
that the commission is reasonable in relation to the value of the brokerage and research services
provided to the client as a whole.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Soft Dollars
Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will
generally be used to service all of our clients but not necessarily all at any one particular time.
Client Brokerage Commissions
Fidelity does not make client brokerage commissions generated by client transactions available for
our firm’s use.
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Client Transactions in Return for Soft Dollars
Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar
benefits.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
Neither our firm nor any of our firm’s representatives have discretionary authority in making the
determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale
of securities are placed for execution, and the commission rates at which such securities transactions
are effected. Our firm routinely recommends that clients direct us to execute through a specified
broker-dealer. Our firm recommends the use of Fidelity. Each client will be recommended to establish
their account(s) with Fidelity if not already done. Please note that not all advisers have this
recommendation.
Client-Directed Brokerage
Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to
achieve the most favorable execution of client transactions. Client directed brokerage may cost
clients more money. For example, in a directed brokerage account, clients may pay higher brokerage
commissions because our firm may not be able to aggregate orders to reduce transaction costs, or
clients may receive less favorable prices.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when our firm believes
that to do so will be in the best interest of the effected accounts. When such concurrent authorizations
occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, our firm attempts to allocate trade executions in the most equitable
manner possible, taking into consideration client objectives, current asset allocation and availability of
funds using price averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
Periodic Reviews
While investment management accounts are monitored on an ongoing basis by our management
personnel or financial advisors, Serenus’ investment adviser representatives seek to have at least one
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Serenus Wealth Advisors℠, LLC
annual meeting with each client to conduct a formal review of the clients’ accounts. Accounts are
reviewed for consistency with the investment strategy and other parameters set forth for the account
and to determine if any adjustments need to be made.
Other Reviews and Triggering Factors
In addition to the periodic reviews described above, reviews may be triggered by changes in an
account holder’s personal, tax or financial status. Other events that may trigger a review of an account
are material changes in market conditions as well as macroeconomic and company- specific events.
Clients are encouraged to notify Serenus of any changes in their personal financial situation that
might affect their investment needs, objectives, or time horizon.
Regular Reports
Written brokerage statements are generated no less than quarterly and are sent directly from the
qualified custodian. These reports list the account positions, activity in the account over the covered
period, and other related information. Clients are also sent confirmations following each brokerage
account transaction unless confirmations have been waived.
Serenus may also determine to provide account statements and other reporting to clients on a
periodic basis. Serenus also provides account reports during client meetings.
Clients are urged to carefully review all custodial account statements and compare them to any
statements and reports provided by Serenus. Serenus statements and reports may vary from
custodial statements based on accounting procedures, reporting dates, or valuation methodologies
of certain securities.
Financial Planning and Consulting Client Reporting
Due to the nature of standalone financial planning and consulting services Financial Planning and
Consulting clients do not receive reviews of their written plans unless they take action to schedule a
financial consultation with us. Our firm does not provide ongoing services to these clients, but are
willing to meet with such clients upon their request to discuss updates to their plans, changes in their
circumstances, etc. These clients do not receive written or verbal updated reports regarding their
financial plans unless they separately engage our firm for a post-financial plan meeting or update to
their initial written financial plan.
Item 14: Client Referrals & Other Compensation
Fidelity
Except for the arrangements outlined in Item 12 of Form ADV Part 2A, our firm has no additional
arrangements to disclose.
Client Referrals
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In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Item 15: Custody
Client Login Credentials
Representatives of our firm may have access to username and password of client accounts and will
only be done at a financial institutions whose policy allows for the sharing of login credentials. As
such, our firm is deemed to have custody. The client funds and securities of which our firm has
custody are verified by actual examination at least once during each calendar year by an independent
public accountant (“IPA”) registered with the Public Company Accounting Oversight Board
(“PCAOB”), at a time that is chosen by the accountant without prior notice or announcement to our
firm and that is irregular from year to year. Clients are encouraged to raise any questions with us
about the custody, safety or security of their assets and our custodial recommendations.
Deduction of Advisory Fees:
While our firm does not maintain physical custody of client assets (which are maintained by a
qualified custodian, as discussed above), we are deemed to have custody of certain client assets if
given the authority to withdraw assets from client accounts, as further described below under “Third
Party Money Movement.” All of our clients receive account statements directly from their qualified
custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review
these statements. Additionally, if our firm decides to send its own account statements to clients, such
statements will include a legend that recommends the client compare the account statements
received from the qualified custodian with those received from our firm. Clients are encouraged to
raise any questions with us about the custody, safety or security of their assets and our custodial
recommendations.
Trustee for Client Accounts:
Persons associated with our firm may serve as trustees to certain accounts for which we also
provide investment advisory services. In all cases, the persons associated with our firm have been
appointed trustee as a result of a family or personal relationship with the trust grantor and/or
beneficiary and not as a result of employment with our firm. Therefore, we are not deemed to
have custody over the advisory accounts for which persons associated with our firm serve as
trustee.
Third Party Money Movement:
On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client
funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody.
As such, our firm has adopted the following safeguards in conjunction with our custodian:
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•
•
•
•
•
•
•
The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, our firm is
authorized to execute securities transactions, determine which securities are bought and sold, and
the total amount to be bought and sold. Should clients grant our firm non-discretionary authority,
our firm would be required to obtain the client’s permission prior to effecting securities transactions.
Limitations may be imposed by the client in the form of specific constraints on any of these areas of
discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write or email us to discuss questions
they may have about particular proxy votes or other solicitations.
Third party money managers selected or recommended by our firm may vote proxies for clients.
Therefore, except in the event a third party money manager votes proxies, clients maintain exclusive
responsibility for: (1) directing the manner in which proxies solicited by issuers of securities
beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s
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investment assets. Therefore (except for proxies that may be voted by a third party money manager),
our firm and/or the client shall instruct the qualified custodian to forward copies of all proxies and
shareholder communications relating to the client’s investment assets.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
•
•
•
Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
Our firm does not take custody of client funds or securities.
Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
Our firm has never been the subject of a bankruptcy proceeding.
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