Form ADV is the Securities and Exchanges Regulatory requirement for any Fiduciary Advisor. This form outlines the basics of what we do and how we do it. This link takes you to SEC.GOV and the Form is updated either annually or upon any material change in our firm, ownership or way we operate.

Please click here to go to the SEC

Click on "Latest ADV Form" https://adviserinfo.sec.gov/firm/summary/171750

Form ADV is the Securities and Exchanges Regulatory requirement for any Fiduciary Advisor. This form outlines the basics of what we do and how we do it. This link takes you to SEC.GOV and the Form is updated either annually or upon any material change in our firm, ownership or way we operate.

Please click here to go to the SEC

Click on "Part 2 Brochures"

https://adviserinfo.sec.gov/firm/summary/171750

Form ADV is the Securities and Exchanges Regulatory requirement for any Fiduciary Advisor. This will outline the basics of what we do and how we do it. This link takes you to SEC.GOV and the Form is updated either annually or upon any material change in our firm, ownership or way we operate.

The CRS stands for Customer Relationship Summary. This is a short form outline of the longer version (ADV Part II)

Please click here to go to the SEC

Click on "Relationship Summary" https://adviserinfo.sec.gov/firm/summary/171750

We custody funds at some of the largest custodians. We primarily use Charles Schwab, but also use Interactive Brokers, as well as Alltruist. For 401-ks and pension plans we may use different custodians based on the plan. We can use Fidelity and Etrade as long as the accounts are not institutional and or a company plan as these are locked out. We use Vanguard for ETFs but Vanguard no longer has an Institutional Arm.

Custody denotes that we have access to your funds and can add or move funds. We do not now and will never take custody of your funds. It has been our founders belief that there is too much risk by taking custody. This risk is from any mistakes or potential that anyone from our firm can ever have access to any clients funds. This is why we use large custodians such as Charles Schwab. We do not at any time have control to move money without your signed consent, or to have any access to your account other than to trade the account based upon the constraints you set up with an Investment Policy Statement (IPS).

Almost every single Ponzi scheme or theft of clients money by advisors or money managers happens when the advisor or money manager takes custody of the funds.

Bernie Madoff, the most famous crook in history, had custody of customers accounts in his business trust account. Only he saw the true value but continued to produce fake statements. If you have your funds custodied at a separate company like Schwab or Interactive Brokers, you see the accounts directly.

Usually, the way these criminals steal money is to send out fake statements and the client only knows after it's too late. We believe it's better to have the funds held at a custody so you are the only one that can control the accounts.

We do service accounts for clients at these custodians which means we do have a back end connection to the institutional side of the custodian.

Sometimes clients ask us to move money, pay the IRS etc. We do not have access to the accounts but we are able to facilitate a digital form for a client to sign to move money to their personal accounts or pay the IRS. The process is we must first connect the accounts you want linked which is usually a three to five day process due to our internal security checks as well as the custodians checks. Once the accounts are linked, you can move money between your accounts online or you can request our office to facilitate. To clarify, we do not have access to move money on your behalf without your linked account with prior approval and security checks.

Any movements must be done with a Docu-Sign and must only be moved to an approved account that you have set up to be authorized to move money to or from.

Are we open to additional Custodians? Yes.

If you have a favorite custodian you can ask if we can set up an institutional agreement with them. We will do our due diligence and determine if the custodian is a good fit compared to what we already use.

We will compare the following

Best Trade Practices

(What are the prices they get on a buy or a sell compared to other custodians)

Costs

What if any commissions do they charge as well as hidden costs such as the buying and selling of bonds or private REITS

Online Access

What does their online access for us as intuitional managers as well as to you as the end client look like.

Additional Services Offerings

We review additional service offerings.

Some large custodians only offer online access and are weak in other services such as.

Checking and Debit Card Issuing

Costs and constraints such as limiting a certain number of checks or requiring a minimum balance before getting charged for an account

Online wire processing with low fees

SSL (Security Secured Lending)

Allows loans against assets at competitive interest rates. This is important when using assets for our Grow-Borrow-Die strategy as well as our ROTH conversion strategies

SLA (Stock Lending Account)

A service that the custodian borrows your stock and pays you an interest rate on the borrow. The custodians offer this to lend to others that are shorting their portfolios.

The custodians pay you a rate of return and you still have full control to sell or change the stock positions.

Customer Service

This is by far the most important. While we have reviewed many custodians we will not use them due to their lack of quality talent and lackluster attention to detail. We cannot process items and have to rely on these custodians. If they don't process items timely or even incorrectly that poses a risk to you as our client. Our founders usually will move some of their personal accounts to such custodians to test their processes and their service quality. From past experience we only use one out of ten new companies we test.

Our founder is a student of Benjamin Graham and Warren Buffett. We don't follow crystal balls, tarot cards or any other magical prediction devices.

It is our belief that all portfolios must be reviewed for the potential return with an equal emphasis to the volatility risk.

There are two types of clients, those in the accumulation stage and those in the distribution phase.

Each phase is treated differently. If a person is in the accumulation stage we have to first determine the number of years to convert from accumulation to distribution. We design the portfolios based on the volatility and when the portfolio is needed.

If you are in the distribution phase, we analyze your cash flow needed and then we reverse engineer the portfolio to produce the income needed at the lowest possible volatility based on historical volatility and returns. While past returns, and volatility can never be guaranteed to repeat themselves we have to have a basis of how to produce income with a strategy to lower risk.

We believe that the concept of what is best is not a viable option as it would denote that there is a "best" investment. If there was a investment better than any other, everyone would be in it.

There are investments however that we believe are not good and should never be used.

Investments we will never use

Variable Annuities

Non-Traded REITS

Private Offerings

Self Structured Notes

Mutual Funds

Investments we will use

Exchange Traded Funds

Individual Stocks

Individual Government, corporate and municipal bonds

Money Managers that use the above types of investments

We have two methods of investment.

1) Our internal ETF models. These models are designed to strive for the lowest risk and span from a Model 1 (all bonds, low volatility and low return) and go to a Model 6 (all stock and REITS with the highest potential for return but with the highest volatility)

2) Market Place Models. Due to our association with Orion Investments we have access to institutions managers that retail investors do not have access to These are specialized portfolios and models managed by Wall Streets top managers such as Goldman Sachs, Black Rock and more.

3) Alternative investment models. These models are available through the Model Market plan and can span from specialized portfolios such as Crypto, REITS, Hedge Funds and AI.

Your planner will work through mathematical calculations to determine the right model and balance as we don't ever give "opinions" without the calculations.

We do not select the models for you. We work through the planning process showing you different outcomes and risks based on the combination of strategies. While we will make recommendations as to what we see is appropriate to you, ultimately it is your decision.

Before we invest, we both sign off on an Investment Policy Statement (IPS). This is a formal blueprint as to the model and the constraints we have. If you contact us to change methods or models we will do so after a new IPS is signed. The IPS is our guideline to what we can and cannot do.

You may be holding legacy assets that you have either held for a long period of time, or have large built in taxable gains.

Our first goal is to see if you have concentration risk within these legacy investments. If you have concentration risk and we advise you to either reduce the percentage invested or to totally divest, this is ultimately up to you.

Normally we can figure out how to eliminate the large built in gains but in some cases clients want to hold investments for personal reasons. As an example, a stock given by a grandparent.

In these cases we will review with you all positions before changing and if you have investments you want left out of the remodel then we classify them as:

DNS A Do Not Sell Asset

With a DNS we bring in the investment and then we work the model around it so as to not duplicate the allocation to that sector or category. We will not sell these positions we we also do not take the liability against the investment failing to perform or a complete outright loss.

DNM A Do Not Manage

With a DNM classification we will not only freeze the position from any sale but we will also not bring it into our analysis for over concentration risk or any type of tax planning or issues. You will be responsible for all tax consequences, and risks that fall on that investment including lack of performance, outright failure and full loss as well as any over concentration risk.

Our fee system is very simple.

No hidden charges, and we don't get any hidden compensation from any companies, investment managers, mutual funds or plan sponsors.

Everything we do is 100% transparent and shows on your custodians statement. It's very easy to understand and clearly shown without confusing and hidden codes like many institutions.

Level 1 is comparative with most other financial advisors. The fee ranges from .5 to 1.25% per year depending on how much is under management. We don't overlay or implement any tax strategies. This is most appropriate for those with smaller accounts and have no tax issues and are in the lowest tax rates. We typically will meet once per year to review the investment strategy.

Level 2 is a slightly higher rate but includes investment tax strategies called GAMMA. These include location optimization (identifying the tax type of the investments and arranging it to the correct account such as IRA, ROTH or Regular Account), as well as tax swapping, shifting and low tax distribution strategies. (This does not include any tax planning on anything else other than your investment accounts) This is best suited for those with higher account values than Level 1 and will incur taxation for capital gains, dividends and interest. It is also important for those that have other taxable income and want to reduce the overall tax from investment gains and distributions. We typically will meet twice per year to assess your portfolio and your tax strategy as it applies to the investment plan

Level 3 - Total Wealth Oversight. This is a slightly higher fee than Level 1 or 2 but we integrate all aspects of your financial life into One Wealth Map. We automate the entire plan with tags and alerts so once we set the plan, it will stay on track. We integrate insurance, risk management, investments, distributions, tax and even your asset protection into one place. We will typically meet with you every quarter and will keep your tax plan, your income structure integrated with all other aspects of your life.