Item 1: Cover Page 

Concinnus Financial, Inc  

Form ADV Part 2A – Firm Brochure 

509-220-1895 

www.concinfin.com 

Dated August 9, 2021 

This Brochure provides information about the qualifications and business practices of Concinnus Financial Inc, “Concinnus”. If you have any questions about the contents of this Brochure, please contact us at 509-220-1895. 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. 

 

Concinnus Financial Inc is registered as an Investment Adviser with the State of Idaho. Registration of an Investment Adviser does not imply any level of skill or training. 

 

Additional information about Concinnus is available on the SEC’s website at www.adviserinfo.sec.gov which can be found using the firm’s identification number 218515. 

Item 2: Material Changes 

 

Material changes since the last filing of this Form ADV Part 2A include the following: 

 

Item 4: Advisory Business – Concinnus Financial now manages $20.2 million in assets on a discretionary basis. At the time of the last filing of Form ADV Part 2A, Concinnus managed $11.7 million in assets on a discretionary basis. 

Item 3: Table of Contents

 

Contents 

 

Item 1: Cover Page

Item 2: Material Changes 

Item 3: Table of Contents 

Item 4: Advisory Business

Item 5: Fees and Compensation

Item 6: Performance-Based Fees and Side-By-Side Management

Item 7: Types of Clients

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss

Item 9: Disciplinary Information

Item 10: Other Financial Industry Activities and Affiliations

Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

Item 12: Brokerage Practices

Item 13: Review of Accounts

Item 14: Client Referrals and Other Compensation

Item 15: Custody

Item 16: Investment Discretion

Item 17: Voting Client Securities 

Item 18: Financial Information

Item 4: Advisory Business

 

Description of Advisory Firm

 

Concinnus Financial Inc is registered as an Investment Adviser with the States of Idaho, Washington, and Arizona. We were founded in October 2014 and registered as an Investment Adviser in June of 2015. Nicholas Rossolillo, Eric Martin, and Molly Martin are the owners of Concinnus Financial. As of March 15, 2021, we manage $20.2 million in assets on a discretionary basis.

 

Types of Advisory Services 

 

Investment Management Services

 

We are in the business of managing individually tailored investment portfolios. Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation target. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may also review and discuss a client’s prior investment history, as well as family composition and background. We provide investment management services on a discretionary basis, having the authority to determine the type and amount of securities to be bought and sold on behalf of the client, and will not give advance notice or seek the client’s consent for any changes to the portfolio. We provide updates on our research and advisory services free of charge on our website, concinnusfin.com. 

 

Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Fees pertaining to this service are outlined in Item 5 of this brochure. 

 

Financial Planning 

 

Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information and analysis will be considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. 

 

In general, the financial plan will address any or all of the following areas of concern. The client and advisor will work together to select the specific areas to cover. These areas may include, but are not limited to, the following: 

 

  • Business Planning: We provide consulting services for clients who currently operate their own business, are considering starting a business, or are planning for an exit from their current business. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. 

 

  • Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. 

 

  • Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. 

 

  • Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. 

 

  • Investment Analysis: This may involve developing an asset allocation strategy to meet clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. 

 

  • Retirement Planning: Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (i.e., working longer, saving more, spending less, taking more risk with investments). 

        If you are near retirement or already retired, advice may be given on appropriate distribution strategies to                      minimize the likelihood of running out of money or having to adversely alter spending during your retirement                years. 

  • Risk Management: A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long‐term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance (“self‐insuring”). 

 

  • Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. 

 

       We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and           we may provide you with contact information for accountants or attorneys who specialize in this area if you wish           to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax                   professional with your approval. 

 

  • Tax Preparation: In addition to tax planning strategies, tax preparation for individuals, families, and small businesses. This includes the gathering of all tax documents, inputting onto the corresponding tax forms, and filing at the state and Federal level. 

 

  • 401k Plan and Retirement Plan Consulting: Advice to businesses that have or desire to provide a retirement plan to employees can be provided. These include the best plan for the business, how to structure the plan properly, and best practices on implementation. Education on the plan is given to both the employer and to employees on how the plans work and eligibility requirements. 

 

Client Tailored Services and Client Imposed Restrictions 

 

We offer the same suite of services to all of our clients. However, specific client services are dependent upon the client Investment Policy Statement and risk tolerance questionnaire which outline each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may impose reasonable restrictions on investing in certain securities or types of securities.

 

Publishing of periodicals

 

Nicholas Rossolillo publishes commentary on the stock market and on individual securities through The Motley Fool. As a complimentary service, these articles can be accessed on Concinnus’ website and available to the general public through The Motley Fool’s website. 

 

Wrap Fee Programs

 

We do not participate in wrap fee programs. 

 

Disclosure on Potential Conflicts of Interest 

 

For clients who receive our Financial Planning services, we must state when a conflict exists between the interests of our firm and the interests of our client. The client is under no obligation to act upon our recommendation. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through our firm. 

 

Item 5: Fees and Compensation

 

Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing the investment advisory contract, the investment advisory contract may be terminated by the client within five (5) business days of signing the contract without incurring any advisory fees and without penalty. How we are paid depends on the type of advisory service we are performing. Please review the fee and compensation information below. 

 

Investment Management Services

 

Our standard advisory fee is based on the market value of the assets under management and is 7

calculated as follows: 

 

Account Value                    Annual Advisory Fee

$1 - $500,000                     1.00%

$500,001 and Above          0.75%


 

The annual fees are negotiable and are pro-rated and paid in arrears on a monthly basis. No increase in the annual fee shall be effective without agreement from the client by signing a new agreement or amendment to their current advisory agreement. 

 

Advisory fees are directly debited from client accounts, or the client may choose to pay by check. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time the account was open during the billing period. An account may be terminated with written notice. 

 

In all instances, the Adviser will send the client a written invoice, including the fee, the formula used to calculate the fee, the fee calculation itself, the time period covered by the fee, and, if applicable, the amount of assets under management on which the fee was based and the name of the custodian(s) on your fee invoice. The Adviser will send these to the client concurrent with the request for payment or payment of the Adviser’s advisory fees. We urge the client to compare this information with the fees listed in the account statement. 

 

Financial Planning and Retirement Plan Participant Hourly Fee 

 

All Financial Planning and Retirement Plan Participant services are charged at an hourly rate of $200.00 and a hard estimate of time to be spent and total charges will be provided in advance. The fee may be negotiable in certain cases and is due at the completion of the engagement. In the event of early termination by client any fees for the hours already worked will be due and any completed work, such as completed sections of the financial plan and analysis, will be given to the client. In all instances, we will send clients an invoice including amount of time worked or scope of work completed for a previously agreed upon price. We will send these upon completion of work for the client to review before payment is due. 

 

Other Types of Fees and Expenses 

 

Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs. 

 

Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for client’s transactions and determining the reasonableness of their compensation (e.g., commissions). 

 

We do not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds. 

 

Disclosure Regarding Fees 

 

Please note, lower fees for comparable services may be available from other sources.

 

Item 6: Performance-Based Fees and Side-By-Side Management 

 

We do not offer performance-based fees. 

 

Item 7: Types of Clients 

 

We provide financial planning and investment management services to individuals and high net-worth individuals. We do not have a minimum account size requirement. Additionally, we offer financial planning and education to employer-sponsored retirement plan participants (like 401k, 503b, and 457 account participants). 

 

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss 

 

Our primary methods of investment analysis are fundamental, technical, cyclical and charting analysis. 

 

Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience, and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. 

 

Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick sectors that may outperform market indices. However, there is no assurance of accurate forecasts or that trends will develop in the markets we follow. In the past, there have been periods without discernible trends and similar periods will presumably occur in the future. Even where major trends develop, outside factors like government intervention could potentially shorten them. 

 

Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical method may fail to identify trends requiring action. In addition, technical methods may overreact to minor price movements, establishing positions contrary to overall price trends, which may result in losses. Finally, a technical trading method may under-perform other trading methods when fundamental factors dominate price moves within a given market. 

 

Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and trends based upon business cycles. Economic/business cycles may not be predictable and may have many fluctuations between long term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. 

 

Charting analysis involves the gathering and processing of price and volume information for a particular security. This price and volume information is analyzed using mathematical equations. The resulting data is then applied to graphing charts, which is used to predict future price movements based on price patterns and trends. Charts may not accurately predict future price movements. Current prices of securities may not reflect all information about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. 

 

Material Risks Involved 

 

All investing strategies we offer involve risk and may result in a loss of your original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities and any other investment or security. Material risks associated with our investment strategies are listed below. 

Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. 

 

Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. 

 

Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. 

 

Risks Associated with Securities 

 

Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. 

 

Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks. 

 

Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. 

 

Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the

construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. 

 

Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the complete loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price. 

 

Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which client’s invest. 

 

Item 9: Disciplinary Information 

 

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Concinnus or the integrity of our management. We have no information applicable to this Item. 

 

Item 10: Other Financial Industry Activities and Affiliations 

 

No Concinnus employees are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. 

 

No Concinnus employees are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor. 

 

Concinnus does not have any related parties. As a result, we do not have a relationship with any related parties. 

 

Concinnus only receives compensation directly from clients. We do not receive compensation from any outside source. We do not have any conflicts of interest with any outside party. 

Nicholas Rossolillo writes articles on a freelance basis for The Motley Fool, primarily on individual and stock and market analysis in the technology and consumer goods sector. This takes approximately 10% of his working time but is conducted in accord with Concinnus Financial’s portfolio management services. 

 

Concinnus also operates as a tax preparation firm. Molly Martin is the manager of this business segment. 

 

Disclosure of Material Conflicts 

 

All material conflicts of interest have been disclosed regarding Concinnus, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice. 

 

Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 

 

As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of each client. Our clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. 

 

This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not shield associated persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory clients. A summary of the Code of Ethics' Principles is outlined below. 

 

  • Integrity - Associated persons shall offer and provide professional services with integrity.

 

  • Objectivity - Associated persons shall be objective in providing professional services to clients. 

 

  • Competence - Associated persons shall provide services to clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged. 

 

  • Fairness - Associated persons shall perform professional services in a manner that is fair and reasonable to clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services. 

  • Confidentiality - Associated persons shall not disclose confidential client information without the specific consent of the client unless in response to proper legal process, or as required by law. 

 

  • Professionalism - Associated persons’ conduct in all matter shall reflect credit of the profession.

 

  • Diligence - Associated persons shall act diligently in providing professional services.

 

We will, upon request, promptly provide a complete code of ethics. 

 

Our firm and its “related persons” (associates, their immediate family members, etc.) may buy or sell securities the same as, similar to, or different from, those we recommend to clients for their accounts. A recommendation made to one client may be different in nature or in timing from a recommendation made to a different client. Clients often have different objectives and risk tolerances. At no time, however, will our firm or any related party receive preferential treatment over our clients. 

 

In an effort to reduce or eliminate certain conflicts of interest involving the firm or personal trading, our policy may require that we restrict or prohibit associates’ transactions in specific securities transactions. Any exceptions or trading pre‐clearance must be approved by our Chief Compliance Officer in advance of the transaction in an account, and we maintain the required personal securities transaction records per regulation. 

 

Item 12: Brokerage Practices 

 

Factors Used to Select Custodians and/or Broker-Dealers 

 

Concinnus Financial Inc does not have any affiliation with Broker-Dealers. Specific custodian recommendations are made to clients based on their need for such services. We recommend custodians based on the reputation and services provided by the firm. Our current recommended custodian is Interactive Brokers LLC. 

 

1. Research and Other Soft-Dollar Benefits 

We currently do not receive soft dollar benefits. 

 

2. Brokerage for Client Referrals 

We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 

 

3. Clients Directing Which Broker/Dealer/Custodian to Use 

We do recommend a specific custodian for clients to use, however, clients may custody their assets at a 14

custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute transactions. By allowing clients to choose a specific custodian, we may be unable to achieve most favorable execution of client transactions and this may cost clients money over using a lower-cost custodian. 

 

Aggregating (Block) Trading for Multiple Client Accounts 

 

Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion, regarding particular circumstances and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. 

Item 13: Review of Accounts 

 

Client accounts with the Investment Management Service will be reviewed regularly on a quarterly basis by Nicholas Rossolillo, President and CCO. The account is reviewed with regards to the client’s investment policies and risk tolerance levels. Events that may trigger a special review would be unusual performance, addition or deletions of client imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per client's needs. 

 

Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest. 

 

Concinnus will provide written reports to Investment Management clients on a quarterly basis which will include account performance and market commentary. We urge clients to compare these reports against the account statements they receive from their custodian. 

Item 14: Client Referrals and Other Compensation 

 

We do not receive any economic benefit, directly or indirectly from any third party for advice rendered to our clients. Nor do we directly or indirectly compensate any person who is not advisory personnel for client referrals. 

 

Item 15: Custody 

 

Concinnus does not accept custody of client funds. Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains the client's investment assets. We urge you to carefully review such statements and compare such official custodial records to the account statements or reports that we may provide to you. Our statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. 

 

For client account in which Concinnus directly debits their advisory fee: 

    i.     Concinnus will send a copy of its invoice to the custodian at the same time that it sends the client a copy. 

    ii.    The custodian will send at least quarterly statements to the client showing all disbursements for the account,                    including the amount of the advisory fee. 

    iii.   The client will provide written authorization to Concinnus, permitting them to be paid directly for their                              accounts held by the custodian. 

 

Item 16: Investment Discretion 

 

For those client accounts where we provide investment management services, we maintain discretion over client accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold. Investment discretion is explained to clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the client will execute a Limited Power of Attorney which will grant our firm discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory contract and signed by the client. 

Item 17: Voting Client Securities 

 

We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure. 

 

In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies. 

 

Item 18: Financial Information 

 

Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to clients, and we have not been the subject of a bankruptcy proceeding. 

 

We do not have custody of client funds or securities or require or solicit prepayment of more than $500 in fees per client six months in advance.