To approximately how many clients* for whom you do not have regulatory assets under management did you provide investment advisory services during your most recently completed fiscal year?

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Approximately what percentage of your clients are non-United States persons* and have a primary permanent address located in a foreign country?

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What is the approximate amount of your total regulatory assets under management attributable to clients who are non United States persons*?

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Indicate the approximate number of your clients and the amount of your regulatory assets under management (AUM)* attributable to each of the following types of clients.

AUM - Assets that an advisor or institution actively manages on behalf of a client. The advisor has the authority to make investment decisions and execute trades on these assets. AUM can be discretionary or non-discretionary, but the crux of the determination is that the RIA has trading authority.

AUA - Assets that an advisor provides advice on, but does not have the authority to make investment decisions or execute trades for. The advisor can still charge a fee as a percentage of the assets. AUA can include assets such as mutual funds, stocks, bonds, and other investment accounts. A common example of an AUA is a 401(k) account over which the RIA does not have trading authority.

When distinguishing between AUM and AUA, it's important to be clear about the difference in services being provided. Ask, are you managing, or just advising on the account?

Please note: The total amount of regulatory assets under management reported in this question must equal the total amount of regulatory assets under management reported in Step 6.

Type of Advisory Client

Number of Households*

Regulatory AUM

Individuals*:

High Net Worth Individuals*:

Banking or Thrift Institutions:

Investment Companies:

Business Development Companies:

Pooled Investment Vehicles:

Pension & Profit-Sharing Plans*:

Charitable Organizations:

State or Municipal Government Entities*:

Other Investment Advisers:

Insurance Companies:

Sovereign Wealth Funds & Foreign Official Institutions:

Corporations or Other Businesses Not Listed Above:

Other:

Total:

For additional guidance or definitions of key terms, simply hover your mouse over the text containing an asterisk (*). This interactive feature provides quick access to relevant information.

What is the amount of your regulatory AUM* and the total number of accounts?

Please note: The total amount of regulatory AUM reported must equal the total AUM reported in Step 2.

Type of Account

U.S. Dollar Amount

Total Number of Accounts*

Discretionary:

Non-Discretionary*:

Total:

For additional guidance or definitions of key terms, simply hover your mouse over the text containing an asterisk (*). This interactive feature provides quick access to relevant information.

The total Discretionary and Non-Discretionary AUM must equal the total Regulatory AUM reported in Step 5.

If you provide financial planning services, how many clients* did you provide these services to during your last fiscal year?

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Do you participate in a Wrap Fee Program? 

Provide the percentage of AUM* for each of the following asset types.
The total must equal 100%.

Please round percentages to the nearest whole number.

Asset Type

As of December 31st

Exchange-Traded Equity Securities*:

Non-Exchange-Traded Equity Securities*:

U.S. Government/Agency Bonds:

U.S. State & Local Bonds*:

Sovereign Bonds*:

Investment Grade Corporate Bonds:

Non-Investment Grade Corporate Bonds*:

Derivatives*:

Securities Issued by Registered Investment Companies or Business Development Companies*:

Securities Issued by Pooled Investment Vehicles*:

Cash & Cash Equivalents*:

Other:

Total:

For additional guidance or definitions of key terms, simply hover your mouse over the text containing an asterisk (*). This interactive feature provides quick access to relevant information.

Are you an adviser to any private fund?

Please list the custodian's name and the amount (in dollars) held.

Please Note: You do not need to report AUM for custodians holding less than 10%. Please only list custodians who individually hold more than 10% of the Firm's total AUM as of Dec 31, 2024.

Custodian's Name

Amount

Do you have custody of any advisory clients’ cash or bank accounts or securities?

Note: If you have SLOAs on file for clients to transfer funds to third parties, these accounts and client calculations need to be included.

If you have custody with Schwab, you should also include SLOAs on file for clients to transfer funds to joint accounts.

If you are a Florida state-registered advisor, you need to calculate the amount of assets and number of clients from which you automatically deduct fees.

If you have full custody and are required to have a surprise audit each year, please answer “yes” to this question and provide calculations.

In connection with advisory services you provide to clients, do any of your related persons* have custody of any of your advisory clients' cash, bank accounts, or securities?

How many separate custodians have custody of these assets?

If you are filing your annual updating amendment and were subject to a surprise examination by an independent public accountant during your last fiscal year, provide the date the examination commenced:

Note: This question is not applicable if the Firm was not subject to a surprise audit. Please skip this question if it is not applicable.

Is there any additional information or specific details you would like to share with us at this time?

Your Form ADV update is now complete.

Upon clicking submit, a report summary will be emailed to your team.

To delve into the findings and address any questions, we recommend scheduling an annual review meeting with your AdvisorLaw team.