General Information The Adviser was formed in 2015 and provides financial planning, portfolio management, and general consulting services to its clients. At the outset of each client relationship, the Adviser spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and reviewing options for the client. Based on its reviews, the Adviser generally develops with each client an understanding of the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile”), as well as, the client’s investment objectives and guidelines (the “Investment Plan”).
The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments the Adviser will make on behalf of the client in order to meet those goals. The elements of the Financial Profile and the Investment Plan are discussed at least annually with each client, but are not necessarily written documents.
Where the Adviser provides general consulting services, the Adviser will work with the client to prepare an appropriate summary of the specific project(s) to the extent necessary or advisable under the circumstances.
Financial Planning The Adviser offers limited financial planning services to those clients in need of such service in conjunction with Portfolio Management services. The Adviser’s limited financial planning services normally address areas such as general cash flow planning, retirement planning, and insurance analysis. The goal of this service is to assess the financial circumstances of the client in order to more effectively develop the client’s Investment Plan. Financial Planning is generally not offered as a stand-alone service or for a separate fee, but is typically provided to clients in conjunction with the management of the portfolio.
Portfolio Management As described above, at the beginning of a client relationship, the Adviser meets with the client, gathers information, and performs research and analysis as necessary to understand the client’s Investment Plan.
To implement the client’s Investment Plan, the Adviser will manage the client’s investment portfolio on a discretionary or a non-discretionary basis pursuant to an investment advisory agreement with the client. As a discretionary investment adviser, the Adviser will have the authority to supervise and direct the portfolio without prior consultation with the client. Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the performance of the portfolio. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio.
Notwithstanding the foregoing, clients may impose certain

written restrictions on the Adviser in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of the Adviser.
SeparateAccountManagers When appropriate and in accordance with the Investment Plan for a client, the Adviser may utilize one or more Separate Account Managers (each, a “Manager”). Having access to various Managers offers a wide variety of manager styles, and offers clients the opportunity to utilize more than one Manager if necessary to meet the needs and investment objectives of the client. The Adviser will usually select the Manager(s) it deems most appropriate for the client. Factors that the Adviser considers in recommending/selecting Managers generally includes the client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing, and research.
The Manager(s) will generally be granted discretionary trading authority to provide investment supervisory services for the portfolio. Under most circumstances, the Adviser retains the authority to terminate the Manager’s relationship or to add new Managers without specific client consent.
In any case, with respect to assets managed by a Manager, the Adviser’s role will be to monitor the overall financial situation of the client, to monitor the investment approach and performance of the Manager(s), and to assist the client in understanding the investments of the portfolio.
General Consulting In addition to the foregoing services, the Adviser may provide general consulting services to clients, which may include other investment adviser clients. For clients who are individuals, these services are generally provided on a project basis, and may include, without limitation, minimal cash flow planning for certain events such as education expenses or retirement, estate planning analysis, income tax planning analysis and review of a client’s insurance portfolio, as well as other matters specific to the client as and when requested by the client and agreed to by the Adviser. The scope and fees for consulting services will be negotiated with each client at the time of engagement for the applicable project.
Principal Owner Matthew Fuller is the sole principal owner of the Adviser.
Type and Value of Assets Currently Managed As of December 31, 2023, the Adviser had approximately $695,707,764 in discretionary regulatory assets under management and $12,099,115 in non-discretionary regulatory assets under management.