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 Texas in
2018. Our firm is wholly owned by Dennis W. Stavinoha.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm or
its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory practice
with open lines of communication for many different types of clients to help meet their financial goals
while remaining sensitive to risk tolerance and time horizons. Working with clients to understand their
investment objectives while educating them about our process facilitates the kind of working relationship
we value.
Types of Advisory Services Offered
Asset Management
As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds,
exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments.
The client’s individual investment strategy is tailored to their specific needs and may include some or all of
the previously mentioned securities. Portfolios will be designed to meet a particular investment goal,
determined to be suitable to the client’s circumstances. 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.
Business Consulting
As part of our Business Consulting service, businesses and other clients will be provided a variety of
consultation services regarding the management of their financial resources. This consultation is based
on our firm’s analysis of the client and/or business’ current situation, goals, and objectives. This service
generally includes general recommendations for a course of activity and often contains specific actions to
be taken by the client and/or business. This consulting service may encompass Business Financial
Planning, Corporate Tax Planning, Mortgage/Debt Coordination, Business Sale/Acquisition, Estate
Planning, Personal Financial Planning, Business Succession Planning, Insurance Analysis, Personal Tax
Planning, Cash Flow Analysis/Projection, Investment Planning, Real Estate Analysis, Charitable Planning,
Lines of Credit Analysis, Retirement Planning, Corporate Structure, and Mortgage/Debt Analysis.
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. Upon client
request, our firm provides a summary of observations and recommendations for the planning or
consulting aspects of this service.
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.
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 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, 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.
Retirement Plan Consulting
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis.
Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring
and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor
dictate, areas of advising could include: investment options, plan structure and participant education.
Retirement Plan Consulting services typically include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad strategies
to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment
options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and notify the
client in the event of over/underperformance and in times of market volatility.
In providing services for retirement plan consulting, our firm does not provide any advisory services with
respect to the following types of assets: employer securities, real estate (excluding real estate funds and
publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments,
or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services
shall be in compliance with the applicable state laws regulating retirement consulting services. This applies
to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan,
and our firm accepts appointment to provide services to such accounts, our firm acknowledges its
fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement
Plan Consulting Agreement with respect to the provision of services described therein.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries 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 we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Referrals to Third Party Money Managers
Our firm utilizes the services of a third-party money manager for the management of client accounts.
Investment advice and trading of securities will only be offered by or through the chosen third party money
manager. Our firm will not offer advice on any specific securities or other investments in connection with this
service. Prior to referring clients, our firm 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.
Our firm will periodically review third party money manager reports provided to the client at least
annually. Our firm will contact clients from time to time in order to review their financial situation and
objectives; communicate information to third party money managers as warranted; and, assist the client
in understanding and evaluating the services provided by the third party money manager. Clients will be
expected to notify our firm of any changes in their financial situation, investment objectives, or account
restrictions that could affect their financial standing.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Asset Management and Comprehensive Portfolio
Management clients. General investment advice will be offered to our Financial Planning & Consulting,
Retirement Plan Consulting, and Referrals to Third Party Money Management clients.
Each Asset Management and 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
As of December 31, 2023, our firm manages a total of $290,733,000 on a discretionary basis.