4a: Firm Description
SMB Financial Services, Inc., was established in February 2003 by Bruce E. Porter and Tim L. Porter. Tim L.
Porter purchased the firm from Bruce E. Porter in 2021. SMB was registered as an investment advisor in the
State of Oregon in July of 2010 and in the state of Washington in July 2011. SMB Financial Services, Inc.,
transitioned to an SEC-registered firm in April of 2019. The firm’s main office is located in Portland, Oregon.
4a1: Principal Members
Tim L. Porter, President and Chief Compliance Officer. Mr. Porter may be contacted by email at
tim@smb.financial or by telephone at (503) 387-3222.
4b: Types of Advisory Services
SMB Financial Services offers a wide range of investment advisory services to its clients. We tailor our advice
and services to your objectives, means and timelines. We will create a document that will precisely define
the types of services we are providing, our role and how we may carry out those services for you.
Discretionary Asset Management
SMB Financial Services (“SMB Financial Services”) will emphasize continuous personal client contact and
interaction in providing discretionary investment supervisory services. Further, SMB Financial Services will
work with its clients to identify their investment goals and objectives, as well as risk tolerance, in order to
create an initial portfolio allocation designed to complement their clients’ financial goals and objectives.
SMB Financial Services may create a portfolio, consisting of, but not limited to individual stocks or bonds,
exchange traded funds, no-load funds and/or load-waived funds.
Each portfolio will be initially designed to meet a particular investment goal, which SMB Financial Services
has determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been
determined, SMB Financial Services will review the portfolio at least quarterly and if necessary, rebalance
the account based upon the client’s individual needs, stated goals and objectives. However, each client will
have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio.
SMB Financial Services’ strategy, generally, will be to seek to meet client investment objectives while
providing clients with access to personal advisory services on at least an annual basis, or more often,
depending upon prior agreement. Client pays the applicable transaction/execution costs associated with
securities trading.
Financial Planning
The Advisor will work with the Client using the following process to determine whether and how the Client
can meet their financial goals:
(a) Gather the data necessary to define the Client’s goals, needs, priorities, and quantitative financial
information relevant to the specific planning areas selected below:
Retirement Planning – including target range of desired spending levels, retirement timeframe and
duration, and asset levels / savings needed to meet those objectives
Education Funding – including estimates of future costs, alternative funding strategies, and savings
needed to meet those objectives
Investment Planning – including a risk tolerance assessment, review of current portfolio holdings
and development of asset allocation recommendations
Other Goal Areas or Projects (Described as “additional financial planning services” on Schedule A)
(b) Analyze the information provided and evaluate the extent to which the goals, needs and priorities can
be met with the current resources and course of action.
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(c) Develop alternatives and recommendations as appropriate to the Client’s situation and present those
recommendations to the Client along with suggestions for steps to take in implementing the
recommendations.
The client is encouraged to review his or her plans on a regular basis.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets
from your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account
(collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP
IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge
you
an asset-based fee as set forth in the advisory agreement you executed with our firm. This
creates a conflict of interest because it creates a financial incentive for our firm to recommend
the rollover to you (i.e., receipt of additional fee-based compensation). You are under no
obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete
the rollover, you are under no obligation to have the assets in an IRA managed by our firm.
Due to the foregoing conflict of interest, when we make rollover recommendations, we operate
under a special rule that requires us to act in your best interests and not put our interests 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
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company
plan. Also, current employees can sometimes move assets out of their company plan before
they retire or change jobs. In determining whether to complete the rollover to an IRA, and to
the extent the following options are available, you should consider the costs and benefits of a
rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance
of understanding the differences between these types of accounts, we will provide you with a
written explanation of the advantages and disadvantages of both account types and the basis
for our belief that the rollover transaction we recommend is in your best interests.
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As an alternative to providing you with a rollover recommendation, we may instead take an
entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive
Bulletin 96-1. Under this approach, our role will be limited only to providing you with general
educational materials regarding the pros and cons of rollover transactions. We will make no
recommendation to you regarding the prospective rollover of your assets and you are advised
to speak with your trusted tax and legal advisors with respect to rollover decisions. As part of
this educational approach, we may provide you with materials discussing some or all of the
following topics: the general pros and cons of rollover transactions; the benefits of retirement
plan participation; the impact of pre-retirement withdrawals on retirement income; the
investment options available inside your Plan Account; and high level discussion of general
investment concepts (e.g., risk versus return, the benefits of diversification and asset
allocation, historical returns of certain asset classes, etc.). We may also provide you with
questionnaires and/or interactive investment materials that may provide a means for you to
independently determine your future retirement income needs and to assess the impact of
different asset allocations on your retirement income. You will make the final rollover decision.
4c: Client Tailored Relationships and Restrictions
As a fiduciary, SMB Financial Services always acts solely in your best interests. Your portfolio is customized
based on your investment objectives. You may make requests or make suggestions regarding the
investments made in your portfolio. Restrictions on trading which, in our opinion, are not in your best
interest cannot be honored and if forced may result in the termination of our agreement.
Similarly, you are under no obligation to act upon SMB Financial Services' or associated person's
recommendations. If you elect to act on any of the recommendations, you are under no obligation to effect
the transaction through SMB Financial Services or its associated person when the person is an agent with a
licensed broker-dealer or through any associate or affiliate of such person.
4d: Wrap Fee Program
SMB Financial Services does not offer a Wrap Fee Program.
4e: Assets under Management (AUM)
SMB Financial Services, as of December 31, 2023, has $138,032,713 in discretionary Assets Under
Management.