APO Financial Services, LLC (“APO”) is a Colorado Limited Liability Company formed on June 1, 2018 owned by John M. Goodhue..
APO provides the following services: Investment Advisory Portfolio Management. APO provides ongoing discretionary portfolio management services to individuals, families and businesses. When providing portfolio management services, the firm not only makes recommendations related to investments, but also implements these recommendations and provides ongoing monitoring and reporting. Each portfolio is tailored to the individual needs of a particular client (whether an individual, a family or a business) through an assessment conducted prior to an engagement. Clients may impose restrictions related to the level of discretion granted, the types of investments used, etc. Clients that determine to engage APO on a non-discretionary investment basis must be willing to accept that APO cannot affect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event of a market correction during which the client is unavailable, APO will be unable to effect any account transactions (as it would for its discretionary clients) without first obtaining the client’s consent. Terms of an actual engagement, including description of service, limitations and restrictions, fees, etc., are all detailed before any engagement begins in a written client agreement.
Financial Planning and Consulting Services. APO provides financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a fixed fee or hourly fee basis. Prior to engaging APO to provide planning or consulting services, clients are required to enter into a Financial Planning and Consulting Agreement with APO setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to APO commencing services. The client always retains absolute discretion over all such implementation decisions and always has the right whether to accept or reject any recommendation from APO. Please Note: It remains the client’s responsibility to promptly notify APO if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising APO’s previous recommendations and/or services.
As indicated above, APO may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc.
Neither APO nor its representatives serve as an attorney or accountant, and no portion of its services should be construed as legal or accounting advice. Accordingly, APO does not prepare estate planning documents or tax returns. To the extent requested by a client, APO may recommend the services of legal or tax professionals. Clients are reminded that they always have the right to decide whether to engage the services of any such recommended professional.
Implementation of Financial Planning Recommendations. The client retains absolute discretion over all such implementation decisions and always has the right whether to accept or reject any recommendation made by APO or its representatives or any affiliated entities. Clients may be offered insurance products through two of APO’s affiliates, Asset Protect One, Inc.
and/or APO Financial, Inc., Colorado licensed insurance agencies. In the event clients purchase any offered insurance products, commissions will be paid to the above insurance agencies and the licensed representative, which is a conflict of interest. APO will exercise its fiduciary duty in regard to any sale of such insurance products and clients are reminded that they always have the right to decide whether to act on any such recommendations and to purchase any insurance products from anyone they so choose. Such recommendations will only be made in the clients best interest.
Pension Consulting Services. APO may offer consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: ● identifying investment objectives and restrictions; ● providing guidance on various assets classes and investment options; ● recommending money managers to manage plan assets in ways designed to achieve ● objectives; ● monitoring performance of money managers and investment options and making recommendations for changes; ● recommending other service providers, such as custodians, administrators and broker dealers; ● creating a written pension consulting plan; and ● services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants.
Investment Advice Relating to Retirement Accounts. When APO provides investment advice regarding a retirement plan account or individual retirement account, APO is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable. 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.
As such, APO is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”).
Under this special rule’s provisions, APO 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.
Retirement Rollovers Conflict of Interest. To the extent APO recommends you roll over your account from a current retirement plan account to an individual retirement account managed by APO, please know that APO and our investment adviser representatives have a conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by APO. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by APO.
Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in APO receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by APO and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover.
When providing advice to your regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of APO or our affiliated personnel.
The client has options other than rolling over the assets to an account managed by APO, including managing the assets without the assistance of APO as part of their current employer sponsored retirement plan or by rolling over the assets to an IRA. In both cases, the client would not be required to pay additional fees to APO and the client would be responsible for managing the assets on their own. The Client always has the right to decide whether or not to rollover retirement plan assets to an account managed by APO.
Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that may be utilized by APO independent of engaging APO as an investment. However, if a prospective client determines to do so, he/she will not receive APO’s initial and ongoing investment services.
Please Note: In addition to APO’s investment fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses).
Portfolio Activity. APO has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment services, APO will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when APO determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by APO will be profitable or equal any specific performance level(s) Please Note: Cash Positions. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), APO may maintain cash positions for defensive purposes. All cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating APO‘s fee.
Client Obligations. In performing its services, APO shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify APO if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising APO’s previous recommendations and/or services. APO shall provide investment services specific to the needs of each client. Prior to providing investment services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, APO shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on APO’s services.
Educational Workshops. APO provides educational seminar sessions for those desiring information on personal finance and investing. Topics may include issues related to general financial planning, educational funding, estate planning, retirement strategies, insurance planning and various other current economic or investment topics.
Wrap Program. APO does not participate in a wrap fee program.
Assets Under Management. As of March 6, 2023 total assets under management are $100,278,222 on a discretionary basis. No assets are advised on a non-discretionary basis.