Our firm provides 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 and has
been in business as an investment adviser since 2007. Our firm is owned by Mr. Jose E. Palafox and
Mr. William G. Friebel.
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”), mutual funds and other public 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, objectives, and market and economic conditions.
Asset Management on the Pontera Platform:
Our firm has entered into a service agreement with Pontera (formerly FeeX Inc.) to provide asset
management services for accounts held away from our primary custodial affiliations. Through this, we
are able to create a portfolio, consisting of the securities/investment opportunities available depending
on the type of held away account being managed by our firm. The Pontera platform allows us to avoid
being considered to have custody of Client funds since we do not have direct access to Client log-in
credentials to affect trades. We are not affiliated with the platform in any way and receive no
compensation from them for using their platform. A link will be provided to the Client allowing them to
connect an account(s) to the platform. The client’s individual investment strategy is tailored to their
specific needs and may include some or all of the securities made available. 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.
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.
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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, Cost Segregation Study, 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 & Monitoring:
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 may 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.
Provider Review & Selection – Assist in evaluating plan recordkeepers, third-party
administrators (TPAs) and other retirement plan service providers.
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.
Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, financial wellness and
general guidance on allocation strategies.
In providing services for retirement plan consulting, our firm does not provide 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
ADV Part 2A – Firm Brochure Page 6 Starfox Financial Services, LLC
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
Plan participants are responsible for placing and implementing their own investment
allocations/choices through the recordkeepers system or application.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Asset Management clients. General
investment advice will be offered to our Financial Planning & Consulting and Retirement Plan
Consulting clients. Each Asset Management client may 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
Our firm manages $215,117,005 on a discretionary basis and $37,752,377 on a non-discretionary
basis as of December 31, 2023.