A. Live Oak Wealth Advisory Group, LLC d/b/a Jobes Solo Investment Group
(“LOWAG”) is a limited liability company formed on August 12, 2010 in the State
of Texas. LOWAG became registered as an Investment Adviser Firm in September
2010. The Firm is owned by Jonathan Solo. Jonathan Solo is the Firm’s Managing
Member.
B. As discussed below, LOWAG offers to its clients (individuals, high net worth
individuals, trusts, and estates) investment advisory services, and, to the extent
specifically requested by a client, financial planning and related consulting services.
INVESTMENT ADVISORY SERVICES
The client can determine to engage LOWAG to provide discretionary and/or non-
discretionary investment advisory services on a fee basis as discussed at Item 5
below. LOWAG’s annual investment advisory fee is based upon a percentage (%)
of the market value of the assets placed under the Firm’s management. Before
engaging LOWAG to provide investment advisory services, clients are generally
required to enter into an Investment Advisory Agreement with LOWAG setting
forth the terms and conditions of the engagement (including termination),
describing the scope of the services to be provided, and the fee that is due from the
client. To commence the investment advisory process, LOWAG will ascertain each
client’s investment objective(s) and then allocate the client’s assets consistent with
the client’s designated investment objective(s). Once allocated, LOWAG provides
ongoing supervision of the account(s).
For individual retail (i.e., non-institutional) clients, LOWAG's annual investment
advisory fee shall include investment advisory services, and, to the extent
specifically requested by the client, financial planning and consulting services. In
the event that the client requires extraordinary planning and/or consultation services
(to be determined in the sole discretion of LOWAG), LOWAG may determine to
charge for such additional services, the dollar amount of which shall be set forth in
a separate written notice to the client.
FINANCIAL PLANNING AND CONSULTING SERVICES
To the extent requested by a client, LOWAG may determine to provide financial
planning and/or consulting services (including investment and non-investment
related matters, including estate planning, insurance planning, etc.) on a stand-alone
separate fee basis. Prior to engaging LOWAG to provide planning or consulting
services, clients are generally required to enter into a Financial Planning and
Consulting Agreement, 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 LOWAG commencing services.
If requested by the client, LOWAG may recommend the services of other
professionals for implementation purposes. (See disclosure at Item 10 C.8). The
client is under no obligation to engage the services of any such recommended
professional. The client retains absolute discretion over all such implementation
decisions and is free to accept or reject any recommendation from LOWAG. Please
Note: If the client engages any such recommended professional, and a dispute
arises thereafter relative to such engagement, the engaged professional shall remain
responsible for resolving any such dispute with the client the client agrees to seek
recourse exclusively from and against the engaged professional. At all times, the
engaged licensed professional([s)] (i.e., attorney, accountant, insurance agent, etc.),
and not LOWAG, shall be responsible for the quality and competency of the
services provided. Please Also Note: It remains the client’s responsibility to
promptly notify LOWAG if there is ever any change in his/her/its financial situation
or investment objectives for the purpose of reviewing/ evaluating/revising
LOWAG’s previous recommendations and/or services.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting and
Implementation Services. As indicated above, to the extent requested by the client,
LOWAG may provide financial planning and related consulting services regarding
non-investment related matters, such as estate planning, tax planning, insurance,
etc. LOWAG does not serve as a law firm or accounting firm, and no portion of its
services should be construed as legal or accounting services. Accordingly, LOWAG
does not prepare estate planning documents or tax returns. To the extent requested
by a client, LOWAG may recommend the services of other professionals for certain
non-investment implementation purposes (i.e. attorneys, accountants, insurance
agents, etc.). The client is under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from
LOWAG and/or its representatives. Please Note: If the client engages any
recommended unaffiliated professional, and a dispute arises thereafter relative to
such engagement, the client agrees to seek recourse exclusively from and against
the engaged professional. Please Also Note- Conflict of Interest: LOWAG’s
Chief Compliance Officer, Jonathan Solo, remains available to address any
questions that a client or prospective client may have regarding the above
conflict of interest.
Please Note: Retirement Rollovers Potential for Conflict of Interest: A client or
prospective client leaving an employer typically has four options regarding an
existing retirement plan (and may engage in a combination of these options): (i)
leave the money in the former employer’s plan, if permitted, (ii) roll over the assets
to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll
over to an Individual Retirement Account (“IRA”), or (iv) cash out the account
value (which could, depending upon the client’s age, result in adverse tax
consequences). If LOWAG recommends that a client roll over their retirement plan
assets into an account to be managed by LOWAG, such a recommendation creates
a conflict of interest if LOWAG will earn new (or increase its current) compensation
as a result of the rollover. If LOWAG provides a recommendation as to whether a
client should engage in a rollover or not (whether it is from an employer’s plan or
an existing IRA), LOWAG is acting as a fiduciary 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. No client is under any
obligation to roll over retirement plan assets to an account managed by LOWAG,
whether it is from an employer’s plan or an existing IRA. LOWAG’s Chief
Compliance Officer, Jonathan Solo, remains available to address any
questions that a client or prospective client may have regarding the potential
for conflict of interest presented by such rollover recommendation.
Separately Managed Account Programs. LOWAG may allocate (and/or
recommend that the client allocate) a portion of a client’s investment assets among
affiliated Separately Managed Account programs, including Interactive Brokers
Money Manager Marketplace, in accordance with the client’s designated
investment objective(s). In such situations, the Separately Managed Account
Manager shall have day-to-day responsibility for the active discretionary
management of the allocated assets. LOWAG shall continue to render investment
advisory services to the client relative to the ongoing monitoring and review of
account performance, asset allocation and client investment objectives. Factors
which LOWAG shall consider in recommending Separately Managed Account
programs include the client’s designated investment objective(s) as applied to the
Separately Managed Account program: management style, performance,
reputation, financial strength, reporting, pricing, and research.
Independent Managers. LOWAG may allocate (and/or recommend that the client
allocate) a portion of a client’s investment assets among unaffiliated independent
investment managers (“Independent Manager(s)”) in accordance with the client’s
designated investment objective(s). In such situations, the Independent Manager(s)
will have day-to- day responsibility for the active discretionary management of the
allocated assets. LOWAG will continue to render investment supervisory services
to the client relative to the ongoing monitoring and review of account performance,
asset allocation and client investment objectives.
LOWAG generally considers the following factors when recommending
Independent Manager(s): the client’s designated investment objective(s),
management style, performance, reputation, financial strength, reporting, pricing,
and research. The investment management fees charged by the designated
Independent Manager(s) are exclusive of, and in addition to, LOWAG’s ongoing
investment advisory fee, which will be disclosed to the client before entering into
the Independent Manager engagement and/or subject to the terms and conditions of
a separate agreement between the client and the Independent Manager(s).
Account Aggregation Platform. LOWAG may provide its clients with access to
one or more online account aggregation platforms (the “Platforms”). The Platforms
allows a client to view their complete asset allocation, including those assets that
LOWAG does not manage (the “Excluded Assets”). LOWAG does not provide
investment management, monitoring, or implementation services for the Excluded
Assets. Unless otherwise specifically agreed to, in writing, LOWAG’ service
relative to the Excluded Assets is limited to reporting only. Therefore, LOWAG
shall not be responsible for the investment performance of the Excluded Assets.
Rather, the client and/or their advisor(s) that maintain management authority for
the Excluded Assets, and not LOWAG, shall be exclusively responsible for such
investment performance. Without limiting the above, the LOWAG shall not be
responsible for any implementation error (timing, trading, etc.) relative to the
Excluded Assets. The client may choose to engage LOWAG to manage some or
all of the Excluded Assets pursuant to the terms and conditions of an Investment
Advisory Agreement between LOWAG and the client. The Platforms may also
provide access to other types of information and applications including financial
planning concepts and functionality, which should not, in any manner whatsoever,
be construed as services, advice, or recommendations provided by LOWAG.
Finally, LOWAG shall not be held responsible for any adverse results a client may
experience if the client engages in financial planning or other functions available
on the Platforms without LOWAG’ assistance or oversight.
Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange
traded funds are available directly to the public. Therefore, a prospective client can
obtain many of the funds that may be utilized by LOWAG independent of engaging
LOWAG as an investment advisor. However,
if a prospective client determines to
do so, he/she will not receive LOWAG’s initial and ongoing investment advisory
services.
In addition to LOWAG’s investment advisory 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).
Variable Annuity Sub-divisions. LOWAG may also render discretionary
investment management services to clients relative to variable annuity products that
they may own. In so doing, LOWAG directs the allocation of client assets among the
various mutual fund sub-divisions which comprise the variable annuity product based
upon the investment objectives of the client.
Bitcoin, Cryptocurrency, and Digital Assets. For clients who want exposure to
cryptocurrencies, including Bitcoin, LOWAG will consider investment in
corresponding exchange traded securities, or an allocation to separate account
managers and/or private funds that provide cryptocurrency exposure.
Cryptocurrencies are digital assets that can be used to buy goods and services and
use an online ledger with strong cryptography (i.e., a method of protecting
information and communications through the use of codes) to secure online
transactions. Unlike conventional currencies issued by a monetary authority,
cryptocurrencies are generally not controlled or regulated, and their price is
determined by the supply and demand of their market. Cryptocurrency is currently
considered to be a speculative investment. The speculative nature of
cryptocurrencies notwithstanding, LOWAG may (but is not obligated to) utilize
crypto exposure in one or more of its asset allocation strategies for diversification
purposes. Please Note: Investment in cryptocurrencies is subject to the potential for
liquidity constraints, extreme price volatility and complete loss of principal. Notice
to Opt Out: Clients can notify LOWAG, in writing, to exclude cryptocurrency
exposure from their accounts. Absent the LOWAG’s receipt of such written notice
from the client, LOWAG may (but is not obligated to) utilize cryptocurrency as part
of its asset allocation strategies for client accounts.
Portfolio Activity. LOWAG has a fiduciary duty to provide services consistent
with the client’s best interest. As part of its investment advisory services, LOWAG
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, fund manager tenure, style drift, 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 LOWAG determines that changes to a
client’s portfolio are neither necessary nor prudent. Clients nonetheless remain
subject to the fees described in Item 5 below during periods of account inactivity
Cash Positions. LOWAG continues to treat cash as an asset class. As such, unless
determined to the contrary by LOWAG, all cash positions (money markets, etc.)
shall continue to be included as part of assets under management for purposes of
calculating LOWAG’s advisory fee. 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), LOWAG may maintain cash
positions for defensive purposes. In addition, while assets are maintained in cash,
such amounts could miss market advances. Depending upon current yields, at any
point in time, LOWAG’s advisory fee could exceed the interest paid by the client’s
money market fund.
Research Signal Provider or Model Provider Arrangements. LOWAG, through
its Quant Strat division, provides research signal provider and investment models
to unaffiliated family offices. Research Signal Provider or Model Provider
Arrangements. Through its QuantStrat division, LOWAG receives quantitative
investment signals and investment models. LOWAG then executes the specified
trades on behalf of clients through its execution partners
Cash Sweep Accounts. Certain account custodians can require that cash proceeds
from account transactions or new deposits, be swept to and/or initially maintained
in a specific custodian designated sweep account. The yield on the sweep account
will generally be lower than those available for other money market accounts.
When this occurs, to help mitigate the corresponding yield dispersion LOWAG
shall (usually within 30 days thereafter) generally (with exceptions) purchase a
higher yielding money market fund (or other type security) available on the
custodian’s platform, unless LOWAG reasonably anticipates that it will utilize the
cash proceeds during the subsequent 30-day period to purchase additional
investments for the client’s account. Exceptions and/or modifications can and will
occur with respect to all or a portion of the cash balances for various reasons,
including, but not limited to the amount of dispersion between the sweep account
and a money market fund, the size of the cash balance, an indication from the client
of an imminent need for such cash, or the client has a demonstrated history of
writing checks from the account. The above does not apply to the cash component
maintained within a LOWAG actively managed investment strategy (the cash
balances for which shall generally remain in the custodian designated cash sweep
account), an indication from the client of a need for access to such cash, assets
allocated to an unaffiliated investment manager and cash balances maintained for
fee billing purposes. The client shall remain exclusively responsible for yield
dispersion/cash balance decisions and corresponding transactions for cash balances
maintained in any LOWAG unmanaged accounts.
ByAllAccounts. LOWAG, in conjunction with the services provided by
ByAllAccounts, Inc., may also provide periodic comprehensive reporting services
which can incorporate all of the client’s investment assets, including those
investment assets that are not part of the assets managed by LOWAG (the
“Excluded Assets”). The client and/or their other advisors that maintain
trading authority, and not LOWAG, shall be exclusively responsible for the
investment performance of the Excluded Assets. Unless otherwise specifically
agreed to, in writing, LOWAG’s service relative to the Excluded Assets is limited
to reporting only. The sole exception to the above shall be if LOWAG is specifically
engaged to monitor and/or allocate the assets within the client’s 401(k) account
maintained away at the custodian directed by the client’s employer. As such, except
with respect to the client’s 401(k) account (if applicable), LOWAG does not
maintain any trading authority for the Excluded Assets. Rather, the client and/or
the client’s designated other investment professional(s) maintain supervision,
monitoring and trading authority for the Excluded Assets. If LOWAG were asked
to make a recommendation as to any Excluded Assets, the client is under absolutely
no obligation to accept the recommendation, and LOWAG shall not be responsible
for any implementation error (timing, trading, etc.) relative to the Excluded Assets.
In the event the client desires that LOWAG provide investment management
services for the Excluded Assets, the client may engage LOWAG to do so pursuant
to the terms and conditions of the Investment Advisory Agreement between
LOWAG and the client.
Cybersecurity Risk. The information technology systems and networks that
LOWAG and its third-party service providers use to provide services to LOWAG’s
clients employ various controls, which are designed to prevent cybersecurity
incidents stemming from intentional or unintentional actions that could cause
significant interruptions in LOWAG’s operations and result in the unauthorized
acquisition or use of clients’ confidential or non-public personal information.
Clients and LOWAG are nonetheless subject to the risk of cybersecurity incidents
that could ultimately cause them to incur losses, including for example: financial
losses, cost and reputational damage to respond to regulatory obligations, other
costs associated with corrective measures, and loss from damage or interruption to
systems. Although LOWAG has established procedures to reduce the risk of
cybersecurity incidents, there is no guarantee that these efforts will always be
successful, especially considering that LOWAG does not directly control the
cybersecurity measures and policies employed by third-party service providers.
Clients could incur similar adverse consequences resulting from cybersecurity
incidents that more directly affect issuers of securities in which those clients invest,
broker-dealers, qualified custodians, governmental and other regulatory authorities,
exchange and other financial market operators, or other financial institutions.
Please Note: Non-Discretionary Service Limitations. Clients that determine to
engage LOWAG on a non-discretionary investment advisory basis must be willing
to accept that the Firm cannot effect any account transactions without obtaining
prior verbal consent to any such transaction(s) from the client. Thus, in the event
of a market correction during which the client is unavailable, LOWAG will be
unable to effect any account transactions (as it would for its discretionary clients)
without first obtaining the client’s verbal consent.
Client Obligations. In performing its services, LOWAG 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 his/her/its responsibility to promptly notify LOWAG if there
is ever any change in his/her/its financial situation or investment objectives for the
purpose of reviewing/ evaluating/revising LOWAG’s previous recommendations
and/or services.
Disclosure Brochure. A copy of LOWAG’s written Brochure and the Client
Relationship Summary, as set forth on Part 2A of Form ADV and Form CRS,
respectively, shall be provided to each client prior to, or contemporaneously with,
the execution of the Investment Advisory Agreement or Financial Planning and
Consulting Agreement.
C. LOWAG shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s). Thereafter,
LOWAG 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 LOWAG’s services.
D. LOWAG does not participate in a wrap fee program.
E. As of December 2023, LOWAG had $133,920,781 assets under management on a
discretionary basis and $0.00 in assets under management on a non-discretionary
basis. LOWAG also has assets under advisement of approximately $260,000,000.