Earned offers a variety of advisory services, which include financial planning, consulting, and investment
management services. Prior to Earned rendering any of the foregoing advisory services, clients are required
to enter into one or more written agreements with Earned setting forth the relevant terms and conditions of
the advisory relationship (the “Advisory Agreement”).
Earned filed for registration as an investment adviser in December 2021 and is principally owned by NoHo
Holdings LLC, John Clendening, NoHo Capital LLC, Juxtapose Ventures L.P., and HSCM Ventures Fund
2 LP. As of February 12, 2024, Earned had $106,567,909 in assets under management; all of which was
managed on a discretionary basis.
While this brochure generally describes the business of Earned, certain sections also discuss the activities
of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying
a similar status or performing similar functions), employees or other persons who provide investment advice
on Earned’s behalf and are subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
Earned offers clients a broad range of financial planning and consulting services, which include any or all
of the following functions:
• Financial Position
• Risk and Insurance Planning
•
Mortgage Consulting
• Career Advisory
• Tax Preparation
•
Tax Planning
• Investment Consulting
• Real Estate Services
• Retirement Planning
•
Debt Refinancing
• Business Planning
• Education Refinancing
•
Debt Refinancing
• Employee Benefit Planning
While each of these services is available on a stand-alone basis, some of them can also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below). The Firm also provides a Wealth Diagnostic service, which
is a stand-alone financial planning service.
In performing these services, Earned is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely
on such information. Earned recommends certain clients engage the Firm for additional related services,
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its Supervised Persons in their individual capacities as insurance agents and/or other professionals to
implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to
recommend that clients engage Earned or its affiliates to provide (or continue to provide) additional services
for compensation, including investment management services. Clients retain absolute discretion over all
decisions regarding implementation and are under no obligation to act upon any of the recommendations
made by Earned under a financial planning or consulting engagement. Clients are advised that it remains
their responsibility to promptly notify the Firm of any change in their financial situation or investment
objectives for the purpose of reviewing, evaluating or revising Earned’s recommendations and/or services.
Wealth Management Services
Earned provides certain clients with wealth management services which include a broad range of financial
planning and consulting services as well as discretionary management of investment portfolios.
Earned primarily allocates client assets among various independent investment managers that will directly
manage separate accounts for clients (“Independent Managers”) in accordance with their stated investment
objectives. This will also include allocating amongst portfolios managed by the Independent Managers.
The Firm will also recommend mutual funds, exchange-traded funds (“ETFs”), individual debt and equity
securities, and options in certain circumstances.
Where appropriate, the Firm can also provide advice about any type of legacy position or other investment
held in client portfolios, but clients should not assume that these assets are being continuously monitored
or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Earned to manage
and/or advise on certain investment products that are not maintained at their primary custodian, such as
variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and
qualified tuition plans (i.e., 529 plans). In these situations, Earned directs or recommends the allocation of
client assets among the various investment options available with the product. These assets are generally
maintained at the underwriting insurance company or the custodian designated by the product’s provider.
Earned tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those
needs and objectives.
Earned consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time
horizon, liquidity constraints and other related factors relevant to the management of their portfolios.
Clients are advised to promptly notify Earned if there are changes in their financial situation or if they wish
to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions
or mandates on the management of their accounts if Earned determines, in its sole discretion, the conditions
would not materially impact the performance of a management strategy or prove overly burdensome to the
Firm’s management efforts.
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Retirement Plan Consulting Services
Earned provides various consulting services to qualified employee benefit plans and their fiduciaries. This
suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing
their corporate retirement plans. Each engagement is individually negotiated and customized, and includes
any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
•
Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
•
Fiduciary and Compliance
• Participant Education
As disclosed in the Advisory Agreement, some of the foregoing services are provided by Earned as a
fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In
accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of
Earned’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the
Firm reasonably expects under the engagement.
When Earned provides investment advice to clients regarding their retirement plan account or
individual retirement account, Earned is 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 Earned makes money creates some conflicts with client
interests, so Earned operates under a special rule that requires it to act in the client’s best interest
and not put Earned's interest ahead of the clients. Use of Independent Managers
As mentioned above, Earned can select Independent Managers to actively manage a portion of its clients’
assets. The specific terms and conditions under which a client engages an Independent Manager are set
forth in a separate written agreement with the designated Independent Manager. That agreement can be
between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent
Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically
also receive the written disclosure documents of the respective Independent Managers engaged to manage
their assets. The Independent Managers can also include the Firm’s engagement of companies that provide
outsourced chief investment officer relationships. In those circumstances, the Firm can still make the final
investment decisions based on the recommendations of the Independent Manager. When Independent
Managers charge a fee to the Firm for sub-advisory services to clients (including Brinker Capital
Investments, LLC), the Firm will pass that fee on to clients. Those sub-advisory fees are separate and in
addition to the Firm’s investment management fee.
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Earned evaluates a variety of information about Independent Managers, which includes the Independent
Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and
other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the
Independent Managers’ investment strategies, past performance and risk results in relation to its clients’
individual portfolio allocations and risk exposure. Earned also takes into consideration each Independent
Manager’s management style, returns, reputation, financial strength, reporting, pricing and research
capabilities, among other factors.
Earned continues to provide services relative to the discretionary selection of the Independent Managers.
On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent
Managers. Earned seeks to ensure the Independent Managers’ strategies and target allocations remain
aligned with its clients’ investment objectives and overall best interests.
In addition, the Firm can engage third parties for trading support. Clients give the authority to the Firm to
engage the Independent Managers, including third-party trading firms, through the Advisory Agreement.