GENERAL DESCRIPTION
Ethos Financial Group, LLC ("Ethos" or “Advisor”) is a Delaware limited liability company formed on
May 5th, 2022. James Judge is the principal owner of Ethos.
The Advisor's core business is to offer wealth management services to individual and institutional
clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular
investment goal (the "Core Allocation"). Ethos offers its services through several independently owned
offices located across the United States.
As discussed below, Ethos offers to its clients (individuals, high net worth individuals, state or
municipal entities, trusts, estates, and charitable organizations, etc.) investment advisory services, and,
to the extent specifically requested by a client, financial planning, and related consulting services. In
addition, Ethos also provides services to other investment advisers in the form of sub-advisory and
consulting.
Ethos manages advisory accounts on a discretionary or non-discretionary basis through relationships
with Charles Schwab & Company, Inc. (“Schwab”) and US Bancorp Wealth Management (“US Bank”).
Some non-discretionary accounts are managed through a relationship with Citigroup, Inc.
(“Citigroup”). Ethos’s annual investment advisory fee may be either fixed or based upon a percentage
(%) of the market value of the assets placed under Ethos’s management.
Through personal discussions with the client in which the client's goals and objectives are established,
Ethos Investment Adviser Representatives determine which model portfolio is best suited to the client's
individual needs and objectives. The Advisor's Core Allocation starts by forming a fundamental
understanding of the primary drivers of potential portfolio exposures and emphasizes the development
of methods for combining these exposures (often index based) into a diversified risk conscious portfolio.
Once Ethos determines the suitability of the portfolio, the portfolio is managed based on the portfolio's
intended objective. Clients are permitted to place reasonable restrictions on the types of investments to
be held in their account if such restrictions do not materially interfere with Ethos’s ability to effectively
manage client assets. Clients retain individual ownership of all securities.
Because some types of investments involve certain additional degrees of risk, they will only be
implemented/recommended when consistent with the client's stated investment objectives, tolerance for
risk, liquidity needs and overall suitability.
To ensure that Ethos’s initial determination of an appropriate portfolio remains suitable and that the
account continues to be managed in a manner consistent with the client's financial circumstances, Ethos
will:
1. At least annually, contact each participating client to determine whether there have been any
changes in the client's financial situation or investment objectives, and whether the client
wishes to impose investment restrictions or modify existing restrictions;
2. Be reasonably available to consult with the client; and
3. Maintain client suitability information in each client's file.
B. INVESTMENT MANAGEMENT SERVICES
Ethos may be engaged to provide discretionary or non-discretionary investment advisory services.
Ethos’s investment advisory fee is based upon a percentage (%) of the market value of the assets placed
under Ethos’s management and generally ranges from .25% to 2.0% annually.
Ethos’s annual investment advisory fee shall include investment advisory services, and, to the extent
specifically requested by the client, financial planning and consulting services.
Ethos supports its own investment management platform (the "Platform") that is available to the IARs
of Ethos. Before engaging Ethos to provide investment advisory services, clients are required to enter
into an Investment Management Agreement (“IMA”) with Ethos 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, an IAR will first ascertain each client’s investment
objectives and then allocate and/or recommend that the client allocate investment assets consistent with
their designated investment objectives. Once client assets are allocated, Ethos provides ongoing
monitoring and review of account performance and asset allocation.
Ethos shall have discretionary authority to engage unaffiliated investment managers and serve as an
overlay portfolio manager to construct, allocate and reallocate investment portfolios for clients of Ethos
IARs. Ethos also provides the following services, either directly or through contractual relationships
with third parties, with respect to the Platform:
• Investment model administration and Manager facilitation services
• Advisor as Portfolio Manager ("APM") functionality, account administration, billing and
reconciliation, account aggregation, reconciliation and reporting, and client account
reporting
• Business management reporting technology services
Investment Services
Ethos offers compliance, operational and back-office support to its IARs through third party service
providers. These services are typically funded through the fees charged by the IAR to its clients. As part
of these services to the investment advisor, Ethos provides the IARs with access to a range of
discretionary investment advisory services for use by advisors with their clients, including Separately
Managed Accounts ("SMA"), Mutual Funds and Exchange Traded Funds ("ETF") Asset Allocation
Strategies and Unified Managed Accounts ("UMA") (each an "Investment Program" and collectively, the
"Investment Programs"). The Investment Programs are generally made available by Ethos to their IARs,
who may recommend one or more Investment Programs to their clients. A client's investment adviser
determines which services and Investment Programs of Ethos to use with its clients and may use the
services of other third-party service providers in conjunction with the Investment Programs.
The Investment Programs generally consist of model portfolios comprised of mutual funds,
individual stocks/equities and/or exchange-traded funds (“ETFs”) to represent different possible
investment strategies for managing your account. Each of these investment strategies is intended to
meet a specific goal. At all times we will continue to be your financial advisor, with the fiduciary
responsibility to you. You will not have a direct contractual relationship or be in contact with the
Investment Program, or any other Third-Party Service Provider – these are all service providers to us
which we employ on your behalf.
Prior to investing in the Investment Program, you will execute a discretionary investment
management agreement with us setting forth the terms and conditions of our management of your
investments within the Investment Program. Depending on the management services you select, you will
grant us discretionary authority to manage your account through selection of an overlay manager
(“Overlay Manager”) and, optionally, a third-party strategist (“Strategist”) and/or third-party managers
(“Managers”; collectively, “Third-Party Service Providers”). If utilized for your account(s), we will
separately provide you with the firm brochure (Part 2 of Form ADV) for the applicable Third-Party
Service Provider(s) which includes information about their services, model portfolios, and investment
strategies. It is our responsibility to monitor the performance of these Third-Party Service Providers.
Ethos will maintain the authority to replace any Strategist and/ or Manager associated with your account(s)
when we deem doing so is in your best interest.
In addition, you will authorize the custodian to follow our instructions as well as instructions given
by Overlay Manager to effect transactions, deliver securities, deduct fees, and take other actions with
respect to your account(s).
The timing of trades in your account(s) will primarily depend upon the model portfolio or
changes in the model portfolio and, generally, will not take into consideration how long you may have
held the position indicated by the model portfolio – unless the optional tax overlay management services
are elected. Tax Overlay Management is available only to U.S. account holders. By default, accounts
are managed without Tax Overlay Management services unless specifically elected by you.
Tax Overlay Management Services
Tax overlay management services are available as an option for accounts utilizing the Investment
Program through the Overlay Manager. If you elect tax overlay management services, the portion of your
fee paid as the management fee on your account will increase. The Overlay Manager will develop a tax
strategy for your account based on the information and instructions provided by us on your behalf. Tax
overlay management services in an investment account offer benefits and limitations, as described below.
The tax strategy developed for you by the Overlay Manager is provided solely in connection with your
account and the Overlay Manager does not provide general tax planning services. If you do elect the tax
overlay management services option, please consider the following:
• The Overlay Manager will implement tax overlay management services based on the
information and instructions provided by us for your account(s).
• The Overlay Manager does not provide general tax advice, tax return preparation or tax
planning services.
• The Overlay Manager will seek to reduce the overall tax burden of the account while
seeking to maintain the risk and return characteristics of the model portfolios received from
Strategists and/or Managers.
• When providing tax overlay management services to the account, short-term gains are avoided
where possible, but long-term gains are not limited unless you have requested a mandate to
limit realized long-term gains.
The Overlay Manager will provide tax overlay management services with the assumption that the
Overlay Manager will continue to provide services to the account for an entire tax year. The termination
or removal of the tax overlay management services before the completion of an entire tax year may
result in adverse tax consequences, including without limitation realization of short-term capital gains.
Regardless of your account size or any other factors, we strongly recommend that you continuously
consult with a tax professional prior to and throughout the investing of your assets.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
Consulting Services
Ethos offers a range of consulting services including allocation research, risk analysis, benchmarking,
and manager assessment. These services are provided pursuant to specialized engagements individually
negotiated with Ethos’s clients based upon their specific needs and objectives.
In performing its services, Ethos is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorney, accountant, etc.) and is authorized to rely on such
information. Ethos may recommend the services of itself, and/or other professionals to implement its
recommendations. Clients are advised that a conflict of interest exists if Ethos recommends its own
services or the services of any of its Advisory Affiliates (as set forth in Item 10). The client is under no
obligation to act upon any of the recommendations made by Ethos under a consulting engagement or to
engage the services of any such recommended professional, including Ethos itself. The client retains
discretion over all such implementation decisions and is free to accept or reject any of Ethos’s
recommendations. Clients are advised that it remains their responsibility to promptly notify Ethos if
there is ever any change in their financial situation or investment objectives for the purpose of
reviewing, evaluating, or revising Ethos’s previous recommendations and/or services.
Financial Planning
To the extent specifically requested by a client, Ethos may 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. Ethos's planning and consulting fees are charged
either at an hourly rate or annual fee, subject to a minimum of $1,000; however, discounted rates can
and may be offered. The fees charged are dependent upon the level and scope of the service(s) required
and the professional(s) rendering the service(s). Prior to engaging Ethos to provide planning or
consulting services, clients are generally required to enter into a Financial Planning and Consulting
Agreement with Ethos 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 Ethos commencing services.
If requested by the client, Ethos will recommend the services of other professionals for implementation
purposes, including Ethos’s representatives in their individual capacities as registered representatives
of a broker-dealer, or licensed insurance agents. (See disclosure at Item 10.C.). 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 Ethos. It remains the client’s responsibility to promptly notify Ethos if there is ever any change in
their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising
Ethos’s previous recommendations and/or services.
Financial planning is a comprehensive evaluation of a client's current and future financial state by using
currently known variables to predict future cash flows, asset values and withdrawal plans. Through the
financial planning process, all questions, information, and analysis are considered as they impact, and
are impacted by, the entire financial and life situation of the client. Clients purchasing this service either
receive a written report or access to software which provides the client with a detailed financial plan
designed to assist the client in achieving his or her financial goals and objectives. In general, the
financial plan can address any or all the following areas:
• PERSONAL: Ethos reviews family records, budgeting, personal liability, estate information
and financial goals.
• TAX & CASH FLOW: Ethos analyzes the client's income tax and spending and planning for
past, current, and future years; then illustrates the impact of various investments on the client's
current income tax and future tax liability.
• INVESTMENTS: Ethos analyzes investment alternatives and their effect on the client's
portfolio.
• INSURANCE: Ethos reviews existing policies to ensure proper coverage for life, health,
disability, long-term care, liability, home, and automobile.
• RETIREMENT: Ethos analyzes current strategies and investment plans to help the client
achieve his or her retirement goals.
• DEATH & DISABILITY: Ethos reviews the client's cash needs at death, income needs of
surviving dependents, estate planning and disability income.
• ESTATE: Ethos assists the client in assessing and developing long-term strategies, including
as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans,
nursing homes, Medicaid, and elder law. Ethos gathers required information through in-depth
personal interviews. Information gathered includes the client's current financial status, tax
status, future goals, returns objectives and attitudes towards risk. Ethos carefully reviews
documents supplied by the client, including a questionnaire completed by the client, and
prepares a written report. Should the client choose to implement the recommendations
contained in the plan, Ethos suggests the client work closely with their attorney, accountant,
insurance agent, and/or investment adviser. Implementation of financial plan recommendations
is entirely at the client's discretion.
Ethos also provides general non-securities advice on topics that may include tax and budgetary
planning, estate planning and business planning. Investment recommendations in financial plans may
include any or all the following:
• Exchange-listed securities
• Securities traded over-the-counter
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
•
Variable life insurance
• Variable annuities
• Mutual fund share
• United States governmental securities
• Options contracts on securities
• Interests in partnerships investing in real estate
• Interests in partnerships investing in oil and gas interests
• Any investments held by the client at the inception of the advisory relationship
Typically, the financial plan is presented to the client within six months of the contract date, provided
that all information needed to prepare the financial plan has been promptly provided. Financial Planning
recommendations are not limited to any specific product or service offered by a broker-dealer or
insurance company. All recommendations are of a generic nature and should be reviewed with your
attorney, accountant or other professional as appropriate prior to implementation.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services: As
indicated above, to the extent requested by the client, Ethos may provide financial planning and related
consulting services regarding non-investment related matters, such as estate planning, tax planning,
insurance, etc. Ethos is not a law firm or accounting firm, and no portion of its services should be construed
as legal, tax or accounting advice. Accordingly, Ethos does not prepare estate planning documents or tax
returns. To the extent requested by a client, Ethos may recommend the services of other professionals for
certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.),
including representatives of Ethos in their separate individual capacities as registered representatives of
Innovation Partners, LLC (“Innovation Partners”) (individually and/or collectively, “Third Party BD”),
each a FINRA member broker-dealer and/or as insurance agents. 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 Ethos and/or its
representatives (See Item 10 below). The recommendation by Ethos’s representative that a client purchase
a security or insurance commission product in his/her separate and individual capacity as a registered
representative of a Third-Party broker dealer, and/or as an insurance agent, presents a conflict of interest,
as the receipt of commissions provides an incentive to recommend investment or insurance products based
on commissions to be received, rather than on a particular client’s need. No client is under any obligation
to purchase any securities or insurance commission products through such a representative. Clients are
reminded that they may purchase securities or insurance products recommended by Ethos through other,
non-affiliated broker-dealers or insurance agencies.
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 one or 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 would,
depending upon the client’s age, result in adverse tax consequences). If Ethos recommends that a client
roll over their retirement plan assets into an account to be managed by Ethos, such a recommendation
creates a conflict of interest as Ethos will earn new (or increase its current) compensation because of
the rollover. No client is under any obligation to roll over retirement plan assets to an account managed
by Ethos.
When Ethos provides investment advice to you regarding your retirement plan account, individual
retirement account, or other qualified asset under ERISA, we are fiduciaries within the meaning of Title
I of the Employee Retirement Income Security and/or the Internal Revenue Code, as applicable, which
are laws governing retirement accounts. The way we make money creates some conflicts with your
interests, so Ethos operates under a special rule that requires us to act in your best interest and not put our
interest ahead of yours. Clients can engage Ethos to provide either education or recommendations with
respect to qualified ERISA assets including:
from a qualified plan to an IRA;
from an existing third-party IRA to an IRA;
changing the account type of an existing IRA;
from a qualified plan to another qualified plan; and
from an IRA to qualified plan rollover.
Such provisions also extend to other qualified assets such as Education Savings Accounts and retirement
annuities. Clients should fully understand all the conflicts, risks, costs & expenses, as well as potential
benefits associated with moving qualified retirement assets. Clients are under no obligation to accept or
follow Ethos’s recommendations.
Unaffiliated Private Funds
Ethos may also provide investment advice regarding unaffiliated private investment funds. Ethos, on a
non-discretionary basis, may recommend that certain qualified clients consider an investment in
unaffiliated private investment funds. Ethos’s role relative to the private investment funds shall be
limited to its initial and ongoing due diligence and investment monitoring services. If a client determines
to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part
of “assets under management” for purposes of Ethos calculating its investment advisory fee. Ethos’s
clients are under absolutely no obligation to consider or make an investment in a private investment
fund(s).
Private investment funds generally involve various risk factors, including, but not limited to, potential
for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of
which is set forth in the Fund's offering documents, which will be provided to each client for review
and consideration. Unlike other liquid investments that a client may maintain, private investment funds
do not provide daily liquidity or pricing. Each prospective client that elects to invest in the Fund will be
required to complete a Subscription Agreement, pursuant to which the client shall establish that the
client is qualified to invest in the Fund and acknowledges and accepts the various risk factors that are
associated with such an investment.
If Ethos references private investment funds owned by the client on any supplemental account reports
prepared by Ethos, the value(s) for all private investment funds owned by the client shall reflect the
most recent valuation provided by the fund sponsor. If the fund sponsor does not provide a post-purchase
valuation, then the valuation shall reflect the initial purchase price (and/or a value as of a previous date)
or the current value(s) (either the initial purchase price and/or the most recent valuation provided by the
fund sponsor). If the valuation reflects the initial purchase price (and/or a value as of a previous date),
then the current value(s) (to the extent ascertainable) could be significantly more or less than the original
purchase price. The client’s advisory fee shall be based upon such reflected fund value(s). Some private
investment funds offered to clients on a non-discretionary basis are funds in which Ethos personnel are
general partners. This creates a conflict of interest, as it is an incentive to recommend those funds to
our clients. Clients are under no obligation to consider or make an investment in any private investment
fund.
Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available
directly to the public. Thus, a prospective client may obtain many, if not all, of the funds(securities)
utilized by Ethos in managing client assets independent of engaging Ethos as an investment advisor.
However, if a prospective client determines to do so, he/she will not receive Ethos’s initial and ongoing
investment advisory services. In addition to Ethos’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).
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),
Ethos may increase or maintain higher cash positions. Absent a specific written agreement to the
contrary, cash positions (i.e., cash, money markets, etc.) are generally included as part of assets under
management for the purposes of calculating Ethos’s advisory fee.
Portfolio Activity: Ethos has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, Ethos 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 Ethos determines that changes to a client’s portfolio are neither necessary nor prudent. There
can be no assurance that investment decisions made by Ethos will be profitable or result in any specific
performance level(s). Clients pay Ethos advisory fees regardless of whether their account increases or
decreases in value.
Fee Differentials: As discussed above and indicated below at Item 5, Ethos shall generally price our
advisory services based upon various objective and subjective factors. As a result, our clients could pay
diverse fees based upon the market value of their assets, the complexity of the engagement, and the
level and scope of the overall investment advisory services to be rendered, and client negotiations. As
a result of these factors, similarly situated clients could pay different fees, and the services provided by
Ethos to any client could be available from other advisers at lower, or greater, cost. Before engaging
Ethos to provide investment advisory services, clients are required to enter into a discretionary or non-
discretionary IMA, setting forth the terms and conditions of the engagement (including termination),
which includes the fees and services to be provided.
Non-Discretionary Accounts Service Limitations: Clients that engage Ethos on a non- discretionary
basis acknowledge that Ethos cannot affect any account transactions without first obtaining consent to
such transaction(s) from the client directly. In the event Ethos would like to make a transaction for a
client’s account (including in the event of an individual holding or general market correction), and the
client is unavailable, Ethos would be unable to affect the account transaction(s) (as it would for its
discretionary clients) without first obtaining the client’s consent. As a result, recommended trades for
non-discretionary accounts will be delayed and, in some cases, may not be executed at all.
Independent Managers: Ethos 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. Ethos 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. The factors Ethos considers in recommending Independent Manager(s) include the client’s
designated investment objective(s), management style, performance, reputation, financial strength,
reporting, pricing, and research.
The investment management fee charged by the Independent Manager(s) is separate from, and in
addition to, Ethos’s advisory fee as set forth in the fee schedule at Item 5 below and 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).
Sub-Advisory Engagements.
Ethos may also serve as a sub-adviser to unaffiliated registered investment advisers per the terms and
conditions of a written Sub-Advisory Agreement. With respect to its sub-advisory services, the
unaffiliated investment advisers that engage Ethos’s sub-advisory services maintain both the initial and
ongoing day-to-day relationship with the underlying client, including initial and ongoing determination of
client suitability for Ethos’s designated investment strategies and or programs. If the custodian/broker-
dealer is determined by the unaffiliated investment adviser, Ethos will be unable to negotiate commissions
and/or transaction costs, and/or seek better execution. As a result, client may pay higher commissions or
other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the
account than would otherwise be the case through alternative clearing arrangements recommended by
Ethos. Higher transaction costs adversely impact account performance.
Inverse/Enhanced Market Strategies: Ethos may utilize long and short mutual funds and/or exchange
traded funds that are designed to perform in either an: (1) inverse relationship to certain market indices
(at a rate of 1 or more times the inverse [opposite] result of the corresponding index) as an investment
strategy and/or for the purpose of hedging against downside market risk; and (2) enhanced relationship to
certain market indices (at a rate of 1 or more times the actual result of the corresponding index) as an
investment strategy and/or for the purpose of increasing gains in an advancing market. There can be no
assurance that any such strategy will prove profitable or successful. Furthermore, Ethos may hold these
positions for longer than the one day that many fund prospectuses suggest, which may lead to additional
risks. For periods longer than a single day, these funds will lose money when the level of the underlying
indices are flat, and it is possible that the funds will lose money even if the level of the indices either
increase or decrease (if inverse). Longer holding periods, higher index volatility, inverse exposure, and
levered exposure each exacerbate the impact of compounding on an investor’s returns. During periods of
high index volatility, the volatility of the indices may affect the returns of the funds as much as, or more.
than the return of the indices. In light of these enhanced risks/rewards, a client may direct Ethos, in writing,
not to employ any or all such strategies for his/her/their/its accounts.
Client Obligations: In performing its services, Ethos 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 Ethos if there is
ever any change in their financial situation or investment objectives for the purpose of reviewing,
evaluating, or revising Ethos’s previous recommendations and/or services.
Disclosure Statement: A copy of Ethos’s written disclosure statement as set forth on Part 2 of Form ADV
and Form CRS shall be provided to each client prior to, or contemporaneously with, the execution of the
Investment Management Agreement and/or Financial Planning and Consulting Agreement.
C. Ethos 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, Ethos 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 Ethos’s services.
D. Ethos does not participate in any wrap fee programs.
E. As of 12/31/2023, Ethos manages 2,481 discretionary accounts with regulatory assets under
management of $750,899,445. Ethos also manages 1 non-discretionary account with regulatory
assets under management of $163,035,360. This totals 2,482 accounts at $913,934,805 regulatory
assets under management.