Item 5 - Additional Compensation .......................................................................................................................... 16
Item 6 - Supervision ..................................................................................................................................................... 16
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 17
Supervised Person – Dustin Johnson ..................................................................................................................... 18
Item 2 - Educational Background and Business Experience ....................................................................... 18
Item 3 - Disciplinary Information ........................................................................................................................... 18
Item 5 - Additional Compensation .......................................................................................................................... 19
Item 6 - Supervision ..................................................................................................................................................... 19
Firm Description
Heritage Asset Management, LLC (“Heritage”) was founded in 2021 and became registered
as an investment advisor in 2022. David Thompson is 100% owner and Chief Compliance
Officer.
Types of Advisory Services
ASSET MANAGEMENT
Heritage offers discretionary management services through a program provided by Orion
Portfolio Solutions, LLC (“OPS”). The terms and conditions under which the Client shall
engage OPS shall be set forth in separate written agreements between (1) the Client and
Heritage and (2) the Client and OPS. Heritage shall continue to render advisory services to
the Client relative to the ongoing monitoring and review of account performance, for which
Heritage shall receive an annual advisory fee which is based upon a percentage of the
market value of the assets being managed at OPS. Factors that Heritage will consider
include determining individual investment goals, time horizons, objectives and risk
tolerance. Investment strategies, investment selection, asset allocation, portfolio
monitoring and the overall investment program will be based on the above factors. The
Client will authorize Heritage discretionary authority to execute selected investment
program transactions as stated within the Investment Advisory Agreement. Clients should
review OPS’s ADV Part 2, Form CRS and Terms of Use for additional details regarding OPS
services.
ASSETS UNDER ADVISEMENT
Heritage will work with individuals on determining their individual investment goals, time
horizons, objectives, and risk tolerance. Investment strategies, investment selection, and
asset allocation are based on the above factors. The accounts will be monitored on a
quarterly basis. Heritage will provide the following services, but implementation will be at
the sole discretion of the client.
• Provide investment advice to the Client about asset classes and investment alternatives
available for the Plan. Client will make the final decision regarding the initial selection,
retention, removal and addition of investment options.
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan. Client shall have the
ultimate responsibility and authority to establish such policies and objectives and to
adopt and amend the IPS.
• Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance
based on client’s objectives and risk tolerance and make recommendations to maintain,
remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
ERISA PLAN SERVICES
Heritage provides service to qualified retirement plans including 401(k) plans, 403(b)
plans, pension and profit-sharing plans, cash balance plans, and deferred compensation
plans. Heritage will act as a 3(21) advisor.
Limited Scope ERISA 3(21) Fiduciary. Heritage may serve as a limited scope ERISA 3(21)
fiduciary that can advise, help and assist plan sponsors with their investment decisions. As
an investment advisor Heritage has a fiduciary duty to act in the best interest of the Client.
The plan sponsor is still ultimately responsible for the decisions made in their plan, though
using Heritage can help the plan sponsor delegate liability by following a diligent process.
1. Fiduciary Services are:
• Provide investment advice to the Client about asset classes and investment
alternatives available for the Plan in accordance with the Plan’s investment policies
and objectives. Client will make the final decision
regarding the initial selection,
retention, removal and addition of investment options. Heritage acknowledges that
it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The
IPS establishes the investment policies and objectives for the Plan. Client shall have
the ultimate responsibility and authority to establish such policies and objectives
and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a
qualified default investment alternative for participants who are automatically
enrolled in the Plan or who have otherwise failed to make investment elections. The
Client retains the sole responsibility to provide all notices to the Plan participants
required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports
that document investment performance, consistency of fund management and
conformance to the guidelines set forth in the IPS and make recommendations to
maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information
and the investment alternatives available to them under the Plan. Client
understands Heritage’s assistance in education of the Plan participants shall be
consistent with and within the scope of the Department of Labor’s definition of
investment education (Department of Labor Interpretive Bulletin 96-1). As such,
Heritage is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the
Plan participants. Heritage will not provide investment advice concerning the
prudence of any investment option or combination of investment options for a
particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
Heritage may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between Heritage and Client.
3. Heritage has no responsibility to provide services related to the following types of
assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to Heritage on the ERISA
Agreement. Specific services will be outlined in detail to each plan in the 408(b)2
disclosure.
FINANCIAL PLANNING AND CONSULTING
Full Financial Plan
Financial planning services include a complete evaluation of a Client’s current and future
financial state and will be provided by using currently known variables to predict
future cash flows, asset values and withdrawal plans. Heritage will use current net worth,
tax liabilities, asset allocation, future retirement date and estate plans in developing
financial plans. Typical topics reviewed may include but are not limited to: financial goals,
personal financial consulting, investment analysis, retirement strategy, cash flow analysis,
risk management, long-term investment and estate preservation.
Consultation Services
This service is appropriate for Clients who need assistance with individual topics. This is
not a detailed financial review and will not result in a complete financial plan. Client may
select individual topics above, or other topics as may be deemed appropriate. The
individual topics that will be included in this service will be outlined and agreed upon on
the financial planning and consulting agreement.
If a conflict of interest exists between the interests of Heritage and the interests of the
Client, the Client is under no obligation to act upon any recommendation. Implementation
of any recommendations will be at the discretion of the Client. If the Client elects to act on
any of the recommendations, the Client is under no obligation to affect the transaction
through Heritage. Financial plans and consultations will be completed and delivered inside
of ninety (90) days contingent upon timely delivery of all required documentation.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities. Agreements may not be
assigned without written Client consent.
Wrap Fee Programs
Heritage does not sponsor any wrap fee programs.
Client Assets under Management
Heritage has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$115,000,000 $0 03/31/2024