Prudeo Partners, LLC (“Prudeo” or “the Firm”) is an SEC-registered investment adviser with its
principal place of business located in West Columbia, South Carolina. Prudeo began conducting
business in 2000. We also have an office in Reading, PA.
Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25%
or more of this company):
Michael Krumholz, Partner
Andrew Creswell Todd, President
Prudeo has entered into an agreement with Perigon Wealth Management (“Perigon”) in which Prudeo
will partner with Perigon. This relationship will expand our resources and increase ways in which
Prudeo can service our clients moving forward. We feel this relationship will expand out resources and
increases ways in which we can services out clients moving forward.
Perigon was founded in 2004 in San Francisco and has 16 U.S. based officers with 58 advisors and
over 45 support staff that support client services, operations, trading and planning. This anticipated
partnership is expected to be completed by the second quarter 2024.
Prudeo Partners, LLC offers the following advisory services to our clients:
INVESTMENT SUPERVISORY SERVICES ("ISS") PORTFOLIO MANAGEMENT SERVICES
Our firm provides continuous advice to a client regarding the investment of client funds based on the
individual needs of the client. During our data-gathering process, we determine the client’s individual
objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and
discuss a client's prior investment history, as well as family composition and background. As part of
our individual Portfolio Management Services, we offer financial planning at no cost to the client. If a
client elects to receive this service, we evaluate a client’s current and future financial state by using
currently known variables to predict future cash flows, asset values and withdrawal plans.
We manage these advisory accounts on a discretionary basis. Account supervision is guided by the
client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income),
as well as tax considerations. Clients may impose reasonable restrictions on investing in certain
securities, types of securities, or industry sectors.
As part of our Portfolio Management Services, in addition to other types of investments (see
disclosures below in this section), we may invest your assets according to one or more
model portfolios developed by our firm. These models are designed for investors with varying degrees
of risk tolerance ranging from a more aggressive investment strategy to a more conservative
investment approach. Clients whose assets are invested in model portfolios may not set restrictions on
the specific holdings or allocations within the model, nor the types of securities that can be purchased
in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of
securities in their account. In such cases, this may prevent a client from investing in certain models
that are managed by our firm.
Our investment recommendations are not limited to any specific product or service offered by a broker-
dealer or insurance company and will generally include advice regarding the following securities:
exchange-listed securities, securities traded over the counter, corporate debt securities (other than
commercial paper), municipal securities, mutual fund shares, structured products, private placements,
REITs, and United States government securities.
Because some types of investments involve certain additional degrees of risk, these investments will
only be implemented/recommended when consistent with the client's stated investment objectives,
tolerance for risk, liquidity, and suitability.
PENSION CONSULTING SERVICES
We also provide pension consulting services along with or separately from our other advisory services.
While the primary clients for these services will be pension, profit sharing and 401(k) plans, we will
offer these services, where appropriate, to individuals, trusts, estates, and charitable organizations.
Pension Consulting Services are comprised of three distinct services. Clients may choose to use any
or all of these services.
Selection of Investment Vehicles:
We assist plan sponsors in constructing appropriate asset allocation models. We will then review
various mutual funds (both index and managed) to determine which investments are appropriate to
implement based on the client's Investment Policy Statement (“IPS”). The number of investments to be
recommended will be determined by the client, based on the IPS.
Monitoring of Investment Performance:
We monitor client investments continually, based on the procedures and timing intervals delineated in
the Investment Policy Statement. Although our firm is not involved in any way in the purchase or sale
of these investments, we supervise the client's portfolio and will make recommendations to the plan
sponsor or client as market factors and the client's needs dictate.
Employee Communications:
For pension, profit sharing and 401(k) plan clients with individual plan participants exercising control
over assets in their own account (''self-directed plans''), we may also provide quarterly educational
support and investment workshops designed for the plan participants.
The nature of the topics to be covered will be determined by us and the client under the guidelines
established in ERISA Section 404(c). The educational support and investment workshops will NOT
provide plan participants with individualized, tailored investment advice or individualized, tailored asset
allocation recommendations.
PARTICIPANT ACCOUNT MANAGEMENT SERVICES
We use a third-party platform, called Pontera, to facilitate management of held away assets such as
defined contribution plan participant accounts, on a discretionary basis. Pontera 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 Pontera in any way and receive no compensation
from them for using their platform. A link will be provided to a client allowing them to connect an
account(s) to Pontera. Once a clients account is connected, we will review the current account
allocations. When deemed necessary, we will rebalance the account considering client investment
goals and risk tolerance, and any change in allocations will consider current economic and market
trends. The goal is to improve account performance over time, minimize loss during difficult markets,
and manage internal fees that can harm account performance. A clients account will be reviewed at
least annually or as needed and allocation changes will be made as we deem necessary.
FINANCIAL PLANNING
We offer financial planning services which typically involves providing a variety of advisory services to
clients regarding the management of their financial resources based upon an analysis of their
individual needs. These services can range from broad-based financial planning to consultative or
single subject planning. If you retain our firm for financial planning services, we will meet with you to
gather information about your financial circumstances and objectives.
Financial planning is an 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 receive a
written report which provides the client with a financial plan designed to assist the client to achieve his
or her financial goals and objectives.
In general, the financial plan can address any or all of the following areas:
PERSONAL: We review family records, budgeting, personal liability, estate information and
financial goals.
TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past,
current and future years; then illustrate the impact of various investments on the client's current
income tax and future tax liability.
INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
INSURANCE: We review existing policies to ensure proper coverage for life, health, disability,
long-term care, liability, home, and automobile.
RETIREMENT: We analyze current strategies and investment plans to help the client achieve
his or her retirement goals.
DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving
dependents, estate planning and disability income.
ESTATE: We assist 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.
We gather client 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.
We carefully review documents supplied by the client, including a questionnaire completed by the
client, and prepare a written report. Should the client choose to implement the recommendations
contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance
agent, and/or stockbroker. Implementation of the financial plan recommendations is entirely at the
client's discretion.
We also provide general non-securities advice on topics that may include tax and budgetary planning,
estate planning, and business planning.
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.
Financial plans are based on your financial situation at the time we present the plan to you and on the
financial information you provide to us. You must promptly notify our firm if your financial situation,
goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to
act on any of our recommendations, you are not obligated to implement the financial plan through any
of our other investment advisory services. Moreover, you may act on our recommendations by placing
securities transactions with any brokerage firm.
FIDUCIARY RESPONSIBILITY FOR RETIREMENT ACCOUNTS
When we provide investment advice to a client regarding a retirement plan account or individual
retirement account, Prudeo is a fiduciary within the meaning of Title I of the Employee Retirement
Income Security Act (ERISA) 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
we operate under a special rule that requires us to act in the best interest of the client and not put
Prudeo’s interest ahead of the client’s interest.
Under this special rule’s provisions, we must:
Meet a professional standard of care when making investment recommendations (give prudent
advice);
Never put our financial interests ahead of the client’s financial interests when making
recommendations (give loyal advice);
Avoid misleading statements about conflicts of interests, fees and investments;
Follow policies and procedures designed to ensure that Prudeo gives advice that is in the best
interest of the client;
Charge no more than is reasonable for services provided; and
Give the client basic information about conflicts of interest.
AMOUNT OF MANAGED ASSETS
As of December 31, 2023, we actively manage $402,212,48 of client assets on a discretionary basis
and $10,639,804 of client assets on a non-discretionary basis.