Overview
Registration Status – Registered with the SEC on September 10, 20041
Principal Owner – Diane S. Bourdo
Assets Under Management – Discretionary Assets – $252,253,627
as of December 31, 2022 Non-discretionary Assets – $0
ADVISORY SERVICES
Investment Management Services
The Humphreys Group is a California limited liability company that provides investment management
and comprehensive financial planning services to its clients. The Humphreys Group’s investment
management services include, among others, financial goal setting, risk assessment, strategic asset
allocation and the selection and management of securities and investments. Securities transactions
are supervised on a continuous basis and each client’s portfolio holdings and asset allocations are
monitored on a periodic basis.
The investment management services we provide are based on each individual client’s financial
circumstances and investment objectives. Our portfolio managers meet with each client to discuss
the client’s current financial condition and to review the client’s current investment holdings. Based
upon each client’s circumstances, we determine an appropriate asset allocation for the client’s
investment portfolio, in accordance with the client’s specific financial objectives and risk tolerance
and in consideration of other factors, including the client’s time horizon (education funding, home
purchase, retirement, legacy planning), liquidity needs, and other available resources (including
external retirement plans, projected social security, outside investments, real estate, and insurance).
Clients are welcome to identify any investment restrictions to be placed on their account. Each
client’s financial objectives, risk tolerance, and liquidity needs, along with a recommended asset
allocation, are incorporated into customized Portfolio Guidelines that are discussed with the client.
A client retains the authority to make additions to and withdrawals from the client’s portfolio account
at any time, subject to the Firm’s right to terminate an account if the amount of assets drops below
our account size minimum. Clients retains the authority to withdraw account assets at any time with
notice to the Firm, subject to the usual and customary securities settlement procedures. However,
we design client portfolios as long-term investments and caution our clients that unplanned asset
withdrawals will impair the timely achievement of the client’s investment objectives. Additions to an
account may be in cash or securities provided that we reserve the right to decline to accept
particular securities into a client’s account or to recommend that the security be liquidated if it is
inconsistent with the Firm’s investment strategy or the client’s investment objectives. Clients are
advised that when transferred securities are liquidated, they will be subject to transaction fees, fees
assessed at the mutual fund level and/or tax ramifications.
The Humphreys Group generally requires clients to place a minimum of $1 million under management
with the Firm. Multiple
client accounts will be aggregated to meet this minimum. The Firm maintains
the right, in its sole discretion, to waive or alter the minimum account size requirement.
Fiduciary Status
When The Humphreys Group provides investment advice to you regarding your investment
accounts, including your retirement plan account or individual retirement account, we are
fiduciaries within the meaning of certain state and federal laws such as the Employee Retirement
1 “Registration” means only that the Firm meets the minimum requirements for registration as an investment
advisor and does not imply that the SEC guarantees the quality of our services or recommends them.
Income Security Act and/or the Internal Revenue Code and the regulations of the U.S. Securities
and Exchange Commission, as applicable. These regulations require us to act in your best interest
and not put our interests ahead of yours.
Comprehensive Financial Planning Services
As a part of its investment management services, The Humphreys Group provides financial planning
services to its clients. These may include a financial review and analysis of some or all of the following
areas:
• Determining Financial Goals and
Objectives
• Asset Allocation Review
• Retirement Plan Analysis
• Employee Stock Option Analysis
• Current Portfolio Review
• Education Funding Analysis
• Cost Audit of Current Investments
• Cash Flow Management Review
• Review of Insurance Needs
• Mortgage and Refinance Evaluation
• Estate Plan Review or Development
• Charitable (or social capital) Planning
• Opinion on Current Investment
Strategy/Advisors
• Other financial or investment analysis
On occasion, financial planning services are provided to non-investment management clients on an
hourly or fixed fee basis. Unless provided in connection with the investment management services
described above, clients engaging The Humphreys Group to provide financial planning services will
generally be required to enter into a separate written agreement with The Humphreys Group setting
forth the terms and conditions of the planning engagement and describing the scope of the services
to be provided.
General Notice
In performing its services, The Humphreys Group relies upon the information received from its client or
from their other professional legal and accounting advisors and is not required to independently
verify such information. Clients must promptly notify us of any change in their financial situation or
investment objectives that would necessitate a review or revision by our advisors of the client’s
portfolio and/or financial plan.
TERMINATION OF AGREEMENT
Clients may terminate their investment management agreement upon thirty (30) days’ written
notice to the Firm. The Firm does not assess any fees related to termination but will be entitled to all
management fees earned up to the date of termination. Any prepaid fees owed to the client are
refunded pro rata based on the amount of time expired in the calendar quarter.