Firm Description The Firm was founded in 2009.
The Firm provides asset management services to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations and small businesses ("Primary Accounts").
The Firm also provides asset management services, on a discretionary basis, via acting as a sub- adviser to client accounts ("Sub-advisory Accounts") also advised by another registered investment adviser. The Sub-advisory accounts are managed utilizing the same models as, and trading along with, the Primary Accounts.
Advice is provided through consultation with the client and includes, depending upon the particular situation: determination of financial objectives, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning. In general, the Firm seeks to provide its clients with optimal after-tax, risk adjusted returns over long- term time horizons consistent with the clients' investment objectives.
Investment advice is an integral part of financial planning. In addition, the Firm advises clients regarding cash flow, college planning, retirement planning, tax planning and estate planning. The Firm also publishes quarterly newsletters made available on the Firm's website, as well as distributed via email to clients, prospects, and other centers of influence.
Investment advice is provided on a discretionary or non-discretionary basis. The Firm does not act as a custodian of client assets. The client always maintains asset control. The Firm also provides independent consulting services to 401(k) and pension plans. The Firm does not sell or have any 401(k) or pension plan proprietary products.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. The Firm strives to disclose any conflicts of interest to the client.
The Firm also serves as investment manager to a private fund, Shorepoint Income Fund I, LP ("Fund"). The Fund's objective is to preserve capital, deliver attractive current yields, and accrue additional capital gains upon investment exits. The Fund invests in private real estate, debt and equity securities. It has invested a small portion in public income producing securities such as closed-end funds, master limited partnerships, etc.
Principal Owners The Firm is organized as a Massachusetts limited liability company. Timothy Vanech owns 50% of the membership interests of the Firm. Luis Raposo owns the remaining 50% membership interests of the Firm.
Types of Advisory Services The Firm provides investment supervisory services, also known as asset management services. This means that the Firm provides its clients with regular and continuous investment advice which is particularly tailored to that client's investment needs.
4 On more than an occasional basis, the Firm furnishes advice to clients on matters not involving securities, such as financial planning matters, taxation issues, and retirement planning services that often include 401(k) investment and planning.
As of January 1, 2023, the Firm managed $618,337,886 in assets. Of this, $591,205,861 in assets were managed on a discretionary basis and $27,132,025 in assets were managed on a non-discretionary basis.
Tailored Relationships The goals and objectives for each client are documented in our performance reporting system. Investment guideline statements 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 client consent.
Types of Agreements The following agreements define the typical client relationships.
Investment Management Agreement Most clients choose to have the Firm manage their assets in order to obtain ongoing in-depth advice and life planning. All aspects of the client's financial affairs are reviewed. Realistic and measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis.
In general, the Firm seeks to provide strong after-tax, risk adjusted returns over long-term time horizons consistent with clients' investment objectives, which investment objectives take into account clients' risk tolerance, investment constraints, tax consequences and liquidity needs. The Firm pursues its clients' investment objectives by strategically investing client accounts in multiple asset classes, including, but not limited to, traditional assets such as equity, fixed income and government securities and mutual funds.
The scope of work and fee for an Investment Management Agreement is provided to the client in writing prior to the start of the relationship. An Investment Management Agreement may include: cash flow analysis; insurance review; investment management (including performance reporting); education planning; retirement planning; and estate planning, as well as the implementation of recommendations within each area.
For Primary Accounts, although the Investment Management Agreement is a continuing agreement, the length of service to the client is at the

client's discretion. The client or the Firm may terminate an Agreement by 30-day written notice to the other party. Fees are generally charged quarterly, in advance. At termination, fees will be refunded on a pro rata basis for the portion of the quarter remaining. The portfolio value at the completion of the prior full-billing quarter is used as the basis for the fee computation, adjusted for the number of days during the billing quarter prior to termination.
401(k) Consulting Agreement The 401(k) consulting services are designed to provide independent consulting services to 401(k) and pension plans. The Firm does not sell or have any 401(k) or pension plan proprietary products.
5 The Firm provides the following services as part of its 401(k) consulting services offering: in- person enrollment and education services provided by a principal of the Firm; creation and management of customized investment allocation models for participants; conduction of annual trustee review meetings; and screening, selection, recommendation and monitoring of plan investment choices.
Financial Planning Agreement A financial plan is designed to help the Primary Account client with all aspects of financial planning without ongoing investment management after the financial plan is completed.
The financial plan includes, but is not limited to: a net worth statement; a cash flow statement; a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations.
Detailed investment advice and specific recommendations are provided as part of a financial plan. Implementation of the recommendations is at the discretion of the client.
Investment Management Assets are invested primarily in stocks, bonds, mutual funds and exchange traded funds. Stocks and bonds are purchased or sold through a brokerage account when appropriate. The brokerage firm charges a fee for stock and bond trades. No-load mutual funds and exchange-traded funds are usually purchased through discount brokers or fund companies. Fund companies charge each fund shareholder an investment management fee that is disclosed in the fund prospectus. Discount brokerages may charge a transaction fee for the purchase of some funds.
Investments may also include corporate bonds, municipal securities and U.S. government securities.
Initial public offerings (IPOs) are not available through the Firm.
Investment in the Fund will only be made by accredited investors via separate subscription documents. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are 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 we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: 6
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Termination of Agreement For Primary Accounts, the client or the Firm may terminate any of the aforementioned agreements by a 30-day written notice to the other party. Fees collected for services not yet rendered will be refunded to the client on a pro rata basis, based on the number of days remaining in the quarter. Any fees due for services rendered or time spent on the investment advisory engagement prior to notification of termination will be due and payable upon termination of the agreement. Upon notice of termination, the Firm will await further instructions from the client as to what steps the client requests the Firm to take to liquidate and/or transfer the portfolio and remit the proceeds.