This Disclosure document is being offered to you by Barber Financial Group, Inc. (“BFG”) about the investment
advisory services we provide. It discloses information about the services we provide and the way those services
are made available to you, the client.
BFG is a fee-based investment management firm located in Lenexa, Kansas, specializing in investment advisory
services for investors. BFG was established by F. Dean Barber, the firm’s principal owner, as Comprehensive
Financial Planning Services (CFPS, Inc.) in October 1998. The name was officially changed to Barber Financial Group
in November 2004 and became a registered investment adviser in January 2010.
BFG is committed to helping clients build, manage, and preserve their wealth as well as to assisting clients to help
achieve their stated financial goals. We may offer an initial complimentary meeting; however, investment advisory
services are initiated only after you and BFG execute an engagement letter or client agreement.
1. The Barber Financial Group Guided Retirement System™
The Barber Financial Group Guided Retirement System™ (GRS or Guided Retirement System) is an
inclusive combination of many of BFG’s service. This service encompasses services related to investment
management, tax planning, risk management planning, and estate planning into a single offering. The
GRS allows clients of Barber Financial Group access to investment advisors, CPAs, insurance specialists,
social security specialists, and estate attorneys that all work together under the Barber Financial Group
umbrella.
2. Investment Management Services as a Stand-Alone Service
BFG may provide this service without any additional financial planning services, if desired by the client.
BFG offers discretionary investment management services for a fee based on a percentage of your assets
under management. These services include investment analysis, allocation of investments, quarterly
portfolio statements and ongoing monitoring services for the portfolio.
BFG determines your portfolio composition based on your needs, portfolio restrictions, if any, financial
goals and risk tolerances. BFG will work with you to obtain necessary information regarding your financial
condition, investment objectives, liquidity requirements, risk tolerance, time horizons, and any
restrictions on investing. This enables BFG to determine the portfolio best suited for your investment
objective and needs. Although BFG generally recommends long-term investment strategies, its advisors
may recommend various short-term investment strategies to accommodate certain Client goals or
objectives.
3. Financial Planning Services
BFG offers modular planning services designed to meet individual Clients’ specific needs. These services
may include one or more of the following:
a. Financial Planning
BFG advisors will prepare a financial plan designed to answer the question “am I ok?”. Financial
plan will include an analysis of all client’s financial assets as well as a stress test of that plan
against certain life events. Fundamental financial plans do not include estate plan analysis or
tax planning analysis. Client meetings occur in-person or remotely by telephone or webinar.
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b. Optional Delivery of Financial Plan Updates
Clients who request any financial planning service described above will have the option to
receive their financial plan three different ways. The options available to clients include:
✓ a one-time delivery of a financial plan where the service is considered complete upon
delivery and review with the client;
✓ A financial plan that includes the initial delivery and review plus annual updates and reviews
with BFG; or
Client meetings occur in-person or remotely by telephone or webinar.
c. Tax Planning Services
Tax planning services offered through BFG Tax Services, LLC. BFG Tax Service will assist you in the
development of a multi-year income tax plan after careful consideration of your objectives and
present financial situation. This process begins with the preparation of a comprehensive financial
plan. Based on this analysis, we will recommend strategies to implement today that can have
positive impact on taxes due in future years, especially during retirement. Tax return preparation
is not included in this agreement but can be obtained through BFG Tax Service at an additional
cost.
d. Custom Tax Analysis
A custom tax analysis is designed to answer a specific client question about impact on current
year taxes given a specific act. Examples include “Should I make a Qualified Charitable Donation
this year?” or “What is the impact on my taxes if I pay cash or take out a mortgage to purchase
a second home?”. Custom tax Analysis may also require a current financial plan. Actual Fee will
be determined prior to providing the service.
e. Tax Return Preparation
Includes preparation of federal income tax return, and applicable tax returns for the state and local
taxing authorities in which you declare residency. Requires separate, annual agreement with BFG
Tax Services, LLC. Actual fee based on complexity of return.
Requires separate, annual agreement with BFG Tax Services, LLC. Actual fee is based on
complexity of return.
f. Estate Planning Services
BFG may provide estate planning assistance to our clients. This could include the following: 1)
General estate tax education and guidance; (2) General trust guidance –types and features; (3)
General explanation of estate planning structures/documents; (4) General explanation of estate
planning and gifting strategies; (5) General explanation of taxation issues of trusts and estates;
(6) General explanation of types and treatment of trust income; (7) General guidance on sources
of estate liquidity; (8) General guidance on ownership titles and assistance with titling of assets;
(9) General guidance on impact of account and trust beneficiary designations (10) Assistance
with gathering information to transmit to EncorEstate Plans.
In some instances, BFG may use the software of EncorEstate (“Encore) to produce an estate plan
based on the information provided through the ENCORE software. The services provided by
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Encore include the following: (1) Preparation of estate planning documents; (2) Preparation and
recordation of real estate deed into trust; and (3) Review of information transmitted by CLIENT
to make sure estate planning goals are adequately met.
Beyond the review of current estate plan documents described above, additional estate
planning services may require a separate engagement and fee to law firms that provide this
service. These law firms work in coordination with BFG and all estate plan meetings/services
will occur at the offices of BFG or via virtual meeting technology (i.e., Zoom, GoToMeeting, etc.).
Estate planning services typically include documents such as wills, trusts, durable power of
attorney, beneficiary designations, healthcare power of attorney, guardianship designations,
etc. that are customized to protect your personal property and assets. Additionally, these
documents define how you want to pass down your personal property and assets as well as who
will guard your them in your absence.
g. Insurance Needs Analysis
This service is a stress test of your financial plan or as a stand-alone service. Includes analysis of
your current financial assets and typically requires you to go through the BFG financial planning
process. Types of policies to be reviewed include, but may not be limited to, life insurance, long
term care, Medicare, disability and health insurance.
h. Key Man Business Owner Analysis
Included as part of your financial plan or as a stand-alone service. Includes policy review
specifically for business owners. Includes analysis of your current financial assets and may also
require you to go through the BFG financial planning process.
i. Custom Planning
BFG may engage with clients for any customized, unique financial planning needs not specifically
described above.
4. Other Services available through BFG
a. Institutions and Employer Sponsored Retirement Plans
For employer-sponsored retirement plans with participant-directed investments, our firm
provides its advisory services as an investment adviser as defined under Section 3(21) of the
Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
When serving as an ERISA 3(21) investment adviser, the Plan Sponsor and our Firm share
fiduciary responsibility. The Plan Sponsor retains ultimate decision-making authority for the
investments and may accept or reject the recommendations in accordance with the terms of a
separate ERISA 3(21) Investment Adviser Agreement between our Firm and the Plan Sponsor.
We provide the following services to the Plan Sponsor:
✓ Screen investments and make recommendations.
✓ Monitor the investments regularly and suggests replacement investments when
appropriate.
✓ Provide an annual investment report.
✓ Assist the Plan Sponsor in developing an Investment Policy Statement (“IPS”).
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We can also be engaged to provide financial education to Plan participants. The scope of
education provided to participants will not constitute “investment advice” within the meaning
of ERISA and participant education will relate to general principles for investing and information
about the investment options currently in the Plan. We may also participate in initial enrollment
meetings and periodic workshops and enrollment meetings for new participants.
b. 401(k) Dynamic Investment Strategy
Additionally, BFG may provide advice to individuals on their employer sponsored retirement
plan assets as defined under Section 3(21) of the Employee Retirement Income Security Act of
1974, as amended (“ERISA”). This advice is not considered to be discretionary asset
management and requires the BFG client (plan participant) to implement plan changes on their
own.
c. Discretionary Investment Management of Advisor Variable Annuity Contracts
Where appropriate, the Firm may also provide advice about any type of legacy position or other
investment held in client portfolios. If appropriate, BFG can provide recommendations for
advisor variable annuities. Clients can engage BFG to manage and/or advise on certain
investment products that are not maintained at their primary custodian,
such as annuity
contracts and assets held in employer sponsored retirement plans and qualified tuition plans
(i.e., 529 plans). In these situations, BFG directs or recommends the allocation of client assets
among the various investment options available with the product, including the initial purchase
of the advisor variable annuity contract. These assets are generally maintained at the
underwriting insurance company or the custodian designated by the product’s provider.
d. Third Party Money Manager Sub Advisor Agreements
BFG may utilize independent third-party investment advisers (“TPMM”) to aid us in the
implementation of investment strategies for your portfolio. Including a digital experience with
no account minimums. Risk tolerance decisions and investment options available on the digital
platform are the only available services at this time. In certain circumstances, we may allocate
a portion of a portfolio to an independent TPMM for separate account management based upon
your individual circumstances and objectives, including, but not limited to, your account size and
tax circumstances. Upon the recognition of such situations, in coordination with you, we will hire
a TPMM for the management of those securities. The sub-advisor arrangement may be a Wrap
Program.
BFG evaluates a variety of information about TPMMs, which may include the TPMMs’ public
disclosure documents, materials supplied by the TPMMs themselves and other third-party
analyses it believes are reputable. To the extent possible, we seek to assess the TPMMs’
investment strategies, past performance and risk results in relation to its clients’ individual
portfolio allocations and risk exposure. BFG also takes into consideration each TMPP’s
management style, returns, reputation, financial strength, reporting, pricing and research
capabilities, among other factors.
BFG continues to provide services relative to the discretionary or non-discretionary selection of
the TPMMs. On an ongoing basis, we monitor the performance of those accounts being
managed by TPMMS. BFG seeks to ensure the TPMMS’ strategies and target allocations remain
aligned with its clients’ investment objectives and overall best interests.
In certain instances, the TPMM utilized by Barber Financial Group may hire a third party to avail
itself of the services or facilities of other organizations for the purposes of providing services, as
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appropriate for the discharge of its client obligations. TPMMs utilized by Barber Financial Group
may provide investment advisory, administrative, support and supervisory services.
Use of Riskalyze & Financial Planning Tools
To develop a complete picture of a client’s investment objectives, our investment adviser representatives work
one-on-one with the advisory client through the initial and on-going planning process to create an investment plan
which fits the client’s risk tolerance and investment objectives. Based on this information, we obtain a broad
understanding of the client’s investment objectives, goals, and the amount of risk the client will tolerate. To
further fine tune our understanding of a client’s risk tolerance, our Firm does utilize Riskalyze, a third-party vendor
tool to assist in identifying the client’s risk tolerance.
Riskalyze technology assists financial planners in two critical tasks: (1) measuring the risk preferences of investors,
and (2) applying these preference measurements to portfolio selection. Riskalyze summarizes an investor’s mean-
variance risk aversion on a 99-point scale. In connection with this output, the Riskalyze tool “quantifies” the
client’s indicated investment risk tolerance through the illustration of expected return (plus/minus) and
investment volatility (investment variance) which uses past data to calculate expected variance.
Our Firm works with Riskalyze to customize client portfolios using a combination of existing holdings and
recommended allocation strategies to provide the client with the desired risk score. Once the Risk Score is
identified, our Firm prepares a strategy, which is also scored by Riskalyze tools. Generally, clients are
recommended a mixture of strategies with various allocations, including strategies which focus on fixed income,
growth, balanced, moderate, or aggressive investments, which correlate to the client’s risk score. We seek to go
beyond a traditional asset allocation strategy by incorporating investments on each end of the risk spectrum. As
part of the risk assessment and financial planning processes, BFG advisors may make use of financial planning
software including Money Guide Pro, Right Capital and/or eMoney. Decisions on which planning tool is
appropriate for the client are based on individual client facts and circumstances.
FinLife Partners Technology Platform
In an effort to enhance the quality and breath of services that BFG provides to its Clients, BFG utilizes a suite of
digitally powered technology solutions offered by FinLife Partners, a division of United Capital Financial Advisers,
LLC (“FinLife Partners”). FinLife Partners provides access to its technology platform to BFG that includes use of
certain technology platform, training relating to use of such technology platform, and certain clerical document
and data compilation services. FinLife Partners is not in any way involved in, or responsible for, the individual
investment management or guidance provided to BFG’s clients.
BFG pays FinLife Partners a flat fee for its technology implementation services. Fees are calculated per percentage‐
basis formula in accordance with the volume of clients for whom BFG utilizes such services and/or products. As
such, for certain services offered, Clients indirectly contribute to the payment of cost of services paid to FinLife
Partners. FinLife Partners technology will typically be used as part of the GRS ℠ service and financial planning
services.
BFG receives the following incentives:
✓ Certain technology implementation fees incurred by BFG through use of FinLife Partners’ technology
solutions will be waived if a predetermined number of BFG clients utilize such technology solutions.
✓ If BFG does not utilize predetermined threshold volume of services or technology solutions offered by
United Capital or FinLife Partners, as applicable, then the relationship with FinLife Partners may be
terminated due to insufficient revenue generation.
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BFG is eligible for these benefits as an early adopter of the FinLIfe Partner Service Offering. As an early adopter,
BFG has the ability to collaborate with United Capital Financial Advisors, LLC to continue to enhance the quality
and breadth of the FinLife Partner Service Offering.
Additionally, and to address this conflict, the Client may discuss alternative service options with BFG. BFG
recognizes the fiduciary responsibility to place your interests first and have established policies in this regard to
avoid any potential conflict of interest this arrangement may create.
Disclosure Regarding Rollover Recommendations
A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may
engage in 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) rollover to an
Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s
age, result in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to an IRA for
which our Firm provides investment advisory services. As a result, our Firm and its representatives may earn an
asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their
previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no
compensation to our Firm. Our Firm therefore has an economic incentive to encourage a client to roll plan assets
into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest,
there are various factors that our Firm will consider before recommending a rollover, including but not limited to:
(i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and
expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s
investment professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v)
required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. All
rollover recommendations are reviewed by the firm
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you
regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests.
Miscellaneous
In performing its services, BFG does not independently verify any information it receives from Clients or from a
Client’s other service providers; it relies solely on the information Clients and their authorized representatives
provide. The Client is free to accept or reject any recommendation made by BFG. Moreover, each Client is advised
that it remains the Client’s responsibility to promptly notify BFG if there is ever any change in the Client’s financial
situation or investment objectives so that BFG, if necessary, can re-evaluate or revise any previous
recommendations or services it provided to the Client.
Wrap Fee Programs
BFG does not place Client assets into a wrap fee program sponsored by BFG. However, certain TPMMs may use a
wrap program. Under these circumstances, the TPMM will provide each client the Wrap Fee Brochure for each
Wrap Platform.
Assets Under Management
As of December 31, 2022, BFG managed $1,426,839,762 in client assets on a discretionary basis and $82,291,401
in client assets on a non-discretionary basis.
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