Our Owners and Principals
Lumin Financial, LLC (hereinafter “Lumin,” “we,” “our,” and “us”) is an independent
federally registered investment adviser, providing investment advisory services to employer-
sponsored ERISA retirement plans, and 401(k) Plan participants. Since the firm’s inception in
February of 2000, Lumin has serviced Plan trustees and fiduciaries in the various disciplines of
investment management, fiduciary compliance, plan design, and participant education services.
Additionally, Lumin provides investment advisory services to individuals, primarily
high-net-worth investors, who seek a comprehensive approach towards building a secure
retirement. Advisory services for clients include investment advisory, retirement income
planning, and estate planning.
Lumin Financial, LLC is 100% owned by Victor Hayes Hicks II.
Our Advisory Services
Lumin provides the following services to advisory clients:
ERISA Retirement Plan Services
We provide services to qualified retirement plans, which are subject to the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”), on a discretionary and
nondiscretionary basis. As part of our services to qualified plans, we will act as a fiduciary of the
plan under Section 3(21)(A)(ii) and when requested as an investment manager under Section
3(38) of ERISA.
Lumin provides a variety of ongoing fiduciary and non-fiduciary services to qualified
retirement plans based on an analysis of the needs of the Plan, Plan Fiduciary and Plan Sponsor.
As a Plan “fiduciary,” Lumin provides services that include, but are not limited to:
Advising on a discretionary and non-discretionary basis to the Plan Sponsor about
asset classes and investment alternatives available for the Plan.
Assisting the Plan Sponsor with the selection of a broad range of investment options
consistent with ERISA section 404(c), and the regulations thereunder.
oAs a 3(21) investment advisor, we will not have discretion to invest and reinvest
the Plan assets without the Plan Sponsor’s prior consent. Thus, as a 3(21)
advisor, we will share responsibility for the selection of investments.
Part 2A of Form ADV 2 Lumin Financial, LLC
oAs a 3(38) investment manager, the Plan Sponsor gives us discretionary authority
to manage the Plan’s assets. This means the Plan Sponsor shifts their fiduciary
responsibility to us for the selection of the Plan’s menu of investments.
Assisting the Plan Sponsor in the development, and ongoing management, of an
Investment Policy Statement (IPS).
Providing the Plan Sponsor with advice on the selection of qualified default
investment alternatives (“QDIA”), and other “default” funds.
As a “Non-ERISA Fiduciary,” Lumin provides services that include, but are not limited
to:
Delivering retirement and investment education to Plan participants, designed to
increase retirement Plan participation and illustrate the importance of a calculated
retirement savings strategy.
Reporting on performance, risk and fees of investment alternatives available for the
Plan.
Conducting “provider searches” of various recordkeepers, custodians, and third party
administrators.
Performing an analysis of the fees and expenses associated with all service providers.
401(k) Plan Participant Services
As part of our services to qualified retirement plans, we will provide investment advice as
a fiduciary as defined in Sections 3(21)(A) and 3(38) of ERISA, to Plan participants who
specifically request such advice. Lumin provides services to 401(k) Plan participants as a
“Participant Adviser,” delivered through our advisory arrangement, titled “Managed Account
Program” (hereinafter “MAP”). The MAP offers a broad range of “Allocation Models,”
representing various levels of risk and return. Each Allocation Model is comprised of a
diversified portfolio of competitively-priced mutual funds or exchange-traded funds (“ETFs”).
In our comprehensive approach to operating the MAP, Lumin’s process adopts the seven
“Global Fiduciary Principles,” which include:
1.Know the professional standards, governing laws, and provisions of ERISA plans
2.Diversify assets to a specific risk/return profile of the Plan participant
3.Prepare the participant’s IPS
4.Select prudent investments, and document the activities
5.Control and account for investment expenses
Part 2A of Form ADV 3 Lumin Financial, LLC
6.Monitor the selected investments
7.Avoid conflicts of interest and prohibited transactions
Individual Investment Advisory Services
Lumin provides investment advisory services for individuals (which includes individuals,
high-net-worth investors, charitable organizations, and corporations) on a discretionary basis.
Investment advisory services are based on the individual goals, objectives, time horizon,
and risk tolerance of each client. Based on the information provided by each client, Lumin
creates and delivers an IPS, which includes a projection of retirement income and investment
risk. The IPS outlines the client’s income, wealth, risk tolerance and tax levels; and it helps
establish parameters for the investment advisory process.
Investment Advisory Services include, but are not limited to, the following:
Analyzing the economy and financial markets;
Developing and managing investment strategy;
Constructing and managing the personal investment policy;
Implementing asset allocation and securities selection;
and
Continuously monitoring and reporting progress of the portfolio.
We rely upon the information you provide us; Lumin will not independently verify the
accuracy or completeness of the information you provide. Therefore, clients must let us know, in
writing, if their financial needs, circumstances or objectives change.
Clients receiving discretionary investment advisory services may also elect to receive
additional, non-discretionary advice with respect to outside accounts, including retirement
accounts, for no additional fee. If a client elects to receive this additional service, Lumin will
provide investment recommendations for the client’s identified outside accounts based on the
strategies available to such accounts for the client’s self-implementation.
Recommendations to Rollover or Transfer Retirement Assets
We act as an “investment advice fiduciary” under ERISA and the Internal Revenue Code
of 1986, as amended (the “Code”) when we make a recommendation to a retirement investor to
distribute or transfer (“rollover”) a retirement plan account or individual retirement account
including, Health Savings Accounts (“HSAs”), Medical Savings Accounts (“MSAs”) and
Coverdell Education Savings Accounts (“Educational IRAs”) to us for management. Retirement
investors include ERISA plans, participants and individual retirement account (“IRA”) owners.
If you accept the recommendation, Lumin will receive compensation that we would not
Part 2A of Form ADV 4 Lumin Financial, LLC
otherwise receive. Therefore, the recommendation creates a conflict of interest. To address this
conflict we must comply with the impartial conduct standards that require us to always provide
prudent investment advice designed to meet the retirement investor’s investment goals. We must
put the retirement investor’s financial interest ahead of our own interests when making such
recommendations and avoid misleading statements about conflicts of interest, fees, and
investments. In addition, among other requirements, our fees must be reasonable for our services.
A retirement investor leaving an employer has four options regarding an existing
retirement plan (and under certain circumstances may engage in a combination of the following
options). We will provide general education, for discussion purposes, regarding the “pros and
cons” to each of these choices: (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) roll over to an IRA, or (iv) cash out the account value (which could, depending upon the
client’s age, result in adverse tax consequences). If we recommend a roll over from a retirement
plan account or a transfer of an IRA account into an account to be managed by Lumin, such a
recommendation creates a conflict of interest if the retirement investor accepts the
recommendation as we earn a fee on the market value of the rollover or transferred IRA which
would not be earned if the money was not placed under our management.
529 Education Plan Advisory Services
Lumin provides investment advisory services for 529 Education Plans. Investment
advisory services are based on the individual goals, objectives, time horizon, and risk tolerance
of each client.
Financial Planning Services
Financial Planning Services may include, but are not limited to: investment planning, life
insurance, tax concerns, retirement planning, college planning, and debt/credit planning.
Implementation of any advice or recommendations pertaining to securities and/or non-securities
matters (such as insurance), in whole or in part, is entirely at the client’s discretion through the
service provider(s) of the client’s choice. Clients will engage us by first executing a Financial
Planning agreement and our services are offered on a fixed fee or hourly fee basis. If you choose
to engage us to provide other services, such as investment advisory, you will sign a separate
investment advisory agreement and pay a separate and additional fee.
Types of Investments
Lumin limits our investment advice to mutual funds, equities, bonds, fixed income, debt
securities, ETFs, insurance products including fixed annuities and government securities. Lumin
may use other securities as well to help diversify a portfolio when applicable.
Part 2A of Form ADV 5 Lumin Financial, LLC
Client Tailored Services and Client Imposed Restrictions
Lumin offers the same suite of services to all of our clients. However, each client’s
financial plan and implementation is dependent upon the client’s IPS. The IPS outlines each
client’s current situation (income, tax levels, time horizon, and risk tolerance levels) and is used
to construct a specific plan that best matches the client’s restrictions, needs, and targets.
Clients may impose restrictions in investing in certain securities or types of securities in
accordance with their values or beliefs. However, if the restrictions prevent Lumin from properly
servicing the client account, or if the restrictions would require Lumin to deviate from our
standard suite of services, Lumin reserves the right to end the relationship.
Assets Under Management
Regulatory
Discretionary Assets
Regulatory
Non-discretionary Assets
Non-Regulatory
Assets
Date
Calculated
$145,858,745 $29,599,792 $1,533,156 12/31/2022