Description of Firm
Compass Advisory Partners, LLC is a registered investment adviser primarily based in Cookeville, TN.
We are organized as a limited liability company ("LLC") under the laws of the State of Tennessee. We
have been providing investment advisory services since 2008. We are primarily owned by Travis
Giffey. We also conduct business under the d/b/a ("Doing Business As") names of Fidelis Financial
Strategies, Wakefield Venture Group, and Corley/Kent Group.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we," "our," and "us" refer to you either as a client or
prospective client of our firm.
Travis W. Giffey is the sole principal owner of Compass. Please see Brochure Supplements, Exhibit A,
for more information on Mr. Giffey and other individuals who formulate investment advice and have
direct contact with clients, or have discretionary authority over client accounts.
As of December 31, 2023, we provide continuous management services for $262,536,905 in client
assets on a discretionary basis.
SERVICES PROVIDED
At the outset of each client relationship, Compass spends time with the client, asking questions,
discussing the client's investment experience and financial circumstances, and reviewing options for
the client. Based on its reviews, Compass generally develops with each client:
•a financial outline for the client based on the client's financial circumstances and goals, and the
client's risk tolerance level (the "Financial Profile" or "Profile"); and
•the client's investment objectives and guidelines (the "Investment Plan" or "Plan").
The Financial Profile is a reflection of the client's current financial picture and a look to the future goals
of the client. The Investment Plan outlines the types of investments Compass will make or recommend
(both) on behalf of the client to meet those goals. The Profile and the Plan are discussed regularly with
each client, but are not necessarily written documents.
Financial Planning
Compass offers both Limited and Full Financial Planning services to those clients in need of such
services in conjunction with Portfolio Management services. Compass's Limited Financial Planning
services normally address areas such as general cash flow planning, retirement planning, and
insurance analysis. The goal of this service is to assess the financial circumstances of the client in
order to more effectively develop the client's Investment Plan. Limited Financial Planning is not offered
as a stand-alone service or for a separate fee.
If requested, Compass will provide a client with Full Financial Planning services for a separate and
additional fee. These more comprehensive services are provided in conjunction with Portfolio
Management services and may include advice that addresses one or more areas of a client's financial
situation, such as estate planning, risk management, budgeting and cash flow controls, retirement
planning, education funding, and investment portfolio design. You are under no obligation to act on our
financial planning recommendations. Should you choose to act on any of our recommendations, you
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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.
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.
Portfolio Management
We offer discretionary portfolio management services. Our investment advice is tailored to meet our
clients' needs and investment objectives. If you participate in our discretionary portfolio management
services, we require you to grant our firm discretionary authority to manage your account.
Discretionary authorization will allow us to determine the specific securities, and the amount of
securities, to be purchased or sold for your account without your approval prior to each transaction.
Discretionary authority is typically granted by the investment advisory agreement you sign with our firm
and the appropriate trading authorization forms.
Most clients choose to have Compass Advisory Partners, LLC manage their assets in order to obtain
ongoing in-depth advice and life planning. As described above, at the beginning of a client
relationship, Compass meets with the client, gathers information, and performs research and analysis
as necessary to develop the client's Investment Plan. The Investment Plan will be updated from time
to time when requested by the client, or when determined to be necessary or advisable by Compass
based on updates to the client's financial or other circumstances.
To implement the client's Investment Plan, Compass will manage the client's investment portfolio on a
discretionary basis. As a discretionary investment adviser, Compass will have the authority to
supervise and direct the portfolio without prior consultation with the client.
Notwithstanding the foregoing, clients may impose certain written restrictions on Compass in the
management of their investment portfolios, such as prohibiting the inclusion of certain types of
investments in an investment portfolio or prohibiting the sale of certain investments held in the account
at the commencement of the relationship. Each client should note, however, that restrictions imposed
by a client may adversely affect the composition and performance of the client's investment portfolio.
Each client should also note that his or her investment portfolio is treated individually by giving
consideration to each purchase or sale for the client's account. For these and other reasons,
performance of client investment portfolios within the same investment objectives, goals and/or risk
tolerance may
differ and clients should not expect that the composition or performance of their
investment portfolios would necessarily be consistent with similar clients of Compass.
Model Portfolios (material disclosure). 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. The models are Risk-Based Global Allocation Models
utilizing funds as the investment vehicle. 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.
Third Party Money Managers (TPMMs)
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Occasionally our firm utilizes the sub-advisory services of a TPMM for the management of client
accounts. Prior to utilizing sub-advisors for our clients, our firm will provide initial due diligence on third
party money managers and ongoing reviews of their management of client accounts. In order to assist
in the selection of a TPMM, our firm will gather client information pertaining to financial situation,
investment objectives, and reasonable restrictions to be imposed upon the management of the
account.
The sub-adviser(s) may use one or more of their model portfolios to manage your account. We will
regularly monitor the performance of your accounts managed by sub-adviser(s), and may hire and fire
any sub-adviser without your prior approval. We may pay a portion of our advisory fee to the sub-
adviser(s) we use; however, you will not pay our firm a higher advisory fee as a result of any sub-
advisory relationships.
When appropriate and in accordance with the Investment Plan for a client, Compass may utilize one or
more TPMMs, each a "Manager". Having access to various Managers offers a wide variety of manager
styles, and offers clients the opportunity to utilize more than one Manager if necessary to meet the
needs and investment objectives of the client. Compass will recommend the Manager(s) it deems most
appropriate for the client. Factors that Compass considers in recommending Managers generally
include the client's stated investment objective(s), management style, performance, risk level,
reputation, financial strength, reporting, pricing, and research.
The client will select one or more Managers recommended by Compass. The Manager(s) will generally
be granted discretionary trading authority to provide investment supervisory services for the portfolio.
With respect to assets managed by a Manager, Compass's role will be to monitor the overall financial
situation of the client, to monitor the investment approach and performance of the Manager(s), and to
assist the client in understanding the investments of the portfolio.
Financial Consulting Services
We offer financial consulting services that primarily involve advising clients on specific financial-related
topics. The topics we address may include, but are not limited to, risk assessment/management,
investment planning, financial organization, or financial decision making/negotiation.
Types of Investments
We offer advice on equity securities, certificates of deposit, municipal securities, variable annuities,
mutual fund shares, United States government securities, options contracts on securities, money
market funds, REITs and ETFs.
Additionally, we may advise you on various types of investments based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception
of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the
investment advice we provide to you may be different or conflicting with the advice we give to other
clients regarding the same security or investment.
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
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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:
•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.
Wrap Fee Programs
We are not the sponsor or manager of any wrap fee program.