firm brochure 15 page amended 031114-1

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    Part 2A of Form ADV: Firm Brochure

    Item 1 Cover Page

    Legacy Innovations, Inc.

    157 N Chambers, Unit 1Galesburg, IL 61401

    Branch Office:7001 16th StreetBerwyn, IL 60402

    Telephone: 708-668-5971309-351-9638

    Website: legacyinnovations.net

    This brochure provides information about the qualifications and business practices of Legacy Innovations,Inc. If you have any questions about the contents of this brochure, please contact us at 708-668-5971 or309-351-9638 or by e-mail to [email protected] for Mike; 847-606-9842 [email protected] for Dave. The information in this brochure has notbeen approved or verified by the United States Securities and Exchange Commission or by any statesecurities authority.

    Additional information about Legacy Innovations, Inc. also is available on the SEC's website atwww.adviserinfo.sec.gov.

    Registration as a "Registered Investment Advisor" or "Investment Advisor Representative" does not implyany certain level of skill or training.

    Brochure dated March 11, 2014

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    Item 2 Material Changes

    No material changes.

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    Item 3 Table of Contents

    Cover Page 1, continues on page 20Material Changes 2, continues on page 21Table of Contents 3, continues on page 22Advisory Business 4, continues on page 23

    Fees and Compensation 5, continues on page 24Performance Based Fees 6, continues on page 25Types of Clients 7, continues on page 26Methods of Analysis 8, continues on page 27Disciplinary Information 9, continues on page 28Other Affiliations 10, continues on page 29Code of Ethics, Personal Trading 11, continues on page 30

    Participation or interestClient Transactions

    Brokerage Practices 12, continues on page 31Review of Accounts 13, continues on page 32Client Referrals 14, continues on page 33Custody of Client Assets 15, continues on page 34

    Investment Discretion 16Voting of Client Securities 17Financial Information 18Executive Officer Information 19

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    Item 4 Advisory Business

    Legacy Innovations, Inc. is a financial services company which offers fee for service, asset based fees formanagement and commission based products depending upon our clients wants and needs. The firm wasfounded in November of 2009 and became a Registered Investment Advisor in March of 2010. Currently,the only owner is Michael Ramage. Michael and David Mattea are currently the only Investment Advisor

    Representatives at the firm.

    Fee based services are offered in several different formats. Flat fee services are charged for several typesof single topic financial plans, i.e. college expense planning, retirement planning, survivor needs planning,etc. The flat fee will be quoted after the initial data gathering session (which is free of charge) is completed.This is necessary to allow the Investment Advisor Representative the opportunity to determine the extent ofthe clients needs and estimate the time that will be involved to produce the desired financial plan. Inaddition, comprehensive financial plans are available. Fee based services are also available for researchand opinion on any permitted financial products or services, or for consulting work regarding any and allfinancial issues. The fee for these services is $250 per hour.

    Our practice is driven to the needs of our clients. Our financial plans are customized to each individualclient and reflect their needs and desires. We will follow any restrictions that are placed upon us by our

    clients in regards to industries in which they will not invest for whatever reason or products that they will notutilize.

    We currently also have client assets under management on an asset based fee, such fees are put forth inthe following schedules.

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    Item 5 Fees and Compensation

    Investment Advisory services and Portfolio management services are provided to all clients with nominimum asset size or net worth requirement and charged as follows:Individual Securities PortfolioClient Level Asset Level Fee Structure

    1 Below $250,000 $2,500$250,000 - $499,999 1%

    2 $500,000 - $999,999 $5,000 plus .9% of assets over $500,000$1,000,000 - $2,500,000 $9,500 plus .8% of assets over $1,000,000

    3 $2,500,000 - $4,999,999 $21,500 plus .7% of assets over $2,500,0004 $5,000,000+ $39,000 plus .5% of assets over $5,000,000

    Mutual Fund/ETF PortfolioClient Level Asset Level Fee Structure

    1 Below $250,000 $2,000$250,000 - $499,999 .8%

    2 $500,000 - $999,999 $4,000 plus .7% of assets over $500,000

    $1,000,000 - $2,500,000 $7,500 plus .6% of assets over $1,000,0003 $2,500,000 + $16,500 plus .5% of assets over $2,500,000

    These fees are for advisory/managementservices only. Custody fees and transaction fees are separate anddisclosed prior to transactions being performed or contained in fund prospectuses, if applicable.

    Fees are negotiable.

    Asset based fees include the following based on client level: (1) portfolio allocation and monitoringincluding quarterly/threshold rebalancing with annual client review; (2) same with quarterly client review;(3) same with monthly/threshold rebalancing with monthly client review; (4) same with anytime clientreview. The first fee may be prorated based on date of Advisory Services Agreement and based upon value

    agreed upon by client. The client has a right to terminate the contract without penalty within five (5)business days after entering into the contract, thereafter, Advisory Services agreements may be cancelled by30 days written notice before its expiration date, fees are not refundable.

    Our firm bills our clients for the fees which they incur. We bill on a quarterly basis beginning with the datewe have a signed advisory agreement using an agreed upon figure for your "assets under management. Forexample if your agreement is dated January 13, we will bill you on the following dates: January 13, April13, July 13, and October 13. The bills for your ongoing asset under management fees will be based uponthe most recent statement available.

    Our firm does sell insurance products for commissions. This may represent a conflict of interest due to thedifferent amounts of compensation that may be received for different financial products. Our firm discloses

    the commissions which we earn from the sale of any financial products that we recommend along with thereasons for our recommendation of a certain financial product over another. Sometimes the best productmay pay the most commission, sometimes it may pay the least. We offer a variety of products from

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    Item 6 Performance-Based Feesand Side-By-Side Management

    Our firm does not charge performance based fees.

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    Item 7 Types of Clients

    Legacy Innovations, Inc. provides investment advisory and financial planning services to a wide variety ofindividuals, companies and trustees. Our practice focuses upon personal financial planning (collegefunding, retirement, survivor needs, long term care, etc.), business financial planning (business succession,fringe benefits, buy/sell agreements, etc.) and investment management for all our clients.

    We do not have a minimum account size. We do not hold our clients assets, therefore, we do not havecontrol over whether the custodian of our clients assets has a minimum account size or their requirementsfor opening or maintaining accounts.

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    Item 8 Methods of Analysis, Investment Strategies and Risk of Loss

    The firm utilizes NaviPlan for its comprehensive and single issue financial plans. The methods of analysisfor making Investment recommendations is based upon research provided from various news sources,Bloomberg News, CNBC, CNN, etc on television. Also, the firm conducts research on the internet includingthe use of information from company websites, news organization websites, SEC disclosure documents,

    etc.

    All investment strategies are the proprietary property of the firm. Clients are given the opportunity tochoose from a variety of investment products, securities, insurance, etc. that will be utilized to achieve theclient's desired goals and objectives while attempting to limit the clients risk of loss through the use ofportfolio diversification (holding investments from different investment classes). Advanced strategies forminimizing the risk of loss may consist of the use of hedging strategies to minimize risk in portfolio positionsthat cannot be diversified, i.e., options to cover downside risk in large positions of employer stock is thebest example of when this would occur.

    All investment strategies are fully disclosed to and approved by the client before they are used.

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    Item 9 Disciplinary Information

    There have never been nor are there currently pending any disciplinary actions against the firm or any of itsinvestment advisory representatives.

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    Item 10 Other Financial Industry Activities and Affiliations

    The firm's sole shareholder, Michael Ramage, is the sole proprietor of a law firm and real estate brokeragefirm as well as an investor and member of several Real Estate Investment Groups. This relationship isdisclosed to all clients prior to their engagement of services. These relationships do not create conflicts ofinterests between the firm and its clients.

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    Item 11 Code of Ethics, Participation or Interest in ClientTransactions and Personal Trading

    The firm places the needs of our clients first. We do not engage as parties in transactions with our clients.For example, we are not the buyer of the securities that you are selling in the transaction. Due to divergentneeds, the firm or one of its affiliates may be selling a particular security that you are buying or buying asecurity that you are selling. This could occur due to an over exposure to a single security (typically

    employer stock). A reason for the divergent actions is given whenever this occurs.

    The firm will always disseminate recommendations to clients and execute client transactions, giving aminimum of one hour to respond to recommendations, before acting on its or its officers, employees, andindependent contractors (affiliated entities) behalf. The client's interests always come first. The firm and itsaffiliated entities will not be allowed to sell anything they are recommending to clients to buy or buyanything they are recommending for clients to sell without contacting all clients and informing them of areversal in the firms position and waiting for a period of 24 hours to perform such a transaction. Unless thetransaction is a buy recommendation and adverse information about the subject security becomes known tothe general public causing a loss greater than 10% in the security. Under such circumstances the firm andits affiliated entities may act to minimize their losses after disseminating the information to all affectedclients and eliminating client positions, if desired, unless the client perceives such a move in the stock to bea buying opportunity and acts contrary to the firm's reversal.

    The firm may not have control over certain transactions in its own or a clients account that may reflect aconflict. For example, the firm may be recommending a client sell a security while the firm is buying thesecurity due to a person affiliated with the firm having a spouse that is exercising a stock award oremployee stock purchase plan from their employer. Also, a client may sell or buy stock by the exercise of astock award or employee stock purchase program of their employer which results in a transaction that isagainst the position of the firm in the given security.

    If anyone in the firm trades on a personal basis, the individual will disseminate their trade to client's beforeexecuting their personal trade. This dissemination may be done by e-mail, telephone call or posting to thecompany website.

    The firm obeys all laws related to securities transactions and insider trading.

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    Item 12 Brokerage Practices

    The firm is not a broker/dealer and does not maintain a relationship with a broker/dealer. When needed byadvisory clients, the firm utilizes the services of a broker/dealer chosen by the client. If the client does notcurrently have a relationship with a broker/dealer, the firm will make a recommendation of at least 3broker/dealers for the client to consider. The firm does not receive any compensation from broker/dealers

    in any form.

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    Item 13 Review of Accounts

    Reviews are conducted on a basis as determined by the client: monthly, quarterly or annually. The levelsvary from maintaining asset allocation to measuring financial plan goals. The triggering factors are thepassage of time or asset allocation hitting the clients predetermined allocation cap.

    Reviews are prepared by the Investment Adviser Representative and approved by the CCO MichaelRamage to ensure compliance with client contract, financial plan and/or account questionnaire andcorporate policies and procedures on all accounts.

    Clients receive a review letter on the basis of their selected review cycle documenting their situation andcorresponding goals, the client has the option of discussing their review over the telephone or schedulingan in-person meeting.

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    Item 14 ClientReferrals and Other Compensation

    The firm does not accept referrals from other firms for compensation. The firm also does not refer clients toother service providers for compensation.

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    Item 15 Custody

    The firm does not have custody over client assets or funds. The firm may have third party authority overaccounts that are held in the name of the client at other financial firms and/or banks, if given to the firm bythe client.

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    Item 16 Investment Discretion

    The firm may exercise discretion over a clients account in accordance with the clients' engagementagreement. It is the firms practice to get client approval for any and all transactions. However, undercertain circumstances, i.e. the client is traveling and unavailable, the firm may exercise its discretionaryauthority after a failure of the client to respond to the recommendation of the firm if the market is reacting

    adversely to the clients' interests.

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    Item 17 Voting ClientSecurities

    The firm does not vote client securities.

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    Item 18 Financial Information

    The firm has no financial conditions that are reasonably likely to impair our ability to meet contractualcommitments to clients.

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    Item 19 Requirements for State-Registered Advisers

    Michael R Ramage, Sole Owner, Pres/CEO/CCO, Bachelor's Degree in Political Science with minor inEconomics (Western Illinois University), Juris Doctor Degree from Northern Illinois University. For the pastfive (15) years Michael has been engaged in the following endeavors: extensive experience preparing andimplementing financial plans for retirees, entrepreneurs and young professionals. Financial planning

    focused upon long-term investing, asset protection, college education funding, asset allocation, retirementplanning, estate tax planning, real estate investing, business succession planning, and fringe benefit plans.Investment advisory services focused upon investment selection and asset management. As amanager/Registered Principal, Michael was responsible for training and supervising registeredrepresentative and insurance agents in all aspects of their activities. Michael maintains an IL real estatemanaging broker's license, he spends minimal time related to this activity (20 hours per month). Michael isalso actively engaged in the practice of law, in Illinois. He handles estate planning, real estate, corporateand family law matters. Michael spends approximately 60 hours per month on these activities. Michaelworks approximately 60 to 70 hours per week.

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    companies that allows us to make the best recommendations for our clients. These recommendations willbe based upon the clients needs and desires regarding their overall portfolio as well as the strengths of theproducts that we recommend.

    Clients always have the option to utilize the services of another firm to purchase any financial product thatthey believe they need to achieve their financial goals or that was recommended in one of our financialplans.

    Our firm is not affiliated with any Broker/Dealer and does not receive commissions, marketing fees,markups or any other compensation from any Broker/Dealer or sponsor of any investment product. Thecommissions referenced above are solely from the sale of insurance products.

    If a client desires a level of access that is higher than their asset level, the firm may accommodate theclients wish on an hourly fee basis for the additional meetings or reviews.

    The firm also maintains a time of services based fee arrangement for individuals that take an activeinvolvement in the management of their assets but want to have access to our advisers to evaluate their

    portfolios and discuss their decisions and plans. The fee for these arrangements is as follows:

    Level 1: Comprehensive financial plan withportfolio allocation and annual client reviewLevel 2: Comprehensive financial plan withportfolio allocation and semiannual client reviewLevel 3: Comprehensive financial plan withportfolio allocation and quarterly client reviewLevel 4: Comprehensive financial plan withportfolio allocation and monthly client reviewLevel 5: Comprehensive financial planwith portfolio allocation and anytime client review

    These services are based upon a retainer plus time expended basis as follows:Level 1: $2000 Level 2: $3000 Level 3: $5000 Level 4: $8000 Level 5: $10,000

    The retainer applies to the following items: Comprehensive financial plan and the corresponding review toinclude two hours of preparation and one hour of review both at the frequency determined by the clientlevel chosen by the client. Additional time is billed at the hourly rate of $250 per hour.

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