Business Continuity Plan Disclosure Statement And Fee Disclosures

 

Aspetuck Financial Management LLC (the “Firm”) is providing you with this document to inform you of its ability to respond to certain business disruptions at Aspetuck Financial Management LLC. Aspetuck Financial Management LLC, is associated with TD Ameritrade Institutional Services (TD) and Charles Schwab Institutional Services (Schwab). Ability to respond to business disruptions is  important to your relationship with Aspetuck Financial Management LLC. TD and Schwab are our custodians. Our Custodians hold your assets and along with their respective Broker/Dealer, they process all transactions in your brokerage account as directed by the Firm and owner of account. In general, Aspetuck Financial Management LLC, TD, and Schwab maintain business continuity plans and intend to continue business in the event of a significant business disruption.

 Aspetuck Financial Management LLC has made arrangements and plans to service your business in case our offices are closed for either one day or an extended period of time. Certain services such as the execution of securities transactions and the maintenance of customer funds and securities are expected to be available even if the offices are closed due to a business disruption event.  Accordingly, the Firm’s ability to respond to certain business disruptions is partially dependent on TD Ameritrade Inc. and or Charles Schwab & Co. Inc. to carry out those functions.

In the event of a significant business disruption the firm may route calls to our custodians from alternate locations, or transfer operations to the alternate emergency office, 1400 Cross Highway Fairfield CT; or The Patterson Club if there is no power at 1400 Cross Highway. The Patterson club is a Hot site with its own power generator and secure web access services. Aspetuck Financial pays to use its facilities and provides office space and accommodations. Although Aspetuck Financial Management LLC intends to continue business in the event of a significant business disruption, there are some disruptions that may render the Firm unable to continue business.  Under such circumstances, the Firm will ensure that clients will be able to access their funds and securities within a reasonable time.

 

To provide clients with up-to-date information during a significant business disruption to Aspetuck Financial Management LLC office, clients may call the Firm’s telephone number at (203)226-5733 or visit our Business Continuity information Web page at www.aspetuckfinancial.com. If for any reason the main line is not in service, then clients should use the following emergency number, 203-216-4882. If the main line is down (203-226-5733), calls will be forwarded to 203-216-4882 and 203-767-7094, to be serviced. Optimum Voice Dashboard allows for call forwarding to two numbers. If primary backup numbers are down, then optional numbers are available to leave messages. Clients may also leave a message for an Investment Adviser at 203-520-5086 or 203-767-9318. Please identify yourself, state that you’re a client of Aspetuck Financial Management, and that you would like to speak to Patrick Byrne. Your message will be forwarded to Patrick Byrne and he will return your call as soon as possible.

I.  Aspetuck Financial Management LLC Response to Events of Varying Scope:

The following sections describe specific events and Aspetuck Financial Management LLC corresponding general response to those events.  Clients, however, should note that these responses are subject to modification and, depending on the severity of a specific event; Aspetuck Financial Management LLC cannot guarantee that it will be able to follow the stated course of action.  If these responses are modified, Aspetuck Financial Management LLC will update the information on its Web site. 

If Aspetuck Financial Management LLC office is closed for more than one day to five days we plan to service your business from alternate locations by telephone and using web based technology provided by our broker/custodian. You will be instructed via our website or by recorded message on how to contact your Investment Adviser in order to conduct business. All business related documents can be mailed by overnight courier to the address stated on our recorded message and on our web site. Alternate emergency address to use if 27A Imperial Ave. office is closed down is 1400 Cross Highway.

 

If Aspetuck Financial Management LLC office is closed for more than five days to ten business days we plan to service your business from a pre-arranged alternate location. Clients will be able to visit our temporary office. You will be instructed via our website or by recorded message on how to contact your Investment Adviser in order to conduct business and get the address of our alternate temporary office.

 

If Aspetuck Financial Management LLC office is closed for more than ten business days we plan to service your business from an alternative location based in Westport area indefinitely until further notice. You will be instructed via our website or by recorded message on how to contact your Investment Adviser in order to conduct business and get the address of our alternate office.

 

Under the following scenarios, Aspetuck Financial Management LLC intends to continue its business:

 

A Disruption to a single building or Firm-Only business disruption

 

These disruptions may be caused by physical damage, technology problems, or an inability to have personnel arrive at an office.  In the event that there is a significant business disruption to a single building or the Firm’s internal primary systems, Aspetuck Financial Management LLC may, if necessary, transfer its operations or route incoming calls to TD Ameritrade Advisory Services and Charles Schwab Institutional Services, another alternative office in Westport area, or provide instructions via our website and telephone message on how to conduct business.  From this separate location, Aspetuck Financial Management LLC. will accept client orders.   In this process, clients may experience a minor delay in reaching the firm due to increased client calls, technology delays, or other minor difficulties arising from the transfer of operations.  Aspetuck Financial Management LLC expects that operations could be disrupted for several hours or days.  If TD Ameritrade Advisory Services and or Charles Schwab Institutional Services Inc. trading platform is affected, there may be a more significant delay.  TD Ameritrade Advisory Services and Charles Schwab Institutional Services Ameritrade Inc., however, will be able to place orders outside the trading platform.

A Business-District, City-Wide or Regional Disruption

In the event that there is a significant business disruption that affects the business district, city or region where any of the Aspetuck Financial Management LLC primary systems are located, Aspetuck Financial Management LLC may, if necessary, transfer its operations or route incoming calls to an alternate temporary office.  In this process, Aspetuck Financial Management LLC may experience a minor delay in reaching our Custodians due to increased client calls, technology delays or other minor difficulties arising from the transfer of operations.

II. In the event that Aspetuck Financial Management LLC employees cannot be accessed by clients.

If client’s cannot make contact with a Aspetuck Financial Management LLC appropriate service personnel then clients that have a TD Ameritrade account must call them at 1-866-268-3247. If client has a Schwab Institutional account call (877) 347-6984, for assistance. If our custodians are also experiencing an emergency then visit TD Ameritrade or Schwab’s emergency web page for instructions:

TD Ameritrade Client accounts, login at www.advisorclient.com,

Aspetuck Financial Investment Adviser can log in on www.advisorservices.com (see business continuity hyper link lower part of page)

Charles Schwab Client accounts, login at www.schwaballiance.com

Aspetuck Financial Investment Adviser can log in on www.schwabinstitutional.com

Client may use your Morningstar site at http://cwp.morningstar.com/ to access account balances. You will need your ID and password to access account information on Morningstar. Morningstar client service number is 866-215-2503. They can only provide instructions on how to access your account balances. You cannot access funds or make any business transactions.

If you have a 529 College Savings account, contact American Funds Service at (800) 421-0180 x3 for service. Web address for American Funds is https://www.americanfunds.com. Morningstar has emergency contact information on site in case of an emergency and multiple backup service groups in different geographical areas of the country.

Mail any correspondence to:

American Funds Service Center

5300 Robin Hood rd

Norfolk VA, 23513-2430

If clients cannot make contact with a Aspetuck Financial Management LLC appropriate service personnel then clients that have a T.D. Ameritrade account must call TD at 1-866-268-3247. If client has a Schwab account call Schwab Signature Alliance at 800-515-2157 (our client support center) for assistance. If you use your Schwab mobile application, you may access account information and services using your smart phone. If you have T.D. Ameritrade accounts and have signed up for T.D.’s mobile application, you can access your T.D. Ameritrade account(s) by using your smart phone. You may call me at 203-216-4882, our emergency line, if you need help or service.

Send all deposit and account related documents to:

TD Ameritrade Accounts:

Service and Technical Support (866) 983-2683

Overnight Mail:

TD Ameritrade Institutional

7801 Mesquite Bend Drive, Suite 112

Irving, TX 75063-6043

Standard U.S. Mail

TD Ameritrade Institutional

PO Box 650567

Dallas, TX 75265-0567

Make check payable to T.D. Ameritrade Clearing, Inc.

866-983-2683

Charles Schwab Accounts:

 

For standard Delivery:

 

Overnight;

Charles Schwab & Co. Inc.

Attn: Core Service Team

1958 Summit Park Drive #400

Orlando, FL 32810-5931

 

Mailing address:

Charles Schwab & Co. Inc.

Attn: Core Service Team

P.O. Box 628290

Orlando, FL 32862-8290

 

 

American Funds

 

Regular Mail:

CollegeAmerica/ American Funds

P.O. Box 2280

Norfolk, VA

23501-2280

 

Or mail

American Funds Service Center

5300 Robin Hood rd

Norfolk VA, 23513-2430

 

(800) 421-0180 x3 service

 

 

For Aspetuck Client Correspondence ONLY

 

Aspetuck Financial Management, LLC/

CO Patrick Byrne

1400 Cross Highway

Fairfield, CT 06824

 

A.         Trades

 

Custodians will process the following closing security trades:  (1) Sale of security position held long in your account or (2) Purchase of a security to close-out a short security position.  These orders will only be handled as market orders. In order to place these specific orders, you must provide our Custodians with the following information:

 

Your brokerage account number;

1.      Your name (as registered on the brokerage account);

2.      Security description, including symbol or CUSIP® number; and

3.      Number of shares

 

If web account access is down and Aspetuck Financial can’t process your trades then Aspetuck can call in trade. If Aspetuck can’t place trade client can call Schwab Alliance or TD Ameritrade using phone numbers provided.

 

B.         Cash Disbursements

 

Our Custodians will process cash disbursements upon written instructions (verbal confirm) that must include the following information:

1.      Your brokerage account number;

2.      Your name (as registered on the brokerage account);

3.      Exact amount to be disbursed;

4.      Indicate method of disbursement (as follows) and provide the information indicated:

a.      For a check, which is payable to account name only, indicate name and address of record check is to be mailed to;

b.      For federal funds, please indicate receiving bank name, ABA number, and receiving bank account number.  Please note that the receiving bank account name and brokerage account name must be identical unless we have a letter of authorization on file indicating alternate instructions.

 

If web account access is down and Aspetuck Financial can’t process your disbursement, then Aspetuck can call in disbursement instructions. If Aspetuck can’t disburse funds client can call Schwab Alliance or TD Ameritrade using phone numbers provided to provide instructions for disbursement.

 

 

 

C.         Securities Transfers

 

Our Custodians will process security transfer requests upon written instructions that must include the following information:

 

1.      Your brokerage account number;

2.      Your name (as registered on the brokerage account);

3.      Description of security (ies) to be transferred, including symbol(s) or CUSIP number(s);

4.      Quantity to be transferred; and

5.      Receiving account information for securities, as follows:

a.      Name of brokerage firm (address, phone number), account title (names, address), account number, DTC number. A simple way to transfer securities is to complete a Transfer of Asset form obtainable on client website.

Updated March 10, 2019

Fee Disclosures 
Aspetuck Financial Management, LLC (AFM) charges for its investment advisory services as a percentage of assets under management per account.  As a participant in the Program, Client will pay an annualized Investment Advisory Fee, in accordance with Schedule A appearing below. Effective for all new clients, January,1, 2018, the maximum Investment Advisory Fee is 0.85% per annum, and reduces based on asset breakpoints. 2017 Bloomberg's Investor Guide to Fees and Expenses report, shows that investors with less than $100,000 pay more than 1.12% on average; investors with more than $100,000 pay less than 1.12%; a $1,000,000 account pays 1.02% on average. Advisory fee may also be subject to negotiation depending upon a number of factors, including size of the Account(s)(multi-million dollars) or a special promotional offer. Fees may be lower for different clients in the future, which may be lower than existing clients.  In addition to paying for portfolio management services, Advisory fee covers cost of administrative services, client support services, research, portfolio management tools, portfolio reports, tax reports, tax preparation assistance, brokerage statements, and financial/retirement planning services. Additionally, there may be a nominal transaction fee/commission for execution of each trade by brokerage firm. The transaction fee or commission is charged by the brokerage firm and not by AFM. AFM is not compensated by commission or transaction fee. AFM will seek to minimize transaction costs when possible by investing in no-transaction fee mutual funds, no-transaction fee ETFs. Transaction fees incurred by a client may be added to your cost basis in non-retirement accounts thereby lowering future taxes. At present time, TD Ameritrade commission charge for equity and non-commission free ETF transactions executed by AFM is $9.99 and Charles Schwab it’s $6.95. TD Ameritrade commission charge for non-NTF mutual funds is $25 transactions executed by AFM, and Charles Schwab is $76 (no charge for sale). Clients shall pay Brokerage firm’s short term mutual fund or ETF redemptions fees if charged or short term ETF redemption fee if triggered by a sale of an ETF within 30 days after a purchase and the sale of a no transaction fee mutual fund held less than 90 days. Those charges could be triggered by unplanned client funds request that exceed cash-equivalents and or client decision to “time the market” (sell equities and going to cash). AFM asa matter of practice will seek to avoid those fees by investing in no transaction fee ETFs whenever possible or not selling until redemption fee period has expired. TD Ameritrade charges $49.99 for short term mutual fund redemption fee, and Charles Schwab $49.99. TD Ameritrade charges $9.99 for no transaction fee ETFs sold within 30 days., and Charles Schwab does not charge any ETF redemption fees given a no transaction fee ETF. When a transaction fee ETF is sold at Charles Schwab the fee is $6.95.  The above rates apply to online trades and for clients with electronic statements. If client choose statement delivery by mail then transaction fees are for TD Ameritrade and Charles Schwab respectively$9.99 and $6.95. The transaction costs of liquidation requests or client account closing liquidation request are charged to client. The Adviser will not be compensated on the basis of a share of capital gains upon or capital appreciation of client funds (or any portion of client funds). Client understands that Client may be able to purchase shares of mutual funds or ETFs offered through the Program outside of the Program directly from the mutual fund complex issuing them or Discount Brokerage Firm, its principal underwriter or distributor without paying the Advisory Fees on such shares (by subject to any applicable sales charges). Certain of the mutual funds or ETFs offered through the Program may be offered generally to the public without a sales charge or commissions. Clients will not be invested in mutual funds that have upfront or contingent deferred sales charges nor mutual funds that have 12b-l distribution fees (trail commissions).  

SCHEDULE A  Program: Risk Managed Portfolio Program Fee Schedule 
 Assets Under                                                 Investment Advisory Management Fee
First $1,000,000                                             0.85%
Next $3,000,000                                            0.70%  
Thereafter                                                      0.65% 

 CollegeAmerica 529 Savings Plan advisory fee is a flat fee of 0.65%.

Disclosure

Aspetuck Financial Management does not offer legal or accounting advice to our clients. However, we may from time to time, discuss or recommend financial strategies, products, and services which have tax implications, and under specific agreements with clients or because of our fiduciary role, assist with the preparation of tax returns. Clients are urged to consult with their own legal, accounting, and tax adviser with respect to specific situations. Securities offered through Charles Schwab & Co. Inc, a registered broker-dealer – Member FINRA/SIPC. Securities offered through TD Ameritrade. Inc, a registered broker-dealer – Member FINRA/SIPC Advisory services offered through Aspetuck Financial Management, LLC, a Registered Investment Advisor. Aspetuck Financial is an independent firm not affiliated with either Charles Schwab & Co, Inc. or TD Ameritrade Inc.

There is no guarantee that participation in the Aspetuck Financial Management's RMP - Risk Managed Portfolio Program will protect you against loss of investment or meeting your financial objectives. This is no guarantee financial planning services will accomplish stated objectives. Aspetuck Financial Management does not offer legal or accounting advice to our clients. However, we may from time to time, discuss or recommend financial strategies, products, and services which have tax implications, and under specific agreements with clients or because of our fiduciary role, assist with the preparation of tax returns. Clients are urged to consult with their own legal, accounting, and tax adviser with respect to specific situations. Past performance may not be indicative of future results. Performance period period ending 05/31/2018. Aspetuck's composite returns for each of its four strategies (Aggressive 70-85% Equities , Moderate 50-70% Equities, Conservative 30-50% Equities, Risk Averse 15-30% Equities) compared to comparable MorningStar Asset Allocation Fund Benchmark Category returns (average return calculated for all asset allocation funds in respective category) for last one year, three years, and fives years periods. Comparisons made to following fund category average returns: Allocation 70-85% equities (Aspetuck's Aggressive Strategy category), Allocation 50-70% Equities (Aspetuck's Moderate strategy category), Allocation 30-50% Equities (Aspetuck's Conservative Strategy), Allocation 15-30% Equities (Aspetuck's Risk Averse Strategy). Call us to review performance results for Aspetuck's asset allocation strategies Performance compares firm's composite net return less expenses and advisory fee. Advisory fee will reduce return. Advisory fees may be found in Part2A of the advisor's Form ADV (Firm Brochure). Past Performance is no indication (or “guarantee) of future results. Asset allocation is the process of spreading assets across several different investment styles and asset classes. The purpose is to potentially reduce long-term risk and capture potential profits across various asset classes. Asset allocation does not ensure a profit nor protect against losses. All investing is subject to risk, including the possible loss of the money you invest. Past performance is no guarantee of future returns. Diversification does not ensure a profit or protect against a loss. Be aware that fluctuations in the financial markets and other factors may cause declines in the value of your account. There is no guarantee that any particular asset allocation or mix of funds will meet your investment objectives or provide you with a given level of income. IT SHOULD NOT BE ASSUMED THAT RECOMMENDATIONS MADE IN THE FUTURE WILL BE PROFITABLE OR WILL EQUAL THE PERFORMANCE OF THE SECURITIES IN THIS LIST. A copy of Firm Brochure, discussing our advisory services and fees is available for review upon request.

Please refer to Aspetuck Financial Management’s Firm Brochure for more information including advisory services and fees. Aspetuck’s Risk Managed Portfolio program risk-management process includes an effort to monitor and manage risk, but should not be confused with, and does not imply, low risk, or the ability to control risk. Diversification strategies does not ensure a profit and do not protect against losses in declining markets. Past performance may not be indicative of future results. There is risk of loss..

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The Web Site includes information obtained form various third party sources and other opinions that must be construed solely as statements of opinion and should not be construed as statements of fact. Aspetuck Financial Management LLC (AFM) opinions are not recommendations to buy, sell or hold any security or obligation issued by any obligor. Aspetuck Financial Management LLC relies on information provided by obligors, their accountants, counsel and other experts and does not perform an audit in connection with any of the information found on our site. The use of the Aspetuck Financial Management LLC Web Site by User should not be construed as an endorsement of the accuracy of any of the data or conclusions, or as an attempt to independently assess or vouch for the financial condition of any company. Each recommendation made or other opinion must be considered, if at all, as only one factor in any investment decision made by you.

Due to the number of sources from which the Content is obtained, and the potential hazards of electronic distribution, there may be delays, omissions or inaccuracies in such Content and the Web Site. THE CONTENT AND THE WEB SITE ARE PROVIDED "AS IS", WITHOUT ANY WARRANTIES. ASPETUCK FINANCIAL MANAGEMENT DOES MAKES ANY GUARANTEES OR WARRANTIES AS TO THE ACCURACY OR COMPLETENESS OF OR RESULTS TO BE OBTAINED FROM, ACCESSING AND USING ASPETUCK FINANCIAL MANAGEMENT WEB SITE. THE OTHER CONTENT, NOR ANY MATERIAL THAT CAN BE ACCESSED (VIA A DIRECT OR INDIRECT HYPERLINK OR OTHERWISE) THROUGH OUR WEB SITE. ASPETUCK FINANCIAL MANAGEMENT HEREBY DISCLAIMS ANY AND ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE AND OF NONINFRINGEMENT. ASPETUCK FINANICAL MANAGEMENT (AFM) SHALL NOT BE LIABLE TO THE USER OR ANYONE ELSE FOR ANY INACCURACY, DELAY, INTERRUPTION IN SERVICE, ERROR OR OMISSION, REGARDLESS OF CAUSE, OR FOR ANY DAMAGES RESULTING THEREFROM. IN NO EVENT WILL AFM NOR ANY OF THEIR THIRD PARTY LICENSORS BE LIABLE FOR ANY INDIRECT, SPECIAL OR CONSEQUENTIAL DAMAGES, INCLUDING BUT NOT LIMITED TO, LOST TIME, LOST MONEY, LOST PROFITS OR GOOD WILL, WHETHER IN CONTRACT, TORT, STRICT LIABILITY OR OTHERWISE, AND WHETHER OR NOT SUCH DAMAGES ARE FORESEEN OR UNFORESEEN WITH RESPECT TO ANY USE OF THE AFM WEB SITE. NEITHER AFM NOR ANY OF ITS AFFILIATES, AGENTS OR LICENSORS WILL BE LIABLE TO YOU OR ANYONE ELSE FOR ANY LOSS OR INJURY RESULTING FROM USE OF THE WEB SITE, IN WHOLE OR PART, WHETHER CAUSED BY NEGLIGENCE, CONTINGENCIES BEYOND ITS CONTROL IN PROCURING, COMPILING, INTERPRETING, REPORTING OR DELIVERING THE WEB SITE AND ANY CONTENT AT THE WEB SITE OR OTHERWISE. IN NO EVENT WILL AFM, ITS AFFILIATES, AGENTS OR LICENSORS BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DECISION MADE OR ACTION TAKEN BY YOU IN RELIANCE ON SUCH CONTENT OR THE WEB SITE.

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You may, through hypertext or other computer links, gain access to Web Sites operated by persons other than AFM's. Such hyperlinks are provided for your reference and convenience only, and are the exclusive responsibility of such Web Sites' owners. You agree that AFM's is not responsible for the content or operation of such Web Sites, and that AFM's shall have no liability to you or any other person or entity for the use of third party Web Sites. Except as described below, a hyperlink from this Web Site to another Web Site does not imply or mean that AFM endorses the content on that Web Site or the operator or operations of that site. You are solely responsible for determining the extent to which you may use any content at any other Web Sites to which you link from AFM's Web Site. AFM's assumes no responsibility for the use of third party software on the AFM's site and shall have no liability whatsoever to any person or entity for the accuracy or completeness of any outcome generated by such software.

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The Content displayed on the Web Site, including, but not limited to, reports and other opinions, are current as of the date appearing on the report and are subject to change without notice. Unless indicated otherwise, recommendations are updated periodically by AFM to reflect changes in the market and other criteria. AFM does not guarantee or warrant the accuracy, timeliness, or completeness of any recommendations you receive using the Web Site.