A. Description of the Advisory Firm Staines Financial, LLC (hereinafter “Staines Fin”) is a Limited Liability Company
organized in the State of California. The firm was formed in April 2017, and the principal
owner is Michael L Staines.
B. Types of Advisory Services
Portfolio Management Services Staines Fin offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. Staines Fin creates an
Investment Policy Statement for each client, which outlines the client’s current situation
(income, tax levels, and risk tolerance levels). Portfolio management services include, but
are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
Staines Fin evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. Risk tolerance levels are documented in the Investment
Policy Statement, which is given to each client.
Staines Fin seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of Staines Fin’s economic,
investment or other financial interests. To meet its fiduciary obligations, Staines Fin
attempts to avoid, among other things, investment or trading practices that systematically
advantage or disadvantage certain client portfolios, and accordingly, Staines Fin’s policy
is to seek fair and equitable allocation of investment opportunities/transactions among
its clients to avoid favoring one client over another over time. It is Staines Fin’s policy to
allocate investment opportunities and transactions it identifies as being appropriate and
prudent among its clients on a fair and equitable basis over time.
Services Limited to Specific Types of Investments
Staines Fin generally limits its investment advice to mutual funds, fixed income securities,
real estate funds (including REITs), insurance products including annuities, equities, ETFs
(including ETFs in the gold and precious metal sectors), commodities and private
placements. Staines Fin may use other securities as well to help diversify a portfolio when
applicable.
C. Client Tailored Services and Client Imposed Restrictions Staines Fin offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client Investment
Policy Statement which outlines each client’s current situation (income, tax levels, and risk
tolerance levels). 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
Staines Fin from properly servicing the client account, or if the restrictions would require
Staines Fin to deviate from its standard suite of services, Staines Fin reserves the right to
end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program wherein the investor pays one stated fee
that includes management fees, transaction costs, and certain other administrative fees.
Staines Fin does not participate in any wrap fee programs.
E. Assets Under Management
Staines Fin has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $0 $146,500,000.00 December 2019
please register to get more info
A. Fee Schedule
Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $499,999 1.35%
$500,000 - $999,999 1.25%
$1,000,000 - and up 0.85%
Specialized accounts* 1.00%
*For the specialized accounts, which Staines Fin considers accounts that are not held with
the custodian, but that the firm manages like an employee sponsored 401K.
The advisory fee is calculated using the value of the assets in the Account on the last
business day of the prior billing period.
The final fee schedule will be memorialized in the client’s advisory agreement. Clients
may terminate the agreement without penalty for a full refund of Staines Fin's fees within
five business days of signing the Investment Advisory Contract. Thereafter, clients may
terminate the Investment Advisory Contract generally with 30 days' written notice.
B. Payment of Fees
Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a quarterly basis, or may be invoiced and billed
directly to the client on a quarterly basis. Clients may select the method in which they are
billed. Fees are paid in advance.
C. Client Responsibility For Third Party Fees
Clients are responsible for the payment of all third party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by Staines Fin. Please see Item 12 of this
brochure regarding broker-dealer/custodian.
D. Prepayment of Fees
Staines Fin collects fees in advance. Refunds for fees paid in advance but not yet earned
will be refunded on a prorated basis and returned within fourteen days to the client via
check, or return deposit back into the client’s account.
For all asset-based fees paid in advance, the fee refunded will be equal to the balance of
the fees collected in advance minus the daily rate* times the number of days elapsed in
the billing period up to and including the day of termination. (*The daily rate is calculated
by dividing the annual asset-based fee rate by 365.)
E. Outside Compensation For the Sale of Securities to Clients Neither Staines Fin nor its supervised persons accept any compensation for the sale of
investment products, including asset-based sales charges or service fees from the sale of
mutual funds.
please register to get more info
Staines Fin does not accept performance-based fees or other fees based on a share of capital gains
on or capital appreciation of the assets of a client.
please register to get more info
Staines Fin generally provides advisory services to the following types of clients:
❖ Individuals
❖ High-Net-Worth Individuals
There is no account minimum for any of Staines Fin’s services.
please register to get more info
Loss A. Methods of Analysis and Investment Strategies
Methods of Analysis Staines Fin’s methods of analysis include Technical analysis.
Technical analysis involves the analysis of past market data; primarily price and volume.
Investment Strategies Staines Fin uses long term trading.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
B. Material Risks Involved Methods of Analysis
Technical analysis attempts to predict a future stock price or direction based on market
trends. The assumption is that the market follows discernible patterns and if these
patterns can be identified then a prediction can be made. The risk is that markets do not
always follow patterns and relying solely on this method may not take into account new
patterns that emerge over time.
Investment Strategies
Long term trading is designed to capture market rates of both return and risk. Due to its
nature, the long-term investment strategy can expose clients to various types of risk that
will typically surface at various intervals during the time the client owns the investments.
These risks include but are not limited to inflation (purchasing power) risk, interest rate
risk, economic risk, market risk, and political/regulatory risk.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
C. Risks of Specific Securities Utilized
Clients should be aware that there is a material risk of loss using any investment strategy.
The investment types listed below are not guaranteed or insured by the FDIC or any other
government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may
lose money investing in mutual funds. All mutual funds have costs that lower investment
returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity”
nature.
Equity investment generally refers to buying shares of stocks in return for receiving a
future payment of dividends and/or capital gains if the value of the stock increases. The
value of equity securities may fluctuate in response to specific situations for each
company, industry conditions and the general economic environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount
of the payments can vary. This type of investment can include corporate and government
debt securities, leveraged loans, high yield, and investment grade debt and structured
products, such as mortgage and other asset-backed securities, although individual bonds
may be the best known type of fixed income security. In general, the fixed income market
is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond
prices usually fall, and vice versa. This effect is usually more pronounced for longer-term
securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and
credit and default risks for both issuers and counterparties. The risk of default on treasury
inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting
(extremely unlikely); however, they carry a potential risk of losing share price value, albeit
rather minimal. Risks of investing in foreign fixed income securities also include the
general risk of non-U.S. investing described below.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges,
similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100%
loss in the case of a stock holding bankruptcy). Areas of concern include the lack of
transparency in products and increasing complexity, conflicts of interest and the
possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver,
or Palladium Bullion backed “electronic shares” not physical metal) specifically may be
negatively impacted by several unique factors, among them (1) large sales by the official
sector which own a significant portion of aggregate world holdings in gold and other
precious metals, (2) a significant increase in hedging activities by producers of gold or
other precious metals, (3) a significant change in the attitude of speculators and investors.
Real estate funds (including REITs) face several kinds of risk that are inherent in the real
estate sector, which historically has experienced significant fluctuations and cycles in
performance. Revenues and cash flows may be adversely affected by: changes in local real
estate market conditions due to changes in national or local economic conditions or
changes in local property market characteristics; competition from other properties
offering the same or similar services; changes in interest rates and in the state of the debt
and equity credit markets; the ongoing need for capital improvements; changes in real
estate tax rates and other operating expenses; adverse changes in governmental rules and
fiscal policies; adverse changes in zoning laws; the impact of present or future
environmental legislation and compliance with environmental laws.
Annuities are a retirement product for those who may have the ability to pay a premium
now and want to guarantee they receive certain monthly payments or a return on
investment later in the future. Annuities are contracts issued by a life insurance company
designed to meet requirement or other long-term goals. An annuity is not a life insurance
policy. Variable annuities are designed to be long-term investments, to meet retirement
and other long-range goals. Variable annuities are not suitable for meeting short-term
goals because substantial taxes and insurance company charges may apply if you
withdraw your money early. Variable annuities also involve investment risks, just as
mutual funds do.
Private placements carry a substantial risk as they are subject to less regulation than are
publicly offered securities, the market to resell these assets under applicable securities
laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial
discount to the underlying value or result in the entire loss of the value of such assets.
Commodities are tangible assets used to manufacture and produce goods or services.
Commodity prices are affected by different risk factors, such as disease, storage capacity,
supply, demand, delivery constraints and weather. Because of those risk factors, even a
well-diversified investment in commodities can be uncertain.
Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
please register to get more info
A. Criminal or Civil Actions There are no criminal or civil actions to report.
B. Administrative Proceedings There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
please register to get more info
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither Staines Fin nor its representatives are registered as, or have pending applications
to become, a broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor
Neither Staines Fin nor its representatives are registered as or have pending applications
to become either a Futures Commission Merchant, Commodity Pool Operator, or
Commodity Trading Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Michael L Staines, Jr is an independent licensed insurance agent, and from time to time,
will offer clients advice or products from those activities. Clients should be aware that
these services pay a commission or other compensation and involve a conflict of interest,
as commissionable products conflict with the fiduciary duties of a registered investment
adviser. Staines Fin always acts in the best interest of the client; including the sale of
commissionable products to advisory clients. Clients are in no way required to utilize the
services of any representative of Staines Fin in connection with such individual's activities
outside of Staines Fin.
D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections Staines Fin does not utilize nor select third-party investment advisers.
please register to get more info
Transactions and Personal Trading A. Code of Ethics
Staines Fin has a written Code of Ethics that covers the following areas: Prohibited
Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted
Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment,
Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance
with Laws and Regulations, Procedures and Reporting, Certification of Compliance,
Reporting Violations, Compliance Officer Duties, Training and Education,
Recordkeeping, Annual Review, and Sanctions. Staines Fin's Code of Ethics is available
free upon request to any client or prospective client.
B. Recommendations Involving Material Financial Interests
Staines Fin does not recommend that clients buy or sell any security in which a related
person to Staines Fin or Staines Fin has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of Staines Fin may buy or sell securities for themselves
that they also recommend to clients. This may provide an opportunity for representatives
of Staines Fin to buy or sell the same securities before or after recommending the same
securities to clients resulting in representatives profiting off the recommendations they
provide to clients. Such transactions may create a conflict of interest. Staines Fin will
always document any transactions that could be construed as conflicts of interest and will
never engage in trading that operates to the client’s disadvantage when similar securities
are being bought or sold.
D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of Staines Fin may buy or sell securities for themselves
at or around the same time as clients. This may provide an opportunity for representatives
of Staines Fin to buy or sell securities before or after recommending securities to clients
resulting in representatives profiting off the recommendations they provide to clients.
Such transactions may create a conflict of interest; however, Staines Fin will never engage
in trading that operates to the client’s disadvantage if representatives of Staines Fin buy
or sell securities at or around the same time as clients.
please register to get more info
A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on Staines Fin’s duty to seek
“best execution,” which is the obligation to seek execution of securities transactions for a
client on the most favorable terms for the client under the circumstances. Clients will not
necessarily pay the lowest commission or commission equivalent, and Staines Fin may
also consider the market expertise and research access provided by the broker-
dealer/custodian, including but not limited to access to written research, oral
communication with analysts, admittance to research conferences and other resources
provided by the brokers that may aid in Staines Fin's research efforts. Staines Fin will
never charge a premium or commission on transactions, beyond the actual cost imposed
by the broker-dealer/custodian.
Staines Fin will recommend clients to use Millennium Trust Company.
1. Research and Other Soft-Dollar Benefits Staines Fin receives no research, product, or services other than execution from a
broker-dealer or third-party in connection with client securities transactions (“soft
dollar benefits”).
2. Brokerage for Client Referrals Staines Fin receives no referrals from a broker-dealer or third party in exchange for
using that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use Staines Fin may permit clients to direct it to execute transactions through a specified
broker-dealer. Clients must refer to their advisory agreements for a complete
understanding of how they may be permitted to direct brokerage. If a client directs
brokerage, the client will be required to acknowledge in writing that the client’s
direction with respect to the use of brokers supersedes any authority granted to
Staines Fin to select brokers; this direction may result in higher commissions, which
may result in a disparity between free and directed accounts; and trades for the client
and other directed accounts may be executed after trades for free accounts, which may
result in less favorable prices, particularly for illiquid securities or during volatile
market conditions. Not all investment advisers allow their clients to direct brokerage.
B. Aggregating (Block) Trading for Multiple Client Accounts If Staines Fin buys or sells the same securities on behalf of more than one client, then it
may (but would be under no obligation to) aggregate or bunch such securities in a single
transaction for multiple clients in order to seek more favorable prices, lower brokerage
commissions, or more efficient execution. In such case, Staines Fin would place an
aggregate order with the broker on behalf of all such clients in order to ensure fairness for
all clients; provided, however, that trades would be reviewed periodically to ensure that
accounts are not systematically disadvantaged by this policy. Staines Fin would
determine the appropriate number of shares and select the appropriate brokers consistent
with its duty to seek best execution, except for those accounts with specific brokerage
direction (if any).
please register to get more info
A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews
All client accounts for Staines Fin's advisory services provided on an ongoing basis are
reviewed at least Quarterly by Michael Staines, Owner/Advisor, with regard to clients’
respective investment policies and risk tolerance levels. All accounts at Staines Fin are
assigned to this reviewer.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews may be triggered by material market, economic or political events, or by changes
in client's financial situations (such as retirement, termination of employment, physical
move, or inheritance).
C. Content and Frequency of Regular Reports Provided to Clients Each client of Staines Fin's advisory services provided on an ongoing basis will receive a
quarterly report detailing the client’s account, including assets held, asset value, and
calculation of fees. This written report will come from the custodian. Staines Fin will also
provide at least quarterly a separate written statement to the client.
please register to get more info
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Staines Fin does not receive any economic benefit, directly or indirectly from any third
party for advice rendered to Staines Fin's clients.
B. Compensation to Non – Advisory Personnel for Client Referrals
Staines Fin does not directly or indirectly compensate any person who is not advisory
personnel for client referrals.
please register to get more info
When advisory fees are deducted directly from client accounts at client's custodian, Staines Fin
will be deemed to have limited custody of client's assets and must have written authorization
from the client to do so. Clients will receive all account statements and billing invoices that are
required in each jurisdiction, and they should carefully review those statements for accuracy.
please register to get more info
Staines Fin will not accept voting authority for client securities. Clients will receive proxies
directly from the issuer of the security or the custodian. Clients should direct all proxy questions
to the issuer of the security.
please register to get more info
A. Balance Sheet Staines Fin neither requires nor solicits prepayment of more than $1,200 in fees per client,
six months or more in advance, and therefore is not required to include a balance sheet
with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Staines Fin nor its management has any financial condition that is likely to
reasonably impair Staines Fin’s ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years Staines Fin has not been the subject of a bankruptcy petition in the last ten years.
please register to get more info
Open Brochure from SEC website