A. Description of the Advisory Firm Sound View Wealth Advisors Group, LLC (“Sound View Wealth” or the “Firm”) is acquiring the advisory
business of Sound View Wealth Advisors, LLC which was registered with the United States Securities and
Exchange Commission (“SEC”) on January 3, 2018. Sound View Wealth is a limited liability company
organized in Delaware. Sound View Wealth is an investment advisory firm registered with the United States
Securities and Exchange Commission (“SEC”).
Sound View Wealth is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically,
Sound View is a wholly-owned subsidiary of Focus Operating, LLC (“Focus Operating”), which is a wholly-
owned subsidiary of Focus LLC. Focus Financial Partners Inc. (“Focus Inc.”) is the sole managing member
of Focus LLC and is a public company traded on the NASDAQ Global Select Market. Focus Inc. owns
approximately two-thirds of the economic interests in Focus LLC.
Focus Inc. has no single 25% or greater shareholder. Focus Inc. is the managing member of Focus LLC and
has 100% of its governance rights. Accordingly, all governance is through the voting rights and Board at
Focus Inc. As of the end of 2019, investment vehicles affiliated with Stone Point Capital, LLC (“Stone
Point”) had a greater than 25% voting interest in Focus Inc., and Stone Point had the right to designate two
of seven directors on the Focus Inc. Board. As of the end of 2019, investment vehicles affiliated with
Kohlberg Kravis Roberts & Co. L.P. (“KKR”) had a less than 25% voting interest in Focus Inc., and KKR
had the right to designate one of seven directors on the Focus Inc. Board.
Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance
firms, business managers and other firms (the “Focus Partners”), most of which provide wealth
management, benefit consulting and investment consulting services to individuals, families, employers,
and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or
investment companies as disclosed on their respective Form ADVs.
Sound View Wealth is managed by Kelly Bouchillon, Melissa Bouchillon, O. Emerson Ham III, and Edward
Ambrose (“Sound View Wealth Principals”), pursuant to a management agreement between SVWA Partners
and Sound View Wealth. The Sound View Wealth Principals serve as officers of Sound View Wealth and
are responsible for the management, supervision and oversight of Sound View Wealth.
B. Types of Advisory Services Sound View Wealth provides holistic and personalized financial planning and discretionary and non-
discretionary investment advisory services to individuals, including high net worth individuals, and entities,
including, but not limited to, family offices, trusts, estates, private foundations, and qualified retirement
plans.
Financial Planning and Consulting Services
Sound View Wealth may provide a variety of comprehensive financial planning and consulting services to
clients. Such engagements may be part of the investment advisory engagement or pursuant to a separate
engagement. Generally, such financial planning services will involve preparing a financial plan
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or rendering a financial consultation based on the client’s financial goals and objectives. This planning or
consulting may encompass one or more areas of need, including, but not limited to cash flow analysis,
investment planning, retirement planning, estate planning, personal savings, educational savings, and other
areas of a client’s financial situation.
A financial plan developed for or financial consultation rendered to the client will typically include
general recommendations for a course of activity or specific actions to be taken by the client. For example,
recommendations may be made that the client start or revise their investment programs, commence or
alter retirement savings, establish education savings and/or charitable giving programs. Sound View
Wealth may recommend the services of itself and/or other professionals to implement its
recommendations. Clients are advised that a conflict of interest exists if Sound View Wealth recommends
its own services, as such a recommendation may increase the advisory fees paid to Sound View Wealth.
The client is under no obligation to act upon any of the recommendations made by Sound View Wealth
under a financial planning or consulting engagement to engage the services of any such recommended
professional, including Sound View Wealth itself.
Investment Management Services
In designing and implementing customized models and portfolio strategies, Sound View Wealth can
manage, on a discretionary or nondiscretionary basis, a broad range of investment strategies and vehicles.
Sound View Wealth primarily allocates client assets among various mutual funds, exchange-traded funds
(“ETFs”), and individual debt and equity securities in accordance with clients’ stated investment
objectives.
Sound View Wealth may further recommend to clients that all or a portion of their investment portfolio
be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms
(“External Managers”). The client may be required to enter into a separate agreement with the External
Manager(s), which will set forth the terms and conditions of the client’s engagement of the External
Manager or will receive a Statement of Investment Selection in a single contract relationship. Sound View
Wealth generally renders services to the client relative to the discretionary selection of External Managers.
Sound View Wealth also assists in establishing the client’s investment objectives for the assets managed
by External Managers, monitors and reviews the account performance and defines any restrictions on the
account. The investment management fees charged by the designated External Managers, together with
the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be
exclusive of, and in addition to, the annual advisory fee charged by Sound View Wealth.
Investment Management Services for Qualified Retirement Plans
Discretionary Investment Advisory Services to Plans: When serving in a discretionary investment
advisory capacity for a Plan, Sound View Wealth is in the status defined by section 3(38) of the
Employee Retirement Income Security Act of 1974 (“ERISA”). As a discretionary investment
advisor to qualified retirement plans (“Plans”) Sound View Wealth assumes the fiduciary
responsibility for the selection, monitoring and replacement of the investment options of the Plan.
As an initial action step, Sound View Wealth seeks to obtain the investment policy statement for
the Plan that details the methodologies and criteria utilized to define the style universe of investment
options, the specific investment options to be utilized and the ongoing
criteria for monitoring and replacing investment options. If the Plan does not have an investment
policy statement Sound View Wealth may assist the Plan sponsor/trustees of the Plan in drafting an
investment policy statement. In instances where an investment policy statement is not available,
Sound View Wealth will collect information from the Plan sponsor/trustees determined necessary
for Sound View Wealth’s provision of services to the Plan.
In its role as a 3(38) fiduciary, Sound View Wealth is only responsible for those Plan investments
selected by Sound View Wealth and Sound View Wealth has no responsibility for any other Plan
investments maintained in the Plan by direction of the Plan sponsor/trustees or any other person or
entity. As an example, employer securities and investments held in a directed brokerage account are
not subject to any fiduciary responsibility or duty on the part of Sound View Wealth. Furthermore,
the Plan sponsor/trustees should be aware that when Sound View Wealth assumes the investment
responsibilities by serving as a 3(38) fiduciary, the Plan sponsor/trustees retain all of their fiduciary
duties, obligations and responsibilities pursuant to applicable law.
Non-Discretionary Investment Advisory Services to Plans: When serving in a non-discretionary
investment advisory capacity for a Plan, Sound View Wealth is in the status defined by section 3(21)
of ERISA. In this capacity, Sound View Wealth assumes no fiduciary responsibility for the
completion of an investment policy statement or any aspect of the definition, selection, maintenance
or replacement of any Plan investment options. In this non-discretionary role Sound View Wealth
provides information to the Plan sponsor/trustees regarding investment option style parameters and
performance reporting. The Plan sponsor/trustees exercise full authority over the selection of Plan
investment options and may, or may not, utilize the information provided by Sound View Wealth
as part of their decision making process.
Other Services for Plans: As part of providing the discretionary or non-discretionary investment
services to Plans, Sound View Wealth may provide certain information and services to the Plan
and the Plan sponsor/trustees. These other services are designed to assist the Plan
sponsor/trustees in meeting their management and fiduciary obligations to the Plan. The other
services may consist of the following:
o Assist with platform provider search and Plan set-up;
o Plan review;
o Plan fee and cost review;
o Acting as third party service provider liaison;
o Plan participant education and communication;
o Plan benchmarking;
o Assist with Plan conversion to new vendor platform; and
o Assistance in Plan merger.
Additional Information Regarding ERISA Plans and Individual Retirement Accounts
As detailed above, Sound View Wealth is a fiduciary under ERISA with respect to investment management
services and investment advice provided to ERISA plan clients, including ERISA plan participants. Sound
View Wealth is also a fiduciary under the Internal Revenue Code (the “IRC”) with respect to investment
management services and investment advice provided to ERISA plans, ERISA plan participants, individual
retirement accounts and individual retirement account owners (collectively “Retirement Account Clients”).
As such, Sound View Wealth is subject to specific duties and obligations
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under ERISA and the IRC, that include, among other things, prohibited transaction rules which are intended
to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a
conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a prohibited
transaction exemption (a “PTE”).
C. Client-Tailored Advisory Services Sound View Wealth provides portfolio management services using investment models designed to meet a
variety of client investment objectives. Client portfolios are managed on the basis of individual clients’
financial situation and investment objectives. Clients may impose reasonable restrictions on the
management of their accounts if Sound View Wealth determines, in its sole discretion, that the conditions
would not materially impact the performance of a management strategy or prove overly burdensome for
Sound View Wealth’s management efforts.
D. Assets Under Management As of December 31, 2019, Sound View Wealth had $824,340,161 in assets under management, of which
$732,690,954 were managed on a discretionary basis.
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A. Fee Schedule for Advisory Services ADVISORY FEE SCHEDULE Market Value of Assets Rate Up to $499,999 1.5%
$500,000 to $999,999 1.25%
$1,000,000 to $1,999,999 1.1%
$2,000,000 to $4,999,999 .95%
$5,000,000 to $9,999,999 .75%
$10,000,000 to $24,999,999 .60%
$25,000,000 to $49,999,999 .50%
$50,000,000 to $99,999,999 .40%
$100,000,000 and above customizable
The percentage for the highest range of Managed Asset value
achieved applies to all Managed Assets, not just Managed Assets
within that range.
Sound View Wealth charges an annual advisory fee that is agreed upon with each client and set forth in an
agreement executed by Sound View Wealth and the client. If based on a percentage of the value of assets
under management, the advisory fee for the initial quarter is payable on a pro rata basis, in arrears, based on
the period ending value of the net billable assets under management. For subsequent quarters, the advisory
fee generally is payable in advance (except for services to participant-directed 401k plans, which generally
are payable in arrears), based on the average daily net billable asset value of the client’s accounts through
the last day of the previous quarter as provided by third-party sources. If fixed, the
advisory fee for the initial quarter is payable, on a pro rata basis, in arrears, based on the period ending value
of the net billable assets under management. For subsequent quarters, the fixed fee generally is payable in
advance, based on the average daily net billable asset value of the client’s accounts through the last day of
the previous quarter as provided by third-party sources.
Notwithstanding the foregoing, Sound View Wealth and the client may choose to negotiate an annual
advisory fee that varies from the schedule set forth above. Factors upon which a different annual advisory
fee may be based include, but are not limited to, the size and nature of the relationship, the services rendered,
the nature and complexity of the products and investments involved, time commitments, and travel
requirements. The advisory fee charged by the Firm will apply to all of the client’s assets under management,
unless specifically excluded in the client agreement. The advisory fee may include the financial planning
services described above.
Clients have five (5) business days from the date of execution of the client agreement to terminate Sound
View Wealth’s services. The investment advisory agreement between Sound View Wealth and the client
may be terminated at will by either Sound View Wealth or the client upon written notice. Sound View
Wealth does not impose termination fees when the client terminates the investment advisory relationship,
except when agreed upon in advance.
Sound View Wealth offers its clients financial planning services. Such services, for some clients, may be
included as part of the annual advisory fee. Clients may also enter into a separate agreement with Sound
View Wealth for financial planning services. Such fee is negotiable, and is based on either an hourly rate
that varies, depending on the experience, knowledge, and skill of those performing the services on behalf of
Sound View Wealth, or a flat fee agreed upon in writing by Sound View Wealth and the client.
The hourly rate for ad-hoc and project-based consultations for clients varies depending on the services
provided and the experience, knowledge, and skill of those performing the services on behalf of Sound View
Wealth. Hourly rates may generally range from $250 to $500 per hour. The scope and charges of all hourly
ad-hoc work must be agreed-upon in writing by Sound View Wealth and the client before any billing begins.
B. Payment of Fees Sound View Wealth generally deducts its advisory fee from a client’s investment account(s) held at his/her
custodian. Upon engaging Sound View Wealth to manage such account(s), a client grants Sound View
Wealth this limited authority through a written instruction to the custodian of his/her account(s). The client
is responsible to verify the accuracy of the calculation of the advisory fee; the custodian will not determine
whether the fee is accurate or properly calculated. See Section A herewith for further information on fee
billing. A client may utilize the same procedure for financial planning or consulting fees if the client has
investment accounts held at a custodian.
Although clients generally are required to have their investment advisory fees deducted from their accounts,
in some cases, Sound View Wealth will directly bill a client for investment advisory fees if it determines
that such billing arrangement is appropriate given the circumstances.
The custodian of the client’s accounts provides each client with a statement, at least quarterly, indicating
separate line items for all amounts disbursed from the client's account(s), including any fees paid directly to
Sound View Wealth.
Clients may make additions to and withdrawals from their account at any time, subject to Sound View
Wealth’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves
the right to liquidate transferred securities or decline to accept particular securities into a client’s account.
Clients may withdraw account assets at any time on notice to Sound View Wealth, subject to the usual and
customary securities settlement procedures. However, the Firm generally designs its portfolios as long-term
investments and the withdrawal of assets may impair the achievement of a client’s investment objectives.
Sound View Wealth may consult with its clients about the options and implications of transferring securities.
Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees,
short-term redemption fees, fees assessed at the mutual fund level (e.g. contingent deferred sales charges)
and/or tax ramifications.
C. Clients Responsible for Fees Charged by Financial Institutions and External Money Managers In addition to Sound View Wealth’s advisory fee, clients will be responsible for the fees and expenses of
the broker-dealers who execute securities transactions for client accounts (such as commissions and mark-
ups or mark-downs), custodian(s), underlying mutual funds, ETFs, External Managers and their platform
manager (if any), transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing
fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law,
retirement plan account fees (where applicable), electronic fund and wire fees. Clients should review the
applicable prospectuses for additional information about fund fees and expenses. For External Managers,
clients should review each manager’s Form ADV 2A disclosure brochure and either the contract they
sign with the External Manager (in a dual contract relationship) or their Statement of Investment Selection
(in a single contract relationship) for additional information about fees and expenses charged.
D. Prepayment of Fees As noted in Item 5(B) above, Sound View Wealth’s advisory fees generally are paid in advance. Upon the
termination of a client’s advisory relationship, Sound View Wealth will issue a refund equal to any unearned
management fee for the remainder of the quarter. The client may specify how he/she would like such refund
issued (i.e., a check sent directly to the client or a check sent to the client’s custodian for deposit into his/her
account).
E. Outside Compensation for the Sale of Securities or Other Investment Products to Clients An advisory person of Sound View Wealth is a registered representative of Pushe Kaplan Sterling
Investments (“PKS”), a FINRA member broker-dealer, and through this relationship receives transaction-
based compensation for annuities where PKS is the broker of record. This is a potential conflict of interest
in that it could incentivize the recommendation of annuities based on the compensation the advisory person
receives, rather than on a client’s needs. Sound View Wealth addresses this conflict through this disclosure.
Additionally, neither the advisory person nor Sound View Wealth receive advisory fees on these annuities
(e.g., they do not “double dip”).
Advisory persons of Sound View Wealth may also be licensed as insurance professionals. Such persons earn
commission-based compensation for selling insurance products to clients. Insurance commissions earned
by advisory persons who are insurance professionals are separate from and in addition to Sound View
Wealth ’s advisory fee. This practice presents a conflict of interest as an advisory person who is an insurance
professional may have an incentive to recommend insurance products for the purpose of generating
commissions rather than solely based on client needs. Clients are under no obligation to purchase insurance
products through any person affiliated with Sound View Wealth.
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Sound View Wealth does not charge performance-based fees or participate in side-by-side management.
Performance-based fees are fees that are based on a share of a capital gains or capital appreciation of a
client’s account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-based
fees. Sound View Wealth’s fees are calculated as described in Item 5 above.
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Sound View Wealth offers investment advisory services to individuals, including high net worth individuals,
families, family offices, trusts, businesses, charitable foundations, and retirement/profit-sharing plans.
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A. Methods of Analysis and Risk of Loss A primary step in Sound View Wealth’s investment strategy is getting to know the clients – to understand
their financial condition, risk profile, investment goals, tax situation, liquidity constraints – and assemble
a complete picture of their financial situation. To aid in this understanding, Sound View Wealth offers
clients financial planning that is highly customized and tailored. This comprehensive approach is integral
to the way that Sound View Wealth does business. Once Sound View Wealth has a true understanding of
its clients’ needs and goals, the investment process can begin, and the Firm can recommend strategies and
investments that it believes are aligned with the client’s goals and risk profile.
Sound View Wealth primarily employs fundamental analysis methods in developing investment strategies
for its clients. Research and analysis from Sound View Wealth is based on numerous sources, including
third-party research materials and publicly-available materials, such as company annual reports,
prospectuses, and press releases.
Sound View Wealth generally employees a long-term investment strategy for its clients, as consistent
with their financial goals. Sound View Wealth will typically hold all or a portion of a securities position
for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting
the cash needs of clients. At times, the Firm may also buy and sell positions that are more short-term in
nature, depending on the goals of the client and/or the fundamentals of the security, sector or asset class.
Sound View Wealth has an investment committee. The investment committee selects assets and products
from across many asset classes, including global and domestic equities, taxable and non-taxable fixed
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income, mutual funds and ETFs. Once the investment committee reviews and approves mutual funds and
ETFs, they are added to the Firm’s model portfolios and approved list and may be purchased for clients.
Similarly, Sound View Wealth may select External Managers to manage a portion of its clients’ assets. The
investment committee also reviews and approves the External Managers in which the Firm has placed client
assets. Overall investment strategies recommended to each client emphasize long-term ownership of a
diversified portfolio of marketable and non-marketable investments intended to provide superior after-tax,
inflation-adjusted, economic returns.
Client portfolios with similar investment objectives and asset allocation goals may own different securities
and investments. The client’s portfolio size, tax sensitivity, desire for simplicity, income needs, long-term
wealth transfer objectives, time horizon and choice of custodian are all factors that influence Sound View
Wealth’s investment recommendations.
Investing in securities involves a risk of loss. A client can lose all or a substantial portion of his/her
investment. A client should be willing to bear such a loss. Some investments are intended only for
sophisticated investors and can involve a high degree of risk.
B. Material Risks Involved The mutual funds, ETFs and External Managers that the Firm frequently invests client assets with or
recommends to clients generally own securities and therefore also involve the risk of loss that is inherent in
investing in securities. The extent of the risk of ownership of fund shares generally depends on the type and
number of securities held by the fund. Mutual funds invested in fixed income securities are subject to the
same interest rate, inflation, and credit risks associated with the fund’s underlying bond holdings. Fixed
income securities may decrease in value as a result of many factors, for example, increases in interest rates
or adverse developments with respect to the creditworthiness of the issuer. Risks also may be significantly
increased if a mutual fund pursues an alternative investment strategy. An investment in an alternative mutual
fund involves special risks such as risk associated with short sales, leveraging the investment, potential
adverse market forces, regulatory changes, and potential illiquidity. Investing in alternative strategies
presents the opportunity for significant losses. Returns on mutual fund investments are reduced by
management costs and expenses.
An ETF’s risks include declining value of the securities held by the ETF, adverse developments in the
specific industry or sector that the ETF tracks, capital loss in geographically focused funds because of
unfavorable fluctuation in currency exchange rates, differences in generally accepted accounting principles,
or economic or political instability, tracking error, which is the difference between the return of the ETF and
the return of its benchmark and trading at a premium or discount, meaning the difference between the ETF’s
market price and NAV. ETFs also are subject to the individual risks described in their prospectus. Although
many mutual funds and ETFs may provide diversification, risks can be significantly increased if a mutual
fund or ETF is concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage to a significant degree, or concentrates in a particular type of security. One of the
main advantages of mutual funds and ETFs is that they give individual investors access to professionally
managed, diversified portfolios of equities, bonds and other securities.
Although the goal of diversification is to combine investments with different characteristics so that the risks
inherent in any one investment can be balanced by assets that move in different cycles or respond to different
market factors, diversification does not eliminate the risk of loss. In some circumstances, price movements
may be highly correlated across securities and funds. A specific fund may not be diversified and a client
portfolio may not be diversified. Additionally, when diversification is a client objective, there
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is risk that the strategies that the Firm uses may not be successful in achieving the desired level of
diversification. There is also risk that the strategies, resources, and analytical methods that the Firm uses to
identify mutual funds and ETFs will not be successful in identifying investment opportunities.
Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss.
The following events also could cause mutual funds, ETFs, equities and fixed income securities and other
investments managed for clients, as well as those managed by External Managers, to decrease in value:
Market Risk: The price of an equity security, bond, or mutual fund may drop in reaction to tangible
and intangible events and conditions. This type of risk is caused by external factors independent of
a security’s particular underlying circumstances. For example, changes in political, economic and
social conditions may trigger adverse market events.
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing their
market values to decline.
Event Risk: An adverse event affecting a particular company or that company’s industry could
depress the price of a client’s investments in that company’s stocks or bonds. The company,
government or other entity that issued bonds in a client’s portfolio could become less able to, or
fail to, repay, service or refinance its debts, or the issuer’s credit rating could be downgraded by a
rating agency. Adverse events affecting a particular country, including political and economic
instability, could depress the value of investments in issuers headquartered or doing business in
that country.
Liquidity Risk: Securities that are normally liquid may become difficult or impossible to sell at an
acceptable price during periods of economic instability or other emergency conditions. Some
securities may be infrequently or thinly traded even under normal market conditions.
Leverage Risk: The use of leverage may lead to increased volatility of a fund’s NAV and market
price relative to its common shares. Leverage is likely to magnify any losses in the fund’s portfolio,
which may lead to increased market price declines. Fluctuations in interest rates on borrowings or
the dividend rates on preferred shares that take place from changes in short- term interest rates
may reduce the return to common shareholders or result in fluctuations in the dividends paid on
common shares. There is no assurance that a leveraging strategy will be successful.
Domestic and/or Foreign Political Risk: The events that occur in the U.S. relating to politics,
government, and elections can affect the U.S. markets. Political events occurring in the home
country of a foreign company such as revolutions, nationalization, and currency collapse can have
an impact on the security.
Inflation Risk: Countries around the globe may be more, or less, prone to inflation than the U.S.
economy at any given time. Companies operating in countries with higher inflation rates may find
it more difficult to post profits reflecting its underlying health.
Currency Risk: Overseas investments are subject to fluctuations in the value of the U.S. dollar
against the currency of the investment’s originating country. This is also referred to as exchange
rate risk.
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Reinvestment Risk: This risk is that future proceeds from investments may have to be reinvested
at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income
securities.
Operational Risk: Fund advisors and other ETF service providers may experience disruptions or
operating errors such as processing errors or human errors, inadequate or failed internal or external
processes, or systems or technology failures, that could negatively impact the ETF.
Regulatory/Legislative Developments Risk: Regulators and/or legislators may promulgate rules or
pass legislation that places restrictions on, adds procedural hurdles to, affects the liquidity of, and/or
alters the risks associated with certain investment transactions or the securities underlying such
investment transactions. Such rules/legislation could affect the value associated with such
investment transactions or underlying securities
Illiquid Securities: Investments in hedge funds and other private investment funds may
underperform publicly offered and traded securities because such investments:
o Typically require investors to lock-up their assets for a period and may be unable to meet
redemption requests during adverse economic conditions;
o Have limited or no liquidity because of restrictions on the transfer of, and the absence of
a market for, interests in these funds;
o Are more difficult to monitor and value due to a lack of transparency and publicly
available information about these funds;
o May have higher expense ratios and involve more inherent conflicts of interest than
publicly traded investments; and
o Involve different risks than investing in registered funds and other publicly offered and
traded securities. These risks may include those associated with more concentrated, less
diversified investment portfolios, investment leverage and investments in less liquid and
non-traditional asset classes.
Cybersecurity: The computer systems, networks and devices used by Sound View Wealth and
service providers to us and our clients to carry out routine business operations employ a variety of
protections designed to prevent damage or interruption from computer viruses, network failures,
computer and telecommunication failures, infiltration by unauthorized persons and security
breaches. Despite the various protections utilized, systems, networks or devices potentially can be
breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity
breaches can include unauthorized access to systems, networks or devices; infection from computer
viruses or other malicious software code; and attacks that shut down, disable, slow or otherwise
disrupt operations, business processes or website access or functionality. Cybersecurity breaches
cause disruptions and impact business operations, potentially resulting in financial losses to a
client; impediments to trading; the inability by us and other service providers to transact business;
violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage,
reimbursement or other compensation costs, or other compliance costs; as well as the inadvertent
release of confidential information. Similar
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adverse consequences could result from cybersecurity breaches affecting issues of securities in
which a client invests; governmental and other regulatory authorities; exchange and other
financial market operators, banks, brokers, dealers and other financial institutions; and other
parties. In addition, substantial costs may be incurred by those entities in order to prevent any
cybersecurity breaches in the future.
Use of Independent Managers Sound View Wealth may select certain External Managers to manage a portion of its clients’ assets. In
these situations, Sound View Wealth conducts due diligence of such managers, but the success of such
recommendations relies to a great extent on the External Managers’ ability to successfully implement their
investment strategies. In addition, Sound View Wealth generally may not have the ability to supervise the
External Managers on a day-to-day basis.
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Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary
events that would be material to a client’s evaluation of Sound View Wealth and the integrity of Sound View
Wealth’s management. Sound View Wealth has no information applicable to this Item.
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Recommendation of External Managers
Sound View Wealth may recommend that clients use External Managers based on the client’s needs and
suitability. Sound View Wealth does not receive separate compensation, directly or indirectly, from such
External Managers for recommending that clients use their services. Sound View Wealth does not have any
other business relationships with the recommended External Managers.
Registered Representatives
As described above in Item 5, an advisory person of Sound View Wealth is a registered representative of
PKS and through this relationship receives transaction-based compensation for annuities where PKS is the
broker of record. This is a potential conflict of interest in that it could incentivize the recommendation of
annuities based on the compensation the advisory person receives, rather than on a client’s needs. Sound
View Wealth addresses this conflict through this disclosure. Additionally, neither the advisory person nor
Sound View Wealth receive advisory fees on these annuities (e.g., they do not “double dip”). Furthermore,
as a result of this relationship PKS may have access to certain confidential information (e.g., financial
information, investment objectives, transactions and holdings) about clients, even if client does not
establish an account through PKS. If you would like a copy of the PKS privacy policy, please contact our
Chief Compliance Officer as described on the cover page of this brochure.
Licensed Insurance Agents
A number of the Firm’s advisory persons may be licensed insurance agents and may offer certain insurance
products on a fully-disclosed commissionable basis. Please refer to the advisory person’s individual 2B
Supplement for more information. A conflict of interest exists to the extent that Sound View Wealth
recommends the purchase of insurance products where its advisory persons may be entitled to insurance
commissions or other additional compensation. Clients are under no obligation to purchase
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insurance products through any person affiliated with Sound View Wealth. The Firm has procedures in place
whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of any
such affiliations.
Focus Financial Partners
As noted above in response to Item 4, certain vehicles managed by Stone Point collectively are principal
owners of Focus LLC and Focus Inc., and certain investment vehicles managed by KKR collectively are
minority owners or Focus LLC and Focus Inc. Because Sound View Wealth is an indirect, wholly-owned
subsidiary of Focus LLC and Focus Inc., the Stone Point and KKR investment vehicles are indirect owners
of Sound View Wealth. None of Stone Point, KKR or any of their affiliates participates in the management
or investment recommendations of our business.
In addition, Sound View Wealth does not believe the Focus Partnership presents a conflict of interest with
our clients. Sound View Wealth has no business relationship with other Focus Partners that is material to its
advisory business or to its clients.
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Transactions A. Description of Code of Ethics Sound View Wealth has a Code of Ethics (the “Code”) which requires Sound View Wealth’s employees
(“supervised persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the
Firm’s clients. Among other things, the Code of Ethics sets forth policies and procedures related to conflicts
of interest, outside business activities, gifts and entertainment, compliance with insider trading laws and
policies and procedures governing personal securities trading by supervised persons.
Personal securities transactions of supervised persons present potential conflicts of interest with the price
obtained in client securities transactions or the investment opportunity available to clients. The Code
addresses these potential conflicts by prohibiting securities trades that would breach a fiduciary duty to a
client and requiring, with certain exceptions, supervised persons to report their personal securities holdings
and transactions to Sound View Wealth for review by the Firm’s Chief Compliance Officer. The Code also
requires supervised persons to obtain pre-approval of certain investments, including initial public offerings
and limited offerings.
Sound View Wealth will provide a copy of the Code of Ethics to any client or prospective client upon
request.
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A. Factors Used to Select Custodians and/or Broker-Dealers Sound View Wealth generally recommends that its investment management clients utilize the custody and
brokerage services of an unaffiliated broker/dealer custodian (a “BD/Custodian”) with which Sound View
Wealth has an institutional relationship. Currently, this includes Schwab Advisor Services, a division of
Charles Schwab & Co., Inc. (“Schwab”), which is a “Qualified Custodian” as that term is described in Rule
206(4)-2 of the Investment Advisers Act of 1940 (the “Advisers Act”). Each BD/Custodian provides custody
of securities, trade execution, and clearance and settlement of transactions placed by Sound View
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Wealth. If your accounts are custodied at Schwab, Schwab will hold your assets in a brokerage account and
buy and sell securities when we instruct them to. Clients may pay Schwab either asset-based pricing or
transaction-based pricing for custody and the execution of securities transactions in their accounts.
In deciding to recommend Schwab, some of the factors that Sound View Wealth considers include:
Trade order execution and the ability to provide accurate and timely execution of trades;
The reasonableness and competitiveness of commissions and other transaction costs;
Access to a broad range of investment products;
Access to trading desks;
Technology that integrates within Sound View Wealth’s environment, including interfacing
with Sound View Wealth’s portfolio management system;
A dedicated service or back office team and its ability to process requests from Sound View
Wealth on behalf of its clients;
Ability to provide Sound View Wealth with access to client account information through
an institutional website; and
Ability to provide clients with electronic access to account information and investment and
research tools.
Sound View Wealth places portfolio transactions through Schwab. In exchange for using the services of
Schwab, Sound View Wealth may receive, without cost, computer software and related systems support that
allows Sound View Wealth to monitor and service its clients’ accounts maintained with Schwab.
Schwab also makes available to the Firm products and services that benefit the Firm but may not directly
benefit the client or the client’s account. These products and services assist us in managing and administering
client accounts. They include investment research, both Schwab’s own and that of third parties. Sound View
Wealth may use this research to service all or some substantial number of client accounts, including accounts
not maintained at Schwab. In addition to investment research, Schwab also makes available software and
other technology that:
provide access to client account data (such as duplicate trade confirmations and account
statements);
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
provide pricing and other market data;
facilitate payment of our fees from our clients’ accounts; and
assist with back-office functions, recordkeeping, and client reporting.
Schwab also offers other services intended to help us manage and further develop our business enterprise.
These services include:
educational conferences and events;
technology, compliance, legal, and business consulting;
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants, and insurance
providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to the Firm. Schwab may also discount or waive its fees for some of these services or
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pay all or a part of a third party’s fees. Schwab may also provide the Firm with other benefits such as
occasional business entertainment of Firm personnel.
Transition-related expenses: In connection with the launch of the predecessor firm to Sound View Wealth
and the intention to recommend that clients custody their assets with Schwab, Schwab has agreed to provide
the predecessor firm and, now, therefore, Sound View Wealth with reimbursement of transfer or account
exit fees for a value not to exceed $200,000.00 for accounts transferred to the predecessor firm, and, now,
therefore, Sound View Wealth within a specified time period. These funds were used by the predecessor
firm and, now, therefore, Sound View Wealth, toward fees client accounts bore if the accounts were
transferred to Schwab. Schwab also agreed to pay the predecessor firm, and, now, therefore, Sound View
Wealth, for eligible third party vendor services and services provided by Schwab affiliates not to exceed
$500,000 for marketing, technology, consulting, or research expenses. These payments shall be distributed
as follows: (1) $125,000 in initial support once there are $100 million in net new non-retirement assets
transferred to the Schwab platform; and (2) $125,000 in additional support once there are $225 million in
net new non-retirement assets transferred to the Schwab platform; and (3) $125,000 in additional support
once there are $350 million in net new non-retirement assets transferred to the Schwab platform; and (4)
$125,000 in additional support once there are $500 million in net new non-retirement assets transferred to
the Schwab platform.
These products and services from Schwab benefit Sound View Wealth in that Sound View Wealth does not
have to purchase them. The benefits may incentivize Sound View Wealth to routinely recommend Schwab
as custodian over custodians who do not offer such products and services.
Sound View Wealth will periodically review its arrangements with the BD/Custodians and other broker-
dealers against other possible arrangements in the marketplace as it strives to achieve best execution on
behalf of its clients. In seeking best execution, the determinative factor is not the lowest possible cost, but
whether the transaction represents the best qualitative execution, taking into consideration the full range of
a broker-dealer’s services, including, but not limited to, the following:
a broker-dealer’s trading expertise, including its ability to complete trades, execute and
settle difficult trades, obtain liquidity to minimize market impact and accommodate unusual
market conditions, maintain anonymity, and account for its trade errors and correct them in
a satisfactory manner;
a broker-dealer’s infrastructure, including order-entry systems, adequate lines of
communication, timely order execution reports, an efficient and accurate clearance and
settlement process, and capacity to accommodate unusual trading volume;
a broker-dealer’s ability to minimize total trading costs while maintaining its financial
health, such as whether a broker-dealer can maintain and commit adequate capital when
necessary to complete trades, respond during volatile market periods, and minimize the
number of incomplete trades;
a broker-dealer’s ability to provide research and execution services, including advice as to
the value or advisability of investing in or selling securities, analyses and reports concerning
such matters as companies, industries, economic trends and political factors, or services
incidental to executing securities trades, including clearance, settlement and custody; and
a broker-dealer’s ability to provide services to accommodate special transaction needs, such
as the broker-dealer’s ability to execute and account for client-directed
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arrangements and soft dollar arrangements, participate in underwriting syndicates, and
obtain initial public offering shares.
As described above, Schwab provides to Sound View Wealth, without cost, research and trade execution
services. Schwab makes these services available to similarly situated investment advisers whose clients
custody their assets with Schwab. Access to research and trade execution services is not predicated on the
execution of client securities transactions (e.g., not “soft dollars.”) Sound View Wealth has not entered into
any formal “soft dollar” arrangements with broker-dealers.
Sound View Wealth’s clients may utilize qualified custodians other than Schwab for certain accounts and
assets, particularly where clients have a previous relationship with such qualified custodians.
Brokerage for Client Referrals
Sound View Wealth does not select or recommend broker-dealers based solely on whether or not it may
receive client referrals from a broker-dealer or third party.
Client-Directed Brokerage
Generally, in the absence of specific instructions to the contrary, for brokerage accounts that clients engage
Sound View Wealth to manage on a discretionary basis, Sound View Wealth has full discretion with respect
to securities transactions placed in the accounts. This discretion includes the authority, without prior notice
to the client, to buy and sell securities for the client’s account and establish and affect securities transactions
through the BD/Custodian of the client’s account or other broker-dealers selected by Sound View Wealth.
In selecting a broker-dealer to execute a client’s securities transactions, Sound View Wealth seeks prompt
execution of orders at favorable prices.
A client, however, may instruct Sound View Wealth to custody his/her account at a specific broker-dealer
and/or direct some or all of his/her brokerage transactions to a specific broker-dealer. In directing brokerage
transactions, a client should consider whether the commission expenses, execution, clearance, settlement
capabilities, and custodian fees, if any, are comparable to those that would result if Sound View Wealth
exercised its discretion in selecting the broker-dealer to execute the transactions. Directing brokerage to a
particular broker-dealer may involve the following disadvantages to a directed brokerage client:
Sound View Wealth’s ability to negotiate commission rates and other terms on behalf of
such clients could be impaired;
such clients could be denied the benefit of Sound View Wealth’s experience in selecting
broker-dealers that are able to efficiently execute difficult trades;
opportunities to obtain lower transaction costs and better prices by aggregating (batching)
the client’s orders with orders for other clients could be limited; and
the client could receive less favorable prices on securities transactions because Sound View
Wealth may place transaction orders for directed brokerage clients after placing batched
transaction orders for other clients.
In addition to accounts managed by Sound View Wealth on a discretionary basis where the client has
directed the brokerage of his/her account(s), certain institutional accounts may be managed by Sound View
Wealth on a non-discretionary basis and are held at custodians selected by the institutional client. The
decision to use a particular custodian and/or broker-dealer generally resides with the institutional client.
Sound View Wealth endeavors to understand the trading and execution capabilities of any such custodian
and/or broker-dealer, as well as its costs and fees. Sound View Wealth may assist the
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institutional client in facilitating trading and other instructions to the custodian and/or broker-dealer in
carrying out Sound View Wealth ’s investment recommendations.
Trade Errors
Sound View Wealth’s goal is to execute trades seamlessly and in the best interests of the client. In the event
a trade error occurs, Sound View Wealth endeavors to identify the error in a timely manner, correct the error
so that the client’s account is in the position it would have been had the error not occurred, and, after
evaluating the error, assess what action(s) might be necessary to prevent a recurrence of similar errors in the
future.
Trade errors generally are corrected through the use of a “trade error” account or similar account at Schwab,
or another BD, as the case may be. In the event an error is made in a client account custodied elsewhere,
Sound View Wealth works directly with the broker in question to take corrective action. In all cases, Sound
View Wealth will take the appropriate measures to return the client’s account to its intended position.
B. Trade Aggregation To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities,
including securities in which the Firm’s supervised persons may invest, the Firm will generally do so in a
fair and equitable manner in accordance with applicable rules promulgated under the Advisers Act and
guidance provided by the staff of the SEC and consistent with policies and procedures established by the
Firm.
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A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Sound View Wealth monitors investment advisory portfolios as part of a continuous and ongoing process.
Sound View Wealth advisors have at least one annual meeting with each client to conduct a formal review
the clients’ accounts. These reviews may include the following:
compare the account’s allocation with stated goals and client cash-flows at time of review;
review holdings and consider alternatives;
monitor the size of individual securities relevant to their sectors, asset classes, and overall account
size;
analyze an account’s composition and performance, income, appreciation, gains/losses, and asset
allocation; and
assess its performance.
Factors that may trigger an additional review, other than a periodic review, include: material market,
economic or political events, known significant changes in a client’s financial situation and/or objectives,
and large deposits or withdrawals from the accounts. Clients are encouraged to notify Sound View Wealth
if changes occur in the client’s personal financial situation that might adversely affect the client’s investment
plan.
B. Other Reviews Sound View Wealth may perform compliance and/or supervisory reviews of a sampling of client accounts.
These reviews may include comparing an account’s strategy and/or allocation to the account’s
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stated objectives, reviewing commission and transaction costs borne by the account, and reviewing the
billing rate and charges.
C. Content and Frequency of Regular Reports Provided to Clients Clients will receive brokerage statements no less than quarterly from the qualified custodian. These
brokerage statements are sent directly from the custodian to the client. The client may also establish
electronic access to the custodian’s website so that the client may view these reports and their account
activity. Client brokerage statements will include all positions, transactions and fees relating to the client’s
account[s]. Sound View Wealth may also provide clients with periodic reports regarding their holdings,
allocations, and performance.
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A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients Sound View Wealth does not receive benefits from third parties for providing investment advice to clients.
B. Compensation to non-Supervised Persons for Client Referrals Sound View Wealth does not currently have referral arrangements with solicitors but may in the future enter
into referral arrangements with unaffiliated individuals who may from time-to-time refer potential investors
to Sound View Wealth for investment management services and be compensated for successful referrals by
receiving a percentage of the advisory fee Sound View Wealth receives from such clients. Any such
arrangements must be in compliance with Rule 206(4)-3 of the Advisers Act.
C. Other Compensation As described above in Item 4, Sound View Wealth is part of the Focus Financial Partners partnership
(“Focus”). From time to time, Focus holds partnership meetings and other industry and best-practices
conferences, which typically include Sound View Wealth, other Focus firms and external attendees. These
meetings are first and foremost intended to provide training or education to personnel of Focus firms,
including Sound View Wealth. However, the meetings do provide sponsorship opportunities for asset
managers, asset custodians, vendors and other third party service providers. Sponsorship fees allow these
companies to advertise their products and services to Focus firms, including Sound View Wealth. Although
the participation of Focus firm personnel in these meetings is not preconditioned on the achievement of a
sales target for any conference sponsor, this practice could nonetheless be deemed a conflict as the marketing
and education activities conducted, and the access granted, at such meetings and conferences could cause
Sound View Wealth to focus on those conference sponsors in the course of its duties. Focus attempts to
mitigate any such conflict by allocating the sponsorship fees only to defraying the cost of the meeting or
future meetings and not as revenue for itself or any affiliate, including Sound View Wealth. Conference
sponsorship fees are not dependent on assets placed with any specific provider or revenue generated by such
asset placement.
The following entities have provided conference sponsorship to Focus in the last year:
Charles Schwab & Co., Inc.
eMoney Advisors, LLC
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Envestnet Financial Technologies, Inc.
Fidelity Brokerage Services LLC
Fidelity Institutional Asset Management LLC
Orion Advisor Services, LLC
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All clients must utilize a “qualified custodian” as detailed in Item 12. Clients are required to engage the
custodian to retain their funds and securities and direct Sound View Wealth to utilize the custodian for the
client’s securities transactions. Sound View Wealth’s agreement with clients and/or the clients’ separate
agreement with the B/D Custodian may authorize Sound View Wealth through such BD/Custodian to debit
the client’s account for the amount of Sound View Wealth’s fee and to directly remit that fee to Sound View
Wealth in accordance with applicable custody rules.
The BD/Custodian recommended by Sound View Wealth has agreed to send a statement to the client, at
least quarterly, indicating all amounts disbursed from the account including the amount of management fees
paid directly to Sound View Wealth. Sound View Wealth encourages clients to review the official statements
provided by the custodian, and to compare such statements with investment reports received from Sound
View Wealth. For more information about Custodians and brokerage practices, see “Item 12 - Brokerage
Practices.”
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Clients have the option of providing Sound View Wealth with investment discretion on their behalf, pursuant
to a grant of a limited power of attorney contained in Sound View Wealth’s client agreement. By granting
Sound View Wealth investment discretion, a client authorizes Sound View Wealth to direct securities
transactions and determine which securities are bought and sold, the total amount to be bought and sold, and
the costs at which the transactions will be effected. Clients may impose reasonable limitations in the form
of specific constraints on any of these areas of discretion with the consent and written acknowledgement of
Sound View Wealth. See also Item 4(C), Client-Tailored Advisory Services.
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A. Voting Client Securities Sound View Wealth votes proxies on behalf of our clients who have provided us with written authorization
to do so. Clients may, however, choose to retain proxy voting responsibility and will receive proxies from
their custodian.
Sound View Wealth has adopted proxy voting policies, procedures and guidelines designed to vote
proxies efficiently and in the best interest of its clients. Sound View Wealth seeks to identify any material
conflicts of interest and to ensure that any such conflicts do not interfere with voting in clients’ best
interests. Sound View Wealth has retained a third-party service provider, Broadridge Investor
Communication Solutions, Inc. (“Broadridge”), to provide access to proxy vote recommendations based
on the “Shareholder Value Guidelines” and assist with the voting and record-keeping of clients’ proxy
ballots through the Broadridge ProxyEdge® platform. Clients may obtain a copy of Sound View Wealth’s
proxy voting policies and information about how Sound View Wealth voted a client’s proxies by
contacting Sound View Wealth.
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B. Securities Class Actions and Proofs of Claim Sound View Wealth is not obligated to file, nor will it act in any legal capacity with respect to class action
settlements or related proofs of claim. However, for clients that would like assistance to help monitor and
file class action litigation claims Broadridge will also assist in the processing and filing of class actions
litigations. In the event that underlying clients are eligible to participate in such claims Broadridge will
handle all phases of class actions filing, including distribution of proceeds from class actions litigations. For
their services, Broadridge charges a contingency fee of 20%, which is subtracted from the client’s award
when it is paid.
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A. Balance Sheet Sound View Wealth does not require prepayment of more than $1,200 in fees per client, six months or more
in advance, and therefore does not need to include a balance sheet with this Brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Sound View Wealth nor its management has any financial conditions that are reasonably likely to
impair its ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Years Sound View Wealth has not been the subject of a bankruptcy petition.
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