This section of the brochure tells you about our business, including ownership and a description of the services we offer.
Bryan Advisory Services, LLC is referred to in this document as "BAS", "the Company", "us", "we", or "our". In this document we
refer to current and prospective clients of Bryan Advisory Services as "you", "client", or "your". Bryan Advisory Services was established
legally in 2010. Richard G Bryan Jr. is the sole and managing member of the LLC and has a history of investment counseling
beginning in 1981 with Bryan Funding, Inc., a registered brokerage firm.
Types of Advisory Services All clients enter into a written Investment Advisory Agreement where BAS and our investment adviser representatives provide asset
management services on a continuous and ongoing basis guided by the individual needs of the client. Using the information provided
by you, the investment advice provided to you is tailored to your individual situation. We regularly inquire about, and you are
responsible for providing, information about your investment goals, time horizon, and risk tolerance. These investment supervisory
services are not generally provided to all your holdings or net assets but rather to specific assets designated by y ou and accepted by
us as managed assets.
Portfolio Management Bryan Advisory Services LLC provides portfolio management of client funds based on the individual needs of the clients. We establish the
client’s personal investment policy through personal discussions in order to determine goals and objectives. We create and manage the
portfolio based on the clients’ particular circumstances. During the initial discussion, we determine the client’s individual objectives, time
horizons, risk tolerance, and liquidity needs. As appropriate, we may also review and discuss a client’s prior investment history.
We manage these accounts on a discretionary basis unless otherwise noted. Clients choosing us to provide investment advisory services
sign an agreement giving us the authorization to effect security transactions on behalf of their portfolio. Discretionary client portfolios may
invest in equities, fixed income, open or closed end mutual funds exchange trades funds (ETFs) or a combination of the above depending on
the investment strategy chosen by the client.
Pension Consulting Services
BAS offers consulting services to pension or other employee benefit plans. For some clients we provide financial projections to assist
them in their retirement planning. Any reports, financial statement projections, and analyses are intended for your use in developing
and implementing your financial plan. Because of this limited purpose, the projections should not be considered a complete
financial plan for you. Bryan Advisory Services will not audit, review, or compile financial statements. We will not express an opinion
or other form of assurance regarding the reasonableness of assumptions and other data which may be used by others for prospective
financial statements. There will likely be material differences between projected and actual results because events are variable and
circumstances frequently do not fit predictions.
Our analyses will be highly dependent upon certain economic assumptions about the future. Therefore, you should establish
familiarity with the historical data regarding key assumptions such as inflation and investment rates of return, as well as an
understanding of how these assumptions affect the results of our analysis. We may counsel you about the consistency of your
assumptions when applying relevant historical data but we will not express assurance as to the accuracy or reasonableness of your
data and assumptions. You are ultimately responsible for the assumptions and personal data upon which we base projections. The
reports are not intended to, nor do they provide a guarantee about future events including your investment returns. The
implementation of the plan is your responsibility.
Bryan Advisory Services does not provide comprehensive financial planning. The financial planning for our clients is focused upon
investment and retirement planning. Risk management issues such as life, health, disability, and long‐term care insurance are not
usually addressed and you will be encouraged to seek professional help in these areas. Additionally, BAS does not provide tax or
legal advice but we may suggest transactions or investments for their tax benefits.
Types of Investments Used We will consider many types of securities when formulating our investment advice to you. If you come to us with existing
investments, we evaluate them in relationship to your financial goals, risk tolerance, and time horizon. Depending upon your
situation, your account(s) managed by us may contain individual stocks, corporate/government bonds, treasuries, mutual funds,
variable annuities, variable life insurance, or exchange traded funds ("ETF's").
Non‐correlated Investments We may suggest non‐correlated mutual funds or ETF's. Non‐correlated mutual funds or ETF's may rise in value during general stock
market declines and move down in an up market. We may use these non‐correlated assets in an attempt to reduce volatility in your
portfolio. The use of this strategy does not guarantee that the volatility, draw down, or loss of portfolio principal will be less and it
may actually reduce long term performance.
Wrap Fees A wrap account is a professionally managed investment plan in which all expenses, including brokerage commissions, management
fees and administrative costs are “wrapped “into a single charge. BAS does not offer wrap fee services.
Tailored Services and Investment Restrictions We attempt to tailor your investment portfolio to your situation as you have described it to us. It is important that you let us know
when you have changes to your financial situation, goals, or investment time horizon.
You may place restrictions upon our selection of investments and it is important that you document this in written form to us. We
will respect your wishes and maintain our communication about your portfolio.
Assets Under Management As of January 2020 Bryan Advisory Services has managed $ 166,795,876 of client assets on a discretionary basis. The amount of
client assets Bryan Advisory Services manages on a non-discretionary basis is zero.
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Fees and Compensation This section of the brochure describes how we are compensated for the services we offer. Compensation Methodology and Rates Assets Under Management Clients are typically charged for our asset management services based on a percentage of the assets being managed. The follow
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ing fee schedule is our basic fee arrangement for investment supervisory services. Your specific annual fee arrangement will be
described in the written Investment Advisory Agreement entered into between BAS and you. Investment advisory fees charged by
us are negotiable and are established by agreement with you. All clients do not pay the same fee.
Assets Under Management Annual Rates
First $2,000,000 1.00%
Next $8,000,000 0.75%
Thereafter 0.50%
Duties that do not include asset allocation and require limited investment advice will have a minimum annual rate of 0.30%.
Consultant evaluations will be charged at an annual rate of 0.10%. Depending on the agreement with the client, the annual fee for
our services is billed either monthly or quarterly in arrears based on the value of the account at the end of the month or quarter. If
the management agreement does not span the entire billing period, the fee will be pro-rated based on the number of days the
account is open during the billing period. Your account custodian will send you a statement, at least quarterly, showing all
disbursements including any advisory fee if authorized by you in writing. We share responsibility with you to verify the accuracy of
the fee calculation because the custodian will not determine that the fee has been properly calculated. We will send you a written
invoice itemizing the fee, including any formulae used to calculate the fee, the time period covered by the fee and the amount of
assets under management on which the fee was based. Please see Item 12 (Brokerage Practices) in this brochure for more
information about your account custodian(s).
You may terminate the Investment Advisory Agreement without fee or penalty by providing written notice to Bryan Advisory
Services within five (5) business days from the execution of our agreement. After that time, either you or we may terminate the
arrangement by giving written notice. Any fees collected in advance of service will be returned to you on a pro rata basis and any
fees due will be billed to you.
How Clients Pay Advisory Fees The following information describes how Bryan Advisory Services, LLC is compensated for the advisory services that it provides to
each client account. Unless otherwise specified below or in the advisory contract that BAS enters into with a particular client, Bryan
Advisory Services will bill in arrears either on a monthly or quarterly basis. At the end of each month or quarter a calculation will be
made based on the assets under management and the fees will be deducted by the custodian from the clients’ money market
account. Any collected but unearned fees will be refunded to you.
Other Types of Fees and Expenses In addition to our fees, you may pay transaction fees to your custodian or broker
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dealer for executing securities transactions.
There may be other possible charges for special services elected by you or us in the active management of the account. These fees
may include:
periodic distribution fees electronic fund and wire transfer fees
certificate delivery fees reorganization fees
account transfer fees (outbound) international security transfer fees
overnight mail and check fees transfer agent fees
This list is not meant to be all inclusive. Any fee on a special service incurred by the client will be fully disclosed. Please refer to
Item 12 of this document for an explanation of our brokerage practices.
Investment Company Fees Investment company funds (mutual funds or ETF's) that are held by you will bear their own internal transaction and execution
costs, as well as direct compensation to their investment managers along with internal administration costs. Some funds pay 1 2b-
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1 fees, and /or shareholder service fees to broker
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dealers that offer investment company funds. These fees affect the valuation of
your shares and are indirectly a cost to you.
Some fund companies have a redemption fee. A redemption fee is charged to a shareholder when the shares are sold or
redeemed within a stated period of time from the purchase date. Although a redemption fee is deducted from redemption
proceeds like a deferred sales load, it is not considered to be a sales load. Unlike a sales load, which generally is used to
compensate broker
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dealers, this kind of fee is used to defray fund costs associated with the redemption and is paid directly to the
fund, not to a broker. The SEC generally limits redemption fees to 2%. We will not ordinarily sell your shares in a period wh en
there would be a redemption charge. However, the issue may come up if you request liquidation.
A more complete explanation of these charges is part of any Prospectus and Statement of Additional Information supplied by the
investment company fund. We suggest that you obtain a Prospectus for your fund either through us or directly from the
investment company through their website, by telephone, or by mail.
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Performance‐Based Fees and Side‐By‐Side Management This section of the brochure explains any performance‐based fees we charge.
Bryan Advisory Services does not charge fees based upon a share of capital gains or capital appreciation of client assets. Our advisory
fees are only charged as mentioned above in Item 5. BAS does not offer side by side management services.
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Types of Clients This section of the brochure describes our clients.
Bryan Advisory Services provides investment advisory services to a variety of clients including State or Municipal government entities,
pension and profit sharing plans, trusts, foundations, business organizations, and individuals. There is an account minimum of $500,000
which may be waived by the investment advisor depending on the situation.
Pension Plans Bryan Advisory Services provides advisory services to pension plans. These services include recommendations to the plan which are
then sent to the pension plan sponsor for approval. Full disclosure of our role is available to you from the plan sponsor.
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Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis, Investment Strategies, and Risk of Loss
This section of the brochure explains how we formulate our investment advice and manage client assets. Methods of Analysis Modern Portfolio Theory
As part of our analysis of portfolio structure, we use a method called modern portfolio theory. Modern Portfolio Theory ("MPT") is a
theory of investment that tries to maximize an investment portfolio's expected return for a given amount of portfolio risk. (Risk is
defined as volatility of the value of the portfolio.) The analysis might also attempt to minimize risk for a given level of expected
return. We attempt to do this by carefully choosing the proportions of various assets in an investment portfolio.
MPT is a mathematical formulation of the concept of diversification in investing, with the goal of selecting an assortment of assets that
has collectively lower risk than any individual asset. MPT models an asset's return as a normally distributed function, defines risk as
the standard deviation of return, and models a portfolio as a weighted combination of assets so that the return of a portfolio is the
weighted combination of the assets' returns. By combining different assets whose returns are not perfectly positively correlated,
MPT seeks to reduce the total variance of the portfolio return. MPT assumes that investors are rational, markets are efficient, and
that the future performance of investments will have some similarity to their historical performance. These assumptions can be
problematic and may not be true in the real time activity of the markets. Black swans happen and force us to humility and the
realization that past performance is not always indicative of future performance. This realization is not fatal to our efforts to
manage risk and we work for you by staying alert to the vagaries of real life portfolio management without blind adherence to theory.
Investment Strategies We tend to build our investment portfolios using MPT. We construct portfolios along the risk spectrum from more conservative to
more aggressive. The more conservative portfolios will generally be constructed with less equity-like investments while the more
aggressive portfolios will generally hold more equity-like investments. To implement the strategies, we may utilize individual stocks
and bonds or, more commonly, your portfolio manager will research and select from the universe of mutual funds and ETF's to build
your portfolio.
Our methods for researching and analyzing prospective selections for your portfolios are both quantitative and qualitative. We
encourage you to speak directly with us to understand how we choose investments for you and the rationale that led us to your
allocation of assets.
We, at all times, seek to provide you with transparency regarding our methods and pursue your interests first with disclosure of any
possible conflict of interests.
Risks General Risks
Investing is not without risk and it involves the risk of principal loss, which you should be prepared to face if it happens. We attempt
to reduce risk in your portfolio by diversifying it across multiple asset classes.
Nevertheless, historical evidence shows that every asset class has experienced severe declines in value, even sustained over many
years. Our strategy to minimize risk may not succeed because the benefits of diversification decline if asset classes become more
correlated. Additionally, security prices can be affected substantially when exchanges are closed due to company specific news or
macroeconomic/geopolitical conditions and events.
As with any investment, you could lose all or part your investments managed by Bryan Advisory Services and your account's per-
formance may be less than other investments.
Asset Class Risk
Securities in your portfolio(s) or in underlying investments such as mutual funds may under perform in comparison to the general
securities markets or other asset classes.
Concentration Risk
To the extent that Bryan Advisory Services recommends portfolio allocations that are concentrated in a particular market, industry,
or asset class, your portfolio may be susceptible to loss due to adverse occurrences affecting that market, industry, or asset class.
Management Risk
The performance of your account is subject to the risk that our investment management strategy may not produce the intended
results.
Market Risk
Your account could lose money over short periods due to short-term market movements and over longer periods during market
downturns. The value of a security may decline due to general market conditions, economic trends, or events that are not specifically
related to the issuer of the security or to factors that affect a particular industry or industries. During a general downturn in the
securities markets, multiple asset classes may experience loss.
Passive Investment Risk Bryan Advisory Services may use a passive investment strategy that is not actively managed where we do not attempt to take de-
fensive positions in declining markets.
Regulatory Risk Changes in government regulations may adversely affect the value of a security. An insufficiently regulated industry or market
might also permit inappropriate practices that adversely affect an investment.
Disciplinary Information This section of the brochure gives legal and disciplinary information of our owner and management team.
Smaller Company Securities Risk Securities of companies with smaller market capitalizations have historically tended to be more volatile and less liquid than larger
company stocks. Smaller companies may have no or relatively short operating histories or are new public companies. Additional
risks are inherent if they have aggressive capital structure, high debt levels, or are active in growing/changing industries and new
technologies.
Key Man Risk We are a small firm with one person, Richard G. Bryan, who performs many critical functions. This fact leads to "key man risk", the
risk that something could happen to Mr. Bryan that negatively affects your portfolio. We are in the planning stage of bringing coverage
of some functions to help reduce this risk. BAS has several investment advisors two of which also hold an insurance license.
Small Firm Risk We are reliant on research from leading national firms to assist us in our investment decisions. Additionally, we do not have the
level of financial resources that larger firms have to invest in market data systems or industry consultants to provide insig ht on
specific companies or industries in which we may invest. We have been associated with these firms over the years and now bring
our experience and educated selective attention to the work of your investment management. We use a filtered perspective from
the big firms to come to our own determinations.
Private Placement Risk ~It may take many years, if ever, for developmental wells drilled to produce sufficient revenue to return the amount of your
investment.
~Deductions of IDC and tangible costs occur over the first few years of the program as wells are being drilled and completed.
~ The revenues are directly related to marketing the natural gas and oil. Gas and oil prices are volatile and cannot be predicted. If
these prices decrease, your investment return will also decrease.
~Wholesale buyers of natural gas may experience financial difficulties and be unable to pay for natural gas at market prices.
~ If you invest as an Investor General Partner, you will have the liability during the drilling of the wells for Partnership obligations.
Investing partners who purchase units of general partnership interests, thereby becoming General Partners, will be jointly and
severally liable for all liabilities and obligations of the Partnership. One or more General Partnership unitholders may be held liable
for more than their pro rata share of the Partnership liabilities. After the drilling phase, you will be converted by the Managing
General Partner to a Limited Partner.
~The tax option may not cover certain allocations of the federal income tax deductions. This could possibly increase the risk that a
portion of the intangible drilling costs may be disallowed in the event of an IRS audit.
~Changes in tax laws may reduce the tax benefits of your investment in the Partnership.
~You are committing to complete reliance on the Managing General Partner and its affiliates.
~Each partnership will also pay substantial fees to the Managing General Partner and affiliates.
~Lack of liquidity or a market for the units.
~Conflicts of interest may arise between you and the Managing General Partner, including which services they will provide to each
Partnership, the amount the Partnership will pay for those services, how management time and services are allocated, and which
leases will be assigned to each Partnership for drilling.
Item 9— Disciplinary Information Disciplinary Information This section of the brochure gives legal and disciplinary information of our owner and management team.
There are no legal or disciplinary events that are material to our relationship to you as your investment adviser. Neither the firm
nor management staff has been involved in such actions.
Item 10—Other Financial Industry Activities and Affiliations Other Financial Industry Activities and Affiliations This section of the brochure describes other financial services affiliations that could present a conflict of interest with you
Richard G. Bryan, the sole owner of Bryan Advisory Services, is the owner and President of Bryan Funding, Inc., securities Broker‐ Dealer,
member FINRA/SIPC. He also is the owner of Bryan Energy Management, LLC, a sponsor and general manager partner of oil and gas
limited partnerships.
Vescio Asset Management LLC is solely owned by William Vescio. This is a non-registered company that is comprised of investment adviser
representatives registered to offer advisory services through Bryan Advisory Services. Some of the representatives are also licensed agents
with various life insurance companies.
Neither Bryan Advisory Services nor any of its representatives receive any compensation, commissions or fees directly or indirectly from any
investment advisors or advisory firms. Bryan Advisory Services does not maintain any relationships with advisors with any other advisory
firms.
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Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading This section of the brochure describes our code of ethics adopted pursuant to SEC rule 204‐1, and how we deal with client and
related person trading. Code of Ethics We have adopted a code of ethics designed to prevent and detect violations of securities rules by our employees and affiliated
persons. Our controls in this area focus upon securities transactions made by our employees that have access to material information
about the trading of Bryan Advisory Services. We will provide a copy of our code of ethics to clients or prospective client s upon
request.
Material Financial Interest and Personal Trading From time‐to‐time the interests of the principal and employees of Bryan Advisory Services may coincide with yours and other clients.
Individual securities may be bought, held, or sold by a principal or employee of BAS that is also recommended to or held by you or
another client. If potential insider information is inadvertently provided or learned by a principal or employee, it is our p olicy to
strictly prohibit its use.
It is the policy of BAS to permit the firm, its employees and investment advisor representatives (IARs) to buy, sell, and hold the
same securities that the IARs also recommend to clients. It is acknowledged and understood that we perform investment service s
for different types of clients with varying investment goals, risk profiles, and time horizons. As such, the investment advice offered to
you may differ from other clients and investments made by our IARs. We have no obligation to recommend for purchase or sale a
security that BAS, its principal, affiliates, employees, or IARs may purchase, sell, or hold. When a decision is made to liquidate a security
from all applicable accounts, priority will always be given to client orders before those of a related or associated person to BAS. In
some cases the trades of the clients and advisory personnel will be combined in a single block trade, all trades will then receive the
average price. We have procedures for dealing with insider trading, employee‐related accounts, "front running" and other issues that
may present a potential conflict when buy/sell recommendations are made. These procedures include reviewing employee security
transactions and holdings to eliminate, to the extent possible, the adverse effects of potential conflicts of interest on clients.
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Brokerage Practices This section of the brochure describes how we recommend broker‐dealers for client transactions. Factors Considered When Recommending Broker‐Dealers You may choose your qualified custodian; however we may suggest or recommend that you use a specific qualified custodian and
broker‐dealer. When we make this recommendation, we consider and carefully review:
Competitive commissions and other costs of trading, ability to facilitate trades, access to client records, computer trading support,
and other operational considerations.
These areas are reviewed regularly to assure us that the best interests of you and your account are serviced by the relationship with
the broker‐dealer.
Research and Other Associated Benefits We recommend that clients establish brokerage accounts with quality firms (as "custodian"), registered broker‐dealers, Member
FINRA/SIPC or NYSE, to maintain custody of your assets and to execute trades for your account(s).
The custodian provides us with access to its institutional trading and operations services which are typically not available to retail
investors. These services are offered to independent investment advisors at no charge in exchange for keeping a minimum amount of
account assets at the custodian. The custodian's services include research, brokerage, and custody. The custodian offers access to
mutual funds and other investments that are available only to institutional investors or require a significantly higher minimum
investment. They also make other products and services available that benefit us but may not benefit our clients. Some of these
other products and services help us manage and administer client accounts, and include software and other technology that:
provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (also allocation
of aggregated trade orders for multiple client accounts), provide research, pricing information, and other market data, facilitate
payment of our fees from your account(s), help with back‐office support, record keeping, and client reporting. These services may be
used with all or a substantial number of clients' accounts, including accounts not maintained at the custodian. We do not attempt to
allocate the benefit to accounts proportionately to the accounts that generate the benefit.
Some of the products or services provided by the custodian do not qualify for the safe harbor in section 28(e) of the Securities
Exchange Act of 1934, including those services that do not aid in investment decision‐making or trade execution. These business
management and development services, in addition to those listed above, may include consulting, publications and presentation s
on practice management, information technology, business succession, regulatory compliance, and marketing. In addition, the
custodian may use third parties to offer these services to Bryan Advisory Services. The custodian may discount or waive fees it
would otherwise charge for some of these business management and development services or pay all or part of the fees of a third
party providing these services to us. Because we receive discounts, research, products, or services, we may have an incentive to
select or recommend a broker‐dealer based on our interest in receiving these benefits rather than on the client's interest in the
most favorable execution. The chosen custodian may charge commissions (or markups/markdowns) higher than those charged by
other broker‐dealers in return for services and benefits.
Brokerage for Client Referrals Bryan Advisory Services does not have any agreements to direct transactions to a particular broker‐dealer in exchange for client
referrals.
Directed Brokerage If you direct Bryan Advisory Services to execute transactions at a broker‐dealer other than one we have customarily used, you may
pay higher execution costs due to the fact that we have not negotiated for volume discounts or batched orders.
Aggregated Orders When we decide to purchase or sell a specific security for multiple clients at the same time, we may aggregate or combine the
orders. This procedure will result in a single average price for all clients in the aggregated order. The custodian charges may result in
savings versus not aggregating.
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Review of Accounts This section of the brochure describes how often client accounts are reviewed and by whom. Reviews Richard Bryan, President of Bryan Advisory Services formally reviews all client accounts on an annual, semi‐annual, or quarterly
basis depending upon client preference. Reviews are coordinated with the Investment Advisory Representative of record in accordance
with client request and/or regulatory supervisory procedures. Reviews are often used to rebalance according to a predetermined asset
mix and to monitor performance. Trades to rebalance are made by client consent.
Reports BAS prepares written reports after each review. The report includes portfolio accounting, performance, asset class, and investment
company performance in absolute and relative measurements.
Clients also will receive reports, at least quarterly, directly from their qualified custodian which confirms the assets domiciled there
and the activity/performance for the quarter. This serves as a third party check and balance for client disclosure and transparency.
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Client Referrals and Other Compensation This section of the brochure discloses our arrangements with people who are compensated for referring us business. Referral
Relationships Bryan Advisory Services has not entered into any agreements with third parties to give or receive referrals for compensation.
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Custody This section of the brochure encourages you to check the statements sent to you by your account custodian (broker‐dealer) to ensure
the accuracy of the fee calculation.
You are encouraged to review account statements carefully and compare the amounts on the custodian statements with any
statements we send to you and the fee schedule as per your Investment Advisory Agreement.
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Investment Discretion This section of the brochure discloses the power we have to make trades in your account.
Except as otherwise set forth in the advisory contract, Client authorizes IA to investigate, purchase, and sell on behalf of Client,
various securities and investment. IA is authorized to execute purchases and sales of securities on client’s behalf without consulting
Client regarding each sale or purchase.
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Voting Client Securities This section of the brochure explains our proxy voting policy and your ability to get proxy voting information from us.Bryan Advisory
Services will not vote proxies for securities held in your investment account. Your account custodian or transfer agent will send
proxy statements directly to you. If the investment account is for a pension or other employee benefit plan governed by ERISA, the
right to vote such proxies is expressly reserved for you or your plan fiduciary, not BAS.
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Financial Information This section of the brochure is where investment advisors that collect more than $1200 in fees, six months or more in advance
would include a balance sheet for you. Prepayment of Fees Bryan Advisory Services does not require prepayment of investment advisory fees greater than $1200 and does not require payment
of fees more than six months in advance.
For your information, we are not aware of any financial condition that is reasonably likely to impair our ability meet our
contractual commitments to you, including possible refunds that may be due you.
Item 19— Requirements for State‐Registered Advisers Requirements for State‐Registered Advisers This section is where state registered advisers disclose any additional information required by the state. Principal Executives Richard G. Bryan is the principal executive of Bryan Advisory Services. His education and business background is as follows:
Education: BA, Robert Morris College
Business Background: 2010-present Bryan Advisory Services, LLC –President
2009-present Bryan Management, LLC – President
2004-present Discovery Oil & Gas- President
1983- present Bryan & Bryan General Partners- Managing Partner
1981-2019 Bryan Funding, Inc. – President
1975-present Brymone Management- President
1975-present Brymone Inc.- President
Privacy Statement We, like other professionals who advise on personal financial matters, are required by federal law to inform you of policies regarding
the privacy of your information.
In our advisory role, we may be privy to your personal financial information such as financial statements, account statements, and
tax returns. All non-public personal information regarding you is held in strict confidence in accordance with our professional
obligation and is not released to others without your consent. There may be times that you will be informed that we are required by
legal process to release information that we have of yours. These are rare circumstances and you will be informed accordingly.
We may share your information with third parties who assist us in providing our services to you and they are subject to the same
obligation not to disclose your personal information.
In order to guard your nonpublic personal information, we maintain physical, electronic, and procedural safeguards to help us
perform our responsibility to you. We must retain your records to assist you with your need for professional services from BAS and to
meet our professional guidelines and obligations.
Notes: Exhibit I Identification of Custodian The custodian for the account is: TD Ameritrade Clearing, Inc.
Mailing Address: 200 South 108th Avenue Omaha, NE 68154
Phone Number: 1 (800) 454-9272
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