Part 2A Of Form ADV: Firm Brochure - Glassjacobson

Transcription

Glass Jacobson Investment Advisors, LLC10711 Red Run Boulevard, Suite 101Owings Mills, MD 21117410-356-1000www.glassjacobson.comSeptember 23, 2020Part 2A of Form ADV: Firm BrochureThis brochure provides information about the qualifications and business practices of Glass JacobsonInvestment Advisors, LLC, d/b/a Glass Jacobson Financial Group (“Glass Jacobson” or the “Company”). If youhave any questions about the contents of this brochure, please contact us at 410-356-1000 orwww.glassjacobson.com. The information contained in this brochure has not been approved or verified bythe United States Securities and Exchange Commission (“SEC”) or by any state securities authority.Glass Jacobson is registered as an investment adviser with the SEC. The firm’s registration does not imply acertain level of skill or training.Additional information about Glass Jacobson also is available at www.adviserinfo.sec.gov.The information included in this brochure is intended to provide you with useful information to evaluate ourservices and enable you to compare them with those of other advisory firms.1Glass Jacobson Investment Advisors LLC / Part 2A Form ADV

ITEM 2. MATERIAL CHANGESThis Brochure is an updating amendment to the prior brochure dated June 11, 2020.The summary of material changes from the last update to the Brochure are in the following sections:Item 4 – Advisory Business. We discuss our automated investment program.Item 5 – Fees and Compensation. We discuss the fees associated with out automated investmentprogram.Item 7 - Types of Clients. We discuss the applicability of the automated investment program to our clientbase.Item 14 – Client Referrals and Other Compensation. We have removed our discussion of Mr. SanfordSaidman (deceased) as an external solicitor for the firm. We discuss the economic benefit received fromCharles Schwab & Co., Inc. in offering our automated investment program on their Institutional IntelligentPortfolios platform.Clients may request a copy of the Form ADV Part 2A at any time without charge by sending a writtenrequest to our Chief Compliance Officer at our address or by e-mail to Jon.Dinkins@Glassjacobsonia.com.ITEM 3. TABLE OF CONTENTSItem 4. Advisory BusinessItem 5. Fees and CompensationItem 6. Performance-Based Fees and Side-By-Side ManagementItem 7. Types of ClientsItem 8. Methods of Analysis, Investment Strategies and Risk of LossItem 9. Disciplinary InformationItem 10. Other Financial Industry Activities and AffiliationsItem 11. Code of EthicsItem 12. Brokerage PracticesItem 13. Review of AccountsItem 14. Client Referrals and Other CompensationItem 15. CustodyItem 16. Investment DiscretionItem 17. Voting Client SecuritiesItem 18. Financial InformationItem 19. Requirements for State-Registered AdvisersPg. 3Pg. 7Pg. 13Pg. 14Pg. 14Pg. 16Pg. 16Pg. 17Pg. 17Pg. 22Pg. 22Pg. 23Pg. 24Pg. 24Pg. 24Pg. 252Glass Jacobson Investment Advisors LLC / Part 2A Form ADV

ITEM 4. ADVISORY BUSINESSDESCRIPTION AND HISTORY OF ADVISORY BUSINESS:Glass Jacobson Financial Group offers a proactive, integrated approach to financial services. Our integratedservices include tax preparation & planning, accounting & audit, strategic business consulting, divorce &litigation support, investment advisory services, financial planning, and ERISA retirement plan services.Bringing these services together allows you to see your finances in their entirety and make better decisionsfor your business and life. The result is a cohesive approach to your finances and future.Glass Jacobson Financial Group is comprised of two affiliated companies: Glass Jacobson PA, an accountingfirm, and Glass Jacobson Investment Advisors, LLC. (The Company), a registered investment advisor.Messrs. Edward Jacobson, Michael Cohen and Jonathan Dinkins, Sr. are Managing Members of the Company.The Company has been an investment advisor since 1998.GENERAL INFORMATION ABOUT THE COMPANY AND ITS SERVICESAlthough the Company’s advice is not limited to such investments, The Company’s investment adviceprimarily relates to mutual funds and certain investment products. Mr. Dinkins and at least two of theCompany’s investment adviser representatives constitute the Company’s investment committee thatdetermines general investment solutions suitable for client use.The committee meets quarterly and reviews its investment solutions. The criteria which the committee usesto review these solutions includes but is not limited to; historical performance, fees, manager tenure,investment risk metrics, securities composition, style, appropriate benchmarks, and industry indices.The Company offers:1) Discretionary or Non-Discretionary Investment Advisory Services;2) Financial Planning Services;3) Retirement Plan Consulting Services4) Administrative ServicesOur Current clients include individuals; high net worth individuals; 401(k), defined contribution, and definedbenefit pension plans; trusts; estates; and charitable organizations.Each of these services is now discussed.Discretionary or Non-Discretionary Investment Advisory ServicesRegardless of how an account is managed, the Company tailors’ advisory services to the individual needs ofits clients, by diversifying and managing each client’s portfolio in line with the client’s pre-defined investmentobjectives, risk tolerance, time horizon, financial information, and other various suitability factors that aredetermined. Such factors also include any restrictions the client may impose on investing in certain securitiesor types of securities. However, restrictions and other guidelines imposed by clients on the management oftheir accounts may affect the composition and performance of a client’s portfolio. Therefore, performance ofthe portfolio may not be identical with accounts of other clients with similar investment objectives andmanaged by the same investment adviser representative.Stemming from our holistic approach to our services, client accounts are usually managed on a householdbasis. The discretionary managed account is designed to permit the Company to make investment decisionsfor the account pursuant to investment objectives chosen by the client. Rarely will The Company manage anadvisory account on a non-discretionary basis.Generally, The Company requires that clients establish brokerage accounts with Schwab Institutional(“Schwab”), a division of Charles Schwab & Co., Inc., Fidelity Registered Investment Advisor Group(“Fidelity”), a division of Fidelity Investments, or TD Ameritrade (“TDA”) to maintain custody of such client’s3Glass Jacobson Investment Advisors LLC / Part 2A Form ADV

assets and to effect trades for the client’s account. Each of these custodians is a registered broker-dealer. TheCompany maintains a relationship with Schwab, Fidelity and TDA which enables clients to receiveinstitutional trading and operations services to which the average retail client would not otherwise haveaccess. All transactions are cleared through Schwab, Fidelity or TDA.Clients can also establish Apex Accounts. Apex Accounts are like the brokerage accounts-mentioned above,but the Company may manage the account on either a discretionary or non-discretionary basis (asdetermined by the client). The Custodian for the client’s assets is National Financial Services through TriadAdvisors, LLC. (“Triad”), a registered broker-dealer. The Apex Account is designed to permit the Company tomake investments in, or make recommendations concerning investments in, mutual funds, stocks, optionsand bonds pursuant to investment objectives chosen by the client. In addition, investors can buy or sell avariety of no-load or load-waived mutual funds (i.e., with a 5.00 transaction charge); however, suchtransactions in mutual funds may result in other fees (such as a surcharge or distribution fees) being chargedto the account. To offer clients flexibility and one consolidated brokerage statement, stock and bond trading isavailable for discounted transaction charges. Variable annuities may be linked to the Apex account forconsolidated reporting.The Apex Account is a non- “wrap fee” account. The management fees to be paid under the Apex Account aredescribed in the Advisory Agreement. A portion of the management fees will be paid to Triad as transactionrelated service fees, which will be paid to our custodian, National Financial Services (NFS) for its services. TheApex Account has no minimum account size. Management fees are negotiable. The portion of themanagement fee attributable to compensation to the investment adviser representative varies but willgenerally be based on a percentage of the account and will not exceed 2.50% of the account on an annualbasis.Clients may also choose to maintain a brokerage relationship with one or more custodians other thanSchwab, Fidelity or TDA and in connection therewith participate in the custodial integrator By All Accounts,Inc. (“BAA”) service provided by the Company. The BAA service consolidates information about clientinvestments held with such other custodians. Clients may participate in the BAA service in one or both of thefollowing ways:First, clients may choose to participate in the BAA service with respect to one or more custodial accounts thatare included for investment management purposes in the Investment Advisory Account managed by theCompany. In connection with this manner of participation, clients direct the Company to place trades throughsuch other custodians. The value of the accounts maintained with such other custodians is included in theoverall value of the Investment Advisory Account for purposes of calculating the Company’s Management Feediscussed later in this brochure.Next, clients may choose to participate in the BAA service with respect to one or more accounts that are notincluded in the Investment Advisory Account managed by the Company. Such participation enables theCompany to consider information about the client’s investments held with other custodians when renderingadvice with respect to the Investment Advisory Account, as well as to provide non-discretionary advice tosuch client as to the investments in the accounts reported through BAA. Such clients are under no obligationto act on or consider any advice that may be rendered by the Company with respect to such accounts, andclients may direct the investments in such accounts in any manner they desire. With respect to any accountsreported through BAA that are not included in the Investment Advisory relationship, the Company has noresponsibility to direct investments in, and/or place trades for such accounts. Clients are charged an annualfee of 0.25% of the value of all the client’s accounts reported through BAA that are not included in theInvestment Advisory Account, payable quarterly in advance. The value of such accounts is not included in theoverall value of the Investment Advisory Account for purposes of calculating the Company’s Management Fee.Clients with mutual funds and/or variable annuity sub-accounts in their portfolios are effectively paying theCompany and the mutual fund/variable annuity advisor for the management of the client’s assets. Suchclients therefore are subject to both the Company’s management fee and the management fee of the mutualfund. For variable annuities, such management fees include both fees to the manager of the variable annuity4Glass Jacobson Investment Advisors LLC / Part 2A Form ADV

sub-account and fees to the insurance company (Mortality and Administrative). For example, a client whooffers a 401(k)-retirement plan to their employees knows that the plan participants pay the mutual fundmanagement fees in addition to other applicable costs.Automated Investment ProgramWe offer an automated investment program (the “Program”) through which clients are invested in a range ofinvestment strategies we have constructed and manage, each consisting of a portfolio of exchange-tradedfunds and mutual funds (“Funds”) and a cash allocation. The client may instruct us to exclude up to threeFunds from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at CharlesSchwab & Co., Inc. (“CS&Co”). We use the Institutional Intelligent Portfolios platform (“Platform”), offeredby Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors andan affiliate of CS&Co., to operate the Program. We are independent of and not owned by, affiliated with, orsponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are theclient’s investment advisor and primary point of contact with respect to the Program. We are solelyresponsible, and Schwab is not responsible, for determining the appropriateness of the Program for theclient, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, andmanaging that portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform,which consists of technology and related trading and account management services for the Program. ThePlatform enables us to make the Program available to clients online and includes a system that automatescertain key parts of our investment process (the “System”). The System includes an online questionnaire thatcan help us determine the client’s investment objectives and risk tolerance and select an appropriateinvestment strategy and portfolio. Clients should note that when using the online questionnaire, we willrecommend a portfolio via the System in response to the client’s answers to the online questionnaire. Theclient may then indicate an interest in a portfolio that is one level less or more conservative or aggressivethan the recommended portfolio, but we then make the final decision and select a portfolio based on all theinformation we have about the client. The System also includes an automated investment engine throughwhich we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-lossharvesting (if the client is eligible and elects).We charge clients a fee for our services as described below under Item 5 Fees and Compensation. Our fees arenot set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. aspart of the Program. Schwab does receive other revenues, including (i) the profit earned by Charles SchwabBank, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep Program described inthe Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii) investment advisory and/oradministrative service fees (or unitary fees) received by Charles Schwab Investment Management, Inc., aSchwab affiliate, from Schwab ETFs Schwab Funds and Laudus Funds that we select to buy and hold inthe client’s brokerage account; (iii) fees received by Schwab from mutual funds in the Schwab Mutual FundMarketplace (including certain Schwab Funds and Laudus Funds) in the client’s brokerage account forservices Schwab provides; and (iv) remuneration Schwab receives from the market centers where it routesETF trade orders for execution.We do not pay SPT fees for the Platform so long as we maintain 100 million in client assets in accounts atCS&Co. that are not enrolled in the Program. If we do not meet this condition, then we pay SPT an annuallicensing fee of 0.10% (10 basis points) on the value of our clients’ assets in the Program. This feearrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in theProgram be maintained with CS&Co.The Company has designed a (3) Tiered Service model to meet Client’s needs. Each tier provides for anincreasing level of service, investment sophistication, advisor access and financial tools. A description ofeach service model follows and fees for each model are discussed in Item 5.Intelligent Portfolio Tier 1 Service Model (Base Camp) Web access thru Schwab’s brokerage portal to view holdings, transactions and values Web access thru GJIA’s portal to view:o Investment performance reporting and benchmarking5Glass Jacobson Investment Advisors LLC / Part 2A Form ADV

Archive DocumentsFinancial planning tools for budgeting and advanced calculatorsExternal linking of all other accounts for aggregation and reporting of Client’s financialassetsCustomer service (website only)Automatic portfolio rebalancing to manage investment risk according to Client’s profileTax-loss harvesting ( 50,000 account minimum)Low cost global diversification (Basic design)ooo Intelligent Portfolio Tier 2 Service Model (Ascent) – Account minimum 100,000 Tier 1 services plus Low cost global diversification (Advanced design) Life event planning Unlimited access to advisory team for investment advice and financial guidanceIntelligent Portfolio Tier 3 Service Model (Apex) – Account minimum 100,000 Tier 2 services plus Comprehensive financial planning Dedicated investment advisor relationship Coordination of outside investment accountsFinancial Planning ServicesThe Company offers the following financial planning services to its clients:Personal Financial AnalysisInsurance and EstateCapital Needs AnalysisTax & Cash FlowRetirementInvestment AnalysisEducationFinancial planning information is obtained through personal interviews with the client concerning the client’scurrent financial status, future goals and attitudes towards risk. Related documents supplied by the clientare carefully reviewed, along with data gathered from the client. Typically, a written report is delivered.Retirement Plan Consulting ServicesThe Company offers retirement plan consulting services for ERISA and Non-ERISA covered plans. TheCompany uses various internet-based 401(k) daily valuation retirement plan platforms, to deliver its401(k) services to businesses across the United States. The platforms allow a company to offer its employeesthe widest possible array of investment options using daily valuation connectivity and multi-fund/multi-familyinvestments.In connection with providing these platforms, the Company will enter into its agreement with theResponsible Plan Fiduciary and such plan’s trustee(s) to provide discretionary and non-discretionaryinvestment advice for the 401(k) plan. The decision whether to implement or act upon the Company’srecommendations or advice rests solely with the Responsible Plan Fiduciary.The services provided by the Company to such plan typically include the following:A) Assist in the development of an Investment Policy Statement, which establishes the investmentpolicies and objectives for the plan;B) Assist in the search for and selection of mutual funds;C) Evaluate plan costs, mutual fund performance and risk;D) Monitor the suitability of all selected investment options and recommend changes whenappropriate;6Glass Jacobson Investment Advisors LLC / Part 2A Form ADV

E)F)G)Provide assistance to plan fiduciary(ies) regarding ongoing supervision and due diligence of mutual fundsperformance and risk metrics;Assist the plan fiduciary(ies) in evaluating how to avoid or manage conflicts of interest; andWhen engaged to do so, the Company may assist in the education of the plan participants about generalinvesting principles and the investment alternatives available under the plan. The educationcomponent will customarily be delivered through group meeting, one-on-one counseling, or aproprietary interactive video workshop designed to provide investment education for participants ofcompany sponsored 401(k) plans. A participant may access the website by registering as a user andaccepting terms of use. The participant will then be guided through a series of videos that describe theadvantages of joining the company plan, saving for retirement, and general principals of investing. Eachparticipant has the opportunity to take a risk questionnaire to assess their risk tolerance. Participants arethen guided to potential suitable investment allocation solutions provided by the Company plan (themutual fund lineup).Only if a participant engages the Company as an Investment Advisor, will we provide individualized adviceregarding their investments in the company plan.Administrative ServicesIn addition to the investment advisory services described above, The Company provides administrativeservices to one or more of its clients. These arrangements require the execution of a separate agreement withthe Company.WRAP FEE PROGRAMThe Company does not sponsor or manage any wrap fee programs.AUMThe Company manages client assets on a discretionary and a non-discretionary basis, As of December 31,2019, The Company managed 476.9 million on a discretionary basis.ITEM 5. FEES AND COMPENSATIONCOMPENSATIONDiscretionary or Non-Discretionary Investment Advisory Management FeeThe Company's Management Fee with respect to Investment Advisory Accounts is based upon a percentage ofthe portfolio value on the last day of the prior quarter and is billed in advance at the beginning of each quarter.Adjustments for significant contributions and withdrawals to the portfolio are prorated for the quarter inwhich the change occurs.If an Investment Advisory Account is opened during the quarter, the Management Fee will be prorated for theentire quarter and based on the beginning account value. The account will be charged two fees during the firstbilling cycle to reflect the partial quarter when the account was opened (payment in arrears) and the currentquarter (billing in advance).For Investment Advisory Accounts, including types of accounts serviced through the firm’s InvestmentAdvisory services platform for Individuals, Trust’s, Estates, Foundations, and Pooled Retirement accounts (e.g.Cash Benefit Pension, Defined Benefit Pension, and Solo 401(k)), the Management Fee is charged according tothe following tiered fee schedule:For account relationships of 1 million or more:PORTFOLIO VALUEFirst 2,000,000 of assetsNext 3,000,000 of assetsNext 5,000,000 of assetsOver 10,000,000 of assetsANNUAL RATE1.00%0.85%0.75%0.50%7Glass Jacobson Investment Advisors LLC / Part 2A Form ADV

For account relationships of less than 1 million, the following fixed rate fee schedule applies: 0 - 250,000 250,001 - 1,000,0001.50%1.25%Although the Management Fee listed above is a standard fee, such fee in some circumstances is negotiableaccording to a variety of factors; such as size and type of account, complexity, relationship to the Company(including with respect to services provided to client by the Company or its affiliates), its owners andemployees, etc.Clients grant the Company written authority to receive quarterly payments directly from the client's accountheld by the respective custodian. The Company will send to the client an informational invoice, showing theamount of the fee to be charged to the account, the value of the client's assets on which the fee is based, and thespecific manner in which the fee is calculated. Fees for each quarter are noted on the monthly statement eachclient receives from the custodian one month after quarter-end. Clients may elect to be billed for fees ratherthan having them deducted from their accounts.In addition to the above Management Fee and the BAA service fee, Investment Advisory Accounts are assessedbrokerage and transaction charges with respect to trades placed for the account. These charges are paid to theaccount custodian for effecting transactions and may be higher or lower than transaction charges orcommissions the client may pay at other broker-dealers. Please refer to the section below (Item 12) entitled,“Brokerage Practices” for additional information. Clients do not pay a separate custodial fee.Inherent Conflict of Interest: Because we charge an ongoing asset-based fee, The Company is incentivized toincrease the managed assets in a client account, thereby increasing the fees paid by its clients.TERMINATIONAn Advisory Agreement may be terminated at any time for any reason by either party upon ten days (10)days’ written notice to the other. The Company will reject any termination instructions, including accountliquidation instructions, unless Client provides those instructions in writing. The client will be entitled to apro-rata refund of any prepaid quarterly account fee based upon the number of days remaining in the quarterafter the termination date.COMPENSATION FOR THE SALE OF SECURITIES OR OTHER INVESTMENT PRODUCTSTypically, the Company recommends no-load and load-waived mutual funds to its clients. Clients benefit fromnot paying a sales commission to purchase a mutual fund but may pay a nominal transaction fee to the accountcustodian.Certain investment adviser representatives of the Company also serve as registered representatives of TriadAdvisors, LLC. (“Triad”), a registered broker-dealer. A conflict of interest exists between the interests of theCompany and the interests of its clients when the Company recommends securities that may be purchasedthrough such registered representatives. In such cases, the registered representative receives a commission onthe purchase or sale recommended by the Company. This gives such registered representative an incentive torecommend investment products based on the compensation received, rather than on a client’s needs. TheCompany believes that such conflict is addressed by fully disclosing to clients in this brochure and in itsfinancial planning agreements that such registered representatives receive additional compensation on thepurchase or sale of certain securities.Additionally, no client is under any obligation to act on the recommendations of these investment adviserrepresentatives of the Company who also serve as registered representatives of Triad Advisors, LLC. (“Triad”),a registered broker-dealer. If a client elects to act on any of the recommendations, the client is under noobligation to effect the transactions through a registered representative who is also an investment adviserrepresentative of the Company, and clients have the option to purchase investment products recommended bythe Company through other brokers or agents that are not affiliated with the Company.8Glass Jacobson Investment Advisors LLC / Part 2A Form ADV

Such commissions do not provide the primary or exclusive compensation for the investment adviserrepresentatives of the Company who also serve as registered representatives of Triad Advisors, LLC. (“Triad”),a registered broker-dealer.When the investment adviser representatives of the Company who are also registered representatives of TriadAdvisors, LLC. (“Triad”), a registered broker-dealer, receive commissions for a product sale; thecommissionable product is excluded from the asset based Management Fee discussed above.Additionally, it is possible for a client to also incur certain charges imposed by third parties other than theCompany in connection with investments made through the account. These charges may include, but are notlimited to, mutual fund 12b-1 distribution fees and/or service fees (paid to the custodian), or certain deferredsales charges on previously purchased mutual funds purchased while the account assets were custodied at aprior custodian. These fees are disclosed in the fund's prospectus provided to the client by outside thirdparties.APEX ACCOUNTSThe Apex Account may be suitable for investment accounts that invest primarily in mutual funds. There is nominimum account size and fees are negotiable.The service fees are calculated by multiplying the Account Value to the corresponding fee percentage shownbelow. Each account is assessed a minimum 110 service fee.ACCOUNT VALUE 0― 150,000 150,001 ― 500,000 500,001 ― 1,000,000 1,000,001 ― 2,000,000 2,000,001 ― 3,000,000SERVICE FEE.25%.20%.13%.10%.10%Equity TradesMutual Fund TradesAlternative Investment TradesFixed Income TradesUnit Investment Trust TradesOption TransactionsVariable Annuity “Posting”Trade Confirmations (Emailed)Trade Confirmations (Mailed)Mutual Fund Prospectus DeliverySurcharge Mutual FundsOption Additions (Index/Currency)Minimum Service Fee (per year) 4.00 .0075 per share 5 50 10 1.25 per bond 10 4 0.50 per contract 50 per contract 0.40 0.68 2.00 15.00 0.75 110As mentioned above, in addition to the management fees, Apex Accounts are assessed transaction and otherservice charges. These transaction and other service charges may be higher or lower than transaction charges,commissions or other service fees client would pay at other broker-dealers. The current Apex transactioncharges are as follows:The Company charges a Management Fee in connection with its services to Apex Account clients according tothe following fixed rate fee schedule:PORTFOLIO VALUE 0 - 250,000 250,001 - 1,000,000ANNUAL RATE1.50%1.25%9Glass Jacobson Investment Advisors LLC / Part 2A Form ADV

1,000,001 - 2,000,000Assets over 2,000,0001.00%0.85%Minimum Fee for accounts less than 50,000 - 31.25 per quarterTriad does not charge clients a separate custodial fee. However, Triad charges the Company an annual servicecharge of up to .25% of the value of the account upon which the Management Fee is based. Such fee is payableby the Company and not the client.The Company’s Management Fee is billed directly to, and deducted from, the Apex Account. The amount ofsuch fee is noted on the statements provided to clients by the custodian. Clients are billed on a quarterly billingcycle.With respect to accounts with quarterly billing, fees are calculated at the end of the quarter and charged duringthe first month of the quarter based on the average daily balance of the account during the quarter.If an Apex Account is opened in the first or second month of a quarter, the account will be charged one feeduring its first billing cycle, which will occur during the first full month after the account is established. Thefirst fee is prorated for the number of days the account was open based on the start date through the end of themonth. The fee will be base

Charles Schwab & Co., Inc. in offering our automated investment program on their Institutional Intelligent Portfolios platform. Clients may request a copy of the Form ADV Part 2A at any time without charge by sending a written request to our Chief Compliance Officer at our address or by e-mail to Jon.Dinkins@Glassjacobsonia.com. ITEM 3.