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SUMMARY OF MATERIAL CHANGESBrighton Financial Planning's Brochure does have material changes that have occurred since the lastannual update of our brochure in January 23, 2019.Item 5 Fee Schedules shown for Financial Planning and Financial Coaching.Item 15 Custody – changed to reflect TD Ameritrade acquisition of Scottrade.Item 14 Client Referral – has been updated to reflect the firm uses a solicitor.
Brighton Financial Planning1728 Rt. 31, Clinton, NJ .comFebruary 1, 2019FORM ADV PART 2ABROCHUREThis brochure provides information about the qualifications and business practices of BrightonFinancial Planning. If you have any questions about the contents of this brochure, please contactus at 908-730-7000 or info@brightonfinancial.com. The information in this brochure has not beenapproved or verified by the United States Securities and Exchange Commission or by any statesecurities authority.Additional information about Brighton Financial Planning is also available on the SEC’s website atwww.adviserinfo.sec.gov. The searchable IARD/CRD number for Brighton Financial Planning is153112.Brighton Financial Planning is a Registered Investment Adviser. Registration with the United StatesSecurities and Exchange Commission or any state securities authority does not imply a certainlevel of skill or training.
Brighton Financial PlanningForm ADV Part 2ABrochureIARD/CRD No: 153112SEC File No.: 801- 711692/1/19Table of ContentsSUMMARY OF MATERIAL CHANGES . 1Advisory Business . 1Fees and Compensation . 3Performance-Based Fees and Side-By-Side Management . 5Types of Clients . 6Methods of Analysis, Investment Strategies and Risk of Loss . 7Disciplinary Information . 8Other Financial Industry Activities and Affiliations . 9Code of Ethics, Participation or Interest in Client Transactions and PersonalTrading . 10Brokerage Practices . 13Review of Accounts . 14Client Referrals and Other Compensation. 15Custody . 16Investment Discretion. 17Voting Client Securities . 18Financial Information . 19Requirements for State Registered Advisors . 20Brighton Financial Planning
Brighton Financial PlanningForm ADV Part 2ABrochureIARD/CRD No: 153112SEC File No.: 801- 711692/1/19Advisory BusinessForm ADV Part 2A, Item 4FIRM NAME AND OWNERSHIP INFORMATIONMiddleton Financial Management, LLC d/b/a Brighton Financial Planning (BFP) is a New Jersey Bureau ofSecurities, Pennsylvania Securities Commission and the Florida Division of Securities registered investmentadvisor providing discretionary investment management, non-discretionary investment advisory and financial andestate planning services. The firm is 100% owned by John P. Middleton, CFA, CAIA, AIF . The firm, includingits predecessor, Brighton Financial Planning, Inc., has been in business since 1984. John Middleton, viaMiddleton Financial Management, LLC, acquired Brighton Financial Planning, Inc. in February 2010 effectiveJanuary 1, 2010.SERVICES PROVIDEDDISCRETIONARY AND NON-DISCRETIONARY INVESTMENT MANAGEMENTBrighton Financial Planning provides discretionary and non-discretionary investment management for clientsprimarily using exchange traded, closed-end and open-end mutual funds. Prior to investing assets on behalf of aclient, we meet with each client, write an Investment Policy Statement (IPS) for every client, create an assetallocation for that client and invest the assets entrusted to us according to the IPS. BFP has authority to activelymanage client assets by making changes to the asset allocation and to underlying investments when necessaryin accordance with the client approved IPS. As part of our investment services, we attempt to meet with clientson a semi-annual basis and to update the IPS on a bi-annual basis, or, in both cases, as needed resulting fromchanges in client circumstances. This service is billed on a percentage of assets under discretionarymanagement, per our fee schedule on page 3.ASSET MONITORING PROGRAMBFP monitoring investment advisory services include providing analyses and recommendations regardinginvestment portfolios. We evaluate these portfolios in context of client provided information regarding goals,objectives, time horizon, perceived risk tolerance and other specified criteria and suggest portfolio changes asnecessary. Clients are responsible for implementing changes if they choose to accept our recommendations.This service is billed on percentage of assets under advisory basis, quarterly, in arrears per our fee schedule onpage 3. BFP may provide advisory services, such as retirement plan advice, to existing discretionarymanagement clients at no additional fee.BFP also provides financial and estate planning services. Financial planning services include cash flowsufficiency analysis which is focused on helping clients determine if they have sufficient cash flow to meetspecified needs and full financial planning that is focused on addressing client concerns regarding a variety ofgoals such as college funding and retirement income planning. Estate planning services incorporate adviceregarding how a client’s remaining assets can continue to provide for the financial needs of beneficiaries. Theseservices are billed on an hourly basis per our fee schedule on page 3.NON-DISCRETIONARY DEFINED CONTRIBUTION ADVISORY SERVICESOur non-discretionary defined contribution advisory services involve establishing, monitoring and providing ongoing support for defined contribution plans for small to mid-size businesses. We use an unaffiliated third-partyadministrator to provide administration, reporting and online access for participants to manage their accounts.BFP assists plan sponsors with establishment of the plan, determination of the initial investment options andeducational support to participants. On an ongoing basis, we advise clients regarding investment options,suggesting changes when necessary and administer ongoing educational services to participants regardinginvestment options and market and economic performance. This service is billed on a percentage of assets underadvisement basis, quarterly, in arrears, and is collected and paid to BFP by the third-party administrator.1Brighton Financial Planning
Brighton Financial PlanningForm ADV Part 2ABrochureIARD/CRD No: 153112SEC File No.: 801- 711692/1/19Please Also Note: It remains the client’s responsibility to promptly notify BFP if there is ever any change inhis/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising BFP’sprevious recommendations and/or services.NON-DISCRETIONARY DEFINED CONTRIBUTION PARTICIPANT ALLOCATION SERVICESVia Active401k, BFP provides a non-discretionary subscription-based investment advisory service that providesspecific and customized allocation recommendations to participants of company sponsored retirement plans.Active401k is provided through Q3 Advisors, LLC (“Q3 Advisors”) an SEC registered investment adviser.Through the service, the client receives automated messages with a link to their subscription account atwww.Active401k.com so that they can review the recommended allocation of the investments inside of theirexisting company plan. The client has discretion to act on those recommendations by navigating over to theircompany interface to make changes in their own account.Third Party Money ManagersWe have a contract with Q3 Advisors, LLC to provide you with the level of assistance you need. Due to thenature of their program, Q3 Advisors is required to provide you with a separate disclosure document. Youshould carefully review this document for important and specific program details.FINANCIAL PLANNING SERVICESTo the extent requested by a Client, BFP may be engaged to provide a Client with a onetime financial planwithout ongoing investment management services on a stand-alone separate fee basis. BFP’s planning andconsulting fees are negotiable based on our fee schedule provided below. Prior to engaging BFP to provideplanning or consulting services on a stand-alone basis, Clients are generally required to enter into a FinancialPlanning and Consulting Agreement with BFP setting forth the terms and conditions of the engagement(including termination), describing the scope of the services to be provided, and the portion of the fee that isdue from the Client prior to BFP commencing services. If requested by the Client, BFP may recommend theservices of other professionals for implementation purposes. The Client is under no obligation to engage theservices of any such recommended professional. The Client retains absolute discretion over all suchimplementation decisions and is free to accept or reject any recommendation from BFP. Please Note: If theClient engages any such recommended professional, and a dispute arises thereafter relative to suchengagement, the Client agrees to seek recourse exclusively from and against the engaged professional.Please Also Note: It remains the Client’s responsibility to promptly notify BFP if there is ever any change intheir financial situation or investment objectives for the purpose of reviewing/evaluating/revising BFP’s previousrecommendations and/or services.FINANCIAL COACHING SERVICESBFP provides Financial Coaching services for an hourly fee. These services include, but are not limited to: Educating clients on financial fundamentals such as budgeting and using services such as Quickenand Mint to organize their personal finances.Assist clients in the process of overcoming their financial indebtedness through evaluation of debt,consolidation options, alternate payment schedules, etc.Help clients identify and modify ineffective money management behaviors such as excessivespending, poor prioritization of debt management, etc.Guide clients in developing successful strategies for achieving their financial goals such asdeveloping, funding and maintaining cash reserves, proper use of retirement plans, etc.Support clients as they work through their financial challenges and opportunities.Help clients address large financial decisions such as new cars, home, re-location, etc.2Brighton Financial Planning
Brighton Financial PlanningForm ADV Part 2ABrochureIARD/CRD No: 153112SEC File No.: 801- 711692/1/19Limitations of Financial Planning and Non-Investment Consulting/ImplementationServices. As indicated above, to the extent requested by a client, BFP may provide financial planning andrelated consulting services regarding non-investment related matters, such as estate planning, tax planning,insurance, etc. BFP does not serve as an attorney, accountant or insurance agent, and no portion of itsservices should be construed as legal or accounting services. Accordingly, BFP does not prepare estateplanning documents or tax returns or sell insurance products. To the extent requested by a client, BFP mayrecommend the services of other professionals for certain non-investment implementation purpose (i.e.attorneys, accountants, insurance agents, etc. The client is under no obligation to engage the services of anysuch recommended professional. The client retains absolute discretion over all such implementation decisionsand is free to accept or reject any recommendation from BFP or its representatives.CUSTOMIZATION OF SERVICESOur clients are primarily individual investors. As a result, we may tailor our services to meet individual criteria.This may include adjusting asset allocations to incorporate cash flow needs, risk tolerance, time horizon andother specific criteria. We do not accept restrictions regarding investing in certain securities or types of securitieshowever, we do accept client restrictions regarding investments they may transfer into their accounts. Thistypically includes employer stock or securities a client does not want sold for personal reasons. We treat thesesecurities as non-managed assets.WRAP FEE PROGRAMSWe do not participate in wrap fee programs.ASSETS UNDER MANAGEMENTAs of December 31, 2018, Brighton Financial Planning had 55,073,292 in discretionary assets and 11,493,932in non-discretionary assets. As of December 31, 2018, Brighton Financial Planning had total assets 66,567,224.Fees and CompensationForm ADV Part 2A, Item 5DISCRETIONARY FEE SCHEDULE (Accounts over 50,000) 50,000 to 1,000,000 –NEXT 1,000,001– 2,500,000NEXT 2,500,000 1.25% on average daily balances0.75% on average daily balances0.25% on average daily balancesAccounts opened after January 1, 2014 and under 50,000 and all held away accounts (regardless of assets)opened after January 1, 2014 are billed a flat .20% annually, paid quarterly in arrears. Fees are calculatedquarterly, in arrears, using average daily balance for the completed quarter. Each client receives a quarterlybilling statement with his/her quarterly account statement. Fees are deducted directly, with client consent, fromthe client account seven (7) days after the quarterly billing statement is mailed to clients. Related client accountassets are aggregated for fee purposes. Fees are billed on a pro-rated basis (from the first of the quarter to thedate of termination) upon client account termination for any reason. BFP reserves the right to negotiate fees andaccept accounts below 50,000.Discretionary fee includes aggregating family accounts (parent/child or siblings, etc.) for purposes of calculating fees.ASSET MONITORING FEE SCHEDULESAsset Monitoring/Investment Advisory:.2% of assets under advisement, paid quarterly, in arrears using the custodian statement. BFP reserves theright to negotiate fees.3Brighton Financial Planning
Brighton Financial PlanningForm ADV Part 2ABrochureIARD/CRD No: 153112SEC File No.: 801- 711692/1/19FINANCIAL PLANNING AND FINANCIAL COACHING SCHEDULES:Financial and Estate PlanningWe will quote our services in advance of an engagement. The quote will represent the maximum a client willpay for our financial planning services. If we spend less time providing our services than intended, we willadjust the final invoice accordingly. Our fees are based on the following hourly schedule:Data Collection 200 per hourData Analysis/Plan Preparation 250 per hourMeetings with the Financial Planning team 300 per hourThe fee encompasses data collection and analysis, plan creation, recommendations, 2-3 meetings and anadditional follow up meetings as needed for the next 12 months post plan presentation. Clients pay an initial feeof 500 at the time the financial planning agreement is signed. This fee is credited toward the final invoice.Payment for the final invoice is due upon receipt.Any client for whom we manage 300,000 or more in discretionary managed assets receive services on acomplimentary basis as needed/requested. Clients with discretionary assets under 300,000 receive serviceson a pro-rated basis.Financial Coaching 250 per hourFinancial coaching services are quoted in advance of engagement and represent the maximum the client willpay for the services rendered. BFP reserves the right to negotiate all financial planning and coaching fees.NON-DISCRETIONARY DEFINED CONTRIBUTION PARTICIPANT ALLOCATION SERVICESBFP charges 300 annually for the services of Q3 Advisors. You will not pay a separate fee to them. Thisservice is complimentary for clients who retain BFP to manage assets on a discretionary basis.The fee is collected by a third party via credit card and can be paid quarterly or annually. Neither BFP nor Q3Advisors retain credit card information. This service isAll advisory, financial and estate planning fees are calculated in advance and presented to clients prior toengagement. There is an initial fee of 500.00 applied to the total service fee. Non-discretionary investmentadvisory, financial and estate planning fees are credited against discretionary investment management fees ifthe client retains BFP to manage assets on a discretionary basis. Accounts exceeding 50,000 in value during aquarter are charged on a pro-rated basis according to the discretionary investment management fee schedule.BFP reserves the right to negotiate fees.NON-DISCRETIONARY DEFINED CONTRIBUTION ADVISORY SERVICESOur fee for this service is 0.5% of assets under advisory annualized and is calculated, debited from plan assetsand paid to BFP by the third party administrator on a quarterly basis. Prior written consent of clients is providedto the third-party administrator.ADDITIONAL FEESClients for whom Brighton Financial Planning manages assets pay additional fees charged by the custodian.Clients also pay transaction fees charged by the custodian for securities transactions initiated for clients by BFP.Please see Section on Brokerage Practices for more information.4Brighton Financial Planning
Brighton Financial PlanningForm ADV Part 2ABrochureIARD/CRD No: 153112SEC File No.: 801- 711692/1/19Financial and estate planning clients pay an initial set up fee of 500. If the agreement is cancelled within 5 days,this fee will be refunded to clients. All other fees are paid in arrears. For clients closing investment managementaccounts during a calendar quarter, all fees are pro-rated to the date of termination. The pro-rated fee is deductedfrom the account prior to liquidation or transfer out of the custodian. This applies whether termination was initiatedby the client or by BFP.Performance-Based Fees and Side-By-Side ManagementForm ADV Part 2A, Item 6Brighton Financial Planning does not charge performance-based fees and does not participate in side-by-sidemanagement. Side-by-side management refers to the practice of managing accounts that are chargedperformance-based fees while at the same time managing accounts that are not charged performance-basedfees. Performance-based fees are fees that are based on a share of capital gains or capital appreciation of aclient's account.Types of ClientsForm ADV Part 2A, Item 7Brighton Financial Planning provides investment management, financial and estate planning and nondiscretionary defined contribution investment advisory services to individual investors, trusts and small to midsize companies. Our minimum account size for discretionary investment management is 50,000. BFP doesreserve discretion to accept accounts under 50,000. BFP does not have a minimum for non-discretionarydefined contribution investment advisory services, non-discretionary investment advisory services or for financialand estate planning services.Methods of Analysis, Investment Strategies and Risk of LossForm ADV Part 2A, Ite
Item 15 Custody – changed to reflect TD Ameritrade acquisition of Scottrade. Item 14 Client Referral – has been updated to reflect the firm uses a solicitor. Brighton Financial Planning 1728 Rt. 31, Clinton, NJ 08809 908-730-7000 . nature of their program, Q3 Advisors is require
