A. Firm Information
Compass Advisory Group LLC d/b/a Compass Advisors (“Compass Advisors” or the “Advisor”) is a registered
investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Compass Advisors is organized
as a Limited Liability Company (“LLC”) under the laws of the State of Delaware. Compass Advisors was founded
in March 2017 and is owned and operated by Lauren M. King (Partner) and Michael A. Cuneo (Partner). This
Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by Compass Advisors.
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B. Advisory Services Offered
Compass Advisors offers investment advisory services to individuals, high net worth individuals, trusts, estates,
businesses and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Compass Advisors’ fiduciary commitment is further described in the Advisor’s Code of Ethics.
For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest
in Client Transactions and Personal Trading.
Investment Management Services
Compass Advisors provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary investment management and
related advisory services. Compass Advisors works closely with each Client to identify their investment goals and
objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Compass
Advisors will then construct an investment portfolio consisting primarily of low-cost, diversified mutual funds
and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize
individual stocks, bonds or options contracts to meet the needs of its Clients. The Advisor may retain certain
legacy investments based on portfolio fit and/or tax considerations.
Compass Advisors’ investment approach is primarily long-term focused, but the Advisor may buy, sell or re-
allocate positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Compass Advisors will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
Compass Advisors evaluates and selects investments for inclusion in Client portfolios only after applying its
internal due diligence process. Compass Advisors may recommend, on occasion, redistributing investment
allocations to diversify the portfolio. Compass Advisors may recommend specific positions to increase sector or
asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against
market movement. Compass Advisors may recommend selling positions for reasons that include, but are not
limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of
securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client,
generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will Compass Advisors accept or maintain custody of a Client’s funds or securities, except for the
limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated
account[s] at the Custodian, pursuant to the Client investment advisory agreement. For additional information,
please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
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provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Schwab Institutional Intelligent Portfolios – The Advisor may recommend an automated investment program
through which Clients are invested in a range of investment strategies Compass Advisors has constructed and
manages (“Program”). The Client’s portfolio is held in a brokerage account opened by the Client at Charles
Schwab & Co., Inc. (“Schwab”). The Advisor utilizes the Institutional Intelligent Portfolios® platform, offered by
Schwab Performance Technologies, a software provider to independent investment advisors
and an affiliate of
Schwab, to operate the Program. The Advisor remains the Client’s investment advisor and primary point of
contact. The Advisor is responsible for determining the appropriateness of the Program for the Client, choosing a
suitable investment strategy and portfolio for the Client’s investment needs and goals, and managing that
portfolio on an ongoing basis.
Retirement Plan Advisory Services
Compass Advisors provide retirement plan advisory services on behalf of the retirement plans (each a “Plan”)
and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist
the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is
customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight Services (ERISA 3(21))
• Investment Management Services (ERISA 3(38))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
These services are provided by Compass Advisors serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA section 408(b)(2),
the Plan Sponsore is provided with a written description of Compass Advisors’ fiduciary status, the specific
services to be rendered and all direct and indirect compensation the Advisor resonablt expects under the
engagement.
Financial Planning Services
Compass Advisors will typically provide a variety of financial planning and consulting services to Clients, either
as a component of investment management services or pursuant to a written financial planning agreement.
Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
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, investment planning, retirement planning,
personal savings, education savings, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually 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.
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Compass Advisors may also refer Clients to an accountant, attorney or other specialists, as appropriate for their
unique situation. For certain financial planning engagements, the Advisor will provide a written summary of
Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the
Advisor may not provide a written summary. Plans or consultations are typically completed within six months of
contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
C. Client Account Management
Prior to engaging Compass Advisors to provide investment advisory services, each Client is required to enter into
one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the
Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Compass Advisors, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Compass Advisors will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Compass Advisors will develop a portfolio for the Client that is intended to meet
the stated goals and objectives of the Client.
• Investment Management and Supervision – Compass Advisors will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Compass Advisors does not manage or place Client assets into a wrap fee program. Investment management
services are provided directly by Compass Advisors.
E. Assets Under Management
As of December 31, 2022, Compass Advisors manages $392,312,142 in Client assets, $250,455,549 of which
are managed on a discretionary basis and $141,856,593 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.