A. Farther Finance Advisors, LLC (“Farther”) is a limited liability company formed in the
state of Delaware. Farther became registered as an Investment Adviser Firm in July 2019.
Farther is solely owned by Farther, Inc., and Mr. Matthews and Mr. Genser are Farther’s
are founding members.
B.
INVESTMENT ADVISORY SERVICES
Farther typically offers advisory services through a website and mobile application portal
(“Platform”) designed to help clients accomplish both near-term and long-term personal
finance goals, where both preservation of capital and capital growth are important
considerations. Through this Platform, Farther offers an in person and online discretionary
investment management service, on a wrap fee basis, designed expressly for investors who
want investment advice for a reasonable price and without a significant time commitment.
Specifically, Farther offers clients investment advice based on personalized information
that each client provides via the firm’s Platform. Farther’s investment strategy is based on
Modern Portfolio Theory which strives to maximize return relative to risk.
Depending upon the circumstance Farther will craft bespoke portfolio allocations or use a
proprietary algorithm to implement model portfolios designed by investment experts with
target asset allocations of equity and fixed-income securities based on the client’s financial
situation, risk tolerance, and time horizon (“Objective”).
Clients who do not wish to use the Platform may also meet directly with several of the
firm’s representatives for advisory services.
When a client deposits money, Farther allocates that money to portfolios based on the
client’s goals, which may include saving for emergencies, retirement, large purchases, or
general long-term savings. In doing so, Farther constructs a combination of securities
purchases to align the client’s account with the corresponding target asset allocation. Upon
a client’s request to withdraw money, a combination of securities sales is initiated while
continuing to pursue the corresponding target asset allocation.
Clients may manually select one of the target asset allocations other than the one
recommended or currently in effect. As clients deposit or withdraw money the
corresponding transactions will rebalance to pursue the modified target asset allocation. If
the holdings of the account significantly deviate from the newly selected target asset
allocation, then Farther will initiate a rebalancing to bring the holdings within an acceptable
range of the target asset allocation.
In the model portfolios, Farther’s algorithm is designed to keep the holdings within each
client’s portfolio within a specified range of the target asset allocation, even when the
market prices fluctuate. Client holdings are rebalanced and dividends are reinvested
automatically. In general, Farther will consider rebalancing whenever the percentage
holding of one or more positions fluctuate 5% above or below its target allocation.
The rebalancing process is automated and not limited to number or frequency of
rebalances. As a result, there is a possibility that Farther may sell overrepresented positions
and use the proceeds to buy underrepresented positions to bring portfolios towards its target
allocation without taking into account individual tax consequences or market
circumstances.
FARTHER ADVISORS WRAP PROGRAM
Farther sponsors the Farther Advisors Wrap Program (the “Program”) through which it
offers all of its discretionary investment management services. The services offered under,
and the corresponding terms and conditions pertaining to, the Program are discussed in the
Wrap Fee Program Brochure, a copy of which is presented to all prospective Wrap Program
participants.
Under the Program, Farther is able to offer participants discretionary investment advisor
services, for a single specified annual Program fee, inclusive of trade execution, custody,
reporting, account maintenance, investment management fees.
The current annual Program fee generally ranges from 0.35% to 1.50%, depending upon
the complexity of the account, the amount of the client assets in the Program and the
independent/separately managed accounts utilized by the client’s investment portfolio.
The terms and conditions for client participation in the Program are set forth in detail in
the Wrap Fee Program Brochure, which is presented to all prospective Program participants
in accordance with disclosure requirements. All prospective Program participants should
read both the Brochure and the Wrap Fee Program Brochure, and ask any corresponding
questions that they may have, prior to participation in the Program.
As indicated in the Wrap Fee Program Brochure, participation in the Program may cost
more or less than purchasing such services separately. When managing a client’s account
on a wrap fee basis, Farther shall receive as payment for its asset management services, the
balance of the wrap fee after all other non-excluded costs incorporated into the wrap fee
have been deducted. As also indicated in the Wrap Fee Program Brochure, the Program fee
charged by Farther for participation in the Program may be higher or lower than those
charged by other sponsors of comparable wrap fee programs.
Wrap Program-Conflict of Interest. Under Farther’s wrap program, the client generally
receives investment advisory services, the execution of securities brokerage transactions,
custody and reporting services for a single specified fee. When managing a client’s account
on a wrap fee basis, Farther shall receive as payment for its investment advisory services,
the balance of the wrap fee after all other costs incorporated into the wrap fee have been
deducted.
Because wrap program transaction fees and/or commissions are being paid by Farther to
the account custodian/broker-dealer, Farther has an economic incentive to maximize its
compensation by seeking to minimize the number of trades in the client's account.
RETIREMENT PLAN SERVICES
Farther also provides retirement plan consulting services, pursuant to which it assists
sponsors of self-directed and pooled retirement plans organized under the Employee
Retirement Security Act of 1974 (“ERISA”). The terms and conditions of the engagement
shall be set forth in the agreement between Farther and the plan sponsor.
If the plan sponsor engages Farther in a ERISA Section 3(21) capacity, Farther will assist
with the selection and/or monitoring of investment options (generally open-end mutual
funds and exchange traded funds) from which plan participants shall choose in self-
directing the investments for their individual plan retirement accounts.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. To the extent requested by a client, Farther may provide financial planning and
related consulting services. Neither Farther nor its investment adviser representatives assist
clients with the implementation of any financial plan, unless they have agreed to do so in
writing. Farther does not monitor a client’s financial plan, and it is the client’s
responsibility to revisit the financial plan with Farther, if desired.
Furthermore, although Farther may provide recommendations regarding non-investment
related matters, such as estate planning, tax planning and insurance, Farther does not serve
as a law firm or accounting firm and no portion of Farther’s services should be construed
as legal or accounting services. Accordingly, Farther does not prepare estate planning
documents or tax returns.
To the extent requested by a client, Farther may recommend the services of other
professionals for certain non-investment implementation purpose (i.e., attorneys,
accountants, insurance agents, etc.), including certain of its related persons in their capacity
as licensed insurance agents. The client is under no obligation to engage the services of
any such recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from Farther
and/or its representatives.
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional[s]
(i.e., attorney, accountant, etc.), and not Farther, shall be responsible for the quality and
competency of the services provided.
Cash Positions. Farther continues to treat cash as an asset class. As such, unless
determined to the contrary by Farther, all cash positions (money markets, etc.) shall
continue to be included as part of assets under management for purposes of calculating
Farther’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated market
conditions/events will occur), Farther may maintain cash positions for defensive purposes.
In addition, while assets are maintained in cash, such amounts could miss market advances.
Depending upon current yields, at any point in time, Farther’s advisory fee could exceed
the interest paid by the client’s money market fund.
When the account is holding cash positions, those cash positions will be subject to the same
fee schedule as set forth below.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from
account transactions or new deposits, be swept to and/or initially maintained in a
specific custodian designated sweep account. The yield on the sweep account will
generally be lower than those available for other money market accounts. When this
occurs, to help mitigate the corresponding yield dispersion Farther shall (usually within 30
days thereafter) generally (with exceptions) purchase a higher yielding money market fund
(or other type security) available on the custodian’s platform, unless Farther reasonably
anticipates that it will utilize the cash proceeds during the subsequent 30-day period to
purchase additional investments for the client’s account. Exceptions and/or modifications
can and will occur with respect to all or a portion of the cash balances for various reasons,
including, but not limited to the amount of dispersion between the sweep account and a
money market fund, the size of the cash balance, an indication from the client of an
imminent need for such cash, or the client has a demonstrated history of writing checks
from the account.
The above does not apply to the cash component maintained within a Farther actively
managed investment strategy (the cash balances for which shall generally remain in the
custodian designated cash sweep account), an indication from the client of a need for access
to such cash, assets allocated to an unaffiliated investment manager and cash balances
maintained for fee billing purposes.
The client shall remain exclusively responsible for yield dispersion/cash balance decisions
and corresponding transactions for cash balances maintained in any Farther unmanaged
accounts.
Unaffiliated Private Investment Funds. Farther also provides investment advice
regarding private investment funds. Farther, on a non-discretionary basis, may recommend
that certain qualified clients consider an investment in private investment funds, the
description of which (the terms, conditions, risks, conflicts and fees, including incentive
compensation) is set forth in the fund’s offering documents. Farther’s role relative to
unaffiliated private investment funds shall be limited to its initial and ongoing due diligence
and investment monitoring services. If a client determines to become an unaffiliated private
fund investor, the amount of assets invested in the fund(s) shall be included as part of
“assets under management” for purposes of Farther calculating its investment advisory fee.
Farther’s fee shall be in addition to the fund’s fees. Farther’s clients are under absolutely
no obligation to consider or make an investment in any private investment fund(s).
Private investment funds generally involve
various risk factors, including, but not limited
to, potential for complete loss of principal, liquidity constraints and lack of transparency,
a complete discussion of which is set forth in each fund’s offering documents, which will
be provided to each client for review and consideration. Unlike liquid investments that a
client may own, private investment funds do not provide daily liquidity or pricing. Each
prospective client investor will be required to complete a Subscription Agreement,
pursuant to which the client shall establish that he/she is qualified for investment in the
fund, and acknowledges and accepts the various risk factors that are associated with such
an investment.
Valuation. In the event that Farther references private investment funds owned by the client
on any supplemental account reports prepared by Farther, the value(s) for all private
investment funds owned by the client shall reflect the most recent valuation provided by
the fund sponsor. However, if subsequent to purchase, the fund has not provided an
updated valuation, the valuation shall reflect the initial purchase price. If subsequent to
purchase, the fund provides an updated valuation, then the statement will reflect that
updated value. The updated value will continue to be reflected on the report until the fund
provides a further updated value.
As result of the valuation process, if the valuation reflects initial purchase price or an
updated value subsequent to purchase price, the current value(s) of an investor’s fund
holding(s) could be significantly more or less than the value reflected on the report. Unless
otherwise indicated, Farther shall calculate its fee based upon the latest value provided by
the fund sponsor.
Cryptocurrency. For clients who want exposure to cryptocurrencies, including Bitcoin,
Farther, will advise the client to consider a potential investment in corresponding exchange
traded securities or private funds that provide cryptocurrency exposure. Crypto is a digital
currency that can be used to buy goods and services, but uses an online ledger with strong
cryptography (i.e., a method of protecting information and communications through the
use of codes) to secure online transactions. Unlike conventional currencies issued by a
monetary authority, cryptocurrencies are generally not controlled or regulated and their
price is determined by the supply and demand of their market. Because cryptocurrency is
currently considered to be a speculative investment, Farther will not exercise discretionary
authority to purchase a cryptocurrency investment for client accounts. Rather, a client must
expressly authorize the purchase of the cryptocurrency investment. Farther does not
recommend or advocate the purchase of, or investment in, cryptocurrencies. Farther
considers such an investment to be speculative. Clients who authorize the purchase of a
cryptocurrency investment must be prepared for the potential for liquidity constraints,
extreme price volatility and complete loss of principal.
Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client
leaving an employer typically has four options regarding an existing retirement plan (and
may engage in a combination of these options): (i) leave the money in the former
employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is
available and rollovers are permitted, (iii) roll over to an Individual Retirement Account
(“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age,
result in adverse tax consequences). If Farther recommends that a client roll over their
retirement plan assets into an account to be managed by Farther, such a recommendation
creates a conflict of interest if Farther will earn new (or increase its current) compensation
as a result of the rollover. If Farther provides a recommendation as to whether a client
should engage in a rollover or not, Farther is acting as a fiduciary within the meaning of
Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code,
as applicable, which are laws governing retirement accounts. No client is under any
obligation to roll over retirement plan assets to an account managed by Farther.
Account Aggregation Reporting Services. Farther uses account aggregation software,
which can incorporate client investment assets that are not part of the assets that Farther
manages (the “Excluded Assets”). Unless agreed to otherwise, in writing, the client and/or
their other advisors that maintain trading authority, and not Farther, shall be exclusively
responsible for the investment performance of the Excluded Assets. Unless also agreed to
otherwise, in writing, Farther does not provide investment management, monitoring or
implementation services for the Excluded Assets. The client can engage Farther to provide
investment management services for the Excluded Assets pursuant to the terms and
conditions of the Investment Advisory Agreement between Farther and the client.
Independent Managers. Farther may allocate a portion of the client’s investment assets
among unaffiliated independent investment managers in accordance with the client’s
designated investment objective(s). In such situations, the Independent Manager[s] shall
have day-to- day responsibility for the active discretionary management of the allocated
assets. Farther shall continue to render investment supervisory services to the client relative
to the ongoing monitoring and review of account performance, asset allocation and client
investment objectives. Factors that Farther shall consider in recommending Independent
Manager[s] include the client’s designated investment objective(s), management style,
performance, reputation, financial strength, reporting, pricing, and research. The
investment management fee charged by the Independent Manager[s] is separate from, and
in addition to, Farther’s investment advisory fee disclosed at Item 5 below.
Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing
involves the incorporation of Environmental, Social and Governance (“ESG”)
considerations into the investment due diligence process. ESG investing incorporates a set
of criteria/factors used in evaluating potential investments: Environmental (i.e., considers
how a company safeguards the environment); Social (i.e., the manner in which a company
manages relationships with its employees, customers, and the communities in which it
operates); and Governance (i.e., company management considerations). The number of
companies that meet an acceptable ESG mandate can be limited when compared to those
that do not and could underperform broad market indices. Investors must accept these
limitations, including potential for underperformance. Correspondingly, the number of
ESG mutual funds and exchange-traded funds are limited when compared to those that do
not maintain such a mandate. As with any type of investment (including any investment
and/or investment strategies recommended and/or undertaken by Farther), there can be no
assurance that investment in ESG securities or funds will be profitable or prove
successful. Farther does not maintain or advocate an ESG investment strategy but will
seek to employ ESG if directed by a client to do so. If implemented, Farther shall rely upon
the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or
separate account portfolio manager to determine that the fund’s or portfolio’s underlying
company securities meet a socially responsible mandate.
Use Mutual Funds and Exchange Traded Funds: Farther may recommend that clients
allocate investment assets to publicly available mutual funds and/or ETFs that the client
could obtain without engaging Farther as an investment adviser. However, if a client or
prospective client determines to allocate investment assets to publicly available mutual
funds or ETFs without engaging Farther as an investment adviser, the client or prospective
client would not receive the benefit of Farther’s initial and ongoing investment advisory
services.
Portfolio Activity. Farther has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Farther will review client
portfolios on an ongoing basis to determine if any changes are necessary based upon
various factors, including, but not limited to, investment performance, fund manager
tenure, style drift, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time
when Farther determines that changes to a client’s portfolio are neither necessary nor
prudent. Clients nonetheless remain subject to the fees described in Item 5 below during
periods of account inactivity.
Client Obligations. In performing its services, Farther shall not be required to verify any
information received from the client or from the client’s other professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify Farther if there is ever any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating or revising
Farther’s previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that Farther and
its third-party service providers use to provide services to Farther’s clients employ various
controls, which are designed to prevent cybersecurity incidents stemming from intentional
or unintentional actions that could cause significant interruptions in Farther’s operations
and result in the unauthorized acquisition or use of clients’ confidential or non-public
personal information. Clients and Farther are nonetheless subject to the risk of
cybersecurity incidents that could ultimately cause them to incur losses, including for
example: financial losses, cost and reputational damage to respond to regulatory
obligations, other costs associated with corrective measures, and loss from damage or
interruption to systems. Although Farther has established procedures to reduce the risk of
cybersecurity incidents, there is no guarantee that these efforts will always be successful,
especially considering that Farther does not directly control the cybersecurity measures and
policies employed by third-party service providers. Clients could incur similar adverse
consequences resulting from cybersecurity incidents that more directly affect issuers of
securities in which those clients invest, broker-dealers, qualified custodians, governmental
and other regulatory authorities, exchange and other financial market operators, or other
financial institutions.
Disclosure Statement. A copy of Farther’s written Brochure as set forth on Part 2 of Form
ADV and Client Relationship Summary as set forth in Form CRS shall be provided to each
client prior to, or contemporaneously with, the execution of the Investment Advisory
Agreement.
C. Farther shall provide investment advisory services specific to the needs of each client. Prior
to providing investment advisory services, an investment adviser representative will
ascertain each client’s investment objective(s). Thereafter, Farther shall allocate and/or
recommend that the client allocate investment assets consistent with the designated
investment objective(s). The client may, at any time, impose reasonable restrictions, in
writing, on Farther’s services.
D. As discussed above, Farther only provides its investment management services on a wrap
fee basis. If a client determines to engage Farther, the client will pay a single fee for
bundled services (i.e., investment advisory, brokerage, custody) (See Item 4.B). The
services included in a wrap fee agreement will depend upon each client’s particular need.
When managing a client’s account on a wrap fee basis, Farther shall receive as payment
for its investment advisory services, the balance of the wrap fee after all other costs
incorporated into the wrap fee have been deducted.
E. As of December 31, 2023, Farther had $2,181,821,779 in assets under management on a
discretionary basis.