Material claims selected for substantiation are listed here with their governing source, evidence, verification date, and reopen trigger.
Registered with the U.S. Securities and Exchange Commission. CRD #316908, SEC File #801-135277. Verifiable on the SEC’s public Investment Adviser Public Disclosure database.
As an SEC-registered adviser, the firm owes the fiduciary duties of care and loyalty under the Advisers Act, as interpreted in the SEC’s Commission Interpretation Regarding Standard of Conduct (IA-5248, 2019). Disciplinary history, if any, appears on IAPD.
Organized in Florida in 2021; registered office 4210 Valley Ridge Blvd, Suite 105, Ponte Vedra Beach, FL 32081, in the Jacksonville metro area, per the filed ADV amendment and the current IAPD record.
The firm is compensated solely by client advisory fees. It receives no commissions, 12b-1 fees, or product compensation from any third party.
Tiered, blended advisory fee calculated on quarter-end value: 1.12% first $1M, 0.97% next $1M, 0.85% next $1M, 0.69% next $2M, 0.62% above $5M. Separate third-party platform fees of ~0.12–0.30% apply.
The planning menu on the Pricing page reproduces the fixed-fee schedule as filed, including the $125 Family Mapping annual update. A 50% deposit is collected at the start; for clients who enroll in investment management the remaining 50% is waived and the deposit credited.
The stated account minimum and the firm’s discretion to waive it are disclosed in the brochure.
Annual reimbursement toward a qualified preparer — up to $400 for households under $1M in managed assets and $825 at $1M and above — when the client provides the written authorization that enables coordinated tax planning.
Assets are held at independent qualified custodians — Charles Schwab and Fidelity. The firm takes no physical possession of client assets; it is deemed to have custody solely through fee deduction and standing letters of authorization, exactly as Items 12 and 15 disclose.
Portfolio construction draws on third-party manager platforms (Adhesion Wealth, AssetMark) and Pontera for held-away retirement accounts, each disclosed.
When advised on, an annuity’s value may be included in billable assets — a category distinct from regulatory assets under management — a conflict of interest the brochure discloses plainly.
BAFAos is developed and owned by BAFA Labs, Inc., a technology company under common ownership with the firm. Disclosed as a related-party conflict in Item 10.C.
Wealth.com is an independent provider; the firm drafts no legal documents, gives no legal advice, and receives no compensation from Wealth.com.
No automated system independently gives client advice or effects a transaction; human review of client-facing recommendations is operative and disclosed.
The artifact-bound release gate — approval cryptographically tied to the exact document version — is an approved design (DR-01) whose implementation is tracked separately; operating effectiveness is not certified by this row.
Registry snapshot v1.9, dated 2026-08-13, contains 502 distinct planning-rule atoms; each records its governing authority, effective and expiry dates, and version. The count is pinned to that dated snapshot and changes only with a new one. Operating use of every atom is not certified by this row, and a detector without the facts it requires returns insufficient data rather than a finding.
Books and records are retained as Rule 204-2 requires. The fuller decision bundle described on the BAFAos page — inputs, assumptions, alternatives weighed, approvals, the delivered artifact — is a governed build target under DR-01; WORM and artifact-binding operating effectiveness is not certified by this row.
eMoney, Nitrogen, Black Diamond, and Wealth.com are independent service providers; the firm receives no compensation from any of them. Provider identity is confirmed; live status of each integration is tracked per connection in the service-provider inventory (v0.4, working) and is not certified wholesale by this row.
The controlling disclosure is Item 13.A: score recomputation is initiated at the advisor’s desk, not by an autonomous scheduler. This row supersedes the prior daily-cadence design language; the cadence copy on the Health Score page, Journeys, Investment Management, WealthChat, and llms.txt now reads desk-initiated, per the sweep of Aug 18, 2026.
A composite constructed for illustration — not an actual client, not a testimonial, and not a representation that any client obtained these results. Every specimen and plate on this site is labelled hypothetical for the same reason.
The written program requires TLS 1.2+ in transit, AES-256 at rest, MFA for all personnel and portal access, role-based access, and audit logging. This row verifies the written policy text and version identity only — v2.2 expressly supersedes v2.1 — and does not certify operating effectiveness while the ISP’s adoption disposition is open.
The website policy governs visitor inquiries; the Reg S-P Privacy Notice governs client information under its own sharing table. Each policy is cited to its own scope, and the notice-to-practice data-flow reconciliation remains open (v0.4 TR-13).
Hypothetical figures — the sample folio, the ledger, the health score, the fee illustration — are labeled as illustrative wherever they appear and represent no actual client. The material claims identified in this register trace to the sources above.
