Material claims on this site, on the record.
Material claims selected for substantiation are listed here with their governing source, evidence, verification date, and reopen trigger.
Tier A — operative. Describes something running today; a dated artifact is on file.
Tier B — architectural. Describes the design; promotion to Tier A requires dated operating evidence.
Tier C — forward-looking. Not permitted on these pages; any Tier C claim found is removed, not dated.
Verified by: CCO · TRUE — the cited artifact was located and its stated version/date was matched as of the verification date shown.
TRUE does not, by itself, certify filing submission, policy adoption, or operating effectiveness; each row’s posture states those limits.
Registration & standing
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Any change in registration status
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Registration change or disciplinary event
Organized in Florida in 2021; registered office 4210 Valley Ridge Blvd, Suite 105, Ponte Vedra, FL 32081, in the Jacksonville metro area, per the filed ADV amendment and the current IAPD record.
Dated · Aug 18, 2026 · Verified · CCO · Aug 18, 2026
Reopens · Office relocation or ADV amendment (trigger re-armed Aug 18, 2026)
Fees & compensation
The firm is compensated solely by client advisory fees. It receives no commissions, 12b-1 fees, or product compensation from any third party.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Any new compensation arrangement
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Any amendment to the filed fee schedule
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Any amendment to the filed planning menu
The stated account minimum and the firm’s discretion to waive it are disclosed in the brochure.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Any change to the account minimum
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Any change to the reimbursement terms
Custody & platforms
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Custodian change or any custody event
Portfolio construction draws on third-party manager platforms (Adhesion Wealth, AssetMark) and Pontera for held-away retirement accounts, each disclosed.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Platform addition or termination
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Any change to the fee-base policy
Conflicts & related parties
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Change in ownership, licensing, or client fees
Wealth.com is an independent provider; the firm drafts no legal documents, gives no legal advice, and receives no compensation from Wealth.com.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Any compensation or affiliation change with Wealth.com
Technology & the record
No automated system independently gives client advice or effects a transaction; human review of client-facing recommendations is operative and disclosed.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Any change to the approval workflow or supervision procedures
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Dated operating evidence of the release gate, or any change to DR-01
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.
Dated · Aug 17, 2026 · Verified · CCO with BAFA Labs · Aug 17, 2026
Reopens · Registry version, count, or source-pin change
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Change in records policy or dated production evidence
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Provider, contract, data-flow, or integration-status change
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 18, 2026
Reopens · Any scheduler deployment, cadence change, or change to the desk-initiated posture
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Any specimen shown without its hypothetical label
Security & data
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.
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · ISP re-cut or disposition, adoption status, or control change
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).
Dated · Aug 17, 2026 · Verified · CCO · Aug 17, 2026
Reopens · Any change to website or client-information sharing
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.