Firm Brochure

 

(Part 2A and 2B of Form ADV)

 

Annual Privacy Policy Notice

 

 

 

 

Ability First Financial, LLC.

 

2390 E Camelback Rd #130

 

Phoenix, Arizona 85016

 

410-336-6118

 

www.Ability-first.com

 

ria@Ability-first.com

 

 

 

 

 

 

This brochure provides information about the qualifications and business practices of Ability First Financial, LLC. If you have any questions about the contents of this brochure, please contact us at 410-336-6118, or by email at ria@Ability-First.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority.

 


 

Table of Contents              

Table of Contents  2

Document Change History  6

March 27, 2019  6

Advisory Business  6

Firm Description   6

Additional Brand Names  7

Principal Owners  7

Control/ Access Persons  7

Chief Compliance Officer 7

Types of Advisory Services  7

Tailored Relationships  8

Types of Agreements  8

Financial Planning Agreement 8

Advisory Service Agreement 8

Retainer Agreement 9

Investment Management Agreement 9

Tax Preparation Agreement 9

Termination of Agreement 10

Fees and Compensation   10

Description   10

Non-Asset based fees/ Annual Service Fees  10

Affiliated Vendors  11

Fee Billing  12

Other Fees  12

Expense Ratios  12

Hidden Fees  12

Past Due Accounts and Termination of Agreement 13

Performance-Based Fees  13

Sharing of Capital Gains  13

Types of Clients  13

Description   13

Account Minimums  13

Methods of Analysis  14

Investment Strategies  14

Risk of Loss  14

Disciplinary Information   15

Legal and Disciplinary  15

Other Financial Industry Activities and Affiliations  15

Financial Industry Activities  15

Code of Ethics, Participation or Interest in Client Transactions and Personal Trading  15

Code of Ethics  15

Participation or Interest in Client Transactions  16

Personal Trading  16

Brokerage Practices  16

Selecting Brokerage Firms  16

Selecting other service providers  16

Best Execution   16

Soft Dollars  16

Order Aggregation   17

Review of Accounts  17

Periodic Reviews  17

Review Triggers  17

Regular Reports  17

Client Referrals and Other Compensation   17

Incoming Referrals  17

Referrals Out 17

Other Compensation   18

Custody  18

Account Statements  18

Performance Reports  18

Net Worth Statements  18

Investment Discretion   18

Discretionary Authority for Trading  18

Limited Power of Attorney  18

Voting Client Securities  19

Proxy Votes  19

Financial Information   19

Financial Condition  19

State Required Information: Executive Experience  19

Seth Aaron Rosenberg: 19

Business Continuity Plan   20

General 20

Disasters  20

Alternate Offices  20

Loss of Key Personnel 20

Information Security Program   20

Information Security  20

ADV  2B: Seth Aaron Rosenberg 6414032  21

Educational Background and Business Experience  21

Designation and Degree information   22

Disciplinary Information: 23

Other Business Activities  23

Additional Compensation  23

Supervision   23

Requirements for State-Registered Advisors  23

Additional Documents and Resources  24

Business practices  24

Public Information   24

Social Media  24

Ability First Financial, LLC.  Privacy Policy  25

FACTS   25

Why?  25

What?  25

How?  25

To limit our sharing  25

Who we are  26

What we do  26

Definitions  26

Other important information   26

Ability First Financial Solutions, LLC (Fiduciary Policy) 27

Ability First Financial Is a Fiduciary  27

1.          Analyze  27

2.          Strategize  27

3.          Formalize  27

4.          Implement 27

5.          Monitor 28

Transparency  28

Referenced Documents  29

 



Document Change History

March 27, 2019

1.    Various grammatical changes that do not change the meaning of any section.

2.    Changed minimum financial planning fee to reflect changing business needs.  Minimum Fee raised from $2000 to $4000 at the time of the change no client or prospect had an in force agreement or proposal for $2000.

3.    Created a parallel web-accessible version of this document to provide easy access for clients.

4.    Added additional URL information.

5.    Corrected email and linking in the document.

6.    Corrected font and layout issues.

Advisory Business

Firm Description

 

Ability First Financial, LLC. was founded in 2018 to provide expert advising solutions to Individuals, Businesses, and Organizations needing advance tax mitigation and investment strategies.

 

Ability First Financial, LLC. provides personalized and confidential investment advice to Individuals, Pension and Profit-sharing plans, Trusts, Estates, Charitable Organizations, and Businesses. Advice is provided through consultation to help determine (among other things,) the client’s investment objectives and risk tolerance.

 

Ability First Financial, LLC. focuses on long-term relationships with businesses and their Executives.

 

Ability First Financial, LLC. provides investment advice through a variety of third-party investment managers, Mutual Funds, ETFs, REITs, and other alternatives with the client making the final decision on investments. Ability First Financial, LLC. does not act as a custodian of client assets. Client assets are held at third-party trust companies.

 

Periodic reviews of the client’s investment selection and financial situation are undertaken to address the performance and structure of the investment program as well as assess any changes in the client’s risk tolerance and investment objective. If necessary and agreed upon by the client, specific courses of action may be implemented. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended.

 

Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur.

 

Ability First Financial, LLC operates both as an RIA and an Insurance agency.  Ability First is aware of the inherent conflict of interest that this may pose, and discloses it to all clients, and whenever appropriate seeks to find suitable products that do not pay commission.

 

Additional Brand Names

Ability First Financial, L.L.C. uses the following additional names for marketing and advertising purposes.

 

Ability401k

Ability-Financial

Ability-Planning

Ability-First

Ability-401k

Ability-Retirement

AbilityRetirement

Selfdirect.info

Ability-insurance

Incomefor.Life

 

Additional names do not in any way change the services or offerings but are used solely for marketing purposes.

 

To simplify navigation the Prefix “Retire.”  has been added to simplify participants access to there accounts.

Principal Owners

Seth Aaron Rosenberg, LUTCF, GFS CRD No. 6414032

Control/ Access Persons

At the time of filing, no other Access persons exist.

 

Chief Compliance Officer

 

Seth Rosenberg CRD No. 6414032

Types of Advisory Services

 

Ability First Financial, LLC. provides investment supervisory services, also known as asset management services and furnishes investment advice through consultations. Client assets are managed through approved, third-party investment managers, Mutual funds, ETFs and Alternative Assets including but not limited to REITs, Private Placements, Unit Investment Trusts, and Bonds.

 

Tailored Relationships

 

The goals and objectives for each client are documented in our client relationship management system. Investment policy statements are created and reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities.

 

Agreements may not be assigned without client consent.

Types of Agreements

 

The following agreements define the typical client relationships.

Financial Planning Agreement

 

Ability First Financial, LLC. offers fee-based advice for Financial Planning for Business and Business owners. Financial Planning services are provided on an annual basis for clients that would like a holistic review of all their financial needs and goals.  Financial Planning services are distinct from any investment management services and are not performance based.  Financial planning services may include specific investment category recommendations, insurance products, tax mitigation, estate planning, and business planning advice. Financial planning agreements generally have a $4000 per year minimum.  Planning requires extensive involvement between the advisor and client if the client is unable or unwilling to complete questionnaires a pro-rated refund will be made, and the agreement terminated.

Advisory Service Agreement

 

Ability First Financial, LLC. currently focuses on high net-worth individuals, businesses and business owners, providing services in a consultative and non-discretionary format for clients.

 

“Advisory Services” is intended to be a broad term for Investment and non-investment related solutions provided to clients, the term is not to be used as a replacement for the specifically listed services below but a general description for marketing purposes.  Client agreements will always reflect the exact services they receive, if they are subject to ERISA, if they are Fiduciary or non-Fiduciary, Insurance or investment related, as well as the respective regulatory bodies that review transactions for the specific services.   For example, an Advisor may discuss the need for asset protection with a client, the solution may be determined to be a Universal Life Policy, The Universal Life Policy, is not subject to review by securities regulators but insurance regulators.  However, the same due diligence will be applied to offering the service.  In addition, as an abundance of caution and to comply with FinCEN and Anti-Money Laundering rules a Know Your Customer packet, based on the sample packet provided by FINRA is used for all individual clients prior to completing any transaction with them.

Retainer Agreement

 

Ability First Financial, LLC. offers business planning and management solutions on retainer.  Ability First Financial, LLC. may require a retainer or minimum engagement for non-investment activities.  All proposals reflect disclosure of Investment and non-investment expenses.  Examples may include insurance consulting, TPA and/or recordkeeping solutions. Retainers generally have a minimum of $2000 per year are non-refundable and are for Fiduciary and non-Fiduciary services distinct from investment advice and management.  The services may be offered alongside investment-related services but are not bundled, all services receive a distinct line item and are distinctly billed for, investment clients need not use, and ancillary services provided by Ability First Financial, LLC. as a condition of service and receive no discount for doing so.   Additionally, in the case when fees are to be drawn from accounts plan or participant accounts a bill is sent to the client for approval and the fees are disclosed on the 408(b)2 and other relevant disclosure documents.  For example, a 401k Record Keeping solution is currently $15 PE/PM subject to the complexity of the services offered and is inclusive of any fees charged by subcontracted providers, like daily valuation, pricing, statement, and customer service providers.  Each subcontracted provider is disclosed on the 408(b)2.  Ability First does not offer the option of charging these services based on an asset fee like many providers or in a bundled manner since the cost to provide these services is not related to the size of the account but the number of phone calls a participant makes to customer service, the time they spend using research services and the number of transactions they make per year.

Investment Management Agreement

 

An Investment Management Agreement is executed as an integral part of the relationship. The annual fee for our advisory services (as noted in the Investment Management Agreement) is generally between 1% and 2% depending on variables such as the third-party manager used, the investment vehicles implemented (i.e., mutual fund and ETF expenses ratios,) and the dollar value of the client account. In certain situations, the annual fee may be negotiable.

 

Ability First Financial, LLC.  Regularly uses third-party money managers to provide the best options to clients that would benefit from the use of a specialized portfolio manager.  The fees for these third-party money managers is inclusive in the 1% to 2% and is listed in disclosures as applicable.

Tax Preparation Agreement

 

Ability First Financial, LLC.  engages the service of a CPA who is also a CFA.  A Copy of the engagement agreement is included as a supplement to this agreement.     Tax preparation and/or advice is never bundled with Investment Management Services and always requires a separate agreement.

 

Termination of Agreement

 

A Client may terminate any of the aforementioned agreements with a 30-day notice by notifying Ability First Financial, LLC. in writing and paying the rate for the time spent on the investment advisory engagement prior to notification of termination. If the client made an advance payment, Ability First Financial, LLC. (through the relevant third-party platform) will refund any unearned portion of the advance payment.

 

Ability First Financial, LLC. may terminate any of the aforementioned agreements at any time by notifying the client in writing. If the client made an advance payment, Ability First Financial, LLC. will refund any unearned portion of the advance payment.

 

Fees and Compensation

 

Description

 

Third-party managers utilized by Ability First Financial, LLC. base their fees on a percentage of assets under management. As previously stated, annual fees are generally between 1% and 2% depending on the third-party manager, the investment vehicles utilized, and the size of the account. In certain situations, the annual fee may be negotiable.

 

·         Less than 1MM 2%

·         1MM to 10MM 1.5%

·         10MM and up 1%

Non-Asset based fees/ Annual Service Fees

 

Ability First Financial, LLC. may charge fees not related to investment services including fees that are based on asset values including fees for record keeping.

 

Ability First Financial, LLC. offers non-investment Insurance products to clients as appropriate.  However:

·         Variable Insurance products (if deemed appropriate) are only sold when an AUM or zero compensation version is available.

·         If neither option is available and the advisor deems the product to be the best option for the client, the advisor will refer the client to the manufacturer or distributor of the said product and will not accept any compensation for the sale.

·         Fixed and Equity Index products are deemed to be compliant with Rule 3030, however, Ability First Financial LLC has adopted a fiduciary program to ensure that the client’s best interest is always taken into consideration and procedures are in place to ensure and disclose accordingly.

 

Even though CFR 29 § 2510.3-21(b) (Employee Benefits Security Administration, Labor, 2016) the “Fiduciary Rule” is in question. Ability First Financial, L.L.C. has chosen to implement a Fiduciary framework to ensure that all clients are aware of the potential conflicts of interest that exist in the financial world.   Please see Fiduciary Framework starting on page 26

Ability First Financial, LLC.  Annual Service Minimums and fee structures.  

 

Financial Planning and Business Planning services start at a minimum of $4000 per year and are generally billed annually, however on an exception basis may be paid quarterly for the benefit of the client, quarterly or monthly payments may be subject to a service charge.  The Financial Planning and Business planning processes start with a 1-hour free consultation, the prospective client has presented a proposal based on the mutually determined complexity. Pricing is reviewed approximately 90 days before renewal based on experience during the covered period.  No surcharges are provided during the year for services covered in the initial agreement. Additionally, the proposal may include the recommendation of other providers or for the client to engage additional services as part of the relationship. For example, Ability First Financial LLC. provides a general discussion on Estate related concerns but is not an Attorney or Affiliated with one.  

 

In an abundance of caution, Ability First Financial, LLC.  treats all consulting services regulated or not as if they are regulated, a signed agreement, and a know your customer packet is completed prior to any engagement.  Additionally, Ability First Financial, LLC. discloses all potential conflicts as part of its Fiduciary Framework policy which is attached to this document.

 

Affiliated Vendors

 

Ability First Financial, LLC. provides Financial Planning, Insurance, Record Keeping and Tax Services to its clients.   It may engage the use of non-affiliated providers to aid in the offerings. 

 

Clients of Ability First Financial, LLC.  have the option to purchase and select investments with other advisors.  In doing so clients may select brokers, dealers, distributors or agents other than organization recommended and or vetted by Ability First Financial, LLC. and its affiliates.  Clients are free to conduct these transactions on their own, subject to costs and terms set by the vendors of their choice.

 

Clients need-not use Ability First Financial, LLC ’s recommended platforms and are free to conduct transactions entirely outside with any assistance from Ability First Financial, LLC.  When this occurs, the client is charged a reduced advisory fee to cover only the limited scope relationship to the transaction.  Such assets are noted on each statement and the billing reflects the relationship.

Fee Billing

 

Third-party investment management fees are billed quarterly (sometimes in advance,) meaning that fees are deducted from client accounts before the three-month billing period has begun. Fees are deducted from a designated client account to facilitate billing. The client must consent in advance to direct debiting of their investment account. 

Other Fees

Custodians may charge transaction fees on purchases or sales of certain mutual funds and exchange-traded funds. These transaction charges are usually small and incidental to the purchase or sale of a security. The selection of the security by third-party managers is more important than the nominal fee that the custodian charges to buy or sell the security.

 

Expense Ratios

Mutual funds generally charge a management fee for their services as investment managers. The management fee is called an expense ratio. For example, an expense ratio of 0.50 means that the mutual fund company charges 0.5% for their services. Exchange Traded Funds (ETFs) also have expense ratios similar to mutual funds but are generally lower than those fees charged by mutual funds. These fees are in addition to the fees paid investment owner to third-party investment managers for their portfolio management services. Performance figures quoted by mutual fund companies in various publications are after their fees have been deducted. 

 

In today’s fee-compression environment Ability First Finical, LLC. is keenly aware of the effect of excessive fees on accounts. Ability First Financial, LLC., believes that a higher fee on a similar product should not be an eliminating factor. If however, the product provider demonstrates value for the additional expense, it may be appropriate to use a higher fee product.  An Example may include an index fund provided by two different fund companies, the expense ratio may only be one overall factor in the selection of fund, the performance of the fund net of expenses may be a better indicator the selection of investment products.

 

Hidden Fees

Ability First Financial, LLC. does not believe that hidden fees are never beneficial for the client.  As such, Ability First Financial, LLC. does not accept any 12(b)1 fee, Sub-TA fee or other disclosed or non-disclosed fees from any third-party to any client account.   In rare cases, a fund or product that is requested by a client may not be available in a fee-waived version. In that case, Ability First Financial, LLC. works with vendors to return fees directly to plan participant(s) or client(s) accounts wherever possible and permitted by law.  If it is not possible, the advisor will discount its fee by an equal amount of the fee received on an as earned basis.

Past Due Accounts and Termination of Agreement

Due to the fact that Ability First Financial, LLC. does not directly custody client assets, and because management fees are generally deducted directly from client accounts, rarely should a past due situation arise. However, Ability First Financial, LLC. reserves the right to stop work on any account that is more than 90 days overdue should that situation arise, and the client waives Ability First Financial, LLC. of any expenses, penalties, losses or expenses during a work stoppage.

 

In addition, Ability First Financial, LLC. reserves the right to terminate any relationship where a client has willfully concealed or has refused to provide pertinent information, in Ability First Financial, LLC. sole judgment, in providing proper investment advice. Any unused portion of fees collected in advance will be refunded within 30 days. Note:  In cases where a planning relationship is terminated due to a client’s failure to comply, a minimum fee may be charged.

 

Performance-Based Fees

 

Sharing of Capital Gains

Fees are not based on a share of the capital gains or capital appreciation of managed securities.

 

Ability First Financial, LLC. does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client.

 

Types of Clients

Description

Ability First Financial, LLC. specializes in providing investment advice to Pensions and Qualified Plans, as well as High Net worth individuals, other business owners and select individuals for investment and plan design strategy.   Ability First Financial, LLC. also provides consulting and advice to Income Trust and other entities with a focus on long-term tax mitigation strategies.

 

Client relationships vary in scope and length of service.

Account Minimums

Minimum account sizes vary depending on the third-party platform and the specific investment manager used within that platform and are subject to change without notice.

           

Ability First Financial, LLC. will open individual accounts with less than $100,000 on an exception only basis.

Methods of Analysis

Security analysis methods used by third-party managers may include but is not limited to, charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information may include original fundamental research, financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases.

 

Other sources of information that third-party managers may use include but are not limited to Morningstar Principia mutual fund information, Morningstar, Advisor Intelligence, and the World Wide Web.

 

Additional details would be provided in the third-party manager’s disclosures and brochures, when applicable.

Investment Strategies

Ability First Financial, LLC.  believes that individual investment only plays a small part in the overall solutions it provides clients including the management of Levered Planning solutions, the use of qualified plans, engaging in tax planning (with the help of outside tax counsel and or affiliated tax advisors) and the purchase of non-traditional assets that may provide special tax advantages or provide non-correlated risk management from traditional market offerings.  As such, third-party managers, mutual funds and ETF’s are regularly used. Ability First Financial, LLC. reviews all fee options and strives to provide the most cost-effective options to purchase investments as needed by its clients.

Risk of Loss

All investment programs have certain risks that are borne by the investor. Our approach constantly keeps the risk of loss in mind. Investors face the following investment risks:

 

·         Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.

 

·         Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events.

 

·         Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.

 

·         Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Currency risk also is also considered when investing in crypto-currency, cash equivalents, and certain alternatives.

 

·         Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.

 

·         Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it (a lengthy process,) before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.

 

·         Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not.

 

·         Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or declining market value.

 

·         Political and Governmental risk: Changes in tax policy as well as ongoing domestic and international changes in markets.

Disciplinary Information

Legal and Disciplinary

The firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients.

 

Other Financial Industry Activities and Affiliations

Financial Industry Activities

Ability First Financial, LLC. operates as an insurance brokerage, provides tax consulting and preparation as well as providing investment advice.

 

Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

Code of Ethics

 

The employees of Ability First Financial, LLC. have committed to a Code of Ethics that is available for review by clients and prospective clients upon request. The firm will provide a copy of the Code of Ethics to any client or prospective client upon request.

 

Participation or Interest in Client Transactions

Ability First Financial, LLC. and its employees may buy or sell securities that are also held by clients.  Ability First Financial, LLC. primarily provides planning and qualified plan administration. Direct trades are handled on a limited basis. Advisors may not trade ahead of clients and must disclose similar holdings to any client.

Personal Trading

Ability First Financial, LLC. regularly uses third-party managers and as such, it is not aware of the timing of said manager’s trades. Copies of all personal trades are reviewed by the compliance officer to ensure that personal trades are not contrary to the advice provided to clients.

Brokerage Practices

Selecting Brokerage Firms

Ability First Financial, LLC. currently uses MidAtlantic Trust Company and National Financial Services for clients based on specific client needs.  Additional firms may be used as appropriate for each client’s unique needs.

 

Selecting other service providers

Ability First Financial, LLC. works with its clients to provide a mix of in-house comprehensive solutions along with other qualified providers.  Ability First Financial encourages all clients to compare its offerings to other providers and works to source the best options for each client’s specific needs.

Best Execution

Ability First Financial, LLC. provides relevant Best Execution disclosures for the specific custodian holding the client’s assets (including third-party money managers policies as appropriate.)

Soft Dollars

Ability First Financial, LLC.  provides non-investment related services.  All services are individually disclosed.  Ability First Financial LLC. does not select supporting vendors or providers based on its other relationships with that vendor.  Example: while Ability First Financial LLC. uses Mid Atlantic Trust Company as one of its custodians it additionally uses Mid Atlantic Trust Companies stable value and deposit products each product is selected for its own merits.

Order Aggregation

Ability First Financial, LLC. does not aggregate orders, however, as a qualified plan administrator, the orders of individual participants may be aggregated to the plan level.  Orders are not aggregated past the plan level by Ability First Financial, LLC. or its affiliates.

Review of Accounts

Periodic Reviews

Client account reviews are typically performed quarterly by Investment Advisor Representatives (IARs). Account reviews are performed more frequently when market conditions or client needs dictate.  Since the firm is currently a solo-firm there is no second party to review the IAR however once the firm has additional employees the IAR’s supervisor will review recommendations before they are finalized. Seth Rosenberg will be the final review on all accounts.

Review Triggers

Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's own situation.

Regular Reports

Investment Management clients receive quarterly report updates. Among other things, these updates detail the portfolio holdings as well as changes and detailed performance reporting. In most cases, clients also have internet access to their accounts if they chose to activate that feature. Internet access would permit clients to view their accounts daily if they so choose.

Client Referrals and Other Compensation

Incoming Referrals

Ability First Financial, LLC. does not currently offer any referral fees for investment-related services.   Non-Investment related services may be subject to their own referral policies and disclosures.

Referrals Out

Ability First Financial LLC.  does not accept referral fees from any third party however it “White Labels” and works with vendors that may provide enhanced pricing to Ability First Financial LLC. based on its overall relationship with the said vendor.   Examples may include tiered pricing discounts with its back office or transaction clearing vendors.

Other Compensation

Since Ability First Financial LLC. also operates as an Insurance Agency it may receive commissions for the sale and service of insurance-related products.  This inherent conflict is disclosed whenever applicable.  In addition, insurance products that contain a regulated component (i.e. Variable Life and Annuities) may only be offered in a fee-only format.  Ability First Financial, LLC. takes the position that fixed indexed insurance products remain an exempt product and may be offered on a commission or fee basis with an additional disclosure to the client as appropriate. Additionally  Ability First Financial also provides non-custodial record keeping, plan design consulting, document preparation these services may be offered in a Fiduciary or non-Fiduciary compacity and are fully disclosed in any Advisory agreement. 

Custody

Account Statements

All assets are held by qualified custodians. The custodians provide account statements directly to clients at their address of record at least quarterly.

 

Performance Reports

Clients are urged to compare the account statements received directly from their custodians.  In addition, clients may receive additional reports from Ability First Financial, LLC. and its providers.

 

Net Worth Statements

Ability First Financial, LLC. has an affiliated CFA/CPA, however, this service when offered is provided independently of Investment related fees and services.

Investment Discretion

Discretionary Authority for Trading

Ability First Financial, LLC. may accept discretionary authority on accounts only on a limited basis however, it does not currently have any such accounts at this time.

 

The client is expected to complete an agreement authorizing the duration of the authority, the portion of the portfolio subject to authority, limitations on the types of investment and investment products, and the size and scope of the authority.

Limited Power of Attorney

Ability First Financial, LLC. may obtain a limited Power of Attorney for Qualified Accounts to act under the direction of the plan trustees.

Voting Client Securities

Proxy Votes

Ability First Financial, LLC. does not vote proxies on securities. Clients are expected to vote their own proxies.

 

Ability First Financial, LLC. does not maintain custody of any securities, but instead works with custodial partners to ensure that clients receive any and all notices due to them via the custodial partners.

 

Ability First Financial, LLC. will not provide advice on proxy votes.

 


Financial Information

Financial Condition

Ability First Financial, LLC. does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients.

 

A balance sheet is not required to be provided because Ability First Financial, LLC. does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $500 per client, and six months or more in advance.

State Required Information: Executive Experience

Seth Aaron Rosenberg:

Seth Aaron Rosenberg, LUTCF, GFS

Chief Investment Officer

Ability First Financial, LLC.

 

2390 E Camelback Rd #130

410-336-6118

Seth@Ability-First.com

www.Ability-First.com

 

Seth Rosenberg has worked with small and large businesses. He is the fifth generation providing insurance and financial planning solutions to businesses and individuals. He currently holds the designation of Life Underwriting and Training Council Fellow from the National Association of Insurance and Financial Advisors and a Baccalaureate in Business Administration from University of Maryland University College and the Global Financial Stewardship designation from 3Ethos

 

Seth Rosenberg has obtained the Series 7 and 66 and maintains Personal Lines, Life, and Health Insurance licenses as well as the NAIC Model State Education for Long-Term Care and Annuities.

 

Business Continuity Plan

General

Ability First Financial, LLC. has a Business Continuity Plan in place that provides detailed steps to mitigate and recover from the loss of office space, communications, services or key people.

Disasters

The Business Continuity Plan covers natural disasters such as snowstorms, hurricanes, tornadoes, and flooding. The Plan covers man-made disasters such as loss of electrical power, loss of water pressure, fire, bomb threat, nuclear emergency, a chemical event, biological event, Internet outage, railway accident an aircraft accident. Electronic files are backed up daily and archived offsite.

Alternate Offices

Alternate offices are identified to support ongoing operations in the event the main office is unavailable. It is our intention to contact all clients within five days of a disaster that dictates moving our office to an alternate location, as detailed in Ability First Financial, LLC. Business Continuity Plan.

Loss of Key Personnel

In the event of Seth Rosenberg’s serious disability or death, Ability First Financial RIA will engage the services of properly licensed providers until such time that the entity can properly cease operations. 

Information Security Program

Information Security

Ability First Financial, LLC. maintains an information security program to reduce the risk that personal and confidential information may be breached. 


 

ADV  2B: Seth Aaron Rosenberg 6414032 

 

Seth Aaron Rosenberg, LUTCF, GFS

President

 

2390 E Camelback Rd #130

Phoenix, Arizona 85016

410-336-6118

www.Ability-First.com

 

 

This Brochure Supplement provides information about Seth Aaron Rosenberg that supplements the Ability First Financial, LLC. Advisors Brochure. You should have received a copy of that Brochure. Please contact Seth Rosenberg if you did not receive the Ability First Financial, LLC. Brochure or if you have any questions about the contents of this supplement. Additional information about Seth Aaron Rosenberg is available on the SEC’s website at www.adviserinfo.sec.gov.

 

Educational Background and Business Experience

 

Seth Aaron Rosenberg, Age 39

       Global Financial Steward (GFS) 2016

       University of Maryland University College, Bachelor of Science in Business Administration and Management 2015

       The American College for Financial Services, Life Underwriting Training Council Fellowship 2014

       The Community Colleges of Baltimore County Associates of Arts and Sciences in General Studies 2012

 

       Ability First Financial, LLC.  2018- Present

       Jewish Committee on Scouting, Grand Canyon Council, Boy Scouts of America 2018

       Cub Scout Pack 210, Grand Canyon Council, Boy Scouts of America 2018-Present

       Boy Scout Troop 210, Grand Canyon Council, Boy Scouts of America 2018-present

       Capital Executive Solutions, Inc. 2018

       Capital Services, Inc.  2015- 2018

       LifeMark Securities Corporation.  2015-2018

       Prudential Insurance Company of America 2014-2015

       Liberty Mutual Insurance 2012-2014

       CMYK and Hometech Publishing 2010-2012

       Precision Postal 2006-2010

 

 

Designation and Degree information

 

·         Global Financial Steward (GFS) 2016

·         The GFS® designation is awarded to professionals who complete an approved course of instruction on LeaderMetrics® and pass a comprehensive written final exam. The GFS® is the first and only professional designation which is based on leadership and stewardship. (Trone, Branham, & Wattman, Founders, 2018)

 

·         The GFS® designation requires the designee to have read the LeaderMetrics (Trone, Branham, & Wattman, LeaderMetrics, 2015) book, complete a minimum of 22-hour onsite program of coursework and training, and complete a classroom administered exam.

 

·         12 hours of continuing education per year is required to maintain the designation. (FINRA, 2018)

 

·         Bachelor of Science in Business Administration and Management 2015

·         The University of Maryland University College (UMUC) is accredited by the Middle States Commission on Higher Education and is governed by the USM Board of Regents (University Maryland University College, 2018)

 

·         The Business Administration Bachelor’s Degree is a study of “accounting, business law, ethics, and social responsibility, finance, human resource management, strategic management, organizational behavior, marketing and sales, and statistical analysis” (University of Maryland University College, 2018)

 

·         The American College for Financial Services, Life Underwriting Training Council Fellowship 2014

 

·         The designation was jointly conferred by the American College of Financial Services and the National Association of Insurance and Financial Advisors.  Designees where required to complete (5) 8-week courses and 1 self-study course. After each course, a proctored exam was administered.   At the time of confirmation, the designee must be a member of the National Association of Insurance and Financial Advisors.

 

·         The American College for Financial Services is accredited by the Middle States Commission on Higher Education and has been since 1978 (The American College, 2018)

 

·         The National Association of Insurance and Financial advisors or NAIFA is one of the Oldest and largest trade organizations in the insurance field founded in 1890 as the National Association of Life Underwriters (National Association of Insurance and Financial Advisors, 2018).

 

·         The designation provides an in-depth understanding of Life Insurance, Disability, and other protection products, how they interact, as well as an ethical framework for Insurance professionals.

 

Disciplinary Information:

 Mr. Rosenberg has no disciplinary history to disclose.

Other Business Activities

 

Ability First Financial, LLC. is a full-service Financial Services Firm providing Investment, Insurance, Tax and other business consulting services.

 

Personal Real Estate Holdings:  Rental and Investment property in Baltimore, Maryland. 

 

Volunteer Positions:

Cub Scout Pack 210, Grand Canyon Council, Boy Scouts of America (The 1st Sabbath observant Kosher Family Pack in the country): Cub Master 2018-Present

Additional Compensation

Seth Rosenberg receives all compensation related to Financial services through Ability First, LLC, any compensation paid is directed to the entity and disclosed as such.

Supervision

Seth Rosenberg is responsible for the investment activity of Ability First Financial, LLC.

Requirements for State-Registered Advisors

 Mr. Rosenberg has not been involved in/with, or been accused nor found liable for any of the following:

1.    An award or otherwise being found liable in an arbitration claim alleging damages in excess of $2,500, involving any of the following:

(a)   an investment or an investment-related business or activity;

(b)   fraud, false statement(s), or omissions;

(c)   theft, embezzlement, or other wrongful taking of property;

(d)   bribery, forgery, counterfeiting, or extortion; or

(e)   dishonest, unfair, or unethical practices.

2.    An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following:

(a)   an investment or an investment-related business or activity;

(b)   fraud, false statement(s), or omissions;

(c)   theft, embezzlement, or other wrongful taking of property;

(d)   bribery, forgery, counterfeiting, or extortion; or

(e)   dishonest, unfair, or unethical practices.

 

Seth Rosenberg has not been the subject of a bankruptcy petition.

 

Additional Documents and Resources

This document is not intended to replace discussions with your advisor or other research you might consider.

Business practices

Ability First Financial, LLC’s approach is based on Ethotic Leadership and the Universal Framework approach (Trone, Branham, & Wattman, LeaderMetrics, 2015) and are used with permission.

 

Public Information

The most up-to-date version of this document is on file at https://www.adviserinfo.sec.gov/.  Where you may review the most current version or information about this firm and its advisors.   Additionally, some states provide resources to review your advisors and the companies they represent.

 

The primary Ability First Financial, LLC website is located at www.Ability-First.com  however, we use multiple other landing pages to provide an enhanced focus on our service offerings.  All publicly available pages are accessible via the main page.

 

Social Media

We believe in making sure that you have easy access to information about our organizations and we post regularly in a variety of publicly accessible sites. 

https://www.linkedin.com/in/setharosenberg/

 


 

Ability First Financial, LLC.  Privacy Policy

WHAT DOES Ability First Financial LLC,

DO WITH YOUR PERSONAL INFORMATION?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

The types of personal information we collect and share depend on the product or service you have with us. This information can include but is not limited to:

         Social Security number and income

         Account balances and payment history

         Investment Selections

         Health Information (HIPAA Protected)

         Family Status

         Benefit Selections

 

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Ability First chooses to share; and whether you can limit this sharing.

 

Reasons we can share your personal information

Does Ability First Financial LLC., share?

Can you limit this sharing?

For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

YES

NO

For our marketing purposes – to offer our products and services to you

YES

NO

For joint marketing with other financial companies

YES

NO

For our affiliates’ everyday business purposes – information about your transactions and experiences

YES

NO

For our affiliates’ everyday business purposes – information about your creditworthiness

YES

YES

For our affiliates to market to you

YES

YES

For nonaffiliates to market to you

NO

YES

 

To limit our sharing

Call us at 410-336-6118 or speak with your representative to update your privacy choices.

 

Please note:

If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. If you’re an existing customer and have opted out previously, you do not need to update your privacy choices again. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

 

 

Who we are

Who is providing this notice?

Ability First Financial, LLC.

What we do

How does Ability First protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Ability First collect my personal information?

We collect your personal information, for example, when you:

   Open an account or deposit money

   Complete an Application

   Make or change Investments

   Make or change benefit options

   Make or change beneficiaries.

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

   Sharing for affiliates’ everyday business purposes – information about your creditworthiness

   Affiliates from using your information to market to you

   Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

What happens when I limit sharing for an account, I hold jointly with someone else?

Your choices will apply to everyone on your account.  Please note that employees do not necessarily own accounts or benefits provided by current or former employees, please consult the plan documents provided

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Non-Affiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

   Non-Affiliates we share with can include insurance companies, service providers, co-branded partners, retailers, data processors, and advertisers.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

   Our joint marketing partners include companies such as banks and insurance companies.

Other important information

Telephone Communications: All telephone communications with us or our authorized agents may be monitored or recorded. Email and SMS Communication:  All electronic communications are logged and may be analyzed for compliance and security purposes.

Additional rights:   You may have additional rights or obligations from other providers we have engaged on your behalf or have recommended to you. Please review each policy.

 


 

Ability First Financial Solutions, LLC (Fiduciary Policy)

Ability First Financial Is a Fiduciary

 

Pursuant to the Department of Labor’s Rule CFR 29 § 2510.3-21(b) we acknowledge that we are a Fiduciary (This means we disclose conflicts of interest and we place your interests ahead of ours.)

 

To ensure Ability First Financial, LLC acts in your best interest the 3ethos method for fiduciary governance has been adopted.

 

1.   Analyze

Ability First Financial, LLC begins by diligently gathering information from plan participants, employers, plan sponsors and other affected parties gathering information to develop an understanding of the importance of each parties’ goals and preferences and the resources available to achieve them thereby developing an understanding of each party’s needs, goals, resources, risk tolerance, and preferences.

 

2.   Strategize

Ability First Financial, LLC prides itself in providing advisors with sufficient ability in each area of an overall plan.  This provides us with the ability to work together to develop a strategy that benefits each of the responsible parties.  We consider a universe of options and work together to select a strategy that both reasonable and prudent given your stated goals, risk tolerances, geographic location, personal delivery care preferences, and individual expectations.

 

3.   Formalize

Using a structured information gathering approach we present a plan using the experience of our varied team to present one or a series of solutions that we believe to be a logical best recommendation.

 

4.   Implement

Once a solution has been selected our dedicated team of industry professionals will build a roadmap to implement the recommendations from our jointly developed strategy.

 

5.   Monitor

Business is ever changing, when you select a firm you expect them to provide an ongoing relationship, not simply a transaction. Ability First Financial, LLC reviews all plans and programs at least annually during enrollment periods and other times throughout the year as individually appropriate. In addition, we provide a transparent approach ensuring that you receive all statements from the carriers, custodians, and trustees of your accounts as well as the explanation of benefits and plan summary documents you may need to make decisions.

 

Transparency:   We believe that the best relationships come from mutual trust and full disclosure.

 

Ability First Financial, LLC may receive compensation in a number of ways that may vary depending on the recommendations which may cause an unavoidable conflict of interest. As industry professionals, we believe that “Fiduciary is a floor, not a ceiling – [and] you should never be satisfied by being merely compliant with a Fiduciary standard” (Trone, Donald & Mary Lou Wattman, 2015.) We, therefore, believe that we are ethically bound to disclose as much detail as is reasonably possible.

 

An example may include differences in compensation depending on the carrier or plans selected in our recommendations.

 

When we deal with other organizations, (like Insurance Companies, Benefits Administrators, Third-Party Managers, and Investment Fund families,) conflict may arise including:


 

         An organization may be the sponsor of an event or informational session we run, either paying directly for or paying for expenses that Ability First Financial, LLC.  would normally incur.

 

         We may receive a bonus or other compensation for reaching specific business tiers, giving an incentive to concentrate business with specific vendors.

 

         An organization may assist with enrollment or claims processing.

 

         A vendor may recommend some or all of the services as preferred to its existing clients.

 


 

In the end, many conflicts of interest are unavoidable.  However, we believe that by exercising Ethotic leadership™ we can minimize the effects of the conflicts.

         We will not create an economic incentive that favors any specific institution, including affiliated organizations.

         We provide all our advisors with ongoing training and review processes.

         All transactions are reviewed by a supervisor.

         We review and disclose all “Soft Dollar” benefits paid to advisors.

 

As the President of Ability First Financial, LLC I remain ultimately responsible for fostering an environment of Ethotic leadership™ but this document is only a piece of paper. For you to receive the full benefit of Ability First Financial, LLC’s approach to financial advising, you must have an open and honest discussion with your advisors, ask questions, raise concerns and push us to provide ever greater levels of service, unique solutions, and professional advice.

 

Thank you for choosing Ability First Financial, LLC.  We hope to bring change to the industry and exceed your expectations in every way.

Referenced Documents

Employee Benefits Security Administration, Labor. (2016). Code of Federal Regulations. US GPO. Retrieved August 16, 2018, from https://www.gpo.gov/fdsys/pkg/CFR-2016-title29-vol9/pdf/CFR-2016-title29-vol9-sec2510-3-21.pdf

FINRA. (2018, August 15). Global Financial Steward (GFS). Retrieved from FINRA: Professional Designations: https://www.finra.org/investors/professional-designations/gfs

National Association of Insurance and Financial Advisors. (2018, August 15). History. Retrieved from National Association of Insurance and Financial Advisors: https://www.naifa.org/about-naifa/history

The American College. (2018, August 15). ACCREDITATION & STUDENT OUTCOMES. Retrieved from The American College: https://www.theamericancollege.edu/about-the-college/accreditation

Trone, D., Branham, S., & Wattman, M. (2015, August 15). In LeaderMetrics. 3ethos. Retrieved from 3Ethos: http://3ethos.com/#founders

Trone, D., Branham, S., & Wattman, M. (2018, August 15). Founders. Retrieved from 3Ethos: http://3ethos.com/#founders

U.S. Department of Health & Human Services. (2018, August 16). The Health Insurance Portability and Accountability Act (HIPAA). Retrieved from U.S. Department of Health & Human Services (HHS.gov): https://www.hhs.gov/hipaa/index.html

U.S. Federal Trade Commission. (2018, August 16). A Summary of Your Rights Under the Fair Credit Reporting Act. Retrieved from Federal Trade Commission: https://www.consumer.ftc.gov/articles/pdf-0096-fair-credit-reporting-act.pdf

University of Maryland University College. (2018, August 15). Accreditation. Retrieved from http://www.umuc.edu/about/accreditation.cfm

University of Maryland University College. (2018, August 15). Academic Programs. Retrieved from Business Administration Bachelor's Degree: http://www.umuc.edu/academic-programs/bachelors-degrees/business-administration-major.cfm