Taxes are Overrated™
Firm Brochure
Firm Brochure
(Part 2A and 2B of Form ADV)
Annual Privacy Policy Notice
2390 E Camelback Rd #130
Phoenix, Arizona 85016
410-336-6118
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
Investment Management Agreement
Non-Asset based fees/ Annual Service Fees
Past Due Accounts and Termination of Agreement
Other Financial Industry Activities and Affiliations
Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Participation or Interest in Client Transactions
Selecting other service providers
Client Referrals and Other Compensation
Discretionary Authority for Trading
State Required Information: Executive Experience
ADV 2B: Seth
Aaron Rosenberg 6414032
Educational Background and Business Experience
Designation and Degree information
Requirements for State-Registered Advisors
Additional Documents and Resources
Ability First Financial, LLC. Privacy Policy
Ability First Financial Solutions, LLC (Fiduciary
Policy)
Ability First Financial Is a Fiduciary
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 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
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.
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.
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.
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.
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.
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