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What We Do
Form ADV Part 3 : Regulations require Registered Investment Advisers to provide Form ADV part 3 also known as “Form CRS” to clients and prospects as of June 30, 2020.
A: My name is Benjamin Lupu and I am a CERTIFIED FINANCIAL PLANNER and own a Registered Investment Advisory firm named Kensington A.M.I. LLC based in Burbank California. The firm is registered with the California Department of Business Oversight (DBO), and submits annual registration documents to the IARD section of FINRA, both of which are Federal agencies that oversee investment businesses. Our firm is not a brokerage, it is an advisory and asset management business.
Question: What is your relevant experience and what licenses do you hold?
A; Benjamin Lupu CFP has been employed as an investment professional continuously since 1979. He is licensed as a CERTIFIED FINANCIAL PLANNER and a Registered Investment Adviser. Benjamin Lupu CFP has long experience in advising clients in every aspect of Financial Planning and Investment Management.
B: Simple tools that are free to the public are available at Investor.gov/CRS which provides educational materials about investment advisers, broker-dealers and investing topics. You may also reference FINRA.gov for more information.
2: Relationship and Services:
A: Question: What investment services and advice can you provide me?
B: Answer: We offer investment management services, where we manage assets for your benefit in your account according to your needs. We have discretionary and non-discretionary account choices, which means you can choose whether we make transactions for you without asking you first, (discretionary), or need to ask your approval before making transactions (non-discretionary.) Discretionary authority means we determine what transactions are in your best interest and proceed with them according to the investment plan we agree upon before we make any transactions for you. We do not impose any minimum account balances. Investment recommendations and transactions are made with the client’s best interest as the paramount objective, above all other considerations. We also offer holistic Financial Planning Services that assist you with most or all aspects of your financial life.
C: Monitoring: We monitor the specifics that pertain to the progress of your investments each business day and keep up to date as to what needs to be done in your best interest.
1) “Given my financial situation, should I choose an investment advisory service?” Why or why not? “How will you choose investments for me?
2) “What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean?”
3: Fees, Costs, Conflicts, and Standard of Conduct Question: What Fees and Costs Will I Pay?
Answer: You will pay an annual management fee for investment advisory and management services. You will pay fees whether you make or lose money. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. We will agree in writing on the amount of fees before you invest any money. These fees range between 0.5% and 1.5% of total account value per year. The fees are deducted in increments of 25% of the total annual fee, deducted from your account in mid-January, April July and October. Some mutual funds and exchange traded funds also charge internal fees. These additional costs will be described to you. If you want Financial Planning services without investment management services, we will agree in writing before we start on a set fee for Financial Planning services or agree on an hourly fee for Financial Planning, whichever works best for you.
Question: What about conflicts of interest?’’
Answer: There are no direct or intended conflicts of interest at our firm. We do better when you do better and when you make less , we make less. There may be incidental conflicts such as: the more assets there are in a retail investor’s advisory account, the more a retail investor may pay in fees, and the firm may therefore have an incentive to encourage the retail investor to increase the assets in his or her account.
Conversation starters: “Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?”
“What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have?”
Answer: When we act as your investment adviser, we must act in your best interest and not put our interest ahead of yours. This is called “Fiduciary” responsibility. At the same time, the way we make money may create some conflicts with your interests. You should understand these potential conflicts and ask us about them because they can affect the investment advice we provide you. Here are some examples to help you understand what this means:
Example1: Your account value goes up and you make money, though the management fee percentage may stay the same, the total money you pay goes up proportionately. Example 2: Your account value goes down, but you still must pay a management fee.
More information about this is available in document ADV Part 2, 2A and 2B which is provided for you.
Description of How Financial Professionals Make Money: If you deal with a broker (we are not a broker, we are an advisory firm) you pay commissions, which means you must pay a commission every time you make a transaction, even if you lose money on the transaction. If you pay fees, you pay an annual or interim fee, even if you lose money. Some financial professionals get both commissions and fees. In some cases, some financial professionals can get extra payments from mutual funds, insurance companies and other parties to offer incentives to sell more investments.
We are fee only, which means the only money we make is from investment management and/or Financial Planning fees. We will give you a fee-rate sheet for asset management and/or financial planning so you know the cost of services before we do anything for you. We do not earn any commissions or any other payments from anyone. The more money we manage, the more money we make. If you pay hourly fees, the more hours we work, the more money we make.
4: Disciplinary History: “Do you or your financial professionals have legal or disciplinary history?”
Answer: NO. Neither Benjamin Lupu CFP or Kensington A.M.I. LLC have any disciplinary history and are in good standing with regulators. See Investor.gov/CRS .
Conversation Starter: “As a financial professional, do you have any disciplinary history? For what type of conduct?”
5: Additional Information: If you wish for more information on the Relationship Summary, please contact our office at 818.333.5318.
Conversation Starter: “Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?