DISCLOSURES
ADV 2A
Item 1 Cover Page
FUSION FAMILY WEALTH, LLC
SEC File # 801-78339

ADV Part 2A, Brochure
Dated: March 2, 2026
Contact: Brett Stanton, Chief Compliance Officer
88 Froehlich Farm Boulevard, Suite 401, Woodbury, New York 11797 B.Stanton@FusionFamilyWealth.com
(516) 206-1320
www.FusionFamilyWealth.com
This Brochure provides information about the qualifications and business practices of Fusion Family
Wealth, LLC (the “Registrant”). If you have any questions about the contents of this Brochure,
please contact us at BStanton@FusionFamilyWealth.com or (516) 206-1320. 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.
Additional information about Fusion Family Wealth, LLC also is available on the SEC’s website at
www.adviserinfo.sec.gov.
References herein to Fusion Family Wealth, LLC as a “registered investment adviser” or any
reference to being “registered” does not imply a certain level of skill or training.
Item 2 Material Changes
There have been no material changes made to this Disclosure Brochure since the last annual
amendment filing on February 14ᵗʰ, 2025.
ANY QUESTIONS: The Registrant’s Chief Compliance Officer, Brett Stanton, remains available to
address any questions regarding this Form ADV Part 2A, including the disclosure additions and
enhancements below.
Item 3 Table of Contents
Item 1 Cover
Page................................................................................................
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Item 2 Material Changes
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Item 3 Table of
Contents............................................................................................
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Item 4 Advisory Business
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Item 5 Fees and Compensation
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Item 6 Performance-Based Fees and Side-by-Side Management
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Item 7 Types of
Clients.............................................................................................
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Item 8 Methods of Analysis, Investment Strategies and Risk of
Loss................................................... 14
Item 9 Disciplinary Information
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Item 10 Other Financial Industry Activities and Affiliations
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Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading.............. 18
Item 12 Brokerage Practices
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Item 13 Review of
Accounts............................................................................................
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Item 14 Client Referrals and Other Compensation
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Item 15
Custody.............................................................................................
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Item 16 Investment
Discretion..........................................................................................
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Item 17 Voting Client
Securities..........................................................................................
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Item 18 Financial Information
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Item 4 Advisory Business
A. Fusion Family Wealth, LLC (the “Registrant”) is a Delaware limited liability company, which has
been registered as an Investment Adviser with the United States Securities and Exchange Commission
on July 25, 2013. The Registrant is principally owned by Fusion Family Wealth Holdings, LLC. That
entity is principally owned by FFW, Legacy, LLC, which is principally owned by Jonathan Blau, who
also serves as the Registrant’s sole Member and Chief Executive Officer.
B. As discussed below, the Registrant offers investment advisory services and retirement plan
consulting services to its clients (generally comprised of individuals, high net worth individuals,
related trusts and estates, pension, and profit-sharing plans, etc.).
INVESTMENT ADVISORY SERVICES
The client can engage the Registrant to provide discretionary or non-discretionary investment
advisory services. The Registrant’s annual investment advisory fee is based upon a percentage (%)
of the market value of the assets placed under the Registrant’s management. Before engaging the
Registrant to provide investment advisory services, clients are required to enter into an
Investment Advisory Agreement with Registrant setting forth the terms and conditions of the
engagement (including termination), describing the scope of the services to be provided, and the
fee that is due from the client. Registrant’s annual investment advisory fee shall include
investment advisory services, and, to the extent specifically requested by the client and accepted
by the Registrant, financial planning and consulting services. If Registrant determines in its sole
discretion that the client requires extraordinary planning and/or consultation services, the
Registrant may seek to charge for such additional services pursuant to a stand-alone Financial
Planning Agreement as further described below.
Registrant provides investment advisory services specifically tailored to the needs of each client.
Before providing investment advisory services, an investment adviser representative will ascertain
each client’s investment objectives and develop an asset allocation based on a defined investment
policy statement that focuses on client’s investment objectives, time horizon, and risk tolerance.
Once client investment assets are allocated, the Registrant provides ongoing monitoring and review
of account performance and asset allocation as compared to client-designated investment objectives
and may execute or recommend execution of account transactions as a result of those reviews or
based on other triggering events. The advisor may retain certain types of investments from the
Client’s legacy portfolio due to the fit with the overall portfolio strategy, tax-related reasons,
or other reasons as identified between the Registrant and the Client.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
To the extent specifically requested by a client, the Registrant may determine to provide financial
planning and/or consulting services (including investment and non-investment related matters,
including estate planning, insurance planning, etc.) on a stand-alone separate fee basis.
Registrant’s planning and consulting fees are negotiable, depending upon the level and scope of the
service(s) required and the professional(s) rendering the service(s). Before engaging the
Registrant to provide planning or consulting services, clients are generally required to enter into
a Financial Planning and Consulting Agreement with Registrant setting forth the terms and
conditions of the engagement (including termination), describing the scope of the services to be
provided, and the portion of the fee that is due from the client before Registrant commences services. If requested by the client,
Registrant may recommend the services of other professionals for implementation purposes (i.e.,
attorney, accountant, insurance agent, etc.), including professionals who serve as a promoter for
the Registrant-see disclosure at Item 14 below. The client is under no obligation to engage the
services of any such recommended professional. At all times, the engaged licensed professionals
(i.e., attorney, accountant, insurance agent, etc.), and not Registrant, shall be responsible for
the quality and competency of the services provided. The client retains absolute discretion over
all such implementation decisions and is free to accept or reject any recommendation from the
Registrant.
ERISA PLAN and 401(k) INDIVIDUAL ENGAGEMENTS:
• Trustee Directed Plans. Registrant may be engaged to provide discretionary investment advisory
services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the
investment objective designated by the Plan trustees. In such engagements, Registrant will serve as
an investment fiduciary as that term is defined under The Employee Retirement Income Security Act
of 1974 (“ERISA”). Registrant will generally provide services on an “assets under management” fee
basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the
Firm.
• Participant Directed Retirement Plans. Registrant may also provide investment advisory and
consulting services to participant directed retirement plans per the terms and conditions of a
Retirement Plan Services Agreement between Registrant and the plan. For such engagements,
Registrant shall assist the Plan sponsor with the selection of an investment platform from which
Plan participants shall make their respective investment choices (which may include investment
strategies devised and managed by Registrant), and, to the extent engaged to do so, may also
provide corresponding education to assist the participants with their decision-making process.
• Client Retirement Plan Assets. If requested to do so, Registrant shall provide investment
advisory services relative to the client’s 401(k) plan assets. In such event, Registrant shall
recommend that the client allocate the retirement account assets among the investment options
available on the 401(k) platform. The client is exclusively responsible for making all
transactions. Registrant’s ability shall be limited to making recommendations regarding the
allocation of the assets among the investment alternatives available through the plan. Registrant
will not receive any communications from the plan sponsor or custodian, and it shall remain the
client’s exclusive obligation to notify Registrant of any changes in investment alternatives,
restrictions, etc. pertaining to the retirement account.
MISCELLANEOUS
Limitations of Non-Investment Consulting/Implementation Services. To the extent requested by a
client, Registrant may provide financial planning and related consulting services regarding
non-investment related matters, such as estate planning, tax planning, insurance, etc. The
Registrant does not serve as a law firm, accounting firm, or insurance agency, and no portion of
Registrant’s services should be construed as legal, accounting, or insurance implementation
services. Accordingly, Registrant does not prepare estate planning documents, tax returns, or sell
insurance products. To the extent requested by a client, Registrant may recommend the services of
other professionals for certain non-investment implementation purposes (i.e., attorneys,
accountants, insurance agents, etc.), which may include professionals who serve as a promoter for
the Registrant-see disclosure at Item 14 below. Clients are reminded that they are under no
obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by Registrant or its representatives. Please Note: If the client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client should seek recourse exclusively from and
against the engaged professional. At all times, the engaged licensed professionals (i.e., attorney,
accountant, insurance agent, etc.), and not Registrant, shall be responsible for the quality and
competency of the services provided. Please Note: Registrant will generally provide such planning
and consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could
occur based upon assets under management, special projects, stand-alone planning engagements, etc.
for which Firm may charge a separate or additional fee). Registrant believes that it is important
for the client to address financial planning issues with the Registrant on an ongoing basis.
Registrant’s fee, as set forth at Item 5 below, will remain the same regardless of whether or not
the client determines to address planning issues with Registrant. Registrant remains available to
address planning issues with the client on an ongoing basis.
Wealth Advisor Growth Network. Registrant’s indirect minority shareholder, Merchant Wealth
Partners, LLC, maintains a minority ownership interest in Wealth Advisor Growth Network (“WAGN”), a
company that offers consulting and support services to independent wealth management firms. Fusion
has engaged a service provider (LibertyFi LLC, an advisory industry technology and administrative
services support provider) that compensates WAGN for introductions. Fusion’s Chief Compliance
Officer, Brett Stanton, remains available to address any questions that such arrangements may
create, including conflicts of interest.
Investment Risk. Different types of investments involve varying degrees of risk, and it should not
be assumed that future performance of any specific investment or investment strategy (including the
investments and/or investment strategies recommended or undertaken by Registrant) will be
profitable or equal any specific performance level(s).
Client Obligations. In performing its services, Registrant shall not be required to verify any
information received from the client or from the client’s other professionals and is expressly
authorized to rely thereon. Moreover, each client is advised that it remains their responsibility
to promptly notify the Registrant if there is ever any change in their financial situation or
investment objectives for the purpose of reviewing, evaluating, or revising Registrant’s previous
recommendations and/or services.
Disclosure Brochure. A copy of this Brochure shall be provided to each client prior to, or
contemporaneously with, the execution of the applicable form of client agreement.
Non-Discretionary Service Limitations. Clients that determine to engage Registrant on a
non-discretionary investment advisory basis must be willing to accept that Registrant cannot affect
any account transactions without obtaining prior consent to such transaction(s) from the client.
Thus, in the event that Registrant would like to make a transaction for a client’s account
(including in the event of an individual holding or general market correction), and the client is
unavailable, the Registrant will be unable to affect the account transaction(s) (as it would for
its discretionary clients) without first obtaining the client’s consent. This could place affected
accounts at a disadvantage.
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Registrant will review
client portfolios on an ongoing basis to determine if any changes are necessary based upon various
factors, including, but not limited to, investment performance, market conditions, fund manager
tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment
objective. Based upon these factors, there may be extended periods of time when Registrant
determines that changes to a client’s portfolio are neither necessary, nor prudent. The advisory
fees described in Item 5 below remain due and payable during periods of account inactivity.
Asset Aggregation / Reporting Services. Registrant may provide access to reporting services through
one or more third-party aggregation / reporting platforms that can reflect all of the client’s
investment assets, including those investment assets that the client has not engaged the Registrant
to manage (the “Excluded Assets”). Registrant’s service for the Excluded Assets is strictly limited
to reporting and specifically excludes investment management or implementation. Because Registrant
does not have trading authority for the Excluded Assets, the client (and/or another investment
professional), and not Registrant, will be exclusively responsible for directly implementing any
recommendations for the Excluded Assets. Please refer to Item 5 below with respect to the
additional reporting fee that clients may incur for the Excluded Assets. Further, the client and/or
their other advisors that maintain trading authority, and not Registrant, shall be exclusively
responsible for the investment performance or related activity (such as timing and trade errors)
pertaining to the Excluded Assets. The third-party aggregation / reporting platforms may also
provide access to financial planning information and applications, which should not be construed as
services, advice, or recommendations provided by Registrant. Accordingly, Registrant shall not be
held responsible for any adverse results a client may experience if the client engages in financial
planning or other functions available on the third-party reporting platforms without Registrant’s
participation or oversight.
Availability of Mutual Funds and Exchange Traded Funds. While the Registrant may allocate
investment assets to mutual funds and exchange traded funds (“ETFs”) that are not available
directly to the public, the Registrant may also allocate investment assets to publicly available
mutual funds and ETFs that the client could purchase without engaging Registrant as an investment
adviser. However, if a client or prospective client determines to purchase publicly available
mutual funds or ETFs without engaging Registrant as an investment adviser, the client or
prospective client would not receive the benefit of Registrant’s initial and ongoing investment
advisory services with respect to management of the asset. In addition to Registrant’s investment
advisory fee described below, and transaction and/or custodial fees discussed below, clients will
also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the
fund level (e.g., management fees and other fund expenses).
Cybersecurity Risk. The information technology systems and networks that Registrant and its
third-party service providers use to provide services to Registrant’s clients employ various
controls that are designed to prevent cybersecurity incidents stemming from intentional or
unintentional actions that could cause significant interruptions in Registrant’s operations and/or
result in the unauthorized acquisition or use of clients’ confidential or non-public personal
information. Clients and Registrant are nonetheless subject to the risk of cybersecurity incidents
that could ultimately cause them to incur financial losses and/or other adverse consequences.
Although Registrant has established processes to reduce the risk of cybersecurity incidents, there
is no guarantee that these efforts will always be successful, especially considering that
Registrant does not directly control the cybersecurity measures and policies employed by
third-party service providers, issuers or securities, broker-dealers, qualified custodians, governmental and other regulatory authorities,
exchanges and other financial market operators and providers.
Artificial Intelligence. The Registrant may use certain Artificial Intelligence (“AI”) tools in
connection with its investment advisory services. The Registrant has adopted an AI Policy that
governs the appropriate use of AI tools to ensure that the Registrant and its employees abide by
their fiduciary duty and comply with all applicable regulations. AI tools are not used by the
Registrant as a substitute for professional judgment by the Registrant or its employees, and all AI
generated output is reviewed by the Registrant for accuracy. All investment decisions and
recommendations are made and approved by the Registrant. The use of AI tools does not guarantee the
accuracy of analyses or the success of any investment strategy. Clients should not assume that
reliance on AI tools results in better performance or reduces risk. AI tools involve limitations
and risks. These risks include, but are not limited to, data security concerns, potential
inaccuracies, and possible algorithmic biases. To mitigate these risks, the Registrant has
implemented controls such as pre-approval requirements for AI tools, restrictions on providing
nonpublic personal information to public AI systems, vendor due diligence, review of AI-generated
materials, and employee training on appropriate AI usage.
Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client
leaving an employer typically has four options regarding an existing retirement plan (and may
engage in a combination of these options): (i) leave the money in the former employer’s plan, if
permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers
are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the
account value (which could, depending upon the client’s age, result in adverse tax consequences).
If Registrant recommends that a client roll over their retirement plan assets into an account to be
managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn
new (or increase its current) compensation as a result of the rollover. If Registrant provides a
recommendation as to whether a client should engage in a rollover or not (whether it is from an
employer’s plan or an existing IRA), Registrant is acting as a fiduciary within the meaning of
Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. No client is under any obligation to roll
over retirement plan assets to an account managed by Registrant, whether it is from an employer’s
plan or an existing IRA. Registrant’s Chief Compliance Officer, Brett Stanton, remains available to
address any questions that a client or prospective client may have regarding the potential for
conflict of interest presented by such rollover recommendation.
Independent Managers. The Registrant may allocate (and/or recommend that the client allocate) a
portion of a client’s investment assets among unaffiliated independent investment managers /
separately managed account platforms (“Independent Manager(s)”) in accordance with the client’s
designated investment objectives according to the terms and conditions of a separate agreement
between the client and the Independent Manager(s). In such situations, the Independent Manager(s)
shall have day-to-day responsibility for the active discretionary management of the allocated
assets. The Registrant shall continue to render investment advisory services to the client relative
to the ongoing monitoring and review of account performance, asset allocation and client investment
objectives. The Registrant generally considers the following factors when considering its
recommendation to allocate investment assets to Independent Manager(s): the client’s designated
investment objectives, management style, performance, reputation, financial strength, reporting,
pricing, and research. The annual investment management fee charged by the Independent Manager(s)
can range from 0.17% to 0.53% of the assets allocated to the Independent
occurs, to help mitigate the corresponding yield dispersion, Fusion shall (usually within 30 days
thereafter) generally (with exceptions) purchase a higher yielding money market fund available on
the custodian’s platform, unless Fusion reasonably anticipates that it will utilize the cash
proceeds during the subsequent 30-day period to purchase additional investments for the client’s
account. Exceptions and/or modifications can and will occur with respect to all or a portion of the
cash balances for various reasons, including, but not limited to the amount of dispersion between
the sweep account and a money market fund, the size of the cash balance, an indication from the
client of an imminent need for such cash, or the client has a demonstrated history of writing
checks from the account. Please Note: The above does not apply to the cash component maintained
within a Fusion actively managed investment strategy (the cash balances for which shall generally
remain in the custodian designated cash sweep account), assets allocated to an unaffiliated
investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The
client shall remain exclusively responsible for yield dispersion/cash balance decisions and
corresponding transactions for cash balances maintained in any Fusion unmanaged accounts. ANY
QUESTIONS: Fusion’s Chief Compliance Officer, Brett Stanton, remains available to address any
questions that a client or prospective client may have regarding the above.
Unaffiliated Private Investment Funds.
Registrant does not recommend that its clients purchase private investment funds. However, the
Registrant will assist the client with the purchase of same upon express request. Upon such
request, the Registrant, on a non-discretionary basis, shall present prospective private funds to
the client for the client’s review and consideration. Registrant’s role relative to unaffiliated
private investment funds shall be limited to its initial and ongoing review and investment
monitoring services. If a client determines to become an unaffiliated private fund investor, the
amount of assets invested in the fund(s) shall be included as part of “assets under management” for
purposes of Registrant calculating its investment advisory fee. Registrant’s fee shall be in
addition to the fund’s fees. Registrant’s clients are under absolutely no obligation to consider or
make an investment in any private investment fund(s).
Please Note: Private investment funds generally involve various risk factors, including, but not
limited to, potential for complete loss of principal, liquidity constraints and lack of
transparency, a complete discussion of which is set forth in each fund’s offering documents, which
will be provided to each client for review and consideration. Unlike liquid investments that a
client may own, private investment funds do not provide daily liquidity or pricing. Each
prospective client investor will be required to complete a Subscription Agreement, pursuant to
which the client shall establish that the client is qualified for investment in the fund and
acknowledges and accepts the various risk factors that are associated with such an investment.
Please Also Note: Valuation. In the event that Registrant references private investment funds owned
by the client on any supplemental account reports prepared by Registrant, the value(s) for all
private investment funds owned by the client shall reflect the most recent valuation provided by
the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated
valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the
fund provides an updated valuation, then the statement will reflect that updated value. The updated
value will continue to be reflected on the report
until the fund provides a further updated value. Please Also Note: As result of the valuation
process, if the valuation reflects initial purchase price or an updated value subsequent to
purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more
or less than the value reflected on the report. Unless otherwise indicated, Registrant shall
calculate its fee based upon the latest value provided by the fund sponsor.
Conflict of Interest: To assist with identifying funds for the client’s review and consideration,
the Registrant shall use the private fund due diligence and platform services provided by Opto
Investments (“Opto”). Registrant’s minority shareholder, Merchant Wealth Partners, LLC
(“Merchant”), maintains a minority ownership interest in Opto, thereby creating a potential
conflict of interest (i.e., Opto will derive compensation from private funds that are available on
its platform). ANY QUESTIONS: Registrant’s Chief Compliance Officer, Brett Stanton, remains
available to address any questions regarding Opto and the above referenced conflict of interest.
Cash Positions. Registrant continues to treat cash as an asset class. As such, unless determined to
the contrary by Registrant, all cash positions (money markets, etc.) shall continue to be included
as part of assets under management for purposes of calculating Registrant’s advisory fee. At any
specific point in time, depending upon perceived or anticipated market conditions/events (there
being no guarantee that such anticipated market conditions/events will occur), Registrant may
maintain cash positions for defensive purposes. In addition, while assets are maintained in cash,
such amounts could miss market advances. Depending upon current yields, at any point in time,
Registrant’s advisory fee could exceed the interest paid by the client’s money market fund. ANY
QUESTIONS: The Registrant’s Chief Compliance Officer, Brett Stanton, remains available to address
any questions that a client or prospective may have regarding the above fee billing practice.
Borrowing Against Assets/Risk. A client who has need to borrow money could determine to do so by
using:
• Margin – The account custodian or broker-dealer lends money to the client. The custodian charges
the client interest for the right to borrow money, and uses the assets in the client’s brokerage
account as collateral; and
• Pledged Assets Loan – In consideration for a lender (i.e., a bank, etc.) to make a loan to the
client, the client pledges its investment assets held at the account custodian as collateral;
These above-described collateralized loans are generally utilized because they typically provide
more favorable interest rates than standard commercial loans. These types of collateralized loans
can assist with a pending home purchase, permit the retirement of more expensive debt, or enable
borrowing in lieu of liquidating existing account positions and incurring capital gains taxes.
However, such loans are not without potential material risk to the client’s investment assets. The
lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in
the event of loan default or if the assets fall below a certain level. For this reason, Fusion does
not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to
purchase a new residence). Fusion does not recommend such borrowing for investment purposes (i.e.,
to invest borrowed funds in the market). Regardless, if the client was to determine to utilize
margin or a pledged assets loan, the following economic benefits would inure to Fusion:
• By taking the loan rather than liquidating assets in the client’s account,
Fusion continues to earn a fee on such Account assets; and,
• If the client invests any portion of the loan proceeds in an account to be managed by Fusion,
Fusion will receive an advisory fee on the invested amount; and,
• If Fusion’s advisory fee is based upon the higher margined account value, Fusion will earn a
correspondingly higher advisory fee. This could provide Fusion with a disincentive to encourage the
client to discontinue the use of margin.
Please Note: The client must accept the above risks and potential corresponding consequences
associated with the use of margin or a pledged assets loan.
C. The Registrant provides investment advisory services specific to the needs of each client.
Before providing investment advisory services, an investment adviser representative will ascertain
each client’s investment objectives. Thereafter, the Registrant shall allocate and/or recommend
that the client allocate investment assets consistent with the designated investment objective(s).
The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s
services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2025, the Registrant had $1,441,403,309 in Client assets,
$1,425,894,758 of which are managed on a discretionary basis and $15,508,551 on a non-discretionary
basis. Clients may request more current information at any time by contacting the Registrant.
Item 5 Fees and Compensation
A. Registrant offers its services on a fee basis, meaning that clients pay an annual fee based upon
assets under management and/or advisement as described below.
INVESTMENT ADVISORY SERVICES
If a client chooses to engage the Registrant to provide discretionary and/or non-discretionary
investment advisory services on a negotiable fee basis, the Registrant’s annual investment advisory
fee shall be generally based upon a percentage (%) of the market value of assets under management
according to the following fee schedule:
Market Value of Portfolio Annual Fee*
Under $3,000,000 1.10%
Over $3,000,000 but less than $10,000,000 0.95%
Above $10,000,000 0.80%
Client accounts will be aggregated by household for billing purposes to achieve the lowest possible
pricing. The annual investment advisory fee is billed on a quarterly basis, in advance (except for
Participant Directed Retirement Plans, which are billed in arrears), based upon the market value of
the assets on the last day of the previous quarter. If assets in excess of $10,000 are deposited
into or withdrawn from an account after the inception of a billing period, the fee payable with
respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial period of an engagement, the fee is calculated
on a pro rata basis.
*Where applicable, agreed upon non-managed assets held as part of your portfolio with Fusion Family
Wealth will not be charged any Fusion fee. These non-managed assets will be assessed a reporting
services fee of 0.02% (2 bps).
Independent Manager Fees. Without limiting the above, the annual investment management fee charged
by Independent Manager(s) to the client can range from 0.17% to 0.53% of the assets allocated to
the Independent Manager(s). Fees for equity managers are generally higher than those for fixed
income managers. The applicable advisory fee charged by the Independent Manager(s), any related
platform fee, “SMA” fee, “UMA” fee, “TAMP” fee, or similarly named fee is separate from, and in
addition to, the Registrant’s investment advisory fee as set forth above.
Fee Dispersion. Registrant, in its discretion, may charge a lesser investment advisory fee, waive
its asset minimum, charge a flat fee, waive its fee entirely, or charge a fee on a different
interval, based upon certain criteria (i.e. anticipated future earning capacity, anticipated future
additional assets, dollar amount of assets to be managed, related accounts, account composition,
complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules,
employees and family members, courtesy accounts, competition, negotiations with client, etc.). As
result of the above, similarly situated clients could pay different fees. In addition, similar
advisory services may be available from other investment advisers for similar or lower fees.
Fee Level Adjustment. Registrant’s annual fee generally decreases at the asset levels described
above (over $3 million and over $10 million). Correspondingly, if the client’s managed assets fall
below those agreed levels, Registrant’s annual fee will increase. If the asset level changes occur
during any billing quarter, there will be no interim intra-quarter fee adjustments. Rather, the fee
shall be adjusted as of the beginning of the following initial full billing quarter.
Reporting Services Fee. Clients who choose to receive reporting services for investment assets that
the client has not engaged the Registrant to manage (the “Excluded Assets”) will incur an
additional annual reporting services fee of $80/Yodlee account for the Excluded Assets.
ANY QUESTIONS: Registrant’s Chief Compliance Officer, Brett Stanton, remains available to address
any questions that a client or prospective client may have regarding advisory fees.
RETIREMENT ACCOUNTS
For new clients that engage the Registrant’s services, effective March 1, 2021, assets maintained
by the client in their employer sponsored retirement plan shall be included for purpose of
Registrant calculating its quarterly fee per the fee schedule set forth at Item 5 above. However,
if the client advises the Registrant, in writing, that it does not desire for the Registrant to
provide advisory services for the client’s employer sponsored retirement plan, such assets shall
not be included for Registrant’s fee billing purposes. At no time shall the Registrant maintain the
client’s password for such retirement accounts, and it will be the client’s exclusive obligation to
implement the Registrant’s recommendations.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
To the extent specifically requested by a client, the Registrant may determine to provide financial
planning and/or consulting services (including investment and non-investment related matters,
including estate planning, insurance planning, etc.) on a stand-alone fee basis. Registrant’s
planning and consulting fees are negotiable but are generally charged at a rate of $300 per hour,
depending upon the level and scope of the service(s) required and the professional(s) rendering the
service(s).
RETIREMENT PLAN CONSULTING SERVICES
If a participant directed retirement plan sponsor client chooses to engage the Registrant to
provide retirement plan consulting services, Registrant’s annual fee for these services ranges from
20bps to 35bps based on the value of plan’s assets on the last day of the previous quarter payable
quarterly, in arrears.
B. Clients may elect to have the Registrant’s investment advisory fees and retirement plan
consulting fees deducted from their custodial account. Registrant’s Investment Advisory Agreement,
Retirement Plan Services Agreement, and the applicable custodial/clearing agreement may authorize
the custodian to debit the account for the amount of the Registrant’s investment advisory fee and
to directly remit that fee to the Registrant in compliance with regulatory procedures. In the
limited event that the Registrant bills the client directly for those services, payment is due upon
receipt of the Registrant’s invoice. The Registrant shall deduct investment advisory fees and
retirement plan consulting fees
C. As discussed below, unless the client directs otherwise or an individual client’s circumstances
require, the Registrant shall generally recommend that Fidelity Institutional Wealth Services, an
SEC-registered and FINRA member broker dealer (“Fidelity”), and/or Pershing Advisor Solutions, LLC
an SEC-registered and FINRA member broker dealer serve as the broker-dealer/custodian for client
investment advisory assets. Broker-dealers such as Fidelity and Pershing charge brokerage
commissions, transaction, and/or other type fees for effecting certain types of securities
transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and
mark-downs charged for fixed income transactions, etc.). The types of securities for which
transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall
differ depending upon the broker-dealer/custodian (while certain custodians do not currently charge
fees on individual equity transactions (including ETFs), others do). Currently, neither Fidelity
nor Pershing charges transaction fees for individual equity transactions (including ETFs), with the
exception that Fidelity will charge a transaction fee of $0.01 per share for equity transactions in
excess of 10,000 shares. Pershing will also assess fees to clients who elect to receive account
statements by regular mail rather than electronically. Pershing currently charges $2 per hard copy
statement. In addition to Registrant’s investment advisory fee, brokerage commissions and/or
transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund
(“ETF”) purchases, charges imposed at the fund level (e.g. management fees and other fund
expenses). Clients (to the extent applicable to their account assets), can also incur deferred
sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees and
other fees and taxes on brokerage accounts and securities transactions, advisory fees imposed by
Independent Manager(s) (including any related platform fee, “SMA” fee, “UMA” fee, “TAMP” fee, or
similarly-named fee). Registrant does not receive any portion of these fees/charges. ANY QUESTIONS:
The Registrant’s Chief Compliance Officer, Brett Stanton, remains available to address any
questions regarding fees to be incurred by the client.
D. The Registrant’s annual investment advisory fee shall be prorated and paid quarterly in advance,
based upon the market value of the assets on the last day of the previous quarter. The Registrant’s
annual retirement plan consulting fee shall be prorated and paid quarterly in arrears, based upon
the market value of the assets on the last day of the previous quarter. The applicable form of
agreement between the Registrant and the client will continue in effect until terminated by either
party in conformity with the terms of such agreement. Upon termination of such agreement, the
Registrant shall, based upon the type of account:
(1) retirement plans bill the client or debit the account for the pro-rated portion of the unpaid
advisory fee based upon the number of days those services were provided during the billing quarter;
or, (2) all other types of accounts refund the pro-rated portion of the advanced advisory fee paid
based upon the number of days remaining in the billing quarter, as applicable. ANY QUESTIONS: The
Registrant’s Chief Compliance Officer, Brett Stanton, remains available to address any questions
regarding fees to be incurred by the client.
E. Neither the Registrant, nor its representatives accept compensation from the sale of securities
or other investment products.
Item 6 Performance-Based Fees and Side-by-Side Management
Neither the Registrant nor any supervised person of the Registrant accepts performance-based fees.
Item 7 Types of Clients
The Registrant’s clients generally include individuals, high net worth individuals, related trusts
and estates, pension, and profit-sharing plans. The Registrant generally requires a $5 million
aggregate asset minimum for investment advisory services. The Registrant, in its sole discretion,
may reduce its minimum asset preference based upon certain criteria (i.e., anticipated future
earning capacity, anticipated future additional assets, dollar amount of assets to be managed,
related accounts, account composition, negotiations with client, etc.). Please also refer to Item 5
above with respect to “Fee Dispersion.”
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
A. The Registrant may utilize the following methods of security analysis:
• Fundamental - (analysis performed on historical and present data, with the goal of making
financial forecasts);
• Technical – (analysis performed on historical and present data, focusing on price and trade
volume, to forecast the direction of prices); and/or
• Cyclical – (analysis performed on historical relationships between price and market trends, to
forecast the direction of prices).
The Registrant may utilize the following investment strategies when implementing investment advice
given to clients:
• Long Term Purchases (securities held at least a year);
• Short Term Purchases (securities sold within a year); and/or
• Margin Transactions (use of borrowed assets to purchase financial instruments) 14
Investment Risk. Past performance does not guarantee future results. Investing in securities
involves risk of loss that clients should be prepared to bear, including the complete loss of
principal investment. Different types of investments involve varying degrees of risk, and it should
not be assumed that future performance of any specific investment or investment strategy (including
the investments and/or investment strategies recommended or undertaken by the Registrant) will be
profitable or equal any specific performance level(s). While markets may increase and client
account values could benefit as a result, it is also possible that markets may decrease, and such
account values could suffer a loss. It is therefore important that clients understand investment
risks, diversification strategies, and ask Registrant any questions they may have before making any
investment decisions.
B. The Registrant’s methods of analysis and investment strategies do not present any significant or
unusual risks. However, every method of analysis has its own inherent risks. To perform an accurate
market analysis the Registrant must have access to current/new market information. The Registrant
has no control over the dissemination rate of market information; therefore, unbeknownst to the
Registrant, certain analyses may be compiled with outdated market information, severely limiting
the value of the Registrant’s analysis. Furthermore, an accurate market analysis can only produce a
forecast of the direction of market values. There can be no assurances that a forecasted change in
market value will materialize into actionable and/or profitable investment opportunities.
The Registrant’s primary investment strategies (Long-Term Purchases and Short-Term Purchases) are
fundamental investment strategies. However, every investment strategy has its own inherent risks
and limitations. For example, longer term investment strategies require a longer investment time
period to allow for the strategy to potentially develop. Shorter term investment strategies require
a shorter investment time period to potentially develop but, as a result of more frequent trading,
may incur higher transactional costs when compared to a longer-term investment strategy.
C. Registrant recommends asset allocations based on a particular client’s: economic situation,
liquidity needs, risk tolerance, proposed investment period, need for diversification, reliance
upon current income, present and anticipated tax situation. Registrant also considers historical
yields, potential appreciation, and marketability before making investment recommendations.
Registrant primarily allocates or recommends that clients allocate investment assets among mutual
funds, ETFs, and Independent Managers in accordance with the clients’ designated investment
objectives. To a lesser extent, when consistent with investment objectives, Registrant may also
allocate or recommend that clients allocate investment assets among individual equities (stocks)
and individual bonds. In certain limited circumstances, when consistent with a client’s investment
objectives, the Registrant may also recommend the use of margin transactions.
Each type of investment has its own unique set of risks associated with it. The following provides
a short description of some of the underlying risks associated with the types of investments that
Registrant uses or recommends:
Market Risk. The price of a security may drop in reaction to tangible and intangible events and
conditions. This type of risk may be caused by external factors (such as economic or political
factors) but may also be incurred because of a security’s specific underlying investments.
Additionally, each security’s price can fluctuate based on market movement,
which may or may not be due to the security’s operations or changes in its true value. For example,
political, economic, and social conditions may trigger market events which are temporarily
negative, or temporarily positive.
Unsystematic Risk. Unsystematic risk is the company-specific or industry-specific risk in a
portfolio that the investor bears. Unsystematic risk is typically addressed through
diversification. However, as indicated above, diversification does not guarantee better performance
and cannot eliminate the risk of investment losses.
Value Investment Risk. Value stocks may perform differently from the market as a whole and
following a value-oriented investment strategy may cause a portfolio to underperform growth stocks.
Growth Investment Risk. Prices of growth stocks tend to be higher in relation to their companies’
earnings and may be more sensitive to market, political and economic developments than other
stocks, making their prices more volatile.
Small Company Risk. Securities of small companies are often less liquid than those of large
companies and this could make it difficult to sell a small company security at a desired time or
price. As a result, small company stocks may fluctuate relatively more in price. In general, small
capitalization companies are more vulnerable than larger companies to adverse business or economic
developments and they may have more limited resources.
Commodity Risk. The value of commodity-linked derivative instruments may be affected by changes in
overall market movements, commodity index volatility, changes in interest rates, or factors
affecting a particular industry or commodity, such as drought, floods, weather, livestock disease,
embargoes, tariffs, and international economic, political, and regulatory developments.
Foreign Securities and Currencies Risk. Foreign securities prices may decline or fluctuate because
of: (i) economic or political actions of foreign governments, and/or (ii) less regulated or liquid
securities markets. Investors holding these securities are also exposed to foreign currency risk
(the possibility that foreign currency will fluctuate in value against the U.S. dollar).
Interest Rate Risk. Fixed income securities and fixed income-based securities are subject to
interest rate risk because the prices of fixed income securities tend to move in the opposite
direction of interest rates. When interest rates rise, fixed income security prices tend to fall.
When interest rates fall, fixed income security prices tend to rise. In general, fixed income
securities with longer maturities are more sensitive to these price changes.
Inflation Risk. When any type of inflation is present, a dollar at present value will not carry the
same purchasing power as a dollar in the future, because that purchasing power erodes at the rate
of inflation.
Reinvestment Risk. Future proceeds from investments may have to be reinvested at a potentially
lower rate of return (i.e., interest rate), which primarily relates to fixed income securities.
Credit Risk. The issuer of a security may be unable to make interest payments and/or repay
principal when due. A downgrade to an issuer’s credit rating or a perceived change
in an issuer’s financial strength may affect a security’s value and impact performance. Credit risk
is considered greater for fixed income securities with ratings below investment grade. Fixed income
securities that are below investment grade involve higher credit risk and are considered
speculative.
Call Risk. During periods of falling interest rates, a bond issuer will call or repay a
higher-yielding bond before its maturity date, forcing the investment to reinvest in bonds with
lower interest rates than the original obligations.
Regulatory Risk. Changes in laws and regulations from any government can change the market value of
companies subject to such regulations. Certain industries are more susceptible to government
regulation. For example, changes in zoning, tax structure or laws may impact the return on
investments.
Mutual Fund Risk. Mutual funds are operated by investment companies that raise money from
shareholders and invest it in stocks, bonds, and/or other types of securities. Each fund will have
a manager that trades the fund’s investments in accordance with the fund’s investment objective.
Mutual funds charge a separate management fee for their services, so the returns on mutual funds
are reduced by the costs to manage the funds. While mutual funds generally provide diversification,
risks can be significantly increased if the fund is concentrated in a particular sector of the
market. Mutual funds come in many varieties. Some invest aggressively for capital appreciation,
while others are conservative and are designed to generate income for shareholders. In addition,
the client’s overall portfolio may be affected by losses of an underlying fund and the level of
risk arising from the investment practices of an underlying fund (such as the use of derivatives).
Exchange Traded Fund Risk. ETFs are marketable securities that are designed to track, before fees
and expenses, the performance or returns of a relevant index, commodity, bonds or basket of assets,
like an index fund. Unlike mutual funds, ETFs trade like common stock on a stock exchange. ETFs
experience price changes throughout the day as they are bought and sold. In addition to the general
risks of investing, there are specific risks to consider with respect to an investment in ETFs,
including, but not limited to: (i) an ETF’s shares may trade at a market price that is above or
below its net asset value; (ii) the ETF may employ an investment strategy that utilizes high
leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s
officials deem such action appropriate, the shares are de-listed from the exchange, or the
activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices)
halts stock trading generally.
Margin Transactions. A margin transaction strategy, in which an investor uses borrowed assets to
purchase financial instruments, involves a high level of inherent risk. The investor generally
obtains the borrowed assets by using other securities as collateral for the borrowed sum. The
effect of purchasing a security using margin is to magnify any gains or losses sustained by the
purchase of the financial instruments on margin. Please Note: To the extent that a client
authorizes the use of margin, and margin is thereafter employed by the Registrant in the management
of the client’s investment portfolio, the market value of the client’s account and corresponding
fee payable by the client to the Registrant may be increased. As a result, in addition to
understanding and assuming the additional principal risks associated with the use of margin,
clients authorizing margin are advised of the potential conflict of interest whereby the client’s
decision to employ margin may correspondingly increase the management fee payable to the
Registrant. Accordingly, the decision as to whether to employ margin is left totally to the
discretion of client.
Item 9 Disciplinary Information
The Registrant has not been the subject of a disciplinary action.
Item 10 Other Financial Industry Activities and Affiliations
A. Neither the Registrant, nor its representatives, are registered or have an application pending
to register, as a broker-dealer or a registered representative of a broker-dealer.
B. Neither the Registrant, nor its representatives, are registered or have an application pending
to register, as a futures commission merchant, commodity pool operator, a commodity trading
advisor, or a representative of the foregoing.
C. As indicated above relative to Independent Manager(s), the Registrant recommends or selects
other investment advisors (i.e., Independent Manager(s)) for its clients for which the Registrant
earns an advisory fee.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. The Registrant maintains an investment policy relative to personal securities transactions.
This investment policy is part of Registrant’s overall Code of Ethics, which serves to establish a
standard of business conduct for all of Registrant’s Representatives that is based upon fundamental
principles of openness, integrity, honesty and trust, a copy of which is available upon request.
In accordance with Section 204A of the Investment Advisers Act of 1940 and similar state law, the
Registrant also maintains and enforces written policies reasonably designed to prevent the misuse
of material non-public information by the Registrant or any person associated with the Registrant.
B. Neither the Registrant nor any related person of Registrant recommends, buys, or sells for
client accounts, securities in which the Registrant or any related person of Registrant has a
material financial interest.
C. The Registrant and/or representatives of the Registrant may buy or sell securities that are also
recommended to clients. This practice may create a situation where the Registrant and/or
representatives of the Registrant are in a position to materially benefit from the sale or purchase
of those securities. Therefore, this situation creates a potential conflict of interest. Practices
such as “scalping” (i.e., a practice whereby the owner of shares of a security recommends that
security for investment and then immediately sells it at a profit upon the rise in the market price
which follows the recommendation) could take place if the Registrant did not have adequate policies
in place to detect such activities. In addition, this requirement can help detect insider trading,
“front-running” (i.e., personal trades executed before those of the Registrant’s clients) and other
potentially abusive practices.
The Registrant has a personal securities transaction policy in place to monitor the personal
securities transactions and securities holdings of each of the Registrant’s “Access Persons.” The
Registrant’s securities transaction policy requires that Access Person of the Registrant must
provide the Chief Compliance Officer or his/her designee with a written report of their current
securities holdings within ten (10) days after becoming an Access Person.
Furthermore, Access Persons must provide the Chief Compliance Officer with a quarterly transaction
report, detail all trades in the Access Person’s account during the previous quarter; and on an
annual basis, each Access Person must provide the Chief Compliance Officer with a written report of
the Access Person’s current securities holdings. However, at any time that the Registrant has only
one Access Person, he or she shall not be required to submit any securities report described above.
D. The Registrant and/or representatives of the Registrant may buy or sell securities, at or around
the same time as those securities are recommended to clients. This practice creates a situation
where the Registrant and/or representatives of the Registrant are in a position to materially
benefit from the sale or purchase of those securities. Therefore, this situation creates a
potential conflict of interest. As indicated above in Item 11.C. the Registrant has a personal
securities transaction policy in place to monitor the personal securities transaction and
securities holdings of each of Registrant’s Access Persons.
Item 12 Brokerage Practices
A. In the event that the client requests that the Registrant recommend a broker-dealer/custodian
for execution and/or custodial services (exclusive of those clients that may direct the Registrant
to use a specific broker-dealer/custodian), Registrant generally recommends that investment
advisory accounts be maintained at Fidelity and/or Pershing. Clients are not obligated to use the
recommended custodian and will not incur any extra fee or cost from the Registrant associated with
using a custodian not recommended by the Registrant. Depending on which custodian the client
selects to maintain their accounts, clients may experience differences in customer service,
transaction timing, the availability of sweep account vehicles and money market funds and other
aspects of investing. In certain instances, some of these differences could cause differences in
account performance. Before engaging Registrant to provide investment advisory services, the client
will be required to enter into a formal Investment Advisory Agreement with Registrant setting forth
the terms and conditions under which Registrant shall manage the client’s assets, and a separate
custodial/clearing agreement with each designated broker-dealer/ custodian.
Factors that the Registrant considers in recommending Fidelity and/or Pershing (or any other
broker-dealer/custodian) to clients include historical relationship with the Registrant, financial
strength, reputation, execution capabilities, pricing, research, and service. Although the
commissions and/or transaction fees paid by Registrant’s clients shall comply with the Registrant’s
duty to obtain best execution, a client may pay a commission that is higher than another qualified
broker-dealer might charge to affect the same transaction where the Registrant determines, in good
faith, that the commission/transaction fee is reasonable. In seeking best execution, the
determinative factor is not the lowest possible cost, but whether the transaction represents the
best qualitative execution, taking into consideration the full range of broker-dealer services,
including the value of research provided, execution capability, commission rates, and
responsiveness. Accordingly, although Registrant will seek competitive rates, it may not
necessarily obtain the lowest possible commission rates for client account transactions. The
brokerage commissions or transaction fees charged by the designated broker-dealer/custodian are
exclusive of, and in addition to, Registrant’s investment advisory fee. The Registrant’s best price
execution responsibility is qualified if securities that it purchases for client accounts are
mutual funds that trade at net asset value as determined at the daily market close.
1. Non-Soft Dollar Research and Additional Benefits
Although not a material consideration when determining whether to recommend that a client utilize
the services of a particular broker-dealer/custodian, Registrant can receive from Fidelity and/or
Pershing (or other broker-dealer/custodians, unaffiliated investment managers, Independent
Manager(s), investment platforms, vendors, and/or product/fund sponsors) without cost (and/or at a
discount) support services and/or products, certain of which assist the Registrant to better
monitor and service client accounts maintained at such institutions. Included within the support
services that can be obtained by the Registrant may be investment-related research, pricing
information and market data, software and other technology that provide access to client account
data, compliance and/or practice management-related publications, discounted or gratis consulting
services, discounted and/or gratis travel expenses/attendance at conferences, meetings, and other
educational and/or social events, marketing support (including a financial contribution toward the
cost of the Firm’s annual golf tournament), computer hardware and/or software and/or other products
used by Registrant in furtherance of its investment advisory business operations.
Certain of the support services and/or products that may be received may assist the Registrant in
managing and administering client accounts. Others do not directly provide such assistance, but
rather assist the Registrant to manage and further develop its business enterprise.
Registrant’s clients do not pay more for investment transactions effected and/or assets maintained
at a broker-dealer/custodian as a result of this arrangement. There is no corresponding commitment
made by the Registrant to any broker-dealers/custodians or any other entity to invest any specific
amount or percentage of client assets in any specific mutual funds, securities or other investment
products as a result of the above arrangements. ANY QUESTIONS: The Registrant’s Chief Compliance
Officer, Brett Stanton, remains available to address any questions that a client or prospective
client may have regarding the above arrangements and the corresponding conflicts of interest
presented by such arrangements.
2. The Registrant does not receive referrals from broker-dealers.
3. Directed Brokerage.
The Registrant does not generally accept directed brokerage arrangements (when a client requires
that account transactions be affected through a specific broker-dealer). In such client directed
arrangements, the client will negotiate terms and arrangements for their account with that
broker-dealer, and Registrant will not seek better execution services or prices from other
broker-dealers or be able to “batch” the client’s transactions for execution through other
broker-dealers with orders for other accounts managed by Registrant. As a result, the client may
pay higher commissions or other transaction costs or greater spreads, or receive less favorable net
prices, on transactions for the account than would otherwise be the case.
Please Note: In the event that the client directs Registrant to effect securities transactions for
the client’s accounts through a specific broker-dealer, the client correspondingly acknowledges
that such direction may cause the accounts to incur higher commissions or transaction costs than
the accounts would otherwise incur had the client determined to effect account transactions through
alternative clearing arrangements that may be available through Registrant. Higher transaction
cost
Compliance Officer, Brett Stanton, remains available to address any questions that a client or
prospective client may have regarding the above arrangement.
B. Transactions for each client account generally will be affected independently, unless the
Registrant decides to purchase or sell the same securities for several clients at approximately the
same time. The Registrant may (but is not obligated to) combine or “bunch” such orders to obtain
best execution, to negotiate more favorable commission rates or to allocate equitably among the
Registrant’s clients differences in prices and commissions or other transaction costs that might
have been obtained had such orders been placed independently. Under this procedure, transactions
will be averaged as to price and will be allocated among clients in proportion to the purchase and
sale orders placed for each client account on any given day. The Registrant shall not receive any
additional compensation or remuneration as a result of such aggregation.
Item 13 Review of Accounts
A. For those clients to whom Registrant provides investment supervisory services, account reviews
are conducted on an ongoing basis by the Registrant’s investment adviser representatives and/or
Chief Compliance Officer. All investment supervisory clients are advised that it remains their
responsibility to advise the Registrant of any changes in their investment objectives and/or
financial situation. All clients (in person or via telephone) are encouraged to review financial
planning issues (to the extent applicable), investment objectives and account performance with the
Registrant on an annual basis.
B. The Registrant may conduct account reviews on an other-than periodic basis upon the occurrence
of a triggering event, such as a change in client investment objectives and/or financial situation,
market corrections and client request.
C. Clients are provided, at least quarterly, with written transaction confirmation notices and
regular written summary account statements directly from the broker-dealer/custodian and/or program
sponsor for the client accounts. The Registrant may also provide a written periodic report
summarizing account activity and performance.
Item 14 Client Referrals and Other Compensation
A. As referenced in Item 12.A.1 above, the Registrant can receive economic benefits from Fidelity
and/or Pershing (or other broker-dealer/custodians, unaffiliated investment managers, Independent
Manager(s), investment platforms, and/or mutual fund sponsors), such as support services and/or
products without cost or at a discount. Registrant’s clients do not pay more for investment
transactions effected and/or assets maintained at a broker-dealer/custodian as a result of this
arrangement. There is no corresponding commitment made by the Registrant to a
broker-dealer/custodian or any other entity to invest any specific amount or percentage of client
assets in any specific mutual funds, securities or other investment products as a result of the
above arrangements. ANY QUESTIONS: The Registrant’s Chief Compliance Officer, Brett Stanton,
remains available to address any questions that a client or prospective client may have regarding
the above arrangements and the corresponding conflicts of interest presented by such arrangements.
B. The Registrant engages promoters to introduce new prospective clients to the Registrant
consistent with the Investment Advisers Act of 1940, its corresponding. Rules, and applicable state
regulatory requirements. If the prospect subsequently engages the Registrant, the promoter shall
generally be compensated by the Registrant for the introduction. Because the promoter has an
economic incentive to introduce the prospect to the Registrant, a conflict of interest is
presented. The promoter’s introduction shall not result in the prospect’s payment of a higher
investment advisory fee to the Registrant (i.e., if the prospect was to engage the Registrant
independent of the promoter’s introduction).
C. In the event that a client advises Fusion Family that it requires the services of an
unaffiliated professional (i.e., attorney, CPA, insurance agent, etc.), and the client
correspondingly requests an introduction from Fusion Family, Fusion Family may make an introduction
to a professional who is also a Fusion Family client and/or referral source. Unless otherwise
expressly indicated, in writing, neither Fusion Family, nor any Fusion Family employee, shall
receive any compensation from the professional for the introduction. Nevertheless, because the
recommended professional is also a Fusion Family client, a conflict of interest arises because by
making the introduction, Fusion Family is assisting an individual or entity from whom it derives
(and anticipates in the future will derive) compensation as a Fusion Family client. In addition,
Fusion Family currently (and anticipates continuing to do so in the future) provides advisory
services to referral sources on a discounted basis. In the event that Fusion Family introduces a
client to an unaffiliated professional who is also a Fusion Family client, Fusion Family will
disclose the conflict to the client. No client is under any obligation to utilize the services of
any such recommend professional.
Item 15 Custody
The Registrant shall have the ability to have its advisory fee for each client debited by the
custodian on a quarterly basis. Clients are provided, at least quarterly, with written transaction
confirmation notices and regular written summary account statements directly from the
broker-dealer/custodian and/or program sponsor for the client accounts. The Registrant may also
provide a written periodic report summarizing account activity and performance.
Please Note: To the extent that the Registrant provides clients with periodic account statements or
reports, the client is urged to compare any statement or report provided by the Registrant with the
account statements received from the account custodian. The account custodian does not verify the
accuracy of the Registrant’s advisory fee calculation.
Certain clients have established asset transfer authorizations that permit the qualified custodian
to rely upon instructions from Fusion to transfer client funds or securities to third parties.
These arrangements are disclosed at Item 9 of Part 1 of Form ADV. However, in accordance with the
guidance provided in the SEC’s February 21, 2017, Investment Adviser Association No-Action Letter,
the affected accounts are not subject to an annual surprise CPA examination. In addition, in
limited circumstances, Registrant engages in certain custody-related services and/or practices
(i.e., trustee service), that are disclosed at Item 9 of Part 1 of Form ADV. These services and
practices are subject to an annual surprise CPA examination. ANY QUESTIONS: Fusion’s Chief
Compliance Officer, Brett Stanton, remains available to address any questions that a client or
prospective client may have regarding custody-related issues.
Item 16 Investment Discretion
The client can determine to engage the Registrant to provide investment advisory services on a
discretionary or non-discretionary basis. Before the Registrant assumes discretionary authority
over a client’s account, client shall be required to execute an Investment Advisory Agreement,
naming the Registrant as client’s attorney and agent in fact, granting the Registrant full
authority to buy, sell, or otherwise effect investment transactions involving the assets in the
client’s name found in the discretionary account.
Clients who engage the Registrant on a discretionary basis may, at any time, impose restrictions,
in writing, on the Registrant’s discretionary authority (i.e., limit the types/amounts of
particular securities purchased for their account, exclude the ability to purchase securities with
an inverse relationship to the market, limit or proscribe the Registrant’s use of margin, etc.).
Item 17 Voting Client Securities
A. The Registrant does not vote client proxies. Clients maintain exclusive responsibility for:
(1) directing the manner in which proxies solicited by issuers of securities owned by the client
shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers,
bankruptcy proceedings or other type events pertaining to the client’s investment assets.
Registrant will introduce a third-party service provider, Chicago Clearing Corp. (CCC), to assist
the client with participation in securities class action lawsuits pertaining to the assets under
Registrant’s management. Registrant would then provide trade data and other necessary information
to the third-party service provider, which would research class action cases and complete and
calculate the applicable proof of claim. The third-party service provider would then file the
applicable proof of claim with the claims administrator, verify payment received from the claims
administrator and distribute the payment to the client minus a fifteen percent (15%) contingency
fee of securities class action settlements collected. Otherwise, if clients choose not to engage in
the class action monitoring, filing, and recovery services provided by the third-party service
provider, clients will be exclusively responsible for voting in all legal proceedings or other type
events pertaining to the assets under Registrant’s management including, but not limited to, class
action lawsuits.
Fair Fund Process. In the event that the third-party service provider is required to process a Fair
Fund payment (i.e., a fund established by the SEC to distribute money to defrauded investors), the
third-party service provider shall deposit the gross settlement into the client’s account. However,
CCC, unlike its does for class action settlements, the third-party service provider will not deduct
its percentage fee from the client‘s gross settlement. Rather, the third-party service provider
shall accrue its Fair Fund fee and deduct it from the client’s subsequent class action
settlement(s).
B. Clients will receive their proxies or other solicitations directly from their custodian. Clients
may contact the Registrant to discuss any questions they may have with a particular solicitation.
Item 18 Financial Information
A. The Registrant does not solicit fees of more than $1,200, per client, six months or more in
advance.
B. The Registrant is unaware of any financial condition that is reasonably likely to impair its
ability to meet its contractual commitments relating to its discretionary authority over certain
client accounts.
C. The Registrant has not been the subject of a bankruptcy petition.
ANY QUESTIONS: The Registrant’s Chief Compliance Officer, Brett Stanton, remains available to
address any questions that a client or prospective client may have regarding the
above disclosures and arrangements.
FUSION FAMILY WEALTH, LLC
SEC File # 801-78339
ADV Part 2A, Brochure
Dated: March 2, 2026
Contact: Brett Stanton, Chief Compliance Officer
88 Froehlich Farm Boulevard, Suite 401, Woodbury, New York 11797 B.Stanton@FusionFamilyWealth.com
(516) 206-1320
www.FusionFamilyWealth.com
This Brochure provides information about the qualifications and business practices of Fusion Family
Wealth, LLC (the “Registrant”). If you have any questions about the contents of this Brochure,
please contact us at BStanton@FusionFamilyWealth.com or (516) 206-1320. 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.
Additional information about Fusion Family Wealth, LLC also is available on the SEC’s website at
www.adviserinfo.sec.gov.
References herein to Fusion Family Wealth, LLC as a “registered investment adviser” or any
reference to being “registered” does not imply a certain level of skill or training.
Item 2 Material Changes
There have been no material changes made to this Disclosure Brochure since the last annual
amendment filing on February 14ᵗʰ, 2025.
ANY QUESTIONS: The Registrant’s Chief Compliance Officer, Brett Stanton, remains available to
address any questions regarding this Form ADV Part 2A, including the disclosure additions and
enhancements below.
Item 3 Table of Contents
Item 1 Cover
Page................................................................................................
.................................... 1
Item 2 Material Changes
....................................................................................................
...................... 2
Item 3 Table of
Contents............................................................................................
.............................. 2
Item 4 Advisory Business
....................................................................................................
.................... 3
Item 5 Fees and Compensation
....................................................................................................
.......... 11
Item 6 Performance-Based Fees and Side-by-Side Management
.......................................................... 14
Item 7 Types of
Clients.............................................................................................
............................. 14
Item 8 Methods of Analysis, Investment Strategies and Risk of
Loss................................................... 14
Item 9 Disciplinary Information
....................................................................................................
........ 18
Item 10 Other Financial Industry Activities and Affiliations
.................................................................. 18
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading.............. 18
Item 12 Brokerage Practices
....................................................................................................
................ 19
Item 13 Review of
Accounts............................................................................................
........................ 21
Item 14 Client Referrals and Other Compensation
.................................................................................. 21
Item 15
Custody.............................................................................................
.......................................... 22
Item 16 Investment
Discretion..........................................................................................
....................... 22
Item 17 Voting Client
Securities..........................................................................................
.................... 23
Item 18 Financial Information
....................................................................................................
............. 24
2
Item 4 Advisory Business
A. Fusion Family Wealth, LLC (the “Registrant”) is a Delaware limited liability company, which has
been registered as an Investment Adviser with the United States Securities and Exchange Commission
on July 25, 2013. The Registrant is principally owned by Fusion Family Wealth Holdings, LLC. That
entity is principally owned by FFW, Legacy, LLC, which is principally owned by Jonathan Blau, who
also serves as the Registrant’s sole Member and Chief Executive Officer.
B. As discussed below, the Registrant offers investment advisory services and retirement plan
consulting services to its clients (generally comprised of individuals, high net worth individuals,
related trusts and estates, pension, and profit-sharing plans, etc.).
INVESTMENT ADVISORY SERVICES
The client can engage the Registrant to provide discretionary or non-discretionary investment
advisory services. The Registrant’s annual investment advisory fee is based upon a percentage (%)
of the market value of the assets placed under the Registrant’s management. Before engaging the
Registrant to provide investment advisory services, clients are required to enter into an
Investment Advisory Agreement with Registrant setting forth the terms and conditions of the
engagement (including termination), describing the scope of the services to be provided, and the
fee that is due from the client. Registrant’s annual investment advisory fee shall include
investment advisory services, and, to the extent specifically requested by the client and accepted
by the Registrant, financial planning and consulting services. If Registrant determines in its sole
discretion that the client requires extraordinary planning and/or consultation services, the
Registrant may seek to charge for such additional services pursuant to a stand-alone Financial
Planning Agreement as further described below.
Registrant provides investment advisory services specifically tailored to the needs of each client.
Before providing investment advisory services, an investment adviser representative will ascertain
each client’s investment objectives and develop an asset allocation based on a defined investment
policy statement that focuses on client’s investment objectives, time horizon, and risk tolerance.
Once client investment assets are allocated, the Registrant provides ongoing monitoring and review
of account performance and asset allocation as compared to client-designated investment objectives
and may execute or recommend execution of account transactions as a result of those reviews or
based on other triggering events. The advisor may retain certain types of investments from the
Client’s legacy portfolio due to the fit with the overall portfolio strategy, tax-related reasons,
or other reasons as identified between the Registrant and the Client.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
To the extent specifically requested by a client, the Registrant may determine to provide financial
planning and/or consulting services (including investment and non-investment related matters,
including estate planning, insurance planning, etc.) on a stand-alone separate fee basis.
Registrant’s planning and consulting fees are negotiable, depending upon the level and scope of the
service(s) required and the professional(s) rendering the service(s). Before engaging the
Registrant to provide planning or consulting services, clients are generally required to enter into
a Financial Planning and Consulting Agreement with Registrant setting forth the terms and
conditions of the engagement (including termination), describing the scope of the services to be
provided, and the portion of the fee
3
that is due from the client before Registrant commences services. If requested by the client,
Registrant may recommend the services of other professionals for implementation purposes (i.e.,
attorney, accountant, insurance agent, etc.), including professionals who serve as a promoter for
the Registrant-see disclosure at Item 14 below. The client is under no obligation to engage the
services of any such recommended professional. At all times, the engaged licensed professionals
(i.e., attorney, accountant, insurance agent, etc.), and not Registrant, shall be responsible for
the quality and competency of the services provided. The client retains absolute discretion over
all such implementation decisions and is free to accept or reject any recommendation from the
Registrant.
ERISA PLAN and 401(k) INDIVIDUAL ENGAGEMENTS:
• Trustee Directed Plans. Registrant may be engaged to provide discretionary investment advisory
services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the
investment objective designated by the Plan trustees. In such engagements, Registrant will serve as
an investment fiduciary as that term is defined under The Employee Retirement Income Security Act
of 1974 (“ERISA”). Registrant will generally provide services on an “assets under management” fee
basis per the terms and conditions of an Investment Advisory Agreement between the Plan and the
Firm.
• Participant Directed Retirement Plans. Registrant may also provide investment advisory and
consulting services to participant directed retirement plans per the terms and conditions of a
Retirement Plan Services Agreement between Registrant and the plan. For such engagements,
Registrant shall assist the Plan sponsor with the selection of an investment platform from which
Plan participants shall make their respective investment choices (which may include investment
strategies devised and managed by Registrant), and, to the extent engaged to do so, may also
provide corresponding education to assist the participants with their decision-making process.
• Client Retirement Plan Assets. If requested to do so, Registrant shall provide investment
advisory services relative to the client’s 401(k) plan assets. In such event, Registrant shall
recommend that the client allocate the retirement account assets among the investment options
available on the 401(k) platform. The client is exclusively responsible for making all
transactions. Registrant’s ability shall be limited to making recommendations regarding the
allocation of the assets among the investment alternatives available through the plan. Registrant
will not receive any communications from the plan sponsor or custodian, and it shall remain the
client’s exclusive obligation to notify Registrant of any changes in investment alternatives,
restrictions, etc. pertaining to the retirement account.
MISCELLANEOUS
Limitations of Non-Investment Consulting/Implementation Services. To the extent requested by a
client, Registrant may provide financial planning and related consulting services regarding
non-investment related matters, such as estate planning, tax planning, insurance, etc. The
Registrant does not serve as a law firm, accounting firm, or insurance agency, and no portion of
Registrant’s services should be construed as legal, accounting, or insurance implementation
services. Accordingly, Registrant does not prepare estate planning documents, tax returns, or sell
insurance products. To the extent requested by a client, Registrant may recommend the services of
other professionals for certain non-investment implementation purposes (i.e., attorneys,
accountants, insurance agents, etc.), which may include professionals who serve as a promoter for
the Registrant-see disclosure at Item 14 below. Clients are reminded that they are under no
obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by Registrant or its representatives. Please Note: If the client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client should seek recourse exclusively from and
against the engaged professional. At all times, the engaged licensed professionals (i.e., attorney,
accountant, insurance agent, etc.), and not Registrant, shall be responsible for the quality and
competency of the services provided. Please Note: Registrant will generally provide such planning
and consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could
occur based upon assets under management, special projects, stand-alone planning engagements, etc.
for which Firm may charge a separate or additional fee). Registrant believes that it is important
for the client to address financial planning issues with the Registrant on an ongoing basis.
Registrant’s fee, as set forth at Item 5 below, will remain the same regardless of whether or not
the client determines to address planning issues with Registrant. Registrant remains available to
address planning issues with the client on an ongoing basis.
Wealth Advisor Growth Network. Registrant’s indirect minority shareholder, Merchant Wealth
Partners, LLC, maintains a minority ownership interest in Wealth Advisor Growth Network (“WAGN”), a
company that offers consulting and support services to independent wealth management firms. Fusion
has engaged a service provider (LibertyFi LLC, an advisory industry technology and administrative
services support provider) that compensates WAGN for introductions. Fusion’s Chief Compliance
Officer, Brett Stanton, remains available to address any questions that such arrangements may
create, including conflicts of interest.
Investment Risk. Different types of investments involve varying degrees of risk, and it should not
be assumed that future performance of any specific investment or investment strategy (including the
investments and/or investment strategies recommended or undertaken by Registrant) will be
profitable or equal any specific performance level(s).
Client Obligations. In performing its services, Registrant shall not be required to verify any
information received from the client or from the client’s other professionals and is expressly
authorized to rely thereon. Moreover, each client is advised that it remains their responsibility
to promptly notify the Registrant if there is ever any change in their financial situation or
investment objectives for the purpose of reviewing, evaluating, or revising Registrant’s previous
recommendations and/or services.
Disclosure Brochure. A copy of this Brochure shall be provided to each client prior to, or
contemporaneously with, the execution of the applicable form of client agreement.
Non-Discretionary Service Limitations. Clients that determine to engage Registrant on a
non-discretionary investment advisory basis must be willing to accept that Registrant cannot affect
any account transactions without obtaining prior consent to such transaction(s) from the client.
Thus, in the event that Registrant would like to make a transaction for a client’s account
(including in the event of an individual holding or general market correction), and the client is
unavailable, the Registrant will be unable to affect the account transaction(s) (as it would for
its discretionary clients) without first obtaining the client’s consent. This could place affected
accounts at a disadvantage.
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Registrant will review
client portfolios on an ongoing basis to determine if any changes are necessary based upon various
factors, including, but not limited to, investment performance, market conditions, fund manager
tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment
objective. Based upon these factors, there may be extended periods of time when Registrant
determines that changes to a client’s portfolio are neither necessary, nor prudent. The advisory
fees described in Item 5 below remain due and payable during periods of account inactivity.
Asset Aggregation / Reporting Services. Registrant may provide access to reporting services through
one or more third-party aggregation / reporting platforms that can reflect all of the client’s
investment assets, including those investment assets that the client has not engaged the Registrant
to manage (the “Excluded Assets”). Registrant’s service for the Excluded Assets is strictly limited
to reporting and specifically excludes investment management or implementation. Because Registrant
does not have trading authority for the Excluded Assets, the client (and/or another investment
professional), and not Registrant, will be exclusively responsible for directly implementing any
recommendations for the Excluded Assets. Please refer to Item 5 below with respect to the
additional reporting fee that clients may incur for the Excluded Assets. Further, the client and/or
their other advisors that maintain trading authority, and not Registrant, shall be exclusively
responsible for the investment performance or related activity (such as timing and trade errors)
pertaining to the Excluded Assets. The third-party aggregation / reporting platforms may also
provide access to financial planning information and applications, which should not be construed as
services, advice, or recommendations provided by Registrant. Accordingly, Registrant shall not be
held responsible for any adverse results a client may experience if the client engages in financial
planning or other functions available on the third-party reporting platforms without Registrant’s
participation or oversight.
Availability of Mutual Funds and Exchange Traded Funds. While the Registrant may allocate
investment assets to mutual funds and exchange traded funds (“ETFs”) that are not available
directly to the public, the Registrant may also allocate investment assets to publicly available
mutual funds and ETFs that the client could purchase without engaging Registrant as an investment
adviser. However, if a client or prospective client determines to purchase publicly available
mutual funds or ETFs without engaging Registrant as an investment adviser, the client or
prospective client would not receive the benefit of Registrant’s initial and ongoing investment
advisory services with respect to management of the asset. In addition to Registrant’s investment
advisory fee described below, and transaction and/or custodial fees discussed below, clients will
also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the
fund level (e.g., management fees and other fund expenses).
Cybersecurity Risk. The information technology systems and networks that Registrant and its
third-party service providers use to provide services to Registrant’s clients employ various
controls that are designed to prevent cybersecurity incidents stemming from intentional or
unintentional actions that could cause significant interruptions in Registrant’s operations and/or
result in the unauthorized acquisition or use of clients’ confidential or non-public personal
information. Clients and Registrant are nonetheless subject to the risk of cybersecurity incidents
that could ultimately cause them to incur financial losses and/or other adverse consequences.
Although Registrant has established processes to reduce the risk of cybersecurity incidents, there
is no guarantee that these efforts will always be successful, especially considering that
Registrant does not directly control the cybersecurity measures and policies employed by
third-party service providers, issuers or
securities, broker-dealers, qualified custodians, governmental and other regulatory authorities,
exchanges and other financial market operators and providers.
Artificial Intelligence. The Registrant may use certain Artificial Intelligence (“AI”) tools in
connection with its investment advisory services. The Registrant has adopted an AI Policy that
governs the appropriate use of AI tools to ensure that the Registrant and its employees abide by
their fiduciary duty and comply with all applicable regulations. AI tools are not used by the
Registrant as a substitute for professional judgment by the Registrant or its employees, and all AI
generated output is reviewed by the Registrant for accuracy. All investment decisions and
recommendations are made and approved by the Registrant. The use of AI tools does not guarantee the
accuracy of analyses or the success of any investment strategy. Clients should not assume that
reliance on AI tools results in better performance or reduces risk. AI tools involve limitations
and risks. These risks include, but are not limited to, data security concerns, potential
inaccuracies, and possible algorithmic biases. To mitigate these risks, the Registrant has
implemented controls such as pre-approval requirements for AI tools, restrictions on providing
nonpublic personal information to public AI systems, vendor due diligence, review of AI-generated
materials, and employee training on appropriate AI usage.
Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client
leaving an employer typically has four options regarding an existing retirement plan (and may
engage in a combination of these options): (i) leave the money in the former employer’s plan, if
permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers
are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the
account value (which could, depending upon the client’s age, result in adverse tax consequences).
If Registrant recommends that a client roll over their retirement plan assets into an account to be
managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn
new (or increase its current) compensation as a result of the rollover. If Registrant provides a
recommendation as to whether a client should engage in a rollover or not (whether it is from an
employer’s plan or an existing IRA), Registrant is acting as a fiduciary within the meaning of
Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. No client is under any obligation to roll
over retirement plan assets to an account managed by Registrant, whether it is from an employer’s
plan or an existing IRA. Registrant’s Chief Compliance Officer, Brett Stanton, remains available to
address any questions that a client or prospective client may have regarding the potential for
conflict of interest presented by such rollover recommendation.
Independent Managers. The Registrant may allocate (and/or recommend that the client allocate) a
portion of a client’s investment assets among unaffiliated independent investment managers /
separately managed account platforms (“Independent Manager(s)”) in accordance with the client’s
designated investment objectives according to the terms and conditions of a separate agreement
between the client and the Independent Manager(s). In such situations, the Independent Manager(s)
shall have day-to-day responsibility for the active discretionary management of the allocated
assets. The Registrant shall continue to render investment advisory services to the client relative
to the ongoing monitoring and review of account performance, asset allocation and client investment
objectives. The Registrant generally considers the following factors when considering its
recommendation to allocate investment assets to Independent Manager(s): the client’s designated
investment objectives, management style, performance, reputation, financial strength, reporting,
pricing, and research. The annual investment management fee charged by the Independent Manager(s)
can range from 0.17% to 0.53% of the assets allocated to the Independent
Manager(s). Fees for equity managers are generally higher than those for fixed income managers. The
applicable advisory fee charged by the Independent Manager(s), any related platform fee, “SMA” fee,
“UMA” fee, “TAMP” fee, or similarly named fee is separate from, and in addition to, the
Registrant’s investment advisory fee as set forth in Item 5. Certain Independent Manager(s) may
impose more restrictive account requirements and varying billing practices than Registrant. In such
instances, Registrant may alter its corresponding account requirements and/or billing practices to
accommodate those of the Independent Manager(s). ANY QUESTIONS: The Registrant’s Chief Compliance
Officer, Brett Stanton, remains available to address any questions regarding Independent
Manager(s), and the additional fees to be incurred by the client as result of such engagements.
Please Note: Conflict of Interest: Registrant can allocate (or recommend that the client allocate)
assets to Piton Management (“Piton”), an independent fixed income manager. Registrant’s minority
shareholder, Merchant Wealth Partners, LLC (“Merchant”), maintains a minority ownership interest in
Piton, thereby creating a conflict of interest if/when the Registrant allocates (or recommends that
the client allocate) a portion of their investment assets to Piton. Registrant does not factor
Merchant’s ownership in Piton when allocating client assets to, or retaining assets with, Piton.
Given the conflict of interest, the Registrant shall not allocate client assets to Piton on a
discretionary basis. Rather, the Registrant shall recommend Piton to the client on a
non-discretionary basis, and no portion of the client’s assets shall be allocated to Piton without
the client’s prior consent. ANY QUESTIONS: Registrant’s Chief Compliance Officer, Brett Stanton,
remains available to address any questions regarding Piton and the above-mentioned conflict of
interest.
Custodian Charges-Additional Fees. As discussed below at Items 5 and 12 below, when requested to
recommend a broker-dealer/custodian for client accounts, Registrant generally recommends that
Fidelity or Pershing serve as the broker-dealer/custodian for client investment management assets.
Broker-dealers such as Fidelity and Pershing charge brokerage commissions, transaction, and/or
other type fees for effecting certain types of securities transactions (i.e., including transaction
fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions,
etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as
well as the amount of those fees, which also slightly differ for mutual fund and Independent
Managers at Fidelity vs. Pershing) shall differ depending upon the broker-dealer/custodian (while
certain custodians do not currently charge fees on individual equity transactions (including ETFs),
others do). Currently, neither Fidelity nor Pershing charges transaction fees for individual equity
transactions (including ETFs), with the exception that Fidelity will charge a transaction fee of
$0.01 per share for equity transactions in excess of 10,000 shares. Pershing will also assess fees
to clients who elect to receive account statements by regular mail rather than electronically.
Pershing currently charges $2 per hard copy statement. Please Note: there can be no assurances that
either Pershing or Fidelity will not change their transaction fee pricing in the future. These
fees/charges are in addition to Registrant’s investment advisory fee at Item 5 below. Registrant
does not receive any portion of these fees/charges. ANY QUESTIONS: Registrant’s Chief Compliance
Officer, Brett Stanton, remains available to address any questions that a client or prospective
client may have regarding the above.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account
transactions or new deposits, be swept to and/or initially maintained in a specific custodian
designated sweep account. The yield on the sweep account will generally be lower than those
available for other money market accounts. When this
occurs, to help mitigate the corresponding yield dispersion, Fusion shall (usually within 30 days
thereafter) generally (with exceptions) purchase a higher yielding money market fund available on
the custodian’s platform, unless Fusion reasonably anticipates that it will utilize the cash
proceeds during the subsequent 30-day period to purchase additional investments for the client’s
account. Exceptions and/or modifications can and will occur with respect to all or a portion of the
cash balances for various reasons, including, but not limited to the amount of dispersion between
the sweep account and a money market fund, the size of the cash balance, an indication from the
client of an imminent need for such cash, or the client has a demonstrated history of writing
checks from the account. Please Note: The above does not apply to the cash component maintained
within a Fusion actively managed investment strategy (the cash balances for which shall generally
remain in the custodian designated cash sweep account), assets allocated to an unaffiliated
investment manager, and cash balances maintained for fee billing purposes. Please Also Note: The
client shall remain exclusively responsible for yield dispersion/cash balance decisions and
corresponding transactions for cash balances maintained in any Fusion unmanaged accounts. ANY
QUESTIONS: Fusion’s Chief Compliance Officer, Brett Stanton, remains available to address any
questions that a client or prospective client may have regarding the above.
Unaffiliated Private Investment Funds.
Registrant does not recommend that its clients purchase private investment funds. However, the
Registrant will assist the client with the purchase of same upon express request. Upon such
request, the Registrant, on a non-discretionary basis, shall present prospective private funds to
the client for the client’s review and consideration. Registrant’s role relative to unaffiliated
private investment funds shall be limited to its initial and ongoing review and investment
monitoring services. If a client determines to become an unaffiliated private fund investor, the
amount of assets invested in the fund(s) shall be included as part of “assets under management” for
purposes of Registrant calculating its investment advisory fee. Registrant’s fee shall be in
addition to the fund’s fees. Registrant’s clients are under absolutely no obligation to consider or
make an investment in any private investment fund(s).
Please Note: Private investment funds generally involve various risk factors, including, but not
limited to, potential for complete loss of principal, liquidity constraints and lack of
transparency, a complete discussion of which is set forth in each fund’s offering documents, which
will be provided to each client for review and consideration. Unlike liquid investments that a
client may own, private investment funds do not provide daily liquidity or pricing. Each
prospective client investor will be required to complete a Subscription Agreement, pursuant to
which the client shall establish that the client is qualified for investment in the fund and
acknowledges and accepts the various risk factors that are associated with such an investment.
Please Also Note: Valuation. In the event that Registrant references private investment funds owned
by the client on any supplemental account reports prepared by Registrant, the value(s) for all
private investment funds owned by the client shall reflect the most recent valuation provided by
the fund sponsor. However, if subsequent to purchase, the fund has not provided an updated
valuation, the valuation shall reflect the initial purchase price. If subsequent to purchase, the
fund provides an updated valuation, then the statement will reflect that updated value. The updated
value will continue to be reflected on the reportuntil the fund provides a further updated value. Please Also Note: As result of the valuation
process, if the valuation reflects initial purchase price or an updated value subsequent to
purchase price, the current value(s) of an investor’s fund holding(s) could be significantly more
or less than the value reflected on the report. Unless otherwise indicated, Registrant shall
calculate its fee based upon the latest value provided by the fund sponsor.
Conflict of Interest: To assist with identifying funds for the client’s review and consideration,
the Registrant shall use the private fund due diligence and platform services provided by Opto
Investments (“Opto”). Registrant’s minority shareholder, Merchant Wealth Partners, LLC
(“Merchant”), maintains a minority ownership interest in Opto, thereby creating a potential
conflict of interest (i.e., Opto will derive compensation from private funds that are available on
its platform). ANY QUESTIONS: Registrant’s Chief Compliance Officer, Brett Stanton, remains
available to address any questions regarding Opto and the above referenced conflict of interest.
Cash Positions. Registrant continues to treat cash as an asset class. As such, unless determined to
the contrary by Registrant, all cash positions (money markets, etc.) shall continue to be included
as part of assets under management for purposes of calculating Registrant’s advisory fee. At any
specific point in time, depending upon perceived or anticipated market conditions/events (there
being no guarantee that such anticipated market conditions/events will occur), Registrant may
maintain cash positions for defensive purposes. In addition, while assets are maintained in cash,
such amounts could miss market advances. Depending upon current yields, at any point in time,
Registrant’s advisory fee could exceed the interest paid by the client’s money market fund. ANY
QUESTIONS: The Registrant’s Chief Compliance Officer, Brett Stanton, remains available to address
any questions that a client or prospective may have regarding the above fee billing practice.
Borrowing Against Assets/Risk. A client who has need to borrow money could determine to do so by
using:
• Margin – The account custodian or broker-dealer lends money to the client. The custodian charges
the client interest for the right to borrow money, and uses the assets in the client’s brokerage
account as collateral; and
• Pledged Assets Loan – In consideration for a lender (i.e., a bank, etc.) to make a loan to the
client, the client pledges its investment assets held at the account custodian as collateral;
These above-described collateralized loans are generally utilized because they typically provide
more favorable interest rates than standard commercial loans. These types of collateralized loans
can assist with a pending home purchase, permit the retirement of more expensive debt, or enable
borrowing in lieu of liquidating existing account positions and incurring capital gains taxes.
However, such loans are not without potential material risk to the client’s investment assets. The
lender (i.e., custodian, bank, etc.) will have recourse against the client’s investment assets in
the event of loan default or if the assets fall below a certain level. For this reason, Fusion does
not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to
purchase a new residence). Fusion does not recommend such borrowing for investment purposes (i.e.,
to invest borrowed funds in the market). Regardless, if the client was to determine to utilize
margin or a pledged assets loan, the following economic benefits would inure to Fusion:
• By taking the loan rather than liquidating assets in the client’s account,
Fusion continues to earn a fee on such Account assets; and,
• If the client invests any portion of the loan proceeds in an account to be managed by Fusion,
Fusion will receive an advisory fee on the invested amount; and,
• If Fusion’s advisory fee is based upon the higher margined account value, Fusion will earn a
correspondingly higher advisory fee. This could provide Fusion with a disincentive to encourage the
client to discontinue the use of margin.
Please Note: The client must accept the above risks and potential corresponding consequences
associated with the use of margin or a pledged assets loan.
C. The Registrant provides investment advisory services specific to the needs of each client.
Before providing investment advisory services, an investment adviser representative will ascertain
each client’s investment objectives. Thereafter, the Registrant shall allocate and/or recommend
that the client allocate investment assets consistent with the designated investment objective(s).
The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s
services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2025, the Registrant had $1,441,403,309 in Client assets,
$1,425,894,758 of which are managed on a discretionary basis and $15,508,551 on a non-discretionary
basis. Clients may request more current information at any time by contacting the Registrant.
Item 5 Fees and Compensation
A. Registrant offers its services on a fee basis, meaning that clients pay an annual fee based upon
assets under management and/or advisement as described below.
INVESTMENT ADVISORY SERVICES
If a client chooses to engage the Registrant to provide discretionary and/or non-discretionary
investment advisory services on a negotiable fee basis, the Registrant’s annual investment advisory
fee shall be generally based upon a percentage (%) of the market value of assets under management
according to the following fee schedule:
Market Value of Portfolio Annual Fee*
Under $3,000,000 1.10%
Over $3,000,000 but less than $10,000,000 0.95%
Above $10,000,000 0.80%
Client accounts will be aggregated by household for billing purposes to achieve the lowest possible
pricing. The annual investment advisory fee is billed on a quarterly basis, in advance (except for
Participant Directed Retirement Plans, which are billed in arrears), based upon the market value of
the assets on the last day of the previous quarter. If assets in excess of $10,000 are deposited
into or withdrawn from an account after the inception of a billing period, the fee payable with
respect to such assets is adjusted to reflect theinterim change in portfolio value. For the initial period of an engagement, the fee is calculated
on a pro rata basis.
*Where applicable, agreed upon non-managed assets held as part of your portfolio with Fusion Family
Wealth will not be charged any Fusion fee. These non-managed assets will be assessed a reporting
services fee of 0.02% (2 bps).
Independent Manager Fees. Without limiting the above, the annual investment management fee charged
by Independent Manager(s) to the client can range from 0.17% to 0.53% of the assets allocated to
the Independent Manager(s). Fees for equity managers are generally higher than those for fixed
income managers. The applicable advisory fee charged by the Independent Manager(s), any related
platform fee, “SMA” fee, “UMA” fee, “TAMP” fee, or similarly named fee is separate from, and in
addition to, the Registrant’s investment advisory fee as set forth above.
Fee Dispersion. Registrant, in its discretion, may charge a lesser investment advisory fee, waive
its asset minimum, charge a flat fee, waive its fee entirely, or charge a fee on a different
interval, based upon certain criteria (i.e. anticipated future earning capacity, anticipated future
additional assets, dollar amount of assets to be managed, related accounts, account composition,
complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules,
employees and family members, courtesy accounts, competition, negotiations with client, etc.). As
result of the above, similarly situated clients could pay different fees. In addition, similar
advisory services may be available from other investment advisers for similar or lower fees.
Fee Level Adjustment. Registrant’s annual fee generally decreases at the asset levels described
above (over $3 million and over $10 million). Correspondingly, if the client’s managed assets fall
below those agreed levels, Registrant’s annual fee will increase. If the asset level changes occur
during any billing quarter, there will be no interim intra-quarter fee adjustments. Rather, the fee
shall be adjusted as of the beginning of the following initial full billing quarter.
Reporting Services Fee. Clients who choose to receive reporting services for investment assets that
the client has not engaged the Registrant to manage (the “Excluded Assets”) will incur an
additional annual reporting services fee of $80/Yodlee account for the Excluded Assets.
ANY QUESTIONS: Registrant’s Chief Compliance Officer, Brett Stanton, remains available to address
any questions that a client or prospective client may have regarding advisory fees.
RETIREMENT ACCOUNTS
For new clients that engage the Registrant’s services, effective March 1, 2021, assets maintained
by the client in their employer sponsored retirement plan shall be included for purpose of
Registrant calculating its quarterly fee per the fee schedule set forth at Item 5 above. However,
if the client advises the Registrant, in writing, that it does not desire for the Registrant to
provide advisory services for the client’s employer sponsored retirement plan, such assets shall
not be included for Registrant’s fee billing purposes. At no time shall the Registrant maintain the
client’s password for such retirement accounts, and it will be the client’s exclusive obligation to
implement the Registrant’s recommendations.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
To the extent specifically requested by a client, the Registrant may determine to provide financial
planning and/or consulting services (including investment and non-investment related matters,
including estate planning, insurance planning, etc.) on a stand-alone fee basis. Registrant’s
planning and consulting fees are negotiable but are generally charged at a rate of $300 per hour,
depending upon the level and scope of the service(s) required and the professional(s) rendering the
service(s).
RETIREMENT PLAN CONSULTING SERVICES
If a participant directed retirement plan sponsor client chooses to engage the Registrant to
provide retirement plan consulting services, Registrant’s annual fee for these services ranges from
20bps to 35bps based on the value of plan’s assets on the last day of the previous quarter payable
quarterly, in arrears.
B. Clients may elect to have the Registrant’s investment advisory fees and retirement plan
consulting fees deducted from their custodial account. Registrant’s Investment Advisory Agreement,
Retirement Plan Services Agreement, and the applicable custodial/clearing agreement may authorize
the custodian to debit the account for the amount of the Registrant’s investment advisory fee and
to directly remit that fee to the Registrant in compliance with regulatory procedures. In the
limited event that the Registrant bills the client directly for those services, payment is due upon
receipt of the Registrant’s invoice. The Registrant shall deduct investment advisory fees and
retirement plan consulting fees
C. As discussed below, unless the client directs otherwise or an individual client’s circumstances
require, the Registrant shall generally recommend that Fidelity Institutional Wealth Services, an
SEC-registered and FINRA member broker dealer (“Fidelity”), and/or Pershing Advisor Solutions, LLC
an SEC-registered and FINRA member broker dealer serve as the broker-dealer/custodian for client
investment advisory assets. Broker-dealers such as Fidelity and Pershing charge brokerage
commissions, transaction, and/or other type fees for effecting certain types of securities
transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and
mark-downs charged for fixed income transactions, etc.). The types of securities for which
transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall
differ depending upon the broker-dealer/custodian (while certain custodians do not currently charge
fees on individual equity transactions (including ETFs), others do). Currently, neither Fidelity
nor Pershing charges transaction fees for individual equity transactions (including ETFs), with the
exception that Fidelity will charge a transaction fee of $0.01 per share for equity transactions in
excess of 10,000 shares. Pershing will also assess fees to clients who elect to receive account
statements by regular mail rather than electronically. Pershing currently charges $2 per hard copy
statement. In addition to Registrant’s investment advisory fee, brokerage commissions and/or
transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund
(“ETF”) purchases, charges imposed at the fund level (e.g. management fees and other fund
expenses). Clients (to the extent applicable to their account assets), can also incur deferred
sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees and
other fees and taxes on brokerage accounts and securities transactions, advisory fees imposed by
Independent Manager(s) (including any related platform fee, “SMA” fee, “UMA” fee, “TAMP” fee, or
similarly-named fee). Registrant does not receive any portion of these fees/charges. ANY QUESTIONS:
The Registrant’s Chief Compliance Officer, Brett Stanton, remains available to address any
questions regarding fees to be incurred by the client.
D. The Registrant’s annual investment advisory fee shall be prorated and paid quarterly in advance,
based upon the market value of the assets on the last day of the previous quarter. The Registrant’s
annual retirement plan consulting fee shall be prorated and paid quarterly in arrears, based upon
the market value of the assets on the last day of the previous quarter. The applicable form of
agreement between the Registrant and the client will continue in effect until terminated by either
party in conformity with the terms of such agreement. Upon termination of such agreement, the
Registrant shall, based upon the type of account:
(1) retirement plans bill the client or debit the account for the pro-rated portion of the unpaid
advisory fee based upon the number of days those services were provided during the billing quarter;
or, (2) all other types of accounts refund the pro-rated portion of the advanced advisory fee paid
based upon the number of days remaining in the billing quarter, as applicable. ANY QUESTIONS: The
Registrant’s Chief Compliance Officer, Brett Stanton, remains available to address any questions
regarding fees to be incurred by the client.
E. Neither the Registrant, nor its representatives accept compensation from the sale of securities
or other investment products.
Item 6 Performance-Based Fees and Side-by-Side Management
Neither the Registrant nor any supervised person of the Registrant accepts performance-based fees.
Item 7 Types of Clients
The Registrant’s clients generally include individuals, high net worth individuals, related trusts
and estates, pension, and profit-sharing plans. The Registrant generally requires a $5 million
aggregate asset minimum for investment advisory services. The Registrant, in its sole discretion,
may reduce its minimum asset preference based upon certain criteria (i.e., anticipated future
earning capacity, anticipated future additional assets, dollar amount of assets to be managed,
related accounts, account composition, negotiations with client, etc.). Please also refer to Item 5
above with respect to “Fee Dispersion.”
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
A. The Registrant may utilize the following methods of security analysis:
• Fundamental - (analysis performed on historical and present data, with the goal of making
financial forecasts);
• Technical – (analysis performed on historical and present data, focusing on price and trade
volume, to forecast the direction of prices); and/or
• Cyclical – (analysis performed on historical relationships between price and market trends, to
forecast the direction of prices).
The Registrant may utilize the following investment strategies when implementing investment advice
given to clients:
• Long Term Purchases (securities held at least a year);
• Short Term Purchases (securities sold within a year); and/or
• Margin Transactions (use of borrowed assets to purchase financial instruments) 14
Investment Risk. Past performance does not guarantee future results. Investing in securities
involves risk of loss that clients should be prepared to bear, including the complete loss of
principal investment. Different types of investments involve varying degrees of risk, and it should
not be assumed that future performance of any specific investment or investment strategy (including
the investments and/or investment strategies recommended or undertaken by the Registrant) will be
profitable or equal any specific performance level(s). While markets may increase and client
account values could benefit as a result, it is also possible that markets may decrease, and such
account values could suffer a loss. It is therefore important that clients understand investment
risks, diversification strategies, and ask Registrant any questions they may have before making any
investment decisions.
B. The Registrant’s methods of analysis and investment strategies do not present any significant or
unusual risks. However, every method of analysis has its own inherent risks. To perform an accurate
market analysis the Registrant must have access to current/new market information. The Registrant
has no control over the dissemination rate of market information; therefore, unbeknownst to the
Registrant, certain analyses may be compiled with outdated market information, severely limiting
the value of the Registrant’s analysis. Furthermore, an accurate market analysis can only produce a
forecast of the direction of market values. There can be no assurances that a forecasted change in
market value will materialize into actionable and/or profitable investment opportunities.
The Registrant’s primary investment strategies (Long-Term Purchases and Short-Term Purchases) are
fundamental investment strategies. However, every investment strategy has its own inherent risks
and limitations. For example, longer term investment strategies require a longer investment time
period to allow for the strategy to potentially develop. Shorter term investment strategies require
a shorter investment time period to potentially develop but, as a result of more frequent trading,
may incur higher transactional costs when compared to a longer-term investment strategy.
C. Registrant recommends asset allocations based on a particular client’s: economic situation,
liquidity needs, risk tolerance, proposed investment period, need for diversification, reliance
upon current income, present and anticipated tax situation. Registrant also considers historical
yields, potential appreciation, and marketability before making investment recommendations.
Registrant primarily allocates or recommends that clients allocate investment assets among mutual
funds, ETFs, and Independent Managers in accordance with the clients’ designated investment
objectives. To a lesser extent, when consistent with investment objectives, Registrant may also
allocate or recommend that clients allocate investment assets among individual equities (stocks)
and individual bonds. In certain limited circumstances, when consistent with a client’s investment
objectives, the Registrant may also recommend the use of margin transactions.
Each type of investment has its own unique set of risks associated with it. The following provides
a short description of some of the underlying risks associated with the types of investments that
Registrant uses or recommends:
Market Risk. The price of a security may drop in reaction to tangible and intangible events and
conditions. This type of risk may be caused by external factors (such as economic or political
factors) but may also be incurred because of a security’s specific underlying investments.
Additionally, each security’s price can fluctuate based on market movement,\
which may or may not be due to the security’s operations or changes in its true value. For example,
political, economic, and social conditions may trigger market events which are temporarily
negative, or temporarily positive.
Unsystematic Risk. Unsystematic risk is the company-specific or industry-specific risk in a
portfolio that the investor bears. Unsystematic risk is typically addressed through
diversification. However, as indicated above, diversification does not guarantee better performance
and cannot eliminate the risk of investment losses.
Value Investment Risk. Value stocks may perform differently from the market as a whole and
following a value-oriented investment strategy may cause a portfolio to underperform growth stocks.
Growth Investment Risk. Prices of growth stocks tend to be higher in relation to their companies’
earnings and may be more sensitive to market, political and economic developments than other
stocks, making their prices more volatile.
Small Company Risk. Securities of small companies are often less liquid than those of large
companies and this could make it difficult to sell a small company security at a desired time or
price. As a result, small company stocks may fluctuate relatively more in price. In general, small
capitalization companies are more vulnerable than larger companies to adverse business or economic
developments and they may have more limited resources.
Commodity Risk. The value of commodity-linked derivative instruments may be affected by changes in
overall market movements, commodity index volatility, changes in interest rates, or factors
affecting a particular industry or commodity, such as drought, floods, weather, livestock disease,
embargoes, tariffs, and international economic, political, and regulatory developments.
Foreign Securities and Currencies Risk. Foreign securities prices may decline or fluctuate because
of: (i) economic or political actions of foreign governments, and/or (ii) less regulated or liquid
securities markets. Investors holding these securities are also exposed to foreign currency risk
(the possibility that foreign currency will fluctuate in value against the U.S. dollar).
Interest Rate Risk. Fixed income securities and fixed income-based securities are subject to
interest rate risk because the prices of fixed income securities tend to move in the opposite
direction of interest rates. When interest rates rise, fixed income security prices tend to fall.
When interest rates fall, fixed income security prices tend to rise. In general, fixed income
securities with longer maturities are more sensitive to these price changes.
Inflation Risk. When any type of inflation is present, a dollar at present value will not carry the
same purchasing power as a dollar in the future, because that purchasing power erodes at the rate
of inflation.
Reinvestment Risk. Future proceeds from investments may have to be reinvested at a potentially
lower rate of return (i.e., interest rate), which primarily relates to fixed income securities.
Credit Risk. The issuer of a security may be unable to make interest payments and/or repay
principal when due. A downgrade to an issuer’s credit rating or a perceived change
in an issuer’s financial strength may affect a security’s value and impact performance. Credit risk
is considered greater for fixed income securities with ratings below investment grade. Fixed income
securities that are below investment grade involve higher credit risk and are considered
speculative.
Call Risk. During periods of falling interest rates, a bond issuer will call or repay a
higher-yielding bond before its maturity date, forcing the investment to reinvest in bonds with
lower interest rates than the original obligations.
Regulatory Risk. Changes in laws and regulations from any government can change the market value of
companies subject to such regulations. Certain industries are more susceptible to government
regulation. For example, changes in zoning, tax structure or laws may impact the return on
investments.
Mutual Fund Risk. Mutual funds are operated by investment companies that raise money from
shareholders and invest it in stocks, bonds, and/or other types of securities. Each fund will have
a manager that trades the fund’s investments in accordance with the fund’s investment objective.
Mutual funds charge a separate management fee for their services, so the returns on mutual funds
are reduced by the costs to manage the funds. While mutual funds generally provide diversification,
risks can be significantly increased if the fund is concentrated in a particular sector of the
market. Mutual funds come in many varieties. Some invest aggressively for capital appreciation,
while others are conservative and are designed to generate income for shareholders. In addition,
the client’s overall portfolio may be affected by losses of an underlying fund and the level of
risk arising from the investment practices of an underlying fund (such as the use of derivatives).
Exchange Traded Fund Risk. ETFs are marketable securities that are designed to track, before fees
and expenses, the performance or returns of a relevant index, commodity, bonds or basket of assets,
like an index fund. Unlike mutual funds, ETFs trade like common stock on a stock exchange. ETFs
experience price changes throughout the day as they are bought and sold. In addition to the general
risks of investing, there are specific risks to consider with respect to an investment in ETFs,
including, but not limited to: (i) an ETF’s shares may trade at a market price that is above or
below its net asset value; (ii) the ETF may employ an investment strategy that utilizes high
leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s
officials deem such action appropriate, the shares are de-listed from the exchange, or the
activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices)
halts stock trading generally.
Margin Transactions. A margin transaction strategy, in which an investor uses borrowed assets to
purchase financial instruments, involves a high level of inherent risk. The investor generally
obtains the borrowed assets by using other securities as collateral for the borrowed sum. The
effect of purchasing a security using margin is to magnify any gains or losses sustained by the
purchase of the financial instruments on margin. Please Note: To the extent that a client
authorizes the use of margin, and margin is thereafter employed by the Registrant in the management
of the client’s investment portfolio, the market value of the client’s account and corresponding
fee payable by the client to the Registrant may be increased. As a result, in addition to
understanding and assuming the additional principal risks associated with the use of margin,
clients authorizing margin are advised of the potential conflict of interest whereby the client’s
decision to employ margin may correspondingly increase the management fee payable to the
Registrant. Accordingly, the decision as to whether to employ margin is left totally to the
discretion of client.
Item 9 Disciplinary Information
The Registrant has not been the subject of a disciplinary action.
Item 10 Other Financial Industry Activities and Affiliations
A. Neither the Registrant, nor its representatives, are registered or have an application pending
to register, as a broker-dealer or a registered representative of a broker-dealer.
B. Neither the Registrant, nor its representatives, are registered or have an application pending
to register, as a futures commission merchant, commodity pool operator, a commodity trading
advisor, or a representative of the foregoing.
C. As indicated above relative to Independent Manager(s), the Registrant recommends or selects
other investment advisors (i.e., Independent Manager(s)) for its clients for which the Registrant
earns an advisory fee.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. The Registrant maintains an investment policy relative to personal securities transactions.
This investment policy is part of Registrant’s overall Code of Ethics, which serves to establish a
standard of business conduct for all of Registrant’s Representatives that is based upon fundamental
principles of openness, integrity, honesty and trust, a copy of which is available upon request.
In accordance with Section 204A of the Investment Advisers Act of 1940 and similar state law, the
Registrant also maintains and enforces written policies reasonably designed to prevent the misuse
of material non-public information by the Registrant or any person associated with the Registrant.
B. Neither the Registrant nor any related person of Registrant recommends, buys, or sells for
client accounts, securities in which the Registrant or any related person of Registrant has a
material financial interest.
C. The Registrant and/or representatives of the Registrant may buy or sell securities that are also
recommended to clients. This practice may create a situation where the Registrant and/or
representatives of the Registrant are in a position to materially benefit from the sale or purchase
of those securities. Therefore, this situation creates a potential conflict of interest. Practices
such as “scalping” (i.e., a practice whereby the owner of shares of a security recommends that
security for investment and then immediately sells it at a profit upon the rise in the market price
which follows the recommendation) could take place if the Registrant did not have adequate policies
in place to detect such activities. In addition, this requirement can help detect insider trading,
“front-running” (i.e., personal trades executed before those of the Registrant’s clients) and other
potentially abusive practices.
The Registrant has a personal securities transaction policy in place to monitor the personal
securities transactions and securities holdings of each of the Registrant’s “Access Persons.” The
Registrant’s securities transaction policy requires that Access Person of the Registrant must
provide the Chief Compliance Officer or his/her designee with a written report of their current
securities holdings within ten (10) days after becoming an Access Person.
Furthermore, Access Persons must provide the Chief Compliance Officer with a quarterly transaction
report, detail all trades in the Access Person’s account during the previous quarter; and on an
annual basis, each Access Person must provide the Chief Compliance Officer with a written report of
the Access Person’s current securities holdings. However, at any time that the Registrant has only
one Access Person, he or she shall not be required to submit any securities report described above.
D. The Registrant and/or representatives of the Registrant may buy or sell securities, at or around
the same time as those securities are recommended to clients. This practice creates a situation
where the Registrant and/or representatives of the Registrant are in a position to materially
benefit from the sale or purchase of those securities. Therefore, this situation creates a
potential conflict of interest. As indicated above in Item 11.C. the Registrant has a personal
securities transaction policy in place to monitor the personal securities transaction and
securities holdings of each of Registrant’s Access Persons.
Item 12 Brokerage Practices
A. In the event that the client requests that the Registrant recommend a broker-dealer/custodian
for execution and/or custodial services (exclusive of those clients that may direct the Registrant
to use a specific broker-dealer/custodian), Registrant generally recommends that investment
advisory accounts be maintained at Fidelity and/or Pershing. Clients are not obligated to use the
recommended custodian and will not incur any extra fee or cost from the Registrant associated with
using a custodian not recommended by the Registrant. Depending on which custodian the client
selects to maintain their accounts, clients may experience differences in customer service,
transaction timing, the availability of sweep account vehicles and money market funds and other
aspects of investing. In certain instances, some of these differences could cause differences in
account performance. Before engaging Registrant to provide investment advisory services, the client
will be required to enter into a formal Investment Advisory Agreement with Registrant setting forth
the terms and conditions under which Registrant shall manage the client’s assets, and a separate
custodial/clearing agreement with each designated broker-dealer/ custodian.
Factors that the Registrant considers in recommending Fidelity and/or Pershing (or any other
broker-dealer/custodian) to clients include historical relationship with the Registrant, financial
strength, reputation, execution capabilities, pricing, research, and service. Although the
commissions and/or transaction fees paid by Registrant’s clients shall comply with the Registrant’s
duty to obtain best execution, a client may pay a commission that is higher than another qualified
broker-dealer might charge to affect the same transaction where the Registrant determines, in good
faith, that the commission/transaction fee is reasonable. In seeking best execution, the
determinative factor is not the lowest possible cost, but whether the transaction represents the
best qualitative execution, taking into consideration the full range of broker-dealer services,
including the value of research provided, execution capability, commission rates, and
responsiveness. Accordingly, although Registrant will seek competitive rates, it may not
necessarily obtain the lowest possible commission rates for client account transactions. The
brokerage commissions or transaction fees charged by the designated broker-dealer/custodian are
exclusive of, and in addition to, Registrant’s investment advisory fee. The Registrant’s best price
execution responsibility is qualified if securities that it purchases for client accounts are
mutual funds that trade at net asset value as determined at the daily market close.
1. Non-Soft Dollar Research and Additional Benefits
Although not a material consideration when determining whether to recommend that a client utilize
the services of a particular broker-dealer/custodian, Registrant can receive from Fidelity and/or
Pershing (or other broker-dealer/custodians, unaffiliated investment managers, Independent
Manager(s), investment platforms, vendors, and/or product/fund sponsors) without cost (and/or at a
discount) support services and/or products, certain of which assist the Registrant to better
monitor and service client accounts maintained at such institutions. Included within the support
services that can be obtained by the Registrant may be investment-related research, pricing
information and market data, software and other technology that provide access to client account
data, compliance and/or practice management-related publications, discounted or gratis consulting
services, discounted and/or gratis travel expenses/attendance at conferences, meetings, and other
educational and/or social events, marketing support (including a financial contribution toward the
cost of the Firm’s annual golf tournament), computer hardware and/or software and/or other products
used by Registrant in furtherance of its investment advisory business operations.
Certain of the support services and/or products that may be received may assist the Registrant in
managing and administering client accounts. Others do not directly provide such assistance, but
rather assist the Registrant to manage and further develop its business enterprise.
Registrant’s clients do not pay more for investment transactions effected and/or assets maintained
at a broker-dealer/custodian as a result of this arrangement. There is no corresponding commitment
made by the Registrant to any broker-dealers/custodians or any other entity to invest any specific
amount or percentage of client assets in any specific mutual funds, securities or other investment
products as a result of the above arrangements. ANY QUESTIONS: The Registrant’s Chief Compliance
Officer, Brett Stanton, remains available to address any questions that a client or prospective
client may have regarding the above arrangements and the corresponding conflicts of interest
presented by such arrangements.
2. The Registrant does not receive referrals from broker-dealers.
3. Directed Brokerage.
The Registrant does not generally accept directed brokerage arrangements (when a client requires
that account transactions be affected through a specific broker-dealer). In such client directed
arrangements, the client will negotiate terms and arrangements for their account with that
broker-dealer, and Registrant will not seek better execution services or prices from other
broker-dealers or be able to “batch” the client’s transactions for execution through other
broker-dealers with orders for other accounts managed by Registrant. As a result, the client may
pay higher commissions or other transaction costs or greater spreads, or receive less favorable net
prices, on transactions for the account than would otherwise be the case.
Please Note: In the event that the client directs Registrant to effect securities transactions for
the client’s accounts through a specific broker-dealer, the client correspondingly acknowledges
that such direction may cause the accounts to incur higher commissions or transaction costs than
the accounts would otherwise incur had the client determined to effect account transactions through
alternative clearing arrangements that may be available through Registrant. Higher transaction
costs adversely impact account performance. ANY QUESTIONS: The Registrant’s Chief
Compliance Officer, Brett Stanton, remains available to address any questions that a client or
prospective client may have regarding the above arrangement.
B. Transactions for each client account generally will be affected independently, unless the
Registrant decides to purchase or sell the same securities for several clients at approximately the
same time. The Registrant may (but is not obligated to) combine or “bunch” such orders to obtain
best execution, to negotiate more favorable commission rates or to allocate equitably among the
Registrant’s clients differences in prices and commissions or other transaction costs that might
have been obtained had such orders been placed independently. Under this procedure, transactions
will be averaged as to price and will be allocated among clients in proportion to the purchase and
sale orders placed for each client account on any given day. The Registrant shall not receive any
additional compensation or remuneration as a result of such aggregation.
Item 13 Review of Accounts
A. For those clients to whom Registrant provides investment supervisory services, account reviews
are conducted on an ongoing basis by the Registrant’s investment adviser representatives and/or
Chief Compliance Officer. All investment supervisory clients are advised that it remains their
responsibility to advise the Registrant of any changes in their investment objectives and/or
financial situation. All clients (in person or via telephone) are encouraged to review financial
planning issues (to the extent applicable), investment objectives and account performance with the
Registrant on an annual basis.
B. The Registrant may conduct account reviews on an other-than periodic basis upon the occurrence
of a triggering event, such as a change in client investment objectives and/or financial situation,
market corrections and client request.
C. Clients are provided, at least quarterly, with written transaction confirmation notices and
regular written summary account statements directly from the broker-dealer/custodian and/or program
sponsor for the client accounts. The Registrant may also provide a written periodic report
summarizing account activity and performance.
Item 14 Client Referrals and Other Compensation
A. As referenced in Item 12.A.1 above, the Registrant can receive economic benefits from Fidelity
and/or Pershing (or other broker-dealer/custodians, unaffiliated investment managers, Independent
Manager(s), investment platforms, and/or mutual fund sponsors), such as support services and/or
products without cost or at a discount. Registrant’s clients do not pay more for investment
transactions effected and/or assets maintained at a broker-dealer/custodian as a result of this
arrangement. There is no corresponding commitment made by the Registrant to a
broker-dealer/custodian or any other entity to invest any specific amount or percentage of client
assets in any specific mutual funds, securities or other investment products as a result of the
above arrangements. ANY QUESTIONS: The Registrant’s Chief Compliance Officer, Brett Stanton,
remains available to address any questions that a client or prospective client may have regarding
the above arrangements and the corresponding conflicts of interest presented by such arrangements
B. The Registrant engages promoters to introduce new prospective clients to the Registrant
consistent with the Investment Advisers Act of 1940, its corresponding. Rules, and applicable state
regulatory requirements. If the prospect subsequently engages the Registrant, the promoter shall
generally be compensated by the Registrant for the introduction. Because the promoter has an
economic incentive to introduce the prospect to the Registrant, a conflict of interest is
presented. The promoter’s introduction shall not result in the prospect’s payment of a higher
investment advisory fee to the Registrant (i.e., if the prospect was to engage the Registrant
independent of the promoter’s introduction).
C. In the event that a client advises Fusion Family that it requires the services of an
unaffiliated professional (i.e., attorney, CPA, insurance agent, etc.), and the client
correspondingly requests an introduction from Fusion Family, Fusion Family may make an introduction
to a professional who is also a Fusion Family client and/or referral source. Unless otherwise
expressly indicated, in writing, neither Fusion Family, nor any Fusion Family employee, shall
receive any compensation from the professional for the introduction. Nevertheless, because the
recommended professional is also a Fusion Family client, a conflict of interest arises because by
making the introduction, Fusion Family is assisting an individual or entity from whom it derives
(and anticipates in the future will derive) compensation as a Fusion Family client. In addition,
Fusion Family currently (and anticipates continuing to do so in the future) provides advisory
services to referral sources on a discounted basis. In the event that Fusion Family introduces a
client to an unaffiliated professional who is also a Fusion Family client, Fusion Family will
disclose the conflict to the client. No client is under any obligation to utilize the services of
any such recommend professional.
Item 15 Custody
The Registrant shall have the ability to have its advisory fee for each client debited by the
custodian on a quarterly basis. Clients are provided, at least quarterly, with written transaction
confirmation notices and regular written summary account statements directly from the
broker-dealer/custodian and/or program sponsor for the client accounts. The Registrant may also
provide a written periodic report summarizing account activity and performance.
Please Note: To the extent that the Registrant provides clients with periodic account statements or
reports, the client is urged to compare any statement or report provided by the Registrant with the
account statements received from the account custodian. The account custodian does not verify the
accuracy of the Registrant’s advisory fee calculation.
Certain clients have established asset transfer authorizations that permit the qualified custodian
to rely upon instructions from Fusion to transfer client funds or securities to third parties.
These arrangements are disclosed at Item 9 of Part 1 of Form ADV. However, in accordance with the
guidance provided in the SEC’s February 21, 2017, Investment Adviser Association No-Action Letter,
the affected accounts are not subject to an annual surprise CPA examination. In addition, in
limited circumstances, Registrant engages in certain custody-related services and/or practices
(i.e., trustee service), that are disclosed at Item 9 of Part 1 of Form ADV. These services and
practices are subject to an annual surprise CPA examination. ANY QUESTIONS: Fusion’s Chief
Compliance Officer, Brett Stanton, remains available to address any questions that a client or
prospective client may have regarding custody-related issues.
Item 16 Investment Discretion
The client can determine to engage the Registrant to provide investment advisory services on a
discretionary or non-discretionary basis. Before the Registrant assumes discretionary authority
over a client’s account, client shall be required to execute an Investment Advisory Agreement,
naming the Registrant as client’s attorney and agent in fact, granting the Registrant full
authority to buy, sell, or otherwise effect investment transactions involving the assets in the
client’s name found in the discretionary account.
Clients who engage the Registrant on a discretionary basis may, at any time, impose restrictions,
in writing, on the Registrant’s discretionary authority (i.e., limit the types/amounts of
particular securities purchased for their account, exclude the ability to purchase securities with
an inverse relationship to the market, limit or proscribe the Registrant’s use of margin, etc.).
Item 17 Voting Client Securities
A. The Registrant does not vote client proxies. Clients maintain exclusive responsibility for:
(1) directing the manner in which proxies solicited by issuers of securities owned by the client
shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers,
bankruptcy proceedings or other type events pertaining to the client’s investment assets.
Registrant will introduce a third-party service provider, Chicago Clearing Corp. (CCC), to assist
the client with participation in securities class action lawsuits pertaining to the assets under
Registrant’s management. Registrant would then provide trade data and other necessary information
to the third-party service provider, which would research class action cases and complete and
calculate the applicable proof of claim. The third-party service provider would then file the
applicable proof of claim with the claims administrator, verify payment received from the claims
administrator and distribute the payment to the client minus a fifteen percent (15%) contingency
fee of securities class action settlements collected. Otherwise, if clients choose not to engage in
the class action monitoring, filing, and recovery services provided by the third-party service
provider, clients will be exclusively responsible for voting in all legal proceedings or other type
events pertaining to the assets under Registrant’s management including, but not limited to, class
action lawsuits.
Fair Fund Process. In the event that the third-party service provider is required to process a Fair
Fund payment (i.e., a fund established by the SEC to distribute money to defrauded investors), the
third-party service provider shall deposit the gross settlement into the client’s account. However,
CCC, unlike its does for class action settlements, the third-party service provider will not deduct
its percentage fee from the client‘s gross settlement. Rather, the third-party service provider
shall accrue its Fair Fund fee and deduct it from the client’s subsequent class action
settlement(s).
B. Clients will receive their proxies or other solicitations directly from their custodian. Clients
may contact the Registrant to discuss any questions they may have with a particular solicitation.
Item 18 Financial Information
A. The Registrant does not solicit fees of more than $1,200, per client, six months or more in
advance.
B. The Registrant is unaware of any financial condition that is reasonably likely to impair its
ability to meet its contractual commitments relating to its discretionary authority over certain
client accounts.
C. The Registrant has not been the subject of a bankruptcy petition.
ANY QUESTIONS: The Registrant’s Chief Compliance Officer, Brett Stanton, remains available to
address any questions that a client or prospective client may have regarding the
above disclosures and arrangements.

