Beacon Capital Distributors Inc.

Client Brochure

This brochure provides information about the qualifications and business practices of Beacon Capital Distributors Inc. If you have any questions about the contents of this brochure, please do not hesitate to contact us at (330)294-0427 or by mail at 4000 Embassy Parkway Suite 208, Akron Ohio 44333. 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 Beacon Capital Distributors, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov.

Beacon Capital Distributors Inc.’s CRD number is: 169468

4000 Embassy Parkway Suite 208 Akron, Ohio 44333 330-665-1141 www.bcdadvisors.net Registration does not imply a certain level of skill or training. Version Date: 02/25/2016

Item 1: Cover Page

Item 2: Material Changes…………………………………………………………………………………………………………………………..

Item 3: Table of Contents………………………………………………………………………………………………………………………….

Item 4: Advisory Business………………………………………………………………………………………………………………………….

Item 5: Fees and Compensation………………………………………………………………………………………………………………..

Item 6: Performance Based Fees and Side-By-Side Management……………………………………………………………..

Item 7: Types of Clients……………………………………………………………………………………………………………………………..

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss…………………………………………………………

Item 9: Disciplinary Information………………………………………………………………………………………………………………..

Item 10: Other Financial Industry Activities and Affiliations………………………………………………………………………

Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading………………….

Item 12: Brokerage Practices……………………………………………………………………………………………………………………..

Item 13: Review of Accounts……………………………………………………………………………………………………………………..

Item 14: Client Referrals and Other Compensation……………………………………………………………………………………

Item 15: Custody……………………………………………………………………………………………………………………………………….

Item 16: Investment Discretion…………………………………………………………………………………………………………………

Item 17: Voting Client Securities………………………………………………………………………………………………………………..

Item 18: Financial Information…………………………………………………………………………………………………………………..

Item 19: Requirements for State Registered Advisors……………………………………………………………………………….

Table of Contents

Form ADV-Part2A-Firm Brochure

Item 2: Material Changes…………………………………………………………………………………………………………………………………………………………….. Item 3: Table of Contents------------------------------------------------------------------------------------------------------------------------------------. Item 4: Advisory Business------------------------------------------------------------------------------------------------------------------------------------- I.

A. Description of the Advisory Firm---------------------------------------------------------------------------------------------------------------1 B. Types of Advisory Services-----------------------------------------------------------------------------------------------------------------------1 i. Investment Supervisory Services--------------------------------------------------------------------------------------------------------1 ii. Asset Allocation------------------------------------------------------------------------------------------------------------------------------1 iii. Unsupervised Assets------------------------------------------------------------------------------------------------------------------------2 C. Selection of Third Party Advisors---------------------------------------------------------------------------------------------------------------2 D. Newsletter-------------------------------------------------------------------------------------------------------------------------------------------2 E. Financial Planning----------------------------------------------------------------------------------------------------------------------------------2 F. Outside Insurance Business----------------------------------------------------------------------------------------------------------------------2 G. Accounts under Management-------------------------------------------------------------------------------------------------------------------2

Item 5: Fees and Compensation---------------------------------------------------------------------------------------------------------------------------- 2

A. Fee Schedule----------------------------------------------------------------------------------------------------------------------------------------2 i. Investment Supervisory Services Fees-------------------------------------------------------------------------------------------2 ii. Unsupervised Assets Fees-----------------------------------------------------------------------------------------------------------2

B. Payment of Fees-------------------------------------------------------------------------------------------------------------------------------------3 C. Payment of Investment Supervisory Fees-----------------------------------------------------------------------------------------------------3 D. Newsletter Fees-------------------------------------------------------------------------------------------------------------------------------------3 E. Clients are responsible for Third Party Fees--------------------------------------------------------------------------------------------------3 F. Outside Compensation for the Sale of Securities to Clients------------------------------------------------------------------------------3

Item 6: Performance-Based Fees and Side by Side Management-----------------------------------------------------------------------------------3 Item 7: Types of Clients----------------------------------------------------------------------------------------------------------------------------------------3

A. Minimum Account Size--------------------------------------------------------------------------------------------------------------------------- 4 Item 8: Methods of Analysis, Investment Strategies and Risk of Investment Loss--------------------------------------------------------------4

A. Methods of Analysis and Investment Strategies--------------------------------------------------------------------------------------------4 i. Methods of Analysis-----------------------------------------------------------------------------------------------------4 ii. Investment Strategies---------------------------------------------------------------------------------------------------4

B. Material Risks Involved---------------------------------------------------------------------------------------------------------------------------4

i. Methods of Analysis----------------------------------------------------------------------------4

ii. Investment Strategies---------------------------------------------------------------------------------------------------4 C. Risks of Specific Securities Utilized-------------------------------------------------------------------------------------------------------------5

Item 9: Disciplinary Information------------------------------------------------------------------------------------------------------------------------------5 Item 10: Other Financial Industry Activities and Affiliations------------------------------------------------------------------------------------------5

A. Registration as a Broker/Dealer or broker Dealer Representative----------------------------------------------------------------------5 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trader----------------------5 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests-----------------------------5 D. Selection of Other Advisors or Managers and How this Advisor is compensated for those Selections------------------------5

Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. --------------------------------------------6

A. Code of Ethics--------------------------------------------------------------------------------------------------------------------------------------- 6

B. Recommendations Involving Material Financial Interests------------------------------------------------------------6 C. Investing Personal Money in the Same Securities as Client------------------------------------------------------------------------------6 D. Trading Securities At/Around the Same Time as Client’s Selections-------------------------------------------------------------------6

ii.

Item 12: Brokerage Practices---------------------------------------------------------------------------------------------------------------------------------6

A. Factors Used to Select Custodians and/or Broker/Dealers-------------------------------------------------------------------------------6 i. Research and Other Soft Dollar Benefits-----------------------------------------------------------------------------------------7 ii. Brokerage for Client Referrals------------------------------------------------------------------------------------------------------7 iii. Clients Directing Which Broker/ Dealer/Custodian to Use------------------------------------------------------------------7

B. Aggregating (Block) Trading for Multiple Client Accounts--------------------------------------------------------------------------------7 Item 13: Reviews of Accounts--------------------------------------------------------------------------------------------------------------------------------7

A. Frequency and Nature of Periodic Reviews and Who Makes those Reviews--------------------------------------------------------7 B. Factors that will trigger a non-periodic review of Client accounts---------------------------------------------------------------------7 C. Content and Frequency of Regular Reports Provided to Clients------------------------------------------------------------------------7

Item 14: Client Referrals and Other Compensation-----------------------------------------------------------------------------------------------------7

A. Economic benefits provided by third parties for advice rendered to Clients (Includes Sales Awards Other Prizes)-------7 B. Compensation to non-advisory personnel for Client referrals--------------------------------------------------------------------------8

Item 15: Custody-------------------------------------------------------------------------------------------------------------------------------------------------8 Item 16: Investment Discretion------------------------------------------------------------------------------------------------------------------------------8 Item 17: Voting Client Securities (proxy voting) ---------------------------------------------------------------------------------------------------------8 Item 18: Financial Information--------------------------------------------------------------------------------------------------------------------------------8

A. Balance Sheet----------------------------------------------------------------------------------------------------------------------------------------8 B. Financial Conditions Reasonably likely to Impair Ability to Meet Contractual Commitments to Clients----------------------8 C. Bankruptcy Petitions in Previous Ten Years--------------------------------------------------------------------------------------------------8

Item 19: Requirements for State Registered Advisors--------------------------------------------------------------------------------------------------8

A. Managements background and formal education------------------------------------------------------------------------------------------8 B. Outside Business Activity-------------------------------------------------------------------------------------------------------------------------8 C. Performance Based Fees--------------------------------------------------------------------------------------------------------------------------8 D. Disclosure of Material Facts----------------------------------------------------------------------------------------------------------------------8 E. Managements relationship to issuers----------------------------------------------------------------------------------------------------------8 F. New Hampshire advisor requirements--------------------------------------------------------------------------------------------------------8

Item 1: Cover Page Item 2: Material Changes A. Kevin Wray has been appointed as an IAR in the state of Michigan. B. Keith Harris has been appointed as an IAR in the state of Illinois. C. Patrick M. Scholz has been appointed as an IAR in the state of CA. C. BCD Advisors has moved its home office from 3560 West Market Street Suite 305B Akron, Ohio 44333 to 4000 Embassy Parkway Suite 208 Akron, Ohio 44333. D. Assets held at the custodian Trade PMR total $1.5MM, $12.8MM at Beacon Capital Management, $272K at Gradient Investments LLC and $593K at Matson Money, Inc.

Item 3: Table of Contents ITEM 4: ADVISORY BUSINESS

A. Description of the Advisory Firm Beacon Capital Distributors Inc. started doing business in January 2014 in the state of Ohio as an S-Corporation. The principal owner is Robert David Kilivris.

B. Types of Advisory Services Beacon Capital Distributors, Inc. (hereinafter “BCD”) offers the following services to advisory clients: I. Investment Supervisory Services BCD offers third party portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance to each client. BCD creates a New Account Package for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Thus, BCD offers an Investor Profile. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring BCD evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. II. Asset Allocation Service BCD will recommend investment advisory accounts involving Investment Supervisory Services. Each portfolio will be selected to meet a particular investment goal, which BCD has determined is suitable to the client's circumstances. Each portfolio will be selected to meet a particular investment goal, which BCD has determined is suitable to the client's circumstances. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income). • BCD and its representatives will obtain sufficient client information to be able to provide individualized investment advice to the client. At least annually, BCD or its representative will contact the client to determine whether there have been any changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. • BCD is not responsible for accurate reporting if you fail to provide us accurate information. Client must promptly submit to BCD in writing any changes to the Client Profile, Individual Account Application, or any changes to any information you provide us regarding their account. On a quarterly basis BCD will notify the client in writing of any changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. These quarterly notifications will include the means through which contact shall be made to BCD;

P a g e | 1 • BCD will be reasonably available to consult with the client. • Each client is able to impose reasonable investment restrictions on the management of their account. • Each client will receive a quarterly statement with a description of all account activity; and, • Each client will retain certain indicia of ownership of the securities and funds in the account, e.g., the ability to withdraw securities, vote securities, among others. BCD offers the following services and clients are instructed to review each description to ensure they are comfortable with the

style of management they select.

III. Unsupervised Assets

From time to time, advisory clients may have pre-existing investments that they do not want actively managed. These clients

may request that BCD incorporate these holdings into a single account to facilitate future management and reporting. BCD will

initially consolidate these unsupervised assets into a single account within the client's existing portfolio. These assets will not be

actively managed although they will be incorporated into the client's quarterly summary reports prepared by BCD.

C. Selection of Third Party Advisors

BCD will offer third party advisors to provide an open architecture of portfolio managers, investment research, economic

analysis and portfolios tailored to the individual needs of the client. A risk profile questionnaire will be administered for each

client. Clients may impose restrictions on investing in certain securities. BCD may be compensated via a fee share from the

Third Party Advisors to which it directs it to clients. This relationship will be disclosed in in each contract between BCD and the

Third Party Advisor. The fees shared will not exceed any limit imposed by any regulatory agency. Before selecting other advisors

for clients, BCD will always ensure those other advisors are properly licensed or registered or on notice where the client resides.

D. Newsletter

BCD may provide a newsletter for their clients distributed on the www.bcdadvisors.net website.

E. Financial Planning

Will consist of and include, initial financial advice and quarterly updates on portfolio management to determine client’s suitability. The advice is based upon data gathering of information that would affect the client’s current financial situation and goals. All of which is the responsibility of the client to provide. This information will allow the Investment Advisor Representative to determine the suitability of their account. This is most important step in the financial planning process. This will help the IAR to design and recommend an initial investment portfolio. Financial Planning services are included in the advisory fees and will be provided for clients seeking portfolio management services form the advisor. No separate fee will be charged for this service. A conflict of interest exists between the advisor and the client who is under no obligation to act upon the advisors recommendations. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the BCD or the advisor.

P a g e | 2

Outside Insurance Activity

Robert David Kilivris or his affiliates acting in the capacity as a registered Representative (RR) with a broker dealer and may

recommend insurance products that pay a commission, pay bonuses and receive (“tail”) commissions from mutual funds, in

the form of 12b-1 fees. This practice gives the RR an incentive to recommend these investment products based upon

compensation received, rather than on the client’s needs.

F. Amounts under Management: BCD has $1,459,272 of discretionary and $13,665,345 of non-discretionary assets as of 2/01/2016. Item 5: Fees and Compensation

A. Fee Schedule

B. Client will compensate the Advisor for all services furnished under this agreement by the payment of fees (Advisor Fees)

in accordance with the provisions of the Section and the Client Fee Schedule below. These fees will be based on the

aggregate percentage of assets per household as follows:

1. 1.25% per year on the first $500,000

2. 1.05% per year on amounts in excess of $500,000

3. .80% per year on amounts exceeding $1,000,000

4. .50% per year on amounts exceeding $2,000,000

Advisor Fees

Advisor Fee % Program Fee % Total Fee % Client Initials Joint Client Initials

This Management Fee will be deducted monthly or quarterly in advance or in arrears depending upon client situation, and

clients may terminate their contracts with ten days’ written notice. For fees charged in arrears, no refund policy is necessary.

For fees charged in advance, refunds are given on a prorated basis, based on the number of days remaining in a quarter at the

point of termination. Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the

advisory contract. Advisory fees are withdrawn directly from the client’s accounts with client written authorization.

Schedule of Fee Deduction:

Quarterly Fee Monthly Fee Billing in Arrears Billing in Advance

Client understands and agrees that Client may incur certain charges imposed by third party advisory managers other than the

advisor in connection with investments made through the Account, including but limited to all transaction costs, management

fees, mutual fund 12b(1) distribution fees, certain deferred sales charges on previously purchased mutual funds and IRA and

Qualified Retirement Plan Fees. In addition, advisory fees charged to clients will be reasonable in accordance with services

provided, based upon the advisors experience and expertise and the sophistication and bargaining power of the client. The

advisor will disclose to client of lower fees for comparable services that may be available from other sources.

II. Unsupervised Assets Fees For these assets, BCD may charge a minimal administrative fee of 0.10% annually. However, once these unsupervised assets are

sold they will be reclassified as managed assets and fees will be charged in accordance with stated above; BCD Advisory fees.

P a g e | 3

C. Payment of Fees

II. Payment of Investment Supervisory Fees

Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Fees are paid monthly or quarterly in advance or in arrears. D. Newsletter Fees BCD does charge clients for providing a newsletter on the www.bcdadvisor.com website or under any other forms of distribution.

E. Clients Are Responsible For Third Party Fees

Clients are responsible for the payment of all third party fees (i.e. custodian fees, mutual fund fees, transaction fees, etc.).

Those fees are separate and distinct from the fees and expenses charged by BCD. Please see Item 12 of this brochure regarding

broker dealers.

F. Prepayment of Fees

BCD collects fees in advance and in arrears. Fees that are collected in advance will be refunded based on the prorated amount

of work completed at the point of termination and the total days during the billing period. Fees will be returned within fourteen

days to the client via check or return to credit card.

G. Outside Compensation For the Sale of Securities to Clients

BCD and its supervised persons will NOT accept compensation for the sale of securities or other investment products, including

services fees from the sale of mutual funds to its clients. These fees will credit to clients account and/or directed to offset

custodian or any other ancillary costs.

ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT BCD does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the

assets of a client.

ITEM 7: TYPES OF CLIENTS BCD generally provides advisory supervisory services to the following: Types of Clients: • Individuals • High-Net-Worth Individuals

A. Minimum Account Size BCD requires a client to have a minimum account of $50,000, which may include all household accounts. This RIA believes clients maybe better served by placing lesser amounts directly in mutual funds or other investment products. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF INVESTMENT LOSS

A. Methods of Analysis and Investment Strategies:

I. Methods of Analysis

P a g e | 4

BCD’s recommends methods of analysis include fundamental analysis and Modern Portfolio Theory.

• Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. • Modern Portfolio Theory is an approach that attempts to quantify and control portfolio risk through diversification.

II. Investment Strategies

BCD will recommend both Long Term and Short Term Trading strategies. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.

B. Material Risks Involved

I. Methods of Analysis

• Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. • Modern Portfolio Theory emphasizes the relationship among asset classes, instead of particular stocks. This theory holds that specific risk can be diversified away by building portfolios of assets whose returns are not correlated. This diversification allows investors to reduce the risk in a portfolio while simultaneously increasing expected returns.

II. Investment Strategies

• Long Term Trading is designed to capture market rates of both return and risk. Frequent trading, when done, can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. • Short Term Trading generally holds greater risk and clients should be aware that there is a chance of material risk of loss using any of those strategies. . Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.

C. Risks of Specific Securities Utilized

BCD generally seeks investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client,

should be prepared to bear.

ITEM 9: DISCIPLINARY INFORMATION There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business

or the integrity of our management.

Item 10: Other Financial Industry Activities and Affiliations.

A. Registration as a Broker/Dealer or Broker/Dealer Representative

P a g e | 5

Robert David Kilivris is not licensed as registered representative with. a FINRA registered broker dealer. BCD always acts in the best interest of the client. Clients are in no way required to implement a financial plan through BCD Advisors in their capacity as Investment Advisor Representatives. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither BCD nor its representatives are registered as a FCM, CPO, or CTA.

C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Associated persons of BCD are insurance agents and from time to time, they will offer clients advice or products from these

activities. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as

commissionable products can conflict with the fiduciary duties of a registered investment adviser. BCD always acts in the best

interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to

implement a financial plan created or provided through a third party by any representative of BCD. Any material conflicts of

interest have been disclosed in this brochure.

D. Selection of Other Advisors or Managers and How This Adviser is compensated for Those Selections BCD may direct clients to the third party money managers; BCD will be compensated via a fee share to which it directs those

clients. This relationship will be disclosed in each contract between BCD and the third party manager. The fees shared will not

exceed any limit imposed by any regulatory agency. Before selecting other advisors for clients, BCD will always ensure those

other advisors are properly licensed or registered as investment advisor. This creates a conflict of interest in that BCD has an

incentive to direct clients to the third party money managers that provide BCD with a larger fee split. BCD will always act in the

best interests of the client, including when determining which third party manager to recommend to clients. Beacon Capital

Management is a third party manager who BCD as an agreement to offer their services.

ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. Code of Ethics We have a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Our Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests BCD does not recommend that clients buy or sell any security in which a related person to BCD has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of BCD may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of BCD to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. BCD will always document any transactions that could be construed as conflicts of interest and will always transact client business before their own when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of BCD may buy or sell securities for themselves at or around the same time as clients. This

may provide an opportunity for representatives of BCD to buy or sell securities before or after recommending securities to

clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a

conflict of interest. BCD will always transact client’s transactions before its own when similar securities are being bought or sold

P a g e | 6

ITEM 12: BROKERAGE PRACTICES

A. Factors Used to Select Custodians and/or Broker/Dealers For clients in need of brokerage or custodial services, and depending on client circumstances and needs, BCD may recommend the use of one of several broker dealers, provided BCD can meet its fiduciary obligation of best execution. BCD clients must evaluate these brokers before opening an account. The factors considered by BCD when making these recommendations are the Broker’s ability to provide professional services, BCD’s experience with the broker, the broker's reputation, and the broker's quality of execution services and costs of such services, among other factors. Clients are not under any obligation to affect trades through any recommended broker. BCD will participate in Trade PMR custodial services for customized portfolios and Envestnet Solutions where clients’ accounts

will be in custody at Pershing LLC. These custodian services are offered to independent investment advisers, such as BCD. As

part of these programs, BCD receives benefits that it would not receive if it did not offer investment advice.

I. Research and Other Soft-Dollar Benefits We anticipate that some of our Third Party Advisors and Custodial partners will assist BCD in oversight and administering clients’ accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of BCD's fees from its clients’ accounts, and assist with back-office functions, recordkeeping and client reporting. Many of these services generally may be used to service all or a substantial number of BCD's accounts. Recommended brokers also make available to BCD other services intended to help BCD to further develop its business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. BCD does not, however, enter into any commitments with the brokers for transaction levels in exchange for any services or

products from brokers. While as a fiduciary, BCD endeavors to act in its clients’ best interests. While BCD's requirement that

clients maintain their assets in accounts at Trade PMR and/or Envestnet may be based in part on the benefit to BCD, and of the

availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody a brokerage

services provided by the brokers, which may create a potential conflict of interest

II. Brokerage for Client Referrals BCD receives no referrals from a broker-dealer or third party in exchange for using

that broker-dealer or third party services provided by the brokers, who may create a potential conflict of interest.

III. Clients Directing Which Broker/Dealer/Custodian to Use BCD allows clients to direct brokerage. BCD may be unable to achieve most favorable execution of client transactions if clients

choose to direct brokerage. This may cost clients’ money because without the ability to direct brokerage BCD may not be able

to aggregate orders to reduce transactions costs resulting in higher brokerage commissions and less favorable prices. Not all

investment advisers allow their clients to direct brokerage.

B. Aggregating (Block) Trading for Multiple Client Accounts BCD maintains the ability to block trade purchases across accounts. Block trading may benefit a large group of clients by

providing BCD the ability to purchase larger blocks resulting in smaller transaction costs to the client. Declining to block trade

can cause more expensive trades for clients.

ITEM 13: REVIEWS OF ACCOUNTS A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client accounts are reviewed at least quarterly by Robert David Kilivris (CCO). I am instructed to review clients’ accounts with regards to their investment policies and risk tolerance levels. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as

retirement, termination of employment, physical move, or inheritance).

P a g e | 7

C. Content and Frequency of Regular Reports Provided to Clients Each client will receive at least quarterly a written report detailing the client’s account, which may come from the custodian.

ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) BCD may receive a percentage of a management fee, directly or indirectly from any third party for advice rendered to BCD clients. B. Compensation to Non –Advisory Personnel for Client Referrals BCD enters into contractual arrangements with Independent Investment Advisors and independent financial professionals pursuant to which representatives of their firms (“Solicitors”) may offer our services to the public. These compensated person(s) are properly registered as solicitors and follow the requirements under CCR 260.236(c) (2). Through these arrangements, BCD may pay a cash referral fee to the Solicitor and/or their firm based upon a percentage of our investment management fee. The amount of the referral fee may be up to 90% of the amount of the investment management fee received from you. In connection with these arrangements, BCD will comply with Rule 206(4)-3 under the Advisers Act. The referral fee is paid pursuant to a written agreement, which is retained by both your Financial Advisor, as the Solicitor, and

BCD. This information is disclosed to you prior to or at the time of entering into an investment management agreement with

BCD. Solicitors, on their own and not related in any way to their solicitors’ agreements with BCD and not on BCD’s

recommendation, also sell insurance, annuities, mutual funds, stocks, bonds, and/or limited partnerships to clients. These

solicitors may receive separate and typical commissions on the sale of these products.

BCD may pay a portion of the investment management fee to other affiliated or non-affiliated parties who assist with certain

administrative tasks associated with the management of your account.

ITEM 15: CUSTODY BCD does not take custody of client accounts at any time. Custody of client’s accounts is held primarily at the custodians; Trade

PMR, Envestnet (Pershing) or TD Ameritrade. If the client chooses to be billed directly by the Custodian, BCD would have

constructive custody over that account and must have written authorization from the client to do so. Clients will receive all

required account statements and billing invoices that are required in each jurisdiction, and they should carefully review those

statements for accuracy.

ITEM 16: INVESTMENT DISCRETION For those clients accounts where BCD advisors provides ongoing supervision, the client has given BCD written discretionary authority over the client’s accounts with respect to securities to be bought or sold and the amount of securities to be bought or sold. BCD also has discretionary authority to determine the broker or dealer used in the purchase or sale of securities in client’s accounts. Details of this relationship are fully disclosed to the client before any advisory relationship has commenced. The client provided BCD discretionary authority via a limited power of attorney between the client and the custodian. ITEM 17: VOTING CLIENT SECURITIES (PROXY VOTING) BCD will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the

security or the custodian. Clients should direct all proxy questions to the issuer of the security.

P a g e | 8

ITEM 18: FINANCIAL INFORMATION

A. Balance Sheet. BCD is required to provide an independent audit provided under Article 2 of SEC Regulation S-X to clients.

B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither BCD

nor its management have any financial conditions that is likely to reasonably impair our ability to meet contractual commitments to clients.

C. Bankruptcy Petitions in Previous Ten Years BCD has not been the subject of a bankruptcy petition in the last ten year D. The Investment advisor does not have discretionary authority or custody of client’s funds or require or solicit

prepayment of more than $500 in fees per client six months in advance.

Item 19: Requirements for State-Registered Advisers

A. Robert David Kilivris is the President/CEO/CCO of BCD. Formal education and industry related history

can be found on ADV Part 2B.

B. Sole practice and time are devoted to giving and offering advice to other advisors, registered

representatives and clients.

C. BCD is not compensated nor provides performance-based compensation that may create an incentive for

the adviser to recommend an investment that may carry a higher degree of risk to the client.

D. BCD or its Principal has never been found liable in arbitration or civil claims or found liable in a self-

regulatory or administrative proceeding.

E. BCD or its Principal has no affiliations with any issuer of securities.

F. New Hampshire requires a solicitor of New Hampshire residents to be registered as an investment advisor

or investment advisor representative.

P a g e | 8