Disclosures
Important regulatory disclosures and legal information about Pragmatic Advisory's investment advisory services.
Firm Information
Pragmatic Advisory LLC is a registered investment adviser with the U.S. Securities and Exchange Commission (SEC). Registration does not imply a certain level of skill or training. Our Form ADV Part 2A (Brochure) and Part 2B (Brochure Supplements) are available upon request and describe our services, fees, and potential conflicts of interest.
Regulatory Registration
- SEC File Number: 801-XXXXXX
- CRD Number: XXXXXX
- State Registrations: As required
To verify our registration status, visit the SEC's Investment Adviser Public Disclosure (IAPD) website at adviserinfo.sec.gov.
Important Disclosures
Not FDIC Insured
Investment advisory services and securities are:
- Not FDIC insured (not insured by the Federal Deposit Insurance Corporation)
- Not bank guaranteed (not guaranteed by any bank or financial institution)
- Subject to investment risk, including possible loss of principal
Past Performance
Past performance is not indicative of future results. Investment returns and principal values will fluctuate, and investors may have a gain or loss when selling their investments. Historical performance data presented on our website or in our materials is provided for illustrative purposes only and should not be construed as a guarantee of future performance.
Investment Risks
All investments involve risk. The types of risks vary depending on the investment strategy and securities involved. Key risks include, but are not limited to:
- Market risk: The value of investments may decline due to general market conditions
- Interest rate risk: Changes in interest rates may affect the value of fixed-income investments
- Credit risk: Issuers may default on their obligations
- Inflation risk: Inflation may erode the purchasing power of returns
- Liquidity risk: Some investments may be difficult to sell quickly at fair prices
- Currency risk: International investments may be affected by currency fluctuations
- Concentration risk: Portfolios concentrated in specific sectors or securities may be more volatile
- Political and regulatory risk: Changes in laws or political conditions may affect investments
No Guarantee of Results
There can be no assurance that any investment strategy will achieve its objectives. Investment strategies are subject to various market, economic, and regulatory risks. Clients should carefully consider their investment objectives, risk tolerance, and time horizon before investing.
Client Relationship Summary (Form CRS)
What investment services and advice can you provide me?
Pragmatic Advisory offers investment advisory services to individuals, families, trusts, estates, and institutional clients. Our services include:
- Wealth management: Comprehensive financial planning and investment management
- Investment advisory: Discretionary and non-discretionary portfolio management
- Financial planning: Goal-based planning, retirement planning, estate planning
We typically provide continuous monitoring and ongoing advice for discretionary accounts. Account minimums may apply depending on the service type.
What fees will I pay?
Our fees depend on the services you select and may include:
- Asset-based fees: A percentage of assets under management (AUM), typically ranging from 0.50% to 1.50% annually
- Fixed fees: Flat fees for specific services such as financial planning
- Hourly fees: Charged for consulting or project-based work
You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.
What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have?
When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you.
Potential conflicts of interest include:
- Revenue-sharing arrangements with custodians
- Compensation for recommending certain products
- Proprietary products or affiliated services
How do your financial professionals make money?
Our financial professionals receive compensation based on:
- Salary or percentage of advisory fees
- Performance-based bonuses
- Revenue generated from client accounts
Do you or your financial professionals have legal or disciplinary history?
No. Visit Investor.gov/CRS for a free and simple search tool to research us and our financial professionals.
Additional Information
For additional information about our services, visit our website or request a copy of our Form ADV Part 2A (Brochure). To report a problem or request additional information, contact us at (212) 220-6659 or compliance@pragmaticadvisory.com.
Fiduciary Duty
As a registered investment adviser, Pragmatic Advisory has a fiduciary duty to act in the best interests of our clients. This means:
- Duty of care: We must make recommendations that are in your best interest based on your objectives, risk tolerance, and financial situation
- Duty of loyalty: We must not place our interests ahead of yours and must disclose all material conflicts of interest
- Duty to disclose: We must provide full and fair disclosure of all material facts
Compensation and Conflicts of Interest
Fee Structure
Our compensation may create conflicts of interest. For example:
- Asset-based fees may create an incentive to encourage clients to increase assets under management
- Fixed fees may create an incentive to minimize time spent on client matters
- Recommendations of products with higher fees may result in greater compensation
Soft Dollar Practices
We may receive research, data, or other services from broker-dealers in connection with client transactions. These "soft dollar" benefits may influence our choice of broker-dealers.
Referral Arrangements
We may pay or receive referral fees from other professionals. Any such arrangements are disclosed to clients in advance.
Custody and Safekeeping
Client assets are held by qualified custodians (such as Charles Schwab, Fidelity, or TD Ameritrade). Pragmatic Advisory does not take physical custody of client funds or securities, except for the limited purpose of deducting advisory fees from client accounts with proper authorization.
Clients receive account statements directly from their custodian at least quarterly. We encourage clients to carefully review these statements and compare them with any reports we provide.
Privacy and Confidentiality
We are committed to protecting the privacy and confidentiality of client information. Please refer to our Privacy Policy for detailed information about how we collect, use, and protect your personal information.
Business Continuity
Pragmatic Advisory maintains a business continuity plan designed to respond to events that significantly disrupt our business operations. Our plan addresses:
- Data backup and recovery procedures
- Alternative communication methods
- Remote work capabilities
- Mission-critical system recovery
In the event of a significant business disruption, we will notify clients as soon as practical and provide information about how to access their accounts.
Complaints and Questions
If you have a complaint or question about our services, please contact:
- Chief Compliance Officer
- Pragmatic Advisory
- One World Trade Center, 85th Floor
- New York, NY 10007
- Email: compliance@pragmaticadvisory.com
- Phone: (212) 220-6659
We take all complaints seriously and will respond promptly to your concerns.
Regulatory Resources
For more information about investment advisers and your rights as an investor, please visit:
- SEC Investor.gov: investor.gov
- FINRA BrokerCheck: brokercheck.finra.org
- CFP Board: cfp.net
- NAPFA: napfa.org
Updates to Disclosures
These disclosures may be updated periodically. Material changes will be communicated to clients through our website, email, or other appropriate means. The date of the last update is noted at the top of this page.
This disclosure document is provided for informational purposes only and does not constitute legal, tax, or investment advice. For specific guidance, please consult with your Pragmatic Advisory advisor or other qualified professional.
This document was last updated on January 15, 2025. If you have questions about this policy, please contact us at legal@pragmaticadvisory.com.
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