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					                                                                                                                                            www.GVWealth.com




                Firm Brochure
                 Form ADV Part 2A

                 March 31, 2011




555 California Street, Suite 313, San Francisco, California 94104 • (415) 568-2150 • Info@GVWealth.com


This brochure provides information about the qualifications and business practices of Green Valley Wealth Advisors LLC (Green Valley Wealth Advisors). If you have any
questions about the contents of this brochure, please contact us at (415) 568-2150 or visit our website at GVWealth.com. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission (SEC), California’s Department of Corporations, or any other state securities authority.

Green Valley Wealth Advisors LLC refers to itself as a Registered Investment Advisor in materials distributed to current and prospective clients. As a registered investment
advisor with the state of California, Green Valley Wealth Advisors is subject to the rules and regulations adopted by the state and the SEC under the Investment Advisers Act
of 1940, as amended (the Advisers Act). Registration as an investment adviser is not an indication that Green Valley Wealth Advisors or its directors, officers, employees or
representatives have attained a particular level of skill, ability or training.

Additional information about Green Valley Wealth Advisors LLC is available on the SEC’s website at www.adviserinfo.sec.gov.
Material Changes
There has been no material or adverse changes to Green Valley Wealth Advisors’ business
practices that would require disclosure at this time. The firm is solely making an annual update, the
first using this narrative approach.

Annual Update
The Material Changes section of this brochure will be updated annually when material changes
occur to the firm’s business practices. The last update was made January 8, 2010.

Changes since Last Update
The U.S. Securities and Exchange Commission issued a final rule in July 2010 requiring advisers to
provide Form ADV Part 2 as a Firm Brochure in narrative plain English format. The new rule
specifies mandatory sections and organization. Given this new requirement, we have revised our
Form ADV Part 2 to reflect this new rule.




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Table of Contents
Material Changes................................................................................................................................... ii
   Annual Update ................................................................................................................................... ii
   Changes since Last Update ............................................................................................................. ii
Advisory Business ................................................................................................................................. 1
   Firm Description ................................................................................................................................ 1
       Fee-Only ........................................................................................................................................ 1
       Fiduciary Standard ........................................................................................................................ 1
   Principal Owner & Structure .............................................................................................................. 1
   Services Provided .............................................................................................................................. 1
   Investment Supervisory Services (Investment Management) .......................................................... 2
   Wealth Management ......................................................................................................................... 2
   Financial Planning ............................................................................................................................. 3
   Third Party Advisors........................................................................................................................... 3
       Model Portfolios............................................................................................................................. 3
   Personalized Counseling .................................................................................................................. 4
   Managed Assets................................................................................................................................ 5
Fees and Compensation ....................................................................................................................... 5
   Wealth and Investment Management Fee (Wrap Fee Program) ..................................................... 5
       Wrap Account Fee Structure ......................................................................................................... 6
       Fee Billing ...................................................................................................................................... 6
       Negotiability ................................................................................................................................... 6
       Valuation of Account ..................................................................................................................... 6
       Minimums ...................................................................................................................................... 6
       Amendment of Fee Agreement..................................................................................................... 7
       Assignment .................................................................................................................................... 7
   Planning Advice Fee .......................................................................................................................... 7
       Financial Planning Advice Fees .................................................................................................... 7
       College / Retirement Savings Plan Advice Fee ............................................................................ 7
   Payment of Fees................................................................................................................................ 7
       Payment of Investment Management Fees .................................................................................. 7
       Payment of Financial Planning Fees ............................................................................................ 7
   Other Fees ......................................................................................................................................... 8




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       Custodian Fees ............................................................................................................................. 8
       Fund Fees...................................................................................................................................... 8
       Unbundled Fees ............................................................................................................................ 8
       Relative Cost of Services .............................................................................................................. 8
       Margin Accounts ........................................................................................................................... 8
   Termination of Agreement ................................................................................................................. 9
       Past Due Accounts ........................................................................................................................ 9
   Compensation for Sale of Investment Products ............................................................................. 10
Performance-Based Fees and Side-By-Side Management ............................................................... 10
Types of Clients ................................................................................................................................... 10
Methods of Analysis, Investment Strategies, Sources of Information and Risk of Loss ................... 10
   Methods of Analysis ........................................................................................................................ 10
   Sources of Information .................................................................................................................... 10
   Investment Strategies ...................................................................................................................... 11
   Risks of Investing............................................................................................................................. 11
   Firm Risk Controls ........................................................................................................................... 11
Disciplinary Information ....................................................................................................................... 12
Other Financial Industry Activities and Affiliations .............................................................................. 12
   Activities ........................................................................................................................................... 12
   Affiliations and Arrangements ......................................................................................................... 12
       Third Party Providers ................................................................................................................... 12
       Third Party Advisors .................................................................................................................... 13
   Referrals ........................................................................................................................................... 13
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................... 13
       Code of Ethics ............................................................................................................................. 13
       Participation or Interest in Client Transactions (Personal Trading) ............................................ 14
Brokerage Practices ............................................................................................................................ 14
       Best Execution ............................................................................................................................. 14
       Recommendation of a Broker-Dealer (Custodian)..................................................................... 15
       Brokerage Discretion................................................................................................................... 15
       Client Directed Brokerage ........................................................................................................... 16
       Trade Allocation and Aggregation .............................................................................................. 16
       Soft Dollars .................................................................................................................................. 16
       Initial Public Offerings.................................................................................................................. 17



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       Trade Errors ................................................................................................................................. 17
       Class Action Lawsuits ................................................................................................................. 17
Review of Accounts ............................................................................................................................. 17
   Periodic Reviews ............................................................................................................................. 17
   Review Triggers ............................................................................................................................... 18
   Regular Reports............................................................................................................................... 18
       Third Party Advisor Programs ..................................................................................................... 18
Client Referrals and Other Compensation .......................................................................................... 18
       Incoming Referrals ...................................................................................................................... 18
       Referrals to Other Professionals ................................................................................................. 19
Custody ................................................................................................................................................ 19
   Account Statements ........................................................................................................................ 19
   Statements Provided by Green Valley Wealth Advisors ................................................................. 19
Investment Discretion .......................................................................................................................... 19
   Discretionary Authority for Trading.................................................................................................. 19
   Limited Power of Attorney ............................................................................................................... 19
Voting Client Securities ........................................................................................................................ 20
       Proxy Voting Policy ...................................................................................................................... 20
Financial Information ........................................................................................................................... 20
   Financial Condition .......................................................................................................................... 20
       Balance Sheet ............................................................................................................................. 20
Requirements for State-Registered Advisers...................................................................................... 20
Business Continuity Plan ..................................................................................................................... 21
       General ........................................................................................................................................ 21
       Disasters ...................................................................................................................................... 21
       Alternate Offices .......................................................................................................................... 21
Information Security Program.............................................................................................................. 21
   Information Security......................................................................................................................... 21
   Privacy Notice .................................................................................................................................. 21
Questions or Inquiries?........................................................................................................................ 22




                                                                                                                                                              v
Advisory Business
Firm Description
Green Valley Wealth Advisors LLC is an independent registered investment advisory (RIA) firm that
provides personal wealth management, investment advice, and financial planning services.

Green Valley Wealth Advisors is based in San Francisco, California. We help manage our clients’
financial affairs by providing customized investment portfolio management and strategic oversight
so that our clients are better positioned to reach their long-term wealth management objectives.

We offer domestic and global investment opportunities and wealth management services directly
to individuals and their families; trusts; charitable organizations; corporations and other business
entities.

We also provide fiduciary counseling to businesses regarding their pension and profit sharing
plans. And, we manage model portfolios and sub-advise investment accounts for other investment
providers such as other RIAs, broker-dealers, and banks.

Fee-Only
We are a fee-only RIA, which means we charge our clients directly for the advice and/or ongoing
management we provide to them. We provide investment management on a percentage-of-assets
managed basis and financial planning services on an hourly or a flat-fee basis. We receive no
commission compensation and sell no proprietary products. We believe this structure minimizes
conflicts of interest, and strengthens our advocacy in putting our clients’ needs first.

Fiduciary Standard
We are committed to acting as our clients’ fiduciary, which is a legal relationship of trust. We look
to provide the best advice possible without influence from outside interests. Our clients’ needs are
always our highest priority.

Principal Owner & Structure
Green Valley Wealth Advisors is a limited liability company (LLC) formed under the laws of the
State of California in 2009, and is solely owned by Eric Linser, the firm’s Chief Investment Officer
and Managing Member of the LLC. Green Valley is registered as an Investment Advisor in and with
the State of California.

Services Provided
Highlighted below are the typical wealth management arrangements offered to clients:

      Investment Supervisory Services (otherwise known as Investment Management, Portfolio
       Management, or Asset Management)
      Wealth Management (encompassing both discretionary Investment Management and
       Financial Planning)
      Financial Planning



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Prior to engaging Green Valley Wealth Advisors to provide any of the foregoing services, the client
will be required to enter into one or more written agreements setting the terms and conditions
under which Green Valley Wealth shall render its services.

Investment Supervisory Services (Investment Management)
Green Valley provides investment advice to its clients under a discretionary arrangement wherein a
client grants Green Valley Wealth the authority to supervise, invest and trade client assets placed
under its management in a manner consistent with established client objectives and guidelines.

Investment Supervisory Services include, but are not limited to, the following:

      Investment strategy
      Personalized investment structure
      Asset allocation
      Asset selection
      Risk tolerance
      On-going portfolio monitoring and rebalancing

We may create an investment portfolio consisting of individual stocks and bonds; exchange traded
funds; mutual funds; and other securities.

We emphasize continuous and regular supervision of our clients’ accounts for the purpose of
wealth accumulation, preservation, and estate planning. Furthermore, we will work with our clients
to identify their investment goals and timeframe as well as their risk tolerance in order to create an
initial portfolio allocation designed to complement our clients' financial priorities and objectives,
including goals such as education funding, major purchases, starting a business, retirement
planning and wealth transfer.

We do not retain custody of our clients’ assets. A reputable, independent custodian will hold our
clients’ assets.

We will provide investment supervisory services as part of an on-going wealth management
relationship inclusive of financial planning, or as a stand-alone service offering.

Wealth Management
Wealth management is defined, for our disclosure purposes, as discretionary investment
management coupled with financial planning. This service includes financial planning,
recommendations, implementation, and ongoing asset management and monitoring.

We work in conjunction with our clients and their other advisors (be it a tax accountant, estate
planning attorney, insurance agent, etc.) to make sure that we are working together to best serve
them.

We also advise and provide recommendations on assets that are outside of our control, such as
retirement plans and executive benefit plans. Recommendations are given in areas specific to
each client’s needs.



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Financial Planning
Financial planning provides our clients with objective assistance in organizing their personal or
corporate financial affairs to more readily achieve their goal. Financial planning may include
identification of financial problems, cash flow and budget management, risk exposure review,
investment management, education funding, retirement planning, estate planning, charitable
goals, small business planning issues, employee benefits, special needs planning, or other issues
specific to the client.

Green Valley Wealth will provide ongoing guidance on general financial matters. While we make no
warranty or implied guarantee to be a qualified expert in all financial areas, we will, to the best of
our ability, offer thoughtful advice on any financial issues as requested by the client. If appropriate,
we may refer the client to other outside professionals for more specific expertise, and will gladly
make the appropriate introductions. Green Valley Wealth does not cover the cost of engaging nor
warrants the advice provided by outside professionals.

Financial planning engagements may be upgraded to a more comprehensive Wealth Management
arrangement for implementation of the resultant recommendations.

Note: nothing we do constitutes tax or legal advice.

Third Party Advisors
In addition to offering services directly to our clients, Green Valley Wealth Advisors also provides
investment management services to other advisors.

These investment services are offered through and sponsored by independent, third party
investment firms, other registered investment advisory firms, and investment management
consultants (collectively, Third Party Advisors).

Green Valley Wealth Advisors receives compensation pursuant to its non-exclusive agreements
with these Third Party Advisors for the ongoing management of the investment models we create.
We will also receive compensation, in the form of a management fee or a similar arrangement, for
introducing investors to Green Valley Wealth’s offerings with these Third Party Advisors’ programs.
Green Valley Wealth Advisors’ compensation with these outside firms is based on negotiated
contractual agreements between Green Valley Wealth Advisors and these outside firms. We are
not affiliated with these Third Party Advisors.

Model Portfolios
Green Valley Wealth Advisors manages model portfolios for other firms’ investment advisory
platforms (and online investment services). We contribute our intellectual property and modeling
techniques. These innovative online services provide individual investors the ability to search for
and hire independent investment managers like Green Valley Wealth with an initial investment as
low as $10,000 versus our typical account minimum of $250,000 for in-house, fiduciary
management. Our goal in participating in these services is to provide mass affluent households
with the same level of investment management services as received by the wealthiest households.




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The Third Party Advisors are responsible for managing brokerage accounts for its customers by
mirroring the model portfolios through their proprietary trading instructions system, based on our
specific trade directives.

Modeled or mirrored portfolios do not constitute personalized investment advice by Green Valley
Wealth Advisors, and an investor should know that Green Valley in managing model portfolios
does not takes any investor’s personal financial needs into consideration nor do we customize our
offerings based on the needs of any individual investor. Regular rebalancing of the portfolio(s) as
well as tactical adjustments due to short or intermediate term market expectations will be based
solely upon changes in our economic outlook and market opinion.

Given the structure of these investment offerings, Green Valley Wealth Advisors does not act in a
fiduciary capacity to the end-clients. We do not typically interact with the end-clients, as the Third
Party Advisor usually serves as a single point of contact.

Green Valley Wealth Advisors makes reasonable attempts to ensure that the Third Party Advisors
with whom we have contractual agreements are properly licensed or exempt from registration.

A complete description of the programs and services available through the respective Third Party
Advisor will be provided to an investor upon receipt and review of the applicable Third Party
Advisor’s Firm Brochure (Form ADV Part 2), other disclosure brochures/documents, investment
advisory contracts, and account opening documents. Each investor will be required to sign an
advisory agreement directly with the Third Party Advisor selected.

Personalized Counseling
Green Valley’s advisory services are tailored to the individual needs of clients. While we make
available the same suite of services to all of our clients, specific client wealth planning strategies
and the implementation of our services are dependent upon each client’s current situation.

Client goals and objectives are clarified in meetings and via correspondence and are used to
determine the course of action for each individual client. The goals and objectives for each client
are documented in our client relationship management system and in client files, either in hard
copy or in electronic files.

Each client has the opportunity to place reasonable restrictions on the types of investments to be
held in their portfolio, be it certain securities or types of securities in accordance with their values
and beliefs. This must be done in writing and be signed by the client and Green Valley Wealth
Advisors.

In executing our services, Green Valley Wealth is not required to verify any information received
from the client or from the client's other professionals. The client is advised that it remains their
responsibility to promptly notify Green Valley Wealth when there is any change in their financial
situation and/or their financial objectives for the purpose of reviewing, evaluating, or revising
previous recommendations and/or services.




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Managed Assets
As of December 31, 2010, Green Valley had 14 clients and $13.4 million of discretionary assets
under management. We exclude assets where we supervise or consult in an advisory role, such as
where we serve in a sub-advisory capacity with a Third Party Advisor or consult with businesses
regarding their retirement accounts.

We believe that working through various distribution channels we are creating a growing, diverse
revenue structure and enhancing our asset gathering that is necessary to grow the firm.

Fees and Compensation
We look to be transparent in all that we do, and for clients to easily understand what they are going
to be paying for our services. We offer advice, not a sales pitch to buy products. We do not assess
subscription fees or commissions.

Green Valley Wealth primarily provides discretionary supervision for our clients’ investment
accounts. Some of our services are considered financial planning or are known by similar
terminology. Green Valley offers investment advisory services with the following fee structures:

   •   A percentage of assets under management, or asset-based pricing (the majority of our
       arrangements)
   •   A fixed rate, or flat fee
   •   An hourly charge

Wealth and Investment Management Fee (Wrap Fee Program)
The fee schedule is based upon the total value of the client's investment assets. The fee will be
calculated in accordance with the following formula, and is offered on a wrap fee basis.

                                          Annual Advisory Fee
                                                                           Annual Advisory Fee
   Assets Under Management              (Stock/Multi-Asset Class
                                                                            (Bond Accounts)
                                               Accounts)
   Up to $250,000                                1.70%                             0.75%
   $250,001 to $500,000                          1.55%                             0.70%
   $500,001 to $750,000                          1.35%                             0.65%
   $750,001 to $1,000,000                        1.10%                             0.60%
   $1,000,001 to $2,500,000                      0.95%                             0.55%
   $2,500,001 to $5,000,000                      0.80%                             0.50%
   $5,000,001 to $10,000,000                     0.65%                             0.40%
   $10,000,000 and greater                     Negotiable                       Negotiable




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Wrap Account Fee Structure
To best offer objective advice, our asset-based pricing is based on a wrap fee structure. Wrap fee
means there is one fee for investment management services inclusive of customary brokerage
commissions and transaction fees.

A detailed discussion of Green Valley Wealth Advisors’ Wrap Fee Program is located in the Wrap
Fee Program Brochure, which you should find attached to this Firm Brochure.

Fee Billing
The quarterly fee will be equal to the annual rate, times the market value of the account, divided by
four. Our fee is assessed in arrears at the end of each calendar quarter. New account assets held
for a partial quarter will be pro-rated based on the number of days the account was open during
the quarter.

Clients authorize Green Valley Wealth to deduct its investment advisory fee directly from their
custodial account. This authorization is granted under a client‘s signed Investment Advisory
Agreement. In such cases, it is the client’s responsibility, not the custodian’s, to verify the
accuracy of the fee calculation. Clients will be provided with a quarterly statement reflecting
deduction of the advisory fee.

Negotiability
Green Valley, in its sole discretion, may negotiate to charge a lesser annual fee or lesser
investment management fee based upon, among other criteria, anticipated future earning
capacity, anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, pre-existing client relationship, account retention and/or pro bono
activities.
For multiple accounts under the control of the client, client’s spouse, and relatives residing in the
same household, accounts will generally be aggregated for fee purposes.

Valuation of Account
 Market value includes all cash, money market balances and the value of all securities held in the
account and supervised by Green Valley Wealth. Some assets, as mutually agreed, may be
excluded from the fee calculation. These assets may include real estate, mortgages or holdings in
personal or closely held corporations, as well as other investments.
For purposes of determining value, securities and other instruments traded on a market for which
actual transaction prices are publicly reported, shall be valued at the last reported sale price on the
principal market in which they are traded or, if there shall be no sales on such date, then at the
mean between the closing bid and asked prices on such date. Other readily marketable securities
shall be priced using a pricing service or through quotations from one or more broker-dealers.

Minimums
While we don’t have a set minimum, we believe that for proper multiple asset class diversification
an investment of $250,000 is warranted.




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Amendment of Fee Agreement
Green Valley Wealth Advisors and the custodian may amend any of the fees assessed upon 30
days prior written notice to the client.

Assignment
Neither Green Valley Wealth Advisors nor the client may assign the Investment Advisory Agreement
without the prior written consent of the other party. Transactions that do not result in a change of
actual control or management of Green Valley Wealth shall not be considered an assignment.

Planning Advice Fee
Financial Planning Advice Fees
Green Valley charges an hourly rate or a fixed fee rate for its planning advice. Rates for financial
planning may range from $175 per hour up to $400 per hour depending upon the value-added
professional services provided.

The fee is set depending upon the complexity and scope of the plan and the client's objectives.
An estimate of the total time and cost will be determined at the start of the advisory relationship
and will be disclosed to the client. A retainer may be requested depending on the circumstances.

College / Retirement Savings Plan Advice Fee
Green Valley 529 college savings plan and retirement plan clients receive an initial consultation,
either in person or by telephone, during which we help define their college savings / retirement
goals and determine a course of action that has the best chance to achieve the desired results.
For those with an existing plan, we will review your existing savings strategy and recommend any
needed changes.

The flat fee for the engagement is $250, which includes implementing our recommendations and
account paperwork. With the flat fee, as long as we stay within the original scope of our project,
the client won't be charged any incremental hourly fees. The engagement entitles one to email and
phone support for up to a year after the initial meeting at no additional cost. Advice thereafter is
charged at our Financial Planning Advice fee rates.

Payment of Fees
Payment of Investment Management Fees
Fees are withdrawn directly from the client’s account.

Payment of Financial Planning Fees
Hourly and fixed rate financial planning fees are paid via check, PayPal, or money order. If a
retainer payment was made, the balance is payable upon delivery of the financial plan.




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Other Fees
Custodian Fees
Clients may pay separate custodial and administrative fees including for the sundry of services that
custodians provide, such as corporate trustee services, wire transfer fees, etc.

Fund Fees
Mutual funds, index funds, and exchange traded funds (ETFs) generally charge a management fee
for their services as investment managers. The management fee is included in the fund’s expense
ratio. Fees imposed directly by a mutual fund, index fund, or an ETF will be disclosed in the fund's
prospectus.

All fees paid to Green Valley Wealth for investment advisory services are separate and distinct from
the fees and expenses charged by mutual funds and ETFs to their shareholders.

Unbundled Fees
Typical trading costs and commissions are included in our Wealth Management and Investment
Management fee schedule on a wrap fee basis. If negotiated, trading costs may be unbundled
from our stated fee schedule. In that case, custodians (broker-dealers) may charge transaction
fees on purchases or sales of stocks, bonds, mutual funds, ETFs, and other securities.

Please see the section entitled Brokerage Practices for more information.

Relative Cost of Services
Green Valley’s fee schedule is competitive with fees charged by other investment advisors for
comparable services. One may find a firm that charges lower fees than those charged by Green
Valley Wealth.

Additionally, one could invest in a mutual fund directly, without the services of Green Valley Wealth
Advisors. In that case, an investor would not receive the services provided by us which are
designed, among other things, to assist a client in determining goals, asset allocation, and the
type of securities and funds that are most appropriate for one’s financial condition and objectives.
Accordingly, one should review both the fees charged by the funds and the fees charged by Green
Valley to fully understand the total amount of fees to be paid and to thereby evaluate the advisory
services being provided.

Margin Accounts
A client reserves the right to authorize the use of margin (that is, borrowing money from a broker-
dealer) which leverages their investments in such a way as to magnify both their gains and losses.
While Green Valley Wealth Advisors strongly discourages the use of margin, if a margin account is
employed by Green Valley Wealth on behalf of a client in the management of their investment
portfolio, the market value of the client’s account and corresponding fee payable by the client to
Green Valley may be increased.

As a result, in addition to understanding and assuming the additional principal risks associated
with the use of margin, a client authorizing margin is advised of the potential conflict of interest



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whereby the client’s decision to employ margin may correspondingly increase the management
fee payable to Green Valley Wealth. Accordingly, the final decision on whether to employ margin is
left to the discretion of the client. However, Green Valley Wealth reserves the right whether to
accept the account or not for investment management.

Termination of Agreement
Green Valley’s investment strategies are, in part, based on long-range investment horizons and we
look to work with our clients for a very long time. However, circumstances can and do change over
the course of a relationship.

Either party may terminate the agreement at any time by providing written notice to the other party.

If a copy of this Firm Brochure (Form ADV Part 2) and its disclosure statements are not delivered to
a client at least 48 hours prior to the client entering into a written Investment Advisory Agreement
with Green Valley Wealth Advisors, then the client has the right to terminate the contract without
penalty within five (5) business days of signing Green Valley Wealth Advisors’ Investment Advisory
Agreement. After five (5) business days, the client will incur charges for bona fide advisory services
rendered to the point of termination and such fees will be due and payable by the client. For
purposes of this provision, a contract is considered entered into when all parties to the contract
have signed the contract.

Upon termination of a client's relationship, Green Valley Wealth Advisor's relationship will be
removed from all of the client's accounts. The client has the option of continuing to work directly
with the current custodian, assigning another advisor to manage the account(s), or transferring all
assets and account(s) to another custodian.

Fees owed to Green Valley will be pro-rated for the quarter and then deducted from the client's
account prior to termination. Payment of fees may result in the liquidation of some securities if
there is insufficient cash in the account. Upon request, Green Valley Wealth will provide a good-
faith estimate of these fees.

The client is responsible for all applicable charges including, but not limited to, full quarterly
custodial administrative fees, account closure fees, and all trading costs due to the termination
including any fees that mutual funds may assess. Account closure fees are charged per the
custodian’s policy; Green Valley Wealth Advisors, itself, does not impose an account closure fee.

Past Due Accounts
Green Valley Wealth Advisors reserves the right to stop work on any account where fees are more
than 60 days overdue. In addition, Green Valley reserves the right to terminate any client
agreement where a client has willfully concealed or has refused to provide pertinent information
about their financial situation when such information would be necessary for us to provide proper
financial advice, per the judgment of Green Valley Wealth Advisors.




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Compensation for Sale of Investment Products
The firm’s compensation is solely from fees paid directly by clients. The firm does not receive any
form of commission or incentive-based compensation for a client’s purchase of any financial
product, including insurance.

Performance-Based Fees and Side-By-Side Management
Green Valley does not use performance-based fee structures (fees based on a share of capital
gains or capital appreciation of the assets of a client).

Types of Clients
As mentioned earlier, Green Valley Wealth Advisors generally provides investment advice to
individuals, families, trusts and estates. We also extend advice to charitable organizations such as
foundations and endowments, corporations and other business entities. Client relationships vary in
scope based on the level of services and planning that is required.

We also provide fiduciary counseling to businesses regarding their pension and profit sharing
plans. And, we manage model portfolios or sub-advise investment accounts for other investment
providers such as other registered investment advisory firms, broker-dealers, and banks.

Methods of Analysis, Investment Strategies, Sources of Information and Risk of Loss
Methods of Analysis
Green Valley’s methods of analysis include the following:

      Qualitative analysis (or fundamental analysis) uses subjective judgment based on non-
       quantifiable qualities of a company, such as management expertise, financial health,
       competitive advantages, strength of research and development, and labor relations.
      Quantitative analysis is the use of math and statistical methods to evaluate and measure
       investments or business opportunities and make decisions.
      Technical analysis involves the analysis of past market data, primarily price and volume, to
       discern specific security and market trends and business cycles.

Sources of Information
We believe in the mosaic theory to investment analysis; this involves collecting public, non-public
and non-material information about a company in order to determine the underlying value of the
company's securities and to enable us to make recommendations to clients based on that
information.

The widespread use of the Internet provides us with a wealth of information, be it subscription-
based or free services. Efficient investment tools, research products, data feeds, company press
releases and filings, and other information are readily accessible on the Internet.




                                                                                                       10
We also attend on- and off-site visits with fund and portfolio managers, economists, and
strategists; conference calls; and industry conferences.

With the information and the data we gather, we interpret and analyze it to ensure adherence to
appropriate investing and trading strategies.

Investment Strategies
We are focused on creating value for our clients. We believe a disciplined investment strategy can
protect and grow one’s wealth, and that investment opportunities can be found in any market
cycle, anywhere around the world.

In a complex and constantly evolving global economy where sudden market shocks can occur,
investors need to reassess how to best achieve their investment objectives while managing
downside risk. In the new investment landscape, simply investing in stocks and bonds may not be
enough and investors should consider additional sources of portfolio diversification. We believe
that global, multiple asset class diversification with a flexible asset allocation policy may best
provide the growth, income and wealth protection clients need.

We pursue investment strategies across equity, fixed income, and alternative asset classes. Green
Valley Wealth provides, and implements, macroeconomic and investment views across major
asset classes including global equities, global bonds, diversified commodities and real estate.

Managing risk and ensuring adequate diversification are hallmarks of our investment philosophy.
Customized investment plans are tailored around individual and evolving client needs.

Risks of Investing
Green Valley generally seeks investment strategies that do not involve significant or unusual risk
beyond those of the general domestic and/or international equity markets, bond markets, and
commodities markets.

It is important to note that while all investments are subject to certain risks, stocks typically have a
greater degree of risk than bonds. Although both fluctuate in value, stocks are considered to have
a greater degree of risk and increased volatility. Investing in foreign securities involves more risk
than investing in U.S. companies due to currency fluctuations, economic or financial instability,
lack of timely or reliable financial information and unfavorable political or legal developments.
Certificates of deposits (CDs) are insured and offer a fixed rate of return. Money market funds are
not insured and they may possibly lose money. Investment securities employed are not bank
deposits; are not insured by the FDIC or any other governmental entity; are neither obligations of,
nor guaranteed by Green Valley Wealth Advisors, LLC.

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.

Firm Risk Controls
We incorporate certain basic risk controls into our business practices. In particular, adequate
supervision of people at all levels is critical. Specific risk control measures involve separating



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functions – having different people responsible for different activities. For example, trading and
accounting are handled by a different person or team. Portfolio managers come up with
appropriate strategies; traders implement and execute upon respective strategies; administrators
verify trade settlement and cash disbursements; and independent custodians (broker-dealers)
transact and clear the respective trades as well as provide monthly account statements. The
separation of functions and responsibilities serves as a check and verification that the processes
are handled correctly.

Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to a client’s evaluation of each supervised person
providing investment advice or the integrity of Green Valley Wealth Advisors’ management.

Neither Green Valley Wealth Advisors LLC nor any of its employees or representatives has any
derogatory or disciplinary information to disclose.

Other Financial Industry Activities and Affiliations
Activities
Green Valley Wealth Advisors LLC does not participate in any other industry business activities.

Affiliations and Arrangements
Green Valley Wealth Advisors recommends discount brokerage firms and trust companies
(qualified custodians), such as Fidelity Investments. Green Valley Wealth Advisors does not receive
any fees or commissions from any of these arrangements.

Third Party Providers
Green Valley Wealth Advisors LLC has an arrangement with FocusPoint Solutions, Inc., an Oregon
Corporation and SEC registered investment advisor (RIA) to provide certain services in regards to
client accounts. These services may include, but are not limited to, the following activities –
research, due diligence, reporting, portfolio analysis, portfolio management, and back office
administration.

Green Valley Wealth Advisors may make arrangements with unrelated third party providers
(collectively, Third Party Providers) such as FocusPoint Solutions to facilitate the firm’s services
and offerings. The arrangements may include but are not limited to other RIAs. These Third Party
Providers will not have any direct contact with Green Valley Wealth Advisors’ clients, nor will Third
Party Providers enter into any advisory contracts directly with our clients. Third Party Providers
provide services directly to Green Valley Wealth Advisors LLC who is solely responsible for client
accounts.

Upon entering into an Investment Management Agreement with Green Valley Wealth Advisors LLC,
clients authorize Green Valley to use Third Party Providers to service the client’s account, including
billing and the deduction of fees from client accounts. Clients agree to allow Green Valley to share
non-public, personal information with Third Party Providers for the purpose of administering and



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managing clients’ accounts. Green Valley requires Third Party Providers to execute a
Confidentiality Agreement binding them from sharing this information with any unauthorized person
or entity.

The use of Third Party Providers will not cause clients to incur any additional fees. Green Valley
Wealth Advisors pays Third Party Providers for services out of the total advisory fee charged to
clients. Green Valley Wealth Advisors’ fee schedule is disclosed in the section entitled Fees and
Compensation.

Third Party Advisors
Green Valley Wealth Advisors receives compensation from certain Third Party Advisors for
providing model, mirrored, and/or sub-advisory services to these outside firms. Due to the fact that
we may receive compensation for referring investors to these Third Party Advisors and because
such compensation may differ depending upon the individual agreement with each Third Party
Advisor, Green Valley Wealth may have an incentive to recommend one Third Party Advisor over
another with which it has less favorable compensation arrangement. Ultimately, the decision of
which Third Party Advisor is selected, if any, lies with the individual investor.

Referrals
We may at times recommend and refer clients to CPAs, estate planning attorneys, insurance
agents, and other professionals to provide expertise and services in certain disciplines where we
cannot render advice. We do not receive any compensation for the recommendation or selection
of these other advisors.

Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
Green Valley Wealth Advisors LLC has committed to a Code of Ethics and Standards of
Professional Conduct (Code and Standards) for all members, officers, and employees of the firm.
The Code and Standards are the ethical cornerstone of the firm as they are essential in maintaining
the public’s trust.

As a fiduciary, it is the firm’s responsibility to provide fair and full disclosure of all material facts and
to act solely in the best interest of each of our clients at all times.

The key points to the Code and Standards are putting our clients’ interest first; acting with integrity,
competence, and respect; objectivity; confidentiality; suitability; regulatory compliance; full
disclosure; and professionalism. We will happily provide a copy of the Code and Standards to any
client or prospective client upon request.

CFA® charterholders are held to a Code of Ethics and Standards of Professional Conduct as
outlined by the CFA® Institute Board of Governors.

Upon employment with Green Valley Wealth Advisors and at least annually thereafter, all
employees or representatives will sign an acknowledgement that they have read, understand and
agree to comply with the firm’s Code and Standards.



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Participation or Interest in Client Transactions (Personal Trading)
Green Valley Wealth Advisors, its members, officers and employees, and their immediate families
(collectively, employees) may at times buy or sell securities that are also held by clients. We
encourage our employees to be investing similarly to our clients so that our interests are aligned;
however, no employee shall prefer his or her own interest to that of an advisory client.

Block trades in client accounts could trigger employee transactions to be placed simultaneously. If
the firm’s employees purchase or sell the same security on different days, it is possible that the
employees’ personal transactions might be executed at more or less favorable prices that were
obtained for clients.

Green Valley Wealth Advisors’ employees may own securities that are subsequently purchased for
client accounts, but are forbidden from front running or acting on advance knowledge of pending
orders for clients.

Green Valley Wealth Advisors’ employees may buy or sell different securities, based on personal
investment considerations, which the firm may not deem appropriate to buy or sell for clients. This
can occur when securities are not suitable for clients at the time of purchase given that they may
be considered too speculative (such as micro-cap stocks and penny stocks).

All personal trades by employees are reviewed quarterly to ensure that they are not based on
inside information and our clients receive preferential treatment. We also ensure that personal
trades are never of a significant enough value to affect the securities markets. All employees must
comply with the provisions of the firm’s Policies and Procedures Manual. The manual contains
more detailed information regarding personal trading procedures.

Brokerage Practices
As provided for in our Wrap Fee Program, customary brokerage commissions and transaction fees
charged by a custodian are included in the overall investment management fee paid to Green
Valley Wealth Advisors.

A more detailed discussion of Green Valley Wealth’s Wrap Fee Program is located in the Wrap Fee
Program Brochure, which you will find attached to this Firm Brochure.

Best Execution
Best execution is a term that generally refers the obligation of broker-dealers and market makers to
execute customer orders at the best price available at the time the trade is entered.

It is Green Valley Wealth Advisors’ duty to seek the most favorable execution of clients’
transactions consistent with the firm’s judgment as to the business qualifications of the various
broker-dealers with which Green Valley Wealth Advisors may do business.

While Green Valley Wealth Advisors will generally seek competitive transaction fees, we may not
necessarily attempt to obtain the lowest possible fees for transactions within a client’s account.




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Recommendation of a Broker-Dealer (Custodian)
Green Valley Wealth Advisors does not, and will never, maintain custody of client assets.

Green Valley Wealth Advisors will arrange for the execution of securities transactions for client
accounts through a broker-dealer such as Fidelity Investments (Fidelity) that Green Valley Wealth
Advisors reasonably believes will provide best execution. In selecting a broker-dealer, Green Valley
Wealth Advisors may consider, among other things, the custodian’s execution capabilities,
reputation, respective financial strength, pricing, research and service. Fidelity Investments
enables Green Valley Wealth Advisors to obtain many mutual funds without transaction charges
and other securities at nominal transaction charges. The commission and/or transaction fees
charged by Fidelity may be higher or lower than those charged by other broker-dealers.

We chose Fidelity based on their ability to effectively and efficiently execute, report, clear and settle
trade orders, and accurately communicate with our trading desk and operations team; and charge
commission rates which, when combined with these (and other) services, produces the most
favorable total cost or proceeds for each transaction under the circumstances.

Green Valley Wealth Advisors may also benefit from other services provided by custodians, such
as research, continuing education, and practice management advice. These benefits are standard
in a relationship with a custodian, like Fidelity, and are not in return for client recommendations or
transactions.

Fidelity does not maintain supervisory relationships with respect to Green Valley Wealth Advisors or
its representatives, and there is no affiliation between the firms. Green Valley Wealth Advisors does
not receive any portion of the trading fees.

Brokerage Discretion
Green Valley Wealth Advisors generally provides discretionary investment advisory services to its
clients. Where full investment discretion has been granted, Green Valley Wealth Advisors
supervises and manages the client portfolio and makes investment decisions without consultation
with the client involving its determinations regarding which securities are bought and sold for the
account, the total amount of the securities to be bought and sold, the brokers with whom orders
for the purchase or sale of securities are placed for execution and the commission rates at which
securities transactions are effected.

In some instances, Green Valley Wealth Advisors’ discretionary authority in making these
determinations may be limited by conditions imposed by clients in their investment guidelines or
objectives. Green Valley Wealth Advisors’ discretionary authority may also be limited by directions
from a client to have transactions effected through specified brokers, as described more fully in the
Client Directed Brokerage disclosures below.

Clients have the right to place restrictions on their accounts that prohibit certain investments.
Green Valley Wealth Advisors may therefore advise some clients or take actions for them that differ
from recommendations or action taken for other clients. Green Valley Wealth is not obligated to
recommend to any or all clients any investments that it may recommend to, or purchase or sell for,
certain other clients.




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Client Directed Brokerage
In certain cases, a client may direct Green Valley Wealth Advisors to use a specific broker-dealer
for portfolio transactions in their account. Clients who direct brokerage should understand that
similar brokerage services may be obtained from other broker-dealers at lower costs and possibly
with more favorable execution prices.

Green Valley Wealth Advisors is not obligated to, and will generally not, solicit competitive bids for
each transaction or seek the lowest commission rates for the client as the commission rates have
typically been pre-negotiated between the client and the broker and Green Valley Wealth Advisors
is unable to supersede the terms of that agreement. As such, the client may pay higher
commission costs or transaction costs than they otherwise would have had they directed Green
Valley Wealth Advisors to negotiate brokerage rates and seek to obtain volume discounts.

Trade Allocation and Aggregation
Investment decisions are generally applied to all accounts employing a similar strategy, taking into
consideration client restrictions, individual needs, and account characteristics.

As a general rule, all accounts for which trades are aggregated (block trade) will receive the same
average execution price for that day. All allocations of block trades shall be made on a fair and
equitable basis over time, to the extent practicable, without favoring any account or type of
account or client over another over a period of time. In cases where a trade is not completed in a
single day, Green Valley Wealth Advisors will allocate the traded shares on a pro-rata basis among
all of the accounts in the block trade.

The method of trade allocation will be based on various factors including how much of the total
block was completed and the liquidity of the issue being traded. Green Valley Wealth Advisors
cannot assure the equal participation of every client in every investment opportunity or every
transaction. Green Valley Wealth Advisors may determine that a limited supply or demand for a
particular opportunity or investment or other factors may preclude the participation of some clients
in a particular investment opportunity or trade.

When a broker-dealer is client directed, Green Valley may not be able to aggregate trades with
those of other clients, thus not being able to obtain the most favorable execution rate.

Soft Dollars
Green Valley Wealth Advisors does not receive any soft dollar benefits from the broker-dealers to
whom we recommend or refer clients.

Soft dollar refers to investment research materials, products, or brokerage-related services (such
as economic and market information, portfolio strategy advice, research conferences, periodical
subscription fees, performance measurement data, online pricing, news wire charges, quotation
services, computer hardware and software) that are provided or purchased on our behalf in
exchange for Green Valley Wealth Advisors directing commissions to a particular broker-dealer.




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Initial Public Offerings
Green Valley Wealth Advisors typically does not participate in initial public offerings (IPOs) and
certain secondary offerings as they often present limited opportunities for client participation
because not all clients are eligible to participate in every offering; the number of shares of each
offering allotted to Green Valley Wealth Advisors may be too small to permit meaningful
participation by all clients that may be eligible to participate; and the number and nature of
offerings generally may be dependent upon market or economic factors beyond the firm’s control.

Trade Errors
Green Valley Wealth Advisors’ procedures require its personnel to carefully implement investment
management decisions. Nevertheless, if a trade error occurs, it is the firm’s policy that the error be
corrected as soon as possible and in such a manner that the affected client is not disadvantaged
and bears no loss. Except as noted below, Green Valley Wealth Advisors will compensate losses
only for those trade errors made by us and will not be responsible for compensating clients for
losses resulting from trade errors made by the client’s custodian and/or executing broker-dealer.

Applicable law prohibits Green Valley Wealth Advisors from requesting an executing broker-dealer
to accept financial responsibility for a trade error caused by Green Valley Wealth in exchange for
the promise of future compensation through commissions.

Class Action Lawsuits
The timing restrictions and legal procedures for initiating and prosecuting a class action securities
action are complex and require the professional services of licensed legal counsel. Green Valley
Wealth Advisors is an investment advisor to its clients and does not provide legal counsel.
Therefore, we do not make any recommendations to clients seeking advice with either the decision
to bring or join a claim or the procedure to prosecute or join a claim.

In certain circumstances, we will assist with the compilation of documentation necessary for a
client requesting to participate in a class action suit. In those instances, we will look to provide the
client with trade and cost basis data related to their holdings of the security in question.

Review of Accounts
Periodic Reviews
All Wealth Management and Investment Management client accounts are reviewed at least on a
quarterly basis. Frequent reviews ensure that transactions conform to client objectives and
investment guidelines; are consistent with the available cash in the client account; and conform to
the firm's investment strategies.

Wealth Management and Investment Management clients are provided with quarterly, semi-
annual, or annual investment reviews, the frequency of which is individually negotiated with each
client. The reviews typically include asset allocation updates and rebalancing, performance
reviews, and may include tax and estate plan reviews, cash flow monitoring, and more.

Financial Planning clients are provided with semi-annual or annual reviews, which typically include
tax and estate plan reviews, cash flow monitoring, investment reviews, asset allocation updates



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and rebalancing, and more. Financial Planning clients are given the option to return annually at
their expense for an update of their financial plan.

Account reviews and investment plans are conducted and reviewed by Eric Linser, CFA, the firm’s
Chief Investment Officer, prior to distribution to clients.

Additional information regarding Mr. Linser’s background is located in the Brochure Supplement,
which you should find attached to this Firm Brochure.

Review Triggers
Account reviews for Wealth Management and Investment Management clients are performed more
frequently when market conditions dictate, or when a client’s objectives change. A review may be
triggered by client request, changes in market condition, new information about an investment,
changes in tax laws, or other important changes.

Regular Reports
Written reports are sent to Wealth Management and Investment Management clients based on
their negotiated frequency of reviews. The reports may consist of an individualized letter
summarizing the results of the review and our general thoughts on the economy, a statement of
holdings from our portfolio accounting software, a snapshot report or other such portfolio reports,
asset allocation analysis, tax-related information, updates to financial plan reports, portfolio
graphs, or other reports as needed. Financial Planning clients will receive updates to their financial
plan reports based on the scope of the engagement and negotiated frequency of reviews.

Each client will receive transaction confirmations and monthly, or quarterly, statements from their
account custodian. Collectively, these reports will provide detailed valuation of individual securities,
their cost and market value, and a summary of the total account by security type, in addition to a
transaction history showing each purchase and sale during the period covered and fees paid to
Green Valley Wealth Advisors.

Third Party Advisor Programs
Investors in Third Party Advisor programs where we provide model portfolios will typically receive
monthly or quarterly statements and confirmations of transactions from their broker dealer or
custodian. They may receive additional reports from the Program Sponsor. Green Valley Wealth
Advisors does not provide any reports to these clients. Investors with these Third Party Advisor
programs should refer to each program’s disclosure documents for additional information about
the reports provided to program participants.

Client Referrals and Other Compensation
Incoming Referrals
Green Valley Wealth Advisors has been fortunate to receive client referrals as the firm grows its
practice. The referrals have come from current clients, estate planning attorneys, accountants,
personal friends, and other sources. The firm does not pay for these, or any, referrals.




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Referrals to Other Professionals
Green Valley Wealth Advisors does not accept referral fees or any form of remuneration from other
professionals when a prospect or client is referred to them.

Custody
Account Statements
All assets are held at qualified custodians, who provide account statements directly to clients at
their address of record at least quarterly, if not monthly. Clients are encouraged to carefully review
the statements provided by their custodians.

Occasionally, qualified clients may invest in private placements which are not held at qualified
custodians. In these cases, statements are generally provided directly by the investment principal
at least annually.

Statements Provided by Green Valley Wealth Advisors
Clients are at times provided account statements, net worth statements, and net worth graphs that
are generated from our portfolio accounting and financial planning software. Net worth statements
contain approximations of bank account balances provided by the client, as well as the value of
land, real estate, limited partnerships, and other hard-to-price assets. The net worth statements are
used for long-term financial planning where the exact values of assets are not material to the
financial planning tasks. The book values of hard-to-price assets are reviewed whenever
supplemental information relating to valuation is received. Otherwise, these assets are priced at
client cost. Clients are urged to compare the statements they receive from us to those they receive
from their qualified custodians.

Investment Discretion
Discretionary Authority for Trading
Green Valley Wealth Advisors accepts discretionary authority to manage securities accounts on
behalf of clients. Green Valley has the authority to determine, without obtaining specific client
consent, the securities to be bought or sold, and the amount of the securities to be bought or sold.
Discretionary trading authority facilitates placing trades in clients’ accounts on their behalf so that
we may promptly implement the appropriate investment strategies for them. However, if
discretionary authority or a limited power of attorney has not been given, Green Valley consults
with the client prior to each trade to obtain concurrence.

Third party investment managers (such as mutual funds and exchange traded funds) have full
discretion over trades and do not consult with Green Valley or with clients before placing trades.

Limited Power of Attorney
Clients must sign a limited power of attorney before Green Valley is given discretionary authority.
The limited power of attorney is included in the qualified custodian’s account application. For
accounts not held with our main custodian, Fidelity Investments, clients may have to sign a
separate limited power of attorney document giving discretionary authority to Green Valley Wealth.



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Voting Client Securities
Proxy voting allows shareholders in common stocks and mutual funds to vote on matters
scheduled for consideration at annual meetings when they can't attend a shareholder meeting in
person. Shareholder voting is the primary means by which shareholders can influence a
company's or mutual fund's operations, its corporate governance and even activities of social
responsibility that may fall outside of financial considerations.

Proxy Voting Policy
Green Valley Wealth Advisors does not vote proxy material for its clients.

This policy is in place to ensure that Green Valley Wealth Advisors maintains compliance with
proxy voting rules governing registered investment advisers. And, this ensures that our vote does
not create a potential conflict of interest. In voting proxies, you have your own voice on corporate
responsibility issues you deem important. While we expect best practices in corporate governance
for the firms in which we invest, we prefer not to take a stand on issues that may vary in importance
from client to client.

Clients should look to receive their proxies or other solicitations directly from their custodian or a
transfer agent. In the event that Green Valley Wealth Advisors receives any proxies intended for
clients, we will promptly forward such proxies to those clients to vote. When requested by the
client, Green Valley will provide advice regarding proxy proposals submitted to the client for voting.
A client is encouraged to call, email or write us for our thoughts and assistance.

Financial Information
Financial Condition
Green Valley Wealth Advisors does not any financial impairment that would preclude the firm from
meeting contractual commitments to clients.

Balance Sheet
A balance sheet is not required to be provided because Green Valley does not require prepayment
of fees of more than $1,200 per client, six months or more in advance.

Neither Green Valley Wealth Advisors LLC nor any of the firm’s representatives has been the
subject of bankruptcy petition.

Requirements for State-Registered Advisers
The items requested have been addressed elsewhere within the Firm Brochure as well as in the
Brochure Supplement, which you should find attached to this brochure.




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Business Continuity Plan
General
Green Valley Wealth Advisors has a Business Continuity Plan in place that provides detailed steps
to mitigate and recover from the loss of office space, communications, services or key people.

Disasters
The Business Continuity Plan covers natural disasters such as earthquakes, hurricanes, tornadoes,
fire, and flooding. The Plan covers man-made disasters such as loss of electrical power, loss of
water pressure, fire, bomb threat, nuclear emergency, chemical event, biological event,
communications line outage, Internet outage, roadway accident and aircraft accident. Electronic
files are backed up daily and archived offsite.

Alternate Offices
Alternate work locations are identified to support ongoing operations in the event the main office is
unavailable. It is our intention to contact all clients within five days of a disaster that dictates
moving our office to an alternate location.

Information Security Program
Information Security
Green Valley Wealth Advisors maintains an information security program to reduce the risk that
personal and confidential information may be breached.

Privacy Notice
Green Valley Wealth Advisors is committed to maintaining the confidentiality, integrity and security
of the personal information that is entrusted to us. The categories of nonpublic information that we
collect from our clients may include information about personal finances, information about health
to the extent that it is needed for the financial planning process, information about transactions
between clients and third parties, and information from consumer reporting agencies, e.g., credit
reports. We use this information to help our clients meet their personal financial goals.

With our clients’ permission, we disclose limited information to attorneys, accountants, and
mortgage lenders with whom they have established a relationship. Clients may opt out from our
sharing information with these nonaffiliated third parties by notifying us at any time by telephone,
mail, fax, email, or in person. With client permission, we share a limited amount of information with
the client’s brokerage firm in order to execute securities transactions on your behalf.

We maintain a secure office to ensure that our clients’ information is not placed at unreasonable
risk. We employ a firewall barrier, secure data encryption techniques and authentication
procedures in our computer environment.

We do not provide personal information to mailing list vendors or solicitors. We require strict
confidentiality in our agreements with unaffiliated third parties that require access personal




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information, including financial service companies, consultants, and auditors. Federal and state
securities regulators may review our Company records and personal records as permitted by law.

Personally identifiable information will be maintained while still a client of Green Valley Wealth
Advisors and for the required period thereafter that records are required to be maintained by
federal and state securities laws. After that time, information may be destroyed.

We will notify our clients in advance if our privacy policy is expected to change. We are required by
law to deliver this Privacy Notice to our clients annually, in writing.

Questions or Inquiries?
For more information about how we can help you achieve your investment planning goals, please
visit our website at www.GVWealth.com or contact us at (415) 568-2150, or 555 California Street,
Suite 313, San Francisco, California 94104.




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