ALTIUS FINANCIAL ADVISORS, LLC. Firm Brochure (Part 2A of Form ADV)

Transcription

1 ALTIUS FINANCIAL ADVISORS, LLC 3 BETHESDA METRO CENTER, SUITE 700 BETHESDA, MD TELEPHONE: FAX: WEBSITE: MNATHANI@ALTIUSFIN.COM Firm Brochure (Part 2A of Form ADV) This brochure provides information about the qualifications and business practices of, LLC. If you have any questions about the contents of this brochure, please contact us by telephone at: , or by at: mnathani@altiusfin.com. 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, LLC is available on at MARCH 26, 2014

2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update None. Full Brochure Available Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by telephone at or by at mnathani@altiusfin.com. i

3 Table of Contents Material Changes... i Annual Update... i Material Changes since the Last Update... i Full Brochure Available... i Advisory Business... 1 Firm Description... 1 Principal Owners... 1 Types of Advisory Services... 1 Tailored Relationships... 3 Managed Assets... 3 Fees and Compensation... 3 Description... 3 Fee Billing and Setting... 4 Other Fees and Costs... 4 Termination of Agreement and Past Due Accounts... 5 Performance-Based Fees... 5 Sharing of Capital Gains... 5 Types of Clients... 5 Description... 5 Account Minimums... 6 Methods of Analysis, Investment Strategies and Risk of Loss... 6 Methods of Analysis... 6 Investment Strategies... 6 Risk of Loss... 7 Disciplinary Information... 8 Legal and Disciplinary... 8 Other Financial Industry Activities and Affiliations... 8 Financial Industry Activities... 8 Affiliations... 8 TOC 1

4 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading... 8 Code of Ethics... 8 Participation or Interest in Client Transactions... 9 Personal Trading... 9 Brokerage Practices... 9 Selecting Brokerage Firms... 9 Soft Dollars Order Aggregation Review of Accounts Periodic Reviews Review Triggers Regular Reports Client Referrals and Other Compensation Incoming Referrals Referrals Out Other Compensation Custody Account Statements Performance Reports Investment Discretion Discretionary Authority for Trading Limited Power of Attorney Voting Client Securities Proxy Votes Financial Information Financial Condition Requirements for State-Registered Advisers Principal Executive Officer and Management Persons Other Businesses Performance-Based Fees Disciplinary Disclosures TOC 2

5 Relationship with Issuers of Securities Business Continuity Plan General Disasters Alternate Offices Loss of Key Personnel Information Security Program Information Security Privacy Notice TOC 3

6 Advisory Business Firm Description, LLC ( Altius or the firm ) was founded in 2001 by Mehmood Nathani, who is the sole owner of the firm. Altius is registered as an investment adviser in the states of Maryland, Virginia and the District of Columbia. Altius notice files in Texas. Altius offers personalized financial planning, and portfolio management services to individuals, pension and profit sharing plans, trusts, estates, charitable organizations and small businesses. Altius also offers hourly financial consultations to clients with a limited scope of work. Altius offers its services in combination or on a stand-alone basis as described in greater detail in the Types of Advisory Services section below. Altius is strictly a fee-only financial planning and portfolio management firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is not affiliated with entities that sell financial products or securities. The firm does not accept commissions in any form nor does it accept finder s fees. Altius does not act as a custodian of client assets. Assets managed by Altius are held by independent custodians such as Fidelity Investments and TIAA- CREF. The client always maintains asset control. Altius places trades for clients under a discretionary agreement that gives Altius a limited power of attorney. We may recommend other professionals (e.g., attorneys, accountants, insurance agents, real estate agents, mortgage brokers, etc.) at the request of clients. Clients will engage these other professionals based on their needs and at their sole discretion. Altius will disclose conflicts of interest to the client in the event they should occur. Principal Owners Mehmood Nathani is a 100% stockholder of Altius. Types of Advisory Services Altius provides four services: (1) Financial Management: A broad and ongoing service that includes Financial Planning, Portfolio Management, Financial Plan Updates and Ongoing Personal Financial Advice. a. Under Financial Planning, Altius develops a financial plan for the client. See section (2) below for details on the scope and contents of a financial plan. 1

7 b. Under Portfolio Management, Altius manages the client s investment portfolio. See section (3) below for a description of the Portfolio Management service. c. Under Financial Plan Updates, Altius will update the client s financial plan periodically upon the client s request. d. Under Ongoing Personal Financial Planning, Altius will, upon the client s request, provide ongoing advice on ad-hoc financial issues affecting the client. (2) Financial Planning: Under this service, Altius develops a financial plan for the client but does not manage the client s investment portfolio, update the client s financial plan or provide ongoing financial advice to the client. The financial plan can encompass one or more of the following areas: cash flow, debt, taxes, insurance planning, saving for college, investments, retirement planning and estate planning. The specific areas covered by a client s plan will depend on that client s needs. Altius will analyze and provide recommendations on each covered area in a written document. The client is responsible for implementing his/her plan and can seek Altius assistance with the implementation. Altius will provide up to two (2) hours of post-plan assistance at no additional cost provided the client requests such assistance within 90 days of the date the plan is presented to the client. Altius will charge for assistance beyond two (2) hours at its then current hourly rate. Financial plan updates are not included in the basic Financial Planning service and are considered new plans subject to new agreements and fees. (3) Portfolio Management: Under this service, Altius manages a client s investment portfolio but does not develop a financial plan for the client. This typically occurs for institutional clients who might not need a financial plan as described above. For individual clients, Altius usually develops a financial plan prior to managing the client s portfolio. As part of its Portfolio Management services, Altius develops a suitable asset allocation for the client, screens and selects investments, trades for the client, monitors the client s portfolio and rebalances and makes other changes as necessary. Altius sends the client quarterly reports about the portfolio s profile and performance. (4) Hourly Financial Consultation: Altius consults with clients on an hourly basis. Hourly financial consultations are best suited to clients who desire to engage Altius for a few hours to discuss matters not requiring significant prior analysis and modeling on the part of Altius. Hourly consultations are not intended to serve as a substitute for Financial Planning services described in section (2) above. Altius develops financial plans on a fixed fee basis only and not on an hourly basis. 2

8 Tailored Relationships Altius develops personalized financial plans for its clients. Each plan is customized for a specific client and addresses that client s unique goals, objectives, constraints and personal and financial situation. For portfolio management clients, Altius develops an Investment Policy Statement (IPS) documenting the stated goals and objectives of each client and the framework for managing the client s portfolio. Clients may impose restrictions on investing in certain securities or types of securities. Clients are required to approve their IPS. Managed Assets As of February 28, 2014, Altius managed approximately $38.2 mm in assets for approximately 52 clients. Approximately $38.2 mm is managed on a discretionary basis, and $0 is managed on a non-discretionary basis. Fees and Compensation Description, LLC is a fee-only advisor that charges a fixed or hourly fee for all its services. The fee for each service is described below. All fees are negotiable. Altius reserves the right to charge lower or no fees at its discretion. (1) Financial Management Service: There are two fee components (a) a onetime fee for Financial Planning and (b) a recurring (ongoing) fee for Portfolio Management. There is no additional fee for Financial Plan Updates and Ongoing Personal Financial Advice the fee for those services is included in the Portfolio Management fee. (a) The fee for Financial Planning is a one-time fee charged initially for the development of a financial plan. The fee depends on the size of the managed portfolio according to the following schedule: Assets Managed by Altius Financial Planning Fee $250,000 to less than $500,000 $2,000 $500,000 to less than $1,000,000 $1,000 $1,000,000 and more $0 (No charge for plan) (b) The fee for Portfolio Management is described in (3) below under Portfolio Management service. (2) Financial Planning Service: Altius will charge for financial plans only on a fixed (flat) fee basis. The fixed fee for Financial Planning services will range from $3,500 to $5,000 depending on the complexity of the plan. Altius will not charge for financial plans at an hourly rate. Altius charges an hourly rate only 3

9 for limited financial consultations (Hourly Financial Consultations service) and post-plan assistance in excess of two (2) hours for Financial Planning clients. Altius will provide the Client with a fixed fee quote before the engagement begins. Please note that the fee for a standalone financial plan (i.e., no management of portfolio) is higher than the fee for a financial plan developed for a client whose portfolio will be managed by Altius. (3) Portfolio Management Service: The Portfolio Management fee is an ongoing fee based on the size of the portfolio managed by Altius as per the following schedule. The Portfolio Management fee will never be more than 3% of assets under management per year: 1% of the first $500,000 of assets under management 0.75% of the next $500,000 of assets under management 0.40% of any remaining assets under management Subject to a minimum fee of $2,500. (4) Hourly Financial Consultation Service: The fee for hourly financial consultations is $300 an hour with a one hour minimum. Time in excess of one hour will be billed in 15 minute increments. Fee Billing and Setting Fees for financial plans and hourly consultations are billed in arrears with the fee due immediately upon presentation of the financial plan or completion of the financial consultation. Portfolio management fees are billed quarterly, in arrears, meaning that we invoice our clients after the three-month billing period has ended. We expect payment in full when we present the invoice. Fees are usually deducted from a designated client account to facilitate billing. The client must consent in advance to direct debiting of their investment account. Portfolio Management fees are reset twice a year, on March 31 and September 30, based on the size of managed portfolio on those dates. Fees are also reset on dates when the client adds or withdraws 20% or more of the managed portfolio. Altius gives each Portfolio Management client a copy of its Fee Schedule and Fee Policy prior to signing a Portfolio Management Agreement. Other Fees and Costs Custodians may charge transaction fees on purchases or sales of certain mutual funds, exchange-traded funds, stocks or bonds. These transaction charges are usually small relative to the amount of the security being bought or sold. Altius factors the amount and extent of these transaction fees in its decision to buy or sell a particular security. 4

10 Certain securities also incur a bid/ask spread which refers to the difference between the sale price of a security and its purchase price at that same point in time. For example, if the bid/ask spread for a particular security is 50 cents, it means that if we bought and sold that security instantly, it would cost us 50 cents. The wider the bid/ask spread, the higher the effective cost to a client. Altius factors the bid/ask spread in its decision to buy or sell securities. Mutual funds generally charge a management fee for their services as investment managers. The management fee is called an expense ratio. For example, an expense ratio of 0.50 means that the mutual fund company charges 0.5% for their services. These fees are in addition to the fees paid by you to Altius. Termination of Agreement and Past Due Accounts A Client may terminate their agreement at any time by notifying Altius in writing and paying the remaining fee due for the services provided prior to notification of termination. If the client made an advance payment, Altius will refund any unearned portion of the advance payment. Altius may terminate any agreement at any time by notifying the client in writing. If the client made an advance payment, Altius will refund any unearned portion of the advance payment. Altius reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in Altius judgment, to providing proper financial advice. Any unpaid portion of the fees due will be collected from the clients within 30 days. Performance-Based Fees Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. Altius does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. Types of Clients Description Altius generally provides its services to individuals, trusts, estates and charitable organizations though it retains the ability to provide its services to 5

11 other entities such as banks or thrift institutions, investment companies, pension and profit sharing plans and corporations or business entities. Client relationships vary in scope and length of service. Account Minimums Altius does not impose any minimum standards (in terms of assets or income) for its Financial Planning Service and its Hourly Financial Consultation Service. For its Portfolio Management service, Altius does require assets managed by Altius to be at least $250,000. Clients who signed up with Altius prior to April 1, 2008 might have lower minimums. Altius has the discretion to waive the account minimum. Accounts of less than $250,000 may be set up when the client and the Adviser anticipate the client will add additional funds to the accounts bringing the total to $250,000 within a reasonable time. Other exceptions might apply to employees of Altius and their relatives, or relatives of existing clients. Altius minimum fee of $2,500 will be subject to the maximum 3% of assets under management limit. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information include financial newspapers and magazines, research materials prepared by others, publicly available material on the internet and continuing education through attendance at conferences and seminars. Altius also uses information from sources such as Morningstar, Fidelity Investments and Advisor Intelligence. Investment Strategies Altius manages its clients portfolios using a strategic asset allocation approach with a tactical overlay. Altius typically adheres to a client s longterm target allocation by rebalancing periodically (strategic asset allocation) but at times, allows the actual allocation to deviate from the target for valuation reasons, i.e., when Altius believes an asset class is rich or cheap relative to its fair value (tactical overlay). Altius uses a core and satellite approach to implement a client s allocation. This means that we use passively-managed index and exchange-traded funds as the core investments, and then add actively-managed funds where there are greater opportunities to make a difference. 6

12 The investment strategy for a specific client is based upon the objectives stated by the client during consultations. The client may change these objectives at any time. Each client executes an Investment Policy Statement that documents their objectives and describes the framework for managing their portfolios. Investments may also include: equities (stocks), warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (variable life insurance, variable annuities, and mutual funds shares), U. S. government securities, options contracts, futures contracts, and interests in partnerships. Initial public offerings (IPOs) are not available through Altius. Risk of Loss All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks: Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment s originating country. This is also referred to as exchange rate risk. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from 7

13 a steady stream of customers who buy electricity no matter what the economic environment is like. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Financial/Leverage Risk: Excessive borrowing to finance a business operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Disciplinary Information Legal and Disciplinary The firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other Financial Industry Activities and Affiliations Financial Industry Activities Altius is registered as an investment Adviser in Maryland, Virginia and the District of Columbia. It notice files in Texas. Affiliations Altius does not have any arrangements that are material to its advisory or its clients with a related person who is a broker-dealer, investment company, other investment Adviser, financial planning firm, commodity pool operator, commodity trading adviser or futures commission merchant, banking or thrift institution, accounting firm, law firm, insurance company or agency, pension consultant, real estate broker or dealer, or an entity that creates or packages limited partnerships. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The employees of Altius have committed to a Code of Ethics that is available for review by clients and prospective clients upon request. The firm will provide a copy of the Code of Ethics to any client or prospective client upon request. 8

14 Participation or Interest in Client Transactions Altius and its employees may buy or sell securities that are also held by clients. Employee trades generally involve mutual funds and exchangetraded funds and are not significant enough to affect the securities markets. However, there is a possible conflict of interest in trading the same securities held by clients, even though such conflict is small. Altius addresses such conflicts of interest by ensuring that any employee purchases and sales occur simultaneously or after the clients purchases and sales so that the price received by the client is the best possible price at the time of the trade. Employees comply with the provisions of Altius Compliance Manual. Personal Trading The Chief Compliance Officer of Altius is Mehmood Nathani. He reviews all employee trades each quarter including his own trades. The personal trading reviews ensure that the personal trading of employees does not affect the markets, and that clients of the firm receive preferential treatment. See above for details. Brokerage Practices Selecting Brokerage Firms Altius requires its portfolio management clients to use custodians and broker(s) that Altius selects. Altius is an adviser within Fidelity s Institutional Brokerage Group and uses Fidelity Investments and National Financial Services as the custodian and broker respectively for the majority of its managed assets. Altius also has a signed master agreement with TIAA- CREF which enables Altius to manage a client s TIAA-CREF account if the client so authorizes. Altius might use other custodians and brokers as necessary. Altius does not receive any fees or commission from this arrangement with Fidelity and Altius is not required to use Fidelity mutual funds or products in its clients portfolios. Altius selects custodians and brokers based on a number of factors including financial strength and stability, transaction costs, dependability, reputation, trading capabilities, breadth of products and services (including research) and back-office/technological efficiencies and NOT upon a financial arrangement between Altius and the selected custodian or broker. The commissions paid to the broker for effecting transactions will be competitive but might be higher than the lowest available rate that another broker might have charged if Altius determines, in good faith, that the commissions are reasonable in relation to the value of the brokerage services provided. Altius does receive benefits from its custodians including electronic delivery of client information, access to electronic trading platforms, research, continuing 9

15 education and practice management advice. Altius believes that its clients ultimately benefit from the services provided by custodians by virtue of receiving smooth and efficient trading and processing of their transactions and up-to-date, detailed information about their portfolios. Altius will recommend brokers and custodians to clients when requested. Financial planning clients are free to select any broker or custodian they wish to use to implement Altius investment advice. Altius does not receive fees or commissions for any of these recommendations. Soft Dollars As discussed above under Selecting Brokerage Firms, Altius receives research, trading software and other services from Fidelity Investments because client assets are custodied at Fidelity. All clients benefit from the research and trading software received from Fidelity because Altius uses the research and software on all client accounts. The selection of Fidelity Investments as a custodian for clients is not affected by the specific research and software received. Order Aggregation Most trades are mutual funds or exchange-traded funds where trade aggregation does not garner any client benefit. Review of Accounts Periodic Reviews Account reviews are performed quarterly by Mehmood Nathani. Account reviews are performed more frequently when market conditions dictate. Review Triggers Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's own situation. Regular Reports The account reviewer, Mehmood Nathani, is the sole owner of Altius. He considers the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Clients receive periodic communications on at least an annual basis. Portfolio Management clients receive written quarterly updates. The written updates may include a market review, a summary of market performance, a summary of the client s portfolio performance and asset allocation and a portfolio statement. 10

16 Client Referrals and Other Compensation Incoming Referrals Altius has been fortunate to receive many client referrals over the years. The referrals came from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not pay for these referrals. Referrals Out Altius does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Other Compensation None Custody Account Statements All assets are held at qualified custodians. Qualified custodians provide account statements directly to clients at their address of record at least quarterly. Clients should carefully review the statements they receive from their custodians. Performance Reports Clients are urged to compare the account statements received directly from their custodians to the performance report statements provided by Altius. Investment Discretion Discretionary Authority for Trading Altius accepts discretionary authority to manage securities accounts on behalf of clients. Altius 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. Clients may place restrictions on the discretionary authority given to Altius by restricting the types of securities that Altius can trade for the client. For example, clients might restrict or prohibit the use of options and other derivatives. If discretionary authority or a limited power of attorney has not been given by the client, Altius will consult with the client prior to each trade to obtain concurrence. 11

17 The client approves the custodian to be used and the commission rates to be paid to the custodian. Altius does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Discretionary trading authority facilitates placing trades in clients accounts on their behalf so that we may efficiently implement the investment policy that they approved in writing. Limited Power of Attorney Clients must sign a limited power of attorney before Altius is given discretionary authority. The limited power of attorney is included in the custodian s account application. Voting Client Securities Proxy Votes Altius does not vote proxies on securities. Clients are expected to vote their own proxies. Clients will receive proxy notices directly from their custodians or transfer agents and not from Altius. If a Client needs assistance on voting proxies, they can request Altius for assistance by contacting Altius via phone, or mail. When assistance on voting proxies is requested, Altius will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. Financial Information Financial Condition Altius does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients. A balance sheet is not required to be provided because Altius does not serve as a custodian for client funds or securities, and does not require prepayment of fees of more than $500 per client, and six months or more in advance. Requirements for State-Registered Advisers Principal Executive Officer and Management Persons Please see Part 2B of this form for details. Other Businesses Please see Part 2B of this form for details. Neither Altius nor Mehmood Nathani is involved in any other businesses. 12

18 Performance-Based Fees Please see Page 6 for details. Disciplinary Disclosures The firm and its employees have not been involved in or found liable in an arbitration claim or civil, self-regulatory or administrative proceeding. Relationship with Issuers of Securities Neither Altius nor Mehmood Nathani has a relationship or arrangement with any issuers of securities. Business Continuity Plan General Altius has a Business Continuity Plan in place that provides steps to mitigate and recover from the loss of office space, communications, services or key people. Disasters The Business Continuity Plan covers natural and man-made disasters such as snow storms, hurricanes, tornados, flooding, loss of electrical power, loss of water pressure, fire, bomb threat and Internet outage. Electronic files are backed up daily and archived offsite. Alternate Offices Alternate offices 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. Loss of Key Personnel Altius has not signed a Business Continuation Agreement with another financial advisory firm to support Altius in the event of Mehmood Nathani s serious disability or death. In such an instance, clients institutional accounts at Fidelity (the custodian holding their assets) will be converted to retail accounts available for the client to manage themselves. Information Security Program Information Security Altius maintains an information security program to reduce the risk that your personal and confidential information may be breached. 13

19 Privacy Notice Altius 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 you may include information about your personal finances, information about your health to the extent that it is needed for the financial planning process, information about transactions between you and third parties, and information from consumer reporting agencies, e.g., credit reports. We use this information to help you meet your personal financial goals. With your permission, we disclose limited information to attorneys, accountants, and mortgage lenders with whom you have established a relationship. You may opt out from our sharing information with these nonaffiliated third parties by notifying us at any time by telephone ( ), mail, fax ( ), (mnathani@altiusfin.com), or in person. With your permission, we share a limited amount of information about you with your brokerage firm in order to execute securities transactions on your behalf. We also share your information with our remote server host (Ntiva), portfolio management software vendor (Advent) and select financial planning software vendors. We maintain a secure office to ensure that your information is not placed at unreasonable risk. We employ a firewall barrier and other safeguards in our computer environment. We do not provide your personal information to mailing list vendors or solicitors. We require strict confidentiality in our agreements with unaffiliated third parties that require access to your personal information, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records and your personal records as permitted by law. Personally identifiable information about you will be maintained while you are a client, 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 you in advance if our privacy policy is expected to change. We are required by law to deliver this Privacy Notice to you annually, in writing. 14

20 MEHMOOD NATHANI ALTIUS FINANCIAL ADVISORS, LLC 3 BETHESDA METRO CENTER, SUITE 700 BETHESDA, MD TELEPHONE: FAX: WEBSITE: MNATHANI@ALTIUSFIN.COM Brochure Supplement (Part 2B of Form ADV) This brochure supplement provides information about Mehmood Nathani that supplements Altius Financial Advisor s brochure. You should have received a copy of that brochure. Please contact Mehmood Nathani at or mnathani@altiusfin.com if you did not receive Altius Financial Advisor s brochure or if you have any questions about the contents of this supplement. Additional information about Mehmood Nathani is available on at MARCH 26, 2014, LLC

21 Education and Business Standards ALTIUS FINANCIAL ADVISORS, LLC ( Altius) requires that Advisers in its employ have a bachelor's degree. Altius encourages but does not require employees to complete further coursework in financial planning and portfolio management. Examples of further coursework include: an MBA, a CFP, a CFA or a CPA. Professional Certifications Employees have earned certifications and credentials that are required to be explained in further detail. Certified Financial Planner (CFP): Certified Financial Planners are licensed by the CFP Board to use the CFP mark. CFP certification requirements: Bachelor s degree from an accredited college or university. Completion of the financial planning education requirements set by the CFP Board ( Successful completion of the 10-hour CFP Certification Exam. Three-year qualifying full-time work experience. Successfully pass the Candidate Fitness Standards and background check. Chartered Financial Analyst (CFA): Chartered Financial Analysts are licensed by the CFA Institute to use the CFA mark. CFA certification requirements: Hold a bachelor's degree from an accredited institution or have equivalent education or work experience. Successful completion of all three exam levels of the CFA Program. Have 48 months of acceptable professional work experience in the investment decision-making process. Fulfill society requirements, which vary by society. Unless you are upgrading from affiliate membership, all societies require two sponsor statements as part of each application; these are submitted online by your sponsors. Agree to adhere to and sign the Member's Agreement, a Professional Conduct Statement, and any additional documentation requested by CFA Institute

22 Mehmood Nathani, CFA, CFP Date of birth: September 24, 1959 Educational Background: Cornell University, Ithaca, NY, MBA, 1985 St. Xavier s College, Calcutta, India, Bachelor of Commerce, 1980 Professional Certifications/Affiliations: CFP Certified Financial Planner CFA Chartered Financial Analyst Chartered Accountant, India NAPFA-Registered Investment Adviser (Mehmood Nathani) Member, NAPFA, FPA, CFP Board, CFA Institute Business Experience:, LLC, MD, 2001 to Present, Owner Fannie Mae, DC, 1989 to 2001, Assistant Treasurer/VP, Director, Manager, Senior Analyst, Analyst. Radan Systems, Inc., MD, 1985 to 1989, Senior Analyst, Analyst G. Basu & Co., India, 1979 to 1982, Trainee Disciplinary Information: None Other Business Activities: None Additional Compensation: None Supervision: Mehmood Nathani supervises himself as he is the owner and sole employee of, LLC. He will establish, maintain and enforce written supervisory guidelines that are reasonably designed to achieve compliance with Regulation.13 of the Maryland Securities Act, Corporations and Associations Article, Title 11, Annotated Code of Maryland and the rules and regulations promulgated under it. Arbitration Claims: None Self-Regulatory Organization or Administrative Proceeding: None Bankruptcy Petition: None - 2 -