item 1: cover page alyssum benefits llc · part 2a of form adv: firm brochure p.o. box 1745...
TRANSCRIPT
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Item 1: Cover Page
Alyssum Benefits LLC
Part 2A of Form ADV: Firm Brochure
P.O. Box 1745
Thousand Oaks, CA 91358
Telephone (805) 501-0864
This Brochure is dated: May 9, 2013
THIS BROCHURE PROVIDES INFORMATION ABOUT THE QUALIFICATIONS
AND BUSINESS PRACTICES OF ALYSSUM BENEFITS LLC. IF YOU HAVE ANY
QUESTIONS ABOUT THE CONTENTS OF THIS BROCHURE, PLEASE CONTACT
US AT (805) 501-0864 or [email protected]. THE INFORMATION IN THIS
BROCHURE HAS NOT BEEN APPROVED OR VERIFIED BY ANY STATE
SECURITIES AUTHORITY.
ADDITIONAL INFORMATION ABOUT ALYSSUM BENEFITS LLC IS AVAILABLE
ONLINE AT WWW.ADVISERINFO.SEC.GOV.
REGISTRATION AS AN INVESTMENT ADVISER WITH ANY STATE SECURITIES
AUTHORITY DOES NOT IMPLY ANY CERTAIN LEVEL OF SKILL OR TRAINING.
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Item 2: Material Changes
This is an initial filing. Therefore, there have been no material changes.
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Item 3: Table of Contents
Table of Contents
Page No.
Item 1. Cover Page 1
Item 2. Material Changes 2
Item 3. Table of Contents 3
Item 4. Advisory Business 4
Item 5. Fees and Compensation 7
Item 6. Performance-Based Fees & Side By Side Management 10
Item 7. Types of Clients 11
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss 12
Item 9. Disciplinary Information 15
Item 10. Other Financial Industry Activities and Affiliations 16
Item 11. Code of Ethics, Participation or Interest in Client Transactions 19
and Personal Trading
Item 12. Brokerage Practices 22
Item 13. Review of Accounts 23
Item 14. Client Referrals and Other Compensation 24
Item 15. Custody 25
Item 16. Investment Discretion 26
Item 17. Voting Client Securities 27
Item 18. Financial Information 28
Item 19. Requirements for State-Registered Advisers 29
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Item 4: Advisory Business
Advisory Business
Alyssum Benefits LLC (“ALYSSUM”) is a newly registered investment
adviser in the state of California. It is a standalone investment adviser
(“Adviser”), and has been in business since March 2013. ALYSSUM is
a limited liability company that was formed in the State of California.
At this time, ALYSSUM is a single owner LLC and is solely operated
by its founder and chief executive officer, Thomas B. Krueger. Neither
ALYSSUM nor its CEO is a registered broker dealer.
ALYSSUM offers a variety of personalized investment advisory
services. ALYSSUM will evaluate the type of client and obtain the
necessary financial data. For retail clients, information such as
investment goals, risk tolerance, time horizon, liquidity needs, etc. will
be obtained. For pension plans, financial information and plan goals
will be obtained. The Adviser will review prior investments and current
holdings, as well as enter into a written advisory contract with the client.
These services will fall under one of the following programs:
A. Financial Planning Services
ALYSSUM engages in various forms of financial planning services for a
fee. Financial planning typically will involve providing a variety of
services, principally advisory in nature, to clients regarding the
management of their financial resources based upon an analysis of their
individual needs.
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B. Portfolio Management
ALYSSUM engages in portfolio management for individuals, small
businesses, pooled investment vehicles, for businesses other than small
businesses and institutional clients. ALYSSUM provides investment
advisory services to these clients based upon their individual investment
objectives, guidelines and restrictions, as provided by the client.
ALYSSUM does not maintain custody or use discretion on these
accounts.
C. Pension Consulting Services
ALYSSUM will provide pension consulting services to plans. These
services may include advice on plan menu of investments, and an
analysis of the plan expenses.
D. Selection of Other Advisers
ALYSSUM may enter into agreements with unaffiliated money
managers to offer managed account services to its clients. Under these
agreements, the money managers will agree to provide various types of
managed account services to the clients of ALYSSUM. All money
managers utilized by ALYSSUM will be licensed as investment advisers
in all applicable states or with the SEC. ALYSSUM’s clients will enter
into a direct contract with the money manager as well. The
compensation of both ALYSSUM and the managed account program
will be fully disclosed to the client. The charged may be part of a wrap
fee arrangement. In a wrap fee arrangement, the Client pays a single fee
for advisory, brokerage, and custodial services provided by the money
manager. The various fees involved will be reviewed with the Client.
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E. Education & Publication of Material
ALYSSUM may, from time to time, publish periodicals or newsletters.
ALYSSUM may also hold educational seminars and workshops. These
materials may be provided to its clients for free as part of a bundled
service, or a fee may be charged separately.
F. Other: Referral Program
In some circumstances, ALYSSUM will refer a Client to another
registered entity (broker-dealer or investment adviser) for a fee.
Pursuant to California Code of Regulations, 10 CCR Section 260.235.2,
ALYSSUM hereby makes the following statement: a conflict exists
between the interest of ALYSSUM and the interests of the Client.
Further, the Client is under no obligation to act upon ALYSSUM’s
recommendations, and if the Client elects to act on any of the
recommendations, the Client is under no obligation to effect the
transactions through the Firm.
All advisory services are offered to clients of ALYSSUM (natural
persons, formed entities, group plans, etc.) on a non-discretionary basis.
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Item 5: Fees and Compensation
Fees and Compensation
Fees will be determined based on the type of advisory activity, but may
include advisory fees, hourly consulting fees, subscription fees, fixed
fees and referral program fees. The maximum annual advisory fee for
money management is 2% of assets under management, per annum, but
an initial fee may be larger depending on the plan. For referral fees,
there is no maximum. However, all contracts will be reviewed for
suitability.
Advisory fees are charged for ongoing services and based on assets
under management. As described in other sections, the fee for this
service is variable depending on the service provided, assets under
management, and other factors. However, 2% of assets under
management, per annum, is the maximum (0% being the unusual
minimum). These fees are typically paid by the administrator or vendor
to ALYSSUM on a periodic basis, usually quarterly.
Hourly consulting fees are charged in lieu of or in conjunction with
advisory fees for start-up plans. These fees are used for one-time
services, financial plans, or when a Client does not want to attach the fee
to the assets in question. The fee is typically negotiated, invoiced after
the service is provided to the Client. As the fee is not related to assets
and negotiated based on services to be determined, there is no set
minimum or maximum.
Subscription fees are typically for newsletters, workshops or other
materials that are educational. These fees may often be waived for
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clients paying advisory or consulting fees, but is the only service
requested, there will be a charge. As with the consulting fee, typically
these fees are not attached to assets and negotiated based on services to
be provided. The fee is invoiced after the service is provided to the
Client. As the fee is not related to assets and negotiated based on
services to be determined, there is no set minimum or maximum.
Fixed fees refer to an Client account where the Client requests a fixed
fee instead of an advisory fee. These fees may be on-going or for a one
time one-time service. The fee is typically negotiated, and invoiced after
the service is provided to the Client (or period it is provided). As the fee
is not a percentage of assets and negotiated based on services to be
determined, there is no set minimum or maximum.
Referral fees could come from the selection of other advisers or
receiving fees from other registered entities when business is referred to
them. Typically, ALYSSUM will receive a percentage of that adviser or
entity's fee. In all cases, ALYSSUM will disclose its relationship, how
much it receives and what the payment schedule is to the Client.
ERISA Accounts: ALYSSUM is deemed to be a fiduciary to advisory
clients that are employee benefit plans or individual retirement accounts
(IRAs) pursuant to the Employee Retirement Income Security Act
("ERISA"), and regulations under the Internal Revenue Code of 1986
(the "Code"), respectively. As such, ALYSSUM is subject to specific
duties and obligations under ERISA and the Internal Revenue Code that
include among other things, restrictions concerning certain forms of
compensation. To avoid engaging in prohibited transactions, ALYSSUM
may only charge fees for investment advice about products for which
ALYSSUM and/or its related persons do not receive any commissions or
12b-1 fees, or conversely, investment advice about products for which
ALYSSUM and/or ALYSSUM related persons receive commissions or
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12b-1 fees, however, only when such fees are used to offset ALYSSUM
advisory fees.
Advisory Fees in General: clients should note that similar advisory
services may (or may not) be available from other registered (or
unregistered) investment advisers for similar or lower fees.
Limited Prepayment of Fees: Under no circumstances does ALYSSUM
require or solicit payment of fees in excess of $500 more than six
months in advance of services rendered.
It is ALYSSUM’s policy to avoid engaging in prohibited transactions.
ALYSSUM may only charge fees for investment advice about products
for which ALYSSUM and/or its related persons do not receive any
commissions or 12b-1 fees.
Fees may be deducted from client’s assets or billed to the Clients. This
arrangement will be negotiated prior to the execution of the contract and
indicated within. Fees will be paid periodically, at the determination of
the ADVISER or per the contract with the client. The fee, if based on
assets, will be based on the market value of the account as of the close of
business on the last business date of the previous quarter. The fee will
be assessed promptly by ALYSSUM.
Client is responsible for paying (i) all expenses of transfer, receipt,
safekeeping, servicing and accounting for the account, including all
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custodial fees charged by the custodian; (ii) all broker’s commission and
other charges incidental to the purchase, sale or lending of the account,
and (iii) all taxes or other fees payable by or with respect to client
federal, state or other government agencies. Expenses will be paid by
client directly or by directing the custodian to pay such expenses.
Fees are typically billed in arrears on a quarterly basis. If a third party
adviser contract dictates otherwise or a Client requests as much, billing
may be done otherwise. If the effective date of termination of the
contract occurs during the quarter in which the notice of termination is
given and is other than the last day of a calendar quarter for which
ALYSSUM has received payment, ALYSSUM shall be entitled to retain
its entire fee for such quarter; provided that if the termination date
extends beyond the last day of the quarter in which the notice is given
and into a new calendar quarter for which ALYSSUM has not been
previously paid, the Client shall pay to ALYSSUM a pro rata portion of
its quarterly fee for such additional period. Any such additional fee shall
be paid concurrently with the notice of termination if given by Client
and within 5 business days following the notice of termination by
ALYSSUM.
Neither ALYSSUM nor any of its supervised persons accepts
compensation for the sale of securities or other investment products,
including asset-based sales charges or service fees from the sale of
mutual funds. This practice would present a conflict of interest and
provide an incentive to recommend investment products based on the
compensation received, rather than on a client’s need.
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ALYSSUM is not affiliated with a broker-dealer or an insurance
company, but will disclose review and disclose any potential conflicts of
interest that may arise.
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Item 6: Performance Based Fees & Side by Side Management
Performance Based Fees & Side-By-Side
Management
ALYSSUM does not accept performance based fees.
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Item 7: Types of Clients
Types of Clients
ALYSSUM provides advisory services to the following types of clients:
Individuals (other than high net worth individuals)
High net worth individuals
Pooled Investment Vehicles
Pension and profit sharing plans (other than plan participants)
Charitable organizations
Corporations or other businesses not listed above
State or municipal government entities
Other Investment Advisers
ALYSSUM does not have an account minimum or other restraints.
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Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis, Investment Strategies and
Risk of Loss
METHODS OF ANALYSIS
ALYSSUM uses the following methods of analysis in formulating its
investment advice and/or managing client assets:
ALYSSUM evaluates the experience, expertise, investment
philosophies, and past performance of investments with in an effort to
determine whether that investment has demonstrated the ability to
perform over a period of time and under different economic conditions.
ALYSSUM monitors the investments’ underlying holdings, strategies,
concentrations, and leverage as part of its overall periodic risk
assessment. In addition, as part of ALYSSUM’s process, it will conduct
due diligence on the identified investments’ operations, compliance and
business functions.
The use of an investment also involves the risk that it will deviate from
its stated allocation or past performance. Also, ALYSSUM may be
unaware of changes in its controls, management, systems, or other
business issues that could impact its performance.
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Past performance does not guarantee future results. Current performance
may be lower or higher than the performance data quoted. The principal
value and investment return of an investment will fluctuate so that the
investment, when redeemed, may be worth more or less than the original
cost. Please consider the investment objectives, risks, charges and
expenses carefully before investing.
Risks for all forms of analysis. ALYSSUM’s analysis methods rely on
the assumption that the investment with which it contracts, the rating
agencies that review the investments, and other publicly-available
sources of information about these investments, are providing accurate
and unbiased data. While ALYSSUM is alert to indications that data
may be incorrect, there is always a risk that ALYSSUM’s analysis may
be compromised by inaccurate or misleading information.
INVESTMENT STRATEGIES
ALYSSUM uses the following strategies in managing client accounts,
provided that such strategies are appropriate to the needs of the client
and consistent with the client's investment objectives, risk tolerance, and
time horizons, among other considerations:
Long-term purchases. ALYSSUM recommends the purchase of
investments with the idea of holding them for the client for a year or,
more likely, longer. ALYSSUM considers these to be "strategic"
investments. Typically ALYSSUM employs this strategy when the
investment is a critical piece of a client’s portfolio and will perform well
versus a set benchmark.
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A risk in a long-term purchase strategy is that by holding the investment
for this length of time, the client may not take advantage of short-term
gains that could be profitable. Moreover, if ALYSSUM’s predictions are
incorrect, an investment may decline sharply in value before ALYSSUM
makes the recommendation to sell.
Short-term purchases. In contrast to "strategic" investments, are
"tactical" investments. When utilizing this strategy, ALYSSUM
recommends the purchase of investments with the idea of selling them
within a relatively short time (typically less than 18 months, sometimes
less than a year). ALYSSUM does this in an attempt to take advantage
of conditions that it believes will soon result in a price swing in the
securities we purchase.
A short-term purchase strategy poses risks should the anticipated price
swing not materialize; the client is then left with the option of having a
long-term investment that was designed to be a short-term purchase, or
potentially taking a loss.
In addition, this strategy involves more frequent trading than does a
longer-term strategy, and will result in increased transaction-related
costs, as well as less favorable tax treatment of short-term capital gains.
RISK OF LOSS
Securities investments are not guaranteed and the client may lose money
on investments. ALYSSUM asks that clients communicate their
tolerance for risk.
Investing in securities involves risk of loss that clients should be
prepared to bear.
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Item 9: Disciplinary Information
Disciplinary Information
ALYSSUM is required to disclose any legal or disciplinary events that
are material to a client's or prospective client's evaluation of its advisory
business or the integrity of its management.
ALYSSUM and its management personnel have no reportable
disciplinary events to disclose.
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Item 10: Other Financial Industry Activities and Affiliations
Other Financial Industry Activities and
Affiliations
ALYSSUM is a standalone state registered investment adviser.
The CEO of ALYSSUM is also a California life and health life
insurance sales agent that is not affiliated with an insurance brokerage
company. He may offer such services to clients directly as an agent.
The CEO may engage in consulting services outside the scope of
ALYSSUM, such as compliance consulting, expert witness or arbitration
and mediation work, or business consulting.
ALYSSUM nor any of its management persons are registered, or have
an application pending to register, as a futures commission merchant,
commodity pool operator, a commodity trading advisor, or an associated
person of the foregoing entities, disclose this fact.
All money managers utilized by ALYSSUM will be licensed as
investment advisers in all applicable states or with the SEC.
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics
ALYSSUM has adopted a Code of Ethics which sets forth high ethical
standards of business conduct that it requires of its employees, including
compliance with applicable state and federal securities laws.
ALYSSUM and its personnel owe a duty of loyalty, fairness and good
faith towards its clients, and have an obligation to adhere not only to the
specific provisions of the Code of Ethics but to the general principles
that guide the Code.
The Code of Ethics includes policies and procedures for the review of
quarterly statements as well as initial account paperwork that must be
reviewed by the ALYSSUM’ Compliance Personnel. The Code also
provides for oversight, enforcement and recordkeeping provisions.
ALYSSUM’s Code of Ethics further includes the firm's policy
prohibiting the use of material non-public information. While
ALYSSUM does not believe that it has any particular access to non-
public information, all employees are reminded that such information
may not be used in a personal or professional capacity.
A copy of the Code of Ethics is available to ALYSSUM’s advisory
clients and prospective clients. Clients may request a copy by email sent
to [email protected], or by calling at 805-501-0864.
The Code of Ethics is designed to assure that the personal investment
transactions, activities and interests of ALYSSUM’s employees will not
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interfere with (i) making decisions in the best interest of advisory clients
and (ii) implementing such decisions while, at the same time, allowing
employees to invest for their own accounts.
ALYSSUM and/or the individuals associated with ALYSSUM may buy
or sell for their personal accounts investments identical to or different
from those recommended to its clients. In addition, any related person(s)
may have an interest or position in a certain investment(s) which may
also be recommended to a client.
It is the policy of ALYSSUM that no person employed by ALYSSUM
may purchase or sell any investment prior to a transaction(s) being
implemented for an advisory account, thereby preventing such
employee(s) from benefiting from transactions placed on behalf of
advisory accounts.
As these situations represent actual or potential conflicts of interest to
clients, ALYSSUM has established the following policies and
procedures for implementing a Code of Ethics, to ensure that
ALYSSUM complies with its regulatory obligations and provides its
clients and potential clients with full and fair disclosure of such conflicts
of interest:
1. No principal or employee of ALYSSUM may put his or her own
interest above the interest of an advisory client.
2. No principal or employee of ALYSSUM may buy or sell investments
for his/her personal portfolio(s) where the decision is a result of
information received as a result of his or her employment unless the
information is also available to the investing public.
3. It is the policy of ALYSSUM that no person employed by ALYSSUM
may purchase or sell any investment prior to a transaction(s) being
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implemented for an advisory account. This prevents such employees
from benefiting from transactions placed on behalf of advisory accounts.
4. ALYSSUM maintains a list of all reportable investment holdings for
ALYSSUM and anyone associated with this advisory practice that has
access to advisory recommendations ("access person"). These holdings
are reviewed on a regular basis by the firm's Chief Compliance Officer
or his/her designee.
5. ALYSSUM has established procedures for the maintenance of all
required books and records.
6. Clients can decline to implement any advice rendered.
7. All of ALYSSUM’s principals and employees must act in accordance
with all applicable Federal and State regulations governing registered
investment advisory practices.
8. We require delivery and acknowledgement of the Code of Ethics by
each supervised person of ALYSSUM.
9. We have established policies requiring the reporting of Code of Ethics
violations to ALYSSUM senior management.
10. Any individual who violates any of the above restrictions may be
subject to termination.
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Item 12: Brokerage Practices
Brokerage Practices
ALYSSUM selects or recommends third party broker-dealers for
transactions based on best execution.
Research and Other Soft Dollar Benefits. ALYSSUM does not receive
research or other products or services other than execution from a
broker-dealer or a third party in connection with client securities
transactions (“soft dollar benefits”).
Brokerage for Client Referrals. ALYSSUM recommends broker-dealers,
and it may have agreements in place to receive client referrals from a
broker-dealer or third party for such services in the future.
Directed Brokerage. ALYSSUM does not recommend, request or
require that a Client use a specific broker-dealer. Further, a client may
not request its brokerage to be directed.
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Item 13: Review of Accounts
Review of Accounts
Review of Accounts: Clients receive statements and confirmations of
transactions from the custodian and may receive annual performance
reports, depending on the advisory service requested. ALYSSUM does
not produce any statements; however, it will review performance
quarterly and at account establishment. Presently, the review is
conducted by its Chief Compliance Officer, Thomas Krueger.
Review of Accounts: ALYSSUM does not produce any statements at
this time, however, it will review billings as they occur and at account
establishment.
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Item 14: Client Referrals and Other Compensation
Client Referrals and Other Compensation
Referrals
ALYSSUM may pay referral fees for introducing clients. Alternatively,
ALYSSUM may receive compensation for referring a client. When we
receive or pay a fee, the solicitor will be required to do the following:
- Provide a copy of this brochure to all prospective clients
- Provide a disclosure statement including the solicitor’s name,
relationship to ALYSSUM, details about the fee, etc.
- As a matter of firm protocol, the fee paid by the client will
not be increased as a result of the referral.
Other Compensation
ALYSSUM and its related persons may pay or receive other forms of
compensation for engaging in its usual business activities. At all times,
ALYSSUM will endeavor to put the interests of its clients first as part of
its fiduciary duty, however, this compensation may create a conflict of
interest, and may affect the judgment of those individuals involved.
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Item 15: Custody
Custody
ALYSSUM does not maintain custody of client funds.
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Item 16: Investment Discretion
Investment Discretion
ALYSSUM does not accept discretionary authority to manage accounts
on behalf of clients.
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Item 17: Voting Client Securities
Voting Client Securities
Unless otherwise instructed to do so, ALYSSUM will vote all client
proxies. Clients have the option to request their voting privileges on the
contract, in which case all voting privileges will be sent to them.
A change in a client’s voting privileges or a copy of ALYSSUM’s proxy
voting policies and procedures may be requested in writing.
Per Rule 206(4)-6 under the Advisers Act, ALYSSUM will vote proxies
in the best interests of clients. ALYSSUM will disclose to clients
information about those policies and procedures, and disclose to clients
how they obtain information on how ALYSSUM has voted their proxies.
ALYSSUM will maintain necessary records relating to proxy voting.
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Item 18: Financial Information
Financial Information
ALYSSUM does not require or solicit prepayment of more than $500 in
fees per client, six months or more in advance.
ALYSSUM does not have discretionary authority or custody of Client
funds or securities, or require or solicit prepayment of more than $500 in
fees per Client, six months or more in advance.
ALYSSUM has not been the subject of a bankruptcy petition during the
past ten years.
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Item 19: Requirements for State-Registered Advisers
Requirements for State-Registered Advisers
A. Thomas B. Krueger will act as chief executive officer and chief
compliance officer. This officer is identified in ALYSSUM’s Form
ADV Part 1.
B. ALYSSUM is a single member LLC and standalone investment
adviser, and offers a variety of advisory products. ADVISER will spend
a varying amount of time on each business, but will be actively engaged
as an ADVISER in no less than 10% of its time.
C. Neither ALYSSUM nor any of its supervised persons accepts
performance-based fees.
D. Neither ALYSSUM nor any of its supervised persons have been
involved in any of the following:
1. An award or otherwise being found liable in an arbitration claim
alleging damages in excess of $2,500, involving any of the
following:
(a) an investment or an investment-related business or
activity;
(b) fraud, false statement(s), or omissions;
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(c) theft, embezzlement, or other wrongful taking of
property;
(d) bribery, forgery, counterfeiting, or extortion; or
(e) dishonest, unfair, or unethical practices.
2. An award or otherwise being found liable in a civil, self-
regulatory organization, or administrative proceeding involving
any of the following:
(a) an investment or an investment-related business or
activity;
(b) fraud, false statement(s), or omissions;
(c) theft, embezzlement, or other wrongful taking of
property;
(d) bribery, forgery, counterfeiting, or extortion; or
(e) dishonest, unfair, or unethical practices.
E. Neither ALYSSUM nor any of its management persons have any
relationship with any issuer of securities.
None of the money managers are compensated with performance-based
fees.
Pursuant to California Code of Regulations, CCR Section 260.238 (k),
ALYSSUM hereby makes the following statement: A conflict inherently
exists between a person or firm that, for compensation, is engaged in the
act of providing advice, making recommendations, issuing reports or
furnishing analyses on securities, either directly or through publications
and the entity compensating it or them.
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Part 2B of Form ADV: Brochure Supplement
Alyssum Benefits LLC
Item 1 – Cover Page
P.O. Box 1745
Thousand Oaks, CA 91358
Telephone (805) 501-0864
Revised 05/09/2013
- Thomas B. Krueger, MBA
This Brochure Supplement provides information on ALYSSUM’S
personnel listed above and supplements the Brochure. Clients should
have also received a copy of the Brochure. If clients have not received
the firm's Brochure, have any questions about professional designations
or about any content of this supplement, please contact the firm at 805-
501-0864.
Additional information about ALYSSUM’s personnel is available on the
website: www.Adviserinfo.sec.gov.
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Thomas B. Krueger
Chief Executive Officer
Chief Compliance Officer
Item 2 – Educational Background and Business Experience
Year of Birth: 1973
Education:
MBA Finance, Marshall School of Business, Los Angeles, CA 2005
BA Psychology, UCLA, Los Angeles, CA 1995
Business Background:
- Alyssum Benefits LLC 2013 – Present CEO & CCO
- HUB Int’l Investment Services Inc. 2011 – 2013 President & CCO
- Financial West Group 2009- 2011 Chief Compliance Officer
- SunAmerica Retirement Markets Inc. 2004 - 2009 Asst. Vice
President, Investment Product Management
- Financial West Group 2000- 2004 Compliance Officer
Item 3 - Disciplinary Information
Thomas B. Krueger has no disciplinary disclosures to be reported.
Item 4 - Other Business Activities
Thomas B. Krueger is currently a life and health agent in CA.
Item 5 - Additional Compensation
Thomas B. Krueger receives compensation for providing advisory
services at ALYSSUM.
Item 6 - Supervision
Thomas B. Krueger is the presently the sole owner and operator of
Alyssum Benefits LLC.
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Item 6 - Requirements for State-Registered Advisers
A. In addition to the events listed in Item 3 of Part 2B above, the
following are disclosed about Thomas B. Krueger:
1. An award or otherwise being found liable in an arbitration claim
alleging damages in excess of $2,500, involving any of the
following:
(a) an investment or an investment-related business or
activity; NO
(b) fraud, false statement(s), or omissions; NO
(c) theft, embezzlement, or other wrongful taking of property; NO
(d) bribery, forgery, counterfeiting, or extortion; NO or
(e) dishonest, unfair, or unethical practices. NO
2. An award or otherwise being found liable in a civil, self-
regulatory organization, or administrative proceeding involving
any of the following:
(a) an investment or an investment-related business or activity; NO
(b) fraud, false statement(s), or omissions; NO
(c) theft, embezzlement, or other wrongful taking of property; NO
(d) bribery, forgery, counterfeiting, or extortion; NO or
(e) dishonest, unfair, or unethical practices. NO
B. If Thomas B. Krueger has been the subject of a bankruptcy petition,
disclose that fact, the date the petition was first brought, and the current
status. Not applicable.