It is required to be made available to investors upon entering into an advisory agreement with an Advisor. Steve Henning is the fund manager, born in 1947, with a Bachelor of Science degree and advanced education in financial planning. He has been an investment manager for at least the past five years.
All accounts are on the same level.
The triggering factor is the end of the month. The reviewer is Steve Henning, qualifying principal of the firm who is responsible for record keeping, maintenance and reviews. There are no instructions from the advisor. All accounts are assigned to him. There are no brokers or dealers or commissions.