Polero ICE Advisers, L.L.C.

Personal Financial Advisory and Planning Services

Business Philosophy

Clients of Polero ICE Advisers will always receive straightforward answers, and will be provided with relevant information in a clear and professional manner. Clients can expect to receive comprehensive financial assistance that is tailor-made to their specific needs, and can be certain that their interests will always be considered first. All business will be conducted with the highest integrity and with full transparency.

The Adviser believes that too many individuals are taken advantage of by high-pressured, overly-aggressive salespeople and professionals who do not act as true fiduciaries when dealing with clients. Instead of offering the best advice for a particular client, more expensive, sub-optimal solutions are often provided. This type of poor service can have long-term, highly detrimental effects on an individual's wealth.

Minimizing the costs of investing is critical to everyone’s financial health. It is important that we avoid the fee-laden, overly-complex products often pushed or selected by brokers and investment firms for their clients' accounts. Often, a broker has an economic incentive to get our money into funds with hard-to-identify fees that can add up to over 3% annually. This is money that comes directly out of our pockets each year -- money that will not be there when we need it for our retirement and other important goals.

Continuously paying high fees to have our money actively traded, is very likely to result in significantly less wealth accumulation than if we invest in a well-diversified, low-cost portfolio. Polero ICE Advisers can assist you in designing such a portfolio, and any fee that the Firm earns will be completely transparent to you.

Listening to your financial concerns and understanding both your short and long-term objectives is a crucial first step in formulating your financial plan. Your individual situation is unique, and many factors need to be considered when deciding what products and services are best for you.

Working closely with you, the Adviser can provide you with the peace of mind that comes from having a sound strategy to achieve your investment and estate planning goals.

Best Practices: A Professional Code of Conduct

Polero ICE Advisers commits to a high code of professional conduct.  As part of that commitment, the Adviser participates in the Best Practices Fiduciary Advisor Affirmation Program, as published by the Institute for the Fiduciary Standard.  An explanation of these Practices is provided below:

The Institute for the Fiduciary Standard’s Best Practices, a professional code of conduct for fiduciary advisors, outlines what advisors agree to do for clients. These Best Practices are listed below, along with the requirements of each practice, which are shown in italics.  These are the specific actions that aim to uphold a high standard. A firm subscribing to Best Practices pledges to:

1.. Affirm the fiduciary standard under the Advisers Act of 1940, common law and, if applicable, ERISA and DOL’s COI Rule, govern all professional advisory client relationships at all times. 

    Fiduciary status, as required in law, applies at all times in all client engagements and this affirmation is stated in writing. 

2. Establish and document a “reasonable basis” for advice in the best interest of the client. 

    Advice is given on a “reasonable basis” and a summary of this “reasonable basis” will be provided by your advisor in writing upon request. 

3. Communicate clearly and truthfully, both orally and in writing. Do not mislead. Make all disclosures and important agreements in writing. 

    All important client agreements and disclosures are put in writing and that no written or verbal statements are misleading. 

4. Provide a written statement of total fees and underlying investment expenses paid by the client. Include any payments to the advisor or the firm or related parties from any third party resulting from the advisor’s recommendations. 

    Your advisor provides a good faith estimate of fees and expenses in writing during the starting phase of the engagement when the investment policy is agreed to. Thereafter, your advisor will offer to all clients and will provide, upon request, an annual good faith estimate in writing of total fees and expenses incurred by each client and paid to the firm or related parties because of my advice. 

5. Avoid conflicts and potential conflicts. Disclose all unavoidable potential and actual conflicts. Manage or mitigate material conflicts. Acknowledge that material conflicts of interest are incompatible with objective advice. 

   Your advisor seeks to avoid conflicts of interest. For unavoidable conflicts, your advisor 1) affirmatively discloses the conflict with ‘sufficiently specific facts’ to allow client understanding, and 2) manages the conflict to preserve the clients best interests. For material conflicts your advisor 3) obtains informed written client consent. Also, 4) your advisor affirms the transaction remains consistent with the client’s best interests. Further, he or she provides clients and prospective clients a written description of conflicts and steps to manage them. 

6. Abstain from principal trading unless a client initiates an order to purchase the security on an unsolicited basis. 

   Your advisor abstains from principal trading – unless specifically requested by a client without your advisor’s urgings. 

7. Avoid compensation in association with client transactions. If such compensation is unavoidable, demonstrate how the conflict is managed and overcome and the product recommendation and compensation serves the client’s best interest. 

   Your advisor does not receive compensation in association with a client transaction. 

8. Avoid gifts or entertainment that are not minimal and not occasional. Avoid third party payments, “benefits” and indirect payments that do not generally benefit the firm’s clients and may reasonably be perceived to impair objectivity. 

   Gifts and entertainment received are minimal and occasional. Any third party compensation or benefits received by the firm generally benefit the firm’s clients and do not impair my objectivity. 

9. Ensure baseline knowledge, competence and ongoing education appropriate for the engagement. 

   Your advisor’s education, professional certifications and ongoing education are appropriate for client engagements, and, at minimum, include an undergraduate degree and either a relevant post graduate education or a specialized designation or certification requiring significant additional education. 

10. Institute an investment policy statement (IPS) or an investment policy process (IPP) that is appropriate to the engagement and describes the investment strategy. Have access to a representative universe of investment vehicles that provide ample options to meet the desired asset allocation in consideration of generally accepted criteria. 

   An investment policy statement or investment policy is developed and furnished in writing to each client, and a sample copy of each document is available on request to any prospective client. 

11. Consider peer group rankings or apply specific procedures in ensuring underlying investment expenses are reasonable. 

   Your advisor benchmarks the fees and costs clients incur with reliable services or surveys other resources and / or has procedures to determine that client expenses are reasonable. 

12. The advisor affirms in writing adherence to Best Practices, and attains written affirmation from the firm that these business practices may be met by the advisor. 

   Your advisor affirms adherence to Best Practices and no firm policy interferes with this adherence. 

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