Form ADV

Beacon Asset Management Inc.

Firm Brochure(Part 2A of Form ADV)

Beacon Asset Management, Inc.16514 N Dale Mabry Highway

Tampa Florida 33618(813) 269-0732

(813) 961-1963 [email protected]

This brochure provides information about the qualifications and businesspractices of Beacon Asset Management, Inc. If you have any questionsabout the contents of this brochure, please contact us at: (813) 269-0732,or by email at: [email protected]. The information in this brochurehas not been approved or verified by the United States Securities andExchange Commission, or by any state securities authority.Registration with any state or the SEC does not imply any certain level ofskill or training.Additional information about Beacon Asset Management, Inc. is availableon the SEC’s website at www.adviserinfo.sec.gov

March 29, 2011

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Material Changes

Annual UpdateThe Material Changes section of this brochure will be updated annually whenmaterial changes occur since the previous release of the Firm Brochure.

Material Changes since the Last UpdateThe U.S. Securities and Exchange Commission issued a final rule in July2010 requiring advisers to provide a Firm Brochure in narrative “plain English”format. The new final rule specifies mandatory sections and organization.

Full Brochure AvailableWhenever you would like to receive a complete copy of our Firm Brochure,please contact us by telephone at: (813) 269-0732 or by email at:[email protected].

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Table of Contents

Material Changes............................................................................................................ iAnnual Update ............................................................................................................ iMaterial Changes since the Last Update .................................................................... iFull Brochure Available ............................................................................................... i

Advisory Business ........................................................................................................ 1Firm Description......................................................................................................... 1Principal Owners........................................................................................................ 2Types of Advisory Services........................................................................................ 2Tailored Relationships ............................................................................................... 2Types of Agreements................................................................................................. 2Financial Planning Agreement ................................................................................... 2Advisory Service Agreement...................................................................................... 3Retainer Agreement................................................................................................... 4Investment Management Agreement ......................................................................... 4Tax Preparation Agreement....................................................................................... 4Hourly Planning Engagements .................................................................................. 4Asset Management .................................................................................................... 4Termination of Agreement ......................................................................................... 5

Fees and Compensation............................................................................................... 5Description................................................................................................................. 5Fee Billing .................................................................................................................. 5Other Fees................................................................................................................. 6Expense Ratios.......................................................................................................... 6Past Due Accounts and Termination of Agreement ................................................... 6

Performance-Based Fees ............................................................................................. 6Sharing of Capital Gains ............................................................................................ 6

Types of Clients............................................................................................................. 7Description................................................................................................................. 7Account Minimums..................................................................................................... 7

Methods of Analysis, Investment Strategies and Risk of Loss................................. 7Methods of Analysis................................................................................................... 7

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Investment Strategies ................................................................................................ 8Risk of Loss ............................................................................................................... 8

Disciplinary Information ............................................................................................... 9Legal and Disciplinary................................................................................................ 9

Other Financial Industry Activities and Affiliations ................................................... 9Financial Industry Activities........................................................................................ 9Affiliations .................................................................................................................. 9

Code of Ethics, Participation or Interest in Client Transactions and PersonalTrading ......................................................................................................................... 10

Code of Ethics.......................................................................................................... 10Participation or Interest in Client Transactions......................................................... 10Personal Trading...................................................................................................... 10

Brokerage Practices.................................................................................................... 10Selecting Brokerage Firms....................................................................................... 10Best Execution ......................................................................................................... 10Order Aggregation ................................................................................................... 11

Review of Accounts .................................................................................................... 11Periodic Reviews ..................................................................................................... 11Review Triggers ....................................................................................................... 11Regular Reports....................................................................................................... 11

Client Referrals and Other Compensation ................................................................ 11Incoming Referrals................................................................................................... 11Referrals Out ........................................................................................................... 12Other Compensation................................................................................................ 12

Custody........................................................................................................................ 12SEC “Custody” ......................................................................................................... 12Account Statements................................................................................................. 12Performance Reports............................................................................................... 12Net Worth Statements.............................................................................................. 12

Investment Discretion................................................................................................. 12Discretionary Authority for Trading........................................................................... 12Limited Power of Attorney........................................................................................ 13

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Voting Client Securities .............................................................................................. 13Proxy Votes ............................................................................................................. 13

Financial Information .................................................................................................. 13Financial Condition .................................................................................................. 13

Business Continuity Plan ........................................................................................... 14General .................................................................................................................... 14Disasters.................................................................................................................. 14Alternate Offices ...................................................................................................... 14Loss of Key Personnel ............................................................................................. 14

Information Security Program.................................................................................... 14Information Security ................................................................................................. 14Privacy Notice .......................................................................................................... 14Education and Business Standards ......................................................................... 16Professional Certifications ....................................................................................... 16MICHAEL LaVOY ChFC CFP®, CERTIFICATIONS ............................................... 18JOHN JONES, CERTIFICATIONS .......................................................................... 19W. MARIE GAY, MBA, CERTIFICATIONS .............................................................. 20

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Advisory Business

Firm DescriptionBeacon Asset Management, Inc., (“Beacon”) was founded in 1996.Beacon Asset Management, Inc. provides personalized confidential financialplanning and investment management to individuals, pension and profitsharing plans, trusts, estates, charitable organizations and small businesses.Advice is provided through consultation with the client and may include:determination of financial objectives, identification of financial problems, cashflow management, tax planning, insurance review, investment management,education funding, retirement planning, and estate planning.Beacon Asset Management, Inc. in its course of providing advice, might useannuities, insurance, stocks, bonds, mutual funds, limited partnerships, orother commissioned products. Beacon Asset Management, Inc. might be paidcash by or receive some economic benefit (including commissions,equipment or non-research services) from a non-client in connection withgiving advice to clients.Investment advice is an integral part of financial planning. In addition,Beacon Asset Management, Inc. advises clients regarding cash flow, collegeplanning, retirement planning, tax planning and estate planning.Investment advice is provided, with the client making the final decision oninvestment selection. Beacon Asset Management, Inc. does not act as acustodian of client assets. The client always maintains asset control. BeaconAsset Management, Inc. places trades for clients under a limited power ofattorney.A written evaluation of each client's initial situation is provided to the client,often in the form of a net worth statement. Periodic reviews are alsocommunicated to provide reminders of the specific courses of action thatneed to be taken. More frequent reviews occur but are not necessarilycommunicated to the client unless immediate changes are recommended.Other professionals (e.g., lawyers, accountants, insurance agents, etc.) areengaged directly by the client on an as-needed basis. Conflicts of interest willbe disclosed to the client in the unlikely event they should occur.The initial meeting, which may be by telephone, is free of charge and isconsidered an exploratory interview to determine the extent to which financialplanning and investment management may be beneficial to the client.

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Principal OwnersMichael LaVoy is a100% stockholder.

Types of Advisory ServicesBeacon Asset Management, Inc. provides investment supervisory services,also known as asset management services; manages investment advisoryaccounts not involving investment supervisory services; furnishes investmentadvice through consultations; issues periodicals about securities bysubscription; issues special reports about securities; and issues, charts,graphs, formulas, or other devices which clients may use to evaluatesecurities.On more than an occasional basis, Beacon Asset Management, Inc. furnishesadvice to clients on matters not involving securities, such as financial planningmatters, taxation issues, and trust services that often include estate planning.As of March 29, 2011, Beacon Asset Management, Inc. managesapproximately $25,000,000 in assets for approximately 60 clients.Approximately $20,000,000, is managed on a discretionary basis, and$5,000,000 is managed on a non-discretionary basis.

Tailored RelationshipsThe goals and objectives for each client are documented in our clientrelationship management system. Investment policy statements are createdthat reflect the stated goals and objective. Clients may impose restrictions oninvesting in certain securities or types of securities.Agreements may not be assigned without client consent.

Types of AgreementsThe following agreements define the typical client relationships.

Financial Planning AgreementA financial plan is designed to help the client with all aspects of financialplanning without ongoing investment management after the financial plan iscompleted.The financial plan may include, but is not limited to: a net worth statement; acash flow statement; a review of investment accounts, including reviewingasset allocation and providing repositioning recommendations; strategic taxplanning; a review of retirement accounts and plans includingrecommendations; a review of insurance policies and recommendations forchanges, if necessary; one or more retirement scenarios; estate planning

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review and recommendations; and education planning with fundingrecommendations.Detailed investment advice and specific recommendations are provided aspart of a financial plan. Implementation of the recommendations is at thediscretion of the client.The fee for a financial plan is predicated upon the facts known at the start ofthe engagement. The minimum fee is $1,000 and is negotiable. Sincefinancial planning is a discovery process, situations occur wherein the client isunaware of certain financial exposures or predicaments.In the event that the client’s situation is substantially different than disclosedat the initial meeting, a revised fee will be provided for mutual agreement.The client must approve the change of scope in advance of the additionalwork being performed when a fee increase is necessary.After delivery of a financial plan, future face-to-face meetings may bescheduled as necessary for up to one month. Follow-on implementation workis billed separately at the rate of $125 per hour.

Advisory Service AgreementMost clients choose to have Beacon Asset Management, Inc. manage theirassets in order to obtain ongoing in-depth advice and life planning. Allaspects of the client’s financial affairs are reviewed, including those of theirchildren. Realistic and measurable goals are set and objectives to reachthose goals are defined. As goals and objectives change over time,suggestions are made and implemented on an ongoing basis.The scope of work and fee for an Advisory Service Agreement is provided tothe client in writing prior to the start of the relationship. An Advisory ServiceAgreement includes: cash flow management; insurance review; investmentmanagement (including performance reporting); education planning;retirement planning; estate planning; and tax preparation, as well as theimplementation of recommendations within each area.The annual Advisory Service Agreement fee is based on a percentage of theinvestable assets according to the following schedule:

_1.00%_ on the first $1,000,000;_0.80%_ on the assets above $1,000,000.

The minimum annual fee is $1,000 and is negotiable Current clientrelationships may exist where the fees are higher or lower than the feeschedule above.Although the Advisory Service Agreement is an ongoing agreement andconstant adjustments are required, the length of service to the client is at theclient’s discretion. The client or the investment manager may terminate anAgreement by written notice to the other party. At termination, fees will bebilled on a pro rata basis for the portion of the quarter completed. The

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portfolio value at the completion of the prior full billing quarter is used as thebasis for the fee computation, adjusted for the number of days during thebilling quarter prior to termination.Tax preparation work is performed as an integral part of the Advisory ServiceAgreement. Eligible federal and applicable state returns are filedelectronically without an additional fee.

Retainer AgreementIn some circumstances, a Retainer Agreement is executed in lieu of anAdvisory Service Agreement when it is more appropriate to work on a fixed-fee basis. The annual fee for a Retainer Agreement is $5,000 and isnegotiable.

Investment Management AgreementAn Investment Management Agreement may be executed when financialplanning is not provided as part of the relationship. The annual fee for anInvestment Management Agreement is $1500 and is negotiable.

Tax Preparation AgreementTax preparation work performed separately from an Advisory ServiceAgreement or a Retainer Agreement is billed at a rate of $125 per hour.Minimum fee for tax preparation is $125. Eligible federal and applicable statereturns are filed electronically without an additional fee.

Hourly Planning EngagementsBeacon Asset Management, Inc. provides hourly planning services for clientswho need advice on a limited scope of work. The hourly rate for limited scopeengagements is $125.

Asset ManagementAssets are invested primarily in no-load or low-load mutual funds andexchange-traded funds, usually through discount brokers or fund companies.Fund companies charge each fund shareholder an investment managementfee that is disclosed in the fund prospectus. Discount brokerages may chargea transaction fee for the purchase of some funds.Stocks and bonds may be purchased or sold through a brokerage accountwhen appropriate. The brokerage firm charges a fee for stock and bondtrades. Beacon Asset Management, Inc. does not receive any compensation,in any form, from fund companies.Investments may also include: equities (stocks), warrants, corporate debtsecurities, commercial paper, certificates of deposit, municipal securities,investment company securities (variable life insurance, variable annuities,

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and mutual funds shares), U. S. government securities, options contracts,futures contracts, and interests in partnerships.Initial public offerings (IPOs) are not available through Beacon AssetManagement, Inc..

Termination of AgreementA Client may terminate any of the aforementioned agreements at any time bynotifying Beacon Asset Management, Inc. in writing and paying the rate forthe time spent on the investment advisory engagement prior to notification oftermination. If the client made an advance payment, Beacon AssetManagement, Inc. will refund any unearned portion of the advance payment.Beacon Asset Management, Inc. may terminate any of the aforementionedagreements at any time by notifying the client in writing. If the client made anadvance payment, Beacon Asset Management, Inc. will refund any unearnedportion of the advance payment.

Fees and Compensation

DescriptionBeacon Asset Management, Inc. bases its fees on a percentage of assetsunder management, hourly charges, fixed fees (not including subscriptionfees), subscription fees, commissions.Some Retainer Agreements may be priced based on the complexity of work,especially when asset management is not the most significant part of therelationship.Financial plans are priced according to the degree of complexity associatedwith the client’s situation.Fees are negotiable.

Fee BillingInvestment management fees are billed monthly, in advance, meaning thatwe invoice you before the monthly billing period has begun. Payment in full isexpected upon invoice presentation.Fees are usually deducted from a designated client account to facilitatebilling. The client must consent in advance to direct debiting of theirinvestment account.Fees for financial plans are billed 50% in advance, with the balance due upondelivery of the financial plan.

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Other FeesCustodians may charge transaction fees on purchases or sales of certainmutual funds and exchange-traded funds. These transaction charges areusually small and incidental to the purchase or sale of a security. Theselection of the security is more important than the nominal fee that thecustodian charges to buy or sell the security.Beacon Asset Management, Inc., in its sole discretion, may waive itsminimum fee and/or charge a lesser investment advisory fee based uponcertain criteria (e.g., historical relationship, type of assets, anticipated futureearning capacity, anticipated future additional assets, dollar amounts ofassets to be managed, related accounts, account composition, negotiationswith clients, etc.).New Advisory Service Agreement fees are calculated on a formula basis andadjusted for complexity of individual situations. The formula is based on grossincome, gross assets and other financial considerations.

Expense RatiosMutual funds generally charge a management fee for their services asinvestment managers. The management fee is called an expense ratio. Forexample, an expense ratio of 0.50 means that the mutual fund companycharges 0.5% for their services. These fees are in addition to the fees paidby you to Beacon Asset Management, Inc..Performance figures quoted by mutual fund companies in various publicationsare after their fees have been deducted.

Past Due Accounts and Termination of AgreementBeacon Asset Management, Inc. reserves the right to stop work on anyaccount that is more than 60 days overdue. In addition, Beacon AssetManagement, Inc. reserves the right to terminate any financial planningengagement where a client has willfully concealed or has refused to providepertinent information about financial situations when necessary andappropriate, in Beacon Asset Management, Inc.’s judgment, to providingproper financial advice. Any unused portion of fees collected in advance willbe refunded within 15 days.

Performance-Based Fees

Sharing of Capital GainsFees are not based on a share of the capital gains or capital appreciation ofmanaged securities.Beacon Asset Management, Inc. does not use a performance-based feestructure because of the potential conflict of interest. Performance-based

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compensation may create an incentive for the adviser to recommend aninvestment that may carry a higher degree of risk to the client.

Types of Clients

DescriptionBeacon Asset Management, Inc. generally provides investment advice toindividuals, banks or thrift institutions, investment companies, pension andprofit sharing plans, trusts, estates, or charitable organizations, corporationsor business entities.Client relationships vary in scope and length of service.

Account MinimumsThe minimum account size is $100,000 of assets under management, whichequates to an annual fee of $1,000.When an account falls below $100,000 in value, the minimum annual fee of$1,000 is charged. Depending upon circumstances, Beacon AssetManagement, Inc. will sign an Hourly Agreement with the client if assets havediminished significantly below $100,000.Beacon Asset Management, Inc. has the discretion to waive the accountminimum. Accounts of less than $100,000 may be set up when the client andthe advisor anticipate the client will add additional funds to the accountsbringing the total to $100,000 within a reasonable time. Other exceptions willapply to employees of Beacon Asset Management, Inc. and their relatives, orrelatives of existing clients.Clients receiving ongoing asset management services will be assessed a$$1,000 minimum annual fee. Clients with assets below the minimum accountsize may pay a higher percentage rate on their annual fees than the fees paidby clients with greater assets under management.

Methods of Analysis, Investment Strategies and Risk of Loss

Methods of AnalysisSecurity analysis methods may include charting, fundamental analysis,technical analysis, and cyclical analysis.The main sources of information include financial newspapers andmagazines, inspections of corporate activities, research materials preparedby others, corporate rating services, timing services, annual reports,prospectuses, filings with the Securities and Exchange Commission, andcompany press releases.

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Other sources of information that Beacon Asset Management, Inc. may useinclude Morningstar Principia mutual fund information, Morningstar Principiastock information, Zack’s Investment Research service, Advisor Intelligence,and the World Wide Web.

Investment StrategiesThe primary investment strategy used on client accounts is strategic assetallocation utilizing a core and satellite approach. This means that we usepassively-managed index and exchange-traded funds as the coreinvestments, and then add actively-managed funds where there are greateropportunities to make a difference. Portfolios are globally diversified tocontrol the risk associated with traditional markets.The investment strategy for a specific client is based upon the objectivesstated by the client during consultations. The client may change theseobjectives at any time. Each client executes an Investment Policy Statementthat documents their objectives and their desired investment strategy.Other strategies may include long-term purchases, short-term purchases,trading, short sales, margin transactions, and option writing (includingcovered options, uncovered options or spreading strategies).

Risk of LossAll investment programs have certain risks that are borne by the investor.Our investment approach constantly keeps the risk of loss in mind. Investorsface the following investment risks:

Interest-rate Risk: Fluctuations in interest rates may cause investmentprices to fluctuate. For example, when interest rates rise, yields onexisting bonds become less attractive, causing their market values todecline.

Market Risk: The price of a security, bond, or mutual fund may drop inreaction to tangible and intangible events and conditions. This type ofrisk is caused by external factors independent of a security’s particularunderlying circumstances. For example, political, economic and socialconditions may trigger market events.

Inflation Risk: When any type of inflation is present, a dollar today willnot buy as much as a dollar next year, because purchasing power iseroding at the rate of inflation.

Currency Risk: Overseas investments are subject to fluctuations in thevalue of the dollar against the currency of the investment’s originatingcountry. This is also referred to as exchange rate risk.

Reinvestment Risk: This is the risk that future proceeds frominvestments may have to be reinvested at a potentially lower rate of

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return (i.e. interest rate). This primarily relates to fixed incomesecurities.

Business Risk: These risks are associated with a particular industry ora particular company within an industry. For example, oil-drillingcompanies depend on finding oil and then refining it, a lengthyprocess, before they can generate a profit. They carry a higher risk ofprofitability than an electric company, which generates its income froma steady stream of customers who buy electricity no matter what theeconomic environment is like.

Liquidity Risk: Liquidity is the ability to readily convert an investmentinto cash. Generally, assets are more liquid if many traders areinterested in a standardized product. For example, Treasury Bills arehighly liquid, while real estate properties are not.

Financial Risk: Excessive borrowing to finance a business’ operationsincreases the risk of profitability, because the company must meet theterms of its obligations in good times and bad. During periods offinancial stress, the inability to meet loan obligations may result inbankruptcy and/or a declining market value.

Disciplinary Information

Legal and DisciplinaryThe firm and its employees have not been involved in legal or disciplinaryevents related to past or present investment clients.

Other Financial Industry Activities and Affiliations

Financial Industry ActivitiesBeacon Asset Management, Inc. is not registered as a securities broker-dealer, or a futures commission merchant, commodity pool operator orcommodity trading advisor.

AffiliationsBeacon Asset Management, Inc. has arrangements that are material to itsadvisory business or its clients with a related person who is an investmentcompany, other investment advisor, financial planning firm, commodity pooloperator, commodity trading adviser or futures commission merchant,banking or thrift institution, accounting firm, law firm, insurance company oragency, pension consultant, real estate broker or dealer, or an entity thatcreates or packages limited partnerships i.e. Altamont Global Partners, LLC,Behringer Harvard LLC.

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Code of Ethics, Participation or Interest in ClientTransactions and Personal Trading

Code of EthicsThe employees of Beacon Asset Management, Inc. have committed to aCode of Ethics that is available for review by clients and prospective clientsupon request. The firm will provide a copy of the Code of Ethics to any clientor prospective client upon request.

Participation or Interest in Client TransactionsBeacon Asset Management, Inc. and its employees may buy or sell securitiesthat are also held by clients. Employees may not trade their own securitiesahead of client trades. Employees comply with the provisions of the BeaconAsset Management, Inc. Compliance Manual.

Personal TradingThe Chief Compliance Officer of Beacon Asset Management, Inc. is MichaelLaVoy. He reviews all employee trades each quarter. The personal tradingreviews ensure that the personal trading of employees does not affect themarkets, and that clients of the firm receive preferential treatment. Sincemost employee trades are small mutual fund trades or exchange-traded fundtrades, the trades do not affect the securities markets.

Brokerage Practices

Selecting Brokerage FirmsBeacon Asset Management, Inc. does not have any affiliation with productsales firms. Specific custodian recommendations are made to Clients basedon their need for such services. Beacon Asset Management, Inc.recommends custodians based on the proven integrity and financialresponsibility of the firm and the best execution of orders at reasonablecommission rates.Beacon Asset Management, Inc. recommends discount brokerage firms andtrust companies (qualified custodians), such as Folio Institutional, orScottrade. Beacon Asset Management, Inc. is an advisor with Curian Capital,Clark Capital and Flexible Plan Investments Ltd.Beacon Asset Management, Inc. does not receive fees or commissions fromany of these arrangements.

Best ExecutionBeacon Asset Management, Inc. reviews the execution of trades at eachcustodian each quarter. The review is documented in the Beacon Asset

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Management, Inc. Compliance Manual. Trading fees charged by thecustodians is also reviewed on a quarterly basis. Beacon AssetManagement, Inc. does not receive any portion of the trading fees.

Order AggregationMost trades are mutual funds or exchange-traded funds where tradeaggregation does not garner any client benefit.

Review of Accounts

Periodic ReviewsAccount reviews are performed quarterly by advisor Michael LaVoy CFP®.Account reviews are performed more frequently when market conditionsdictate.

Review TriggersOther conditions that may trigger a review are changes in the tax laws, newinvestment information, and changes in a client's own situation.

Regular ReportsAccount reviewers are members of the firm's Investment Committee. Theyare instructed to consider the client's current security positions and thelikelihood that the performance of each security will contribute to theinvestment objectives of the client.Clients receive periodic communications on at least an annual basis.Advisory Service Agreement clients, Investment Management clients, andRetainer Agreement clients receive written quarterly updates. The writtenupdates may include a net worth statement, portfolio statement, tax return (ifthe client requests tax preparation services), and a summary of objectivesand progress towards meeting those objectives.

Client Referrals and Other Compensation

Incoming ReferralsBeacon Asset Management, Inc. has been fortunate to receive many clientreferrals over the years. The referrals came from current clients, estateplanning attorneys, accountants, employees, personal friends of employeesand other similar sources. The firm does not compensate referring parties forthese referrals.

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Referrals OutBeacon Asset Management, Inc. does not accept referral fees or any form ofremuneration from other professionals when a prospect or client is referred tothem.

Other CompensationNot applicable

Custody

SEC “Custody”From time to time, Beacon Asset Management, Inc. may be considered tohave custody of certain types of accounts, such as when an employee acts asa trustee of an unrelated trust and the firm acts as the investment adviser tothat trust. When the firm has such custody, an annual surprise audit of thosecustodied accounts is performed by an independent CPA firm in compliancewith SEC requirements.

Account StatementsAll assets are held at qualified custodians, which means the custodiansprovide account statements directly to clients at their address of record atleast quarterly.

Performance ReportsClients are urged to compare the account statements received directly fromtheir custodians to the performance report statements provided by BeaconAsset Management, Inc..

Net Worth StatementsClients are frequently provided net worth statements and net worth graphsthat are generated from our client relationship management system. Networth statements contain approximations of bank account balances providedby the client, as well as the value of land and hard-to-price real estate. Thenet worth statements are used for long-term financial planning where theexact values of assets are not material to the financial planning tasks.

Investment Discretion

Discretionary Authority for TradingBeacon Asset Management, Inc. accepts discretionary authority to managesecurities accounts on behalf of clients. Beacon Asset Management, Inc. hasthe authority to determine, without obtaining specific client consent, thesecurities to be bought or sold, and the amount of the securities to be bought

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or sold. However, Beacon Asset Management, Inc. consults with the clientprior to each trade to obtain concurrence if a blanket trading authorization hasnot been given.The client approves the custodian to be used and the commission rates paidto the custodian. Beacon Asset Management, Inc. does not receive anyportion of the transaction fees or commissions paid by the client to thecustodian on certain trades.Discretionary trading authority facilitates placing trades in your accounts onyour behalf so that we may promptly implement the investment policy that youhave approved in writing.

Limited Power of AttorneyA limited power of attorney is a trading authorization for this purpose. Yousign a limited power of attorney so that we may execute the trades that youhave approved.

Voting Client Securities

Proxy VotesBeacon Asset Management, Inc. does not vote proxies on securities. Clientsare expected to vote their own proxies.When assistance on voting proxies is requested, Beacon Asset Management,Inc. will provide recommendations to the Client. If a conflict of interest exists,it will be disclosed to the Client.

Financial Information

Financial ConditionBeacon Asset Management, Inc. does not have any financial impairment thatwill preclude the firm from meeting contractual commitments to clients.A balance sheet is not required to be provided because Beacon AssetManagement, Inc. does not serve as a custodian for client funds or securities,and does not require prepayment of fees of more than $600 per client, and sixmonths or more in advance.

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Business Continuity Plan

GeneralBeacon Asset Management, Inc. has a Business Continuity Plan in place thatprovides detailed steps to mitigate and recover from the loss of office space,communications, services or key people.

DisastersThe Business Continuity Plan covers natural disasters such as snow storms,hurricanes, tornados, and flooding. The Plan covers man-made disasterssuch as loss of electrical power, loss of water pressure, fire, bomb threat,nuclear emergency, chemical event, biological event, T-1 communicationsline outage, Internet outage, railway accident and aircraft accident. Electronicfiles are backed up daily and archived offsite.

Alternate OfficesAlternate offices are identified to support ongoing operations in the event themain office is unavailable. It is our intention to contact all clients within fivedays of a disaster that dictates moving our office to an alternate location.

Loss of Key PersonnelBeacon Asset Management, Inc. has signed a Business ContinuationAgreement with another financial advisory firm to support Beacon AssetManagement, Inc. in the event of Michael LaVoy’s serious disability or death.

Information Security Program

Information SecurityBeacon Asset Management, Inc. maintains an information security program toreduce the risk that your personal and confidential information may bebreached.

Privacy NoticeBeacon Asset Management, Inc. is committed to maintaining theconfidentiality, integrity and security of the personal information that isentrusted to us.The categories of nonpublic information that we collect from you may includeinformation about your personal finances, information about your health to theextent that it is needed for the financial planning process, information abouttransactions between you and third parties, and information from consumerreporting agencies, e.g., credit reports. We use this information to help youmeet your personal financial goals.

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With your permission, we disclose limited information to attorneys,accountants, and mortgage lenders with whom you have established arelationship. You may opt out from our sharing information with thesenonaffiliated third parties by notifying us at any time by telephone, mail, fax,email, or in person. With your permission, we share a limited amount ofinformation about you with your brokerage firm in order to execute securitiestransactions on your behalf.We maintain a secure office to ensure that your information is not placed atunreasonable risk. We employ a firewall barrier, secure data encryptiontechniques and authentication procedures in our computer environment.We do not provide your personal information to mailing list vendors orsolicitors. We require strict confidentiality in our agreements with unaffiliatedthird parties that require access to your personal information, includingfinancial service companies, consultants, and auditors. Federal and statesecurities regulators may review our Company records and your personalrecords as permitted by law.Personally identifiable information about you will be maintained while you area client, and for the required period thereafter that records are required to bemaintained by federal and state securities laws. After that time, informationmay be destroyed.We will notify you in advance if our privacy policy is expected to change. Weare required by law to deliver this Privacy Notice to you annually, in writing.

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Brochure Supplement (Part 2B of Form ADV)

Education and Business StandardsBeacon Asset Management, Inc. requires that advisors in its employ have abachelor's degree and further coursework demonstrating knowledge offinancial planning and tax planning. Examples of acceptable courseworkinclude: an MBA, a CFP®, a CFA, a ChFC, JD, CTFA, EA or CPA.Additionally, advisors must have work experience that demonstrates theiraptitude for financial planning and investment management.

Professional CertificationsEmployees have earned certifications and credentials that are required to beexplained in further detail.Certified Financial Planner (CFP): Certified Financial Planners are licensedby 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 theCFP Board (www.cfp.net).

Successful completion of the 10-hour CFP® Certification Exam.

Three-year qualifying full-time work experience.

Successfully pass the Candidate Fitness Standards and backgroundcheck.

Chartered Financial Analyst (CFA): Chartered Financial Analysts arelicensed by the CFA Institute to use the CFA mark. CFA certificationrequirements:

Hold a bachelor's degree from an accredited institution or haveequivalent education or work experience.

Successful completion of all three exam levels of the CFA Program.

Have 48 months of acceptable professional work experience in theinvestment decision-making process.

Fulfill society requirements, which vary by society. Unless you areupgrading from affiliate membership, all societies require two sponsorstatements as part of each application; these are submitted online byyour sponsors.

Agree to adhere to and sign the Member's Agreement, a ProfessionalConduct Statement, and any additional documentation requested byCFA Institute.

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Enrolled Agent (EA): Enrolled Agents are enrolled by the Internal RevenueService and authorized to use the EA designation. EA enrollmentrequirements:

Successful completion of the three-part IRS Special EnrollmentExamination (SEE), or completion of five years of employment by theIRS in a position which regularly interpreted and applied the tax codeand its regulations.

Successfully pass the background check conducted by the IRS.

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MICHAEL LaVOY ChFC CFP®, CERTIFICATIONSEducational Background:

Date of birth: 08/08/1956 Attended The University of Michigan (1978).

Business Experience: Broker with Donaldson, Lufkin and Jeanerette from 1982 to 1987 Financial advisor with Benefits Design, Houston Texas from 1987 to

1992. Financial advisor with Advanced Financial Planning, Inc. Palm

Harbor Florida from 1992 to 2001. President Beacon Asset Management Inc. 2001 to present

Disciplinary Information: NoneOther Business Activities: NoneAdditional Compensation: NoneSupervision:

Michael LaVoy CFP® is supervised by James V Lau, attorney. Hereviews Mr. LaVoy’s work through frequent office interactions as well asremote interactions. He also reviews Mr. LaVoy’s activities through ourclient relationship management system.James V Lau’s contact information:

(813) 269-0732 [email protected] Claims: NoneSelf-Regulatory Organization or Administrative Proceeding: NoneBankruptcy Petition: None

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JOHN JONES, CERTIFICATIONSEducational Background:

Date of birth: 09/23/1960 Attended Brevard College (1986) Attended Kaplan University (2001)

Business Experience:

Disciplinary Information: NoneOther Business Activities: NoneAdditional Compensation: NoneSupervision:

John is supervised by Michael LaVoy, CFP®. He reviews Mr. Jones’work through frequent office interactions as well as remote interactions.He also reviews Mr. Jones’ activities through our client relationshipmanagement system.Michael LaVoys’ contact information:

(813) 269-0732 [email protected] Claims: NoneSelf-Regulatory Organization or Administrative Proceeding: NoneBankruptcy Petition: None

Documents

Form ADV