Legal Documents

Part 2A of Form ADV: Firm Brochure

75 East Santa Clara St, 7th Floor
San Jose, CA 95113
Tel: (408) 933-6188

June 30, 2023

This Brochure provides information about the qualifications and business practices of BrightPlan LLC ("BrightPlan"). If you have any questions about the contents of this Brochure, please contact us at info@brightplan.com or by telephone at (408) 933-6188. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority, and references in this Brochure to BrightPlan as a "registered investment adviser" are not intended to imply a certain level of skill or training.

Additional information about BrightPlan is also available on the SEC’s website at www.adviserinfo.sec.gov.

ITEM 2 - MATERIAL CHANGES

The following material changes have been made since our last annual amendment dated March 31, 2022:

• Item 4 has been updated to reflect that no one individual or entity owns more than 25% of BrightPlan Group, Inc, the parent company of BrightPlan, LLC.

This brochure has been updated throughout to reflect that BrightPlan no longer offers discretionary investment management services. All investment advice is provided on a non-discretionary basis and must be implemented by the client.

ITEM 3 - TABLE OF CONTENTS

Item 2 – Material Changes
Item 3 - Table of Contents
Item 4 - Advisory Business
Item 5 - Fees and Compensation
Item 6 - Performance-based Fees and Side-by-Side Management
Item 7 - Types of Clients
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 - Disciplinary Information
Item 10 - Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 – Brokerage Practices
Item 13 – Review of Accounts
Item 14 – Client Referrals and Other Compensation
Item 15 - Custody
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information

ITEM 4 – ADVISORY BUSINESS

A. General Description of Advisory Firm

BrightPlan LLC ("BrightPlan") offers a comprehensive employee financial wellness service ("Financial Wellness") that includes education, goals-based planning, investment advice, and comprehensive personal financial management that helps employees achieve financial success. BrightPlan is the first financial wellness solution certified for fiduciary excellence that is personalized, actionable and integrated with employer benefits. BrightPlan is led by a team of experienced Silicon Valley executives and technology innovators with extensive software and industry expertise. BrightPlan combines transformational digital capabilities with access to financial advisors to make wealth management accessible to everyone, regardless of net worth. BrightPlan is a Delaware limited liability company formed in 2015 and is a wholly owned subsidiary of BrightPlan Group, Inc. ("BPG"). No individual or entity owns more than 25% of BPG.

BrightPlan is focused on the Employee Financial Wellness market. Employers are recognizing that employee financial stress is impacting employee well-being and their bottom line. Stressed employees are less productive, miss more work, are less engaged and more likely to leave their jobs. Many employers are looking to Financial Wellness programs that provide education and tools to help employees adopt positive financial behaviors to manage their finances, achieve their long-term financial goals and help protect against key financial risks. BrightPlan works with employers who provide it as a benefit for their employees. Additionally, Employees may choose to invest through BrightPlan and pay an additional fee based on assets under management.

BrightPlan is certified by the Centre for Fiduciary Excellence, LLC ("CEFEX") as having met their standards for Fiduciary Practices for Investment Advisors. The issuance of a Certificate of Registration and mark by CEFEX following the conclusion of the assessment process signifies that the investment advisor is generally meeting the Fiduciary Standard for the matters and for the time period covered by the certificate, subject to the limitations on scope expressed on the certificate. This certification is valid for twelve months. BrightPlan was first certified in 2017 and has been recertified every year since.

B. Summary of Services Offered

BrightPlan’s mission is to make financial success attainable for everyone. When you build a plan tailored to your unique aspirations and dreams, you can make better financial decisions. And better financial decisions can improve your probability of long-term success.

BrightPlan works with employers who wish to offer the BrightPlan service as a Financial Wellness benefit to their US employees.

BrightPlan uses patented, proprietary technology to provide financial education, planning, investment, and day to day money management services through its website at www.brightplan.com and through its mobile application.

BrightPlan’s service provides clients:

The digital BrightPlan Financial Wellness Coach™ to guide clients to build their financial plan
An overview of their personal finances including net worth, spending analysis, budgeting, debt reduction and cash flow tracking
Asset allocation recommendations based on their unique goals and risk tolerance
Ongoing monitoring of the plan to help clients stay on track
Equity Compensation Planner to assist in the tracking of grants and vesting of equity compensation
Education on financial topics, including managing personal finances, money and investing
Access to a human financial advisor

When clients prepare financial plans using the BrightPlan automated tools, each goal receives its own investment asset allocation recommendation. Clients may opt to personally apply BrightPlan’s recommendations on their own external accounts, see below BrightPlan’s non-discretionary services.

In addition to the website and mobile application, clients have access to a team of BrightPlan representatives via video conference and/or telephone. BrightPlan representatives can help clients evaluate their financial goals and objectives, and provide general assistance with products and services provided by BrightPlan. They help clients evaluate their ability to meet their identified goal(s); however, they are not obligated to provide ongoing financial planning advice, update any analysis provided, or monitor Client progress toward a goal.

Non Discretionary Services

Clients can use BrightPlan’s planning tools to discover their goals and receive a plan to reach them. By linking external savings, investment, employer-sponsored retirement plans, and other financial accounts, clients can track their progress toward their goals over time. After linking accounts, clients can also gain insights into their financial situation, including budgeting, the ability to monitor their net worth, cash flow, transactions, and investment strategy across their linked accounts.

Each goal also includes a BrightPlan recommended asset allocation which clients can implement independently through their account custodian or plan sponsor. For goals linked to an employersponsored plan, if an employer opts into the service, BrightPlan is able to provide security specific recommendations. BrightPlan will analyze the investments available in the plan and recommend which securities to use to implement the asset allocation. The client is then responsible for working with their plan sponsor to implement the recommendation.

Clients may adjust their goals and risk tolerance on the website at any time.

Responsibility of Clients

BrightPlan relies on client information to provide the services. Clients have the responsibility to review and update their profile information and to maintain current and accurate contact information. Recommendations will continue to be based on the client's profile information and it is the client's responsibility to advise BrightPlan through the BrightPlan Website or through a representative if there are any changes. It's important for clients to understand that their profile information, which is used to determine an appropriate asset allocation strategy, will not automatically update as a result of any changes client’s model on their own in any financial planning tool that is made available online.

Advisory Services to Retirement Investors

When BrightPlan provides investment advice to clients regarding their retirement plan account or individual retirement account, they are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way BrightPlan makes money creates some conflicts with client interests, so BrightPlan operates under a special rule that requires them to act in the clients best interest and not put their interest ahead of yours.

Under this special rule’s provisions, BrightPlan must:

Meet a professional standard of care when making investment recommendations (give prudent advice);
Never put their financial interests ahead of client’s when making recommendations (give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in the client’s best interest;
Charge no more than is reasonable for our services; and
Give client’s basic information about conflicts of interest.

Third Party Service Provider Recommendations

BrightPlan may also recommend the services of third party investment and non-investment service providers. Clients are under no obligation to engage the services of any such recommended third party service provider and are free to accept or reject any recommendation from BrightPlan. To the extent that a client engages a recommended service provider, such relationships will be directly between the client and such service provider and will be governed by any applicable terms and conditions associated with the engagement.

C. Tailoring of Advisory Services and Client Imposed Restrictions

Investment and financial planning advice are provided by BrightPlan’s proprietary software and algorithms, which were developed in collaboration with Plancorp, LLC ("Plancorp"), and are overseen and monitored by BrightPlan’s Investment Committee. Plancorp is an SEC registered investment advisor and strategic partner of BrightPlan. Please see Items 10 for more details.

When a client signs up for BrightPlan’s services through www.brightplan.com, the client will be required to input information about his or her finances, life, financial goals, and tolerance for risk. BrightPlan’s proprietary software and algorithms use this information to generate investment and financial planning advice, including portfolio recommendations. Each portfolio asset allocation strategy is one in a series of asset allocations that range from conservative (lower risk and return potential) to aggressive (higher risk and return potential).

BrightPlan’s software and algorithms select one of several asset allocations that BrightPlan believes is most likely to help the client achieve the client’s goals, based on the information provided by the client. BrightPlan’s Investment Committee oversees this process and has approved each potential asset allocation. Please see Item 8 for additional information about the asset allocation process.

BrightPlan’s services are not for investors looking to actively manage and trade within their own accounts.

Clients are strongly encouraged to consider their individual circumstances, risk tolerance and needs prior to following any BrightPlan generated recommendation.

D. Assets Under Management

As of April 1, 2023, BrightPlan had no regulatory assets under management.

ITEM 5 – FEES AND COMPENSATION

A. Fees and Compensation

Subscription Fee: BrightPlan works with employers to offer Financial Wellness programs, under which employers pay some or all of a negotiated fee on behalf of their employees ("Subscription Fee"). In the event an employee leaves the employer they may opt to remain a client of BrightPlan and pay the Subscription Fee which is no more than $20 each month.

BrightPlan reserves the right to reduce, waive, or suspend any fee or any part thereof for any period for any client at its sole discretion.

Clients should review Item 5.C. below, which describes other fees, not charged by BrightPlan, that clients should expect to incur from third parties.

B. Fee Calculation and Deduction

As discussed above, monthly fees are generally paid by a client’s employer. In the event the client is no longer eligible for their employer to pay the monthly fee they may opt to pay the fee directly. In that case monthly fees are payable in advance and charged to the client’s credit card. Clients should read the Fees section of the Investment Advisory Agreement for additional information.

C. Other Fees and Expenses

BrightPlan’s Subscription Fee does not include any custodial or brokerage expenses that a client’s custodian or broker may charge.

Clients will typically pay transaction and/or custodial expenses in connection with independently implementing any of BrightPlan’s asset allocation recommendations, in addition to the Subscription Fee paid to BrightPlan. These transactions and/or custodial expenses vary and are based on the client’s agreement with their account custodian and/or broker-dealer.

ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT

BrightPlan does not charge performance-based fees.

ITEM 7 – TYPES OF CLIENTS

BrightPlan serves employers who are seeking to provide high-quality advisory services available to employees who might not otherwise have access. Clients are not required to have a certain amount of investment experience or sophistication. Any client may create goals, receive a recommended asset allocation, and track progress toward goals with BrightPlan on a non-discretionary basis with no account minimums.

ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS

A. Methods of Analysis and Investment Strategies

As described in Item 4 BrightPlan provides clients with automated financial planning and asset allocation recommendations via its website. BrightPlan’s proprietary software uses the information input by the client through BrightPlan’s website to recommend a particular asset allocation for each of the client’s goals.

Clients are strongly encouraged to conduct their own analysis and to consider their own individual circumstances, risk tolerance and needs prior to following any BrightPlan recommendation, including before investing in accordance with any recommended asset allocation. The fact that a particular allocation of assets is recommended by BrightPlan cannot be interpreted as a guarantee of future performance. Investing in securities involves risk of loss that clients should be prepared to bear.

Clients are strongly encouraged to conduct their own analysis and to consider their own individual circumstances, risk tolerance and needs prior to following any BrightPlan recommendation, including before investing in accordance with any recommended model portfolio. The fact that a model portfolio is recommended by BrightPlan cannot be interpreted as a guarantee of future performance. Investing in securities involves risk of loss that clients should be prepared to bear.

Asset Allocation Models:

The investment philosophy underlying each model portfolio is grounded in Modern Portfolio Theory, which refers to the process of attempting to maximize return for any level of risk in a portfolio. This risk-reward optimization is accomplished through diversification across asset classes and within asset classes for both equities and fixed-income.

BrightPlan uses its goals-based investment strategy software to recommend the investment asset allocation that BrightPlan believes is best suited for each client and that client’s goals. In making these recommendations, BrightPlan’s automated software considers the information that the client has provided through BrightPlan’s website about the client’s goal time horizon, withdrawal timeframe, and risk tolerance.

Information about each recommended asset allocation is available to clients within the BrightPlan application.

B. Risk Factors

Investing in securities, including mutual funds and ETFs, involves risk of loss that clients should be prepared to bear. Client account returns will fluctuate, and you may lose money by investing in securities.

Below are some more specific risks of investing:

Market Risk. Clients should have a long-term perspective and be able to tolerate potentially sharp declines in market value. The prices of securities held by funds in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by the funds; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations.

Management Risk. Plancorp’s investment approach may fail to produce the intended results. If Plancorp’s perception of the performance of a specific asset class or fund is not realized in the expected time frame, the overall performance of clients’ portfolios may suffer. Diversification does not assure or guarantee better performance and cannot eliminate the risk of investment losses.

Investment Company Risk. Plancorp recommends and typically invests client assets in open-end mutual funds and ETFs (collectively, "funds"). Investments in funds are subject to all of the risks of the underlying securities in which those funds invest (including those described below). In addition, the value of a client’s investment in a fund will depend largely on the skill of the fund’s adviser. They have no control over the investment strategies, policies or decisions of the funds they recommend and, in the event of dissatisfaction with such a fund, their only option would be to liquidate clients’ investments in that fund. Client accounts invested in a fund will indirectly bear the fees and expenses payable directly by the fund, including management fees and operational expenses. Fund returns may be volatile, and clients can lose money by investing in funds. ETFs are subject to certain additional risks, including the risk that the market price of the shares of the ETF may trade at prices above or below its net asset value.

Equity Risk. Equity securities tend to be more volatile than other investment choices. The value of a company’s stock generally increases or decreases in value based on factors directly relating to that company, such as demand for the company’s products or decisions by management. The value of a company’s stock is also affected by other factors not directly affecting the company, such as general industry and market conditions. The value of a company’s stock can be more volatile than the market as a whole. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. Investing in individual companies involves inherent risk.

Fixed Income Risk. The issuer of a fixed income security may be unable or unwilling to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If this occurs, or is perceived as likely to occur, the value of the fixed income security may fall significantly. In addition, if a rating agency gives a fixed income security a lower rating, the value of the security may decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. This risk is especially high given the historically low interest rate environment in the United States. A nominal interest rate is the sum of a real interest rate and an expected inflation rate.

REIT Risk. REITs are subject to risks generally associated with investing in real estate, such as (i) possible declines in the value of real estate, (ii) adverse general and local economic conditions, (iii) possible lack of availability of mortgage funds, (iv) changes in interest rates, and (v) environmental problems. In addition, REITs are subject to certain other risks related specifically to their structure and focus such as: dependency upon management skills; limited diversification; the risks of locating and managing financing for projects; heavy cash flow dependency; possible default by borrowers; the costs and potential losses of self-liquidation of one or more holdings; the possibility of failing to maintain exemptions from securities registration; and, in many cases, relatively small market capitalization, which may result in less market liquidity and greater price volatility.

Foreign Securities Risk. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have traditionally been more volatile than the markets of developed countries with more mature economies.

Municipal Securities Risk. Municipal securities carry certain different risks than those of corporate government- and bank-sponsored debt securities. These risks include the municipality’s ability to raise additional tax revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to retire its debt at maturity. Municipal bonds are generally tax-free at the federal level, but may be taxable in individual states other than the state in which both the investor and municipal issuer are domiciled.

U.S. Government Securities Risk. Securities of U.S. government sponsored entities, such as Freddie Mac or Fannie Mae, are neither issued nor guaranteed by the U.S. government. It is possible that the U.S. government would not provide financial support to its agencies or instrumentalities if it is not required to do so by law. If a U.S. government agency or instrumentality in which an underlying fund invests defaults and the U.S. government does not stand behind the obligation, the value and yield of the security would be expected to fall.

Technology Risk. BrightPlan uses its proprietary software system to analyze the information provided by a client and to make recommendations to the client based on the software’s analysis of that information. Technology and software malfunctions, programming inaccuracies, inadvertent system and human errors, and similar circumstances could impair the performance of BrightPlan’s systems, which may negatively impact the quality and applicability of BrightPlan’s recommendations to clients.

Cybersecurity Risk. BrightPlan depends on its computer and technological systems to provide investment recommendations, reporting, and other services to clients. These systems are vulnerable to information security, operational, and related risks resulting from third-party cyberattacks and/or other technological malfunctions. Cyber-attacks may involve hackers and other unauthorized individuals gaining access to or misappropriating client information, stealing or corrupting data, releasing confidential information (including confidential client information) without authorization, preventing legitimate users from accessing their information or services through BrightPlan’s website, or causing other operational disruptions. Successful cyber-attacks against or technological breakdowns of BrightPlan or another service provider may adversely affect clients. For example, cyber-attacks may cause the unauthorized release of client confidential information, and may prevent clients from accessing information about their goals. While BrightPlan has security systems and business continuity plans intended to prevent or reduce the impact of such cyber-attacks and technological malfunctions, these systems and plans are subject to inherent limitations and may not be successful in preventing or reducing the impact of cyberattacks or technological malfunctions.

ITEM 9 – DISCIPLINARY INFORMATION

No material items to report.

ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS

BrightPlan has formed a strategic relationship with Plancorp, LLC, an unaffiliated SEC registered investment advisor. As part of this relationship, BrightPlan and Plancorp share a Chief Investment Officer and additional Plancorp employees are members of the BrightPlan Investment Committee. BrightPlan’s Chief Executive Officer is also a member of the Plancorp Board of Managers. Plancorp’s Chief Executive Office is a member of the BPG Board. For more information about Plancorp, please review Plancorp’s separate Form ADV, Part 2A Brochure, available at Plancorp ADV.

BrightPlan will from time to time recommend unaffiliated third-party investment advisers including Plancorp, to clients who may benefit from more tailored investment management services. Some of these advisers will pay a fee to BrightPlan for each new client referred by BrightPlan. The payment of these fees represents a conflict of interest because BrightPlan has an incentive to refer clients to these advisers and not to a different adviser who pays no fees to BrightPlan. BrightPlan addresses this conflict by disclosing it in this Brochure and at the time of any referral.

BrightPlan provides clients with the opportunity to discuss financial planning and investing matters directly with a representative. This may be a BrightPlan team member, or a representative from an unaffiliated third-party investment adviser which has been engaged to perform these services for BrightPlan. BrightPlan will pay a fee to these advisers for consultations provided by their representatives. This consultation will not affect the overall fees each client pays to BrightPlan.

ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING

BrightPlan has adopted a Code of Ethics (the "Code"), which is designed to meet the requirements of Rule 204A-1 of the Investment Advisers Act of 1940 (the "Advisers Act"). The Code takes into account BrightPlan’s status as a fiduciary and requires all BrightPlan employees to, among other things:

place the interests of clients above their own interests;
comply with applicable federal securities laws; and
promptly report violations of the Code to BrightPlan’s Chief Compliance Officer.

BrightPlan’s employees may from time to time buy or sell securities for their personal accounts that are also recommended to, held by, or bought or sold on behalf of BrightPlan’s clients. Potential conflicts of interest may arise in these situations to the extent that BrightPlan’s employees are able to use their knowledge about pending or currently considered securities transactions for clients to profit personally. However, because BrightPlan invests client assets primarily in mutual funds, which price themselves daily at net asset value, or ETFs which are highly liquid, BrightPlan believes that it is unlikely that an employee could benefit from his or her knowledge of client transactions. Regardless, to address potential conflicts, and as required by Rule 204A-1 of the Advisers Act, BrightPlan’s Access Persons, must provide BrightPlan’s Chief Compliance Officer with a list of their personal accounts and an initial holdings report within 10 days of hire. BrightPlan also requires its Access Persons to report their securities transactions on a quarterly basis thereafter and disclose their securities holdings on an annual basis.

The Code also includes insider trading policies and procedures designed to prevent the improper use of material, non-public information. BrightPlan and its personnel are prohibited from trading for their personal account, or recommending trading in, any securities while in possession of material, non-public information about such securities or their issuer, and from disclosing such information to any person not entitled to receive it.

BrightPlan, its employees or Plancorp may at times give advice and take action in the performance of their duties for some clients or their own accounts that may differ from the advice given, or the timing or nature of actions taken, for other clients or for their proprietary or personal accounts.

Clients or prospective clients may obtain a copy of BrightPlan’s Code by contacting the Chief Compliance Officer at legal@brightplan.com.

ITEM 12 – BROKERAGE PRACTICES

BrightPlan does not recommend or select brokers or account custodians. Clients are solely responsible for choosing which broker-dealer or account custodian will execute trades and hold their funds and securities.

ITEM 13 – REVIEW OF ACCOUNTS

Through BrightPlan’s website, clients can login to view real-time reporting information about their goal progress, account status, securities positions and balances, key statistics, and other information.

BrightPlan periodically contacts clients to remind them to review and update the profile information they previously provided through BrightPlan’s website. Because BrightPlan’s advice and recommendations, including the recommended asset allocations are based on the financial and other information submitted by the client through BrightPlan’s website, it is important for clients to update this information whenever it changes. A client’s failure to timely update the information provided to BrightPlan could materially impact the quality and applicability of BrightPlan’s advice and recommendations.

Additionally, BrightPlan periodically runs automated regression testing and performs manual reviews of client accounts.

ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION

As discussed in Item 10, BrightPlan will from time to time recommend Plancorp to clients with accounts above a certain asset level who may benefit from Plancorp’s more tailored investment management services. Plancorp will pay a fee to BrightPlan for each new client referred by BrightPlan. Please see Item 10 for information about the conflicts of interest this creates and how BrightPlan seeks to address these conflicts.

BrightPlan also has agreements with certain unaffiliated third parties to provide referrals to employers who may wish to offer BrightPlan’s Financial Wellness service to their employees. BrightPlan compensates these unaffiliated third parties based on the number of employees who establish a relationship with BrightPlan as a result of the referral of their employer to BrightPlan.

ITEM 15 – CUSTODY

BrightPlan does not have custody of client funds or securities pursuant to Rule 206(4)-2 of the Advisers Act.

ITEM 16 – INVESTMENT DISCRETION

BrightPlan does not have investment discretion or trading authority over any client account. Clients are solely responsible for implementing any investment advice provided by BrightPlan directly with their account custodian, broker-dealer or 401(k) sponsor.

ITEM 17 – VOTING CLIENT SECURITIES

BrightPlan has no authority to and will not vote proxies, consent to corporate actions, or exercise similar rights with respect to securities held in client accounts. BrightPlan similarly has no authority to and will not take any action or provide any advice with respect to legal actions, including but not limited to class action lawsuits, involving securities held in client accounts. Rather, clients retain this authority with respect to securities held in their accounts.

ITEM 18 – FINANCIAL INFORMATION

BrightPlan is not currently aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to its clients.

Part 2B of Form ADV: Brochure Supplement

75 East Santa Clara St, 7th Floor
San Jose, CA 95113
Tel: (408) 933-6188

March 31, 2023

This brochure supplement provides information about our investment professionals that supplements the BrightPlan LLC ("BrightPlan") brochure.

You should have received a copy of that brochure. Please contact Naomi Kantrowitz, Chief Compliance Officer, at (408) 933-6188, if you did not receive BrightPlan, LLC’s brochure or if you have any questions about the contents of this supplement.

Investment professionals included in this brochure supplement:

Peter Lazaroff
James Mitchell
Daniel Lee
Joan Gonzalez
Chantal Hersey
Daniel Stokes

Additional information about BrightPlan and our investment professionals is also available on the SEC’s website at www.adviserinfo.sec.gov.

Peter Lazaroff, CFA, CFP®
BrightPlan, LLC
75 East Santa Clara St, 5th Floor
San Jose, CA 95113
Tel: (408) 933-6188
Dated: March 31, 2023

This brochure supplement provides information about Peter Lazaroff that supplements the BrightPlan, LLC brochure. You should have received a copy of that brochure. Please contact Naomi Kantrowitz, Chief Compliance Officer, at (408) 933-6188, if you did not receive BrightPlan, LLC’s brochure or if you have any questions about the contents of this supplement.

Additional information about Mr. Lazaroff is available on the SEC’s website at www.adviserinfo.sec.gov.

ITEM 2 – Educational Background and Business Experience

Peter Lazaroff, CFA, CFP®
Chief Investment Officer, 08/2020 – Present
Member of BrighPlan Investment Committee
Year of Birth: 1984

EDUCATION

B.A. Economics & Management, DePauw University, 2007

DESIGNATIONS

Chartered Financial Analyst (CFA) Charterholder, 2012
CERTIFIED FINANCIAL PLANNER™, planning practitioner

CFA - The Chartered Financial Analyst ("CFA") designation is issued by the CFA Institute. CFA candidates must meet one of the following requirements: (1) undergraduate degree and four years of professional experience involving investment decision-making, or (2) four years qualified work experience (full time, but not necessarily investment related) to receive the CFA designation, candidates must complete the CFA Program which is organized into three levels, each requiring 250 hours of self-study and each culminating in a six-hour exam. Candidates must enter into a Member’s Agreement, a Professional Conduct Statement, and any additional documentation requested by CFA Institute. There are no ongoing continuing education or experience thresholds necessary to maintain the CFA designation. CFA® and Chartered Financial Analyst® are registered trademarks owned by the CFA Institute. More information about the designation is available at https://www.cfainstitute.org.

CFP - The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks (collectively, the "CFP® marks") are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. ("CFP Board"). To attain the right to use the CFP® marks, an individual must satisfactorily fulfill various requirements including completing education requirements; passing the CFP® Certification Examination; completing at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and agreeing to be bound by CFP Board’s Standards of Professional Conduct. In addition, ongoing education and ethics requirements must be met in order to maintain the right to continue to use the CFP® marks.

PAST BUSINESS EXPERIENCE

BrightPlan LLC, Los Gatos, CA:
Chief Investment Officer, 08/2020 - Present
Co-Chief Investment Officer, 04/2017 – 08/2020

Plancorp, LLC, St. Louis, MO:
Chief Investment Officer, 08/2020 - Present
Co-Chief Investment Officer, 04/2017 – 08/2020
Wealth Manager, 03/2015 – 04/2017
Director of Investment Research, 05/2015 – 03/2017

Acropolis Investment Management, St. Louis, MO:
Portfolio Manager, 2007 – 2015

ITEM 3 – Disciplinary Information

None

ITEM 4 – Other Business Activities

None

ITEM 5 – Additional Compensation

None

ITEM 6 – Supervision

The Investment Committee oversees the firm’s investment activities. Mr. Mitchell is supervised by Larry Robinson, who is the Chief Product Officer. Mr. Mitchell is subject to BrightPlan’s code of ethics and the firm’s policies and procedures. Please contact Mr. Robinson at (408) 933-6188 if you have any questions about this brochure supplement.

James Michael Mitchell, CFP®
BrightPlan, LLC
75 East Santa Clara St, 5th Floor
San Jose, CA 95113
Tel: (408) 933-6188
Dated: March 31, 2023

This brochure supplement provides information about James Michael Mitchell that supplements the BrightPlan, LLC brochure. You should have received a copy of that brochure. Please contact Naomi Kantrowitz, Chief Compliance Officer, at (408) 933-6188, if you did not receive BrightPlan, LLC’s brochure or if you have any questions about the contents of this supplement.

Additional information about Mr. Mitchell is available on the SEC’s website at www.adviserinfo.sec.gov.

ITEM 2 – Educational Background and Business Experience

James Michael Mitchell, CFP®
Vice President of Client Success, 07/2021 – Present
Year of Birth: 1971

EDUCATION

Master of Business Administration, Southern New Hampshire University, 1994
Bachelor of Science, Marketing, Plymouth State University, 2003

DESIGNATIONS

CERTIFIED FINANCIAL PLANNER™

PAST BUSINESS EXPERIENCE

Fidelity Personal and Workplace Advisors, Boston, MA:
Mass Transfer, 07/2018 – 06/2021

Fidelity Brokerage Services, Inc., Merrimack, NH:
VP Squad Lead/Product Owner Financial Wellness, 2020 – 2021
Vice President /Agile Transformation Retail Phone Centers, 2015 –2018
Director/VP, Transformation/Portfolio Advisory Services, 2012 – 2015
Regional Manager/Portfolio Advisory Services, 2004 – 2012
Brokerage and Investment Manager , 1998 - 2004

Oxford Health Plans, Nashua, NH:
Customer Service Loans Supervisor, 06/1994 – 11/1998

ITEM 3 – Disciplinary Information

None

ITEM 4 – Other Business Activities

None

ITEM 5 – Additional Compensation

None

ITEM 6 – Supervision

Daniel S Lee, CFA, CFP®
BrightPlan, LLC
75 East Santa Clara St, 5th Floor
San Jose, CA 95113
Tel: (408) 933-6188
Dated: March 31, 2023

This brochure supplement provides information about Daniel S Lee that supplements the BrightPlan, LLC brochure. You should have received a copy of that brochure. Please contact Naomi Kantrowitz, Chief Compliance Officer, at (408) 933-6188, if you did not receive BrightPlan, LLC’s brochure or if you have any questions about the contents of this supplement.

Additional information about Mr. Lee is available on the SEC’s website at www.adviserinfo.sec.gov.

ITEM 2 – Educational Background and Business Experience

Daniel S Lee, CFA, CFP®, EA
Director, Financial Planning and Advice, 08/2021 - Present
Year of Birth: 1983

EDUCATION

University of Michigan, B.S., Economics, Biopsychology/Neuroscience, 2005
UC Berkeley Extension, Certificate in Personal Financial Planning, 2009
Enrolled Agent (EA) – IRS

DESIGNATIONS

Chartered Financial Analyst (CFA) Charterholder
CERTIFIED FINANCIAL PLANNER™, planning practitioner

EA - An Enrolled Agent (EA) is an individual who represents taxpayers before the Internal Revenue Service. Enrolled agents, like attorneys and CPAs, are generally unrestricted as to which taxpayer they can represent, which types of tax matters they can handle, and which IRS offices they can represent clients before. To become an EA an individual must: 1) obtain a Preparer Tax Identification Number (PTIN); 2) achieve passing scores on all parts of the Special Enrollment Examination (SEE) within three years; 3) apply for enrollment; 4) and pass a suitability check, which will include tax compliance, to ensure applicants have filed all necessary tax returns and there are no outstanding tax liabilities, and a criminal background check. In addition, an EAs must adhere to ethical standards, renew their status every three years, obtain continuing education and renew their PTIN annually.

PAST BUSINESS EXPERIENCE

Plancorp, LLC, St. Louis, MO:
Senior Wealth Manager, 7/2019 – 8/2021
Wealth Manager, 1/2019 – 06/2019

Bingham, Osborn & Scarborough LLC, San Francisco, CA:
Wealth Manager, 01/2015 – 01/2019
Portfolio Associate, 01/2013 – 12/2014
Portfolio Administrator, 02/2009 – 12/2012
Portfolio Assistant, 04/2008 – 02/2009

ITEM 3 – Disciplinary Information

None

ITEM 4 – Other Business Activities

Employed by the University of California - Berkeley. Instructor at The UC Berkeley – Extension Certificate Program in Personal Financial Planning. Started: 01/2018 - Present

ITEM 5 – Additional Compensation

None

ITEM 6 – Supervision

The Investment Committee oversees the firm’s investment activities. Mr. Lee is supervised by James Mitchell, who is the Vice President of Client Services. Mr. Lee is subject to BrightPlan’s code of ethics and the firm’s policies and procedures. Please contact Mr. Mitchell at (408) 933-6188 if you have any questions about this brochure supplement.

Joan Gonzalez, CFP®
BrightPlan, LLC
75 East Santa Clara St, 5th Floor
San Jose, CA 95113
Tel: (408) 933-6188
Dated: March 31, 2023

This brochure supplement provides information about Joan Gonzalez that supplements the BrightPlan, LLC brochure. You should have received a copy of that brochure. Please contact Naomi Kantrowitz, Chief Compliance Officer, at (408) 933-6188, if you did not receive BrightPlan, LLC’s brochure or if you have any questions about the contents of this supplement.

Additional information about Ms. Gonzalez is available on the SEC’s website at www.adviserinfo.sec.gov.

ITEM 2 – Educational Background and Business Experience

Joan Gonzalez, CFP®
Financial Advisor, 06/2021 – Present
Year of Birth: 1963

EDUCATION

Bachelor of Science, Marketing Management, Boston University, 1989

DESIGNATIONS

CERTIFIED FINANCIAL PLANNER™, CFP®

PAST BUSINESS EXPERIENCE

Advice Systems, Inc., Westborough, MA:
Financial Planning Research Analyst, 04/2019 – 01/2020

Winslow, Evans & Crocker, Inc., Boston, MA:
First Vice President, CFP®, 01/2014 – 04/2019

The Midas Collaborative, Allston, MA:
Financial Wellness Coach, 06/2013 – 12/2018

Financial Planning Association of MA, Westborough, MA:
Director of Partnerships, Board Member, 01/2010 – 12/2013

ITEM 3 – Disciplinary Information

None

ITEM 4 – Other Business Activities

None

ITEM 5 – Additional Compensation

None

ITEM 6 – Supervision

The Investment Committee oversees the firm’s investment activities. Ms. Gonzalez is supervised by James Mitchell, who is the Vice President of Client Services. Ms. Gonzalez is subject to BrightPlan’s code of ethics and the firm’s policies and procedures. Please contact Mr. Mitchell at (408) 933-6188 if you have any questions about this brochure supplement.

Chantal Hersey, CFP®
BrightPlan, LLC
75 East Santa Clara St, 5th Floor
San Jose, CA 95113
Tel: (408) 933-6188
Dated: March 31, 2023

This brochure supplement provides information about Chantal Hersey that supplements the BrightPlan, LLC brochure. You should have received a copy of that brochure. Please contact Naomi Kantrowitz, Chief Compliance Officer, at (408) 933-6188, if you did not receive BrightPlan, LLC’s brochure or if you have any questions about the contents of this supplement.

Additional information about Ms. Hersey is available on the SEC’s website at www.adviserinfo.sec.gov.

ITEM 2 – Educational Background and Business Experience

Chantal Hersey, CFP®
Financial Wellness Advisor, 01/2023 – Present
Year of Birth: 1991

EDUCATION

B.S., Business Administration, University of San Francisco, San Francisco, 2013

DESIGNATIONS

CERTIFIED FINANCIAL PLANNER™, CFP®

PAST BUSINESS EXPERIENCE

Tremorsync, Inc., San Francisco, CA:
Ice Skating Coach, 07/2013 – present

The Financial Zen Group, Inc., San Francisco, CA:
Financial Planner, 05/2020 – 01/2023

Bingham, Osborn & Scarborough LLC, San Francisco, CA:
Senior Client Associate, 07/2014 – 09/2019
Portfolio Assistant, 09/2013 – 07/2014

ITEM 3 – Disciplinary Information

None

ITEM 4 – Other Business Activities

None

ITEM 5 – Additional Compensation

None

ITEM 6 – Supervision

The Investment Committee oversees the firm’s investment activities. Ms. Hersey is supervised by James Mitchell, who is the Vice President of Client Services. Ms. Hersey is subject to BrightPlan’s code of ethics and the firm’s policies and procedures. Please contact Mr. Mitchell at (408) 933-6188 if you have any questions about this brochure supplement.

Daniel Lee Stokes, CFP®
BrightPlan, LLC
75 East Santa Clara St, 5th Floor
San Jose, CA 95113
Tel: (408) 933-6188
Dated: March 31, 2023

This brochure supplement provides information about Daniel Lee Stokes that supplements the BrightPlan, LLC brochure. You should have received a copy of that brochure. Please contact Naomi Kantrowitz, Chief Compliance Officer, at (408) 933-6188, if you did not receive BrightPlan, LLC’s brochure or if you have any questions about the contents of this supplement.

Additional information about Mr. Stokes is available on the SEC’s website at www.adviserinfo.sec.gov.

ITEM 2 – Educational Background and Business Experience

Daniel Lee Stokes, CFP®
Financial Advisor, 09/2022 – Present
Year of Birth: 1988

EDUCATION

Bachelor of Human Environment Sciences, Personal Financial Planning, University of Missouri-Columbia, 2016

DESIGNATIONS

CERTIFIED FINANCIAL PLANNER™, CFP®

PAST BUSINESS EXPERIENCE

BrightPlan, LLC, San Jose, CA:
Client Success Advocate, 05/20219 – 08/2022

Plancorp, LLC, St. Louis, MO:
Financial Planning Associate, 06/2016 – 05/2019

University of Missouri, Office for Financial Success, Columbia, MO:
Student President, 08/2015 – 05/2016

Veterans United Home Loans, Columbia, MO:
Lighthouse Intern, 05/2015 – 08/2015

Commerce Bank, Columbia, MO:
Utility Bank Teller, 01/2014 – 04/2015

ITEM 3 – Disciplinary Information

None

ITEM 4 – Other Business Activities

None

ITEM 5 – Additional Compensation

None

ITEM 6 – Supervision

The Investment Committee oversees the firm’s investment activities. Mr. Stokes is supervised by James Mitchell, who is the Vice President of Client Services. Mr. Stokes is subject to BrightPlan’s code of ethics and the firm’s policies and procedures. Please contact Mr. Mitchell at (408) 933-6188 if you have any questions about this brochure supplement.