Trading Guidelines

The below are the trading policies that we generally follow. Please refer to our “First Ascent Trading Disclosure” for more details.

Specific Trade Instructions

Advisors may submit specific trade instructions by using the form found in the Advisor Portal of our website (link below). Trade instructions are never accepted via phone, voicemail, or any other verbal means. We will use reasonable efforts to execute, as directed, trade instructions that are clear and actionable, as determined in the sole discretion of First Ascent. However, we do not have a trading desk and do not specialize in trading securities other than the ETFs and mutual funds that we recommend.

Trade Timing

Subject to the First Ascent Trading Disclosure, we will use best efforts to implement instructions received by 1:00 pm (ET) on the day they are received. Any orders received after 1:00 pm (ET) will be prioritized for the following day. Regardless, we never promise or guarantee that trades will be initiated or settled within a particular time period or at a particular price.

Situations will arise when securities are sold and purchased at different times and even different days. This will result in portions of the portfolio being “out of the market” for periods of time and possibly result in missed market opportunities. While we use best efforts to minimize these situations, First Ascent is not responsible for any losses or opportunities arising from these events.

Non-Exchange Traded Securities

For securities that do not readily trade on an exchange (individual bonds, CDs) we will work to assist in the liquidation of those securities by coordinating through the client’s custodian to obtain bids for the securities and then relaying those bids to the Advisor.

Volatile Markets

We are long-term investors and do not believe it is imperative to execute trades on any specific day. We will generally avoid trading on volatile days, and absent specific instruction to trade on a certain date, may defer placing trades. Even with specific instructions, we only commit to providing best efforts.

Investing of Accounts

First Ascent fully invests all new accounts according to our models. Any requests for exceptions to this policy must be approved by First Ascent prior to submitting a new account application.

First Ascent Trading Disclosure

First Ascent executes all trades on a “best efforts” basis. This means that we will use reasonable efforts to execute trades in a timely and accurate manner. We do not, however, guarantee that trades will be initiated or settled within a particular time period or at a particular price.

We are usually able to fully invest an account within a day or two after it is opened. However, it can, and often will, take significantly longer for a number of reasons, including, but not limited to: normal trading procedures, heavy trade volume, lack of funds in the account, the passage of time needed to settle or process a transaction, disruptions in our ability to communicate with custodians, unintentional clerical errors or Acts of God. Other activities such as liquidating all or part of an account or tax loss harvesting may be conducted over extended time periods.

First Ascent is focused on long-term investing. We make no effort to time the market, nor do we anticipate the direction of either the securities markets or any particular security. Securities markets can be volatile and the values of securities can and do change significantly on a daily basis. Because of our approach to trading and the possible delays that may occur in connection with our trading activities, the markets may move either up or down significantly before trades are initiated or completed.

First Ascent is not a broker-dealer and does not have a trading desk. First Ascent’s primary focus is on building, maintaining and trading our model portfolios and the ETFs and mutual funds that we recommend in those portfolios. We do not have expertise in trading stocks, bonds, or other securities. When First Ascent is provided instructions to sell a security, we will use “best efforts” to sell those securities through the custodian where the account is maintained.

First Ascent assumes no responsibility for losses, expenses, damages or lost opportunities in connection with any trade (regardless of who initiated the trade) except in cases of negligence on our part.

First Ascent assumes no responsibility for, and accepts no liability in connection with, instructions regarding the opening, closing, trading or management of an account, which, in First Ascent’s sole discretion, are inaccurate, unclear, ambiguous, incomplete or based on incorrect assumptions or incomplete information.

First Ascent only accepts written instructions regarding the opening, closing, trading or management of an account and shall have no responsibility for any losses, expenses, damages or lost opportunities based on its failure to comply with verbal or telephonic instructions in the event that they are given.